Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 1 of 32 1 2 3 4 5 6 7 8 JOSEPH H. HUNT Assistant Attorney General ALEX G. TSE (CABN 152348) United States Attorney SARA WINSLOW (DC Bar No. 457643) Chief, Civil Division MICHAEL T. PYLE (CABN 172954) Assistant United States Attorney 150 Almaden Boulevard, Suite 900 San Jose, California 95113 Telephone: (408) 535-5087 FAX: (408) 535-5081 Email: michael.t.pyle@usdoj.gov 9 10 11 12 13 14 15 MICHAEL GRANSTON MICHAL TINGLE ROBERT CHANDLER Attorneys, Civil Division United States Department of Justice P.O. Box 261, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 514-4678 robert.chandler@usdoj.gov Attorneys for the United States of America UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 19 20 UNITED STATES OF AMERICA, ex rel. JAHR, et al., Plaintiffs, 21 v. 22 23 TETRA TECH EC, INC., et al., Defendants. 24 ) ) ) ) ) ) ) ) ) ) ) Case No. C 13-3835 JD UNITED STATES’ COMPLAINT IN INTERVENTION AGAINST TETRA TECH EC, INC. DEMAND FOR JURY TRIAL 25 26 // 27 // 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 1 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 2 of 32 1 2 For its Complaint in Intervention against Tetra Tech EC, Inc., the United States of America alleges as follows: 3 I. NATURE OF ACTION 4 1. The United States brings this action against Tetra Tech EC, Inc. (“Tetra Tech EC”) to 5 recover treble damages and civil penalties under the False Claims Act, 31 U.S.C. §§ 3729-33, 6 7 8 9 10 and to recover damages and other monetary relief under the common law theory of breach of contract. 2. This action concerns Tetra Tech EC’s submission of false claims under contracts with the United States Navy to provide radiological remediation services at the Hunters Point Naval 11 12 13 Shipyard (“Hunters Point”) in San Francisco, California. 3. Hunters Point was established as a commercial shipyard in 1870. The Navy operated 14 the shipyard from 1940 to 1974 and, during that time, it used Hunters Point to house the Naval 15 Radiological Defense Laboratory and to decontaminate ships. In 1989, Hunters Point was 16 declared a Superfund site under the Comprehensive Environmental Response, Compensation, 17 18 and Liability Act (CERCLA), requiring a long-term cleanup plan. In 1991, the Base 19 Realignment and Closure Commission (BRAC) recommended Hunters Point for closure. The 20 Navy has agreed to convey Hunters Point to the City and County of San Francisco for residential 21 and commercial development on a parcel-by-parcel basis as the environmental cleanup is 22 23 24 completed. 4. From 2003 through 2014, Tetra Tech EC and certain of its predecessor companies 25 (collectively, “Tetra Tech”) entered into a series of contracts with the United States Navy to 26 provide radiological remediation services at Hunters Point. These contracts required Tetra Tech, 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 2 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 3 of 32 1 among other things, to investigate radiological contamination of soil and buildings, remediate 2 and remove waste as necessary, and provide status reports to the Navy documenting its activities 3 to support the redevelopment of radiologically impacted sites and buildings at Hunters Point for 4 non-military use. The objective of these contracts was to achieve “free-release” of radiologically 5 impacted areas by testing soil and buildings in those areas, and remediating as necessary, until 6 7 test results demonstrated that radiation levels were below applicable release criteria and 8 regulatory limits. Pursuant to its agreement with the City and County of San Francisco, the Navy 9 must complete the radiological remediation of Hunters Point before it can transfer the property to 10 the City and County for redevelopment. The Navy awarded contracts to Tetra Tech to perform 11 12 these services at certain areas of Hunters Point designated as Parcels B, C, D-2, E and G, and 13 Utility Corridors 1, 2, and 3. 1 The following map depicts the Parcels of Hunters Point, 14 including those where Tetra Tech was to perform radiological remediation: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The Navy awarded contracts to other contractors to perform testing and remediation in the other parcels of Hunters Point. 1 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 3 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 4 of 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 5. As detailed below, Tetra Tech violated the False Claims Act and breached its contracts with the Navy by: (1) misrepresenting the source of soil samples submitted to the laboratory for testing; (2) manipulating data from radiological testing of buildings; and (3) 23 24 reporting false results from the radiological soil and building tests. Tetra Tech submitted false 25 claims to the Navy for this work as if it was properly performed when it was not. The Navy 26 relied on Tetra Tech’s misrepresentations in concluding that the remediation of radiologically- 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 4 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 5 of 32 1 2 3 4 5 impacted areas at Hunters Point was complete and made payments to Tetra Tech based on these material misrepresentations. 6. During the period May 2005 through January 2018, Tetra Tech submitted, or caused to be submitted, materially false claims to the Navy for fraudulent testing and reporting at Hunters Point, and made, or caused to be made, material false statements to the Navy in 6 7 connection with the fraudulent testing and reporting. In addition, Tetra Tech breached contracts 8 with the Navy, causing disruption, uncertainty, and delays in the remediation and transfer of 9 parcels of land at Hunters Point. Tetra Tech’s conduct caused the United States to incur 10 substantial additional costs, the magnitude of which is still increasing. 11 II. JURISDICTION AND VENUE 12 13 7. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 14 §§ 1331, 1345, 1367(a), and 31 U.S.C. § 3732. The Court may exercise personal jurisdiction 15 over Tetra Tech pursuant to 31 U.S.C. § 3732(a) because Tetra Tech transacts business in this 16 District. 17 18 19 20 21 8. Venue is proper in the Northern District of California under 31 U.S.C. § 3732(a) and 28 U.S.C. § 1391(b) and (c) because Tetra Tech transacts business in this District. III. PARTIES 9. The United States brings this action on behalf of the Department of the Navy. 22 23 10. Tetra Tech EC, Inc. is a wholly-owned subsidiary of Tetra Tech Inc., with its 24 principal place of business in Morris Plains, New Jersey. At all times relevant to this complaint, 25 Tetra Tech EC, Inc., and its predecessor companies, was a company providing remediation and 26 construction services worldwide, including to the federal government. Tetra Tech’s predecessor 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 5 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 6 of 32 1 2 companies include Foster Wheeler Environmental Corporation and Tetra Tech FW Inc. Upon information and belief, Tetra Tech EC assumed all liabilities of its predecessor companies. IV. THE FALSE CLAIMS ACT 3 4 5 6 7 8 9 10 11 12 13 14 15 16 11. The False Claims Act, 31 U.S.C. §§ 3729-33, as amended by the Fraud Enforcement and Recovery Act of 2009, Pub.L. 111-21 (May 20, 2009), provides, in pertinent part, that: [A]ny person who— (A) knowingly presents, or causes to be presented, a false or fraudulent claim for payment or approval; [or] (B) knowingly makes, uses, or causes to be made or used, a false record or statement material to a false or fraudulent claim; is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, as adjusted by the Federal Civil Penalties Inflation Adjustment Act of 1990 (28 U.S.C. § 2461 note; Public Law 104-410), plus 3 times the amount of damages which the Government sustains because of the act of that person. 31 U.S.C. § 3729(a)(1). 12. Prior to the enactment of the Fraud Enforcement and Recovery Act of 2009, the False 17 18 19 20 21 22 23 24 25 26 Claims Act provided, in pertinent part, that: Any person who – (1) knowingly presents, or causes to be presented, to an officer or employee of the United States Government or a member of the Armed Forces of the United States a false or fraudulent claim for payment or approval; (2) knowingly makes, uses, or causes to be made or used, a false record or statement to get a false or fraudulent claim paid or approved by the Government; Is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of damages which the Government sustains because of the act of that person[.] 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 6 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 7 of 32 1 13. Pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended 2 by the Debt Collection Improvement Act of 1996, 28 U.S.C. § 2461, and 64 Fed. Reg. 47099, 3 47103 (1999), the False Claims Act civil penalties were adjusted to $5,500 to $11,000 per false 4 claim for violations occurring on or after September 29, 1999. The penalty range was increased 5 to $10,781 to $21,563 effective August 1, 2016, for violations occurring on or after November 2, 6 7 2015. 81 Fed. Reg 42491, 42494 (2016). 8 14. The False Claims Act defines “knowing” and “knowingly” as follows: 9 [T]he terms “knowing” and “knowingly”— 10 (A) mean that a person, with respect to information— 11 (i) has actual knowledge of the information; 13 (ii) acts in deliberate ignorance of the truth or falsity of the information; or 14 (iii) acts in reckless disregard of the truth or falsity of the information; and 12 15 16 (B) require no proof of specific intent to defraud. 31 U.S.C. § 3729(b)(1). 17 18 V. FACTUAL ALLEGATIONS 19 A. Radiological History of Hunters Point 20 15. Hunters Point is located in southeast San Francisco on a peninsula that extends east 21 into the San Francisco Bay. A subsidiary of the Bethlehem Steel Company operated it as a 22 23 drydock facility for commercial and military ship maintenance and repair from 1868 until 1939, 24 when the Navy purchased it. On December 18, 1941, eleven days after the United States entered 25 World War II, the Navy took full control of Hunters Point. To support the war effort, the Navy 26 constructed numerous buildings, and excavated surrounding hills to expand the shoreline into the 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 7 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 8 of 32 1 2 Bay. After World War II ended, the Navy used Hunters Point’s expansive berthing facilities for reserve fleet ships returning from the Pacific. 3 16. Shipyard operations by the Navy involved the use of general radioactive material. 4 Such operations included refurbishment and handling of radioluminescent devices and paint, 5 gamma radiography, calibration laboratory operations to ensure the accuracy of radiological 6 7 survey instruments, and decontamination of ships (including ships returning from Operation 8 Crossroads -- atomic weapons testing in the Bikini Atoll in the Marshall Islands). In addition, in 9 1946, the Navy established at Hunters Point a laboratory that eventually became the Naval 10 Radiological Defense Laboratory (“Defense Lab”). The Defense Lab, which occupied up to 20 11 12 buildings at Hunters Point, was a center for research into decontamination and the effects of 13 fallout and radiation on living organisms and on natural and synthetic materials. The Defense 14 Lab used a large number of radionuclides, as well as machines that generated radiation and 15 charged particles. The Navy closed the Defense Lab in 1969. The Navy also used Hunters 16 Point’s berthing and drydocking facilities for the maintenance and repair of nuclear-powered 17 18 ships. 19 17. The Navy ceased operating Hunters Point as a Naval shipyard in 1974. From 1974 to 20 1986, the Navy leased facilities at Hunters Point to private tenants. The Navy resumed operation 21 of the shipyard in 1986, when Hunters Point was designated as an annex to Naval Station 22 23 Treasure Island. Shipyard operations were permanently terminated on December 29, 1989. In 24 1991, Hunters Point was identified for closure and reuse pursuant to the Base Realignment and 25 Closure Act of 1988. On January 21, 1994, the Navy and the City and County of San Francisco 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 8 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 9 of 32 1 2 executed a memorandum of understanding establishing a process for the transfer of Hunters Point to the City and County of San Francisco for redevelopment. 18. In 1989, the United States Environmental Protection Agency (EPA) placed Hunters 3 4 5 Point on the National Priorities List of Superfund sites pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), which required 6 7 the Navy to conduct a preliminary assessment of contamination of the property. 2 Accordingly, 8 the Navy conducted and published a two-volume Historical Radiological Assessment (HRA). 9 Volume II, entitled Final Historical Radiological Assessment, History of the Use of General 10 Radioactive Materials, 1939 – 2003, was published in August 2004. It concluded that low levels 11 12 13 of radioactive contamination existed within Hunters Point, and identified impacted sites for further investigation and remediation. 19. On April 21, 2006, the Navy published the Final Basewide Radiological Removal 14 15 16 Action Memorandum-Revision 2006, Hunters Point Shipyard, San Francisco, California (“2006 Action Memo”). The purpose of the 2006 Action Memo was to document for the administrative 17 18 record the Navy’s “decision to undertake time-critical removal actions (TCRAs), at areas 19 throughout the base that may contain localized radioactive contamination in soils, debris/slag, 20 and buildings [at Hunters Point], as identified in [the HRA].” Attached as Table 1 to the 2006 21 Action Memo were the “release criteria.” The release criteria established the cleanup goals for 22 23 each radionuclide of concern for soil, surfaces, and water. The 2006 Action Memo prescribed 24 that “[b]efore initiating a removal action per this [Action Memo], the area being considered will 25 be characterized using real-time radiation detection devices or soil sampling and analysis.” 26 27 28 Parcel A of Hunters Point was removed from the National Priorities List in February 1999, and transferred to the City and County of San Francisco in December 2004. 2 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 9 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 10 of 32 1 20. Several radiological investigations and radiological removal actions have been 2 conducted at Hunters Point since being placed on the National Priorities List. As discussed 3 below, the Navy awarded several contracts to Tetra Tech, to perform these investigations and 4 removal actions. 5 6 7 B. Contracts Awarded to Tetra Tech for Radiological Remediation at Hunters Point 21. In order to conduct the necessary radiological investigation and remediation at 8 9 Hunters Point, the Navy solicited proposals from contractors pursuant to several Environmental 10 Multiple Award Contracts for Environmental Remediation Services for Radiological 11 Contaminants. As discussed below, the Navy awarded several contracts (called “task orders”) to 12 Tetra Tech for the radiological investigation and remediation of radiologically-impacted sites 13 throughout Hunters Point. 14 15 22. The objective of the task orders was to achieve “free release” of the radiologically- 16 impacted areas at Hunters Point so that the Navy could transfer the property to the City and 17 County of San Francisco for redevelopment. The HRA defines “free release” as a 18 19 20 21 recommendation made after investigations and surveys indicate all applicable release criteria have been met and the site is ready for review by Navy and regulatory agencies for future nonradiological use. The release criteria for each radionuclide of concern for surfaces, soil and 22 water, is set forth in Table 1 to the 2006 Action Memo and incorporated by reference into each 23 of the relevant task orders. 24 23. The task orders required the radiological investigation and remediation to be 25 26 27 28 accomplished through testing and analysis of soil samples, and the scanning of building surfaces with radiological detection instruments. Soil samples and radiological readings of building UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 10 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 11 of 32 1 surfaces were conducted within designated “survey units,” which are measured areas throughout 2 Hunters Point. Task orders awarded to Tetra Tech included both cost plus award fee contracts 3 and firm fixed price contracts. 4 5 (1) Cost Plus Award Fee Contracts 24. The cost plus award fee contracts awarded to Tetra Tech obligated the Navy to pay 6 7 Tetra Tech its allowable costs for providing the services described in the scope of work, plus a 8 discretionary award fee, up to a maximum amount. Cost plus award fee contracts allow the 9 payment of an award fee, based on a judgmental evaluation by the government, sufficient to 10 provide motivation for excellence in contract performance. See Federal Acquisition Regulation 11 12 (FAR) § 16.305. A contractor may earn an award fee if its overall cost, schedule, and technical 13 performance is satisfactory. FAR § 16.401. For each of the cost plus award fee contracts 14 identified below, Tetra Tech submitted progress reports and vouchers for its costs and fees. A 15 government official certified the vouchers for payment in reliance on Tetra Tech’s 16 representations. 17 18 25. On March 23, 2003, the Navy awarded contract number N68711-98-D-5713, task 19 order 0072 (“Task Order 5713-0072”), to Foster Wheeler Environmental Corporation, a 20 predecessor company of Tetra Tech EC, Inc. The Navy’s purpose in awarding Task Order 5713- 21 0072 was to acquire radiological sampling and remediation services for Hunters Point. Services 22 23 required under Task Order 5713-0072 included radiological surveys and remedial activities of 24 buildings, former building sites, sewer and drain systems, fill, and surrounding areas in Parcels 25 C, D, and E of Hunters Point. Task Order 5713-0072 was a cost plus award fee contract that 26 obligated the Navy to pay Tetra Tech its allowable costs for providing the required services, plus 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 11 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 12 of 32 1 2 3 4 5 a discretionary award fee, not to exceed the maximum cost plus fee of $31,397,209. After 52 contract modifications, the total contract value awarded was $83,721,008. 26. On February 13, 2004, the Navy awarded contract number N68711-98-D-5713, task order 0084 (“Task Order 5713-0084”), to Tetra Tech FW Inc., a predecessor company of Tetra Tech EC, Inc. The objective of Task Order 5713-0084 was to excavate and dispose of 6 7 anthropogenic polychlorinated biphenyl (“PCB”) soil contamination from a PCB Excavation Site 8 in Parcel E of Hunters Point. Because low-level radiation was expected to be present in the soil, 9 radiation screening of the soil was also required. Task Order 5713-0084 was a cost plus award 10 fee contract that obligated the Navy to pay Tetra Tech its allowable costs for providing the 11 12 13 required services, plus a discretionary award fee, not to exceed the maximum cost plus fee of $1,368,238. After 27 contract modifications, the total contract value awarded was $10,248,848. 14 27. On March 28, 2006, the Navy awarded contract number N62473-06-D-2201, task 15 order 006 (“Task Order 2201-006”) to Tetra Tech EC, Inc. The scope of work in Task Order 16 2201-006 required Tetra Tech to perform radiological investigation and remediation to address 17 18 radiologically-impacted sites in Parcel B and one building in Parcel D. The primary objective of 19 Task Order 2201-006 was for Tetra Tech EC, Inc. to complete all radiological work for each 20 radiologically-impacted site in Parcel B that was identified in the HRA, and to provide general 21 base-wide radiological support services. Task Order 2201-006 was a cost plus award fee 22 23 contract that obligated the Navy to pay Tetra Tech its allowable costs for providing the services, 24 plus a discretionary award fee, not to exceed the maximum cost plus fee of $17,485,300. Task 25 Order 2201-006 included an option to increase the costs by $2,351,058 and the fee by $213,728. 26 After 13 contract modifications, the total contract value awarded was $32,742,848. 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 12 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 13 of 32 1 28. On December 18, 2006, the Navy awarded contract number N44255-01-D-2000, task 2 order 0070 (“Task Order 2000-0070”), to Tetra Tech EC, Inc. The primary objective of Task 3 Order 2000-0070 was for Tetra Tech EC, Inc. to complete all radiological work for each 4 radiologically-impacted site in Parcel D that was identified in the HRA, and some unfinished 5 work in Parcel B. The task order required Tetra Tech to perform surveys and remediation of 6 7 buildings, a pier, and sanitary sewer and storm drain sites. Task Order 2000-0070 was a cost 8 plus award fee task order. The task order obligated the Navy to pay Tetra Tech its allowable 9 costs for providing the services, plus a discretionary award fee, not to exceed the maximum cost 10 plus fee of $14,990,147. After eight contract modifications, the total contract value awarded was 11 12 $22,523,715. 13 29. On April 20, 2009, the Navy awarded contract number N62473-07-D-3211, task 14 order 0018 (“Task Order 3211-0018”), to Tetra Tech EC, Inc. The objective of Task Order 15 3211-0018 was for Tetra Tech to provide base-wide support to contractors performing chemical 16 and radiological removal and remediation at Hunters Point. Tetra Tech was required to maintain 17 18 on-site laboratory services to test survey samples for radionuclides of concern, and to operate a 19 Radiological Screening Yard to support radiological removal actions and investigations being 20 performed under different task orders. Task Order 3211-0018 was a cost plus award fee contract 21 that obligated the Navy to pay Tetra Tech its allowable costs for providing the services, plus a 22 23 24 25 26 discretionary award fee, not to exceed the maximum cost plus fee of $13,882,869. After 12 contract modifications, the total contract value awarded was $19,126,849. 30. On June 3, 2009, the Navy awarded contract number N62473-07-D-3211, task order 0019 (“Task Order 3211-0019”), to Tetra Tech EC, Inc. The primary objective of Task Order 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 13 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 14 of 32 1 3211-19 was for Tetra Tech to complete specified radiological remediation and surveys at 2 remaining Parcel B sanitary sewer and storm drain sites. Task Order 3211-0019 was a cost plus 3 award fee contract that obligated the Navy to pay Tetra Tech its allowable costs for providing the 4 services, plus a discretionary award fee, not to exceed the maximum cost plus fee of $884,716. 5 After five contract modifications, the total contract value awarded was $876,764. 6 7 8 9 10 (2) Fixed Price Contract Awards 31. The firm fixed price contracts awarded to Tetra Tech obligated the Navy to pay a maximum fixed amount for the services required under the contracts, regardless of Tetra Tech’s costs. Firm fixed price contracts place upon the contractor maximum risk and full responsibility 11 12 for all costs and resulting profit or loss. See FAR § 16.202-1. Firm fixed price contracts provide 13 maximum incentive for the contractor to control costs and perform effectively, and impose a 14 minimum administrative burden on the contracting parties. Id. For each of the firm fixed price 15 contracts awarded to Tetra Tech identified below, Tetra Tech submitted monthly progress reports 16 and invoices based on the percentage of work completed. Tetra Tech certified the invoices for 17 18 19 20 21 payment, and government officials authorized payment to Tetra Tech in reliance on Tetra Tech’s representations. 32. On September 4, 2008, the Navy awarded contract number N62473-08-D-8823, task order 002 (“Task Order 8823-002”), to Tetra Tech EC, Inc. The primary objective of Task Order 22 23 8823-002 was to remove and remediate sewer and storm drain lines along Fisher and Spear 24 Avenues. Task Order 8823-002 required Tetra Tech to remove, survey, remediate, clear, and 25 dispose of appropriately all sewer and storm drain systems, including the peripheral soil, in these 26 two areas in order to attain free release. Task Order 8823-002 was a firm fixed price task order 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 14 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 15 of 32 1 that obligated the Navy to pay Tetra Tech a maximum fixed amount of $6,343,703 for providing 2 the services required under the contract, regardless of Tetra Tech’s costs. After six contract 3 modifications, the total contract value awarded was $7,033,848. 4 5 33. On September 21, 2009, the Navy awarded contract number N62473-08-D-8823, task order 003 (“Task Order 8823-003”), to Tetra Tech EC, Inc. Task Order 8823-003 addressed the 6 7 recommendations in the HRA for the radiologically-impacted sites in Parcel E, specifically 8 focusing on sanitary sewer and storm drain lines along Crisp Road, and radiologically-impacted 9 buildings and sites in the central portion of Parcel E. The primary objective of the solicitation 10 was to achieve unrestricted free release of the sewer and storm line survey units along Crisp 11 12 Road and the central areas of Parcel E. Additional work required by Task Order 8823-003 13 included surveys, remediation, and reporting for certain radiological buildings and sites in Parcel 14 E. Task Order 8823-003 was a firm fixed price contract that obligated the Navy to pay Tetra 15 Tech a maximum fixed amount of $13,070,672 for providing the services required under the 16 contract, regardless of Tetra Tech’s costs. After five contract modifications, the total contract 17 18 value awarded was $13,019,641. 19 34. On June 23, 2010, the Navy awarded contract number N62473-10-D-0809, task order 20 002 (“Task Order 0809-002”), to Defendant Tetra Tech EC, Inc. The focus of Task Order 0809- 21 002 was Parcel C. The primary objective of the scope of work in Task Order 0809-002 was to 22 23 achieve free release of Buildings 203, 214, 241, 271, and 272, and unrestricted free release of the 24 sewer and storm drain survey units in Parcel C. Task Order 0809-002 was a firm fixed price 25 contract that obligated the Navy to pay Tetra Tech a maximum fixed amount of $11,494,845 for 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 15 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 16 of 32 1 2 3 4 5 providing the services required under the contract, regardless of Tetra Tech’s costs. After nine contract modifications, the total contract value awarded was $12,082,759. 35. On September 9, 2010, the Navy awarded contract number N62473-10-D-0809, task order 0004 (“Task Order 0809-0004”), to Defendant Tetra Tech EC, Inc. Task Order 0809-0004 obligated Tetra Tech to provide base-wide radiological support to enable contractors to complete 6 7 radiological removal and remediation work at Hunters Point, including the operation of 8 radiological screening yards that accepted and processed radiologically impacted soil from the 9 removal of storm and sanitary sewers, and the performance of routine surveys of radiologically 10 impacted buildings and sites. Task Order 0809-0004 was a firm fixed price contract. The 11 12 contract obligated the Navy to pay Tetra Tech a maximum fixed amount of $14,040,521 for the 13 services required under the contract, regardless of Tetra Tech’s costs. After 10 contract 14 modifications, the total contract value awarded was $24,843,771. 15 16 36. On September 22, 2010, the Navy awarded contract number N62473-10-D-0809, task order 007 (“Task Order 0809-007”), to Tetra Tech EC, Inc. The solicitation for Task Order 17 18 0809-007 was for radiological remediation and support for the 500 series area of Parcel E. The 19 objective was to achieve free release of sewer and storm drain survey units, buildings, building 20 sites, and the 500 series site of Parcel E. Task Order 0809-007 was a firm fixed price contract 21 that obligated the Navy to pay Tetra Tech a maximum fixed amount of $9,984,979 for providing 22 23 24 the services required under the contract, regardless of Tetra Tech’s costs. After 11 contract modifications, the total contract value awarded was $11,408,410. 25 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 16 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 17 of 32 1 37. On July 10, 2012, the Navy awarded contract number N62473-10-D-0809, task order 2 0012 (“Task Order 0809-0012”), to Tetra Tech EC, Inc. Task Order 0809-0012 was in support 3 of Phase II of Parcel C remediation, focusing on sanitary sewer and storm drain lines and 4 radiologically-impacted ship berths and sites. The objective of the solicitation was to achieve 5 unrestricted free release of the sewer and storm drain survey units and ship berths in Parcel C. 6 7 For the ship berths, Tetra Tech was required to perform characterization surveys, remediation, 8 remedial action surveys, and final status surveys, and submit a final status survey report. For the 9 sanitary and sewer drain systems, Tetra Tech was responsible for removing the sewer and storm 10 drain lines and the associated impacted soil, surveying the trench and remediating it as necessary, 11 12 performing a final status survey, and submitting a final status survey report to the Navy. Task 13 Order 0809-0012 was a firm fixed price contract that obligated the Navy to pay Tetra Tech a 14 maximum fixed amount of $9,846,298 for providing the services required under the contract, 15 regardless of Tetra Tech’s costs. After five contract modifications, the total contract value 16 awarded was $10,487,802. 17 18 38. On September 19, 2012, the Navy awarded contract number N62473-12-D-2006, task 19 order 0004 (“Task Order 2006-0004”), to Tetra Tech EC, Inc. Task Order 2006-0004 required 20 Tetra Tech to perform and report on surveys to analyze the radiological contamination in 21 Buildings 253 and 211 in Parcel C and to identify and bound the areas of contamination. Task 22 23 Order 2006-0004 was a firm fixed price contract that obligated the Navy to pay Tetra Tech a 24 maximum fixed amount of $5,892,247 for the services required under the contract, regardless of 25 Tetra Tech’s costs. After two contract modifications, the total contract value awarded was 26 $7,255,881. 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 17 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 18 of 32 1 39. On August 13, 2013, the Navy awarded contract number N62473-10-D-0809, task 2 order 0015 (“Task Order 0809-0015”), to Tetra Tech EC, Inc. Task Order 0809-0015 addressed 3 recommendations in the HRA for radiologically-impacted sanitary sewer and storm drain lines in 4 Parcel E. Tetra Tech was responsible for the excavation of the sanitary sewer and storm drain 5 lines, as well as the sampling, analysis, and clearance of radiologically-impacted soils. The 6 7 primary objective of Task Order 0809-0015 was to complete the removal action, and deliver a 8 Final Status Survey Report containing adequate information and data to achieve unrestricted free 9 release. Task Order 0809-0015 was a firm fixed price contract that obligated the Navy to pay 10 Tetra Tech a maximum fixed amount of $4,894,307 for the services required under the contract, 11 12 13 14 15 16 regardless of Tetra Tech’s costs. After two contract modifications, the total contract value awarded was $5,061,910. 40. On September 23, 2014, the Navy awarded contract number N62473-10-D-0809, task order 0016 (“Task Order 0809-0016”), to Tetra Tech EC, Inc. Task Order 0809-0016 was in support of Phase III of Radiological Remediation and Support of Parcel C. The objective of 17 18 Task Order 0809-0016 was to achieve unrestricted free release of the remaining sewer and storm 19 drain survey units in Parcel C, and unrestricted free release of Buildings 205 and 224. Task 20 Order 0809-0016 was a firm fixed price contract that, as modified, obligated the Navy to pay 21 Tetra Tech a maximum fixed amount of $669,812 for the services required under the contract, 22 23 24 25 regardless of Tetra Tech’s costs. 41. The contracts identified in paragraphs 24-40 shall be referred to collectively as the “Relevant Contracts.” 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 18 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 19 of 32 1 2 C. Governing Contract Terms, Regulations, and Procedures to Ensure Proper Radiological Investigation of Soil and Buildings 42. Each of the Relevant Contracts required Tetra Tech to conduct radiological 3 4 investigation of soil and buildings in accordance with the Multi-Agency Radiation Survey and 5 Site Investigation Manual (MARSSIM). MARSSIM is a consensus document published by the 6 EPA, the U.S. Department of Defense, the U.S. Department of Energy, and the U.S. Nuclear 7 Regulatory Commission that provides detailed guidance for the investigation and remediation of 8 9 10 radiologically impacted sites. 43. For the radiological investigation and remediation of soil at Hunters Point, the 11 Relevant Contracts and MARSSIM required Tetra Tech to take the following steps for each 12 survey unit: (1) determine the boundaries of the survey unit; (2) collect soil samples for 13 laboratory analysis in order to characterize the survey unit; (3) if laboratory results demonstrate 14 15 that the soil is above release criteria, remediate survey unit by removing and disposing of soil; 16 (4) collect soil samples for laboratory analysis from locations that tested above release criteria to 17 ensure that remediation was effective; (5) further remediate if necessary; and (6) collect final 18 19 20 21 22 23 24 status survey soil samples for laboratory analysis. The Relevant Contracts require Tetra Tech to “perform remediation and additional excavation until remediation goals have been met and or appropriate risk levels have been reached.” 44. The Relevant Contracts required Tetra Tech to provide radiological investigation of buildings at Hunters Point by conducting alpha, beta, and gamma radiation scans of building surfaces using radiation detection instruments. The Relevant Contracts and MARSSIM required 25 26 27 28 Tetra Tech to take the following steps: (1) scan and remove material, equipment, and building debris; (2) determine the Class, and therefore size, of survey units (Class 1 survey units, defined UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 19 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 20 of 32 1 as having reasonable potential for contamination above release criteria, are divided into areas of 2 less than 100 square meters; Class 2 survey units, defined as having reasonable potential for 3 contamination but below release criteria, are divided into areas less than 1,000 square meters); 4 (3) conduct radiation scans by moving detectors across surfaces at required speeds; (4) download 5 data from detection instruments; (5) correct survey results for naturally occurring background 6 7 radiation; (6) evaluate data to determine whether the survey unit exceeds release criteria; (7) 8 remediate, remove and dispose of material, if necessary; and (8) repeat the above steps until 9 release criteria are met. 10 D. Tetra Tech’s Fraudulent Course of Conduct 11 12 45. At all times relevant to this Complaint, Tetra Tech contracted with New World 13 Technology, Inc. or Radiological Survey & Remedial Services, Inc. to provide Radiological 14 Control Technicians (RCT) to work on the radiological investigation and remediation of Hunters 15 Point. Tetra Tech managers, including Stephen Rolfe and Justin Hubbard, supervised crews of 16 RCTs who were collecting soil samples and conducting building scans in Parcels B, C, D-2, E 17 18 19 20 21 and G, and Utility Corridors 1, 2, and 3. 46. William Dougherty was the Project Manager for Tetra Tech between on or about March 1, 2006 and early 2014. Dougherty worked on-site at Hunters Point, and was responsible for managing all aspects of Tetra Tech’s work. Dougherty had daily contact with, and gave 22 23 direction to, Rolfe and Hubbard. 24 47. At all times relevant to the complaint, Dennis McWade was a Construction Manager 25 for Tetra Tech at Hunters Point. McWade worked on-site at Hunters Point, and was responsible 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 20 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 21 of 32 1 2 for managing the crews performing radiological surveys and remediation at Hunters Point for Tetra Tech. McWade had daily contact with, and gave direction to, Rolfe and Hubbard. 48. At all times relevant to the complaint, Rick Weingarz was employed by Tetra Tech as 3 4 5 an Assistant Project Manager at Hunters Point. Weingarz worked on-site at Hunters Point, and was responsible for managing the crews performing radiological surveys and remediation at 6 7 8 Hunters Point for Tetra Tech. Weingarz had daily contact with, and gave direction to, Rolfe and Hubbard. 9 10 49. Andrew Bolt, who has been Tetra Tech’s President since on or about July 2014, served as Tetra Tech’s Senior Vice President, Remediation and Program Manager, from 1994 11 12 until 2014. Bolt, who was Dougherty’s boss, provided Dougherty with monthly financial 13 reports regarding Tetra Tech’s profits from its contracts to perform remediation work at Hunters 14 Point. 15 16 50. Rolfe, Hubbard, Dougherty, McWade, Weingarz and Bolt were each employed by Tetra Tech EC in a managerial capacity at all times relevant to this Complaint, and each of them 17 18 19 20 21 22 23 24 25 was acting within the scope of employment at all times relevant to this Complaint. 51. Tetra Tech’s fraud was initiated and directed by Tetra Tech’s corporate managers, including, but not limited to, Bolt, Dougherty, Weingarz, McWade, Rolfe, and Hubbard. (1) When Investigating Soil Contamination, Tetra Tech Caused Technicians to Replace Collected Soil Samples with Clean Soil From a Different Location Before Submitting the Samples to the Lab for Analysis 52. In performing the Relevant Contracts, Tetra Tech was responsible for conducting soil surveys, in accordance with MARSSIM, in order to identify and define the boundaries of 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 21 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 22 of 32 1 2 3 4 5 radiological contamination. Soil surveys were used to determine whether further remediation was necessary. 53. As part of the soil survey process, each parcel was divided into a number of “survey units,” each of which defined a discrete area for analysis. Where feasible and practical, survey units were defined with reference to fixed features within a parcel, such as a building, or a 6 7 trench created from the removal of a sewer or storm drain line. For areas other than buildings, 8 Tetra Tech was responsible for collecting soil samples from designated points within each survey 9 unit and submitting the samples to a laboratory for analysis. 10 If the laboratory analysis demonstrated a higher-than-allowable concentration of radionuclides of concern within a 11 12 particular survey unit, Tetra Tech was required to remediate the survey unit. After completing 13 the work it believed was necessary to remediate the area, Tetra Tech would collect new samples 14 (or building scan data) for another round of analysis. This process was repeated until all samples 15 collected within a survey unit passed laboratory analysis, at which time the survey unit was 16 deemed to have met the release criteria. 17 18 54. As detailed below, Tetra Tech managers instructed RCTs to discard soil samples 19 collected from certain Survey Units at Hunters Point, replace the discarded samples with “clean” 20 soil from other locations, and submit the replaced samples to the lab for analysis. Through this 21 process, Tetra Tech misrepresented the location from which soil samples were collected and, 22 23 24 25 26 thus, misrepresented the character of soil in the survey units from which it purported to have collected the samples. 55. In the course of conducting soil surveys under the Relevant Contracts, Tetra Tech managers, including Stephen Rolfe and Justin Hubbard, ordered RCTs to collect soil in buckets 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 22 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 23 of 32 1 from a location where they knew the soil was “clean,” i.e., below the release criteria for 2 radionuclides of concern. Rolfe and Hubbard instructed the RCTs to keep the buckets of “clean” 3 soil in a CONEX box (a trailer-sized container used to transport and store supplies) on site. 4 After RCTs collected soil samples in Ziploc bags, Rolfe and Hubbard ordered the RCTs to bring 5 the bagged samples to the CONEX box, where they were instructed to empty the bags, and fill 6 7 new bags with the “clean” soil from the buckets. Tetra Tech personnel labeled the new bags 8 with the Survey Unit and Sample Identification Numbers of the discarded samples, and 9 submitted the switched soil samples to the onsite lab for analysis. Tetra Tech submitted these 10 falsified soil samples to the lab accompanied by a Tetra Tech Chain-of-Custody Record falsely 11 12 identifying the Survey Unit (and therefore the location from which the soil was collected) of 13 each sample. Each Chain-of-Custody Record was signed by the RCT or Tetra Tech 14 representative relinquishing the samples, as well as the lab employee receiving the samples. 15 16 56. On the cost plus award fee contracts, Tetra Tech benefited from the falsification of soil surveys by billing for work it failed to perform in accordance with the Relevant Contracts, 17 18 and by receiving award fees to which it was not entitled. On firm fixed price contracts, Tetra 19 Tech benefited from the falsification of soil surveys by avoiding its obligation to remediate 20 contaminated areas, thus decreasing its overall costs. Tetra Tech management at Hunters Point, 21 including Project Manager Dougherty, was praised in performance evaluations for performing 22 23 24 25 task orders under cost. 57. Tetra Tech falsified or caused the falsification of soil surveys, as described above, in connection with its work in the survey units identified in Exhibit 1 hereto. As a result, the 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 23 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 24 of 32 1 2 3 4 5 6 7 reports Tetra Tech submitted to the Navy in connection with this work (which are identified in Exhibit 1 and described in paragraphs 66-68 below) were false. (2) Rolfe and Hubbard Plead Guilty to Charges of Destruction, Alteration, or Falsification of Records in Federal Investigations 58. On March 15, 2017, Tetra Tech manager Stephen Rolfe pleaded guilty to destruction, alteration, or falsification of records in federal investigations and bankruptcy, in violation of 18 U.S.C. § 1519. In pleading guilty, Rolfe admitted that on approximately 20 occasions in 2012 he 8 9 instructed the RCTs on his team to get “clean dirt” from areas known to be clean and taken from 10 outside the marked Survey Unit areas to use as substitute samples for the dirt from the Survey 11 Unit, and that he did this so that the Survey Unit would pass the laboratory analysis and not 12 require further remediation. He further admitted that the switching of soil samples was done 13 inside the CONEX box on site at Hunters Point and in his presence. He also admitted that, on 14 15 these occasions, he knew that the soil locations reported on the Chain-of-Custody Record forms 16 were false. Rolfe admitted that the motivation for his conduct came from pressure applied from 17 his Tetra Tech management at Hunters Point, including Dougherty, Weingarz and McWade. 18 19 20 21 22 23 24 Rolfe admitted that Tetra Tech management at Hunters Point directed him to get his crew “the hell out” of a survey unit that was testing above the release criteria, told him that they were “not remediating the whole goddam site,” and directed him on numerous occasions to “get clean dirt.” 59. On May 18, 2017, Tetra Tech manager Justin Hubbard pleaded guilty to destruction, alteration, or falsification of records in federal investigations and bankruptcy, in violation of 18 U.S.C. § 1519. In pleading guilty, Hubbard admitted that in 2012 he obtained “clean” dirt from 25 26 27 28 an area north of Buildings 253 and 211 at Hunters Point and substituted it for dirt taken from at least four Survey Units in the North Pier area of Hunters Point (i.e., Survey Units 1, 8, 10, and UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 24 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 25 of 32 1 11). He further admitted that he filled a five-gallon bucket with “clean” serpentinite soil from an 2 area outside the relevant Survey Unit, and brought the bucket back to the CONEX box. Hubbard 3 admitted that, once inside the CONEX box, he emptied the “legitimate” soil samples previously 4 collected by RCTs from their sampling bags into an empty bucket, and substituted the clean 5 serpentinite soil into each sampling bag. He also admitted that by switching the soil, he knew 6 7 that the data on the Chain-of-Custody Record forms was false. Rolfe further admitted that he 8 knew that the false data on the Chain-of-Custody Record forms was incorporated into maps and 9 reports submitted to the Navy for the purpose of demonstrating that the area had been 10 successfully remediated. 11 12 60. In engaging in the conduct described above, Rolfe and Hubbard acted within the 13 scope of their employment with Tetra Tech, and for the purpose of benefitting Tetra Tech. Tetra 14 Tech Management at Hunters Point, including but not limited to Dougherty, McWade, and 15 Weingarz also acted within the scope of their employment with Tetra Tech, and for the purpose 16 of benefitting Tetra Tech, when they knowingly directed and encouraged, and were aware of, the 17 18 19 20 21 falsification of soil samples. Tetra Tech management did not alert the Navy of the fraud. (3) When Investigating Building Contamination, Tetra Tech Falsified Data Collected from Radiation Detection Instruments 61. In performing the Relevant Contracts, Tetra Tech was responsible for conducting 22 surveys of existing buildings, in accordance with MARSSIM, in order to characterize areas of 23 radiological contamination. Building surveys were used to determine whether further 24 remediation was necessary. 25 26 27 28 62. Tetra Tech conducted radiological building surveys by using radiation detection instruments to scan surfaces in the buildings. The radiation detection instruments were either UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 25 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 26 of 32 1 handheld or mounted on a cart. The data collected by the radiation detection instruments was 2 downloaded by Tetra Tech personnel into a database, and then imported into a spreadsheet that 3 was delivered to the Navy. The Navy relied on the results of Tetra Tech’s building surveys to 4 determine whether further remediation was necessary. 5 63. Following the discovery of the falsification of soil samples, the Navy reviewed the 6 7 data from radiological surveys performed by Tetra Tech in buildings at Hunters Point. The Navy 8 found that strings of data from readings from one instrument and surface were repeated for 9 readings from other instruments and surfaces within a building. Duplicated strings of data were 10 discovered in the results of surveys conducted in 15 of 28 buildings. In some instances, the exact 11 12 time, to the second, that the reading was taken was also duplicated. In other cases, duplicated 13 data strings were altered slightly in an effort to conceal manipulation of the data. The probability 14 that the duplicated strings of data that the Navy discovered could occur by chance or innocent 15 error is extraordinarily low. 16 64. Tetra Tech manipulated and falsified the building scan data that it provided to the 17 18 19 20 21 Navy, rather than providing actual radiation detection results from a full building survey. 65. Tetra Tech falsified data collected from radiological scans of buildings throughout Hunters Point, including but not limited to Buildings 103, 113, 113A, 130, 146, 253, 272, 351, 351A, 365, 366, 401, 411, 439, and 810. Tetra Tech’s falsification of data was sufficiently 22 23 24 widespread that the Navy has been required to obtain new surveys of each of these buildings. E. Final Status Survey Reports, Survey Unit Project Reports, and Removal Action Completion Reports 25 26 27 28 66. Pursuant to the Relevant Contracts, Tetra Tech prepared and submitted to the Navy Final Status Survey Reports, Final Survey Unit Project Reports, final Removal Action UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 26 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 27 of 32 1 Completion Reports, and/or Characterization Survey Result Reports (collectively, the “Reports”) 2 upon completion of the investigation and remediation of a survey unit. The Reports described 3 the procedures and the results of the surveys performed to achieve unrestricted radiological 4 release of the radiologically-impacted sites at Hunters Point. The Reports were signed by 5 Dougherty as Tetra Tech’s Project Manager at Hunters Point, in addition to other Tetra Tech 6 7 8 9 10 officials. 67. In the Reports, Tetra Tech falsely stated that soil samples were properly collected from designated survey units, when, in fact, samples of soil that Tetra Tech management knew to be “clean” were collected from locations outside of the designated survey units and submitted to 11 12 13 14 15 16 the laboratory for analysis. In the Reports, Tetra Tech stated the soil sample analytical results as if the soil was properly collected. 68. In the Reports, Tetra Tech falsely stated that building surveys were completed and properly performed, when in fact the building scan data was manipulated. In the Reports, Tetra Tech stated the building survey results as if the buildings were properly scanned and the data 17 18 19 20 21 were properly recorded and reported. F. Tetra Tech’s Submission of False Claims 69. Tetra Tech submitted claims for payment to the United States under each of the 22 Relevant Contracts knowing that the claims were false or fraudulent because they included 23 claims: (a) for soil surveys in which Tetra Tech misrepresented the source of the soil samples 24 collected; (b) for building surveys in which Tetra Tech falsified the data collected by radiation 25 26 27 28 detection instruments; and/or (c) for preparing status survey reports containing falsified results from soil and building surveys. UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 27 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 28 of 32 1 70. Tetra Tech management, including but not limited to Dougherty and Bolt, submitted 2 or caused to be submitted vouchers and invoices, accompanied by progress reports, representing 3 that it fully and properly investigated and remediated radiological contamination in soil and 4 buildings at Hunters Point. As described above, these representations were false. 5 71. Tetra Tech “knowingly” submitted vouchers and invoices and accompanying 6 7 8 9 10 progress reports containing material misrepresentations, within the meaning of the False Claims Act, 31 U.S.C. § 3729(b). G. Tetra Tech’s Fraud Has Caused Disruption, Uncertainty, and Delays 72. Tetra Tech’s fraudulent course of conduct has caused substantial disruption, 11 12 uncertainty, and delay in the plan to remediate and transfer Hunters Point to the City and County 13 of San Francisco for redevelopment, as well as fear in the community regarding the effects of 14 any continued contamination at the site. Because of Tetra Tech’s fraud in investigating the 15 radiological contamination, the Navy will have pay another contractor to re-test much of the soil 16 and buildings in the Parcels where Tetra Tech worked in order to determine whether further 17 18 remediation is necessary. Tetra Tech’s fraud has also caused the Navy to devote substantial 19 resources to address the health and safety concerns of San Francisco residents. As a result of 20 Tetra Tech’s fraud, the transfer of Hunters Point to the City and County of San Francisco will be 21 delayed by many years. The Government has also had to devote substantial resources to 22 23 investigate the extent and impact of Tetra Tech’s fraud. 24 25 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 28 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 29 of 32 FIRST CAUSE OF ACTION 1 2 (False Claims Act: Presentation of False Claims) 3 (31 U.S.C. § 3729(a)(1)(A)) 4 5 73. The United States repeats and re-alleges the preceding paragraphs as if fully set forth herein. 6 74. Tetra Tech knowingly presented, or caused to be presented, false or fraudulent claims 7 8 for payment or approval to the United States, in violation of 31 U.S.C. § 3729(a)(1)(A), by 9 submitting claims for payment based upon falsified soil surveys, building surveys, and status 10 survey reports. Tetra Tech’s false or fraudulent claims include, but are not limited to, the 11 12 invoices identified on Exhibit 2. 13 75. As a result of the false or fraudulent claims presented or caused to be presented by 14 Tetra Tech, the United States paid Tetra Tech and suffered damages to be determined at trial. 15 Under the False Claims Act, the United States is entitled to three times the amount of damages it 16 sustained, plus civil penalties of not less than $5,500 and not more than $11,000 for each false 17 18 claim. 19 SECOND CAUSE OF ACTION 20 (False Claims Act: False Statement Material to a False Claim) 21 (31 U.S.C. § 3729(a)(1)(B)) 22 23 24 25 26 76. The United States repeats and re-alleges the preceding paragraphs as if fully set forth herein. 77. Tetra Tech made, used, or caused to be made or used, false records or statements material to false claims, in violation of 31 U.S.C. § 3729(a)(1)(B), by reporting false results from 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 29 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 30 of 32 1 2 3 4 5 soil and building surveys. Tetra Tech’s false records or statements material to false claims include, but are not limited to those reports identified on Exhibit 1. 78. As a result of the false records or statements made or used, or cause to be made or used, by Tetra Tech, the United States paid Tetra Tech and suffered damages to be determined at trial. Under the False Claims Act, the United States is entitled to three times the amount of 6 7 8 damages it sustained, plus civil penalties of not less than $5,500 and not more than $11,000 for each violation. 9 THIRD CAUSE OF ACTION 10 (Breach of Contract) 11 12 13 14 15 16 79. The United States repeats and re-alleges the preceding paragraphs as if fully set forth herein. 80. Each of the Relevant Contracts required Tetra Tech to perform soil and building surveys in accordance with MARSSIM and other contract specifications. 81. Based on the actions described above, Tetra Tech breached the Relevant 17 18 19 20 21 Contracts by falsifying soil samples, falsifying building scan data, and failing to perform full, complete, and accurate investigations of radiological contamination. 82. The United States has incurred damages, including consequential damages, as a result of Tetra Tech’s breaches of the Relevant Contracts. 22 23 24 25 PRAYER FOR RELIEF WHEREFORE, the United States demands and prays that judgment be entered in its favor against Defendant Tetra Tech EC, Inc. as follows: 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 30 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 31 of 32 1 1. On the First Cause of Action under the False Claims Act, for the amount of the United 2 States’ damages, trebled as required by law, and such civil penalties as are required by law, 3 together with such further relief as may be just and proper. 4 5 2. On the Second Cause of Action under the False Claims Act, for the amount of the United States’ damages, trebled as required by law, and such civil penalties as are required by 6 7 8 9 10 law, together with such further relief as may be just and proper. 3. On the Third Cause of Action for breach of contract, for an amount equivalent to the loss sustained by the United States, including consequential damages, plus interest, costs, and expenses, and for such further relief as may be just and proper. 11 12 13 14 15 16 17 18 19 DATED: January 14, 2019 Respectfully submitted, ALEX G. TSE United States Attorney /s/ Michael T. Pyle MICHAEL T. PYLE (CABN 172954) Assistant United States Attorney 150 Almaden Boulevard, Suite 900 San Jose, California 95113 Telephone: (408) 535-5087 FAX: (408) 535-5081 Email: michael.t.pyle@usdoj.gov 20 26 MICHAEL GRANSTON MICHAL TINGLE ROBERT CHANDLER Attorneys, Civil Division United States Department of Justice P.O. Box 261, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 514-4678 robert.chandler@usdoj.gov 27 Attorneys for the United States of America 21 22 23 24 25 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 31 Case 3:13-cv-03835-JD Document 28 Filed 01/14/19 Page 32 of 32 1 DEMAND FOR JURY TRIAL 2 3 4 Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the United States demands a jury trial in this action. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 DATED: January 14, 2019 Respectfully submitted, ALEX G. TSE United States Attorney /s/ Michael T. Pyle MICHAEL T. PYLE (CABN 172954) Assistant United States Attorney 150 Almaden Boulevard, Suite 900 San Jose, California 95113 Telephone: (408) 535-5087 FAX: (408) 535-5081 Email: michael.t.pyle@usdoj.gov MICHAEL GRANSTON MICHAL TINGLE ROBERT CHANDLER Attorneys, Civil Division United States Department of Justice P.O. Box 261, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 514-4678 robert.chandler@usdoj.gov 20 21 Attorneys for the United States of America 22 23 24 25 26 27 28 UNITED STATES’ COMPLAINT IN INTERVENTION, No. C 13-3835 JD 32 Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL NON-TIME-CRITICAL REMOVAL ACTION WORK PLAN FOR IR SITE 12 HOT SPOTS AND BUILDINGS 1121 AND 1323 April 2013 DCN: RMAC-0809-0013-0007 NON-TIME-CRITICAL REMOVAL ACTION FOR SOLID WASTE DISPOSAL AREA RADIOLOGICAL HOT SPOT REMOVAL AND BUILDING DEMOLITION INSTALLATION RESTORATION SITE 12 NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA TABLE OF CONTENTS PAGE ABBREVIATIONS AND ACRONYMS ...................................................................................... v 1.0 INTRODUCTION ............................................................................................................. 1-1 1.1 SITE CONDITIONS AND BACKGROUND ........................................................ 1-2 1.2 REGULATORY FRAMEWORK ........................................................................... 1-3 1.3 REMOVAL ACTION OBJECTIVES .................................................................... 1-3 1.4 RELEASE CRITERIA ............................................................................................ 1-4 1.5 AS LOW AS REASONABLY ACHIEVABLE ..................................................... 1-4 1.6 DATA QUALITY OBJECTIVES .......................................................................... 1-4 1.7 PROJECT POINTS OF CONTACT ....................................................................... 1-4 1.8 PROJECT SCHEDULE .......................................................................................... 1-4 1.9 WORK PLAN ORGANIZATION .......................................................................... 1-5 2.0 SITE WORK AND FIELD IMPLEMENTATION ........................................................... 2-1 2.1 PRECONSTRUCTION ACTIVITIES .................................................................... 2-1 2.1.1 Community Relations and Regulatory Interaction..................................... 2-1 2.1.2 Preconstruction Meeting ............................................................................ 2-2 2.1.3 Mobilization ............................................................................................... 2-2 2.1.4 Permitting and Notification ........................................................................ 2-2 2.1.5 Utility Clearance ........................................................................................ 2-2 2.1.6 Utility Protection ........................................................................................ 2-3 2.1.7 Site Survey/Environmental Conditions Report .......................................... 2-3 2.1.8 Preparation of Residential Buildings ......................................................... 2-4 2.2 RADIOLOGICAL STRUCTURE SURVEYS ....................................................... 2-4 2.3 HOT SPOT EXCAVATION NON-TIME-CRITICAL REMOVAL ACTION ..... 2-4 2.3.1 Hot Spot Excavations ................................................................................. 2-5 2.3.2 Final Status Survey .................................................................................... 2-6 2.3.3 Site Restoration .......................................................................................... 2-7 2.4 SOIL SCREENING OPERATIONS ....................................................................... 2-9 2.4.1 Screening Pad Construction ....................................................................... 2-9 2.4.2 Radiological Clearing of the Pad Material ................................................. 2-9 2.4.3 Pad Deconstruction and Site Restoration ................................................. 2-11 2.5 DEMOBILIZATION ............................................................................................ 2-11 3.0 ENVIRONMENTAL PROTECTION PLAN .................................................................... 3-1 3.1 STORMWATER MANAGEMENT MEASURES................................................. 3-1 3.1.1 Best Management Practices for Construction Activities ........................... 3-1 3.1.2 Best Management Practices for Erosion and Sediment Control ................ 3-3 3.1.3 Best Management Practices for Soil Stockpile Areas ................................ 3-4 3.1.4 Postconstruction Best Management Practices............................................ 3-5 3.2 FUGITIVE DUST CONTROL MEASURES ......................................................... 3-5 RMAC-0809-0013-0007 Fn Work Plan.doc i Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 TABLE OF CONTENTS (Continued) PAGE 3.3 3.4 3.5 3.2.1 Construction Traffic ................................................................................... 3-5 3.2.2 Site Preparation and Remediation Activities ............................................. 3-6 3.2.3 Building Demolition .................................................................................. 3-7 3.2.4 Bulk Soil Transport .................................................................................... 3-7 3.2.5 Postconstruction Stabilization of Disturbed Areas .................................... 3-8 AIR MONITORING ............................................................................................... 3-8 3.3.1 Air Quality Monitoring .............................................................................. 3-8 3.3.2 Monitoring Site Locations ......................................................................... 3-9 3.3.3 Personnel Monitoring ............................................................................... 3-10 SPILL/RELEASE PREVENTION, RESPONSE, AND REPORTING ............... 3-11 3.4.1 Spill/Release Prevention .......................................................................... 3-11 3.4.2 Spill/Release Response ............................................................................ 3-11 3.4.3 Spill/Release Reporting............................................................................ 3-11 WASTE MANAGEMENT PRACTICES ............................................................. 3-12 4.0 TRAFFIC CONTROL ....................................................................................................... 4-1 4.1 REVISED SITE TRAFFIC ROUTES .................................................................... 4-1 4.2 TRAFFIC CONTROLS .......................................................................................... 4-1 5.0 DATA AND INFORMATION MANAGEMENT ............................................................ 5-1 6.0 REPORTING ..................................................................................................................... 6-1 6.1 FINAL STATUS SURVEY REPORTS ................................................................. 6-1 6.2 REMOVAL ACTION COMPLETION REPORT .................................................. 6-1 7.0 REFERENCES................................................................................................................... 7-1 TABLES Table 3-1 Sampling Frequency and Monitoring Methods RMAC-0809-0013-0007 Fn Work Plan.doc ii Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 TABLE OF CONTENTS (Continued) FIGURES Figure 1-1 Regional Location Map Figure 1-2 Site Location Map Figure 1-3 Project Organization Chart Figure 1-4 Project Schedule Figure 2-1 Air Monitoring Station Locations Figure 3-1 Track-Out Control Points and Traffic Routes APPENDICES Appendix A BMP Fact Sheets (on CD only) Appendix B Response to Comments ATTACHMENTS Attachment 1 Sampling and Analysis Plan Attachment 2 Project Contractor Quality Control Plan Attachment 3 Radiation Protection Plan Attachment 4 Radiological Management Plan Attachment 5 Waste Management Plan RMAC-0809-0013-0007 Fn Work Plan.doc iii Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 1.0 INTRODUCTION The Department of the Navy (DON) contracted with Tetra Tech EC, Inc. (TtEC) to conduct a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) NonTime-Critical Removal Action (NTCRA) within the Westside Drive Solid Waste Disposal Area (SWDA) A & B at Installation Restoration (IR) Site 12 located at Naval Station Treasure Island (NAVSTA TI), San Francisco, California. This work will be executed under Contract No. N62473-10-D-0809, Contract Task Order (CTO) No. 0013. TtEC will perform the IR Site 12 NTCRA using their State of California Agreement State Radioactive Materials License No. 7909-01. The field activities to be performed under this CTO will be performed under the second phase of the NTCRA at IR Site 12 SWDA A & B. The scope of this NTCRA will be to: • Remove two hot spots identified in the California Department of Public Health (CDPH) Site 12 Gamma Survey Report (CDPH 2011). • Perform a radiological survey and demolish Buildings 1121 and 1323. To perform this work, the following plans will be used in conjunction with the site-specific information provided in this NTCRA Work Plan: • Health and Safety Plan: NAVSTA TI (TtEC 2012) • Task-specific Plan: Task-specific Plan for the Buildings 1121 and 1323 Characterization Survey, NAVSTA TI (TtEC 2013a) • Buildings 1121 and 1323 Demolition Work Procedure: Buildings 1121 and 1323 Demolition Work Procedure, NAVSTA TI (TtEC 2013b) Accident Prevention Plan/Site Safety and Health Plan, This NTCRA Work Plan provides site-specific information not included in the above-referenced plans or attachments listed below. The site-specific information addresses the following: • Dust control and air monitoring requirements specific to the work locations • Stormwater management requirements and Best Management Practices (BMPs) to be implemented during construction activities • Traffic routes and measures for maintaining access for site tenants, residents, and other DON contractors during construction activities • Data management requirements and procedures The following five additional documents have been developed and are presented as attachments to this NTCRA Work Plan: RMAC-0809-0013-0007 Fn Work Plan.doc 1-1 Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 1.1 • Sampling and Analysis Plan (SAP) (Attachment 1) • Project Contractor Quality Control (PCQC) Plan (Attachment 2) • Radiation Protection Plan (Attachment 3) • Radiological Management Plan (Attachment 4) • Waste Management Plan (Attachment 5) SITE CONDITIONS AND BACKGROUND NAVSTA TI is located in San Francisco Bay, midway between San Francisco and Oakland, California (Figure 1-1). The former naval station consists of two contiguous islands: Treasure Island, which is approximately 403 acres, and Yerba Buena Island, which is approximately 147 acres. Treasure Island is a manmade island constructed of materials dredged from the bay. Military activities at the former NAVSTA TI date back to 1866, before the construction of Treasure Island, when the U.S. government took possession of Yerba Buena Island for defensive fortifications. In 1993, NAVSTA TI was designated for closure under the Base Closure and Realignment Act of 1990. The naval station was closed on September 30, 1997, and is currently in the transfer process. IR Site 12 is located on the northwest portion of NAVSTA TI on a relatively flat 93-acre area (Figure 1-2). The site consists of multiplex housing units with private backyards and common area front yards, side yards, and surrounding greenbelts. The area was originally used as a parking lot during the 1939–1940 Golden Gate International Exposition. After Navy occupation of the island in 1940, the area was developed for bunker storage of munitions and other materials, vehicle equipment and storage, recreational playing fields, and disposal or burning of solid waste. Beginning in the1960s, areas of IR Site 12 were incrementally developed into housing for Navy personnel and their dependents. Former residential Buildings 1121 and 1323 are located within IR Site 12 near Westside Drive. An NTCRA was implemented in May 2006 to remediate chemicals in soil associated with chemical/fuel storage and disposal or burning of solid waste in four SWDAs (SWDA A & B, SWDA 1231/1233, SWDA 1207/1209, and SWDA Bigelow Court) located within IR Site 12 (Figure 1-2). A Historical Radiological Assessment (HRA) (Weston 2006) identified the radiological contamination potential for the SWDAs as “unlikely” and recommended radiation monitoring during excavation of identified SWDAs. During the initial stages of this NTCRA, a radiation survey and sample analysis identified radium-226 (Ra-226)-impacted debris and soil in some of the SWDAs. Subsequently, an Action Memorandum (DON 2007) summarizing the site characteristics identified the chemicals of potential concern (COPCs) and the horizontal extent of the SWDAs. Generally, the radiological contamination in IR Site 12 SWDAs is colocated with chemical contaminants. The NTCRAs at IR Site 12 determined that some of the SWDAs were contaminated with radiological items or soil containing Ra-226. Elevated gamma readings were RMAC-0809-0013-0007 Fn Work Plan.doc 1-2 Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 also detected along the northern and southern fence lines (two areas) of SWDA A & B by the CDPH Radiologic Health Branch during a gamma survey conducted in April 2011. The current scope of work is to investigate and remediate these two areas with elevated gamma readings. The Westside Drive SWDA, also known as SWDA A & B, is an approximately 4.5-acre area on the west side of IR Site 12 abutting Perimeter Road (Figure 1-2). Two radiological hot spots were identified near the Westside Drive SWDA along the northern and southern fence lines during the 2011 CDPH survey of this area. The source of radioactivity is believed to be nearsurface radiological commodities containing Ra-226 (deck markers, foils containing radium powder, instrument gauges) but may include limited pockets of soil contamination. Based on CDPH’s report, there is one area of elevated activity north of the currently established Radiologically Controlled Area (RCA) (Northern Hot Spot) and four locations of elevated activity south of the RCA (Southern Hot Spot) (Figure 1-2). This NTCRA focuses only on radiological contamination in the two radiological hot spots. The ongoing NTCRA activities in the center of SWDA A & B are currently being performed by another contractor under a separate contract. 1.2 REGULATORY FRAMEWORK Environmental investigation and remediation activities at NAVSTA TI are being conducted under the Department of Defense IR Program in accordance with CERCLA and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Under Executive Order 12580, the DON is the lead agency responsible for implementation of the IR Program and any removal actions. The California Department of Toxic Substances Control is the lead regulatory agency. The CDPH and Regional Water Quality Control Board San Francisco Bay Region will provide additional state regulatory oversight. 1.3 REMOVAL ACTION OBJECTIVES Based on past site history and results from ongoing NTCRAs, the DON has determined that chemical contamination present in soil and debris at the four SWDAs at IR Site 12 requires a response action. This decision was documented in the final Action Memorandum (AM) (DON 2007) and is consistent with the NCP requirements in Title 40 Code of Federal Regulations (CFR), Part 300.415(b)(2). The removal action objectives for remediation activities are to implement the AM Alternative 3 and protect public health and welfare and the environment by physically removing and disposing of contaminated soil and debris that exceed the criteria for the COPCs presented in Section 2.1.4 of the AM (DON 2007). This work is being performed by another contractor under a separate contract. The removal action objectives for this NTCRA are to address radiological contamination in SWDA A & B, which includes 1) performing hot spot removal in two areas until the release criterion for Ra-226 is achieved and then performing an FSS for free release of these two hot spots; and 2) demolishing Buildings 1121 and 1323. Prior to demolition of the buildings, RMAC-0809-0013-0007 Fn Work Plan.doc 1-3 Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 radiological surveys of the interiors and exteriors will be performed to determine whether radiologically impacted soil has been tracked into the buildings or whether the wind has deposited radiologically impacted soil onto the exterior surfaces. 1.4 RELEASE CRITERIA Residual levels of radioactive material that correspond to allowable radiation dose standards are derived by analysis of various pathways and scenarios such as direct exposure, inhalation, and ingestion. Release limits are presented in terms of activity concentration and usually refer to average levels of radiation or radioactivity above appropriate background levels. Based on existing data, only one radionuclide of concern was identified for this site, Ra-226, and the release criterion for this isotope is 1 picocurie per gram above background for soil. The release criteria for building surfaces are 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha or 200 dpm/100 cm2 beta removable contamination, or 100 dpm/100 cm2 alpha or 1,000 dpm/100 cm2 beta fixed contamination. 1.5 AS LOW AS REASONABLY ACHIEVABLE A basic concept in radiation protection specifies that exposure to ionizing radiation and releases of radioactive material should be managed to reduce collective dose to workers and the public and ensure that exposure is as low as reasonably achievable (ALARA). The ALARA principle will be considered during the course of the radiological work carried out under this NTCRA Work Plan. 1.6 DATA QUALITY OBJECTIVES The data quality objectives (DQOs) specify project objectives, data collection boundaries and limitations, the most appropriate type of data to collect, and the level of acceptable decision error. In addition, the quality and quantity of data required to implement environmental removal actions are defined. The DQOs for the IR Site 12 NTCRA are identified and described in Worksheet #11 of the SAP (Attachment 1). 1.7 PROJECT POINTS OF CONTACT Figure 1-3 presents the key individuals who are responsible for the oversight and/or implementation of the site activities. Section 2.0 of the PCQC Plan describes the organizational structure, functional responsibilities, levels of authority, and lines of communication within the organization to ensure high-quality work. A listing of the points of contact for the project is also provided in the PCQC Plan. 1.8 PROJECT SCHEDULE Figure 1-4 presents the overall project schedule for completing the planning, hot spot removal, building survey and demolition, and reporting activities for this CTO. RMAC-0809-0013-0007 Fn Work Plan.doc 1-4 Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 1.9 WORK PLAN ORGANIZATION This NTCRA Work Plan is organized as follows: • Section 1.0 provides the introduction, site conditions and background, regulatory framework, removal action objectives, release criteria, ALARA concept, DQOs, project points of contact, and report organization. • Section 2.0 describes the site work and field implementation for the hot spot removals and demolition of Buildings 1121 and 1323. • Section 3.0 describes stormwater management measures, site-specific requirements for dust control during implementation of the site work, and spill/release prevention, response, and reporting. • Section 4.0 provides traffic control measures to be implemented during construction activities. • Section 5.0 provides detail on the types of data to be collected over the course of the CTO and the procedures for the management of the data. • Section 6.0 presents details for project reporting. • Section 7.0 lists the references cited in the text. • Tables and figures are included after the text. • Appendix A provides the BMP Fact Sheets. • Appendix B includes the responses to comments on the draft version of this NTCRA Work Plan. • Attachment 1 presents the SAP. This plan details laboratory operations that will support the survey activities. Included are procedures for swipe sample analysis, soil sample preparation, gamma spectroscopy analysis, and quality checks. • Attachment 2 presents the PCQC Plan. This plan establishes specific procedures and methods for field inspections, and provides an effective quality control system to ensure the quality of all work performed by TtEC and its subcontractor personnel during the implementation of the hot spot removal and building demolition. • Attachment 3 presents the Radiation Protection Plan. This plan identifies the day-to-day management of radiologically impacted sites, remediation, surveys, training requirements, health and safety concerns, and material handling requirements for this project. • Attachment 4 presents the Radiological Management Plan. This plan presents the survey and decontamination procedures and methodologies that will be implemented in support of radiological release of buildings, sites, structures, areas, materials and equipment, and personnel at NAVSTA TI. • Attachment 5 presents the Waste Management Plan. This plan presents the waste management practices and procedures to be followed, and identifies the types of waste expected to be generated. RMAC-0809-0013-0007 Fn Work Plan.doc 1-5 Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 § ¦ ¨ LARKSPUR MILL VALLEY 580 RICHMOND PLEASANT HILL § ¦ ¨ 80 101 £ ¤ § ¦ ¨ CLAYTON 680 EL CERRITO WALNUT CREEK TAMALPAISHOMESTEAD VALLEY NAVAL STATION TREASURE ISLAND ! (1 SAUSALITO ALBANY LAFAYETTE DETAIL AREA ORINDA BERKELEY 24 ! ( ALAMO MORAGA § ¦ ¨ CA L PIEDMONT 80 IF 13 ! ( O RN I A DANVILLE OAKLAND ! ( 1 SAN FRANCISCO § ¦ ¨ 580 ALAMEDA SAN RAMON § ¦ ¨ § ¦ ¨ 880 101 £ ¤ 280 SAN LEANDRO CASTRO VALLEY DALY CITY PACIFIC OCEAN 580 SAN LORENZO SOUTH SAN FRANCISCO SAN FRANCISCO BAY 35 ! ( HAYWARD 92 ! ( SAN BRUNO PACIFICA § ¦ ¨ ! ( 238 MILLBRAE UNION CITY BURLINGAME § ¦ ¨ 82 ! ( 880 HILLSBOROUGH § ¦ ¨ 280 1 ! ( º FOSTER CITY 84 ! ( FREMONT NEWARK BELMONT 92 ! ( HALF MOON BAY SAN CARLOS § ¦ ¨ 680 £ ¤ 101 REDWOOD CITY NORTH FAIR OAKS EAST PALO ALTO MENLO PARK 0 2.5 Miles LEGEND ! (1 STATE HIGHWAY 101 £ ¤ US HIGHWAY § ¦ ¨ INTERSTATE HIGHWAY 280 5 NAVAL STATION TREASURE ISLAND WATER BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA NTCRA WORK PLAN INSTALLATION RESTORATION SITE 12 FIGURE 1-1 REGIONAL LOCATION MAP NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CALIFORNIA REVISION: AUTHOR: DMACK DCN: P:\GIS\projects\Treasure Island\Fig1-1 Regional Location Map - Treasure Island (NTCRA).mxd SAN MATEO LEGEND: CDPH Elevated Activity Data Sample ID Longitude 77 -122.3780747 78 -122.3780826 82 -122.3781783 83 -122.3781904 84 -122.378509 Source: CDPH 2011 Latitude 37.82557866 37.82557246 37.825522 37.82554082 37.8281435 Exposure Rate Exposure Rate one meter contact (µR/hr) (µR/hr) 8 800 8 11 6.5 90 6 28 12.5 600 Dose Rate one meter (µrem/hr) Dose Rate contact (µrem/hr) 4 4 4 5 5 500 13 80 10 450 Gamma Count Rate contact (cpm) 349224 53735 155981 24428 880097 BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA NTCRA WORK PLAN INSTALLATION RESTORATION SITE 12 FIGURE 1-2 SITE LOCATION MAP NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-NTCRA_Figure 1-2.dwg 9/27/12 FIGURE 1-3 PROJECT ORGANIZATION CHART QUALITY ASSURANCE OFFICER Joseph Michalowski NAVFAC SW REMEDIAL PROJECT MANAGER Dave Clark/Tony Konzen NAVFAC SW ENVIRONMENTAL PROTECTION MANAGER Zachary Edwards, RASO CSO Doug DeLong ROICCs Gary Munekawa David Smith NAVFAC SF BAY NAVY PROJECT TEAM PROJECT MANAGER Bill Dougherty CERTIFIED HEALTH PHYSICIST/RSO Erik Abkemeier QC PROGRAM MANAGER Greg Joyce PROGRAM CHEMIST Lisa Bienkowski PROJECT CHEMIST Sabina Sudoko Project Engineer Sam Ho, PE LABORATORY COORDINATOR Rick Weingarz PROJECT QC MANAGER Rich Kanaya ALTERNATE Adam Berry DATA MANAGER Terry Sindelar Curtis & Tompkins Ltd/ TestAmerica RADIATION SAFETY OFFICER REPRESENTATIVE Adam Berry SUPERINTENDENT Dennis McWade/ Chris Hanif CONSTRUCTION SUPPORT STAFF SUBCONTRACTORS Legend Abbreviations and Acronyms: CSO – Contractor Site Office NAVFAC SW – Naval Facilities Engineering Command Southwest NTCRA – Non-Time-Critical Removal Action RASO – Radiological Affairs Support Office ROICC – Resident Officer in Charge of Construction RSO – Radiation Safety Officer QC – quality control SF – San Francisco Formal reporting relationship RADIOLOGICAL TASK SUPERVISORS PROGRAM ENVIRONMENTAL SAFETY MANAGER Roger Margotto SITE SAFETY AND HEALTH OFFICER Dan Keenan RADIOLOGICAL CONTROL TECHNICIANS Staff in shaded boxes are responsible for field implementation of activities under the NTCRA Work Plan. The Construction Manager (Jeff Bray) has overall responsibility for coordinating the activities of on-site technical staff. Supporting relationship Primary lines of technical communication Line of technical direction (alternate where dashed) Final NTCRA Work Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 ID 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Task Name Duration GENERAL Contract Award Field Work Notice to Proceed Project Complete Project Management/Administrative Support PTO X002 NTCRA for SWDA - Radiological Hot Spot Removal and Building Demolition IR 12 Project Meetings Kick off meeting 386 days 0 days 0 days 0 days 550 edays 311 days Tue 8/21/12 Mon 8/20/12 Wed 4/24/13 Thu 1/16/14 Mon 8/20/12 Mon 8/20/12 Fri 2/21/14 Mon 8/20/12 Wed 4/24/13 Thu 1/16/14 Fri 2/21/14 Wed 11/6/13 311 days 6 days Mon 8/20/12 Thu 8/30/12 Wed 11/6/13 Fri 9/7/12 1 day 5 days 284 days 168 days 1 day 1 day 1 day 1 day Thu 8/30/12 Fri 8/31/12 Wed 9/5/12 Tue 2/19/13 Tue 2/19/13 Tue 4/16/13 Tue 6/18/13 Tue 10/15/13 Thu 8/30/12 Fri 9/7/12 Tue 10/15/13 Tue 10/15/13 Tue 2/19/13 Tue 4/16/13 Tue 6/18/13 Tue 10/15/13 275 days Wed 9/5/12 Wed 10/2/13 103 days 1 day 1 day 1 day 1 day 275 days 1 day 1 day 1 day 1 day 1 day Wed 11/7/12 Wed 11/7/12 Wed 2/6/13 Wed 3/6/13 Wed 4/3/13 Wed 9/5/12 Wed 9/5/12 Fri 3/1/13 Wed 5/1/13 Wed 6/5/13 Wed 10/2/13 Wed 4/3/13 Wed 11/7/12 Wed 2/6/13 Wed 3/6/13 Wed 4/3/13 Wed 10/2/13 Wed 9/5/12 Fri 3/1/13 Wed 5/1/13 Wed 6/5/13 Wed 10/2/13 Prepare NTCRA Work Plan and Supporting Documents Work Plan w/SAP, RPP, EPP (DMP and SWMP), CQCP, Demolition Work Procedure, RMP, Project Management, WMP, Traffic Plan, Data Management Plan Work Plan 133 days 169 days Mon 8/20/12 Mon 8/20/12 Tue 2/26/13 Wed 4/17/13 169 days Mon 8/20/12 Wed 4/17/13 Prepare Internal Draft Work Plan Navy Review of Internal draft Work Plan (60 days per SMP for RASO Review) Prepare Draft Work Plan (7 days after Navy comments per SMP) 29 days 49 days Mon 8/20/12 Mon 10/1/12 Fri 9/28/12 Fri 12/7/12 5 days Mon 12/10/12 Fri 12/14/12 Regulator Review of Draft Work Plan (30 days per SMP) Develop/Submit Internal Final Work Plan and RTCs/Participate in Working Meeting w Navy/Agencies (33 days per SMP) Navy Review of Internal Final Work Plan (14 days per SMP) Develop/Submit Final Work Plan to Agencies (14 days per SMP) Agency Review of Final Work Plan (14 days per SMP; Plan finalized if no comments received within 14 days per SMP) 34 days 39 days Mon 12/17/12 Tue 2/5/13 Mon 2/4/13 Fri 3/29/13 3 days 3 days 10 days Mon 4/1/13 Mon 4/1/13 Thu 4/4/13 Wed 4/3/13 Wed 4/3/13 Wed 4/17/13 81 days Mon 8/20/12 Wed 12/12/12 27 days 48 days Mon 8/20/12 Thu 9/27/12 Wed 9/26/12 Tue 12/4/12 6 days Wed 12/5/12 Wed 12/12/12 Attend Meeting (Meeting date TBD by the RPM) Meeting minutes (within 10 days of meeting) Community Relations and Regulatory Interaction RAB Meetings (3rd Tues pm, Every other Month) RAB Meeting 1 - Present Draft Work Plan and RTCs RAB Meeting 2 - Update on field activities RAB Meeting 3 - Update on field activities RAB Meeting 4 - Present Draft RACR and RTCs BCT Meetings (1st Wed every month) BCT Monthly Meetings BCT Monthly Meeting 1 (San Francisco) BCT Monthly Meeting 2 (San Francisco) BCT Monthly Meeting 3 (San Francisco) BCT Monthly Meeting 4 (San Francisco) BCT Technical Meetings BCT Technical Meeting 1 - Work Plan Scoping BCT Technical Meeting 2 - Work Plan RTC Meeting BCT Technical Meeting 3 - TBD by Navy BCT Technical Meeting 4 - TBD by Navy BCT Technical Meeting 5 - RACR RTC Meeting Site Safety and Health / Accident Prevention Plan (SSHP/APP) 41 42 Prepare Internal Draft SSHP/APP NMPHC / RPM / NAVFAC SW Safety Office Review Draft SSHP/APP 43 Prepare Final SSHP/APP Plan Project: CTO 0013 Draft NAVSTA TI I Date: Tue 3/26/13 Start Finish Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Task Rolled Up Task Inactive Task Manual Task Start-only Critical Task Rolled Up Critical Task Inactive Task Duration-only Finish-only Milestone Rolled Up Progress Inactive Milestone Manual Summary Rollup Progress Summary Group By Summary Inactive Summary Manual Summary Figure 1-4 Project Schedule NTCRA Work Plan Naval Station Treasure Island, San Francisco, CA Jul Aug Sep Oct Nov Dec Jan Feb Mar ID 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Task Name Duration 0 days 6 days Start Tue 12/4/12 Wed 12/5/12 Finish Tue 12/4/12 Wed 12/12/12 36 days Wed 2/27/13 Wed 4/17/13 5 days Thu 4/18/13 Wed 4/24/13 2 days Thu 4/25/13 Fri 4/26/13 26 days 2 days Mon 4/29/13 Mon 4/29/13 Tue 6/4/13 Tue 4/30/13 3 days 2 days 23 days 1 day Wed 5/1/13 Mon 5/6/13 Wed 5/1/13 Tue 6/4/13 Fri 5/3/13 Tue 5/7/13 Mon 6/3/13 Tue 6/4/13 119 days 3 days 116 days Wed 5/1/13 Wed 5/1/13 Mon 5/6/13 Thu 10/17/13 Fri 5/3/13 Thu 10/17/13 116 days 8 days Mon 5/6/13 Mon 5/6/13 Thu 10/17/13 Wed 5/15/13 44 days Thu 5/16/13 Thu 7/18/13 Prepare Draft FSS (14 days after Navy comments) Agency Review of Draft FSS (30 days per SMP) Develop Final FSS and RTCs/Participate in Working Meeting w Navy/Agencies (33 days per SMP) Final FSS (14 days after Regulatory/Public Concurrence on RTCs) 9 days 21 days 25 days Fri 7/19/13 Thu 8/1/13 Fri 8/30/13 Wed 7/31/13 Thu 8/29/13 Fri 10/4/13 9 days Mon 10/7/13 Thu 10/17/13 Issue Final FSS 0 days 48 days 10 days 15 days 21 days Thu 10/17/13 Wed 3/13/13 Mon 4/29/13 Mon 4/29/13 Mon 5/20/13 Thu 10/17/13 Fri 5/17/13 Fri 5/10/13 Fri 5/17/13 Tue 6/18/13 2 days 40 days 1 day Wed 6/19/13 Mon 4/29/13 Tue 6/25/13 Thu 6/20/13 Mon 6/24/13 Tue 6/25/13 Submit RTC's for Navy Review/Approval Issue Final SSHP/APP Plan Field Work "Implement the NTCRA Work Plan" Receive Notice to Proceed Mobilization Site Work - Removal Activities Radiological Soil Screening / Excavation of Hot Spots / Remediate / Spread Material on Pad Scan / Sample Pad Material / Remediate Backfill Excavations / Site Restoration Waste Characterization and Disposal Scan Ground Surface after Pad Removal Implement Final Status Survey at Westside Drive Hotspots Survey / Sample Excavated Hot Spots Final Status Survey Report FSS Report for Hot Spots Prepare Internal Draft FSS (no later than 60 days after FSS confirmation results received) Navy Review of Internal Draft FSS (60 day RASO Review per SMP) Demolition of Buildings 1121 and 1323 Asbestos and Lead Abatement M&E / Building Surveys Navy and CDPH Review of Survey Data / CDPH Perform Confirmatory Survey Building Demolition Waste Management and Disposal Demobilization Removal Action Completion Reports (RACR) 144 days Wed 6/26/13 Thu 1/16/14 Prepare Internal Draft RACR (no later than 60 days after building demolition/debris disposed) Navy Review of Internal draft RACR (60 day RASO Review per SMP) 21 days Wed 6/26/13 Thu 7/25/13 44 days Fri 7/26/13 Thu 9/26/13 Prepare Draft RACR(7 days after Navy comments per SMP) Regulator Review of Draft RACR (30 days per SMP) Develop/Submit Internal Final RACR and RTCs/Participate in Working Meeting w/ Navy/Agencies (33 days per SMP) Navy Review of Internal Final RACR (14 days per SMP) Develop/Submit Final RACR to Agencies (14 days per SMP) Agency Review of Final RACR (14 days per SMP; RACR finalized if no comments received within 14 days) 4 days 21 days 24 days Fri 9/27/13 Thu 10/3/13 Fri 11/1/13 Wed 10/2/13 Thu 10/31/13 Thu 12/5/13 10 days 10 days 10 days Fri 12/6/13 Fri 12/20/13 Fri 1/3/14 Thu 12/19/13 Thu 1/2/14 Thu 1/16/14 Project: CTO 0013 Draft NAVSTA TI I Date: Tue 3/26/13 Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Task Rolled Up Task Inactive Task Manual Task Start-only Critical Task Rolled Up Critical Task Inactive Task Duration-only Finish-only Milestone Rolled Up Progress Inactive Milestone Manual Summary Rollup Progress Summary Group By Summary Inactive Summary Manual Summary Figure 1-4 Project Schedule NTCRA Work Plan Naval Station Treasure Island, San Francisco, CA Jul Aug Sep Oct Nov Dec Jan Feb Mar LEGEND: BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA NTCRA WORK PLAN INSTALLATION RESTORATION SITE 12 FIGURE 2-1 AIR MONITORING STATION LOCATIONS NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-NTCRA_Figure 2-1.dwg 9/26/12 LEGEND: BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA NTCRA WORK PLAN INSTALLATION RESTORATION SITE 12 FIGURE 3-1 TRACK-OUT CONTROL POINTS AND TRAFFIC ROUTES NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-Figure 3-1.dwg 9/25/12 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 EXECUTIVE SUMMARY The Department of the Navy (DON) has contracted with Tetra Tech EC, Inc. (TtEC) to perform a non-time-critical removal action (NTCRA) involving the removal of two radiological hot spots identified in the California Department of Public Health (CDPH) Site 12 Gamma Survey Report (CDPH 2011) and the demolition of Buildings 1121 and 1323 within Installation Restoration (IR) Site 12, Naval Station Treasure Island (NAVSTA TI), San Francisco, California. This work will be conducted under Contract No. N62473-10-D-0809, Contract Task Order (CTO) No. 0013 and under TtEC’s State of California Agreement State Radioactive Materials License No. 7909-01. This Sampling and Analysis Plan (SAP) (Attachment 1 of the NTCRA Work Plan) has been prepared by TtEC to provide guidance on sampling, analysis, and quality control (QC) in support of remediation activities under this CTO. The quality assurance (QA)/QC elements in this SAP were prepared in accordance with the U.S. Environmental Protection Agency (EPA) Uniform Federal Policy for Quality Assurance Project Plans (EPA 2005) and Requirements for Quality Assurance Project Plans, EPA QA/R-5, QAMS (EPA 2006a) to ensure that all data collected are precise, accurate, representative, complete, and comparable to meet their intended use. TtEC will use two laboratories to perform the analyses required for the remediation activities at IR Site 12. The primary laboratory used to perform radiological analyses for screening, as well as definitive data, is located at Hunters Point Naval Shipyard and is managed by Curtis and Tompkins, Ltd. as a subcontractor to TtEC. (This facility is a satellite laboratory for Curtis and Tompkins, Ltd., as their main laboratory is located in Berkeley, California.) This satellite laboratory (hereinafter referred to as Curtis and Tompkins) has received accreditation by the Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) and the CDPH National Environmental Laboratory Accreditation Program (NELAP) for gamma spectroscopy (which includes radium-226 [Ra-226]) and gross alpha/gross beta analysis of solid and swipe samples. Radiological analyses not listed in Curtis and Tompkins’ DoD ELAP and CDPH NELAP accreditation and any chemical analyses discussed in this SAP will be performed by TestAmerica-St. Louis laboratory. TestAmerica-St.Louis has DoD ELAP and CDPH NELAP accreditation for all the radiological and chemical methods listed in this SAP. Further details on each laboratory are provided in SAP Worksheet #30. BACKGROUND NAVSTA TI is located in San Francisco Bay, midway between San Francisco and Oakland, California. The former naval station consists of two contiguous islands: Treasure Island, which is approximately 403 acres, and Yerba Buena Island, which is approximately 147 acres. Treasure Island is a manmade island constructed of materials dredged from the bay. Military activities at the former NAVSTA TI date back to 1866, before the construction of Treasure Island, when the U.S. government took possession of Yerba Buena Island for defensive fortifications. In 1993, NAVSTA TI was designated for closure under the Base Closure and Realignment Act of 1990. The naval station was closed on September 30, 1997, and is currently in the transfer process. RMAC-0809-0013-0007 Final SAP.docx Page 3 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 IR Site 12 is located on the northwest portion of NAVSTA TI on a relatively flat 93-acre area as illustrated on Figure 1. The site consists of multiplex housing units with private backyards and common area front yards, side yards, and surrounding greenbelts. The area was originally used as a parking lot during the 1939–1940 Golden Gate International Exposition. After Navy occupation of the island in 1940, the area was developed for bunker storage of munitions and other materials, vehicle equipment and storage, recreational playing fields, and disposal or burning of solid waste. Beginning in the1960s, areas of IR Site 12 were incrementally developed into housing for Navy personnel and their dependents. Former residential Buildings 1121 and 1323 are located within IR Site 12 near Westside Drive. An NTCRA was implemented in May 2006 to remediate chemicals in soil associated with chemical/fuel storage and disposal or burning of solid waste in four Solid Waste Disposal Areas (SWDAs) (SWDA A & B, SWDA 1231/1233, SWDA 1207/1209, and SWDA Bigelow Court) located within IR Site 12. A Historical Radiological Assessment (HRA) (Weston 2006) identified the radiological contamination potential for the SWDAs as “unlikely” and recommended radiation monitoring during excavation of identified SWDAs. During the initial stages of this NTCRA, a radiation survey and sample analysis identified radium-226 (Ra-226)impacted debris and soil in some of the SWDAs. Subsequently, an Action Memorandum (DON 2007) summarizing the site characteristics identified the chemicals of potential concern (COPCs) and the horizontal extent of the SWDAs. Generally, the radiological contamination in IR Site 12 SWDAs is colocated with chemical contaminants. The NTCRAs at IR Site 12 determined that some of the SWDAs were contaminated with radiological items or soil containing Ra-226. Elevated gamma readings were also detected along the northern and southern fence lines (two areas) of SWDA A & B by the CDPH Radiologic Health Branch (RHB) during a gamma survey conducted in April 2011. The work described herein will investigate and remediate these two areas with elevated gamma readings. PROJECT SCOPE The Westside Drive SWDA, also known as SWDA A & B, is an approximately 4.5-acre area on the west side of IR Site 12 abutting Perimeter Road. Two radiological hot spots were identified in the Westside Drive SWDA during the 2011 CDPH survey of this area. The source of radioactivity is believed to be near-surface radiological commodities containing Ra-226 (deck markers, foils containing radium powder, instrument gauges) but may include limited pockets of soil contamination. Based on CDPH’s report, there is one area of elevated activity north of the currently established Radiologically Controlled Area (RCA) (Northern Hot Spot) and four locations of elevated activity south of the RCA (Southern Hot Spot). This NTCRA focuses only on radiological contamination in the two radiological hot spots. The ongoing NTCRA activities in the center of SWDA A & B are currently being performed by another contractor under a separate contract. Also included in this CTO is the demolition of Buildings 1121 and 1323, which are located within SWDA A & B near Westside Drive. The scope for building demolition will include asbestos abatement of these structures by a TtEC subcontractor; radiological surveys of the buildings to determine radiological impact (if any) using AEC Regulatory Guide 1.86 established RMAC-0809-0013-0007 Final SAP.docx Page 4 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 in the IR Site 12 NTCRA Work Plan (Shaw 2007) and as described in the DON-approved TSP and technical support from the DON’s RASO; demolition of the structures; disposal of debris characterized below the radiological release limit for NAVSTA TI into a California landfill or appropriate out-of-state landfill; and transfer of debris above the radiological release limit to the DON’s low-level radioactive waste (LLRW) contractor for disposal. REMOVAL ACTION OBJECTIVES Based on past site history and results from ongoing NTCRAs, the DON has determined that chemical contamination present in soil and debris at the four SWDAs at IR Site 12 requires a response action. This decision was documented in the AM (DON 2007) and is consistent with the National Oil and Hazardous Substances Pollution Contingency Plan requirements in Title 40 Code of Federal Regulations, Part 300.415(b)(2). The removal action objectives for remediation activities are to implement the AM Alternative 3 and protect public health and welfare and the environment by physically removing and disposing of contaminated soil and debris that exceed the criteria for the COPCs presented in Section 2.1.4 of the AM (DON 2007). This work is being performed by another contractor under a separate contract. After the results of ongoing NTCRAs and the CDPH gamma survey report (CDPH 2011) identified radiological contamination in SWDA A & B, the DON initiated an NTCRA, which TtEC will conduct under this CTO. This NTCRA includes 1) performing hot spot removal in two areas until the release criterion of 1 picocurie per gram above background for Ra-226 is achieved and then performing an FSS for free release of these two hot spots; and 2) demolishing Buildings 1121 and 1323. Prior to demolition of Buildings 1121 and 1323, radiological surveys of the interiors and exteriors will be performed to determine whether radiologically contaminated soil has been tracked into the buildings or whether the wind has deposited radiologically contaminated soil onto the exterior surfaces. Any areas exceeding the surface release criteria of 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha or 200 dpm/100 cm2 beta removable contamination, or 100 dpm/100 cm2 alpha or 1,000 dpm/100 cm2 beta fixed contamination will be remediated and transferred to the DON’s LLRW contractor for disposal. REGULATORY OVERSIGHT Environmental investigation and remediation activities are being conducted at NAVSTA TI under the DoD IR Program in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act and the NCP. Under Executive Order 12580, the DON is the lead agency responsible for implementation of the IR Program and any removal actions. The California Department of Toxic Substances Control is the lead regulatory agency. The CDPH and the Regional Water Quality Control Board San Francisco Bay Region will provide additional state regulatory oversight. RMAC-0809-0013-0007 Final SAP.docx Page 5 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheets Page #1 – Title and Approval Page ......................................................................................................... 1 #2 – SAP Identifying Information ................................................................................................ 13 #3 – Distribution List .................................................................................................................... 17 #4 – Project Personnel Sign-Off Sheet ......................................................................................... 21 #5 – Project Organizational Chart................................................................................................. 23 #6 – Communication Pathways .................................................................................................... 25 #7 – Personnel Responsibilities and Qualifications Table ............................................................ 29 #8 – Special Personnel Training Requirements Table .................................................................. 35 #9 – Project Scoping Session Participants Sheet .......................................................................... 37 #10 – Problem Definition.............................................................................................................. 39 #11 – Project Quality Objectives/Systematic Planning Process Statements ................................ 41 #12 – Measurement Performance Criteria Table for Soil Samples .............................................. 47 #13 – Secondary Data Criteria and Limitations Table.................................................................. 49 #14 – Summary of Project Tasks .................................................................................................. 51 #15.1 – Reference Limits and Evaluation Table for Soil/Swipe Samples .................................... 57 #15.2 – Reference Limits and Evaluation Table for Water Samples ............................................ 71 #16 – Project Schedule / Timeline Table ...................................................................................... 79 #17 – Sampling Design and Rationale .......................................................................................... 81 #18 – Sampling Locations and Methods/SOP Requirements Table ............................................. 87 #19 – Analytical SOP Requirements Table .................................................................................. 89 #20 – Field Quality Control Sample Summary Table .................................................................. 93 #21 – Project Sampling SOP References Table ............................................................................ 95 #22 – Field Equipment Calibration, Maintenance, Testing, and Inspection Table....................... 97 #23 – Analytical SOP References Table ....................................................................................... 99 #24 – Analytical Instrument Calibration Table .......................................................................... 101 #25 – Analytical Instrument and Equipment Maintenance, Testing, and Inspection Table ....... 107 #26 – Sample Handling System .................................................................................................. 111 #27 – Sample Custody Requirements Table ............................................................................... 113 #28.1 – Laboratory QC Samples Table – Soil ............................................................................ 117 #28.2 – Laboratory QC Samples Table – Water ......................................................................... 127 #29 – Project Documents and Records Table ............................................................................. 135 #30 – Analytical Services Table ................................................................................................. 143 #31 – Planned Project Assessments Table .................................................................................. 147 #32 – Assessment Findings and Corrective Action Responses .................................................. 149 #33 – QA Management Reports Table ....................................................................................... 151 #34 – Verification (Step I) Process Table ................................................................................... 153 #35 – Validation (Steps IIa and IIb) Process Table .................................................................... 155 #36 – Analytical Data Validation (Steps IIa and IIb) Summary Table....................................... 157 #37 – Usability Assessment ........................................................................................................ 159 References ................................................................................................................................... 161 RMAC-0809-0013-0007 Final SAP.docx Page 7 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 FIGURES Figure 1 Site Location Map APPENDICES (on CD only) Appendix A Appendix B Appendix C Appendix D TtEC Standard Operating Procedures DoD QSM TestAmerica-St. Louis Limits Analytical Laboratory Standard Operating Procedures Example of Chain-of-Custody, Sample Label, and Custody Seal RMAC-0809-0013-0007 Final SAP.docx Page 8 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #2 – SAP Identifying Information Site Name/Number: Contractor Name: Contract Number: Contract Title: Non-Time-Critical Removal Action for Solid Waste Disposal Area (SWDA) – Radiological Hot Spot Removal and Building Demolition, Installation Restoration (IR) Site 12, Naval Air Station Treasure Island (NAVSTA TI) Tetra Tech EC, Inc. (TtEC) N62473-10-D-0809 Radiological Environmental Multiple Award Contract 1. This Sampling and Analysis Plan (SAP) was prepared in accordance with the requirements of the Uniform Federal Policy for Quality Assurance Project Plans (EPA 2005) and U.S. Environmental Protection Agency (EPA) Guidance for Quality Assurance Project Plans, EPA QA/G-5, QAMS (EPA 2002). 2. Identify regulatory program: Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 3. This SAP is a project-specific SAP. 4. List dates of scoping sessions that were held. Scoping Session Date None 5. List dates and titles of any SAP documents written for previous site work that are relevant to the current investigation. Title Date None 6. List organizational partners (stakeholders) and connection with lead organization: The California Environmental Protection Agency (Cal/EPA), Department of Toxic Substances Control (DTSC), California Department of Public Health (CDPH), Regional Water Quality Control Board San Francisco Bay Region, Radiological Affairs Support Office (RASO), and United States Fish and Wildlife Service (for sensitive species) will provide regulatory oversight and guidance. 7. Lead organization: the DON 8. If any required SAP elements or required information is not applicable to the project or is provided elsewhere, then note the omitted SAP elements and provide an explanation for its exclusion below: • SAP Worksheet #8 (Special Personnel Training Requirements Table) is not applicable for this project as there are no special training requirements. • SAP Worksheet #12 (Measurement Performance Criteria Table) is applicable to the collection of field QC samples such as the following: rinsate blank sample collection RMAC-0809-0013-0007 Final SAP.docx Page 13 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #2 – SAP Identifying Information (Continued) from nondisposable sampling equipment to ensure that decontamination procedures are sufficiently adequate so that cross-contamination between samples is not occurring; field duplicate sample collection to document variability of the matrix being sampled. Rinsate blanks and field duplicates are not applicable to radiological projects since 1) radiological contaminants are not mobile like chemical contaminants; therefore, rinsate blanks are not needed to verify adequacy of decontamination procedures; and 2) variability of matrices such as soil are not required to meet the project objectives. • SAP Worksheet #13 (Secondary Data Criteria and Limitations Table) is not applicable for this project as secondary data evaluation is not required. SAP elements and required information that are not applicable to the project are noted below. An explanation is provided above and in the appropriate SAP worksheet(s), as necessary. UFP-QAPP Worksheet # Required Information Crosswalk to Related Information A. Project Management Documentation 1 Title and Approval Page 2 Table of Contents SAP Identifying Information 3 Distribution List 4 Project Personnel Sign-Off Sheet Project Organization 5 Project Organizational Chart 6 Communication Pathways 7 Personnel Responsibilities and Qualifications Table 8 Special Personnel Training Requirements Table Not applicable Project Planning/Problem Definition 9 Project Planning Session Documentation (including Data Needs tables) Project Scoping Session Participants Sheet 10 Problem Definition, Site History, and Background Site Maps (historical and present) 11 Site-Specific Project Quality Objectives 12 Measurement Performance Criteria Table for Samples Not applicable 13 Sources of Secondary Data and Information Secondary Data Criteria and Limitations Table Not applicable 14 Summary of Project Tasks 15 Reference Limits and Evaluation Table 16 Project Schedule/Timeline Table B. Measurement Data Acquisition RMAC-0809-0013-0007 Final SAP.docx Page 14 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #2 – SAP Identifying Information (Continued) UFP-QAPP Worksheet # Required Information Crosswalk to Related Information Sampling Tasks 17 Sampling Design and Rationale 18 Sampling Locations and Methods/ SOP Requirements Table Sampling Location Map(s) 19 Analytical Methods/SOP Requirements Table 20 Field Quality Control Sample Summary Table 21 Project Sampling SOP References Table 22 Field Equipment Calibration, Maintenance, Testing, and Inspection Table Analytical Tasks 23 Analytical SOPs Analytical SOP References Table 24 Analytical Instrument Calibration Table 25 Analytical Instrument and Equipment Maintenance, Testing, and Inspection Table Sample Collection 26 Sample Handling System, Documentation Collection, Tracking, Archiving and Disposal Sample Handling Flow Diagram 27 Sample Custody Requirements, Procedures/SOPs Sample Container Identification Example Chain-of-Custody Form and Seal Quality Control Samples 28 QC Samples Table Screening/Confirmatory Analysis Decision Tree Data Management Tasks 29 Project Documents and Records Table 30 Analytical Services Table Analytical and Data Management SOPs C. Assessment Oversight 31 Planned Project Assessments Table Audit Checklists 32 Assessment Findings and Corrective Action Responses Table 33 QA Management Reports Table D. Data Review 34 Verification (Step I) Process Table 35 Validation (Steps IIa and IIb) Process Table 36 Validation (Steps IIa and IIb) Summary Table 37 Usability Assessment RMAC-0809-0013-0007 Final SAP.docx Page 15 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #3 – Distribution List The following distribution list represents the recipients of the final version of this SAP. Name of SAP Recipients Title/Role Organization Mr. Dave Clark Lead Remedial Project Manager (RPM) Mr. Tony Konzen RPM Mr. Zachary Edwards Radiological Environmental Protection Manager RASO Mr. Joseph Michalowski Quality Assurance Officer (QAO) Telephone Number Base Realignment and Closure (619) 532-0973 (BRAC) Program Management Office (PMO) BRAC PMO (619) 532-0924 (757) 887-7762 Naval Facilities Engineering Command Southwest (NAVFAC SW) NAVFAC SW (619) 532-4125 Ms. Diane Silva Administrative Record Manager Mr. Doug DeLong Caretakers Support Office (CSO) BRAC PMO West CSO San Francisco Bay Area (415) 743-4713 Ms. Remedios (Medi) Sunga Lead RPM Cal/EPA DTSC (510) 540-3840 Ms. Myriam Zech RPM (510) 622-5684 Mr. David Stensby RPM Regional Water Quality Control Board San Francisco Bay Region EPA RMAC-0809-0013-0007 Final SAP.docx (619) 556-1280 (415) 972-3246 Mailing and E-mail Address 1455 Frazee Road, Suite 900 San Diego, CA 92108-4310 dave.j.clark2@navy.mil 1455 Frazee Road, Suite 900 San Diego, CA 92108-4310 anthony.konzen.ctr@navy.mil NAVSEA DET RASO P.O. Drawer 260, Building 1971 NWS Yorktown, VA 23691-0260 zachary.edwards@navy.mil 1220 Pacific Coast Highway San Diego, CA 92132 joseph.michalowski@navy.mil 1220 Pacific Highway Code EV33, NBSD Bldg. 3519 San Diego, CA 92132 diane.silva@navy.mil 410 Palm Ave, Building 1, Ste.161 San Francisco, CA 94130-1806 douglas.delong@navy.mil 700 Heinz Ave., Bldg. F, Suite 200 Berkeley, CA 94710-2721 rsunga@dtsc.ca.gov 1515 Clay Street, Suite 1400 Oakland, CA 94612 mzech@waterboards.ca.gov 75 Hawthorne Street, SFD-8-1 San Francisco, CA 94105-3901 stensby.david@epa.gov Page 17 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #3 – Distribution List (Continued) Name of SAP Recipients Title/Role Organization Telephone Number Mr. Larry Morgan Project Manager (PjM) CDPH (916) 449-5921 Mr. Gene Forrer Health Physicist CDPH (510) 620-3744 Mr. Gary Munekawa Resident Officer in Charge of Construction (ROICC) NAVFAC SW (650) 603-9834 Mr. David Smith ROICC NAVFAC SW (650) 603-9836 Mr. Bill Dougherty Project Manager (PjM) TtEC (415) 216-2731 Mr. Erik Abkemeier Radiation Safety Officer (RSO) TtEC (757) 466-4906 Mr. Adam Berry Radiation Safety Officer Representative (RSOR) TtEC (713) 410-7928 RMAC-0809-0013-0007 Final SAP.docx Mailing and E-mail Address Environmental Management Branch 1616 Capital Avenue; MS 7402 P.O. Box 997413 Sacramento, CA 95899-7377 larry.morgan@cdph.ca.gov Radiologic Health Branch 850 Marina Way Pkwy, Bldg P, 1st Floor Richmond, CA 94804-6403 eugene.forrer@cdph.ca.gov NAVFAC SW P.O. Box 68, Building 107 Moffett Field, CA 94035 gary.munekawa@navy.mil NAVFAC SW P.O. Box 68, Building 107 Moffett Field, CA 94035 david.r.smith2@navy.mil 200 Fisher Avenue San Francisco, CA 94124 bill.dougherty@tetratech.com Twin Oaks, Suite 309 5700 Lake Wright Drive Norfolk, VA 23502 erik.abkemeier@tetratech.com 200 Fisher Avenue San Francisco, CA 94124 adam.berry@tetratech.com Page 18 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #3 – Distribution List (Continued) Mr. Greg Joyce Quality Control Program Manager (QCPM) TtEC (360) 780-0371 Mr. Richard Kanaya Project Quality Control Manager (PQCM) TtEC (415) 216-2759 Ms. Lisa Bienkowski Program Chemist TtEC (949) 809-5028 Ms. Sabina Sudoko Project Chemist TtEC (949) 809-5022 Mr. Richard Weingarz Laboratory Coordinator TtEC (415) 216-2733 Mr. Phil Smith Laboratory Supervisor Curtis and Tompkins (415) 216-2768 Ms. Erika Starman Laboratory Project Manager TestAmerica-St. Louis (314) 298-8566 Ms. Linda Rauto Data Validator Project Manager Laboratory Data Consultants (LDC) (760) 634-0437 RMAC-0809-0013-0007 Final SAP.docx 1230 Columbia St., Suite 750 San Diego, CA 92101 greg.joyce@tetratech.com 200 Fisher Avenue San Francisco, CA 94124 rich.kanaya@tetratech.com 17885 Von Karman Ave., Suite 500 Irvine, CA 92614 lisa.bienkowski@tetratech.com 17885 Von Karman Ave., Suite 500 Irvine, CA 92614 sabina.sudoko@tetratech.com 200 Fisher Avenue San Francisco, CA 94124 richard.weingarz@tetratech.com 201A & 201B Fisher Avenue San Francisco, CA 94124 phil.smith@ctberk.com 13715 Rider Trail North Earth City, MO 63045 erika.starman@testamericainc.com 7750 El Camino Real, Suite 2L Carlsbad, CA 92009 lrauto@lab-data.com Page 19 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #4 – Project Personnel Sign-Off Sheet The key personnel listed below will read the final version of this SAP. Their signature and date will be filled in below and included in the project file. Name Organization/Title/Role Signature/E-mail Receipt SAP Section Reviewed Mr. Bill Dougherty TtEC/PjM Entire document Mr. Adam Berry TtEC/RSOR Entire document Mr. Richard Kanaya TtEC/PQCM Entire document Ms. Sabina Sudoko TtEC/Project Chemist Entire document Mr. Richard Weingarz TtEC/Laboratory Coordinator Entire document Mr. Phil Smith Curtis and Tompkins/Laboratory Supervisor Entire document Ms. Erika Starman TestAmerica-St. Louis / Laboratory Project Manager Entire document Ms. Linda Rauto LDC/Data Validator Project Manager Entire document TtEC/Field Crews Entire document TBD a Date SAP Read Notes: a Field crews include multiple persons and vary from project to project. Therefore, persons identified by the PQCM will read the SAP and sign this worksheet as required. RMAC-0809-0013-0007 Final SAP.docx Page 21 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #5 – Project Organizational Chart Lines of Authority Lines of Communication Mr. Zachary Edwards Mr. Tony Konzen Mr. Joseph Michalowski RASO BRAC PMO RPM NAVFAC SW QAO (619) 532-0924 (619) 532-4125 Mr. Gary Munekawa Mr. David Smith Mr. Greg Joyce NAVFAC SW ROICCs (360) 780-0371 (757) 887-7762 Mr. Gene Forrer CDPH-RHB (510) 620-3744 Ms. Remedios (Medi) Sunga Cal/EPA DTSC RPM (510) 540-3840 TtEC QCPM (650) 603-9834 (650) 603-9836 Mr. Bill Dougherty TtEC PjM Mr. Erik Abkemeier (415) 216-2731 Mr. Richard Kanaya TtEC PQCM Ms. Lisa Bienkowski (415) 216-2759 TtEC RSO (757) 466-4906 TtEC Program Chemist Mr. Richard Weingarz TtEC Laboratory Coordinator (415) 216-2733 (949) 809-5028 Ms. Sabina Sudoko TtEC Project Chemist (949) 809-5022 Mr. Phil Smith Curtis and Tompkins Laboratory Supervisor (415) 216-2768 RMAC-0809-0013-0007 Final SAP.docx Ms. Erika Starman/TestAmerica-St. Louis Laboratory Project Manager (314) 298-8566 Ms. Linda Rauto/LDC Data Validator Project Manager (760) 634-0437 Page 23 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #6 – Communication Pathways Communication Drivers Responsible Affiliation Name Phone Number Procedure Point of contact for DON quality issues NAVFAC SW QAO Mr. Joseph Michalowski (619) 532-4125 SAP and its addendum (if applicable) will be approved by the QAO prior to start of sampling. If during sampling, a major change in sampling procedures or strategy is required, the QAO will be notified via e-mail and give concurrence to issue a field change request or SAP addendum. In addition, the QAO has the authority to suspend project execution if quality assurance requirements are not adequately followed. Point of contact for contractor quality issues TtEC QCPM Mr. Greg Joyce (360) 780-0371 The QCPM is responsible for overseeing program quality control (QC), including construction and analytical data acquisition. The QCPM has the authority to suspend project activities if quality standards are not maintained. Project management TtEC PjM Mr. Bill Dougherty (415) 216-2731 If changes are necessary, the PjM is responsible for communicating the changes via phone and/or e-mail to the project staff and is authorized to stop work, if necessary. SAP review and radiological concurrence RASO Mr. Zachary Edwards (757) 887-7762 The RASO will review and concur with the SAP as related to the radiological aspects of NAVSTA TI. SAP review TtEC Program Chemist TtEC QCPM Ms. Lisa Bienkowski (949) 809-5028 The SAP will be written by the Program Chemist and reviewed by the QCPM prior to submittal to the NAVFAC SW QAO for review. Mr. Greg Joyce (360) 780-0371 Notification of nonusable analytical results TtEC Program Chemist Ms. Lisa Bienkowski (949) 809-5028 If significant problems are identified by the laboratories or the project team that impact the usability of the analytical results (i.e., the result is rejected or data quality objectives are not met), the Program Chemist will notify the NAVFAC SW RPM and QAO within 24 hours. RMAC-0809-0013-0007 Final SAP.docx Page 25 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #6 – Communication Pathways (Continued) Communication Drivers Responsible Affiliation Name Coordination of laboratory supplies for field sampling activities TtEC Project Chemist or TtEC Laboratory Coordinator Ms. Sabina Sudoko Submittal of samples to the laboratories TtEC Laboratory Coordinator Mr. Richard Weingarz Reporting laboratory data quality issues or analytical corrective actions Curtis and Tompkins Laboratory Supervisor Mr. Phil Smith TestAmerica-St. Louis Laboratory Project Manager Field corrective actions TtEC PQCM RMAC-0809-0013-0007 Final SAP.docx Mr. Richard Weingarz Ms. Erika Starman Mr. Richard Kanaya Phone Number Procedure (949) 809-5022 The Project Chemist will contact TestAmerica-St. Louis to provide any necessary sample containers and appropriate (415) 216-2733 shipping materials (such as coolers and bubble wrap) to be delivered on-site prior to commencement of field sampling activities and throughout the course of the project. The Laboratory Coordinator will ensure that Curtis and Tompkins provides necessary sample containers for analyses that they will perform. (415) 216-2733 The samplers will either transfer samples to Curtis and Tompkins or ship samples to TestAmerica-St. Louis at the end of each day. These activities will be overseen by the Laboratory Coordinator. For any samples shipped to TestAmerica-St. Louis, the Laboratory Coordinator will inform the Project Chemist. (415) 216-2768 All Curtis and Tompkins data quality issues will be reported in writing by the Laboratory Supervisor to the RSO and Program Chemist within 24 hours. All TestAmerica-St. Louis data quality issues will be reported in writing by the Laboratory Project Manager to the Project Chemist and Program Chemist within 24 hours. Any corrective actions will be documented and verified (314) 298-8566 by the Program Chemist who will notify in writing the QCPM, RSO, and PjM. The PjM will notify the BRAC PMO RPM and RASO. (415) 216-2759 All field corrective actions will be documented in writing by the PQCM who will notify in writing the QCPM, RSO, and PjM. The PjM will notify the BRAC PMO RPM and RASO. Page 26 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #6 – Communication Pathways (Continued) Communication Drivers Release of Curtis and Tompkins analytical results Responsible Affiliation TtEC RSO Release of TtEC Project TestAmerica-St. Louis Chemist analytical results Review of radiological data and concurrence on radiological actions SAP procedure revision during field activities SAP addendums RMAC-0809-0013-0007 Final SAP.docx RASO TtEC Program Chemist TtEC Program Chemist Phone Number Procedure (757) 466-4906 The RSO (or designee) will review Curtis and Tompkins analytical results to verify that the requirements in this SAP have been met prior to releasing the data to the project team for evaluation. Ms. Sabina Sudoko (949) 809-5022 The Project Chemist will review TestAmerica-St. Louis analytical results to verify that the requirements in this SAP have been met prior to releasing the data to the project team for evaluation. Mr. Zachary Edwards (757) 887-7762 The RASO will review all appropriate radiological data provided by the RSO (or designee) and will provide concurrence with actions proposed. Ms. Lisa Bienkowski (949) 809-5028 The Program Chemist (or designee) will prepare a Field Change Request (FCR) for any minor changes in sampling procedures that occur due to conditions in the field. Ms. Lisa Bienkowski (949) 809-5028 Significant changes to the SAP such as additional scope of work that is not covered in this SAP will require that the Program Chemist prepare a SAP addendum, which will be reviewed and approved by the NAVFAC SW QAO prior to initiating the affected field activities. Name Mr. Erik Abkemeier Page 27 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table Name Mr. Joseph Michalowski Title/Role QAO Organizational Affiliation NAVFAC SW • • • • • • Mr. Greg Joyce QCPM TtEC • • • • Mr. Tony Konzen RPM BRAC PMO Mr. Bill Dougherty PjM TtEC RMAC-0809-0013-0007 Final SAP.docx • • • • • • • • • • • • Responsibilities Reviewing and approving this SAP Providing DON oversight of TtEC’s Quality Assurance (QA) Program Providing technical and administrative oversight of TtEC’s surveillance audit activities Acting as point of contact for matters concerning QA and the Department of Defense’s (DoD) Laboratory QA Program Coordinating training on matters pertaining to generation and maintenance of quality of data Authorizing the suspension of project execution if QA requirements are not adequately followed Establishing and maintaining the Quality Program Overseeing program QC, including construction and analytical data acquisition Working directly with the PjM and the DON to ensure implementation of the program QC Plans Acting as a focal point for coordination for quality matters across all projects and resolving quality issues Suspending project activities if quality standards are not maintained Interfacing with the DON, including NAVFAC SW QAO, on quality-related items Conducting field QC audits to ensure project plans are being followed Performing reviews of audit and surveillance reports conducted by others Implementing the DON technical direction letters related to quality topics Approving any FCRs and reviewing addendums to the SAP Performing project management for the DON Ensuring that the project scope of work requirements are fulfilled Overseeing the project cost and schedule Providing formal technical direction to the TtEC project team, as needed Acting as lead interface with agencies Coordinating work activities of subcontractors and TtEC personnel, and ensuring that Page 29 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table (Continued) Name Title/Role Organizational Affiliation • • • • • • • • RMAC-0809-0013-0007 Final SAP.docx Responsibilities all personnel adhere to the administrative and technical requirements of the project Monitoring and reporting the progress of work, and ensuring that the project deliverables are completed on time and within project budget Monitoring the budget and schedule, and notifying the RPM of any changes that may require administrative actions Ensuring adherence to the quality requirements of the contract, project scope of work, and the QC plans Ensuring that all work meets the requirements of the technical specifications and complies with applicable codes and regulations Ensuring that all work activities are conducted in a safe manner in accordance with the Site-Specific Safety and Health Plan, United States Army Corps of Engineers’ Safety and Health Requirements (Engineer Manual 385-1-1), and all applicable Occupational Safety and Health Administration (OSHA) regulations Serving as the primary contact between the DON and TtEC for actions and information related to the work and including appropriate TtEC technical personnel in the decisionmaking Coordinating satisfactory resolution and completion of evaluation and acceptance report for nonconformance reports Suspending project activities if standards are not maintained Page 30 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table (Continued) Name Title/Role Organizational Affiliation Mr. Zachary Edwards Radiological Environmental Protection Manager RASO Mr. Erik Abkemeier TtEC RMAC-0809-0013-0007 Final SAP.docx RSO Responsibilities • Reviewing radiological laboratory data on a routine basis • Reviewing and approving all radiological management plans and final reports • Providing review and concurrence on data for proposed radiological actions • Ensuring that all necessary sample results are provided and are consistent with proposed radiological actions • Comparing radiological data with the requirements of the NTCRA Work Plan, Taskspecific Plans, and SAP to ensure that all proper conditions have been met to implement the action requested • Overseeing overall radiological operations and documentation for the project • Supporting projects as the technical lead for radiological data collection and analysis • Ensuring that RSOR and field sampling personnel have adequate training in radiological sample collection • Receiving and reviewing radiological data from the laboratories to ensure the data quality objectives have been met • Reviewing and evaluating scan survey data and requiring additional scan data, as necessary The RSO (or designee) will also perform the following: • Concurring on the identification of elevated areas for collection of biased samples and the locations of systematic samples including plotting of those samples on maps • Overseeing the preparation of a remediation plan and the performance of remediation activities (including evaluating biased sampling data) when sampling activities indicate the presence of radioactive materials at levels above the release criteria • Recommending radiological activities to the RASO for concurrence including additional sampling, backfilling of trenches, identification of material that can be used as backfill, etc. • Identifying samples to be forwarded to TestAmerica-St. Louis laboratory for additional radiological testing not performed by Curtis and Tompkins Page 31 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table (Continued) Name Mr. Adam Berry Ms. Lisa Bienkowski Title/Role RSOR Program Chemist Organizational Affiliation TtEC TtEC • • • • • • • • • • • Mr. Richard Weingarz Laboratory Coordinator TtEC • • • RMAC-0809-0013-0007 Final SAP.docx Responsibilities Supervising day-to-day radiological operations Ensure site activities are in compliance with State of California Agreement State Radioactive Materials License No. 7909-01. Overseeing performance of radiological static surveys Developing the SAP and any addendums to the SAP Implementing contract requirements for data collection Supporting projects as the technical lead for data collection and analysis Evaluating and selecting qualified laboratories and third-party data validation subcontractor Providing oversight of the laboratories with regards to deliverable requirements for samples representing definitive data Monitoring performance of the laboratories and data validator Overseeing preparation of the Navy Electronic Data Deliverable (NEDD) deliverable to the Naval Installation Restoration Information Solution (NIRIS) website of the analytical results Coordinating submittal of hard-copy analytical data packages with DON Administrative Record Overseeing submittal of samples to Curtis and Tompkins or TestAmerica-St. Louis laboratories. Prioritizing sample analyses, as necessary Coordinating shipment of samples to TestAmerica-St. Louis for analysis with the Project Chemist Page 32 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table (Continued) Name Ms. Sabina Sudoko Title/Role Project Chemist Organizational Affiliation TtEC • • • • Mr. Phil Smith Laboratory Supervisor Curtis and Tompkins • • • • • • • RMAC-0809-0013-0007 Final SAP.docx Responsibilities Tracking samples sent to TestAmerica-St. Louis to ensure laboratory receipt of samples and proper login of samples for analysis Tracking receipt of analytical results from TestAmerica-St. Louis Reviewing TestAmerica-St. Louis analytical results against requirements in this SAP prior to distribution to the project team Coordinating with Laboratory Coordinator regarding deliverables for Curtis and Tompkins results that represent definitive data Coordinating third-party data validation of all definitive laboratory data Reviewing data validation reports Coordinating upload of electronic data to database Providing day-to-day technical and administrative oversight of the laboratory including sample login, preparation, and analysis Performing periodic source checks, background checks and detector calibrations. Reviewing sample analytical results prior to release to project team to ensure the SAP requirements are met Ensuring that reporting requirements are in conjunction with SAP Worksheets #15.1, 28.1, and 29 Page 33 of 162 Project-Specific SAP Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 Final Sampling and Analysis Plan Revision Number: N/A Revision Date: N/A CTO No. 0013 SAP Worksheet #7 – Personnel Responsibilities and Qualifications Table (Continued) Name Ms. Erika Starman Title/Role Organizational Affiliation Laboratory TestAmericaProject Manager St. Louis • • • • Ms. Linda Rauto Data Validator LDC Project Manager • • RMAC-0809-0013-0007 Final SAP.docx Responsibilities Coordinating with the Project Chemist regarding sample receipt and discrepancies Ensuring samples are logged in according to the chain of custody (COC) Checking that analytical results are produced in accordance with this SAP and providing those results to the Project Chemist at the expected turnaround time Ensuring that analytical data packages and electronic deliverable requirements are in accordance with SAP Worksheet #29 Coordinating with Project Chemist regarding data validation requirements in accordance with this SAP Providing data validation reports and electronic deliverables to the Project Chemist in accordance with this SAP Page 34 of 162 LEGEND: CDPH Elevated Activity Data Sample ID Longitude 77 -122.3780747 78 -122.3780826 82 -122.3781783 83 -122.3781904 84 -122.378509 Source: CDPH 2011 Latitude 37.82557866 37.82557246 37.825522 37.82554082 37.8281435 Exposure Rate Exposure Rate one meter contact (µR/hr) (µR/hr) 8 800 8 11 6.5 90 6 28 12.5 600 Dose Rate one meter (µrem/hr) Dose Rate contact (µrem/hr) 4 4 4 5 5 500 13 80 10 450 Gamma Count Rate contact (cpm) 349224 53735 155981 24428 880097 BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA NTCRA SAMPLING AND ANALYSIS PLAN INSTALLATION RESTORATION SITE 12 FIGURE 1 SITE LOCATION MAP NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-NTCRA_Figure 1-1.dwg 12/4/12 FIGURE 1-1 PROJECT ORGANIZATION CHART QUALITY ASSURANCE OFFICER Joseph Michalowski NAVFAC SW REMEDIAL PROJECT MANAGER Dave Clark/Tony Konzen NAVFAC SW ENVIRONMENTAL PROTECTION MANAGER Zachary Edwards, RASO CSO Doug DeLong ROICCs Gary Munekawa David Smith NAVFAC SF BAY NAVY PROJECT TEAM PROJECT MANAGER Bill Dougherty CERTIFIED HEALTH PHYSICIST/RSO Erik Abkemeier QC PROGRAM MANAGER Greg Joyce PROGRAM CHEMIST Lisa Bienkowski PROJECT CHEMIST Sabina Sudoko Project Engineer Sam Ho, PE LABORATORY COORDINATOR Rick Weingarz PROJECT QC MANAGER Rich Kanaya ALTERNATE Adam Berry DATA MANAGER Terry Sindelar Curtis & Tompkins Ltd/ TestAmerica RADIATION SAFETY OFFICER REPRESENTATIVE Adam Berry SUPERINTENDENT Dennis McWade/ Chris Hanif CONSTRUCTION SUPPORT STAFF SUBCONTRACTORS Legend Abbreviations and Acronyms: CSO – Contractor Site Office NAVFAC SW – Naval Facilities Engineering Command Southwest NTCRA – Non-Time-Critical Removal Action RASO – Radiological Affairs Support Office ROICC – Resident Officer in Charge of Construction RSO – Radiation Safety Officer QC – quality control SF – San Francisco Formal reporting relationship RADIOLOGICAL TASK SUPERVISORS PROGRAM ENVIRONMENTAL SAFETY MANAGER Roger Margotto SITE SAFETY AND HEALTH OFFICER Dan Keenan RADIOLOGICAL CONTROL TECHNICIANS Staff in shaded boxes are responsible for field implementation of activities under the NTCRA Work Plan. The Construction Manager (Jeff Bray) has overall responsibility for coordinating the activities of on-site technical staff. Supporting relationship Primary lines of technical communication Line of technical direction (alternate where dashed) Final Waste Management Plan Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0007 CTO No. 0013 Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL POST CONSTRUCTION SUMMARY REPORT FOR SOLID WASTE DISPOSAL AREA A&B NON-TIME CRITICAL REMOVAL ACTION PHASE II, AND RADIOLOGICAL REMOVAL NEAR BUILDINGS 1128, 1303, AND 1306 May 2014 DCN: RMAC-0809-0013-0011 INSTALLATION RESTORATION SITE 12 NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL POST CONSTRUCTION SUMMARY REPORT FOR SOLID WASTE DISPOSAL AREA A&B NON-TIME CRITICAL REMOVAL ACTION PHASE II, AND RADIOLOGICAL REMOVAL NEAR BUILDINGS 1128, 1303, AND 1306 May 2014 INSTALLATION RESTORATION SITE 12 NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA DCN: RMAC-0809-0013-0011 1230 Columbia Street, Suite 750 San Diego, California 92101-8536 Bill Dougherty TtEC Project Manager Erik Abkemeier, CHP, PE, CSP, CHMM TtEC Radiation Safety Officer May 9, 2014 Date May 9, 2014 Date EXECUTIVE SUMMARY This Post Construction Summary Report (PCSR) describes and summarizes the removal of soil from two locations with elevated gamma readings identified by the California Department of Public Health (CDPH) along the northern and southern Solid Waste Disposal Area (SWDA) A&B fence line. It also describes the radiological survey and demolition of Buildings 1121 and 1323 in SWDA A&B. These locations are within Installation Restoration (IR) Site 12 at Naval Station Treasure Island (NAVSTA TI) in San Francisco, California. The hot spot area radiological removal action was performed to protect public health and welfare and the environment from actual or potential releases of radiological contaminants as part of the ongoing non-time critical removal action (NTCRA) for IR Site 12. Buildings 1121 and 1323 were surveyed and demolished, except for the concrete foundations, to allow for the future removal of contaminated soil that may be present underneath the buildings. This PCSR does not address chemical contamination within SWDA A&B or potential radiological contamination present at other areas within the SWDAs. An NTCRA was started in 2007 to remediate chemicals in soil associated with chemical/fuel storage and disposal or burning of solid waste in four SWDAs (SWDA A&B, SWDA 1231/1233, SWDA 1207/1209, and SWDA Bigelow Court) within IR Site 12. During the initial stages of the NTCRA, a radiation survey and sample analysis identified radium-226 (Ra-226) commodities, impacted debris, and soil. Subsequently, radiological contamination has been addressed during the NTCRA for the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) contaminants. Because Buildings 1121 and 1323 are located within SWDA A&B, these buildings were radiologically scanned prior to demolition. This was to ensure that radiologically contaminated building debris would not end up in a California landfill. The IR Site 12 removal actions for SWDA A&B hot spot areas and the building survey and demolition activities were performed in accordance with the requirements of CERCLA of 1980 as amended by the Superfund Amendments and Reauthorization Act of 1986 and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan. The radiological work was performed under Tetra Tech EC, Inc.’s (TtEC’s) CDPH Service Provider Radioactive Material License. The NTCRA activities were performed between April 17, 2013 and December 23, 2013. Buildings 1121 and 1323 preparation, asbestos abatement, radiological survey, and demolition activities were conducted between April 17, 2013 and December 6, 2013, and the radiological hot spot removal activities were performed between May 30, 2013 and June 5, 2013. Site restoration activities were completed on December 11, 2013, and the transport and disposal of RMAC-0809-0013-0011 Fnl PCSR.docx ES-1 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 the wastes generated from the demolition of Buildings 1121 and 1323 were completed on December 23, 2013. As the area around Building 1121 and the laydown area, Lester Court, were not radiologically cleared, TtEC performed additional characterization surveys and soil sampling of the area around Building 1121 and characterization surveys at Lester Court to determine Radiation Work Permit requirements. The survey results indicated that these areas could be down posted from a Contaminated Area to a Radiologically Controlled Area. After preparation of Building 1121 for radiological surveys and completion of asbestos abatement by Bayview Environmental Services, Inc. (Bayview), radiological survey activities commenced on June 28, 2013, and the final survey data were collected on August 16, 2013. The survey data confirmed that the building had not been radiologically impacted. The survey results were below the release criteria of 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha or 1,000 dpm/100 cm2 beta removal contamination, or 100 dpm/100 cm2 alpha or 5,000 dpm/100 cm2 beta fixed contamination. Upon receipt of both CDPH’s and the Department of the Navy’s (DON’s) concurrence to proceed with demolition on September 6, 2013, this building was demolished except for the concrete foundation. The Building 1121 debris was shipped for off-site disposal between September 9, 2013 and December 23, 2013. A total of 29 household appliances were transported by Eighteen Trucking to Recology Hay Road Landfill; 161.61 tons of nonhazardous building demolition debris was transported by Eighteen Trucking and C&K Trucking to Recology Hay Road Landfill; 14.76 tons of building demolition debris with lead paint was transported by Sanchez Transport, Inc. to Clean Harbors Buttonwillow Landfill; 20 cubic yards of asbestos waste was transported by World Environmental and Energy to Recology Hay Road Landfill; and one 5-gallon bucket of universal waste was transported by Eighteen Trucking to Clean Harbors San Jose LLC. Site restoration activities were completed on September 20, 2013. After preparation of Building 1323 for radiological surveys and completion of asbestos abatement (not including the sheetrock and roof penetrations), radiological survey activities commenced on July 18, 2013, and the final survey data were collected on October 3, 2013. The survey data confirmed that the building had not been radiologically impacted. The survey results were below the release criteria of 20 dpm/100 cm2 alpha or 1,000 dpm/100 cm2 beta removal contamination, or 100 dpm/100 cm2 alpha or 5,000 dpm/100 cm2 beta fixed contamination. Upon DON concurrence to resume asbestos abatement activities on October 29, 2013, Bayview remobilized to Building 1323 and completed the abatement of the sheetrock and roof penetrations on November 20, 2013. Upon receipt of both CDPH’s and the DON’s concurrence to proceed with demolition on November 12, 2013 and November 21, 2013, respectively, this building was demolished except for the concrete foundation. The Building 1323 debris was shipped for off-site disposal between December 2, 2013 and December 23, 2013. A total of 144.32 tons of nonhazardous building demolition debris was RMAC-0809-0013-0011 Fnl PCSR.docx ES-2 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 transported by C&K Trucking, J&G Trucking, and H&J Trucking to Recology Hay Road Landfill; 230 cubic yards of asbestos waste was transported by World Environmental and Energy to Recology Hay Road Landfill; and two 55-gallon drums of asbestos mastic were transported by Bayview and KM Industrial, Inc. to Crosby and Overton, Inc. The universal waste present in the building was transported by Eighteen Trucking to Clean Harbors San Jose LLC along with the universal waste from Building 1121. The 29 household appliances located in Building 1323 were transported by Eighteen Trucking to Recology Hay Road Landfill for disposal along with the appliances from Building 1121. Site restoration activities were completed on December 11, 2013. Radiological surveys were conducted to identify the location of the two areas of elevated gamma activity identified by CDPH, which led to the identification of a total of nine discreet areas of elevated activity in close proximity. Soil removal was performed until the post-remediation soil samples indicated that all samples met the screening criterion of 1 picocurie per gram (pCi/g) above the NAVSTA TI background reference area of 0.7 pCi/g for Ra-226 and that the remaining Ra-226 concentration in the soil was similar to background concentrations. The maximum detected gross concentration in the post-remediation soil samples was 1.17 pCi/g. A total of twenty-two 5-gallon buckets of contaminated soil and one radium commodity were transferred to the DON’s low-level radioactive waste (LLRW) contractor, Environmental Management Services, for disposal as LLRW. With the removal of the radiologically impacted soil along the SWDA A&B fence line and the removal of Buildings 1121 and 1323, the project objectives have been achieved. The radiological removal action objective to protect public health and welfare and the environment from actual or potential releases of radiological contaminants has been achieved with the removal of the radiologically impacted soil along the SWDA A&B fence line. The project objective to allow access for future removal of contaminated soil that may be present underneath Buildings 1121 and 1323 has been achieved with the demolition and removal of these buildings. RMAC-0809-0013-0011 Fnl PCSR.docx ES-3 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY ..................................................................................................... ES-1 ABBREVIATIONS AND ACRONYMS ..................................................................................... iii 1.0 INTRODUCTION ............................................................................................................. 1-1 1.1 NAVAL STATION TREASURE ISLAND LOCATION AND DESCRIPTION ....................................................................................................... 1-1 1.2 IR SITE 12 HISTORY ............................................................................................ 1-2 1.3 RELEASE CRITERIA ............................................................................................ 1-3 1.4 PHOTOGRAPHS .................................................................................................... 1-3 1.5 PURPOSE AND ORGANIZATION OF REPORT ................................................ 1-3 2.0 REMOVAL ACTIONS...................................................................................................... 2-1 2.1 PRE-CONSTRUCTION ACTIVITIES .................................................................. 2-1 2.2 SWDA A&B HOT SPOT REMOVAL ACTIONS ................................................ 2-2 2.2.1 Pre-Removal Activities .............................................................................. 2-2 2.2.2 Hot Spot Removals .................................................................................... 2-3 2.2.3 Site Restoration .......................................................................................... 2-7 2.3 RADIOLOGICAL SURVEY AND DEMOLITION OF BUILDINGS 1121 AND 1323 ............................................................................................................... 2-8 2.3.1 Pre-Demolition Activities .......................................................................... 2-8 2.3.2 Building Demolition ................................................................................ 2-10 2.3.3 Site Restoration ........................................................................................ 2-11 3.0 SAMPLE DATA AND ANALYSIS ................................................................................. 3-1 3.1 HOT SPOT REMOVAL ......................................................................................... 3-1 3.1.1 Confirmation Soil Sample Data ................................................................. 3-1 3.1.2 Comparison with NAVSTA TI Ra-226 Background Concentrations ....... 3-1 3.2 BUILDINGS 1121 AND 1323................................................................................ 3-3 3.3 AS LOW AS REASONABLY ACHIEVABLE PROCESS ................................... 3-3 4.0 CONCLUSIONS ................................................................................................................ 4-1 5.0 REFERENCES................................................................................................................... 5-1 RMAC-0809-0013-0011 Fnl PCSR.docx i Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 TABLE OF CONTENTS (Continued) TABLES Table 3-1 Final Soil Sample Definitive Data Results FIGURES Figure 1-1 Figure 1-2 Figure 2-1 Figure 2-2 Figure 2-3 Regional Location Map Site Location Map Pre- and Post-Initial Hot Spot Removal Northern Hot Spot Removal Location Southern Hot Spot Removal Location PHOTOGRAPHS APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Appendix L Appendix M Appendix N Appendix O Field Change Requests (on CD only) Radiological Investigation and Source Removal on March 20 and 21, 2013 Report (on CD only) Asbestos Abatement Notifications and Documentation (on CD only) Permits, Notifications, Pre-Construction/Kick-Off Meeting Minutes, and 24- Hour Work Notice Fliers (on CD only) Calibration Certificates (on CD only) Air Monitoring Results (on CD only) Navy-Approved Import Material Acceptance Package (on CD only) DON-Approved Final Site Walk-Through Inspection Forms (on CD only) Building 1121 and Lester Court Characterization Surveys and Soil Sampling Results (on CD only) Material and Equipment Surveys (on CD only) Waste Disposal Documentation (not including asbestos) (on CD only) Buildings 1121 and 1323 Survey Results (on CD only) DON Notices to Proceed and CDPH Concurrences on Survey Data (on CD only) Final Definitive Soil Sample Ra-226 Results (on CD only) Response to Comments RMAC-0809-0013-0011 Fnl PCSR.docx ii Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 1.0 INTRODUCTION This Post Construction Summary Report (PCSR) describes and summarizes the removal of soil from two locations with elevated gamma readings identified by the California Department of Public Health (CDPH) along the northern and southern Solid Waste Disposal Area (SWDA) A&B fence line. It also describes the removal of five locations with elevated gamma readings identified by CDPH outside SDWA A&B, as well as describes the radiological survey and demolition of Buildings 1121 and 1323 in SWDA A&B. These locations are within Installation Restoration (IR) Site 12 at Naval Station Treasure Island (NAVSTA TI) in San Francisco, California. The hot spot area radiological removal action was performed to protect public health and welfare and the environment from actual or potential releases of radiological contaminants as part of the ongoing non-time critical removal action (NTCRA) for IR Site 12. Buildings 1121 and 1323 were surveyed and demolished to allow for the future removal of contaminated soil that may be present under the buildings. This PCSR does not address chemical contamination within SWDA A&B or potential radiological contamination present at other areas within the SWDAs. The Department of the Navy (DON), Naval Facilities Engineering Command Southwest, with the support of the Radiological Affairs Support Office (RASO) directed the IR Site 12 SWDA A&B hot spot area removal activities and building survey and demolition activities under Contract No. N62473-10-D-0809, Contract Task Order (CTO) No. 0013. The removal actions were performed in accordance with the final NTCRA Work Plan for IR Site 12 Hot Spots and Buildings 1121 and 1323 (TtEC 2013a), Task-Specific Plan for the Buildings 1121 and 1323 Characterization Survey (TtEC 2013b), Demolition Work Procedure for Buildings 1121 and 1323 (TtEC 2013c), Accident Prevention Plan/Site Safety and Health Plan (TtEC 2012), and Field Change Requests 2013-CTO13-001, 2013-CTO13-002, 2013-CTO13-003, and 2013CTO13-008 provided in Appendix A. The removal actions were performed in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The radiological work was performed under Tetra Tech EC, Inc.’s (TtEC’s) CDPH Service Provider Radioactive Material License (RML). 1.1 NAVAL STATION TREASURE ISLAND LOCATION AND DESCRIPTION NAVSTA TI is located in San Francisco Bay, midway between San Francisco and Oakland, California (Figure 1-1). The former naval station consists of two contiguous islands: Treasure Island, which is approximately 403 acres, and Yerba Buena Island, which is approximately RMAC-0809-0013-0011 Fnl PCSR.docx 1-1 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 147 acres. Treasure Island is a manmade island constructed of materials dredged from the bay. Military activities at the former NAVSTA TI date back to 1866, before the construction of Treasure Island, when the U.S. government took possession of Yerba Buena Island for defensive fortifications. In 1993, NAVSTA TI was designated for closure under the Base Closure and Realignment Act of 1990. The naval station was closed on September 30, 1997, and is currently in the transfer process. 1.2 IR SITE 12 HISTORY IR Site 12 is located on the northwest portion of NAVSTA TI on a relatively flat 93-acre area (Figure 1-2). The site consists of multiplex housing units with private backyards and common area front yards, side yards, and surrounding greenbelts. The area was originally used as a parking lot during the 1939–1940 Golden Gate International Exposition. After Navy occupation of the island in 1940, the area was developed for bunker storage of munitions and other materials, vehicle equipment and storage, recreational playing fields, and disposal or burning of solid waste. Beginning in the 1960s, areas of IR Site 12 were incrementally developed into housing for Navy personnel and their dependents. Former residential Buildings 1121 and 1323 are located within IR Site 12 near Westside Drive, within SWDA A&B (Figure 1-2). An NTCRA was started in 2007 to remediate chemicals in soil associated with chemical/fuel storage and disposal or burning of solid waste in four SWDAs (SWDA A&B, SWDA 1231/1233, SWDA 1207/1209, and SWDA Bigelow Court) located within IR Site 12. The four SWDAs were identified as the primary areas of release through evaluation of historical site data (aerial photographs, reports, and construction drawings) and site investigation (trenching, borings, inspection, and sample collection) (DON 2007). During the initial stages of the NTCRA, a radiation survey and sample analysis identified radium-226 (Ra-226) commodities, impacted debris, and soil. Subsequently, radiological contamination has been addressed during the NTCRA for the CERCLA contaminants. In April 2011, CDPH performed a gamma survey of publicly accessible areas around SWDA A&B (CDPH 2011) (Figure 1-2). Elevated gamma readings were detected along the northern and southern fence lines (two areas). The source of radioactivity was believed to be near-surface radiological commodities containing Ra-226 (e.g., deck markers, foils containing radium powder, and instrument gauges) and may include limited pockets of soil contamination. To ensure the health and safety of the public, fencing was installed around the locations with elevated readings. Buildings 1121 and 1323 are located within SWDA A&B. In mid-March 2013, CDPH selected areas to perform public health and screening activities within the accessible areas at IR Site 12. The screening results indicated the presence of Ra-226 at elevated readings at five locations. At the direction of the DON, TtEC performed an expedited radiological investigation and mitigation action on March 20 and March 21, 2013, to protect RMAC-0809-0013-0011 Fnl PCSR.docx 1-2 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 public health and welfare and the environment. The investigation and removal activities are summarized in the Radiological Investigation and Source Removal report provided in Appendix B. Due to site conditions identified during the NTCRA and the CDPH gamma survey report (CDPH 2011) identifying radiological contamination in SWDA A&B, the DON initiated this project. The project objectives for this phase of the NTCRA were to address radiological contamination in SWDA A&B by: 1) performing hot spot removal in two areas along the SWDA A&B fence line until the release criterion for Ra-226 was achieved and the results were similar to reference area results; and 2) demolishing Buildings 1121 and 1323, except for the concrete foundations, to allow future access to the soil underneath the buildings. 1.3 RELEASE CRITERIA The DON-established release criteria for Ra-226 in soil were 1 picocurie per gram (pCi/g) above the NAVSTA TI background reference area of 0.7 pCi/g for Ra-226 (Shaw 2012) and, at the request of CDPH, that the remaining Ra-226 concentration in the soil be similar to background concentrations. The release criteria established for the building surfaces based on the Atomic Energy Commission (AEC) Regulatory Guide 1.86 (AEC 1974) were 20 disintegrations per minute (dpm)/100 square centimeters (cm2) alpha or 1,000 dpm/100 cm2 beta removable contamination, or 100 dpm/100 cm2 alpha or 5,000 dpm/100 cm2 beta fixed contamination. 1.4 PHOTOGRAPHS A photographic record was used to document the work performed during the IR Site 12 SWDA A&B hot spot area removal activities, and building survey and demolition activities. Photographs are provided in a separate section of this PCSR prior to the appendices. 1.5 PURPOSE AND ORGANIZATION OF REPORT The purpose of this PCSR is to describe and summarize the NTCRA performed to protect public health and welfare and the environment from actual or potential releases of radiological contaminants from two locations along the SWDA A&B fence line and to allow future removal of contaminated soil that may be present underneath Buildings 1121 and 1323. This PCSR is organized as follows: • Section 1.0 Introduction – Section 1.0 provides project information including descriptions of NAVSTA TI and IR Site 12, removal action objectives, release criteria, fieldwork photographic documentation, and the purpose and organization of this PCSR document. • Section 2.0 Removal Actions – Section 2.0 provides a summary of the SWDA A&B hot spot and Buildings 1121 and 1323 removal actions. RMAC-0809-0013-0011 Fnl PCSR.docx 1-3 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 • Section 3.0 Sample Data and Analysis – Section 3.0 provides an evaluation of the survey and soil sample data compared to the release criteria and a discussion of how the field activities met the as low as reasonably achievable (ALARA) concept. • Section 4.0 Conclusions – Section 4.0 presents the conclusions to the IR Site 12 SWDA A&B hot spot and Building 1121 and 1323 removal activities. • Section 5.0 References – Section 5.0 lists the documents cited in this PCSR. • Appendix A – Appendix A contains copies of the Field Change Requests describing the DON-approved field changes implemented as compared to what was provided in the DON-approved project plans. • Appendix B – Appendix B contains the Radiological Investigation and Source Removal on March 20 and 21, 2013 Report for the expedited response action performed by TtEC to protect public health and welfare and the environment. • Appendix C – Appendix C contains copies of the asbestos abatement notifications submitted by Bayview Environmental, LLC (Bayview) and a report summarizing their abatement activities. • Appendix D – Appendix D contains copies of the various permits, notifications, pre-construction/kick-off meeting minutes, and 24-hour work notices submitted. • Appendix E – Appendix E contains copies of the calibration certificates for the instrumentation used during the survey activities. • Appendix F – Appendix F contains copies of the air monitoring data collected during the hot spot excavation and building demolition activities. • Appendix G – Appendix G contains a copy of the DON-approved import material acceptance package containing the results of the radiological, chemical, asbestos, and geotechnical analyses. • Appendix H – Appendix H contains copies of the DON-approved final site walk inspection forms documenting the DON’s concurrence that the field activities were completed in accordance with the CTO No. 0013 statement of work and the contract requirements have been met. • Appendix I – Appendix I contains the Building 1121 and Lester Court characterization survey and soil sampling results documenting that these areas could be down posted from a Contaminated Area to a Radiologically Controlled Area. • Appendix J – Appendix J contains the material and equipment survey data confirming that the 58 household appliances found within the two buildings were not radiologically impacted and could be transported for off-site disposal. • Appendix K – Appendix K contains copies of the profiles, manifests, bills of lading, and weight tickets for the wastes (not including asbestos containing material [ACM]) shipped for off-site disposal. • Appendix L – Appendix L contains the Buildings 1121 and 1323 Class 1 and Class 2 survey results documenting that these two buildings were not radiologically impacted. RMAC-0809-0013-0011 Fnl PCSR.docx 1-4 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 • Appendix M – Appendix M contains copies of the DON’s Notices to Proceed with demolition of Buildings 1121 and 1323 along with CDPH’s concurrence with the survey data indicating that the two buildings were not radiologically impacted. • Appendix N – Appendix N contains the final definitive data soil sample results from the soil remaining in the area of the former SWDA A&B hot spot locations. • Appendix O – Appendix O contains responses to regulatory agency comments on the draft version of this report. RMAC-0809-0013-0011 Fnl PCSR.docx 1-5 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 2.0 REMOVAL ACTIONS This phase of NTCRA activities was performed between April 17, 2013 and December 23, 2013. Buildings 1121 and 1323 preparation, asbestos abatement, radiological survey, and demolition activities were conducted between April 17, 2013 and December 6, 2013, and the radiological hot spot removal activities were performed between May 30, 2013 and June 5, 2013. Site restoration activities were completed on December 11, 2013. Transport and disposal of the waste streams generated from the building demolition activities were completed on December 23, 2013. The following sections provide a summary of the radiological survey, removal, demolition, site restoration, and transport and disposal activities performed to meet the removal objectives of this CTO. 2.1 PRE-CONSTRUCTION ACTIVITIES The following activities were conducted in preparation for the removal of the two radiologically elevated locations along the SWDA A&B fence line and radiological survey and demolition of Buildings 1121 and 1323: • On April 10, 2013, One Call notifications were submitted for the two hot spot locations; monthly updates were submitted through July 2013. • On May 1, 2013, a Treasure Island Dig Permit was submitted for the two hot spot locations. • On May 2 and 15, 2013, a pre-existing site conditions survey was performed; photographs of the existing conditions were submitted to the DON on May 22, 2013. • On May 6, 2013, a Builder and Contractors Application was submitted to the San Francisco Public Utilities Commission for use of a fire hydrant located at 1121 Westside Drive on May 6, 2013; approval was received on May 15, 2013. • On May 15, 2013, Bayview (asbestos abatement subcontractor) submitted its notification for friable asbestos removal for Buildings 1121 and 1323 to the Bay Area Air Quality Management District (BAAQMD). Bayview submitted the Temporary Worksite Notification for Asbestos Related Work to the State of California Department of Industrial Relations Division of Occupational Safety and Health on May 30, 2013. Copies of the notifications and revisions are provided in Appendix C. • On May 8, 2013, excavation notification was submitted to the State of California Division of Occupational Safety and Health. • On May 14, 2013, the pre-construction/kick-off meeting was held with the DON. • On May 15, 2013, Precision Locating, LLC performed geophysical surveys in the vicinity of the two locations with elevated gamma readings along the SWDA A&B fence line and Buildings 1121 and 1323. RMAC-0809-0013-0011 Fnl PCSR.docx 2-1 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 • On May 17, 2013, 24-hour work notice fliers were hand-delivered to the nearby residents and businesses detailing the excavation and demolition activities to be performed. • On May 20, 2013, demolition notification for Buildings 1121 and 1323 was submitted to the BAAQMD; updates in the completion date were submitted on July 8, 2013 and August 8, 2013. • On October 28, 2013, demolition notification for Building 1323 was submitted to the BAAQMD. • On November 27, 2013, 24-hour work notice fliers were hand-delivered to the nearby residents and businesses informing them of the demolition of Building 1323. Copies of the permits, notifications, pre-construction/kick-off meeting minutes, and 24-hour work notice fliers are provided in Appendix D. In addition to the pre-construction activities above, material-specific background reference areas were established for the soil hot spot removal and building radiological survey activities. Nonradiologically impacted site background reference areas with similar physical, chemical, geological, radiological, and biological characteristics as the building or site being evaluated were selected. For the hot spot removals, the reference background area and soil sample results used were those provided in the report titled Analysis of Gamma Survey and Radium-226 Soil Concentration Data at the Treasure Island Site-Wide Background Areas and the Area 7 Background Reference Area, hereinafter referred to as the Treasure Island Background Area document (Shaw 2012). As TtEC was currently performing radiological controls at other locations at NAVSTA TI, TtEC continued to use Building 570 as the temporary site office during pre-construction and field activities. All equipment and material used were surveyed upon arrival at NAVSTA TI, prior to use, until the equipment was verified to be clear of radioactive contamination. AEC Regulatory Guide 1.86 limits (AEC 1974) specified for Ra-226 were used for clearance of equipment and materials. 2.2 SWDA A&B HOT SPOT REMOVAL ACTIONS The following sections describe the hot spot removal activities that were conducted to meet the removal objectives. Based on CDPH’s Report (CDPH 2011) and as shown on Figure 1-2, four locations in the southern hot spot (77, 78, 82, and 83) and one location in the northern hot spot (84) required further investigation and soil removal. 2.2.1 Pre-Removal Activities On May 30, 2013, Radiological Control Technicians (RCTs) radiologically surveyed the ground surface in the vicinity of the soil hot spots as identified in CDPH’s Report (CDPH 2011) using RMAC-0809-0013-0011 Fnl PCSR.docx 2-2 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 Ludlum Model 2350-1 data loggers with Ludlum Model 44-10 2-inch by 2-inch sodium iodide (NaI) detectors to identify the location of each hot spot. Vegetation was removed, as needed, to allow access to the locations with elevated readings. Roots were left in place so as not to disturb the soil. During the scan of hot spots 78, 82, and 83, additional locations with elevated readings were identified, which led to renaming the hot spot locations 77-01, 78-01, 78-02, 82-01, 82-02, 83-01, 83-02, 83-03, and 84-01 (Figure 2-1) based on proximity to the initial hot spot locations. Gamma readings ranged from 11,000 counts per minute (cpm) to 115,000 cpm, and dose rate measurements with a Bicron microrem meter ranged from 12 to 700 microrem per hour (microrem/hr) as compared to the corresponding background values of 5,000 to 7,000 cpm and 4 to 6 microrem/hr (Figure 2-1). Copies of the calibration certificates for the instrumentation used are provided in Appendix E. 2.2.2 Hot Spot Removals The site conceptual model indicates that the elevated readings identified in the CDPH report are most likely the result of near-surface, gamma-emitting radioluminescent devices. To minimize personnel radiation exposures consistent with the ALARA concept, as well as minimize the generation of low-level radioactive waste (LLRW), remediation of radioactively impacted locations was performed using shovels rather than excavating the impacted soil and transporting it to a screening pad for subsequent surveys and sample collection. During the removal process, soil samples were analyzed by Curtis & Tompkins, Ltd. (C&T), a laboratory accredited by the Department of Defense Environmental Laboratory Accreditation Program and CDPH National Environmental Laboratory Accreditation Program for gamma spectroscopy (which includes Ra-226. Swipe samples for loose contamination were also collected from soil removal equipment (e.g., shovels) and analyzed for gross alpha/gross beta using a Protean WPC 1050 gas-flow proportional gross alpha and beta radiation counter. Soil samples were first screened using the EG&G Spectroscopy System and the 186 kiloelectron-volt (keV) Ra-226 energy peak for expedited analysis. If the release criterion was exceeded, or the Ra-226 results were not similar to the reference area results for any of the soil samples, the iterative process of remediation followed by collection of post-remediation soil samples continued until the release criterion had been achieved. Once post-remediation screening samples confirmed that the release criterion for Ra-226 was achieved, and the results were similar to the reference area results, these samples were reanalyzed after a 21-day ingrowth period using the EG&G Spectroscopy System and the 609 keV bismuth-214 gamma energy peak to quantify Ra-226 results. During removal activities, air monitoring was performed in accordance with the project plans to ensure worker and community safety. Air quality monitoring stations were placed downwind of the southern hot spot location and upwind of the northern hot spot location. Air samples were analyzed for total suspended particulates (TSP), lead, particulate matter smaller than 10 microns RMAC-0809-0013-0011 Fnl PCSR.docx 2-3 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 in diameter (PM 10 ), asbestos, polynuclear aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs) by SCS Engineers. All of the sample data were below the California Occupational Safety and Health Administration permissible exposure limits of 0.5 microgram per cubic meter (µg/m3) for TSP (level chosen to minimize overall permissible dust release from the site), 0.05 milligram per cubic meter (mg/m3) for lead, 5 mg/m3 for PM 10 , 0.1 fiber/cubic centimeter (cm3) for asbestos, and 0.5 mg/m3 for both PAHs and PCBs. Water spray was used as needed to prevent fugitive dust during excavation activities. Air sample analytical results are provided in Appendix F. Air samples for gross alpha and beta airborne contamination concentrations were analyzed by C&T using the Protean WPC 1050 gas-flow proportional gross alpha and beta radiation counter. All of the results were significantly below 10 percent of the derived air concentration (DAC) of 3 × 10-10 microcuries per milliliter (μCi/ml) for Ra-226 for radiation workers, as well as, with one exception, the airborne effluent limit of 9 × 10-13 μCi/ml from 10 Code of Federal Regulations (CFR) 20 Appendix B for protection of members of the public. On March 20, 2013, one grab sample indicated a minimum detectable activity of 1.22 × 10-12 μCi/ml, resulting from the comparatively small volume of air collected. Note that this sample was collected during 30 minutes of soil removal, and the airborne effluent limit from 10 CFR 20 Appendix B is based on 1 year of continuous air emissions. Converting the airborne effluent limit from 10 CFR 20 Appendix B to adjust for a 30-minute work period results in an effluent limit of 3.6 × 10-9 μCi/ml. As such, all air sample results indicate that the general public was protected from airborne emissions. Air sample analytical results are provided in Appendix F. All personnel participating in remediation efforts were dressed in personal protective equipment (PPE) consisting of a Tyvek® suit, gloves, and booties, and were issued personnel dosimeters to monitor their exposures while working in areas with potential radiological contamination. Before the start of the removal action at each hot spot location, plastic was placed adjacent to the area to be remediated to prevent the spread of radioactive contamination. Remediation activities began on May 30, 2013 and were completed on June 7, 2013. A total of twenty-two 5-gallon buckets of contaminated soil and one radium commodity were collected and transferred to the DON’s LLRW contractor, Environmental Management Services (EMS), for disposal as LLRW. Used PPE and sampling supplies were bagged and also transferred to EMS for disposal as LLRW. A summary of the removal activities completed to meet the removal action objectives is provided below. Note that all Ra-226 soil concentrations discussed in this report are gross values. • On May 30, 2013, removal activities began at hot spots 82-01, 82-02, 83-01, 83-02, and 83-03. As the soil was removed with a shovel, the RCT would survey the soil using a Ludlum Model 2350-1 data logger with a Ludlum Model 44-10 2-inch by 2-inch NaI detector to qualitatively determine the source of elevated gamma readings in order to RMAC-0809-0013-0011 Fnl PCSR.docx 2-4 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 secure the source and aid in the decision to terminate excavation operations. The estimated depth of the material with an elevated reading at each location did not exceed 3 inches. No commodities were found at locations 82-01, 82-02, 83-01, 83-02, and 83-03. The material/soil with an elevated reading from each location, not including locations 83-02 and 83-03, was placed in Ziploc® bags, marked according to their location, and placed in a 5-gallon bucket. The soil source of the elevated readings at locations 83-02 and 83-03 was placed directly into a 5-gallon bucket for disposal as LLRW. At location 82-01, the edge of the asphalt pathway was chipped to allow access to the elevated-reading material. The 5-gallon buckets were transferred to the commodity locker located within the Radioactive Materials Area (RMA) adjacent to Building 570 until transferred to EMS for disposal as LLRW. Dose rate measurements taken with a Bicron microrem meter of the excavated material ranged from 30 to 250 microrem/hr. One post-remediation soil sample was collected from the bottom of each excavation. The screening post-remediation soil sample results for Ra-226 ranged from 0.9745 pCi/g to 21.72 pCi/g (Figure 2-1). Gamma readings of the bottom of the excavations with a Ludlum Model 2350-1 data logger and a Ludlum Model 44-10 2-inch by 2-inch NaI detector ranged from 6,815 cpm to 8,276 cpm, and dose rate measurements with a Bicron microrem meter ranged from 5 to 7 microrem/hr (Figure 2-1). • On May 31, 2013, removal activities began at hot spots 77-01, 78-01, and 78-02. As soil was removed with a shovel, the RCT would survey the soil with a Ludlum 2350-1 data logger with a 44-10 2-inch by 2-inch NaI detector. Radioactive commodities were not recovered in these locations. Flecks of material/soil with elevated readings from locations 78-01 and 78-02 were placed in Ziploc bags. The material with elevated readings at location 77-01 was identified at the base of a shrub that had been removed to just above the ground surface the previous day. After the initial material with elevated readings was removed near the surface, additional elevated readings remained near the roots. Hand tools were used to loosen the material near the roots of the former shrub, and the remaining material with elevated readings was recovered and placed in a Ziploc bag. The bags were marked according to their location, placed in a 5-gallon bucket, and transferred to the commodity locker located within the RMA adjacent to Building 570 until transferred to EMS for disposal as LLRW. The estimated depth of the material with elevated readings at these locations did not exceed 3 inches. One post-remediation soil sample was collected from the bottom of each excavation. The screening post-remediation soil sample results for Ra-226 ranged from 0.6196 pCi/g to 1.127 pCi/g (Figure 2-1). Gamma readings of the bottom of the excavations with a Ludlum Model 2350-1 data logger and a Ludlum Model 44-10 2-inch by 2-inch NaI detector ranged from 6,300 cpm to 6,800 cpm, and dose rate measurements with a Bicron microrem meter ranged from 6 to 7 microrem/hr (Figure 2-1). • On June 3, 2013, removal activities began at hot spot 84-01. A small fragment of a radioactive foil was recovered at a depth of approximately 3 inches. The foil was placed inside a Ziploc bag and transferred to a concrete-lined drum located within the commodity locker in the RMA adjacent to Building 570 until transferred to EMS for disposal as LLRW. After removal of the foil, gamma readings with a Ludlum Model 2350-1 data logger with a Ludlum Model 44-10 2-inch by 2-inch NaI detector within the RMAC-0809-0013-0011 Fnl PCSR.docx 2-5 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 area were 15,000 cpm. Soil 1 foot on either side of the location with elevated readings was removed to a depth of 6 inches and placed in four 5-gallon buckets. Bicron microrem meter dose rate measurements of the buckets ranged from 15 to 20 microrem/hr. A large rock used to mark and shield the location during investigative scans was found to have 95 alpha cpm and 1,405 beta cpm. The four buckets and the rock were transferred to the commodity locker located within the RMA adjacent to Building 570 until transferred to EMS for disposal as LLRW. The gamma scan readings of the excavated surfaces ranged from 6,500 cpm to 8,250 cpm, and the dose rate measurement with a Bicron microrem meter was 6 microrem/hr (Figure 2-1). Six post-remediation soil samples (two excavation bottom and four sidewall) were collected (Figure 2-2). The bottom screening soil samples indicated Ra-226 at 0.8622 pCi/g and 0.3101 pCi/g. The sidewall screening soil samples indicated Ra-226 at 0.855 pCi/g, 1.253 pCi/g, 0.5876 pCi/g, and 1.061 pCi/g (Figure 2-2). • On June 4, 2013, remediations were performed at hot spots 83-01, 83-02, and 83-03 due to Ra-226 exceeding the release criterion as shown on Figure 2-1. The screening soil sample results indicated Ra-226 at 1.84 pCi/g, 21.72 pCi/g, and 2.193 pCi/g, respectively. Soil was removed 1 foot around each location to a depth of 6 inches resulting in a single, contiguous excavated area. Following remediation, the gamma reading measured with a Ludlum Model 2350-1 data logger with a Ludlum Model 44-10 2-inch by 2-inch NaI detector was 6,000 cpm, and dose rate measured with a Bicron microrem meter was 6 microrem/hr. The excavated soil was placed in eight 5-gallon buckets and transferred to the commodity locker located within the RMA adjacent to Building 570 until transferred to EMS for disposal as LLRW. Dose rate measurements on the buckets ranged from 5 to 6 microrem/hr with a Bicron microrem meter. Seven post-remediation soil samples were collected at locations where soil sample results showed elevated activity concentrations of Ra-226, as well as on the sidewalls of the excavation to ensure the elevated activity concentrations had been appropriately remediated (Figure 2-3). Three were collected from the excavation bottom at the former locations of the elevated activity, and four were collected from the sidewalls. The excavation bottom screening soil sample results indicated Ra-226 at 0.4231 pCi/g, 0.7058 pCi/g, and 0.716 pCi/g. The sidewall screening soil sample results indicated Ra-226 at 0.3481 pCi/g, 0.631 pCi/g, 0.6865 pCi/g, and 0.766 pCi/g (Figure 2-3). • On June 5, 2013, remediations were performed at hot spots 78-02 and 82-01 (Figure 2-1) and at sidewall sample locations 84-03 and 84-05 (Figure 2-2) due to Ra-226 concentrations dissimilar to background concentrations. The screening soil sample results indicated Ra-226 at 1.127 pCi/g, 1.201 pCi/g, 1.253 pCi/g, and 1.061 pCi/g, respectively. At hot spot 78-02, soil was removed 1 foot around to a depth of 6 inches and placed into two 5-gallon buckets. Dose rate measured with a Bicron microrem meter was 5 microrem/hr. Five post-remediation soil samples were collected. One sample was collected from the excavation bottom and four were collected from the sidewalls (Figure 2-3). The excavation bottom screening soil sample result indicated Ra-226 at 0.8588 pCi/g. The sidewall screening soil sample results indicated Ra-226 at RMAC-0809-0013-0011 Fnl PCSR.docx 2-6 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 0.5686 pCi/g, 0.7447 pCi/g, 0.4706 pCi/g, and 0.4513 pCi/g (Figure 2-3). Gamma readings and dose rate measurements of the excavated surfaces were 5,600 cpm and 5 microrem/hr, respectively. At hot spot 82-01, soil was removed 1 foot around to a depth of 6 inches and placed into two 5-gallon buckets. Dose rate measured with a Bicron microrem meter was 6 microrem/hr. Three post-remediation soil samples were collected. One sample was collected from the excavation bottom and two were collected from the sidewalls (Figure 2-3). The excavation bottom screening soil sample result indicated Ra-226 at 0.5039 pCi/g. The sidewall screening soil sample results indicated Ra-226 at 0.6442 pCi/g and 0.8476 pCi/g (Figure 2-3). Gamma readings and dose rate measurements of the excavated surface were 8,600 cpm and 6 microrem/hr, respectively. At sidewall sample location 84-03, additional soil from the sidewall was removed laterally another 6 inches, which resulted in a portion of the asphalt walkway being removed. The excavated soil and asphalt were placed into two 5-gallon buckets, and the dose rate measured 5 to 6 microrem/hr with a Bicron microrem meter. Two postremediation soil samples (one from the excavation bottom and one from the sidewall) were collected (Figure 2-2). The excavation bottom and sidewall screening soil sample results indicated Ra-226 at 0.7654 pCi/g and 0.6493 pCi/g, respectively (Figure 2-2). Gamma readings and dose rate measurements of the excavated surfaces were 7,500 cpm and 7 microrem/hr, respectively. At sidewall sample location 84-05, additional soil from the sidewall was removed laterally another 6 inches and placed into two 5-gallon buckets. Dose rate measured with a Bicron microrem meter was 6 microrem/hr. Two post-remediation soil samples (one from the excavation bottom and one from the sidewall) were collected (Figure 2-2). The excavation bottom and sidewall screening soil sample results indicated Ra-226 at 0.5012 pCi/g and 0.8756 pCi/g, respectively (Figure 2-2). Gamma readings and dose rate measurements of the excavated surfaces were 7,500 cpm and 7 microrem/hr, respectively. The eight 5-gallon buckets of soil were transferred to the commodity locker located within the RMA adjacent to Building 570 until transferred to EMS for disposal as LLRW. • 2.2.3 • Based on the screening soil sample data indicating that the radiologically impacted material/soil has been removed from each hot spot location and that the remaining soil meets the Ra-226 release criterion, the final post-remediation screening soil samples from each hot spot location were reanalyzed by C&T after a 21-day ingrowth period to confirm that all of the soil with elevated readings had been removed from the southern and northern hot spot locations. The reanalysis confirmed that all of the soil with elevated readings had been removed. Discussion of the confirmation soil sample data is provided in Section 3.1. Site Restoration The screening soil sample data indicated that the radiologically impacted material/soil had been removed from each hot spot location, and the gamma readings of the final excavated surfaces measured with a Ludlum Model 2350-1 data logger with a Ludlum Model 44-10 2-inch by 2-inch NaI detector ranged from 5,000 to 8,000 cpm, which is RMAC-0809-0013-0011 Fnl PCSR.docx 2-7 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 consistent with background levels shown on Figure 2-1. Therefore, site restoration was performed by backfilling the surface excavations with DON-approved import material from Hunters Point Naval Shipyard. A copy of the DON-approved import material acceptance package is provided in Appendix G. • Following DON concurrence that the post-remediation definitive soil sampling data confirmed that the release criterion for Ra-226 had been achieved and the remaining Ra-226 concentrations were similar to background concentrations, the southern and northern hot spot locations were down posted on October 25, 2013. • Following the final site walk-through inspection with the DON on December 11, 2013, the backfilled excavations were graded to match the existing ground surfaces. The DON’s concurrence that the hot spot removal activities were completed in accordance with the CTO No. 0013 statement of work and the contract requirements was received on December 11, 2013. A copy of the DON-approved final site walk inspection form is provided in Appendix H. 2.3 RADIOLOGICAL SURVEY AND DEMOLITION OF BUILDINGS 1121 AND 1323 The following sections describe the Building 1121 and 1323 field activities that were conducted to meet the removal objectives. 2.3.1 Pre-Demolition Activities • As the area around Building 1121 and the laydown area, Lester Court, had not yet been radiologically cleared by the DON, TtEC performed additional characterization surveys and soil sampling of the area around Building 1121 and characterization surveys at Lester Court to determine Radiation Work Permit requirements. The surveys and soil sampling were performed in the vicinity of Building 1121 between April 17, 2013 and May 2, 2013. The surveys of Lester Court were performed between June 6, 2013 and June 10, 2013. The survey results indicated that these areas would be managed as Radiologically Controlled Areas and were posted accordingly. Copies of the characterization surveys and soil sampling results are provided in Appendix I. • On May 7, 2013, Bayview performed an asbestos survey of the two buildings to confirm that all of the ACM had been documented in the DON’s June 1998 asbestos survey reports. Bayview’s subcontractor, Stockton Environmental, identified additional ACM during their survey of the buildings. The black roof mastics associated with the roof penetrations for both buildings were confirmed to be ACM (29 in Building 1121 and 30 in Building 1323). The sheetrock joint compound in Building 1323 was also confirmed to contain asbestos, resulting in an additional 40,100 square feet of ACM requiring abatement and disposal. A copy of Stockton Environmental’s report is provided in Appendix C. • On May 16, 2013, TtEC performed inspections of Buildings 1121 and 1323 to determine if there were any health and safety concerns that would need to be addressed in preparation for the asbestos abatement activities. Medical and biological wastes were encountered. As these waste streams had not been encountered during the site walk of Unit F of Building 1323, unsanitary conditions had not been anticipated. The removal of the medical and RMAC-0809-0013-0011 Fnl PCSR.docx 2-8 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 biological wastes was performed between May 17, 2013 and May 22, 2013, with the waste streams being transferred to the San Francisco Police Department. • Prior to asbestos abatement activities, the household appliances present in each of the buildings were removed and staged in an adjacent carport where material and equipment surveys were performed to confirm that the appliances were not radiologically impacted. Copies of the survey data are provided in Appendix J. On September 20, 2013, 58 household appliances removed from Buildings 1121 and 1323 (29 per building) were transported by Eighteen Trucking to Recology Hay Road Landfill for disposal. Copies of the manifests, bills of lading, and weight tickets are provided in Appendix K. • Bayview performed the asbestos abatement in Building 1121 between May 30, 2013 and June 11, 2013 and performed the first phase of asbestos abatement in Building 1323 between June 10, 2013 and June 24, 2013. Air monitoring for potential alpha and beta airborne contamination was conducted during abatement activities. The materials generated from the roof penetrations were removed from Building 1121 on July 3, 2013 and July 11, 2013. The second phase of the abatement activities in Building 1323 (the removal of the roof penetrations and sheetrock with asbestos-containing joint compound) was performed between October 29, 2013 and November 20, 2013 after receipt of the DON’s concurrence on October 29, 2013, that the survey data indicated that the building had not been radiologically impacted. A total of 20 cubic yards of hazardous asbestos waste from Building 1121 was transferred to Building 96 on September 26, 2013 until transported by World Environmental and Energy to Recology Hay Road Landfill located in Vacaville, California, for disposal on September 30, 2013. A total of 30 cubic yards of hazardous asbestos waste and 200 cubic yards of nonhazardous asbestos waste from Building 1323 were transported by World Environmental and Energy to Recology Hay Road Landfill for disposal on November 26, 2013. Two 55-gallon drums of asbestos mastic were transported by Bayview and KM Industrial, Inc. to Crosby and Overton, Inc. located in Long Beach, California, for disposal on December 17, 2013. Copies of the manifests are provided in Appendix C. • As prior radiation surveys and sample analysis identified Ra-226 impacted debris and soil in some of the SWDAs within IR Site 12, radiological surveys of the interiors and exteriors of Buildings 1121 and 1323 were performed to confirm that radiologically impacted soil had not been tracked into the buildings and the wind had not deposited radiologically impacted soil onto the exterior surfaces prior to demolition of the buildings. This was to ensure that radiologically contaminated debris would not end up in a California landfill. In Building 1121, the first floor and up 2 meters of the wall and stairwells underwent a Class 1 survey, and the exterior wall up 2 meters from the building foundation underwent a Class 2 survey. In Building 1323, the base of the wall to 2 meters up the wall on the first floor and stairwells underwent a Class 1 survey, and the exterior wall up 2 meters from the building foundation underwent a Class 2 survey. A survey of the floor was not completed in Building 1323 as the floor was not to be removed for disposal. A total of six Class 1 survey units and one Class 2 survey unit were established for each of the buildings. Each Class 1 and Class 2 survey unit underwent 100 percent gamma and alpha scans using a Ludlum 2350-1 data logger with a Ludlum 44-10 2-inch by RMAC-0809-0013-0011 Fnl PCSR.docx 2-9 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 2-inch NaI detector. A minimum of 20 systematic swipe samples, static alpha and gamma measurements, and exposure rate measurements were collected in each survey unit. Additional measurements and samples were collected if investigation levels were exceeded. Layouts of each of the survey units including a summary of the scan data, swipe samples, and measurements are provided in Appendix L. The results of the survey confirmed that the buildings had not been radiologically impacted. The survey results were below the release criteria of 20 dpm/100 cm2 alpha or 1,000 dpm/100 cm2 beta removal contamination, or 100 dpm/100 cm2 alpha or 5,000 dpm/100 cm2 beta fixed contamination. The radiological surveys at Building 1121 were performed between June 28, 2013 and July 30, 2013; and at Building 1323, between July 18, 2013 and July 31, 2013 and August 22, 2013 and October 3, 2013. CDPH performed confirmatory surveys of Building 1121 on July 24, 2013, and of Building 1323 on September 20, 2013 and September 27, 2013. TtEC received the DON’s Notice to Proceed with demolition of Building 1121 along with CDPH’s concurrence that Building 1121 was not radiologically impacted on September 6, 2013. TtEC received CDPH’s concurrence that Building 1323 was not radiologically impacted and the DON’s Notice to Proceed with demolition of Building 1323 on November 12, 2013 and November 22, 2013, respectively. Copies of the concurrence on the survey data and Notices to Proceed are provided in Appendix M. • 2.3.2 In addition to the survey of the buildings to ensure they were not radiologically impacted prior to demolition, the six wood storage sheds associated with Building 1121 and the wood panels from the privacy fence associated with Building 1323 also underwent material and equipment surveys to ensure that these items were not radiologically impacted prior to shipment for off-site disposal with the building demolition debris. Copies of the survey data are provided in Appendix J. Building Demolition Following receipt of the Notice to Proceed with demolition of the buildings, the demolition, debris downsizing, and waste transport and disposal activities commenced. During demolition activities, air monitoring was performed in accordance with the project plans to ensure worker and community safety. Upwind and downwind air quality monitoring stations were placed at each building, and air samples were analyzed for TSP, lead, PM 10 , and asbestos by SCS Engineers. All of the sample data were below 0.5 mg/m3 for TSP, 0.05 mg/m3 for lead, 5 mg/m3 for PM 10 , and 0.1 fiber/cm3 for asbestos. Water spray was used as needed to prevent fugitive dust during demolition, debris downsizing, and waste load-out activities. Waste off-hauling was performed between 9:00 am and 2:30 pm to minimize disruptions to residents and NAVSTA TI traffic. • Building 1121 demolition was completed on September 9, 2013. Downsizing and offhaul of the demolition debris were performed between September 9, 2013 and September 13, 2013. A total of 161.61 tons of nonhazardous building demolition debris was transported by Eighteen Trucking and C&K Trucking to Recology Hay Road Landfill for disposal between September 10, 2013 and September 13, 2013. A total of 14.76 tons of building demolition debris with lead paint was transported by Sanchez Transport, Inc. to RMAC-0809-0013-0011 Fnl PCSR.docx 2-10 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 Clean Harbors Buttonwillow Landfill located in Buttonwillow, California for disposal on December 9, 2013. • Building 1323 demolition was completed on December 2 and 3, 2013. Downsizing and off-haul of the demolition debris were performed between December 2, 2013 and December 6, 2013. A total of 144.32 tons of nonhazardous building demolition debris was transported by C&K Trucking, J&G Trucking, and H&J Trucking to Recology Hay Road Landfill for disposal between December 4, 2013 and December 6, 2013. • Prior to the demolition of both Buildings 1121 and 1323, mercury thermostats were removed, containerized in one 5-gallon bucket, and secured. This universal waste was transported by Eighteen Trucking to Clean Harbors San Jose LLC located in San Jose, California, on December 23, 2013. Copies of the waste profiles, manifests, bills of lading, and weight tickets for the waste streams generated from the demolition of Buildings 1121 and 1323 are provided in Appendix K. Used PPE was bagged and disposed of with the demolition debris. 2.3.3 Site Restoration Following removal of the demolition debris, each of the sites underwent restoration before being turned over to the DON. • Site restoration at Building 1121 involved demobilizing equipment and materials from the site. A final site walk-through inspection with the DON was held on September 16, 2013. After completing the one punchlist item of replacing sod in the green belt area across from Lester Court, DON concurrence that the Building 1121 removal activities were completed in accordance with the CTO No. 0013 statement of work and the contract requirements was received on September 20, 2013. • Site restoration at Building 1323 involved demobilizing equipment and materials from the site. A final site walk-through inspection with the DON was held on December 11, 2013. After completing the punchlist items of cutting rebar penetrating from the concrete slab foundation, spray painting the remaining rebar stub and other tripping hazards with high visibility paint, and removing a piece of vinyl flooring from the ground surface, DON concurrence that the Building 1323 removal activities were completed in accordance with the CTO No. 0013 statement of work and the contract requirements was received on December 11, 2013. Copies of the DON-approved final site walk inspection forms are provided in Appendix H. RMAC-0809-0013-0011 Fnl PCSR.docx 2-11 Final Post Construction Summary Report Installation Restoration Site 12 Naval Station Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0011 CTO No. 0013 101 4 80 PLEASANT HILL LARKSPUR 580 RICHMOND DETAIL AREA 80 680 MILL VALLEY 101 CLAYTON EL CERRITO WALNUT CREEK TAMALPAISHOMESTEAD VALLEY CA ALBANY LI FO LAFAYETTE ORINDA NAVAL STATION TREASURE ISLAND BERKELEY RN 24 IA ALAMO SAUSALITO MORAGA PIEDMONT 80 13 DANVILLE INSET OAKLAND 1 SAN FRANCISCO 580 ALAMEDA SAN RAMON 880 280 101 SAN LEANDRO DALY CITY ASHLAND PACIFIC OCEAN CASTRO VALLEY 580 CHERRYLAND SOUTH SAN FRANCISCO 35 PACIFICA HAYWARD SAN FRANCISCO BAY SAN BRUNO 92 238 MILLBRAE 82 880 HILLSBOROUGH SAN MATEO FOSTER CITY 84 280 1 BELMONT SAN CARLOS 92 LEGEND 1 680 101 2.5 0 2.5 US HIGHWAY 280 INTERSTATE HIGHWAY NAVAL STATION TREASURE ISLAND WATER 5 Miles STATE HIGHWAY 101 FREMONT NEWARK BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA POST CONSTRUCTION SUMMARY REPORT INSTALLATION RESTORATION SITE 12 FIGURE 1-1 REGIONAL LOCATION MAP NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CALIFORNIA REVISION: 0 AUTHOR: MS FILE NUMBER: R7791.mxd File Path (IRVSRVR) : P:\GIS\Projects\SanDiego\TreasureIsland\IRSite12\ArcGIS\R7791.mxd UNION CITY BURLINGAME LEGEND: CDPH Elevated Activity Data Sample ID Longitude 77 -122.3780747 78 -122.3780826 82 -122.3781783 83 -122.3781904 84 -122.378509 Source: CDPH 2011 Latitude 37.82557866 37.82557246 37.825522 37.82554082 37.8281435 Exposure Rate Exposure Rate one meter contact (µR/hr) (µR/hr) 8 800 8 11 6.5 90 6 28 12.5 600 Dose Rate one meter (µrem/hr) Dose Rate contact (µrem/hr) 4 4 4 5 5 500 13 80 10 450 Gamma Count Rate contact (cpm) 349224 53735 155981 24428 880097 BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA POST CONSTRUCTION SUMMARY REPORT INSTALLATION RESTORATION SITE 12 FIGURE 1-2 SITE LOCATION MAP NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-NTCRA_Figure 1-2.dwg 2/5/14 LEGEND: 77-01 Location Background 77-01 78-01 78-02 82-01 82-02 83-01 83-02 83-03 84-013/ Dose Rate at Gamma Rate at Gamma Rate at Bottom Dose Rate at Bottom of Ground Surface1/ (microrem/hr) 4-6 60 20 30 50 12 200 17 15 700 Ground Surface 1/ (cpm) 5,000-7,000 69,000 15,400 41,300 17,900 11,000 115,000 15,700 15,100 109,000 of Excavation 2/ (cpm) 5,000-7,000 6,400 6,300 6,800 7,126 7,583 8,276 7,483 6,815 8,250 Excavation2/ (microrem/hr) 4-6 6 6 7 5 7 7 7 7 6 1/ Prior to removal of elevated soil identified in CDPH's Report (CDPH 2011). 2/ After removal of elevated soil identified in CDPH's Report (CDPH 2011). Dose Rate of Excavated Material (microrem/hr) 4-6 1,000 140 50 150 30 250 not analyzed not analyzed 4,000 Post-Remediation Soil Screening Results (pCi/g) 0.7 0.6196 0.9254 1.127 1.201 0.9745 1.84 21.72 2.193 0.8622 RECORD COPY BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA POST CONSTRUCTION SUMMARY REPORT INSTALLATION RESTORATION SITE 12 FIGURE 2-1 PRE- AND POST-INITIAL HOT SPOT REMOVAL 3/ A commodity was only found at location 84-01. The remaining locations contained elevated soil. Only maximum measurements after removal are presented. Abbreviations and Acronyms: cpm - counts per minute hr - hour pCi/g - picocuries per gram P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-Hot Spot_FIGURE 2-1.dwg NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA 2/13/14 Sample ID Screening Soil Definitive Soil Soil Excavation Bottom or Ra-226 Results Ra-226 Results Removed Sidewall Soil Sample (pCi/g) (pCi/g) (cu ft) Notes HOT SPOT 84 13-IR12-E-HS84-01 Excavation Bottom 0.8622 0.629 Sample after removal of elevated material 1/ ; final post-remediation sample 13-IR12-E-HS84-02 13-IR12-E-HS84-03 13-IR12-E-HS84-04 13-IR12-E-HS84-05 13-IR12-E-HS84-06 13-IR12-E-HS84-07 13-IR12-E-HS84-08 13-IR12-E-HS84-09 13-IR12-E-HS84-10 Sidewall Sidewall Sidewall Sidewall Excavation Bottom Sidewall Excavation Bottom Sidewall Excavation Bottom 0.855 1.253 0.5876 1.061 0.3101 0.6493 0.7654 0.8756 0.5012 0.619 N/A 0.596 N/A 0.479 0.585 0.413 0.506 0.547 Final post-remediation sample Initial post-remediation sample Final post-remediation sample Initial post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample 1/ 3 1.5 1 IR SITE 12 BOUNDARY SCALE 1:100 LEGEND: Elevated soil locations identified in CDPH's Report (CDPH 2011). The locations of the highlighted samples have been remediated and are not part of the final soil sample definitive sample data results. 82-01 77-01 RECORD COPY BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA POST CONSTRUCTION SUMMARY REPORT INSTALLATION RESTORATION SITE 12 FIGURE 2-2 NORTHERN HOT SPOT REMOVAL LOCATION NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-Hot Spot_Sample Locations Small.dwg 2/13/14 RECORD COPY LEGEND: 82-01 77-01 HOT SPOTS 77 AND 78 IR SITE 12 BOUNDARY HOT SPOT 82 HOT SPOT 83 SCALE 1:100 Sample ID Soil Excavation Bottom Screening Soil Definitive Soil or Sidewall Soil Ra-226 Results Ra-226 Results Removed (cu ft) (pCi/g) (pCi/g) Sample Notes 13-IR12-E-HS77-01 Excavation Bottom 0.6196 0.705 1 Sample after removal of elevated material1/ ; final post-remediation sample 13-IR12-E-HS78-01 Excavation Bottom 0.9254 1.17 0.5 Sample after removal of elevated material1/ ; final post-remediation sample 13-IR12-E-HS78-02 Excavation Bottom 13-IR12-E-HS78-03 Excavation Bottom 13-IR12-E-HS78-04 Sidewall 13-IR12-E-HS78-05 Sidewall 13-IR12-E-HS78-06 Sidewall 13-IR12-E-HS78-07 Sidewall 1.127 0.8588 0.5686 0.7447 0.4706 0.4513 N/A 0.307 0.336 0.353 0.280 0.342 0.5 Sample after removal of elevated material1/ Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample 13-IR12-E-HS82-01 Excavation Bottom 13-IR12-E-HS82-03 Excavation Bottom 13-IR12-E-HS82-04 Sidewall 13-IR12-E-HS82-05 Sidewall 1.201 0.5039 0.6442 0.8476 N/A 0.582 0.677 0.496 <1 13-IR12-E-HS82-02 Excavation Bottom 0.9745 0.914 <1 Sample after removal of elevated material1/ ; final post-remediation sample 13-IR12-E-HS83-01 Excavation Bottom 1.84 N/A <1 Sample after removal of elevated material1/ 13-IR12-E-HS83-02 Excavation Bottom 21.72 N/A <1 Sample after removal of elevated material 13-IR12-E-HS83-03 13-IR12-E-HS83-04 13-IR12-E-HS83-05 13-IR12-E-HS83-06 13-IR12-E-HS83-07 13-IR12-E-HS83-08 13-IR12-E-HS83-09 13-IR12-E-HS83-10 2.193 0.4231 0.7058 0.716 0.3481 0.631 0.6865 0.766 N/A 0.502 0.417 0.447 0.414 0.675 0.480 0.725 <1 Sample after removal of elevated material1/ Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample Final post-remediation sample 1/ Excavation Bottom Excavation Bottom Excavation Bottom Excavation Bottom Sidewall Sidewall Sidewall Sidewall 1.5 1 5.5 Sample after removal of elevated material1/ Final post-remediation sample Final post-remediation sample Final post-remediation sample 1/ Elevated soil locations identified in CDPH's Report (CDPH 2011). The locations of the highlighted samples have been remediated and are not part of the final soil sample definitive sample data results. BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA POST CONSTRUCTION SUMMARY REPORT INSTALLATION RESTORATION SITE 12 FIGURE 2-3 SOUTHERN HOT SPOT REMOVAL LOCATION NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-Hot Spot_Sample Locations Small.dwg 2/5/14 Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL RADIOLOGICAL INVESTIGATION AND SOURCE REMOVAL ON MARCH 20 AND 21, 2013 February 2014 DCN: RMAC-0809-0013-0010 INSTALLATION RESTORATION SITE 12 FORMER NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL RADIOLOGICAL INVESTIGATION AND SOURCE REMOVAL ON MARCH 20 AND 21, 2013 February 2014 INSTALLATION RESTORATION SITE 12 FORMER NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA DCN: RMAC-0809-0013-0010 Prepared by: 1230 Columbia Street, Suite 750 San Diego, California 92101-8536 Erik Abkemeier, CHP, PE, CSP, CHMM Radiation Safety Officer Bill Dougherty Project Manager TABLE OF CONTENTS PAGE ABBREVIATIONS AND ACRONYMS ...................................................................................... iii 1.0 INTRODUCTION ........................................................................................................... 1-1 1.1 BACKGROUND .................................................................................................... 1-1 1.2 CDPH-RHB HEALTH AND SAFETY SURVEYS .............................................. 1-1 1.3 RESPONSE ACTION ............................................................................................ 1-2 1.4 METHODOLOGY ................................................................................................. 1-2 1.4.1 Soil Sample Collection Methodology ......................................................... 1-3 1.4.2 Excavation and Mitigation Methodology ................................................... 1-3 1.5 PHOTOGRAPHS ................................................................................................... 1-4 2.0 RESPONSE ACTION ..................................................................................................... 2-1 2.1 LOCATION 1128E ................................................................................................. 2-1 2.2 LOCATION 1303A ................................................................................................ 2-2 2.3 LOCATION 1303B ................................................................................................ 2-3 2.4 LOCATION 1306C ................................................................................................ 2-3 2.5 LOCATION 1306D ................................................................................................ 2-4 3.0 SITE RESTORATION .................................................................................................... 3-1 4.0 LABORATORY ANALYTICAL RESULTS ................................................................. 4-1 4.1 LOCATION 1128E ................................................................................................. 4-1 4.2 LOCATION 1303A ................................................................................................ 4-1 4.3 LOCATION 1303B ................................................................................................ 4-1 4.4 LOCATION 1306C ................................................................................................ 4-1 4.5 LOCATION 1306D ................................................................................................ 4-2 5.0 CONCLUSIONS.............................................................................................................. 5-1 FIGURES Figure 1-1 IR Site 12 Radiological Investigation and Source Removal Locations RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal i Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 TABLE OF CONTENTS (Continued) PHOTOGRAPHS Photograph 1 Measuring background prior to backfill Photograph 2 Location 1128E work activities Photograph 3 Location 1128E commodity (in Ziploc bag) Photograph 4 Location 1306C commodity (in Ziploc bag) APPENDICES Appendix A Radiation Work Permit Appendix B Instrument Calibration Certifications Appendix C Air Sample Analytical Results Appendix D Soil Sample Chain-of-Custody Documentation Appendix E Gamma Spectroscopy Soil Sample Analytical Results RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal ii Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 1.0 INTRODUCTION The U.S. Department of the Navy (DON) directed Tetra Tech EC, Inc. (TtEC) to perform a radiological investigation at former Naval Station Treasure Island (NAVSTA TI) on March 19, 2013. The purpose of the investigation was to verify the presence of elevated radioactivity concentrations identified by the California Department of Public Health – Radiologic Health Branch (CDPH-RHB) during public health screening activities and mitigate any potential radiological hazards to protect the public health and welfare, and the environment. The NAVSTA TI investigation and mitigation activities were performed under Contract No. N6247310-D-0809 and Contract Task Order 0013. The radiological work activities were performed in compliance with TtEC’s California Department of Public Health Radioactive Material License No. 7909-01. 1.1 BACKGROUND Located in San Francisco Bay (Bay) to the east of the City of San Francisco, California, NAVSTA TI comprises two contiguous islands. Bisected by the San Francisco Bay Bridge, Treasure Island on the north is approximately 403 acres in size and Yerba Buena Island to the south is about 147 acres in size. Treasure Island is manmade and constructed of materials dredged from the Bay. Prior to the construction of Treasure Island, military activities in the area date back to 1866 when the U.S. government took possession of Yerba Buena Island for defensive fortifications. In 1993, NAVSTA TI was designated for closure under the Base Closure and Realignment Act of 1990 and was finally closed on September 30, 1997. The property is currently undergoing the transfer process. Installation Restoration (IR) Site 12 is located on a relatively flat 93-acre area within the northwest portion of NAVSTA TI. IR Site 12 consists of multiplex housing units with private backyards and common area front yards, side yards, and surrounding greenbelts. Originally, this area was used as a parking lot during the 1939–1940 Golden Gate International Exposition. Following occupation of the NAVSTA TI by the DON in 1940, the area was developed for bunker storage of munitions and other materials, vehicle equipment and storage, recreational playing fields, and disposal or burning of solid waste. Beginning in the 1960s, areas of IR Site 12 were incrementally developed into housing units for DON personnel and their dependents. 1.2 CDPH-RHB HEALTH AND SAFETY SURVEYS At the request of the Treasure Island Development Authority (TIDA), CDPH-RHB conducted walk-over radiological surveys in the occupied housing area of IR Site 12 at NAVSTA TI from approximately March 11 through March 22, 2013. Representatives from CDPH-RHB performed these surveys using a Ludlum Model 19 MicroR survey meter. The initial survey results identified five distinct locations within IR Site 12 with exposure rates that exceeded the RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 background exposure rate of 4 to 6 microroentgens per hour (µR/hour) at a height of approximately 3 feet above ground surface. These areas were identified as Locations 1303A and 1303B situated to the west of Building 1303, Locations 1306C and 1306D situated to the south of Building 1306, and Location 1128E situated to the east of Building 1128. The elevated exposure rates ranged from 17 µR/hour at Location 1303B to 4,200 µR/hour at Location 1128E. Using an in situ gamma spectroscopy Inspector 1000 instrument, CDPH-RHB determined that the areas of elevated activity were due to the presence of radium-226 (Ra-226). Each of these locations within IR Site 12 and the associated exposure rate measurements are provided on Figure 1-1. 1.3 RESPONSE ACTION The DON convened a teleconference with representatives from the Radiological Affairs Support Office, CDPH-RHB, and TtEC on March 19, 2013 to determine the best course of action to address the five suspect areas of elevated activity in IR Site 12. At the conclusion of the teleconference, the DON directed TtEC to meet with CDPH-RHB representatives at NAVSTA TI and confirm their findings, perform radiological screening, and coordinate with CDPH-RHB in the collection of split soil samples. In addition, the DON directed TtEC to implement the measures necessary to mitigate potential radiological hazards to protect the public health and welfare, and the environment. The mitigation measures included limited soil excavation in those areas of confirmed elevated radioactivity to ensure that residual radiation concentrations were indistinguishable from background concentrations following backfill and site restoration. If source removal was unsuccessful, TtEC was directed to perform other mitigation measures including the placement of a steel plate over the area and/or installing temporary fencing to limit public access until further direction from the DON was obtained. 1.4 METHODOLOGY TtEC prepared a Radiation Work Permit (RWP) for the anticipated radiological investigation and removal activities prior to mobilizing to the field. The RWP specified the radiological controls to be used during the investigation and removal activities. A copy of the RWP is provided in Appendix A. TtEC’s methodology for performing the radiological investigation and removal activities included the mobilization of radiologically trained workers who were thoroughly briefed on the requirements of the RWP. Only calibrated instruments were utilized, and a response check was performed at the beginning of each day prior to use. The instrument calibration certificates are provided in Appendix B. In addition, tools and equipment were procured including new shovels, trowels, buckets, and drums to eliminate the possibility of cross-contamination. The tools and equipment were decontaminated prior to being used at each of the suspect sites. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-2 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 Prior to beginning intrusive activities, plastic sheeting was placed around the suspect areas to limit the spread of potential contamination. In addition, radiological air samples were collected using a low-volume air sampler at a rate of one sample per day in the vicinity of the intrusive activities. The air monitoring samples were subsequently submitted to the Curtis and Tompkins on-site laboratory located at Hunters Point Naval Shipyard (HPNS) in San Francisco, California for analysis. None of the air monitoring sample results exceeded 10 percent of the derived air concentration for Ra-226. The air monitoring sample analytical results are provided in Appendix C. 1.4.1 Soil Sample Collection Methodology Soil samples were collected using a hand trowel or core sampler between ground surface and a depth of 6 inches below ground surface (bgs) at each of the five suspect locations. The collected sample materials were subsequently split between CDPH-RHB personnel and TtEC for submittal to separate laboratories for gamma spectroscopy analysis. The TtEC split samples were submitted under chain of custody to the HPNS laboratory for analysis. The chain-of-custody documentation is provided in Appendix D. Typically, soil samples analyzed for Ra-226 using gamma spectroscopy must achieve secular equilibrium with its progeny (21-day ingrowth), including bismuth-214 and lead-214 to obtain definitive quantitative results. However, pending receipt of the 21-day ingrowth quantitative results, a conservative estimate of Ra-226 concentrations can be made using direct analysis of the 186.2 kiloelectron-volt (keV) gamma energy peaks. The soil sample analytical results provided in this report and summarized in Appendix E are reported using the 186.2 keV gamma energy peak. Soil samples were collected from each of the five suspect locations with elevated activities. In addition to the near-surface soil samples split with CDPH-RHB, a soil sample was collected from the excavation bottoms at Locations 1128E, 1303A, 1303B, and 1306C and submitted to the HPNS laboratory for gamma spectroscopy analysis. No soil sample was collected from the Location 1306D excavation bottom, since the elevated material was likely removed during the CDPH-RHB surface soil sample collection activities. Details related to the Location 1306D investigation activities are described in Section 2.5. Soil samples were also collected from the excavated materials for waste characterization as low-level radioactive waste (LLRW). The HPNS laboratory analytical results are provided in Appendix E. 1.4.2 Excavation and Mitigation Methodology Handheld survey instruments were used to determine the lateral extent of the suspect areas and determine whether soil removal was a viable option to mitigate the potential radiological hazards. To expedite the mitigation of the potential hazards, utility locator services were not employed. Consequently, the limited excavation activities were performed by radiologically RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-3 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 trained workers using shovels and digging to a maximum depth of 18 inches bgs, or until gamma exposure rates were indistinguishable from background levels, as agreed to by the CDPH-RHB on-site representative. Background levels for each of the five suspect locations were determined by radiologically scanning the ground surface at least 6 feet from the area of elevated radioactivity using a Ludlum 2350-1 rate meter equipped with a Ludlum 44-10 2-inch by 2-inch sodium iodide (NaI) gamma scintillation detector and a Bicron Microrem meter. The instrument certifications are provided in Appendix B. Radiological commodities, if identified, were removed from the excavations, placed in plastic bags, and assigned a unique identification number. Each commodity would then be transferred to a special container at the NAVSTA TI Building 570 complex for storage pending off-site disposal as LLRW. Once TtEC and CDPH-RHB representatives concurred that no further soil should be removed from the shallow excavations at each of the suspect locations and a soil sample was collected from the bottom material, the excavation was lined with plastic and backfilled with sand. Following backfill activities, a surface dose rate measurement was collected to ensure that the surface area was no longer a potential hazard to the public health and safety, and the environment. 1.5 PHOTOGRAPHS The fieldwork performed during the NAVSTA TI radiological investigation and source removal activities was documented using a photographic record. Photographs of the fieldwork are provided prior to the appendices. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-4 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 2.0 RESPONSE ACTION TtEC professional staff accompanied by senior Radiation Control Technicians and radiologically trained workers met with CDPH-RHB representatives led by John Fassell at Building 1128 on March 20, 2013 to initiate the investigation and mitigation field activities. The fieldwork continued from March 20 through March 21, 2013. The following sections describe and summarize the radiological investigation and mitigation activities performed at NAVSTA TI to verify the presence of elevated radioactivity concentrations identified by the CDPH-RHB during public health screening activities and mitigate any potential radiological hazards to protect the public health and welfare, and the environment. 2.1 LOCATION 1128E The radiological investigation activities were initiated at Location 1128E near Building 1128 on March 20, 2013 (Figure 1-1). The background gamma radiation level was established at approximately 6,500 to 7,000 counts per minute (cpm). Ambient dose rates measured using a Bicron Microrem meter indicated a background level in adjacent areas in the range of 4 to 5 microroentgens equivalent man per hour (µrem/hour). Following the sample collection methodology described in Section 1.4.1, TtEC collected a sample from the top 6 inches of soil at the area of elevated radioactivity identified by CDPH-RHB (Location 1128E) near Building 1128. The soil sample (Sample 13AB1128-001) was divided into two bags, which were split between TtEC and the CDPH-RHB. A flat, hexagonal-shaped commodity was discovered at a depth of approximately 6 inches bgs during the investigation activities on March 20, 2013. On contact, the commodity measured 20 milliroentgens equivalent man per hour (mrem/hour) using the Bicron Microrem meter. Subsequent measurements collected with an Eberline RO-20 ion chamber survey meter indicated a beta exposure of 4.5 radiation absorbed dose per hour (rad/hour) based on an open window measurement and a 35 milliroentgens per hour (mR/hour) gamma exposure rate based on a closed window measurement on contact. Following removal of the Location 1128E commodity, excavation activities continued to a depth of approximately 18 inches bgs. The completed excavation measured 18 inches by 18 inches by 18 inches. Using a Ludlum 2350-1 rate meter equipped with a Ludlum 44-10 sodium iodide (NaI) detector, measurements collected from the bottom of the excavation were approximately 12,000 cpm. This measurement was elevated above background, which may have been due to the geometry effects of measuring gamma radiation from excavation sidewalls as well as the bottom, or a result of residual contamination, or a combination of the two. However, the CDPHRHB representative concurred that a sufficient volume of contaminated soil had been removed to be protective of the public health from surface radiation exposures. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 2-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 A soil sample was collected from the material removed during the excavation process for waste characterization purposes (Sample 13AB1128-002). In addition, a soil sample was collected from the bottom of the excavation (Sample 13AB1128-003). Both soil samples were submitted under chain-of-custody to the HPNS laboratory for analysis by gamma spectroscopy. The chainof-custody documentation is provided in Appendix D. The shallow excavation was lined with plastic and backfilled with sand following concurrence from the CDPH-RHB that a sufficient volume of soil had been removed. Using a Bicron microrem meter over the backfilled Location 1128E surface showed a residual dose rate of 4 µrem/hour. Due to inclement weather conditions, TtEC and CDPH-RHB representatives agreed to discontinue operations for the day and continue the investigation and mitigation activities the following morning. TtEC decontaminated the tools and equipment used during the sample collection activities and transported the split sample to Building 570. However, CDPH-RHB subsequently elected to continue collecting soil samples from the areas of elevated activity associated with Locations 1303A, 1303B, 1306C, and 1306D without the presence of TtEC representatives and coordinate transfer of the split soil samples for analysis. TtEC’s Radiation Safety Officer (RSO) arranged for CDPH-RHB staff to turn over the split soil samples to TtEC personnel at a secure location where TtEC’s Radiation Safety Officer Representative (RSOR) would retrieve them the following morning. The RSOR retrieved the four split samples collected by CDPH-RHB at Locations 1303A (Sample 13AB1303-001), 1303B (Sample 13AB1303-002), 1306C (Sample 13AB1306-001), and 1306D (Sample 13AB1306-002). These soil samples were submitted under chain of custody to the HPNS laboratory for analysis by gamma spectroscopy. The chain-of-custody documentation is provided in Appendix D. 2.2 LOCATION 1303A TtEC performed the investigation and mitigation activities at Location 1303A on March 21, 2013. A representative from CDPH-RHB observed the fieldwork. Since a surface soil sample (Sample 13AB1303-001) was collected by CDPH-RHB within the first 6 inches of soil the previous day, no further surface soil samples were collected. Using the methodologies described in Section 1.4, TtEC applied plastic sheeting around Location 1303A and collected surface soil measurements using a Bicron Microrem meter, and a Ludlum 2350-1 meter. The resulting measurements were 1 mrem/hour and 150,000 cpm, respectively. The calibration certifications for each of these instruments are provided in Appendix B. Using a shovel and hand trowel, TtEC workers removed the soil at Location 1303A to a depth of approximately 10 inches bgs. No specific commodity was found during the excavation activities. The completed excavation measured approximately 18 inches by 18 inches by 10 inches. Using the Ludlum Model 2350-1 instrument over the bottom of the Location 1303A excavation resulted in a measurement of 12,000 cpm. A soil sample was collected from the RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 2-2 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 material at the bottom of the excavation (Sample 13AB1303-003), and a representative soil sample (Sample 13AB1303-004) was collected from the excavated material for waste characterization as LLRW. Each of the soil samples was submitted under chain-of-custody documentation to the HPNS laboratory for analysis by gamma spectroscopy. The chain-ofcustody documentation is provided in Appendix D. The Location 1303A excavation was lined with plastic and backfilled with sand following concurrence from the CDPH-RHB that a sufficient volume of soil had been removed. A measurement collected with a Bicron Microrem meter over the surface of the backfilled excavation showed a residual dose rate of 4 µrem/hour. 2.3 LOCATION 1303B Radiological investigation activities were performed at Location 1303B on March 21, 2013 (Figure 1-1). Using a Ludlum 2350-1 and a Bicron Microrem meter, TtEC obtained measurements at the Location 1303B surface of 10,000 cpm and 20 µrem/hour, respectively. Location 1303B was prepared for the investigation activities as described in Section 1.4. Since a surface soil sample (Sample 13AB1303-002) had been previously collected and split between TtEC and CDPH-RHB, no further surface soil samples were collected. Soil was removed from Location 1303B using a shovel and hand trowel to a depth of approximately 9 inches bgs. No specific commodity that was clearly the source of the elevated readings was removed. At completion, Location 1303B measured approximately 12 inches by 12 inches by 9 inches. Using a Ludlum Model 2350-1, TtEC collected a measurement of 7,000 cpm over the bottom of the excavation. With the concurrence of the CDPH-RHB representative that the source of the elevated measurements appeared to have been mitigated, TtEC collected a soil sample from the material at the bottom of the excavation (Sample 13AB1303-005) for analysis by gamma spectroscopy. No soil sample was collected from the excavated material for waste characterization as LLRW since a characterization sample had been collected from the nearby Location 1303A excavated material. The soil sample collected from the bottom of the Location 1303B excavation was submitted under chain of custody to the HPNS laboratory for analysis. The chain-of-custody documentation is provided in Appendix D. At the conclusion of the excavation activities, the Location 1303B excavation was lined with plastic and backfilled with sand. A measurement collected with a Bicron Microrem meter over the surface of the backfilled excavation showed a residual dose rate of 4 µrem/hour. 2.4 LOCATION 1306C Accompanied by CDPH-RHB, TtEC performed the investigation and mitigation activities at Location 1306C on March 21, 2013 (Figure 1-1). Since a surface soil sample (Sample 13AB1306-001) was collected and split between TtEC and CDPH-RHB, no further surface soil samples were collected. Using the methodologies described in Section 1.4, TtEC applied plastic RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 2-3 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 sheeting around Location 1306C and collected surface soil measurements using a Bicron Microrem meter and a Ludlum Model 2350-1 gamma rate meter. The resulting measurements were 240 µrem/hour and 60,000 cpm, respectively. The instrument certifications are provided in Appendix B. TtEC workers removed the soil at Location 1306C using a shovel and a hand trowel to a depth of approximately 10 inches bgs, when a flat, octagonal metallic commodity was found. Using a Bicron Microrem meter and a Ludlum Model 2350-1 instrument, the Location 1306C commodity measured 200 mrem/hour and 2,000,000 cpm, respectively, on contact (Figure 1-1). Additional measurements were collected at the HPNS laboratory on the following day using an Eberline RO-20 ion chamber survey meter. The commodity measurement results indicated a beta exposure of 1 rad/hour based on an open window measurement and a 60 mR/hour gamma exposure rate based on a closed window measurement. The commodity was removed from the excavation, placed in a plastic bag, and assigned a unique identification number. Following removal of the commodity, excavation continued at Location 1306C to a depth of approximately 16 inches bgs. The completed excavation measured about 16 inches by 20 inches by 16 inches. Using a Ludlum Model 2350-1 gamma meter, TtEC obtained a measurement of approximately 26,000 cpm over the bottom of the Location 1306C excavation. A soil sample (Sample 13AB1306-004) was collected from the material at the bottom of the excavation, and a representative soil sample (Sample 13AB1306-003) was collected from the excavated material for waste characterization as LLRW. Each of the soil samples was submitted under chain-of-custody documentation to the HPNS laboratory for analysis by gamma spectroscopy. The chain-of-custody documentation is provided in Appendix D. With the concurrence of the CDPH-RHB representative that a sufficient volume of elevated soil had been removed to be protective of the public health, the Location 1306C excavation was lined with plastic and backfilled with sand. TtEC collected a final measurement of 4 µrem/hour using a Bicron Microrem meter held over the surface of the backfilled excavation. 2.5 LOCATION 1306D TtEC and CDPH-RHB performed investigation activities at Location 1306D (Figure 1-1) on March 21, 2013. Since a surface soil sample (Sample 13AB1306-002) was collected by CDPHRHB within the first 6 inches of soil the previous day, no further surface soil samples were collected. Using a Bicron Microrem meter and a Ludlum Model 2350-1 instrument, TtEC collected surface soil measurements of 4 µR/hour and 7,000 cpm, respectively. Based on these results, TtEC and CDPH-RHB concluded that the elevated material found at Location 1306D was likely removed during the surface soil sample collection activities, and no further excavation would be necessary to protect public health. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 2-4 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 3.0 SITE RESTORATION Site restoration activities were performed following the completion of the radiological investigation and source removal activities. At the completion of the soil removal activities, each excavation was lined with plastic and backfilled with sand material, and sod was placed over the backfilled excavation. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 3-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 4.0 LABORATORY ANALYTICAL RESULTS The following sections discuss the laboratory analytical results for the soil samples collected from each of the locations identified in IR Site 12 by the CDPH-RHB with elevated radiological measurements. Figure 1-1 depicts the soil sample collection locations and provides a summary of the soil sample analytical results. The laboratory analytical reports are presented in Appendix E. 4.1 LOCATION 1128E The HPNS laboratory analytical results for the surface soil sample (Sample 13AB1128-001) collected from Location 1128E indicated the presence of Ra-226 at 469.4 picocuries per gram (pCi/g). In addition, the waste characterization soil sample analytical results (Sample 13AB1128-002) contained a Ra-226 concentration of 42.54 pCi/g. The analytical results for the soil sample (Sample 13AB1128-003) collected at the bottom of the excavation (approximately 18 inches bgs) identified the presence of residual Ra-226 at 8.344 pCi/g. 4.2 LOCATION 1303A The HPNS laboratory analytical results for the surface soil sample (Sample 13AB1303-001) collected from Location 1303A identified the presence of Ra-226 at an estimated concentration exceeding 30,000 pCi/g. This soil sample could not be effectively quantified at the HPNS laboratory due to the excessive dead time caused by the elevated sample concentration. In addition, the waste characterization soil sample analytical results (Sample 13AB1303-003) contained an Ra-226 concentration of 823.3 pCi/g. The laboratory analytical results for the soil sample (Sample 13AB1303-004) collected from the bottom of the Location 1303A excavation (approximately 10 inches bgs) indicated the presence of residual Ra-226 at 2.174 pCi/g. 4.3 LOCATION 1303B The HPNS laboratory analytical results for the surface soil sample (Sample 13AB1303-002) collected from Location 1303B identified the presence of Ra-226 at 309.5 pCi/g. The analytical results for the soil sample (Sample 13AB1303-005) collected at the bottom of the excavation (approximately 9 inches bgs) identified the presence of residual Ra-226 at 4.853 pCi/g. No waste characterization soil sample was collected from Location 1303B. 4.4 LOCATION 1306C The HPNS laboratory analytical results for the surface soil sample (Sample 13AB1306-001) collected from Location 1306C identified the presence of Ra-226 at 92.82 pCi/g. In addition, the waste characterization soil sample analytical results (Sample 13AB1306-003) contained an Ra226 concentration of 6,147 pCi/g. The laboratory analytical results for the soil sample (Sample 13AB1306-004) collected from the bottom of the Location 1306C excavation (approximately 16 inches bgs) identified the presence of residual Ra-226 activity at 45.29 pCi/g. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 4-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 4.5 LOCATION 1306D The HPNS laboratory analytical results for the surface soil sample (Sample 13AB1306-002) collected from Location 1306D identified the presence of Ra-226 at 2,022 pCi/g. As described in Section 2.5, the cause of the elevated instrument readings was likely removed with the surface soil sample. With the concurrence of the CDPH-RHB, no further soil samples or mitigation efforts were performed for Location 1306D. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 4-2 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 5.0 CONCLUSIONS The DON directed TtEC to perform a radiological investigation at NAVSTA TI. The purpose of the investigation was to verify the presence of elevated radioactivity concentrations identified by the CDPH-RHB during public health screening activities and mitigate any potential radiological hazards to protect the public health and welfare, and the environment. TtEC and CDPH-RHB performed the investigation and mitigation activities on March 20 and March 21, 2013. Material and equipment survey results for equipment used during the investigation identified no residual radiological contamination. Air monitoring sample analytical results did not exceed 10 percent of the derived air concentration for Ra-226. Waste generated during soil excavation activities was containerized in 55-gallon drums. The waste materials were transferred to the NAVSTA TI Building 570 complex for storage pending off-site disposal by the DON’s LLRW contractor. Investigation and removal activities at Locations 1128E and 1306C yielded similar metallic commodities that appear to be the source of the elevated Ra-226 concentrations in those areas. These commodities were placed in a designated storage container within the NAVSTA TI Building 570 complex. Based on the investigation activities and laboratory analytical results, the five IR Site 12 locations of elevated radioactivity have been sufficiently mitigated, and the surface gamma exposure rates are essentially indistinguishable from background levels following excavation and backfill activities. A summary of the radiological measurements and soil sample analytical results is provided on Figure 1-1. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 5-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 PRE-CONSTRUCTION CONFERENCE AGENDA TETRA TECH ECI REMEDIATION CONTRACT INFORMATION Project Title: NTCRA for Solid Waste Disposal Area-Radiological Hot Contract/TaskSpot Removal & Bldg Demolition at IR Site 12, Treasure Island, CA Delivery Order Number: Pre-Construction Meeting Scheduled for 13 May 2013 @ 10:00am at N62473-10-D-0809 TI CSO Conference Room, Building 1or via Conference Call: CTO #0013 Toll Free: Guest Code: Award Date: Award Amount: 21 August 2012 $797,301 1(866) 692-5721 8175375# Contract Duration: Contractor: Tetra Tech ECI Completion Date (Through Mod # 03) 21 February 2014 Liquidated Damages: N/A A-E: N/A I. Introductions. II. Project History, Scope & Schedule to be presented by the Contractor Project Manager III. Key Players 1. Client: BRAC PMO 2. Field Office: ROICC SF Bay - CSO Title RPM Area of Responsibility Name Overall responsibility for this project Tony Konzen Technical/Engineering/Financial. Lead RPM David Clark ROICC SF Bay Overall responsibility for ROICC SF LT Jeremy Office Bay Schwartz ROICC Supervisory Overall responsibility for Franklin Engineer Technical/Engineering Fernandez ROICC Construction Technical/QA/Safety Gary J. Manager Munekawa ROICC Engineering Quality assurance and safety. David R. Technician/Quality Smith Assurance Page 1 of 9 Phone No. 619-532-0924 619-532-0973 510-521-8672 510-755-5877 510-755-5879 510-755-5880 PRE-CONSTRUCTION CONFERENCE AGENDA CSO CSO Supervisor Patricia McFadden 415-743-4720 CSO CSO Environmental POC Doug DeLong 415-743-4713 CSO Facility Manager Glen Nelson 415-743-4703 Contracting Officer Overall responsibility for Contractual matters Cynthia Mafara 619-532-0978 Contracts Specialist Contract modifications/Invoicing/payrolls. Karen Barba 619-532-0786 3. Contractor: Tetra Tech, ECI Title Project Manager (Tetra Tech ECI) Name Bill Dougherty Phone No. (415) 216-2731 Desk (415) 238-7006 Mobile Superintendent Back-up Superintendent Quality Control Manager Dennis McWade Chris Hanif Richard Kanaya Alternate Quality Control Manager Richard Weingarz Dan Keenan Andrew Gorman George Chiu 580-670-0290 Mobile 510-967-1710 Mobile 415-216-2759 Desk 415-516-9583 Mobile 425-785-9220 Mobile Site Safety Officer Alternate Site Safety Officer RSOR 415-272-1015 Mobile 425-241-0713 Mobile 415-216-2745 Desk 714-270-4009 IV. COMMUNICATIONS 1. RPM is the main technical point of contact for this project. 2. The ROICC Project Engineer/Engineering Technician is the first point of contact on most health and safety and fieldwork matters. 3. Copy RPM and CSO on all facilities, technical, safety and QC communication. 4. When sending e-mails to the ROICC office, send to both Gary Munekawa and David Smith. Page 2 of 9 PRE-CONSTRUCTION CONFERENCE AGENDA 5. Notify the ROICC SF Bay Construction Manager (Gary Munekawa) on all field safety and QC issues. For actions requiring a Contracting Officer, such as adding or deleting work, your point of contact is Cynthia Mafara. Changes or modifications to the contract may only be executed by the contracting officer. 6. Include the Company name, contract number and CTO number on all, reports and letters and serialize them for this contract. Send all ROICC correspondence to 950 West Mall Square Bldg. 1, Suite 160, West Wing, Mail Stop 2 Alameda, CA 94501 or Via: US Post Office: ROICC (Moffett Site Office) Moffett Federal Airfield PO Box 68 Moffett Field, CA 94035-0068 Via overnight delivery service: ROICC (Moffett Site Office) Moffett Federal Airfield Bldg 107 (corner of Wescoat Rd & McCord Ave) Moffett Field, CA 94035 7. ROICC Fax # is 650-603-9838. Copy RPM and CSO on all electronic submittals. V. GETTING STARTED 1. Site Access/Administration /Security a. b. c. d. Coordinate site access with CSO if necessary. No firearms or controlled substances are allowed on site. Permits for any photographic or recording equipment are not required. Safety and Health Bulletin: The contractor shall erect a Safety and Health Bulletin in compliance with EM 385-1-1, 01.A.06 (a thru i) requirements. e. Bldg 570 will the on-site location for TetraTech for this CTO. 2. Fire Protection – Contractor is responsible for fire prevention on the job site. 3. Requirements Prior to Starting Construction a. Bonds and Insurance. Page 3 of 9 PRE-CONSTRUCTION CONFERENCE AGENDA b. List of Contractor and Subcontractor personnel (Organization Chart) with recall numbers. c. Quality Control Plan (20 working day ROICC review time): (below is done) 1) QC Manager and Alternate Letter of Authority - Contractor to provide in the QC Plan and Original to Contract Specialist prior to mobilizing to the field. Tetra Tech will provide a Alternate Letter for QC Manager listing Richard Weingarz to replace Adam Berry in the CQC Plan. d. Accident Prevention Plan and Site Specific Health and Safety Plan. e. Environmental Protection Plan, SWPP & Waste Management Plan. f. Schedule of Prices. 1) Must be submitted and approved by the Contracting Officer prior to processing the first payment. If a cost loaded CPM schedule is required the schedule of prices may be omitted. g. Progress Schedule. 1) Submit a realistic construction schedule to the government for approval. Must be submitted and accepted by the Contracting Officer prior to beginning construction. Work Item Descriptions (include administrative items required under the contract such as: submission, review and approval of submittals, testing and inspection) and their start dates, duration, dependencies, and completion dates. Critical Work Items, which if not done as scheduled, will delay the start or completion of the whole project (i.e. critical path items). h. Permits (if required or specified by Contract). 1) Contracting Officer to verify Contractor has received required permits and verify permits remain valid for the duration of the work. 2) Contractor ensures permitting action required of Contractor is fulfilled prior to executing work covered by the permit. 3) Dig Permit. Contact Glen Nelson, CSO. i. Submittals. Submittal requirements are stated in the contract. The QC Manager must maintain a current copy of the submittal register at the job site. The contractor must include what specific specification is being submitted. j. Radiation Briefings. The RSOR, George Chiu will provide Treasure Island-specific radiation training to the ROICC near the start of the project. V. DOING BUSINESS 1. Jobsite a. Safety FIRST! 1) Goal is ZERO safety violations. Safety Sup can (will) be removed unilaterally if non-responsive or non-responsible. 2) COE EM 385-1-1 and OSHA rules. 3) Safety record will weigh heavily in contractor evaluation. Page 4 of 9 Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL RADIOLOGICAL INVESTIGATION AND SOURCE REMOVAL ON MARCH 20 AND 21, 2013 February 2014 DCN: RMAC-0809-0013-0010 INSTALLATION RESTORATION SITE 12 FORMER NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-10-D-0809 CTO NO. 0013 FINAL RADIOLOGICAL INVESTIGATION AND SOURCE REMOVAL ON MARCH 20 AND 21, 2013 February 2014 INSTALLATION RESTORATION SITE 12 FORMER NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA DCN: RMAC-0809-0013-0010 Prepared by: 1230 Columbia Street, Suite 750 San Diego, California 92101-8536 Erik Abkemeier, CHP, PE, CSP, CHMM Radiation Safety Officer Bill Dougherty Project Manager TABLE OF CONTENTS PAGE ABBREVIATIONS AND ACRONYMS ...................................................................................... iii 1.0 INTRODUCTION ........................................................................................................... 1-1 1.1 BACKGROUND .................................................................................................... 1-1 1.2 CDPH-RHB HEALTH AND SAFETY SURVEYS .............................................. 1-1 1.3 RESPONSE ACTION ............................................................................................ 1-2 1.4 METHODOLOGY ................................................................................................. 1-2 1.4.1 Soil Sample Collection Methodology ......................................................... 1-3 1.4.2 Excavation and Mitigation Methodology ................................................... 1-3 1.5 PHOTOGRAPHS ................................................................................................... 1-4 2.0 RESPONSE ACTION ..................................................................................................... 2-1 2.1 LOCATION 1128E ................................................................................................. 2-1 2.2 LOCATION 1303A ................................................................................................ 2-2 2.3 LOCATION 1303B ................................................................................................ 2-3 2.4 LOCATION 1306C ................................................................................................ 2-3 2.5 LOCATION 1306D ................................................................................................ 2-4 3.0 SITE RESTORATION .................................................................................................... 3-1 4.0 LABORATORY ANALYTICAL RESULTS ................................................................. 4-1 4.1 LOCATION 1128E ................................................................................................. 4-1 4.2 LOCATION 1303A ................................................................................................ 4-1 4.3 LOCATION 1303B ................................................................................................ 4-1 4.4 LOCATION 1306C ................................................................................................ 4-1 4.5 LOCATION 1306D ................................................................................................ 4-2 5.0 CONCLUSIONS.............................................................................................................. 5-1 FIGURES Figure 1-1 IR Site 12 Radiological Investigation and Source Removal Locations RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal i Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 TABLE OF CONTENTS (Continued) PHOTOGRAPHS Photograph 1 Measuring background prior to backfill Photograph 2 Location 1128E work activities Photograph 3 Location 1128E commodity (in Ziploc bag) Photograph 4 Location 1306C commodity (in Ziploc bag) APPENDICES Appendix A Radiation Work Permit Appendix B Instrument Calibration Certifications Appendix C Air Sample Analytical Results Appendix D Soil Sample Chain-of-Custody Documentation Appendix E Gamma Spectroscopy Soil Sample Analytical Results RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal ii Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 1.0 INTRODUCTION The U.S. Department of the Navy (DON) directed Tetra Tech EC, Inc. (TtEC) to perform a radiological investigation at former Naval Station Treasure Island (NAVSTA TI) on March 19, 2013. The purpose of the investigation was to verify the presence of elevated radioactivity concentrations identified by the California Department of Public Health – Radiologic Health Branch (CDPH-RHB) during public health screening activities and mitigate any potential radiological hazards to protect the public health and welfare, and the environment. The NAVSTA TI investigation and mitigation activities were performed under Contract No. N6247310-D-0809 and Contract Task Order 0013. The radiological work activities were performed in compliance with TtEC’s California Department of Public Health Radioactive Material License No. 7909-01. 1.1 BACKGROUND Located in San Francisco Bay (Bay) to the east of the City of San Francisco, California, NAVSTA TI comprises two contiguous islands. Bisected by the San Francisco Bay Bridge, Treasure Island on the north is approximately 403 acres in size and Yerba Buena Island to the south is about 147 acres in size. Treasure Island is manmade and constructed of materials dredged from the Bay. Prior to the construction of Treasure Island, military activities in the area date back to 1866 when the U.S. government took possession of Yerba Buena Island for defensive fortifications. In 1993, NAVSTA TI was designated for closure under the Base Closure and Realignment Act of 1990 and was finally closed on September 30, 1997. The property is currently undergoing the transfer process. Installation Restoration (IR) Site 12 is located on a relatively flat 93-acre area within the northwest portion of NAVSTA TI. IR Site 12 consists of multiplex housing units with private backyards and common area front yards, side yards, and surrounding greenbelts. Originally, this area was used as a parking lot during the 1939–1940 Golden Gate International Exposition. Following occupation of the NAVSTA TI by the DON in 1940, the area was developed for bunker storage of munitions and other materials, vehicle equipment and storage, recreational playing fields, and disposal or burning of solid waste. Beginning in the 1960s, areas of IR Site 12 were incrementally developed into housing units for DON personnel and their dependents. 1.2 CDPH-RHB HEALTH AND SAFETY SURVEYS At the request of the Treasure Island Development Authority (TIDA), CDPH-RHB conducted walk-over radiological surveys in the occupied housing area of IR Site 12 at NAVSTA TI from approximately March 11 through March 22, 2013. Representatives from CDPH-RHB performed these surveys using a Ludlum Model 19 MicroR survey meter. The initial survey results identified five distinct locations within IR Site 12 with exposure rates that exceeded the RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 background exposure rate of 4 to 6 microroentgens per hour (µR/hour) at a height of approximately 3 feet above ground surface. These areas were identified as Locations 1303A and 1303B situated to the west of Building 1303, Locations 1306C and 1306D situated to the south of Building 1306, and Location 1128E situated to the east of Building 1128. The elevated exposure rates ranged from 17 µR/hour at Location 1303B to 4,200 µR/hour at Location 1128E. Using an in situ gamma spectroscopy Inspector 1000 instrument, CDPH-RHB determined that the areas of elevated activity were due to the presence of radium-226 (Ra-226). Each of these locations within IR Site 12 and the associated exposure rate measurements are provided on Figure 1-1. 1.3 RESPONSE ACTION The DON convened a teleconference with representatives from the Radiological Affairs Support Office, CDPH-RHB, and TtEC on March 19, 2013 to determine the best course of action to address the five suspect areas of elevated activity in IR Site 12. At the conclusion of the teleconference, the DON directed TtEC to meet with CDPH-RHB representatives at NAVSTA TI and confirm their findings, perform radiological screening, and coordinate with CDPH-RHB in the collection of split soil samples. In addition, the DON directed TtEC to implement the measures necessary to mitigate potential radiological hazards to protect the public health and welfare, and the environment. The mitigation measures included limited soil excavation in those areas of confirmed elevated radioactivity to ensure that residual radiation concentrations were indistinguishable from background concentrations following backfill and site restoration. If source removal was unsuccessful, TtEC was directed to perform other mitigation measures including the placement of a steel plate over the area and/or installing temporary fencing to limit public access until further direction from the DON was obtained. 1.4 METHODOLOGY TtEC prepared a Radiation Work Permit (RWP) for the anticipated radiological investigation and removal activities prior to mobilizing to the field. The RWP specified the radiological controls to be used during the investigation and removal activities. A copy of the RWP is provided in Appendix A. TtEC’s methodology for performing the radiological investigation and removal activities included the mobilization of radiologically trained workers who were thoroughly briefed on the requirements of the RWP. Only calibrated instruments were utilized, and a response check was performed at the beginning of each day prior to use. The instrument calibration certificates are provided in Appendix B. In addition, tools and equipment were procured including new shovels, trowels, buckets, and drums to eliminate the possibility of cross-contamination. The tools and equipment were decontaminated prior to being used at each of the suspect sites. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-2 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 Prior to beginning intrusive activities, plastic sheeting was placed around the suspect areas to limit the spread of potential contamination. In addition, radiological air samples were collected using a low-volume air sampler at a rate of one sample per day in the vicinity of the intrusive activities. The air monitoring samples were subsequently submitted to the Curtis and Tompkins on-site laboratory located at Hunters Point Naval Shipyard (HPNS) in San Francisco, California for analysis. None of the air monitoring sample results exceeded 10 percent of the derived air concentration for Ra-226. The air monitoring sample analytical results are provided in Appendix C. 1.4.1 Soil Sample Collection Methodology Soil samples were collected using a hand trowel or core sampler between ground surface and a depth of 6 inches below ground surface (bgs) at each of the five suspect locations. The collected sample materials were subsequently split between CDPH-RHB personnel and TtEC for submittal to separate laboratories for gamma spectroscopy analysis. The TtEC split samples were submitted under chain of custody to the HPNS laboratory for analysis. The chain-of-custody documentation is provided in Appendix D. Typically, soil samples analyzed for Ra-226 using gamma spectroscopy must achieve secular equilibrium with its progeny (21-day ingrowth), including bismuth-214 and lead-214 to obtain definitive quantitative results. However, pending receipt of the 21-day ingrowth quantitative results, a conservative estimate of Ra-226 concentrations can be made using direct analysis of the 186.2 kiloelectron-volt (keV) gamma energy peaks. The soil sample analytical results provided in this report and summarized in Appendix E are reported using the 186.2 keV gamma energy peak. Soil samples were collected from each of the five suspect locations with elevated activities. In addition to the near-surface soil samples split with CDPH-RHB, a soil sample was collected from the excavation bottoms at Locations 1128E, 1303A, 1303B, and 1306C and submitted to the HPNS laboratory for gamma spectroscopy analysis. No soil sample was collected from the Location 1306D excavation bottom, since the elevated material was likely removed during the CDPH-RHB surface soil sample collection activities. Details related to the Location 1306D investigation activities are described in Section 2.5. Soil samples were also collected from the excavated materials for waste characterization as low-level radioactive waste (LLRW). The HPNS laboratory analytical results are provided in Appendix E. 1.4.2 Excavation and Mitigation Methodology Handheld survey instruments were used to determine the lateral extent of the suspect areas and determine whether soil removal was a viable option to mitigate the potential radiological hazards. To expedite the mitigation of the potential hazards, utility locator services were not employed. Consequently, the limited excavation activities were performed by radiologically RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-3 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 trained workers using shovels and digging to a maximum depth of 18 inches bgs, or until gamma exposure rates were indistinguishable from background levels, as agreed to by the CDPH-RHB on-site representative. Background levels for each of the five suspect locations were determined by radiologically scanning the ground surface at least 6 feet from the area of elevated radioactivity using a Ludlum 2350-1 rate meter equipped with a Ludlum 44-10 2-inch by 2-inch sodium iodide (NaI) gamma scintillation detector and a Bicron Microrem meter. The instrument certifications are provided in Appendix B. Radiological commodities, if identified, were removed from the excavations, placed in plastic bags, and assigned a unique identification number. Each commodity would then be transferred to a special container at the NAVSTA TI Building 570 complex for storage pending off-site disposal as LLRW. Once TtEC and CDPH-RHB representatives concurred that no further soil should be removed from the shallow excavations at each of the suspect locations and a soil sample was collected from the bottom material, the excavation was lined with plastic and backfilled with sand. Following backfill activities, a surface dose rate measurement was collected to ensure that the surface area was no longer a potential hazard to the public health and safety, and the environment. 1.5 PHOTOGRAPHS The fieldwork performed during the NAVSTA TI radiological investigation and source removal activities was documented using a photographic record. Photographs of the fieldwork are provided prior to the appendices. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 1-4 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 5.0 CONCLUSIONS The DON directed TtEC to perform a radiological investigation at NAVSTA TI. The purpose of the investigation was to verify the presence of elevated radioactivity concentrations identified by the CDPH-RHB during public health screening activities and mitigate any potential radiological hazards to protect the public health and welfare, and the environment. TtEC and CDPH-RHB performed the investigation and mitigation activities on March 20 and March 21, 2013. Material and equipment survey results for equipment used during the investigation identified no residual radiological contamination. Air monitoring sample analytical results did not exceed 10 percent of the derived air concentration for Ra-226. Waste generated during soil excavation activities was containerized in 55-gallon drums. The waste materials were transferred to the NAVSTA TI Building 570 complex for storage pending off-site disposal by the DON’s LLRW contractor. Investigation and removal activities at Locations 1128E and 1306C yielded similar metallic commodities that appear to be the source of the elevated Ra-226 concentrations in those areas. These commodities were placed in a designated storage container within the NAVSTA TI Building 570 complex. Based on the investigation activities and laboratory analytical results, the five IR Site 12 locations of elevated radioactivity have been sufficiently mitigated, and the surface gamma exposure rates are essentially indistinguishable from background levels following excavation and backfill activities. A summary of the radiological measurements and soil sample analytical results is provided on Figure 1-1. RMAC-0809-0013-0010 Fn Rad Inv_ Source Removal 5-1 Final Radiological Investigation and Source Removal on March 20 and 21, 2013, IR Site 12 Treasure Island, San Francisco, California DCN: RMAC-0809-0013-0010 CTO No. 0013 DETAIL B DETAIL A LEGEND: BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA SITE LOCATION MAP FIGURE 1-1 IR SITE 12 RADIOLOGICAL INVESTIGATION AND SOURCE REMOVAL LOCATIONS FORMER NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CA P:\CAD Project Files\Treasure Island CAD Files\DWG\TI-Figure 1 CDPH_02-12-14.dwg 2/12/14 Base Realignment and Closure Program Management Office West 33000 Nixie Way, Bldg. 50 San Diego, California 92147 CONTRACT NO. N62473-10-D-0809 CTO NO. 0025 FINAL FINAL STATUS SURVEY REPORT INSTALLATION RESTORATION SITE 6 September 2016 DCN: RMAC-0809-0025-0008 NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA Base Realignment and Closure Program Management Office West 33000 Nixie Way, Bldg. 50 San Diego, California 92147 CONTRACT NO. N62473-10-D-0809 CTO NO. 0025 FINAL FINAL STATUS SURVEY REPORT INSTALLATION RESTORATION SITE 6 September 2016 NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA DCN: RMAC-0809-0025-0008 Prepared by: 1230 Columbia Street, Suite 750 San Diego, California 92101-8536 George Chiu Technical Lead Steven Adams, CHP Radiation Safety Officer Shanti Montgomery Project Manager EXECUTIVE SUMMARY Installation Restoration (IR) Site 6 is located in the northeastern portion of Naval Station Treasure Island in San Francisco, California. This area includes approximately 4.3 acres and is bounded by Avenues I and M, 14th Street, the Naval Station Treasure Island Former Parking and Storage Area, and San Francisco Bay. IR Site 6 was the former firefighting training school, which was used for various firefighting training activities from 1944 to 1992. In 2007, the fenced-in area between Avenues I and M and 14th Street was designated a staging area for low-level radioactive waste consisting of radiologically impacted soil from a removal action being performed at the adjacent IR Site 12. In 2007 and 2008, soil from the IR Site 12 removal action was stockpiled directly on the ground surface and possibly on the concrete foundation of the former firefighting training school building. Since this single stockpiling event, soil from IR Site 12 has been staged in specially designed roll-off bins pending shipment for off-site disposal. The Final Historical Radiological Assessment – Supplemental Technical Memorandum (TriEco-Tt 2014) states that the Former Parking and Storage Area is potentially radiologically impacted as a result of the open area south of Former Building 327 (Salvage Building) being used as a salvage yard. The exact location of the salvage yard was not defined in this report. Former Building 327 is located within the Former Parking and Storage Area south of Building 461. The radionuclide of concern identified for IR Site 6 is radium-226. The Final Status Survey (FSS) was designed in accordance with the Multi-Agency Radiation Survey and Site Investigation Manual (DoD et al. 2000). To perform the survey, IR Site 6 was divided into 17 Class 1 survey units (SUs). The survey results were reviewed to determine whether residual radioactivity was present, and conditions within the SU were compared to background. The final systematic sample radioanalytical results from the ground surfaces at IR Site 6 were comparable to background. When using the higher of the reported activity or the method detection limit, the maximum estimated dose of 1.268 millirem per year (mrem/y) and the increased excess lifetime cancer risk (ELCR) of 2.019 10-5 was associated with SU 1. This is significantly lower than the criterion for unrestricted release. The criterion for unrestricted release is an ELCR that falls below the U.S. Environmental Protection Agency (EPA) acceptable risk management level of 3 x 10-4 (EPA 2014), which is equivalent to 12 mrem/y, according to EPA’s Office of Solid Waste and Emergency Response guidance document 9285.6-20. This ELCR is more conservative than the Nuclear Regulatory Commission dose-based unrestricted release criterion of 25 mrem/y. RMAC-0809-0025-0008 Fnl FSS IR Site 6 ES-1 Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 This FSS report details the procedures and results of the surveys performed to facilitate unrestricted radiological release of IR Site 6. Based on these results, the Department of the Navy recommends IR Site 6 for unrestricted radiological release. RMAC-0809-0025-0008 Fnl FSS IR Site 6 ES-2 Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY ..................................................................................................... ES-1 ABBREVIATIONS AND ACRONYMS .................................................................................... vii 1.0 SITE DESCRIPTION ........................................................................................................ 1-1 1.1 SITE LOCATION AND DESCRIPTION .............................................................. 1-1 1.2 PRIOR HISTORICAL USE .................................................................................... 1-1 1.3 REPORT OBJECTIVE ........................................................................................... 1-1 2.0 HISTORICAL SITE ASSESSMENT ................................................................................ 2-1 2.1 HISTORICAL SURVEYS ...................................................................................... 2-1 2.2 MARSSIM CLASSIFICATION ............................................................................. 2-1 2.3 RADIONUCLIDES OF CONCERN AND RADIATION CHARACTERISTICS ............................................................................................ 2-3 3.0 RELEASE CRITERIA ....................................................................................................... 3-1 3.1 RELEASE CRITERIA ............................................................................................ 3-1 3.2 DERIVED CONCENTRATION GUIDELINES.................................................... 3-1 3.2.1 Release Criteria .......................................................................................... 3-1 3.3 DIRECT APPLICATION OF SCREENING CRITERIA ...................................... 3-2 3.4 INVESTIGATION LEVELS .................................................................................. 3-2 3.4.1 Investigation Levels for Alpha and Beta Radiation Surveys ..................... 3-2 3.4.2 Investigation Levels for Gamma Radiation Surveys ................................. 3-3 4.0 SURVEY DESIGN ............................................................................................................ 4-1 4.1 OBJECTIVE OF SURVEYS .................................................................................. 4-1 4.2 CONCEPTUAL SITE MODEL .............................................................................. 4-1 4.3 SURVEY UNITS .................................................................................................... 4-1 4.4 REFERENCE AREAS ............................................................................................ 4-2 4.5 DATA VERIFICATION AND VALIDATION ..................................................... 4-5 4.6 DETERMINING THE NUMBER OF MEASUREMENTS AND/OR SAMPLES ............................................................................................................... 4-5 4.6.1 LBGR Determination ................................................................................. 4-6 4.6.2 Standard Deviation ..................................................................................... 4-7 4.6.3 Relative Shift.............................................................................................. 4-7 4.6.4 Number of Data Points ............................................................................... 4-7 5.0 FIELD ACTIVITIES ......................................................................................................... 5-1 5.1 MOBILIZATION .................................................................................................... 5-1 5.2 INITIAL ACTIVITIES ........................................................................................... 5-1 5.2.1 Gridding Activities ..................................................................................... 5-1 5.2.2 Former Parking and Storage Area .............................................................. 5-1 5.2.3 Former Low-Level Waste Storage Area .................................................... 5-3 5.3 SCAN SURVEY FOR IR SITE 6 ........................................................................... 5-4 RMAC-0809-0025-0008 Fnl FSS IR Site 6 i Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 TABLE OF CONTENTS (Continued) PAGE 5.4 5.5 5.6 STATIC MEASUREMENT SURVEY AND SAMPLING ACTIVITIES FOR IR SITE 6 ................................................................................................................ 5-4 5.4.1 Static Measurement Surveys ...................................................................... 5-4 5.4.2 Swipe Samples ........................................................................................... 5-5 5.4.3 Summary of Survey Unit Survey and Sampling Results ........................... 5-5 MATERIAL AND EQUIPMENT SURVEYS ....................................................... 5-9 DEMOBILIZATION .............................................................................................. 5-9 6.0 SURVEY INSTRUMENTATION .................................................................................... 6-1 6.1 INSTRUMENTATION SELECTION .................................................................... 6-1 6.2 INSTRUMENT CALIBRATION AND QUALITY ASSURANCE PROCEDURES ....................................................................................................... 6-1 6.3 INSTRUMENT OPERATIONAL CHECKS ......................................................... 6-1 6.4 INSTRUMENTS FOR THE MEASUREMENT OF ALPHA AND BETA SURFACE ACTIVITY ........................................................................................... 6-2 6.4.1 Instruments for the Static Measurement of Alpha and Beta Surface Activity....................................................................................................... 6-2 6.4.2 Instruments for the Scan Measurement of Alpha and Beta Surface Activity....................................................................................................... 6-2 6.4.3 Probe Area Correction Factor for Surface Activity Measurements ........... 6-2 6.4.4 Determination of Instrument Efficiency for Alpha and Beta Surface Activity Measurements .............................................................................. 6-2 6.5 INSTRUMENT FOR THE SCAN MEASUREMENT OF GAMMA SURFACE ACTIVITY ........................................................................................... 6-3 6.6 INSTRUMENT FOR SWIPE SAMPLES .............................................................. 6-4 6.7 SOIL SAMPLE COLLECTION AND ANALYSIS............................................... 6-4 6.7.1 Sample Preparation .................................................................................... 6-4 6.7.2 Initial Curtis & Tompkins, Ltd. On-site Gamma Spectroscopy ................ 6-5 6.7.3 Final Definitive Data Gamma Spectroscopy ............................................. 6-5 6.7.4 Laboratory Gamma Spectroscopy Analysis Flags ..................................... 6-6 6.7.5 Laboratory Counting Uncertainty .............................................................. 6-8 7.0 DETECTION SENSITIVITY – STATIC AND SCAN MINIMUM DETECTABLE CONCENTRATIONS ....................................................................................................... 7-1 7.1 STATIC MINIMUM DETECTABLE CONCENTRATION AND MINIMUM DETECTABLE COUNT RATE ......................................................... 7-1 7.1.1 Calculation of Static MDC for Alpha Surveys (126-cm2 Probe) ............... 7-1 7.1.2 Calculation of Static MDC for Beta Surveys (126-cm2 Probe) ................. 7-2 7.1.3 Calculation of Static MDCR for a Ludlum 2350-1 with a Ludlum Model 44-10 Scintillation Detector............................................................ 7-2 7.2 SCANNING MINIMUM DETECTABLE COUNT RATE ................................... 7-3 RMAC-0809-0025-0008 Fnl FSS IR Site 6 ii Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 TABLE OF CONTENTS (Continued) PAGE 7.2.1 7.3 7.4 7.5 Determination of MDCR and Use of Surveyor Efficiency (Beta, 821-cm2 Probe) .......................................................................................... 7-3 7.2.2 Determination of MDCR and Use of Surveyor Efficiency, Gamma ......... 7-4 SCAN MDC FOR BETA ........................................................................................ 7-5 SCAN MDC FOR ALPHA ..................................................................................... 7-6 SCANNING MINIMUM DETECTABLE COUNT RATE FOR A RASOAPPROVED DRIVE-OVER ARRAY SYSTEM .................................................. 7-7 7.5.1 Determination of MDCR SURVEYOR for a RASO-Approved Drive-Over Array System.............................................................................................. 7-7 7.5.2 RASO-Approved Drive-Over Array System Scan MDC for Gamma Surveys ....................................................................................................... 7-8 8.0 SURVEY PROCEDURES AND MEASUREMENT DATA INTERPRETATION ........ 8-1 8.1 SURVEY PROCEDURES ...................................................................................... 8-1 8.1.1 Static Alpha, Beta, and Gamma Measurement Technique ........................ 8-1 8.1.2 Swipe Sample Technique ........................................................................... 8-1 8.1.3 Scan Measurement Technique ................................................................... 8-1 8.1.4 Soil Sample Collection Technique ............................................................. 8-1 8.2 DATA INTERPRETATION ................................................................................... 8-2 8.3 REVIEW OF DATA QUALITY OBJECTIVES .................................................... 8-2 8.3.1 Step One – State the Problem .................................................................... 8-2 8.3.2 Step Two – Identify the Goal of the Study ................................................ 8-2 8.3.3 Step Three – Identify Information Inputs .................................................. 8-2 8.3.4 Step Four – Define the Boundaries of the Study ....................................... 8-2 8.3.5 Step Five – Develop the Analytical Approach........................................... 8-2 8.3.6 Step Six – Specify Performance or Acceptance Criteria ........................... 8-3 8.3.7 Step Seven – Develop the Plan for Obtaining Data ................................... 8-3 8.4 SURFACE ACTIVITY MEASUREMENTS ......................................................... 8-3 9.0 ANALYSIS AND RESULTS ............................................................................................ 9-1 9.1 SCAN MEASUREMENT RESULTS .................................................................... 9-1 9.1.1 Alpha Scan Measurement Results.............................................................. 9-1 9.1.2 Beta Scan Measurement Results ................................................................ 9-1 9.1.3 Gamma Scan Measurement Results ........................................................... 9-1 9.2 SWIPE MEASUREMENT ANALYSIS AND RESULTS ..................................... 9-2 9.3 STATIC ALPHA MEASUREMENT ANALYSIS AND RESULTS .................... 9-2 9.4 STATIC BETA MEASUREMENT ANALYSIS AND RESULTS ....................... 9-3 9.5 STATIC GAMMA MEASUREMENT ANALYSIS AND RESULTS .................. 9-3 9.6 SOIL SAMPLE ANALYTICAL RESULTS .......................................................... 9-3 9.6.1 Survey Unit Asphalt/Soil Sample Results ................................................. 9-4 9.6.2 Laboratory Analysis and Quality Assurance Checks ................................. 9-4 9.6.3 Comparison with NAVSTA TI 226Ra Background Concentrations ......... 9-19 RMAC-0809-0025-0008 Fnl FSS IR Site 6 iii Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 TABLE OF CONTENTS (Continued) PAGE 10.0 DOSE MODELING ......................................................................................................... 10-1 11.0 AS LOW AS REASONABLY ACHIEVABLE .............................................................. 11-1 11.1 ENVIRONMENTAL ALARA PROCESS ........................................................... 11-1 11.1.1 Identification of Potential Radiological Impacts ..................................... 11-1 11.1.2 Review of Radiological Impacts .............................................................. 11-1 11.1.3 Performance of Qualitative ALARA Analyses ........................................ 11-2 11.1.4 Performance of Quantitative ALARA Analyses ...................................... 11-2 12.0 CONCLUSION AND RECOMMENDATIONS............................................................. 12-1 13.0 REFERENCES................................................................................................................. 13-1 TABLES Table 2-1 Table 2-2 Table 3-1 Table 3-2 Table 3-3 Table 6-1 Table 9-1 Table 9-2 Table 9-3 Table 9-4 Table 9-5 Table 9-6 Table 9-7 Table 9-8 Table 9-9 Table 9-10 Table 9-11 Table 9-12 Table 9-13 Table 9-14 Table 9-15 Table 9-16 Table 10-1 IR Site 6 Survey Units ........................................................................................ 2-2 Radionuclide of Concern .................................................................................... 2-3 Release Criteria for Radionuclides of Concern .................................................. 3-2 Investigation Levels for Alpha and Beta in Counts ............................................ 3-3 Investigation Levels for Gamma in Counts ........................................................ 3-4 Summary of Library for Gamma Spectroscopy Analysis at the On-Site Laboratory ........................................................................................................... 6-7 Summary of IR Site 6 Alpha Measurements ...................................................... 9-2 Summary of IR Site 6 Beta Measurements ......................................................... 9-3 Survey Unit 1 Sampling Summary ..................................................................... 9-5 Survey Unit 2 Sampling Summary ..................................................................... 9-6 Survey Unit 3 Sampling Summary ..................................................................... 9-7 Survey Unit 4 Sampling Summary ..................................................................... 9-8 Survey Unit 5 Sampling Summary ..................................................................... 9-9 Survey Unit 9 Sampling Summary ................................................................... 9-10 Survey Unit 10 Sampling Summary ................................................................. 9-11 Survey Unit 11 Sampling Summary ................................................................. 9-12 Survey Unit 12 Sampling Summary ................................................................. 9-13 Survey Unit 13 Sampling Summary ................................................................. 9-14 Survey Unit 14 Sampling Summary ................................................................. 9-15 Survey Unit 15 Sampling Summary ................................................................. 9-16 Survey Unit 16 Sampling Summary ................................................................. 9-17 Survey Unit 17 Sampling Summary ................................................................. 9-18 IR Site 6 Dose and Risk Modeling Summary ................................................... 10-2 RMAC-0809-0025-0008 Fnl FSS IR Site 6 iv Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 TABLE OF CONTENTS (Continued) PAGE FIGURES Figure 1-1. Figure 4-1. Figure 9-1 Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Appendix L Appendix M Appendix N IR Site 6 Site Plan View ..................................................................................... 1-3 IR Site 6 Class 1 Survey Unit Arrangement ....................................................... 4-3 Boxplots of the 226Ra Concentrations in the IR Site 6 Soil Samples and the NAVSTA TI Background Soil Samples (pCi/g) .............................................. 9-21 APPENDICES (on CD) Survey Instrumentation Instrumentation Calibration Certificates Treasure Island Background Area Memorandum Ancillary, Material, and Equipment Surveys Final Status Survey Figures Survey Unit Data Packages Gamma Survey Results Laboratory Screening Gamma Spectroscopy Results Final Status Survey Radioanalytical Results Dose and Risk Modeling Summary Final Task-Specific Plan for Radiological Characterization, Remediation, and Final Status Surveys at Installation Restoration Site 6 Treasure Island Damage Control School Building 461 Instrument Chi Square Calculations and Quality Control Documentation Response to Comments RMAC-0809-0025-0008 Fnl FSS IR Site 6 v Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 1.0 SITE DESCRIPTION 1.1 SITE LOCATION AND DESCRIPTION Installation Restoration (IR) Site 6 is an open space area in the northeastern portion of Naval Station Treasure Island (NAVSTA TI), located in San Francisco, California (see Figure 1-1). Originally, IR Site 6 was bounded by Avenues I and M, 14th Street, and the San Francisco Bay, and encompassed approximately 3.4 acres. In 2003, elevated concentrations of dioxin detected in soils at the site resulted in the expansion of the site to include an adjacent Former Parking and Storage Area southeast of Building 461. Building 461 is not part of IR Site 6, but the adjacent sidewalk and enclosed stairwell on the southeast side of Building 461 are included as part of the site. As a result of this expansion, the site currently encompasses 4.3 acres of open space. The site, prior to performance of the field activities discussed herein, was comprised of unpaved areas (33 percent), asphalt (25 percent), and concrete (42 percent), as shown in Figure 1-1. Figure 1-1 depicts the site conditions prior to the start of the field activities discussed herein. 1.2 PRIOR HISTORICAL USE IR Site 6 was the former firefighting training school, and was used for various firefighting training activities from 1944 to 1992. In 2007, the fenced-in area between Avenues I and M and 14th Street was designated as a staging area for low-level radioactive waste (LLRW) consisting of radiologically impacted soil from a removal action being performed at adjacent IR Site 12. In 2007 and 2008, soil from the IR Site 12 removal action was stockpiled directly on the ground surface and possibly on the concrete foundation of the former firefighting training school building. After the single stockpiling event, soil was then staged in specially designed roll-off bins pending shipment for off-site disposal. Based on existing data, only one radionuclide of concern (ROC) was identified for IR Site 6, radium-226 (226Ra). LLRW was not stored within the Former Parking and Storage Area. The Final Historical Radiological Assessment – Supplemental Technical Memorandum (HRASTM) (TriEco-Tt 2014) stated that the Former Parking and Storage Area is potentially radiologically impacted as the open area south of Former Building 327 (Salvage Building) was used as a salvage yard. The exact location of the salvage yard was not defined. Former Building 327 is located within the Former Parking and Storage Area southeast of Building 461 (see Figure 1-1). 1.3 REPORT OBJECTIVE This report details the procedures and results of the survey and sampling activities performed by Tetra Tech EC, Inc. (TtEC) to defend unrestricted release of IR Site 6. The objective of the report is to prove a sufficient number, locations, quality, and results of radiation surveys combined with RMAC-0809-0025-0008 Fnl FSS IR Site 6 1-1 Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 a sufficient number, location, quality, and results of environmental samples will demonstrate that the results meet the release criteria specified in Section 3.0, below. The appendices to this report are organized as follows: Appendix A provides information about the instrumentation used for the survey. Appendix B provides the associated instrumentation calibration certificates. Appendix C contains the Treasure Island Background Reference Area Memorandum (Shaw 2012). Ancillary, material, and equipment surveys are contained in Appendix D. The figures illustrating survey maps and the final sample locations to support the Final Status Survey (FSS) are included in Appendix E. Appendices F, G, H, and I provide the survey measurement results, gamma survey results, miscellaneous screening U.S. Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) laboratory results, and FSS radioanalytical results, respectively. Appendix J presents the residual radioactivity (RESRAD) dose and risk modeling summaries. The Task-specific Plan (TSP) for the Radiological Characterization, Remediation, and FSS at IR Site 6 (TtEC 2014a) is included in Appendix K. Appendix L provides information regarding the construction of Building 461 and the adjacent sidewalk and enclosed stairwell on the southeast side of Building 461. Appendix M provides the instrument chi square calculations and quality control documentation. Appendix N presents the Response to Comments on the Draft FSS report. RMAC-0809-0025-0008 Fnl FSS IR Site 6 1-2 Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 FIGURE 1-1. RMAC-0809-0025-0008 Fnl FSS IR Site 6 IR SITE 6 SITE PLAN VIEW 1-3 Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 12.0 CONCLUSION AND RECOMMENDATIONS In total, approximately 3 cubic yards of material (soil and two objects) was remediated. A total of 2 samples identified the presence of 226Ra activity above the screening criterion. The maximum activity identified for 226Ra was 12.29 pCi/g. Elevated activity concentrations were successfully remediated and bounded by clean soil samples. Remediated material (soil and two objects) was transferred to the DON’s radiological waste contractor for off-site disposal. Post-remediation sample analytical results revealed that the residual activities were comparable to background. A total of 198 samples were collected over an area of 17,982 m2, for a sampling density of approximately 1 soil sample per 90.8 m2. A total of 312 alpha/beta static survey measurements were performed over an area of 3,666 m2, for a survey density of approximately 1 static measurement per 11.6 m2. The DON considers these sampling densities sufficient to mitigate any small areas of elevated activity that may have been present at the site. The survey results were reviewed to determine whether residual radioactivity was present and whether conditions within the SU were comparable to background. The maximum 226Ra concentration from the final definitive systematic samples was 1.03 pCi/g. Evaluation of the systematic sample results indicates that the remaining material within IR Site 6 meets the release criteria. The primary descriptive statistical parameters, including the mean and median, for 226Ra concentrations are less than the corresponding values listed in the Treasure Island Background Area document (Shaw 2012). The maximum 226Ra concentration of 1.03 pCi/g is less than the Treasure Island Background Area upper limit of 1.26 pCi/g as calculated using the third quartile, and is less than the screening criterion of 1 pCi/g above the NAVSTA TI Background Area of 0.668 pCi/g for 226Ra. The results of the alpha and beta surveys confirmed the absence of radiological contamination on concrete surfaces. The survey results were below the release criteria of 20 dpm/100 cm2 alpha or 1,000 dpm/100 cm2 beta removal contamination, or 100 dpm/100 cm2 alpha or 5,000 dpm/100 cm2 beta fixed contamination. The results from all FSS systematic samples were found to be comparable to background. The maximum dose and ELCR when using the higher of the reported activity or the MDA/MDL were 1.268 mrem/y with an ELCR of 2.019 10-5 in SU 1. These values are significantly less than the EPA risk management level of 3 x 10-4 (EPA 2014) or 12 mrem/y according to EPA’s OSWER 9285.6-20. Based on these results, the DON recommends IR Site 6 for unrestricted radiological release. RMAC-0809-0025-0008 Fnl FSS IR Site 6 12-1 Final Final Status Survey Report IR Site 6, Naval Station Treasure Island DCN: RMAC-0809-0025-0008 CTO No. 0025 N60028_001565 TREASURE ISLAND SSIC NO. 5090.3.A Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900 San Diego, California 92108-4310 CONTRACT NO. N62473-06-D-2201 CTO NO. 0021 FINAL FINAL STATUS SURVEY REPORT FOR BUILDING 343 October 31, 2008 DCN: ECSD-2201-0021-0008 BUILDING 343 NAVAL STATION TREASURE ISLAND TREASURE ISLAND, CALIFORNIA · Base Realignment and Ch>sure Program Management Office West' 1455 Frazee Road, Suite 900 . San Diego, California 92108:4310 CONTRACTNo. N62473-06-D-2201 CTONo.0021 FINAL FINAL STATUS SURVEY REPORT FOR B.UILDING 343 October 31, 2008 BUILDING 343 NAVAL STATION TREASURE ISLAND TREASURE ISLAND,' CALIFORNIA · DCN: ECSD-2201-0021-0Q08 \ ) TETRA TECH'Ee, INC. 1230 ColumbiaStreet, Suite 75'0 San Diego, California 92101-8536 . Cliff Stephan, " ,) . Patrick A Owens · Radiological Affairs Support Office Brian Maidrand . PTojectManager TETRA TECH EC, n'Jc. Document Control No. Contract No. N62473-06-D-2201 (RAC IV) File Code: TO: Contracting Officer Naval Facilities Engineering Command SW Ms. Beatrice Appling, AQE.BA Building 127, Room 108 1220 Pacific -; .. .. FROM: ECSD-220 1-0021-0008 -5.0- - - - - - - - - - - DATE: CTO: LOCATION: 11103/08 0021 Treasure Island, CA #/_ . ,--,(./ « A. N. Bolt, Program Manager DESCRIPTION: Final Final Status Survey Report for Building 343 October 31, 2008. Building 343 TYPE: VERSION: D D Final (e.g. Draft, Draft Final, Final, etc.) ADMIN RECORD: (PM to Identify) Yes [gJ SCHEDULED DELIVERY DATE: No COPIES TO: D 10/31/08 NUMBER OF COPIES SUBMITTED: D [gJ CTO Deliverable ContractlDeliverable Other 0/9C/6E Notification REVISION#: N/A D Confidential Category ACTUAL DELIVERY DATE: D 11/03/08 Copy of SAP to N. Ancog [gJ (Include Name, Navy Mail Code, and Number of Copies) NAVY: TtEC: OTHER: (Distributed by TtEC) K. Barba (BRAe) 0/1 C J. Whitcomb (BMOW.JW) 2C/2E N. Ancog (EVR.NA) lC D. Silva (EVR.DS) 3C/3E Basic Contract Files (AQE) lC B. Maidrand J. Reese C. Stephan Library Copy SD P. Owens -RASO Ie/IE *See Attached Cover Letter for Additional Distribution 1230 Columbia Street, Suite 750, San Diego, CA 92101 DatefTime Received TABLE OF CONTENTS / PAGE ABBREVIATIONS·AND ACRONYMS EXECUTIVE SUMMARY ; 1.0 SITE DESCRIPTION 1.1 SITE LOCATION AND DESCRIPTION 1.2 PRIOR HISTORICAL USE 1.3 CURRENT AND FUTURE BUILDING OR LAND USE.: 1.4 REPORT OBJECTIVES 1.5 REPORT ORGANIZATION ;..· 2.0 HISTORICAL SITE ASSESSMENT 2.1 PREVIOUS SURVEYS 2.2 RADIONUCLIDE OF CONCERN AND RADIATION CHARACTERISTICS 3.0 ., v , 4.0 5.0 ES-l 1-1· 1-1 1-1 1-2 1-2 1-2 : 2-1 RELEASE CRITERIA 3.1 DOSE RELEASE LIMIT 3.2 DCGL BASED ON DOSE LIMIT , 3.3 DCGL BASED ON REG GUIDE 1.86 3.4 DCGLw AND ALARA , 3.5 DIRECT APPLICATION OFDCGLS 3.6 INVESTIGATION LEVELS 3.6.1 Investigation Levels for Alpha and Beta Radiation Surveys 3.6.Z Investigation Levels for Gamma Radiation Surveys SURVEY DESIGN 4.1 OBJECTIVE OF SURVEYS 4.Z SURVEY UNITS 4.2.1 Survey Unit 1 4.2.Z· SurveyUnit2 REFERENCE AREAS 4.3 .., 4.4 STATISTICAL TESTS 4.5 DETERMINING THE NUMBER OF MEASUREMENTS AND/OR SAMPLES 4.5.1 Number of Data Points 4.5.2 Determining Areas of Elevated Activity ; 4.5.3 Example Calculation ofDCGLEMc FIELD ACTIVITIES 5.1 MOBILIZATION 5.2 EQUIPMENT AND MATERIAL SURVEYS 2-1 2-"1 3-1 3-1 3-1 .3-1 :.·3-1 . 3-2 3:-Z .3-Z 3-Z : 4-1 4-1 4-1 4-1 4-2 4-2 4-2 · 4-Z 4-3· .4-3 4-4 5-1 5-1 5-1 ./ 2201-0021-0008 Fnl FSS Bldg343.doc Final Final Status SillVey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTO No.. 0021 TABLE OF CONTENTS (Continued) PAGE 5.3 5.4 5.5 5.6 BUILDING SURVEyS FLOOR/GROUND SURFACES MEASUREMENTS DEMOBILIZATION ;.. ·.•.....5-1 .. 5-1 : 5-2 5-2 6.0 6-1 SURVEY INSTRUMENTATION 6.1 INSTRUMENT SELECTION ; 6-1 6.2. INSTRUMENT CALillRATION AND QUALITY ASSURANCE PROCEDURES 6-f 6.3 INSTRUMENT OPERATIONAL CHECKS 6-1 6.4 INSTRUMENTS FOR THE MEASUREMENT OF ALPHAAND BETA SURFACE ACTMTY ; 6-2, 6.4.1 Instruments for Static Measurement of Alpha and Beta Radiation Activity :......•.....;; ;........•....· ; 6-2 6.4.2 Instruments for Scan Surveys for Alpha and Beta Radiation Activity' :..........•................................................................... . 6.4.3 Instruments for Scan and Static Surveys for Gamma Radiation , Surface Activity · 6-2 6.5 INSTRUMENT FOR SWIPE SAMPLES 6-3 7.0 EFFICIENCY AND DETECTION SENSITIVITY - STATIC AND SCAN MINIMUM DETECTABLE CONCENTRATION 7.1 INSTRUMENT AND SURFACE EFFICIENCY 7.1.1 Instrument Efficiency · 7.1.2' Surface Efficiency 7.2 STATIC MINIMUM DETECTABLE CONCENTRATION 7.2.1 Calculation of Static Minimum Detectable Concentration for Alpha Surveys (126 cm2 [15.5 inz] probe) : : 7.2.2 Calculation of Static Minimum Detectable Count for Beta Surveys 2 ·2' (126 cm [19.5 In] probe) 7.2.3 Calculation of Static Minimum Detectable Count for Gamma Surveys 7.3 SCANNING MINIMUM DETECTABLE COUNT RATE 7.3.1 Determination ofMinimum Detectable Count Rate and Use of Surveyor Efficiency (Alpha, 126 cm2 [19.5 in2 ] probe) 7.3.2' Determination of Minimum Detectable Count Rate and Use of Surveyor Efficiency (Beta-Gamma, 126 cm2 [19.5 in2] probe) 7.3.3 Determination of Static Minimum Detectable Count Rate (Gamma NaI S.08-cm x 5.08 cm [2 in x 2in] probe) 7.4 SCAN MINIMUM DETECTABLE COUNT FOR ALPHA AND BETA 7.4.1 Scan MinimumDetectable Count for Concrete Surfaces (Beta2 . 2 . Gamma, 126 cm [19.5 III ] probe) 220!-0021-0008 Fnl FSS Bldg343.doc 11 7-1 7-1 7-1 7-1 . 7-2 7-3 7-3 7-3 7-4 7-6 7-6 7-6 7-7 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 .CTONo.0021 TABLE OF CONTENTS (Continued) PAGE 7.4.2 Scan Minimum Detectable Count for Concrete Surfaces (Alpha, 126 , ; cm2 [19.5 in2] probe) 7-8 8.0 SURVEY PROCEDURES AND MEASUREMENT DATA INTERPRETATION .•. .. 8:-1 8.1 REFERENCE (BACKGROUND) AREAS ....................•..................................... 8-1 8.2 DATA INTERPRETATION 8-1 8.2.1 Step One -Define the Problem · 8-2· 8.2.2 Step Two - Identify the Decision 8-2 8.2.3 Step Three - Identify Inputs to the Decision : 8-2 8;..2 ·8.2.4 Step Four - Define the Study Boundaries 8.2.5 Step Five - Develop a Decision Rule 8-2 8.2.6 Step Six - Specify Limits on Decision Error. 8-2 8.2.7 Step Seven - Optimize the Design for Obtaining Data 8-3 8.;.3 8.2.8 Analysis 8.3 SURFACE ACTIVITY MEASUREMENTS.. : 8-3 9.0 ANALYSIS AND RESULTS ·..............•.................................................................. 9-1 9.1 STATISTICAL TESTS ; 9-1 9.2 DECISION ERRORS ; : 9-1· 9.3 PAIRED T-TEST 9-2. 9.4 WILCOXON RANK SUM·TEST 9-2 9-3 9.5 STATIC ALPHA MEASUREMENTS AND RESULTS 9.6 .. STATIC BETA MEASUREMENT ANALYSIS AND RESULTS 9-3 9.7 STATIC GAMMA MEASUREMENT RESULTS 9-4 / 10.0 DOSE MODELING 10-1 11.0. CONCLUSION , 12.0 REFERENCES 2201-0021-0008 Fnl FSS B1dg343.doc ' 11-1 12-1 11l Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTONo.0021 TABLE OF CONTENTS .(Continued) TABLES Table 2-1 Radionuclide of Concern Table 3-1 Release Criteria Table 4-1 Survey Unit.Table Table 4-2 Area Factor Table for Radium 226 Table 9-1 Building 343, Room 101 Alpha Measurements Summary Table 9-2 Building 343, Room 101 Beta Measurements Summary Table 9-3 Building 343, Room 101 Gamma Measurements Sunimary Table 10-1 Dose Modeling Results FIGURES Figure 1-1 Regional Location Map Figure 1-2 Site Location Map Figure 1-3 Building 343, Floor Plan and RM 101 Schematic Figure 4-1 Survey Unit 1 Surveillance Points Figure 4-2 Survey Unit 2 Surveillance Points APPENDICES Appendix A Survey Instrumentation AppendixB Instrument Calibration Documentation Appendix C Alpha and Beta Analysis Appendix D Gamma Analysis Appendix E Field Survey Data Sheets AppendixF Materials and Equipment Release Data Appendix G Project Photographs Appendix H Dose Modeling Reports Appendix I Background Data Appendix J Response to Comments 2201-0021-0008 Fnl FSS B1dg343.doc iv Final Final Status Survey Report for Building 343 Treasure Island, Califomia DCN: ECSD-2201-0021-0008 CTONo.0021 EXECUTIVE SUMMARY· Building 343 is a one-story metal building located at Naval Station Treasure Island on the eastern portion of Treasure Island in the block bordered by Avenues M and N and 5th and 8th Streets. Naval Station Treasure Island is located in San Francisco Bay approximately midway between the City of San Francisco and the City of Oakland. Building 343 is currently not in use; however, future reuse scenarios are under development. Redevelopment of Naval Station Treasure Island facilities is under the responsibility of the Treasure Island Development Authority. The site is located in parcel number T067, which is slated for mixed use and will likely include residential and community areas. The Treasure Island Historical Radiation Assessment (Naval Sea Systems - Command [NAVSEA],2006) stated that Building 343 was part of the Radiation Detection; Indication and Computation Maintenance Calibration School from the early 1950s to the 1970s. Activities in Building 343 associated with the school included training personnel in the use and calibration of radiation detection equipment. After the school was closed, Building 343 was still used for storage of radiological sources and for radiological training into the early 1990s. The radiologically impacted .classification of Building 343 stems from its use for storage of radioactive sources at various times throughout its use. Radiological Affairs Support Office's (RAsa's) analysis of 172 wipes taken in Building 343 was reported in July 1993 (RASa, 1993a). RASa reported all beta(p) wipes were equal to or less than the lower limit of detection (LLD) for p of 88 disintegrations per minute (dpm), and all but six alpha (a) wipes were equal to or less than the LLD for a of 2.5dpm. Two of the six a wipes above the LLD were also above release limits. They were located on a counter top in the storeroom· (Room 101). Of the remaining four wipes above the LLD (but well below release limits), two were in shelves in the storeroom, one was on the floor in the restroom, and one was in a drawer in the Chemical, Biological, Radiological Defense Laboratory: Follow-up wipes were taken bythe Naval Technical Training Center (NTTC) to resolve the six a wipes (RASa, 1993b). NTTC reported that the areas were decontaminated using commercial decontamination spray foam. RASa analyses of the six areas resurveyed by NTTC determined that all six were less than the LLD for both a and p (RASa, 1993c). There were no direct surveys taken, and the wipes were not analyzed for gamma (y) isotopes. An additional 95 wipes were forwarded to RASa for a, p, and y analyses of the remainder of Building 343 in July 1993 (RASa, 1993d). RASa reported all p wipes were equal to or less than the LLD for p of 92 dpm, and all but two of the a wipes were less than or equal to the LLD for a of 2.1 dpm. The two a wipes above the LLD were well below the release limits. All wipes were counted as a group for y in a high purity germanium detector for 50,000 seconds. No yother than natural background was detected (RASa, 1993e). / 2201-0021-0008 Fnl FSS B1dg343.doc E8-1 . Final Final Status Survey Report for Building 343 Treasure Island, California . DCN: ECSD-2201-002J-D008 . CTO No. 0021 Based on the previous activities· performed, it was determined that a final st:;ltus survey was necessary of Building 343, Room 101 to clear the building for unrestricted use. Radium-226 has been identified as the radionuclide of concern.' The Multi-AgenCy Radiation Survey and Site Investigation Manual (Department of Defense et aI., 2000), the Nonparametric Statistical Methodology for the Design and Analysis ofthe Final Status Decommissioning Survey Guide (Nuclear Regulatory Commission, 1998), and the' Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions (Nuclear Regulatory Commission, 1997) were used as guidance in designing and conducting the Final Status Survey at Building 343, Room 101. The room was organized into two survey units, a single Class I and a single Class 2 survey unit. Final status survey measUrements consisting of fixed static and scan measurements for a; 13, and y radiation, in addition to swipe samples for. loose a, 13, and y. radiation, were taken during September 2007. Building structure surfaces were considered acceptable for unrestricted use if the residual radioactivity that was distinguishable .from background resulted in a total effective dose equivalent (TEDE) to an average member of the critical group not exceeding 25 millirem per year (mrem/y) as specified in 10 Code of Federal Regulations 20, Section 1402, and the residual radioactivity was reduced to levels as low as is reasonably achievable (ALARA). The critical group refers to the group of individuals reasonabiy expected to receive the greatest exposure to . residual radioactivity for the reuse intended for the site. Based on previous comments received from the California Department of Public Health, the following release criteria were established. Building structure surfaces will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed the acceptable surface contamination limits from Regulatory Guide 1.86. To ensure ALARA was met, the Navy demonstrated, through radiological surveys and surface swipe sampling, that the radiation levels for structure surfaces did not exceed the smaller value of the acceptable surface contamination limits from Regulatory Guide 1.86 and the screening levels from NUREG/CR-5512, Vols. 2 and 3. c Survey results were statistically analyzed using the Wilcoxon Rank-Sum test to determine if residual radioactivity was present and if conditions within the survey units met the release criteria for unrestricted use. All survey and sample results indicate that Room 101 of Building 343 meets the release criteria and the building can be released to unrestricted use. Furthermore,. the survey results were used to show that the calculated dose to the critical group is 0.048 mrem/y, which is less than the I mrem/y TEDE release criterion. 2201-0021-0008 Fnl FSS Bldg343.doc ES-2 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTONo.0021 ' 1.0 SITE DESCRIPTION This section includes information on the site location and description, prior historical use, current and future building or land use, and the report objectives. 1.1 SITE LOCATION AND DESCRIPTION Naval Station Treasure Island (NAVSTA TI) is located on two islands, Treasure Island (TI) and Verba Buena Island, in San Francisco Bay. NAVSTA TI is located approximately midway between the City of San Francisco and the City of Oakland (Figure 1-1). TI is a man-made island approximately 32.4 square kilometer (km2) (403 acres) in size connected by a man-made Buena Island (a natural island). causeway to the 0.69-km2 (170-acre) . Building 343 is .located in the eastern portion of TI, in the block bordered by Avenues M and N and 5th and 8th Streets. Figure 1-:-2 shows the location of Building 343 on TI. /. Building 343 is an approximately 743.2 square meters (m2) (8,000 square feet [ft2]), one-story metal building on a concrete foundation located on the eastern part of TI. Room 101, a storeroom is the only potentially impacted room in Building 343, per theNAVSTA TI Historical Radiologi·cal Assessment (HRA) (Naval Sea Systems Command [NAVSEA], 2006). Room 101 is located in the northwestern corner of the building and is approximately 83 cubic meters (2,930 cubic feet), measuring roughly 4.88 meters (m) (16 feet [ft]) by 5.67 m (18.6 ft)by 3 m (9.8ft) high. The room has three doors: an entry from the hall to the south-southeast, a door to adjacent Room 102 to the east-northeast, and a door to the outside of the building to the north-northwest (Figure 1-3). 1.2 PRIOR HISTORICAL USE The NAVSTA TI HRA (NAVSEA, 2006) states that Building 343 was part of the Radiation, Detection, Indication and Computation (RADIAC) Maintenance Calibration School from the early 1950s to the 1970s. Activities in Building 343 associated with the school included training personnel in the use and calibration of radiation detection equipment. After the school was closed, Building 343 was still used by the Naval Technical Training Center (NTTC) for storage of radiological sources and for radiological training into the early 1990s. The radiologically impacted classification of Building 343 stems from its use for storage of radioactive sources at various times throughout its use. In support of these activities, an inventory of sealed radioactive sources was maintained on site. Building 343 was the last building on site authorized for . possession of radioactive materials. The last sources were removed from the building in the early 1990s. In June 1993, the Navy performed closeout surveys ofBuilding 343 in support of a request to terminate the remaining radioactive material possession license. There were no known leaks in 2201-0021-0008 Fnl FSS Bldg343.doc 1-1 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 crONo.D021 Building 343; however, swipe testing in support of tennination of the active Navy Radioactive Materials Pennit showed two out of six elevated alpha (a) radiation wipe readings on a counter top in the storeroom (Room 101). 1.3 CURRENT AND FUTURE BUILDING OR LAND USE Building 343 is currently not in use and has been unused for many years. Future reuse scenarios are under development; however, the most recent TI Development Authority documents show that Parcel Number T067, where Building 343 is located, will be zoned for residential and community use. Under this redevelopment scenario, it is anticipated that the building will be removed. 1.4 REPORT OBJECTIVES Detail the procedures and results of the Final Status Survey (FSS) perfonned for Room 101 of Building Demonstrate that the estimated residual dose to the critical group (a receptor assumed to occupy aroom inthe building with contaminated floor, ceiling, and walls for light industrial use, per the guidance in Technical Basis for Calculating Radiation Doses for the Building Occupancy Scenario Using the Probabilistic RESRAD-BUILD 3.0 Code) is less than 25 millirems per year (mrem/y). REPORT ORGANIZATION 1.5 This report is organized as follows: • Section 1.1 presents the site description. • Section 2.0 describes the historical site assessment. • Section 3.0 provides the release criteria. • Section 4.0 describes the survey design. • Section 5.0 details the field activities. • SeCtion 6.0 describes the survey instrumentation. • Section 7.0 provides theefficiency and detection sensitivity. • Section 8.0 details the survey procedures and measurement data interpretation. • Section 9.0 provides the analysis and results. • Section 10.0 provides the dose modeling. • Section 11.0 provides the conclusions. • Section 12.0 provides the references. • Table and figures follow the text. 2201-0021-0008 Fnl FSS Bldg343.doc 1-2 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTONo.0021 Appendices· A and B provide survey instrumentation data and instrument calibration documentation. Appendices C through Epresent field measurements. Appendix F includes materials and equipment release data, and Appendix G is a photographic log of activities at Building 343, Room 101. Appendix H provides dose modeling reports, Appendix I provides background data sheets from the reference area. \ 2201-0021-0008 Fnl FSS Bldg343.doc 1-3 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-220I-0021-0008 CTONo.0021 2.0 HISTORICAL SITE ASSESSMENT This section includes infonnation on the previous surveys, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (DoD et aI., 2000) classification, and the radionuclide of concern (ROC) and radiation characteristics. 2.1 PREVIOUS SURVEYS The Treasure Island HRA (NAVSEA, 2006) stated that in June 1993, the Navyperfonned closeout surveys of Building 343 in support of a request to terminate the remaining radioactive material possession license. The license termination request documented the disposition of all sources, remaining at Building 343. Swipe surveys of all sources, source containers, and associated rooms in Building 343 were documented. Additional documentation included results froIllleak tests conducted on ex radiation calibration sources stored in Building 343. Radiological Affairs Support Office's (RASO's) analysis of 172 wipes taken in Building 343 was reported in July 1993 (RASa, 1993a). RASO reported all beta (P) wipes were equal to or less than the lower limit of detection (LLD) for Pof 88 disintegrations per minute (dpm), and all, but six, a wipes were equal to or less than the LLD for a of 25 dpm. Two of the six a wipes above the LLD were also above release limits. They were located on a counter top in the storeroom (Room 101). Of the remaining four wipes above the LLD (but well below release limits), two were in shelves in the storeroom, one was on the floor in the restroom, and one was in a drawer in the ChemiCal, Biological, Radiological Defense Laboratory. Follow-up wipes were taken by the NTTC to resolve the six a wipes (RASO, 1993b). NTTC reported that the areas were decontaminated using commercial decontamination spray foam. RASa analyses of the six areas resurveyed by NTTC determined that all six were less than the LLD for both a and P (RASO, 1993c). There were no direct surveys taken and the wipes were not analyzed for gamma (y) isotopes. An additional 95 wipes were forwarded to RASO for a, p, and y analyses of the remairiderof Building 343 in July 1993 (RASa, 1993d). RAsa reported all p wipes were equal to or less than the LLD for Pof92 disintegrations perminute (dpm), and all but two of the a wipes were less than or equal to the LLD for a of 2.1 dpm. The two a wipes above the LLD were well below the release limits. All wipes were counted as a group for y in a high purity germanium detector for 50,000 seconds. No yother than natural background was detected (RASa, 1993e). 2.2 RADIONUCLIDEOF CONCERN AND RADIATION CHARACTERISTICS Historical records indicate the potential presence of radioactive materials within Building 343. 26 Radium-226 CZ Ra) is the primary ROC. Table 2-1 lists the ROC, principal types of radiation (a, fl, and )'radiation), and associated half-lives identified for measurement purposes. 2201-0021-0008 Fnl FSS Bldg343.doc 2-1 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-oo21-oo08 CTONo.0021 11.0 CONCLUSION .Building 343, Room 101 was used for storage associated with the RADIAC Maintenance Calibration School on Treasure Island. Building 343 is an approximately 743 m 2 (8,000 ft2), onestory metal building on a concrete foundation. According to the HRA, Room 101 is the only potentially contaminated room in Building 343. The room is located in the northwestern corner of the building. Room 101 of Building 343 was considered radiologically impacted due to the storage of radioactive materials in the building, known elevated measurements during previous surveys of the room, and other radiological activities at TI. Room 101 was cleared of shelving, counters, and floor tiles and investigated for residual contamination. An FSS was conducted to detennine the radiological status of the room and, if appropriate, release the building for unrestricted use. Surveys of Building 343, Room 101 and associated materials and equipment were conducted in September 2007. The room was organized into two survey units: floor and lower walls (Class 1, Survey Unit 1) and ceiling and upper walls (Class 2, Survey Unit 2). FSS methods included, where appropriate, fixed static and scan surface contamination surveys for ex and {3 radiation, static and scan measurements for 'Y radiation, exposure rate measurements, and swipe samples for loose a, {3, and 'Y radiation. Survey results were statistically analyzed using the WRS test to determine if residual radioactivity was present and if conditions within the survey units met the release criteria for. unrestricted use. All survey and sample results indicate that Building 343, Room 101 meets the release criteria, and the building can be released to unrestricted use. The statistical test results can be found in Appendix C and D. The analysis of collected field data shows that the residual radioactivity at Building 343, Room 101 meets the stated release criteria, and that Building 343, Room 101 is ready for unconditionalunrestricted use. Dose modeling based on average net concentration level of the ROC resulted in calculated doses of 0.048 or less mrem/y for both survey units, which is less than the 1 mrem/y TEDE release criterion. 2201-0021-0008 Fnl FSS B1dg343.doc 11-1 Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTONo.0021 DETAIL AREA INSET NAVAL STATION TREASURE ISLAND PLEASANTON PACIFIC OCEAN 4 LEGEND - ...... Feet ...... N FINAL STATUS SURVEY REPORT FOR BUILDING 343 FIGURE 1-2 SITE LOCATION MAP t-_RFii'iSi7)N-?_ _ SAN FRANCISCO, CALIFORNIA REVISION: 2 AUTHOR: GFG DCN: ECSD-2201-0021-0008 FILE NUMBER: 080088S2172.mxd "'r.L ------I TETRA TECH EC.INC RM 101 INSET LEGEND 2.29m N fZZI BUILDING WALL SHELF/COUNTER 1.10m NOTE: m·METER 4.88m H O.46m RM 101 • STORAGE ROOM RM-ROOM o.91mI ·1l;1.91m I 5.67m Rw 'Ill· HALLWAY - / / , , V· · . / RM 103 I RM104 RM 105 - - RM 108 RM 115 - - RM 109 RM 110 RM 111 RM112 I RMl06 RM113 RM 116 RM 114 BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CALIFORNIA FINAL STATUS SURVEY REPORT FOR BUILDING 343 FIGURE 1-3 BUILDING 343 FLOOR PLAN AND RM 101 SCHEMATIC NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA NOT TO SCALE REVlSION:O FilE NUMBER; 0800e8Uln,mo:d I @ 11: TeTRA TECH -C.!r r 1 .. -------5.67 2.00 m m---------··I • • • • Wall 2 • • • • • • Floor Wall 3 • Wall 1 • • • • • • • 2.00 m----.l • BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CA LEGEND E:ZJ 4.88 m • Wall 4 • I I I I I I I I I I SURVEY POINT FINAL STATUS SURVEY REPORT FOR BUILDING 343 DOOR FIGURE 4-1 SURVEY UNIT 1 SURVEILLANCE POINTS NOTE: NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA m - METERS NOT TO SCALE REVISION: 1 AUTHOR: RKH DCN: ECSD-2201-0021-0008 FILE NUMBER: 080088L2214.mxd [11::) TETRA TECH EC INC 5.67 m - - - - - ------- - - - - - - I • 1.00 m • • • I I I Wall 2 • • • -, • • Wall 1 • • 4.88 m Wall 3 Ceiling • • • • • • Wall 4 • - - - - -------- ------ • - BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST SAN DIEGO, CA LEGEND • • SURVEY POINT FINAL STATUS SURVEY REPORT FOR BUILDING 343 DOOR FIGURE 4-2 SURVEY UNIT 2 SURVEILLANCE POINTS NOTE: NAVAL STATION TREASURE ISLAND SAN FRANCISCO, CALIFORNIA m - METERS NOT TO SCALE REVISION: 0 AUTHOR: RKH DCN: ECSD-2201-0021-0008 FILE NUMBER: 080088L2215.mxd [-..:] TETRATECHEC INC Page_1_of-2.- RADIATION/CONTAMINATION SURVEY FORM Date: Time: 9/19/2007 12:30 Survey Number: RSRS-B1dg-343-MRSM-091907 Location: Surveyor: Building 343 43-68 95526 2929 182585 379.48 1.20 S RolfefT Standfuss 432.92 2350-1 126182 lliJ [ill Reviewed By: B Henderson Isotopes of Concern: 226 Ra Survey Type: Final Status Survey Description of survey: BLDG 343 Floor and Walls [ill 24737,1.1988 3,0353,1.1988 [Z] 06383,4.5670 4.2589, 1.1988 2.4235,4.5670 42006, 4.5670 0.9356,1.1988 [22]4.3450,1.1988 [TI 0.6383,2.7813 2.5598, 1.1988 ITQ] 0.7746,1.1933 [1] 0.6383,0.9967 EtQj14.1.1988 Comments: 2350 - Scan range 3.2 - 4.4 Kcpm. Scan Ranges 0 - 2 cpm alpha and 140-250 cpm beta. Smears and statics taken at survey points labeled on map. [IJ 2.4235,2.7818 [L] 2.4235,0.9967 3.1963,1.1988 [§] 1.19S8 4.2086,2.7818 ELJ 4.2085,0.9967 1.4111,1.1988 [JLJ # denotes swipe location or fixed !f denotes G/A radiation readings alP readings # / # denotes contact I 1 meter radiation readings. * denotes highest radiation reading on contact [!] denotes smear and static locations Ii. denotes large area masslinn wipe Unless Otherwise Noted All readings in K = 1000 unless otherwise noted RADIATION/CONTAMINATION SURVEY SUPPLEMENT SURVEY NUMBER: Page_2_of_2_ RSRS-Bldg-343-MRSM-091907 1 4.6 4391 7.26 663.40 -1.20 -86.05 2 4.5 4290 7.26 704.75 -1.20 24.65 3 4.7 4490 1.88 631.25 -1.20 -61.45 4 4.5 4341 1.88 654.22 0.80 -2.41 5 4.4 4246 -3.50 631.25 -1.20 -78.67 6 4.4 4203 1.88 516.39 0.80 -44.23 7 4.3 4090 1.88 576.11 -1.20 -29.47 8 4.4 4185 -3.50 585.30 0.80 -46.69 9 10 4.3 4 4075 3785 1.88 1.88 553.14 309.65 -1.20 -1.20 -22.09 -29.47 11 3.9 3764 12.64 217.77 -1.20 -58.99 12 4.1 3905 -3.50 125.88 -1.20 -73.75 13 4.3 4085 1.88 360.19 -1.20 17.27 14 3.7 3541 7.26 410.72 -1.20 -24.55 15 4 3792 1.88 199.39 -1.20 0.05 16 4 3797 1.88 351.00 0.80 -66.37 17 4.1 3881 -3.50 305.06 2.79 -7.33 18 4.3 4107 -3.50 488.82 0.80 -17.17 1.88 -3.50 438.29 410.72 -1.20 17.27 -24.55 3876 -3.50 Date: 10101/2007 383.16 0.80 19 4.3 4089 20 4.1 3940 21 4.1 Reviewer 1- ,,- RSO/RTM -1.20 -14.71 Date: 10102/2007 t- Time: 12:00 " Time: 12:00 r \ .- , Page_1_of _2_ RADIATION/CONTAMINATION SURVEY FORM Date: Time: 9/25/2007 14:30 Survey Number: RSRS-Bldg-343-Class-2-092507 Location: Building 343 Surveyor: S RolfelT Standfuss 43-68 95526 2929 182585 2350-1 126182 Reviewed By: B Henderson Isotopes of Concem: 226 Ra Survey Type: Building Release Description of survey: BLDG 343 Walls and Celing ... D- G ) -+ ® (0 -0 +-- (0 - - i t CD ® CD C0 CD t CD-..CD C0 ,,'3JJ - ® ® ® i ® I IJ - - 1Ci2:f Comments: # denotes swipe location or fixed 50% Scan on Celing and walls above 2 meters. !! denotes G/A radiation readings Static counts and smeard taken a highest reading found during scan. all3 readings # / # denotes contact 11 meter radiation readings. * denotes highest radiation reading on contact denotes smear and static locations 11 denotes large area masslinn wipe Unless Otherwise Noled i All readings in IJRlhr unless otherwise noted K = 1000 RADIATION/CONTAMINATION SURVEY SUPPLEMENT Page_2_of_2_ r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - , -, SURVEY NUMBER: 3.7 3521 1.88 658.81 0.80 -4.87 2 3.9 3677 7.26 906.90 4.78 -9.79 3 3.8 3643 -3.50 645.03 0.80 -29.47 4 3.7 3499 1.88 837.98 -1.20 -27.01 1 5 3.7 3570 1.88 645.03 0.80 -49.15 6 3.7 3520 1.88 796.64 -1.20 29.57 7 3.8 3657 -3.50 640.43 0.80 -68.83 8 4.1 3878 -3.50 755.29 -1.20 7.43 54.17 9 10 3.7 3.8 3579 -3.50 828.80 -1.20 3638 1.88 773.67 0.80 61.55 11 3.6 3448 1.88 746.10 -1.20 127.97 12 3.8 3628 1.88 778.26 -1.20 49.25 13 4.1 3889 1.88 755.29 0.80 9.89 14 4.1 3900 -3.50 815.01 0.80 17.27 15 3.9 3687 7.26 874.74 -1.20 83.69 0.80 113.21 16 3.9 3743 1.88 851.77 17 3.7 3527 1.88 727.72 -1.20 98.45 18 3.9 3692 -3.50 704.75 2.79 39.41 -3.50 3478 -3.50 3562 Date: 10101/2007 . 796.64 0.80 0.80 19 20 3.6 3.7 Reviewer . 805.83 RSO/RTM (---'0, Time: 12:00 ' .+\ 83.69 108.29 Date: 10102/2007 l '·><1 Time: 12:00 - APPENDIXF / MATERIALS AND EQUIPMENT RELEASE DATA .' 2201-0021-0008 Fnl FSS Bldg343.doc Final Final Status Survey Report for Building 343 Treasure Island, California DCN: ECSD-2201-0021-0008 CTONo.0021 "-. This page left intentionally blank. / \ \. ) 2201-0021-0008 Fnl FSS B1dg343.doc Final Final Status Survey Report . for Building 343 Treasure Island, California DCN: ECSD-2201-oo2I-0008 . CTO No. 0021 RADIATION/CONTAMINATION SURVEY FORM Date: Time: 9/14/2007 12:30 2 Page_1_ot ..... INSTRUMENTATION USED Model InstJDel Serial Number Surve Number: RSRS-Bld -343Shelves-091407 Location: Surve or: Buildin 343 2360 177117 4.3 43-68 190328 671.7 2929 182585 0.6 S Rolfe 1 T Standfuss 436.9 Reviewed B 2350-1 126182 44-10 230620 8/28/2008 2350 Static Count Time: 1 Minute 2360 Static Count Time: 2 Minutes All LAW's were S background a denotes GIA radiation readings Floor Scan - Scan Ranges - 0--3 cpm alpha and 80-100 cpm beta. 2350 - Scan range 3.5 - 4.2 Kcpm. #/ # denotes contact I 1 meter radiation readings. * denotes highest radiation reading on contact 11 denotes large area masslinn wipe Static counts were taken al smear locations. SEE ADDITIONAL PHOTOS ON PHOTO PAGE Unless Otherwise Noted denotes swipe location or fixed readings on backside All readings in K = 1000 unless otherwise noled 2 Page...l..of -4- RADIATION/CONTAMINATION SURVEY SUPPLEMENT RSRS-Bldg-343Shelves-091407 SURVEY NUMBER: SURVEYOR: S Rolfe I T Standfuss Fixed + Removable (NET) Exposure Rate {J.IR1hr} Location Contact I Removable (NET) Comments 1 Meter 1 2 LOCATION: Building 343 , 3 Alpha Beta/Gamma Alpha Beta/Gamma Gamma (cpm) dpml100cm 3815 6.46 95.56 -0.15 -13.28 3540 22.60 67.99 0.35 -13.28 4147 1.08 113.94 0.35 -11.44 2 dpm/100cm 2 dpml100cm 2 dpml100cm 4 3847 6.46 58.81 -0.15 0.25 5 4171 1.08 -5.51 0.85 -16.97 6 4085 1.08 159.88 0.35 -4.67 7 3746 6.46 26.65 -0.15 12.55 8 3702 1.08 35.83 -0.15 -12.67 9 3841 11.84 49.62 -0.15 1.48 10 3632 17.22 12.86 -0.15 -4.67 11 3986 11.84 31.24 -0.15 -4.06 12 4062 -4.30 113.94 0.35 6.40 13 3676 1.08 17.46 0.35 -0.37 14 3577 6.46 -88.21 0.85 -5.29 15 3626 6.46 -33.08 0.35 -13.90 16 3619 1.08 141.50 -0.15 4.55 17 3752 11.84 100.15 -0.15 -10.21 18 3873 -4.30 12.86 0.35 4.55 19 4179 11.84 45.02 3818 6.46 141.50 0.35 -0.15 -12.67 20 " 3796 -4.30 45.02 -0.15 -12.05 3861 6.46 150.69 1.35 10.09 23 3685 1.08 -19.30 -0.15 8.24 24 4032 6.46 150.69 -0.15 6.40 25 4063 1.08 77.18 -0.15 -8.98 26 3848 11.84 45.02 -0.15 -2.21 27 3941 11.84 164.47 0.35 -2.21 28 3743 -4.30 205.82 0.85 -14.51 29 30 3885 1.08 11.84 224.20 67.99 -0.15 10.09 -14.51 Date: Reviewer 3880 Date: Time: RSO/RTM 0.35 "i. , I"', i ,. " "3 -16.36 22 21 2 Time: ...-:;1\ /.' < " l: , -' ,r" BACKGROUND DETERMINATION DATA SHEET Instrument Model: Calibration Due Date: 2360 8/28/2008 Instrument Serial No. :177117 Detector Model: 43-68 WOOD Todays Date:9/12/2007 Data and Calculations Reviewed B : Count Number Gross Count Count Time CPM 1 0 2 0 2 0 2 0 3 0 2 0 4 1 2 0.5 2 0.5 5 6 2 2 1 7 0 2 0 8 2 2 1 9 1 2 0.5 10 0.5 =sum(X) Mean Count =sum(X)/10 Total 4 0.4 0.39 Standard Deviation (- Date: 9/12/2007 BACKGRo.UND DETERMINATION DATA SHEET Instrument Model: 2350 Calibration Due Date: 8/28/2008 Instrument Serial No. :126182 Detector Model: 44-10 WOOD Todays Date:9/12/2007 Data and Calculations Reviewed By: oBeta-Gamma (Check One) Count Number Gross Count Count Time 1 3776 1 2 3625 1 3625 3 3667 1 3667 4 3769 1 3769 5 3765 1 3765 6 3730 1 3730 7 3893 1 3893 8 3807 1 3807 9 4258 1 4258 10 4067 1 4067 11 3918 1 3918 12 . 4375 1 4375 13 4261 1 4261 14 4191 1 4191 15 3824 1 3824 16 4033 1 4033 17 3845 1 3845 18 3987 1 3987 19 3810 1 3810 20 4061 1 4061 =sum(X) Mean Count =sum(X)/20 Total , 3776 78662 3933.1 212.93 Standard Deviation (0") Background Count Rate = Mean CPM 3933.1 CPM x 2cr 4358.96 Calculations Completed By: Date: 9/12/2007 Data and Calculations Reviewed Date: 9/12/2007 \ I / RADIATION/CONTAMINATION SURVEY FORM Date: Time: 9/14/2007 12:30 Page_1_of_2_ Surve Number: RSRS-Bld 343Tile-091407 Location: Buildin 343 Surve or. S Rolfe 1 T Standfuss Reviewed B B Henderson ROOM 101 INSET EXIT ® 0 EXlT ® ® ® 11 ® <0 ® ® - - 8 ® ® RM 101 CD 8 @ AGE ROOM ® ® CD Reviewer .- 4.82 ,(., 11Ut l .' 6460 26.63 -211.10 -0.18 -131.86 6376 48.16 -146.79 1.81 -146.62 6350 21.25 -270.83 -0.18 -126.94 6587 75.06 -110.03 -0.18 -129.40 53.54 -266.23 3.81 -124.48 6416 32.02 -105.44 -0.18 -92.50 6390 53.54 -312.18 -0.18 -90.04 6409 64.30 6427 53.54 Date: 9/28/2007 -73.28 1.81 -330.55 -0.18 -151.54 -112.18 Date: 6392 Time: RSO/RTM • ;, -- :'- 1M ..... N FIGURE 1-2 SITE LOCATION MAP __ SAN FRANCISCO, CALIFORNIA REVISION: 2 AUTHOR: GFG DCN: ECSD-2201-0021-0009 FILE NUMBER: 080090S2174.mxd ...... 1-'- TETRA TECH EC.INC LEGEND SECOND FLOOR • RM203 - 08 5