The Navy has prepared a report that provides a design for cleanup of contaminated soil at Parcel G, a 40 acre tract that was part of an area used for shipping, ship repair, office and commercial activities. The February 10, 2010 report, entitled “Design Basis Report, Parcel G” implements the Record of Decision issued by the Navy on February 18, 2009. The following comments have been prepared for review by the India Basin Neighborhood Association prior to submittal to the Navy by the March 29, 2010 deadline.
The cleanup will involve excavation of two truckloads of soil that is contaminated with lead and benzo(a)pyrene. Lead is a probable carcinogen and affects blood and the nervous system and impairs reproduction and development. Benzo(a)pyrene is a probable carcinogen. The cleanup will also involve the removal of 20 truckloads of material from soil stockpiles. The origin of the soil stockpiles is unknown and the stockpiles have not been sampled for contamination.
After excavation, Parcel G will be paved with asphalt to prevent exposure to underlying soil. The soil excavation and asphalt pavement will achieve goals for protecting the health of the public that were established in the February 18, 2009 Parcel G Record of Decision. Vapors in soil beneath Parcel G will also be tested to ensure that any occupants of buildings will not be exposed to contaminants. Groundwater underlying Parcel G is not addressed by the Design Basis Report. Groundwater was addressed in a 2008 pilot study.
The India Basin Neighborhood Association would like to provide the following comments for consideration in the revision of the Parcel G Design Basis Report:
Specific Comments:
1. A residential scenario is considered for Parcel G in the November 12, 2009 “Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project (Draft Environmental Impact Report (see “Housing Variant, Land Use Plan, http://www.sf-planning.org/ Modules/ShowDocument.aspx?documentid=318). However, human health risks from contaminated soil have been estimated for all 40 acres of Parcel G on the basis of industrial and recreational land use scenarios, with the exception of a Tract 30A, a small, 1.7 acre parcel. The Design Basis Report, prepared subsequent to the release of the DEIR, should be revised to include a supplemental assessment of human health risk under a residential land use scenario. Failure to consider residential land use in the ROD and the Design Basis report, envisioned as a viable scenario in the DEIR, would result in inadequate cleanup if housing were to be constructed at Parcel G.
2. The use of a durable cover (asphalt cap) at Parcel G is of a concern to the community. Concerns with the use of the cap include:
- uncertainty in the durability of the asphalt
- responsibility for the long term maintenance.
We understand that the Record of Decision selected the use of an asphalt cap for Parcel G to address soil contamination. However, the Design Basis Report should address these concerns by better specifying how the use of a cap will protect health over the long term and the responsibility for maintenance of the cap, considering the potential for early transfer and potential changes to land use.
3. Soil stockpiles should be sampled prior to removal. Sampling is necessary to protect the community from dust that would be generated during stockpile removal and from dust that will be generated as trucks take the material through the community for disposal.
4. Removal of contaminated soil via trucks that would utilize transportation corridors within the community should be reconsidered. The use of rail or barges is preferred for transport of excavated soil and stockpiled material from Parcel G to an offsite disposal facility.
General Comments:
1. All documents available for review by the community should be posted at the Navy’s website: http://www.bracpmo.navy.mil/ basepage.aspx?baseid=45&state=California&name=hps.
2. Future remedial activities that would involve the excavation and removal of contaminated soil should consider alternatives to transportation of the material through the community. Alternatives should include transport by barge and by rail. Consideration of these alternatives will protect residents along the transportation corridors from inhalation of dust.
3. Alternatives to use of a durable cover (asphalt) should be considered in future decision documents for the remaining parcels.
4. The cumulative risk from all contaminants from all routes of exposure should be included in all future decision and design documents. The community is concerned that documents such as the Parcel G Design Basis Report parses risks from soil from risks posed by radiological contaminants, for example, and thereby does not facilitate the understanding of total site health risks to human health.
Matt Hagemann
SWAPE
3110 Main Street, Suite 205
Santa Monica, California 90405
Tel: (949) 887-9013
Email: mhagemann@swape.com
Fax: (949) 717-0069
