DRAFT COMMENTS ON THE PARCEL G DESIGN BASIS REPORT

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

Parcel G Design Basis Report Fact Sheet

Fact Sheet: Review of Parcel G Design Basis Report, Hunters Point Naval Shipyard

March 17, 2010

Prepared for a Community Meeting of the India Basin Neighborhood Association

The Navy has circulated a report that provides the 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” has been prepared to implement the Record of Decision issued prepared by the Navy on February 18, 2009.

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 and will reduce the risks of getting cancer to a level that is less than one in a million for a person with lifetime exposure to contaminants at the site. 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 cleaned up in 2008.

Comments are due to the Navy on March 29, 2010.

Please contact Matt Hagemann, India Basin Neighborhood Association Technical Consultant, with any suggestions for comments, or with questions or concerns. Matt can be reached at (949) 887-9013 or mhagemann@swape.com.

Hunters Point Shipyard Cleanup Update
Meet the Technical Advisor: Matt Hagemann

Wednesday March 17 6-8pm
Our Lady of Lourdes Church
Community Room
410 Hawes St.
San Francisco, CA 94124

Agenda Topics Will Include:

• An overview of the EPA’s Technical Assistance Grant, IBNA’s role as TAG Administrator, and IBNA’s workplan
• An introduction to Matt Hagemann of SWAPE Inc. (Soil, Water, Air Protection Enterprise, Inc.)
• An overview of pending decisions at Parcel G (the proposed stadium site)
• Your questions

For More Information Contact:
Kristine Enea (415) 609-5322 or Alex Lantsberg (415) 938-6170

India Basin Neighborhood Association Selects Technical Adviser

After a thorough review process, the India Basin Neighborhood Association selected Soil Water Air Protection Enterprise (SWAPE) to serve as its technical adviser for the Hunters Point Shipyard Cleanup Technical Assistance Grant awarded by the US Environmental Protection Agency.

IBNA will introduce SWAPE to the community at a community meeting in the near future, the exact date of which is still being finalized. Community members will have the opportunity to meet SWAPE's Project Director Matt Hagemann and engage him on the critical technical issues facing the Shipyard's cleanup. Because we expect the Navy to release the Draft Final Feasibility Study for Parcel E sometime in December, the meeting may also include issues related to this important document.

SWAPE is an environmental consulting firm that brings outstanding experience and success to clients on projects involving complex environmental issues. Its clients include a diverse variety of law firms, municipalities, environmental consulting firms, community groups, non-profit organizations, developers, and industries. SWAPE's principals and staff have a diverse range of backgrounds in environmental science, engineering, epidemiology, toxicology, and environmental health. Its team has extensive experience providing expert services to legal clients on some of the largest environmental litigation projects in the nation.

SWAPE has extensive personal and professional relationships with local, state, and federal regulatory officials in most agencies that regulate environmental policy. These long-standing relationships in government and knowledge of regulatory policy allow it to bring experience to decision making involving regulatory and compliance issues and will be an invaluable asset to the Bayview Hunters Point community during the Hunters Point Shipyard cleanup process.

For more information contact alex@indiabasin.org.

REQUEST FOR PROPOSALS

REQUEST FOR PROPOSALS

Technical Consulting Services for Review of Hunters Point Shipyard Superfund Cleanup Documents

The India Basin Neighborhood Association (IBNA) is seeking proposals from qualified firms and/or individuals to provide technical consulting services to facilitate public participation and input into cleanup decisions at the Hunters Point Shipyard (HPS). HPS is a former military base closed in 1974 and designated in 1993 for eventual transfer to the City and County of San Francisco.

Principal duties will include:

• TECHNICAL REVIEW of 13 major and 31 Supplemental documents as identified in review schedule approved by the EPA. Technical Advisor will also provide written comments that will formally submitted to the Navy and EPA as part of the cleanup process.
  
• PUBLIC PRESENTATIONS to provide information, answer
  questions, and solicit community input about significant documents and
  cleanup proposals. Because of resource constraints, presentations will
  be scheduled as required to provide input on major documents at
  critical decision points.
• PREPARE FACT SHEETS as concise and easily understood “translations” and distillations of cleanup documents at critical decision points. Each reviewed and commented on cleanup document will be accompanied by a distillation of the issues and decisions contained within it, written in a popular and accessible style. Chinese and Spanish translation capability is highly desirable.

The ideal respondent will posses:

• Technical capability to review soil, water, and air toxins issues as they may arise at Hunters Point Shipyard.
  
• Extensive experience with Superfund designated BRAC facilities and the military base reuse process.
• Experience working with diverse environmental justice communities.
  

Complete responses will include a statement of qualifications,
curricula vitae of key personnel, and samples of relevant work.


Total compensation is $45,000 over the three year grant period, billable quarterly.

In order to commence the project expeditiously responses to this RFP should be provided electronically to alex@indiabasin.org by September 20, 2009. A decision will be made by October 3, 2009.

Proposals will be reviewed by IBNA's TAG Committee and approved by the
nine-member board of directors. IBNA has the right to reject any or
all proposals.