by Lauren Borja
This briefing book summarizes secondary sources documenting radiological contamination at Hunters Point Shipyard (HPS), the procedures used to assess and remediate these sources, and ensuing controversies. These summaries do not attempt to assess the accuracy of the claims made in the referenced documents. This briefing book is intended only to assist your navigation of reports that might otherwise be too long and complex to understand and should be used in conjunction with the other briefing books and other sources. Please consult the citations for details.
Sources of Radiation
In 2000, the Navy issued a two-volume report assessing the history of radiological contamination at Hunters Point. The first volume discusses the activities related to the Navy Nuclear Propulsion Program (NNPP) and generated by maintenance and repairs of nuclear-powered ships and submarines in the shipyard. The second volume discusses sources of radiation beyond the narrow scope covered by volume I.
Many organizations conducted operations at Hunters Point that led to contamination by radioactive materials. From 1946-1951, HPS decontaminated and conducted experiments on target ships that participated in the Operation Crossroads nuclear test. Experiments using radiation were performed from 1946-1948 under the San Francisco Shipyard Radiation Safety Section or Radiation Laboratory (RADLAB). After 1948, radiological experiments continued under the Naval Radiation Defense Laboratory (NRDL), which closed in 1969. In 1976, the contractor Triple A, a commercial ship repair company, took over operations of the shipyard until 1986. From 1985 through 1989, the Navy resumed operations at Hunters Point.
Lastly, onsite investigations pose a risk of contamination release due to disruptions of the soil or demolition of buildings. Many of the contaminants, radiological or otherwise, reside in the soil. Disruptions to the soil, which could be caused by strong wind, construction, or even environmental sampling, produce dust, which could also contain contaminants. This toxic dust is at the heart of the lawsuit between the San Francisco police officers and the Hunters Point clean-up contractor, Tetra Tech.
The Navy’s assessments list several potential sources of radiological contamination. Radioluminescent dials, gauges, and deck markers were used, repaired, and disposed of at the shipyard. Gamma radiography was used to test metals and welds. Radioactive sources were used to calibrate laboratory equipment and survey instruments. Ships contaminated during the atomic weapons testing were decontaminated and used for research. The RADLAB and NRDL also used radioactive isotopes during their extensive experimentation. Work on nuclear-powered ships and submarines occurred at HPS from 1966-1989, continuing under contractors after the Navy left. This could have released radiation through small volumes of liquid, solid, or gas into the harbor. Radioactive particles could have escaped via the industrial filtration systems. Trace amounts of fission products could have been released during maintenance of the ships’ nuclear reactors.
A full list of the radionuclides used at HPS, their half-lives, and radiation they emit is presented in a table following Section 4 of the “Final Historical Radiological Assessment, History of the Use of General Radioactive Materials 1939-2004 Volume II.”
The U.S. Navy and associated contractors have prepared the Historical Radiological Assessment to investigate areas within Hunters Point that have been impacted by radiation, called an impacted site. According to this report:
An impacted site is one that has potential for radioactive contamination based on historical information, or is known to contain or have contained radioactive contamination…Once a site is designated as impacted, it remains “impacted” even after any residual contamination is removed.
Determination of this status involves scientific methods such as identification of radioactive material. Historical information, including surveys and interviews of previous employees as well as archival research, also influences this determination.
History of Radiological Regulations at HPS
While adverse effects of radiation were observed within a year of its discovery, formal radiation standards for protecting humans were not developed until 1934. The Manhattan Project provided additional incentives and means for developing limits for human exposure to radiation. These standards have continued to evolve up to the present day.
When activities involving radioactive materials began at HPS, the Navy was still in the process of establishing controls for the handling and disposal of radioactive material. Many of these controls were formed in conjunction with research performed at the RADLAB and NRDL at HPS. Formal standards for radium-226 were developed in 1942, and the first Radiological Safety Manual for general radioactive materials was issued in 1947. For example, the components of the uranium-based atomic bomb that was dropped on Hiroshima were loaded onto a naval battle cruiser at Hunters Point on July 15, 1945. These components were stored at Hunters Point for a period of time beforehand, however the duration and location of this storage is unknown.
The Atomic Energy Commission began requiring licenses for various radioactive materials in 1954. Licenses were issued to NRDL and HPS (and later the San Francisco Naval Shipyard) beginning in 1958 and 1959, respectively. Licenses granted to HPS were primarily granted for gamma radiography and calibration of radiation detection devices. Licenses granted to the NRDL authorized
- general radioactive materials,
- radioactive material for human experiments
- radioactive material for high-intensity radiation studies,
- radioactive material for tracer studies,
- disposal of radioactive waste at sea,
- radioactive fuel,
- decontamination of buildings and waste during NRDL’s closure
- radioactive material for calibration of instruments
- studies involving special nuclear materials
In addition to radiation-specific activities, some common-place items, such as smoke detectors or watches, contained radioactive isotopes. The regulation of these commodities began in the late 1960s. Because their disposal was unregulated before this time, it is “likely” that some of these items were disposed of as “normal trash” in the either the Landfill Area (IR-01/21), Bay Fill Area (IR-02), or other commercial landfills. Today, radioactive commodity items continue to appear in Hunters Point, including in areas outside these landfills. No records of radioactive materials licenses or activities have surfaced for the period when the contractor Triple A managed the shipyard (1976-1986).
The Naval Assessment and Control of Installation Pollutants (NACIP) Program was created in the mid-1980s as part of the mandatory U.S. DoD compliance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), commonly referred to as Superfund. This program performed an Initial Assessment Study (IAS) at HPS, completed in 1984. This ultimately led the U.S. Environmental Protection Agency (EPA) to place HPS on its National Priorities List (NPL) in 1989. In 1992, the Navy, EPA, and State of California signed a Federal Facility Agreement (FFA) to establish regulatory responsibilities. As a federal Superfund site, Hunters Point Shipyard is subject to oversight from the EPA. The California Department of Toxic Substances Control (DTSC) plays a similar role at the state level. The California Department of Public Health (CDPH) regulates the cleanup and clearance of buildings at the sites, and the Regional Water Quality Control Board (RWQCB) enforces water quality regulations, especially with regards to groundwater.
For Superfund sites requiring remediation of radiological contamination, the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) provides the CERCLA-consistent guidelines to mitigate these risks. This process guides historical radiological assessments of previous buildings and structures on the site. It also assesses how radiological contamination may have migrated throughout the impacted area. Data collected by the MARSSIM process include archival research, site assessments, personal interviews, site designation and classification, and identification of radionuclides of concern. The MARSSIM process shapes recommendations for remediation actions.
The MARSSIM process designated sites as “impacted” if there was evidence or suspicion of radioactivity due to storage, disposal, or other unusual activities (such as spills or discharges). Impacted sites are rated as
- none: radiation fully assessed and removed, remains impacted but requires no action,
- unknown: radiation levels not established,
- unlikely: no expected radiation, but further investigation needed,
- likely: expected radioactivity, but further investigation needed,
- known-continued access: low levels of radioactivity present in a contained or inaccessible area,
- known-restricted access: known radioactivity that requires protective measures.
Contamination is assessed in surface soil, subsurface soil, sediment, surface water, groundwater, air, structures, and drainage systems. It is classified as high, moderate, low or none. Recommendations are provided for the impacted sites along the following definitions:
- emergency action: immediate remediation or containment,
- scoping survey: historical documents indicate need for minimal surface scans and sampling,
- characterization survey: radioactive contamination confirmed but extend must be determined through in-depth surveys,
- remediation: radioactive contamination is characterized and removal/remediation must be conducted,
- final status survey: site has been remediated historically, but verification needed to assure it complies with MARSSIM standards,
- free release: has been historically remediated, ready to be released for non-radiological use,
- no further action: meets release criteria.
Historical Investigations, Surveys and Studies
During the closure of Hunters Point, the Navy summarized all previous historical investigations, surveys and studies of radioactive materials in the “Final Historical Radiological Assessment, History of the Use of General Radioactive Materials 1939-2004 Volume II.” These are summarized below. For further details, please consult the Historical Radiological Assessment to find citations for specific documents generated by the study. What follows is merely a roadmap to find historical material. For critiques of the methods and conclusions in these historical surveys, see the reports published by the Committee to Bridge the Gap.
Hunters Point has also been divided and subdivided into various “Parcels,” to facilitate transfer of naval lands to the City of San Francisco. The parcel system was established by the Navy in 1992, with five contiguous parcels (A through E), encompassing the immediate shoreline surrounding Hunters Point. Parcel F, was added in 1996 and Parcel A was transferred from the Navy to the San Francisco Redevelopment Agency (SFRA) in December of 2004.
Roadways received a special “UC” labels. Further division of the initial seven parcels (A – F) occurred as follows:
- landfill in Parcel E designated Parcel E-2 in September 2004,
- Parcel D was subdivided into Parcel D-01, D-02, G, and UC-1
- the western edge of Parcel C labeled Parcel UC-2 in July 2008,
- UC-3 was formed from the Crisp Road roadway and nearby areas of Parcel E
From 1946 through 1948 the RADLAB and NRDL surveyed and decontaminated the ships from Operation Crossroads. Decontamination efforts included sandblasting “all rust and marine growth” into containers and disposed of in the Bay. The dry docks were then washed thoroughly; most radiation measurements at the time found the level to be equivalent to background.
In 1955, NRDL began the process of surveying its own buildings for decommissioning. Operations were consolidated into Building 815; surveys were conducted in various buildings that were then released for use. Most of these buildings were released without exception, except for two buildings. These buildings, 506 and 351A, required special treatment of drain lines from the building. It is important to note that radiological standards for release were less stringent that in later years. See Figure 2, Radiation Dose Limits over the Past Century for an example of how regulations have changed over the past century. The data in this figure only goes up to 1993; see the source article for more information.
In 1969, the NRDL conducted more surveys in view of its eventual disestablishment. The NRDL Health Physics Division was tasked with
- removing all radioactive sources (such as those used in device calibration);
- measuring of external radiation levels;
- swiping test areas were general radiation activities were performed;
- decontaminating by scrubbing with detergents, acids or dilute complexing agents;
- chipping, sandblasting, vacuuming, and high-pressure cleaning impacted areas;
- dismantling and disposing of the remaining radioactive equipment.
The Atomic Energy Commission (AEC) conducted the final inspection. The items removed from various buildings were documented, finding no detectable levels of radiation “that exceeded the release limits using detection equipment available at the time.” While detection equipment used was likely more sensitive (and the standards stricter) than that used in the previous decade, the sensitivity of modern equipment is much higher. Residual radioactivity was detected in isolated areas around Building 364, including in the floor and pipes.
From 1969 to 1970, the AEC conducted surveys to verify NRDL’s results. The AEC performed 22 surveys, which included spot testing and collection of radiation levels (alpha, beta, and gamma). Readings were only collected in areas where the AEC determined radiation may have occurred. Many of the buildings were released for unrestricted use because they were below the minimum regulatory levels at the time. The drain in Building 364 had higher radiological reading and was filled with concrete as an additional control measure.
In 1974, surveys began to prepare Hunters Point for Base Closure. The purpose of these surveys was to “ensure that areas where [radiological]-related operations were conducted met applicable radiological release criteria…However, available documentation does not indicate survey or decontamination procedures.”
In April of 1978, LFE Environmental Analysis Laboratories, Inc. (LFE), surveyed Building 815 again, following a change in the Nuclear Regulatory Commission’s allowable radiation levels from 1969 to 1978. The second survey found that various ventilation and laboratory equipment (heating and air ducts, and chemical workstations) contained radioactive isotopes or elevated radiation levels. The survey recommended the radiation either be removed or painted over. The Radiological Affairs Support Office (RASO) performed another survey of Building 815 in July of 1978 to confirm these findings. Isolated “hot spots” were detected in the building. RASO recommended further surveys.
Based on results in Building 815, RASO continued surveying other former NRDL buildings. It retested other buildings by conducting alpha and beta-gamma scans, swipe sampling for alpha and beta-gamma activity, and radionuclide content analysis of soil, paint scrapings, wood scrapings, and other bulk samples. These tests found radiation levels above the Nuclear Regulatory Commission (NRC) guidelines in Building 364.
RASO resurveying continued into 1979 with the retesting of Buildings 364, 815, and 816. According to the Historical Radiological Assessment, every square foot of Building 364 was surveyed for radiation, cleaned by removing paint or chipping away concrete, and then resurveyed until radiological levels fell below an acceptable minimum. In Building 815, decontamination procedures included
- removal of flooring, sinks, surfaces, paint, and concrete;
- cleaning of cabinets, light fixtures, and laboratory workstations;
- vacuuming dusts from ventilation ducts;
- sanding or scraping metal surfaces and floors in the machine shop;
- removing contaminated plumbing.
Building 816 was retested because instruments used previously could not detect some the radiation known to exist. Swipe samples collected for every 50 square feet of floor and wall space found levels below AEC guidelines. All three buildings were cleared for unrestricted use.
In 1986, the Naval Nuclear Propulsion Program requested that the EPA conduct a harbor survey at Hunters Point. The EPA collected bottom sediment, water, and biological specimens (sea lettuce and mussels) near various drydocks and piers in HPS. Trace quantities of cesium-137 were detected in the harbor floor, although the level was not significantly greater than the amount generally observed due to testing of nuclear weapons worldwide. None of the levels were deemed larger than background levels.
Harding Lawson Associated conducted site reconnaissance from 1988 to 1989. These efforts included surface surveys at the Industrial Landfill, the Bay Fill Area, and the Submarine Base Area. These surface surveys revealed radioactivity levels greater than background levels taken at other HPS and Bay Area locations. Elevated readings near the Industrial Landfill were detected, but these were determined to be due to bedrock. Surface gamma radiation levels in the Bay Fill Area were also above background levels, but these were deemed below the reporting limits at the time. The Sub-Base Area gamma radiation levels were within the background of HPS and the Bay Area.
The Remedial Investigation program from 1999 to 2001 was conducted in five phases, along with several interim investigations. This program characterized the scope of remediation efforts at Hunters Point required by the Superfund designation.
Phase I consisted of a surface confirmation radiation survey (SCRS) that included air, soil, and groundwater sampling of many of the landfill areas (Industrial Landfill, Waste Oil Disposal Area, the Sub-Base Area). Several areas were found with higher than normal readings in the areas, some of which contained radium devices, like deck markers. Soil samples taken during this phase contained radium-226 and its daughter products at levels above the naturally occurring background. Measurements of ground water were inconclusive, because particulate matter in the water interfered with analysis. Additional building surveys were conducted; Building 364 (which had been mislabeled Building 351A) had elevated alpha and gamma activity in certain areas.
Following Phase I, Phase II tested for radioactivity below the surface in Parcels B and E, to compare the frequency of radium-containing devices in these areas with the landfill areas. Surveyors dug pits and trenches to test the gamma radiation counts at various depths. While some excavations contained no elevated radiation levels, others contained radium-containing devices, elevated radionuclides, elevated gamma radiation due to geological features. Several interim investigations were also conducted on the soil surrounding Building 816 (previous tests had only sampled inside the structure itself) and additional soil samples from Parcel E. The additional soil surveys revealed that radioactivity from the radium-containing devices might leech into the surrounding soil. The survey recommended removing both the devices and soil in future decontamination efforts. A study of the soil in Parcel B found naturally occurring radioactive isotopes, but that these had not been impacted by HPS activity. Point sources of radium-226 were also removed from the drydock; their existence was known prior to removal. Previous studies had been concerned with other radionuclides, so sources of radium-226 were not removed at the time. Surface soil was removed in area contaminated with cesium-137 outside of Building 364 until the remaining soil was below the amount regulated by the NRC. Some of the waste containers generated by these surveys were tested for radiation. Those that exceeded an established count rate were disposed of by a radiological waste company. The remainder, including ones that had received no testing, were disposed of using normal procedures.
Phase III focused on radiological issues related to (1) NRDL operations at HPS, (2) the licensing of G-RAM use by the NRC in support of NRDL activities, and (3) preliminary findings for buildings and sites used by NRDL in Parcel B. Measurements conducted in this phase were performed by conducting gamma radiation walk over surveys and soil, asphalt, concrete and swipe samples. Some buildings were cleared for unrestricted public use (351A, 507, 508, 510, 510A), but additional investigations were recommended for Buildings 364, 509, 517, 529, and 707. An interim assessment of Parcel E was conducted by Tetra Tech to evaluate exposures and risks to human health. This assessment calculated risk using a model from the Department of Energy based on detected radioactive anomalies within a given area and the proposed use of the area (industrial versus residential). By law, Superfund sites must have an “acceptable” range of excess lifetime cancer risk between one ten-thousandth (1/10,000 or 10-4) and one millionth (1/1,000,000 or 10-6). Their results indicated that people living or working within these areas would not experience an excess lifetime cancer risk (ELCR) greater than 10-4 due to radium-226 in the soil but some areas contained ELCRs greater than 10-4 for radium-222 in the air. The study also clarified that because most people would only be visiting the HPS area for recreational or industrial use (i.e. exposure for less than 10 or 100 days per year, respectively), the actual exposure risk would be much lower.
Phase IV was performed to quantify ambient concentrations of specific radionuclides and to further characterize the presence of cesium-137 in contamination sites outside Buildings 364 and 707. Other radionuclides did not rise above site-specific background levels. Additional interim assessments were performed on sandblast waste, the Gun Mole Pier, the tank vault behind Building 364, and the Parcel E shoreline. Radioactivity sampling of the sandblast waste and the Gun Mole Pier was within background levels. The tank was removed from Building 364 after it was found to exceed site release criteria. The survey of Parcel E shoreline found some areas that exceeded gamma radiation levels that contained radium-226 contamination. These locations were marked on a map but not removed.
From 2001 to 2003, Phase V investigations and removal actions occurred according to MARSSIM; the procedures under MARSSIM differed significantly from previous radiological investigation procedures. The actions taken in this phase are summarized in Table 6-6: Phase V Action Summary, found in the “Final Historical Radiological Assessment: History of the Use of General Radioactive Materials 1939-2003 Volume II.”
Conclusions of 2004 HRA
Because the conclusions of the Historical Radiological Assessment determine many of the actions at Hunters Point over following decades, they are reproduced here.
“The HRA concludes that:
- The potential for residual radioactive contamination exists and needs to be addressed at 60 of the impacted sites.
- The potential for residual radioactive contamination has been addressed at
27 impacted sites. Contamination at these sites was either not present or found and remediated. These sites are recommended for free release pending review of the Final Status Survey Report by the Navy and appropriate regulatory agencies.
- Two of the impacted sites require No Further Action because they were assessed previously and determined to be qualified for free release by RASO (Radiological Affairs Support Office) and CDHS (California Department of Health Services).
- To date, no historical information about radiological operations or previous radiological investigations at any of the impacted sites presents a level of concern that would require any Emergency Action.
- To date, high-level contamination has not been found at the site nor is the potential considered a possibility by the HRA.
- To date, 11 impacted sites require restricted access due to known levels of undisturbed radioactive contamination.
- To date, no evidence for potential airborne contamination has been found.
- To date, potential pathways for contamination migration remain within the impacted site areas. No pathway has been identified for contamination to migrate off the HPS site.
The overall conclusion of the HRA is that, even though there is potential residual radioactive contamination at 60 of the 91 impacted sites, the contamination is expected to be at low levels within the confines of HPS. Recommendations have been made to assess the remaining areas of potential contamination and address its removal. The review of previous radiological activities, cleanup actions, and release surveys has not identified any imminent threat or substantial risk to tenants or the environment of HPS or the local community.” The Committee to Bridge the Gap has critiqued the conclusions of this report due to the limited nature and scope of the sampling.
Remediation reports after the HRA
The EPA requires documents, called Records of Decision (ROD), to release Superfund lands to the public. These are summaries of previous remediation activities taken, future remediation activities needed, and the roles of stakeholders (such as the Navy or local agencies in the case of Hunters Point) in those processes. There is also a period of public comment before RODs are finalized. After RODs have been issued, five-year plans are produced to document long-term maintenance of the land. Records of decision have been issued for all parcels except for Parcel F, which describes the Hunters Point offshore area.
Since the HRA, Four Five-Year reviews have been conducted. These are administrative and community processes where reports are compiled to document remedial activities in the various parcels of Hunters Point. Convenings of the five-year review committees were announced in local news and the public was invited for comment at certain meetings. These documents discuss other sources of contamination from industrial chemicals used at Hunters Point such as asbestos or lead paint. Some of them contain summaries of comments presented by national, state, and local regulatory boards (e.g. the EPA, California Department of Toxic Substances Control, or Regional Water Quality Control Board). Comments from and interviews with the public are also included.
Parcel A was transferred to the City of San Francisco in 2004. It is not discussed in any of the Five-Year Reviews. The Final Finding of Suitability to Transfer for Parcel A finds that items such as radioactive contaminants, polychlorinated biphenyls, radon, and petroleum-related compounds occur at levels that do not pose a threat to human health or the environment. Lead paint and asbestos were found in some buildings; restrictions were placed on future use and demolition of these buildings. In 2018, a radioactive deck marker was found on this parcel.
Second Five-Year Review, November 2008
Parcel B is the main subject of the Second Five-Year review. Despite a ROD being signed in in 1997, additional updates to remediation were signed in 1998 and 2000. Called explanations of significant difference (ESD), these updates discuss additional methods for remediation of soil and groundwater contamination. These include additional soil remediation for industrial contamination, such as mercury or methane, and for radiological contaminants, due to the leakage of radiation from plumbing or ship deck markers. The initial ROD for Parcel B did not contain a remedy for addressing radiological contamination. Groundwater remediation was updated because the previous ROD only discussed monitoring, which would not be sufficient to address new concerns, such as the leaking of contaminants from the breakdown of materials in industrial landfills on Parcel B.
The findings of the Second Five-Year review caused the Navy to revise its remediation strategy; in addition to addressing the problems enumerated above, the Navy began to implement the use of durable covers as part of the remediation process. The initial ROD for Parcel B called for the excavation and disposal of soil contaminated with chemicals above remediation levels. As the Navy began to undertake remedial action, however, it began to encounter higher amounts of heavy metals in the soil than expected. The use of covers allowed for greater amounts of contaminated soil to remain onsite. This strategy was later replicated in the RODs for other parcels.
Third Five-Year Review, November 2013
The third Five-year report cited continuing issues with release of high levels of mercury in the ground water in Parcel B. Tetra Tech had removed soil from the area and covered the remaining ground to limit the release of contamination, including radioactivity, to the air. The area in Parcel B has land use and activity restrictions to manage the exposure to contamination. For example, construction that disturbs the soil could present an increased exposure to contaminated soil, dust and groundwater.
For Parcel C, “Soil excavation, and off-site disposal, groundwater treatment…soil vapor (SVE)…[and] Radiological removals are underway.” After the removal process is complete, covers will be installed to prevent further exposure. Similar to Parcel B, access restrictions will be placed on land to prevent further exposure.
In Parcel D-1, groundwater and soil treatment procedures were underway in 2008 and 2010, respectively. Removal of radiological contamination is also underway. Construction of covers will proceed after the radiological contamination has been fully removed. Access restrictions are in place during this and future constructions.
Soil (2010), groundwater (2008) and radiological contamination have been completely addressed in Parcel G. The Department of Toxic Substances Control (DTSC) approved the land for “unrestricted release for radionuclides.” Covers have also been installed, but construction in the area still poses a higher risk for exposure to contaminants.
In Parcels UC-1 and UC-2, radioactive contamination had been addressed through removal and cover. The DTSC approved both parcels for access, but certain activities, such as the drinking of ground water, are restricted under Industrial Controls (ICs) to limit exposure to industrial toxins in the soil. In parcel UC-2, volatile organic compounds are present, but the report says that these concentrations are either below the limit or naturally decreasing.
Fourth Five-Year Review, July 2019
The Fourth Five-Year Review occurred after the Tetra Tech scandal came to light in 2014 (see below). The review expresses concern over radiological remediation activities in Parcels B-1, B-2, C, D-2, G, E, UC-1, UC-2, and UC-3.
Protocol Violations and Data Falsifications
In 1992, a San Francisco jury found Triple A, the company that operated HPS after the Navy closed down its base, guilty of violating the California Hazardous Waste Control Act from 1985-1987. Criminal penalties on the cases were assessed at $9.2 million, but later reduced to $115,000. A civil suit filed by the city of San Francisco in 1987 requested $300 million to cover the cost of cleaning up the hazardous chemicals, which included polychlorinated biphenyls, industrial solvents, and paint. The civil case was settled for $1.1 million.
In 2000, a fire at the shipyard landfill burned for a month, releasing smoke and contaminants into the air. The EPA later fined the Navy for failing to notify the community about the incident in a timely manner.
In 2014, NBC Bay Area Investigative Unit reported that Tetra Tech had falsified many of the soil samples taken at Hunters Point. The investigation centers around an internal report from Tetra Tech, in which the company admits that tested soil was “collected from locations different than the ones specified.” Tetra Tech was responsible for describing the scope and character of radiological contamination at Hunters Point, which included the writing of the Third Five-Year Review. Tetra Tech employees have admitted to deviating from Navy testing protocols and replacing soil samples with “clean dirt” from areas that had already been remediated. Documents obtained by the Public Employees for Environmental Responsibility, through Freedom of Information Act requests state that the EPA found that 93% of soil sampling data is suspect. As a result, the EPA halted all pending land transfers at the shipyard in 2016.
Because of this scandal, questions have arisen about contamination in areas that share boundaries with the impacted areas. In 2018, the Navy and the California Department of Public Health agreed to retest Parcels G and A, respectively. Almost immediately after this announcement, the Committee to Bridge the Gap criticized the retesting efforts, describing them as inadequate. The U.S. EPA has also criticized the Navy’s Parcel G retesting plan.
Other investigations in 2018 by the San Francisco Chronicle reported that the Navy failed to accurately communicate risks to the city of San Francisco. As a result, Nancy Pelosi has called for a federal investigation into the cleanup. These issues echo earlier concerns raised by residents and activists over the Navy’s dissolution of the Restoration Advisory Board (RAB), an elected board of community members that provided input on the remediation process, in 2009.
Despite many calling the retesting efforts inadequate, a radioactive object was found during the retesting effort in Parcel A. The California Department of Public Health has said that this radioactive deck marker is not hazardous to public health, but the Committee to Bridge the Gap has said that this portrayal is misleading. As a result of its retesting, the California Department of Public Health said that Parcel A poses no threat to public health; however, a health physicist who used to work at the California Department of Public Health and a Navy consultant on radiation data have questioned these conclusions.
More recently, in 2019, the Committee to Bridge the Gap has also critiqued the covers used by the Navy to limit release of contamination in Hunters Point. In addition to questioning the efficacy of the covers, residents and activists contend that the use of covers contravenes Proposition P, a non-binding measure passed in 2000 that requires the cleanup of the shipyard to the highest standards for residential use.
 “Historical Radiological Assessment Hunters Point Annex Volume I Naval Nuclear Propulsion Program 1966-1995” (Pearl Harbor, Hawaii: Radiological Control Office, Pearl Harbor Naval Shipyard & Intermediate Maintenance Facility, August 2000), https://www.navfac.navy.mil/niris/SOUTHWEST/HUNTERS_POINT_NS/N00217_000128.PDF; “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard” (Yorktown: Naval Sea Systems Command, August 2004), https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_shipyard_hunters_point/pdfs/all_documents/environmental_documents/radiological/hps_200408_hra.pdf.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 4–2.
 Jason Fagone and Cynthia Dizikes, “SF Let Shipyard Cops Work amid Tons of Toxic Dirt, Told Them They Were Safe,” San Francisco Chronicle, November 9, 2018, https://www.sfchronicle.com/bayarea/article/SF-let-shipyard-cops-work-amid-tons-of-toxic-13375196.php; Jason Fagone and Cynthia Dizikes, “Hundreds of SFPD Officers Sue Hunters Point Contractor over Health Problems – SFChronicle.Com,” November 18, 2019, https://www.sfchronicle.com/bayarea/article/Hundreds-of-SFPD-officers-sue-Hunters-Point-14844785.php.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 1–4.
 “Historical Radiological Assessment Hunters Point Annex Volume I Naval Nuclear Propulsion Program 1966-1995.”
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 1–2.
 William C. Inkret, Charles B. Meinhold, and John C. Tascher, “A Brief History of Radiation Protection Standards,” Los Alamos Science, 1995 This document is written by radiological scientists from US national research laboratories. .
 United States Department of Energy, “Advisory Committee On Human Radiation Experiments Final Report,” 1996, https://ehss.energy.gov/ohre/roadmap/achre/intro_3.html.
 United States Nuclear Regulatory Commission, “Options to Revise Radiation Protection Regulations and Guidance,” accessed January 17, 2020, https://www.nrc.gov/about-nrc/radiation/related-info/opt-revise.html.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 5–3.
 Ibid., 6–4.
 Ibid., 5–6.
 Ibid., 5–7.
 Ibid., 5–9.
 Phil Matier and Andy Ross, “State Says Radioactive Deck Marker Found at Hunters Point Not Really Dangerous,” San Francisco Chronicle, December 5, 2018, https://www.sfchronicle.com/bayarea/matier-ross/article/Radioactive-deck-marker-found-at-Hunters-Point-13443355.php.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard.”
 OLEM US EPA, “Superfund: CERCLA Overview,” Overviews and Factsheets, US EPA, (September 9, 2015), https://www.epa.gov/superfund/superfund-cercla-overview.
 “Initial Asessment Study of Hunters Point Naval Shipyard (Disestablished)” (Port Hueneme, CA: Naval Energy and Environmental Support Activity, October 1984), https://www.bracpmo.navy.mil/brac_bases/california/former_shipyard_hunters_point/documents1.html#Overallbasewide.
 OAR US EPA, “Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),” Policies and Guidance, US EPA, (January 30, 2015), https://www.epa.gov/radiation/multi-agency-radiation-survey-and-site-investigation-manual-marssim.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 4–7.
 Ibid., 8–2.
 A list of the CBG reports on Hunters Point can be found at “Hunters Point Reports – Committee to Bridge the Gap,” accessed November 30, 2019, http://committeetobridgethegap.org/hunters-point-reports/.
 Tim Mower, “Final Third Five-Year Review of Remedial Actions Hunters Point Naval Shipyard San Francisco, California” (San Diego, CA: Department of the Navy, Base Realignment and Closure Program Management Office West, November 8, 2013), ES-1, https://www.bracpmo.navy.mil/brac_bases/california/former_shipyard_hunters_point/documents1.html#Overallbasewide. Because many of these studies discuss specific buildings, the Table 3-3: Current and Former Facilities at HPS by Building Number in “Final Historical Radiological Assessment, History of the Use of General Radioactive Materials 1939-2004 Volume II” may be useful. Additionally, for a site-specific treatment, Section 8 of the same document presents a summary of each impacted site.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 6–35.
 Ibid., 6–36.
 Inkret, Meinhold, and Tascher, “A Brief History of Radiation Protection Standards,” 121.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 6–39.
 Ibid., 6–40.
 Ibid., 6–41.
 Ibid., 6–42.
 Ibid., 6–44.
 Ibid., 6–45.
 Ibid., 6–47.
 OLEM US EPA, “Superfund Remedial Investigation/Feasibility Study (Site Characterization),” Policies and Guidance, US EPA, (September 16, 2015), https://www.epa.gov/superfund/superfund-remedial-investigationfeasibility-study-site-characterization.
 “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 6–51.
 Ibid., 6–53.
 Ibid., 6–54.
 Ibid., 6–55.
 Ibid., 6–56.
 Ibid., 6–57.
 Ibid., 6–58.
 Ibid., 6–60.
 Ibid., 6–61.
 Ibid., 6–63.
 US EPA, “Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).”
 For more information, see “Historical Radiological Assessment, Volume II, Use of General Radioactive Materials, 1939-2003, Hunters Point Shipyard,” 7–1.
 Ibid., 9–3.
 Daniel Hirsch et al., “The Great Majority of Hunters Point Sites Were Never Sampled for Radioactive Contamination and the Testing That Was Performed Was Deeply Flawed” (San Francisco, CA: Committee to Bridge the Gap, October 2018).
 A flow chart detailing this process can be found on Mike Goldstein, “A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents” (Washington, D. C.: United States Environmental Protecion Adgency, July 1999), https://www.epa.gov/sites/production/files/2015-02/documents/rod_guidance.pdf.
 Ibid., 1–2.
 Cynthia Liu, “Final Fourth Five-Year Review Hunters Point Naval Shipyard, San Francisco , CA” (San Diego, CA: Department of the Navy, Base Realignment and Closure Program Management Office West, July 2019), https://www.bracpmo.navy.mil/brac_bases/california/former_shipyard_hunters_point/documents1.html#Overallbasewide.
 Sami Malaeb, “Final Second Five-Year Review of Remedial Actions Hunters Point Shipyard San Francisco, California” (San Diego, CA: Department of the Navy, Base Realignment and Closure, November 11, 2008), https://www.bracpmo.navy.mil/brac_bases/california/former_shipyard_hunters_point/documents1.html#Overallbasewide; Mower, “Final Third Five-Year Review of Remedial Actions Hunters Point Naval Shipyard San Francisco, California”; Liu, “Final Fourth Five-Year Review Hunters Point Naval Shipyard, San Francisco , CA.”
 Julia Vetromile, “Finding of Suitability to Transfer for Parcel A (Revision 3) Hunters Point Shipyard San Francisco, California,” A-E CERCLA/RCRA/UST Studies and Remedial Action (San Diego, CA: Department of the Navy, Base Realignment and Closure Program Management Office West, October 14, 2004), https://www.bracpmo.navy.mil/brac_bases/california/former_shipyard_hunters_point/documents1.html#Overallbasewide.
 Malaeb, “Final Second Five-Year Review of Remedial Actions Hunters Point Shipyard San Francisco, California,” 11.
 Jason Fagone and Cynthia Dizikes, “Radioactive Object Found near Homes at Hunters Point Shipyard,” San Francisco Chronicle, September 14, 2018, https://www.sfchronicle.com/bayarea/article/Radioactive-object-found-near-homes-at-Hunters-13228476.php; Matier and Ross, “State Says Radioactive Deck Marker Found at Hunters Point Not Really Dangerous.”
 Malaeb, “Final Second Five-Year Review of Remedial Actions Hunters Point Shipyard San Francisco, California.”
 Mower, “Final Third Five-Year Review of Remedial Actions Hunters Point Naval Shipyard San Francisco, California.”
 Ibid., ES-3.
 Mower, “Final Third Five-Year Review of Remedial Actions Hunters Point Naval Shipyard San Francisco, California.”
 Jim Herron Zamora and Jane Kay, “TRIPLE A MACHINE SHOP TOXICS CASE,” SFGate, December 9, 1996, https://www.sfgate.com/news/article/TRIPLE-A-MACHINE-SHOP-TOXICS-CASE-3110790.php.
 Associated Press, “EPA Faults Navy Handling of 4-Week Landfill Fire,” Los Angeles Times, September 12, 2000, https://www.latimes.com/archives/la-xpm-2000-sep-12-mn-19730-story.html.
 Vicky Nguyen, Liz Wagner, and Felipe Escamilla, “Contractor Submitted False Radiation Data at Hunters Point,” NBC Bay Area, October 13, 2014, https://www.nbcbayarea.com/investigations/Contractor-Submitted-False-Radiation-Data-at-Hunters-Point-279025911.html.
 Erik Abkemeier and Greg Joyce, “Investigation Conclusion Anomalous Soil Samples at Hunters Point Naval Shipyard” (San Diego, CA: Tetra Tech EC, Inc, April 2014), ES-1, https://www.documentcloud.org/documents/1312386-tt-report-2.html.
 Liz Wagner, “Former Tetra Tech Workers Sentenced in Hunters Point Cleanup,” NBC Bay Area, May 3, 2018, https://www.nbcbayarea.com/investigations/Former-Tetra-Tech-Workers-Sentenced-for-Falsifying-Records-in-Hunters-Point-Radiation-Cleanup-481712331.html.
 Kirsten Stade, “SF-OWNED HUNTERS POINT PARCELS SOIL TESTING FALSIFIED,” PEER.Org, June 4, 2018, https://www.peer.org/sf-owned-hunters-point-parcels-soil-testing-falsified/; Lily Lee, “USEPA Review of the Draft Radiological Data Evaluation Findings Report for Pacels D2, UC-1, UC-2, UC-3, Soil, Former Hunters Point Naval Shipyard” (Washington, D.C: United States Environmental Protecion Adgency, March 30, 2018), https://www.peer.org/wp-content/uploads/attachments/6_4_18_EPA_reevaluation_D_UC.pdf.
 Jason Fagone and Cynthia Dizikes, “Hunters Point Shipyard Soil Scandal Widens as Analysis Spots Suspect Parcels,” San Francisco Chronicle, June 3, 2018, https://www.sfchronicle.com/bayarea/article/Hunters-Point-shipyard-soil-scandal-widens-with-12963202.php.
 J.K. Dineen, “Navy Releases Plan to Retest Part of SF Shipyard after Botched Cleanup,” San Francisco Chronicle, June 16, 2018, https://www.sfchronicle.com/bayarea/article/Navy-releases-plan-to-retest-40-acres-of-botched-12997862.php.
 J.K. Dineen, “State Will Test Developed Portion of Hunters Point Shipyard, but Critics Say It Won’t Be Enough,” San Francisco Chronicle, June 20, 2018, https://www.sfchronicle.com/science/article/State-will-test-developed-portion-of-Hunters-13009194.php; Daniel Hirsch, Taylor Altenbern, and Maria Caine, “Critique of the California Department of Public Health Work Plan for a Partial Gamma Survey of Parcel A-1 Hunters Point Naval Shipyard” (San Francisco, CA: Committee to Bridge the Gap, July 31, 2018), http://committeetobridgethegap.org/wp-content/uploads/2018/10/Critique_of_HPNS_ParcelA_GammaScan.pdf; “Critique of the Work Plan for Retesting of Parcel G Hunters Point Naval Shipyard” (San Francisco, CA: Committee to Bridge the Gap, August 15, 2018), http://committeetobridgethegap.org/wp-content/uploads/2018/10/WorkPlanCritique.pdf.
 Cynthia Dizikes and J.K. Dineen, “EPA Blasts Navy for Plan to Retest Soil at Former SF Shipyard,” San Francisco Chronicle, August 18, 2018, https://www.sfchronicle.com/bayarea/article/EPA-blasts-Navy-for-plan-to-retest-soil-at-former-13164851.php.
 Jason Fagone and Cynthia Dizikes, “Navy Failed to Alert San Francisco to Tainted Shipyard Water, Documents Show,” San Francisco Chronicle, August 4, 2018, https://www.sfchronicle.com/bayarea/article/Navy-failed-to-alert-San-Francisco-to-tainted-13130734.php.
 Jason Fagone and Cynthia Dizikes, “SF Shipyard Scandal: Pelosi Calls for Federal Probes,” San Francisco Chronicle, August 2, 2018, https://www.sfchronicle.com/bayarea/article/San-Francisco-shipyard-scandal-Pelosi-calls-for-13121300.php.
 Jennifer Liss Ohayon, “Addressing Environmental Risks and Mobilizing Democracy?: Policy on Public Participation in U.S. Military Superfund Sites,” in Proving Grounds: Militarized Landscapes, Weapons Testing, and the Environmental Impact of U.S. Bases, ed. Edwin A. Martini (Seattle: University of Washington Press, 2015), 175–210.
 Fagone and Dizikes, “Radioactive Object Found near Homes at Hunters Point Shipyard.”
 Matier and Ross, “State Says Radioactive Deck Marker Found at Hunters Point Not Really Dangerous.”
 “Hunters Point Shipyard, Parcel A-1 Health and Safety Survey” (Sacramento, CA: California Department of Public Health, February 5, 2019), https://www.cdph.ca.gov/Programs/CEH/DRSEM/CDPH%20Document%20Library/RHB/Environment/Hunters%20Point%20Parcel%20A1%20Final%20Report%20and%20Appendices.pdf.
 Jason Fagone and Cynthia Dizikes, “Limited Scope of Testing at SF Shipyard Housing Area Leaves Site’s Safety in Doubt,” San Francisco Chronicle, February 21, 2019, https://www.sfchronicle.com/green/article/Limited-scope-of-state-testing-in-shipyard-13632243.php.
 Daniel Hirsch et al., “From Cleanup to Coverup: How the Navy Quiety Abandoned Commitments to Clean Up Hunters Point Naval Shipyard and Is Instead Covering Up Much of the Contamination” (San Francisco, CA: Committee to Bridge the Gap, August 2019), http://committeetobridgethegap.org/hunters-point-reports/FromCleanupToCoverup.pdf.
 City and County of San Francisco, “Proposition P: Hunters Point Clean-Up” (November 7, 2000), https://webbie1.sfpl.org/multimedia/pdf/elections/November7_2000.pdf.