PRESTO…CHANGO!
How the Navy Made Parcel F Radiation Contamination Completely Disappear
• • • • • • • • October 2024 • • • • • • • •
Derived from the combination of “presto,” an Italian word meaning “quickly” and “change,” “Presto Chango” is a phrase used in magic shows and performances where objects or situations appear to change instantly.
The Parcel F Radiological Impaction map above was excluded from the Parcel F Record of Decision released on September 26, 2024. Raw data was also excluded from environmental testing for radionuclides, published in the 2017 Addendum to the Feasibility Study Report for Parcel F. It is evident from the map above that every region of the Hunters Point Naval Shipyard colored yellow or green may be radioactive—including its shorelines. That’s why this map was made to disappear.
Health risks to children at play and men at work from potential exposure to radioactive sediments on Parcel F shorelines, where Operation Crossroads ships were docked, Trident nuclear submarines were berthed, and nuclear waste disposed of in unlined landfills—all this data was magically erased!
Indeed, an entire region of Parcel F was excluded as a study area. Area II of Parcel F includes the Submarine Area. Located on Parcel B, the Submarine Area is, arguably, one of the most active regions on the base, housing artists and administrative offices. There is evidence it may also be the most radiation-contaminated region of Parcel F. Area II of Parcel F has been disappeared from all investigation documents.
Area II of Parcel F was not included as a study area in any Parcel F investigation. Area II is not designated on any maps of Parcel F. Area II is historically significant because it includes Drydock 6 - used heavily by Operations Crossroads for decontaminating plutonium-exposed ships. The Historical Radiological Assessment (HRA) identified the underwater areas and all ship’s berths as radiologically impacted, requiring scoping surveys in areas of Operation Crossroads decontamination activities and outfall discharges.
These and many more legitimate findings have vanished from the Final Record of Decision for Parcel F at the Hunters Point Naval Shipyard. This offers yet another clear example of how by using environmental chemistry “slight of hand,” a “Navy blue Magic Marker,” and the “white out” of Federal government sovereign immunity, the Navy Base Realignment and Closure (BRAC) team made the impossible come true.
Believe Your Lying Eyes
WOW! How did they do that and Why was that done?
The Navy BRAC Team achieved this supernatural feat of accomplishment using a system of unethical actions that include:
1. Data Manipulation, Deletion and Concealment.
2. Digital Archive Document Substitutions.
3. Exclude high-risk Parcel F Area II (Parcel B Submarine Area) from allstudy areas.
4. Calculate Parcel F Human Health Risk analysis as recreational use when the development plan intends to site residential development on Parcel B landfills used for disposal of nuclear waste.
5. Inflate remediation goals by adding Hunters Point ambient levels and Preliminary Action Levels (PALs) to background radiation levels in an action that amounts to environmental racism.
Additionally, construction worker exposures were excluded from human exposure scenarios, placing current and future workers at risk of exposure to residual radioactive contaminants. Obviously, uncertainty is evident since they used clams as biomonitoring surrogates—instead of humans. The Navy BRAC team engaged in the cover-up of their evidence of Parcel F radiation contamination at the northern piers and drydocks for three primary reasons:
1. To advance the development plan to site housing on Parcel B landfills at IR-07 & IR-18 in areas documented to be disposal sites for nuclear waste.
2. To reduce legal culpability for contracts siting human populations in radioactive regions of
Parcel F - Area II, the Submarine Area on Parcel B where maximum concentrations of Radionuclides of concern (ROCs)
were detected.
3. To offer biased evidence supporting the preposterous assertion, “The Navy has concluded there is no risk to human health and the environment because of ROCs at Hunters Point Naval Shipyard (HPNS).”
[ Addendum to Feasibility Study 2017}
Parcel F preliminary investigations, beginning in 1993, have excluded Area II as a study area. Strange! Area II is the region with the most human activity on the base. Area II includes radioactive Drydock 6 and the Submarine area of Parcel B, where the artists and administrative offices are sited:
A series of investigations conducted between 2009 and 2013 studied radionuclides of concern at Parcel F. These investigations relied on environmental testing and complex statistical analysis. They are plagued by uncertainty from data because it was derived from biomonitoring clams rather than human biomonitoring.
Hunters Point Biomonitoring detected radionuclides of concern at HPNS in residents and workers on and adjacent to the base, including nuclear fission and decay products.
On September 26, 2024, the Navy and EPA held a strategically timed Press Conference announcing the publication of the Parcel F Record of Decision (ROD). While the decision to advance clean up for a Parcel comprising half the base is welcome—it is 25 years delayed, and the deliberate exclusion of radiological data raises questions of transparency and legality.
Parcel F shoreline sediments envelope the base adjacent to human and ecological receptors. The Navy has determined parcel F to be the parcel most vulnerable to sea level rise and extreme weather events.
The original hardbound Hunters Point Shipyard Parcel F Human Health Evaluation Work Plan is one of several remediation documents in the archives of the Hunters Point Biomonitoring Foundation, Inc. entered into deposition as evidence in civil litigation against Lennar Developers, Tetra Tech Inc, and on behalf of UCSF workers.
Michael Pound - a chemical engineer with over 30 years of experience, was named Navy BRAC Environmental Coordinator in 2023. Pound represented the Navy on the Sediment Team for the 2001 Human Health Evaluation Work Plan, as such, he was uniquely positioned to edit content included in the Parcel F ROD
In 2005, the Parcel F Validation Report relied on the biomonitoring of shellfish to conclude that “South Basin Area X poses the greatest potential risk to human receptors.” Bioaccumulation studies examined theuptake of sediment contaminants in clam tissue and found mercury, copper and PCB’s to be primary drivers of risk. The Parcel F Validation Report concludes “radiological surveys will be performed in areas recommended by the Historical Radiological Assessment”. [DON 2004] [url validation report]
Parcel F raw unaltered data - published in the Statistical Summary of Radionuclides in Sediment at Parcel F - documents the maximum radionuclide detected concentrations in the Submarine Area of the base—located in Region II Parcel B.
By artificially inflating cleanup goals, the Navy made all of the radiation documented in the 2017 Parcel F Feasibility Addendum vanish. The Navy invented remediation goals called PALs that were added to background levels to inflate Parcel F remediation goals for radionuclides of concern. The use of Hunters Point Ambient Levels or HPALs was challenged as environmental racism by members of the Shipyard RAB as early as 2000. The Navy used HPALs for chemicals like diesel fuel and radioactivity to claim they are naturally occurring—or ambient—at Hunters Point.
By simply comparing maximum concentrations of radionuclides detected primarily in the Submarine Area - Area II and the South Basin - Area X, with residential soil remediation goals, without a calculator, it is obvious that extreme elevations of Cesium - 137, Radium -226 and Strontium-90 were detected in Submarine Area II.
Strontium - 90 maximum detected concentrations in Submarine Area ll are 4.56 pCi/g compared to 0.2990 pCi/g in the Bay Farm reference Area.
The Navy detected Strontium - 90 in concentrations fifteen times higher than reference range and fourteen times higher than residential soil remediation goals!
So while the mayor is spending tax dollars gaslighting the community with a new park, the serious work of clean-up and real restitution for the damage the shipyard left behind continues to haunt the Bayview-Hunters Point residents.
Dr. Ahimsa Porter Sumchai is a climate activist living on the Westside.
October 2024
