Parcels UC-­1 & UC-­2 Draft Finding of Suitability for Transfer

Environmental Protection Agency Technical Assistance Grant Hunters Point Shipyard Fact Sheet 

This fact sheet provides a brief summary of the draft finding of suitability for transfer (FOST) of Parcel  UC-­1 and for transfer of Parcel UC-­2 of the Hunters Point Shipyard Superfund Site. The report was  prepared by the U.S. Navy. The FOST was prepared to document the  readiness of the parcels to be transferred to the San Francisco  Redevelopment Agency (SFRA) according to all relevant and  appropriate state and federal regulations including the  Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as Superfund. The report also describes the  readiness of the property for reuse with regard to laws regulating lead  paint, asbestos, petroleum, and other hazardous materials not  covered by Superfund law. The Navy is required to clean up  contaminants that it spilled but does not usually do lead paint or  asbestos abatement in buildings. That cleanup will be done by the  new owners according to regulations that govern these substances.  However, the Navy must disclose what it knows about these other  contaminants as part of the FOST report.

This FOST is different from a Finding of Suitability for Early Transfer (FOSET) because the FOST documents that all Navy cleanup has been completed to the satisfaction of the state and federal agencies. A FOSET such as the one described for Parcels B & G in an earlier Fact Sheet describes what remains to be cleaned up, not by the Navy, but by the new property owners under the watchful eyes of the same regulatory agencies. The transfers of UC-­1 & UC-­2 are not early transfers.

Public involvement is a requirement of the Superfund process. The U.S Environmental Protection Agency's Technical Assistance Grant program provides fact sheets such as this one  to inform  communities near Superfund sites to assist their understanding and participation in the process.  


Site Description and History  

The Hunters Point Shipyard Site (HPS) is located on 866 acres on the west side of San Francisco Bay in  San Francisco, California. About half of the site area is on land and half is under water. The site was used  as a shipyard since the late 1800s. Beginning in 1940, the U.S. Navy used the HPS for a variety of  purposes including shipbuilding, maintenance and repair of ships and submarines, and decontamination,  storage, and disposal of radioactive and radiation testing materials. Over its years of use, HPS became  contaminated with a variety of hazardous substances, causing it to be listed on the Superfund National  Priorities List in 1989. The U.S. Navy is remediating the shipyard under the regulations of the Superfund  law: the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).  Parcels  UC-­1 and UC-­2 are two of several parcels into which the site has been divided to speed up cleanup and transfer of the property to the San  Francisco Redevelopment Agency.


Parcels UC-­1 & UC-­2 are 3.9 acres  each.  Parcel UC-­‐1 includes a portion  of Spear Avenue. It is almost  completely paved and includes  Buildings 819 and 823, asphalt  parking lots, and a small hillside area.  Parcel UC-­‐2 includes parts of Fisher  Avenue and Robinson Street and a  triangular shaped parking area for  Building 101.

Contamination at Parcels UC-­1 & UC-­2

The FOST identifies the following  conditions, actions taken, and  notifications required for these  parcels: presence of hazardous  substances, CERCLA/RCRA, asbestos  containing material (ACM), and lead  based paint (LBP). These conditions  did not apply to UC-­1 and UC-­2:
petroleum products, above-­‐ and below-­‐ground storage tanks, munitions and explosives, or  polychlorinated biphenyls (PCB).

Hazardous Substances: Oils and paints were previously stored in Building 819. The removal of these and  other hazardous substances by the Navy are described in the report in Appendix

CERCLA IR Sites:  There are no Superfund Installation Restoration (IR) Sites in Parcel UC-­1 but part of IR  Site 6 underlies Parcel UC-­2.  Low concentrations of the solvents chloroform and carbon tetrachloride  have been found in groundwater in IR Site 6. The remedy selected in the Record of Decision (ROD) for  these chemicals was natural attenuation and institutional controls. Basewide issues of radiologically  contaminated storm drain and sewer lines, steam lines, and electrical equipment  affected the parcels.  Steamlines were investigated and found not to contain waste oil so further investigation was not  required. Storm drains and sewer lines were excavated to remove any radiological hazard. The electrical  transformer and substation that might have contained PCB was removed.

Pesticides: The property may contain residues of pesticides that were applied to manage the property  before transfer. There is no evidence that pesticides had been applied inappropriately or contrary to the  labeling on their packages. The Navy's position is that it has no responsibility to remediate legally  applied pesticides.

Radiological Materials: The Navy's Historical Radiological Assessment (NAVSEA 2004) described Building  819 as potentially radiologically impacted. The building was surveyed and found to present no  unacceptable radiological risks. Storm and sewer drains potentially impacted have been removed and  surveyed. Final clearance for unrestricted use by the California Department of Health is pending. 
Lead-­Based Paint: Any buildings built before 1978 are assumed to contain lead-­‐based paint which was in  common use up to that time. The Navy did not survey Buildings 819 and 823 for LBP because the  buildings were not intended for residential use. The buildings are assumed to contain LBP so demolition  or re-­‐use as residential by the new owners must comply with applicable LBP regulations.

Asbestos-­Containing Material: The basewide environmental baseline survey detected asbestos in  Building 823 but not in Building 819. This asbestos will be the responsibility of the new owner.
Storage Tanks and Pipelines: There is no record of above ground or underground storage tanks at Parcels UC-1 or UC-2. Natural gas lines run through both parcels. No other petroleum lines run through Parcels UC-1 and UC-2.

Polychlorinated bi-­phenyls: These long-­‐lasting substances, abbreviated PCB, are now known to be toxic  and to accumulate in the food chain.  They were formerly used widely in oils and electrical equipment  such as transformers. The Navy or former tenants at HPS have addressed all PCB issues there by  decontamination or removal.

Groundwater: Groundwater generally flows onto Parcels UC-­1 and UC-­2 from uncontaminated areas  and down gradient from the parcels towards contaminated areas. Possible vapor inhalation risks from  chemicals in the groundwater are addressed by restrictions on use of the land by the new property  owners. These restrictions are described in the Institutional Control (IC) section below.

CERCLA Institutional Controls:  Institutional controls, land use restrictions, will be implemented for  soil and groundwater at Parcels UC-­‐1 and UC-­‐2. The main provisions of these restrictions are the  following. (1) Growing anything for human consumption or using groundwater will be prohibited. (2)

These activities will be prohibited without prior approval from the Navy, U.S. EPA, and State of  California: a residence, a hospital, a school for those under age 21 years, a daycare facility for children,  land disturbing activities, anything that facilitates movement of contaminated groundwater, removal or  modification to any component of the remedy or security features, and construction of any enclosed  structure. A risk management plan will describe the activities and procedures for permitting certain  restricted activities without prior permission of the Navy, EPA, and State.

Inspections and Compliance with Land Use Restrictions: There will be annual inspections and  compliance reports. These reports will continue until a 5-­‐year review determines that the controls are  no longer needed. For example, if the groundwater contamination declines over time, then the areas  needing institutional control to prevent risk from vapor inhalation could decrease. The exact process  and responsible parties for inspections have not been decided yet. One possibility would be for  homeowner associations to self-­‐certify compliance and to have the SFRA perform an annual inspection  to verify it and report to the Navy, EPA, and State of California.

Potential Issues for Community Concern:  
 (1) the draft report does not contain the Remedial Action  Completion Report that will be needed before the FOST is finalized, (2) the durable cover remedy is not  described in detail nor is the required monitoring of the cover and groundwater and maintenance of  monitoring wells. (3) Ongoing soil gas surveys are not yet complete. The public and regulatory agencies  will not be able to review these until the final FOST unless a revised draft is issued.

The report is available in libraries (San Francisco Main, Bayview YMCA, and Portola) and online at:
http://www.bracpmo.navy.mil/basepage.aspx?baseid=45&state=California&name=hps
Draft Finding of Suitability for Transfer of Parcels UC-­1 and UC-­2 Hunters Point Naval Shipyard San  Francisco, California, February 11, 2011. Chaddux Tt Joint Venture, 1230 Columbia Street, Suite 1000,  San Diego, California 92101. 82 pp. 

The title of the report on possible radiological contamination at HPS is:  Naval Sea Systems Command (NAVSEA). 2004. Final historical radiological assessment, volume II, history of the use of general radiological materials, 1939-­‐2003, Hunters Point Shipyard, August 31.

This fact sheet has been funded partly or wholly through the use of U.S. EPA Technical Assistance Grant  funds. Its contents do not necessarily reflect the policies, actions, or positions of the U.S. Environmental  Protection Agency. The India Basin Neighborhood Association does not speak for nor represent the U.S.  Environmental Protection Agency. Arc Ecology prepared this fact sheet on behalf of the India Basin  Neighborhood Association.

Discuss the report with a scientist (mikemcgowan@arcecology.org) at Arc Ecology, 1331 Evans Avenue, SF, CA 94124, (415) 643-1190. Learn more about the local EPA Technical Assistance Grant: contact Jackie Lane: Lane.Jackie@epa.gov (415) 972-3236. Visit the India Basin Neighborhood Association website http://www.indiabasin.org/ Email IBNA at info@indiabasin.org or telephone them at: (415) 938-6170.