Thursday, September 8, 2011

Hunters Point: Remediation Before Redevelopment

Last year, the San Francisco Board of Supervisors approved the massive 702-acre redevelopment of the former Hunters Point Navy Shipyard and Candlestick Point including 10,500 housing units and a new 69,000-seat football stadium for the San Francisco 49ers. The construction is slated to be completed by the developer Lennar Urban Corporation and is projected to last more than twenty years. This caught my eye because for a decade spanning the end of the 20th century and the beginning of the 21st century a significant portion of my work was Brownfield redevelopment, and in 2007 I bought a two and a half year old Lennar subsidiary built home from Freemont Bank that had several flaws, no wax seals on the toilet, a failure to insulate the eves, attic vent covers installed over plywood with no vent holes, missing flashing, and long list of other small flaws that I have systematically corrected over the past few years. That was easy stuff that Lennar failed to get right. Lennar is not exactly the company I would trust to properly finish a remediation and verify its safety to man and the environment.

This past July the superior court of California stopped the early transfer of the shipyard. The court ruled that the City of San Francisco’s redevelopment plan for the former Hunters Point Naval Shipyard failed to properly evaluate the environmental and health risks from allowing the Navy to transfer ownership of the contaminated Superfund site to the City and developer before the clean-up of the area is complete.
The 88-acre Parcel A which was the former military housing portion of the base transferred to the City of San Francisco in December 2004 after EPA approved the FOST (finding of suitability to transfer). During the investigation of Parcel A soil and groundwater, little contamination was found.

In court papers the City of San Francisco and the Lennar Corporation claimed there was no need for the Environmental Impact Report, EIR, to evaluate the environmental and health impacts of transferring the contaminated Superfund site to the City and the developer, Lennar, in advance of a completed, regulatory reviewed and approved clean-up. However, the court found that under the California Environmental Quality Act (CEQA), the City has the responsibility to evaluate these impacts and I would heartily agree. The court also recognized that under early transfer the City and Lennar would become responsible for much of the cleanup as part of the redevelopment, a task which the EIR simply ignored. A large part of remediation is excavation, which is part of construction; however, it is essential that soils be properly tested, characterized and either reused or removed from site. To ensure a safe remediation the work must be through and methodical without cutting corners.

The Hunters Point Naval Shipyard was first established in 1869 on leased land. In 1940 in preparation for war, the Navy obtained ownership of the shipyard for ship building, repair and maintenance for the Pacific fleet. The war effort was the only focus. Fuels, solvents, and lead paint were routinely used, dumped and buried at the shipyard and its landfill. When atomic tests began in the south Pacific, radioactive waste was also disposed of on-site. From 1946 to 1969, the Naval Radiological Defense Laboratory at Hunters Point decontaminated ships and studied the effects of nuclear weapons and disposed of waste on-site.

The Navy operated Hunters Point as a shipbuilding and repair facility from 1941 until 1976 shifting from surface ship repair to submarine servicing and testing after World War II. Between 1976 and 1986, the Navy leased most of the shipyard to Triple A, a private ship-repair company that was eventually charged with criminal violations for the illegal storage and disposal of hazardous waste on the property. In 1989, the shipyard was designated as a federal Superfund site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).The shipyard consists of 936 acres: 493 acres of land adjacent to the Bay and 443 under water within San Francisco Bay.

The reality is that when a military base is assessed, the history of the base is studied so that potentially problem areas can be identified. Contaminated soil and groundwater are identified after testing in areas likely to be impacted. Many areas received regulatory closure after assessment if there was determined to be no significant impact on the area from historical use. To expedite investigation and cleanup, the site was initially divided into 6 parcels; A through F. Parcel F is the offshore parcel and A containing the military housing. During the investigation, sampling on Parcel E and groundwater sampling throughout the Shipyard resulted in the Navy proposing to subdivide Parcel E into parts; E and E2. Parcel E2 contains the landfill. As the investigation and remediation progressed more contamination was found. Utility corridors were found to be conduits of contamination and were separately designated. Parcel D was subdivided D-1, D-2, Utility Corridor 1 (UC-1), UC-2, and G. The remedial investigations and feasibility studies continue for Parcels C through G.

So far the Navy has excavated and removed large sections of soil and contaminated steam and fuel pipelines on Parcels C and D, and cleaned up several aboveground and underground storage tanks. The Navy has also conducted numerous removal actions to address soil and buildings contaminated with radiation. The Navy's largest removal action has been ongoing since 2006 and involves removing over 11 miles of sanitary and storm drain sewer lines site-wide to address low-level radiation that has been discovered throughout the system. Impacted soils are transported and disposed in a low-level radiological landfill.

In 2000, a subsurface landfill fire was discovered and burned for weeks after discovery. In 2002, it was discovered that landfill gas had migrated offsite to an adjacent property. The Navy constructed a barrier wall and trench to prevent future migration of the gas and installed an active landfill gas extraction system to extract methane and volatile organic compounds (VOCs), treat the VOCs and vent the methane (a greenhouse gas).The Navy has conducted extensive removal actions to address areas of metal debris on Parcel E, buried radium dials also on Parcel E, PCBs on Parcel E/E2 and metal slag on Parcel E, but proposes to cap a significant portion of the land fill leaving the trash and materials in place. Even with plans to leave a significant portion of the landfill in place along with contaminated groundwater plums contained on site, the soil excavation is projected to continue until 2017 based on volume of soil to be excavated, sorted, treated, disposed of off site or returned to the site.

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