
TRAINING IN THE SAN FRANCISCO AREA Naval training bulletin, June 1951 Publisher: [Washington, D.C.] : Bureau of Naval Personnel
This article explains the laws violated including the Chemical Warfare Convention Treaty signed in 1993 including
- DOD Regulations
- US Law – 50 U.S. Code Chapter 32 – CHEMICAL AND BIOLOGICAL WARFARE PROGRAM
- 1993 Chemical Weapons Convention Treaty – OPCW Organisation for the Prohibition of Chemical Weapons:
- Chemical Weapons used in Training
The LAW
DOD Regulations :
40 CFR § 266.205 – Standards applicable to the storage of solid waste military munitions.
§ 266.205 Standards applicable to the storage of solid waste military munitions.
a (ii) The waste military munitions must be subject to the jurisdiction of the Department of Defense Explosives Safety Board (DDESB).
US Code recognizes the Department of Defense Explosives Safety Board (DDESB) as the regulator for chemical weapons regulations 40 CFR § 266.205 – Standards applicable to the storage of solid waste military munitions. I cited the first listing of it in this code to establish the authority of the Department of Defense Explosives Safety Board (DDESB) regulations are US Law.
The following are the laws violated by the Navy in illegally transfering Treasure Island Navy Bas to the city of San Francisco.
DOD AMMUNITION AND EXPLOSIVES SAFETY STANDARDS
DoD 6055.09-STD, February 29, 2008 – Incorporating Change 2, August 21, 2009
C12. CHAPTER 12
REAL PROPERTY KNOWN OR SUSPECTED TO CONTAIN MUNITIONS AND EXPLOSIVES OF CONCERN AND CHEMICAL AGENTS pp 268 –
- C12.8. TRANSFER OF REAL PROPERTY OUTSIDE OF DoD CONTROL
Pursuant to DoDguidance on real property disposal Instruction 4165.72 (Reference (al)),real property known to contain or suspected of containing explosive or CA hazards may not be transferred out of DoD control (other than to the Coast Guard) until the Chairman, DDESB, has approved measures submitted by the transferring Component to ensure the recipient of the property is fully informed of both the actual and potential hazards relating to the presence or possible presence of explosives or CA, and restrictions or conditions placed on the use of the property to avoid harm to users due to the presence of explosives or CA.- C12.8.1. Notices. A recipient of such DoD property shall be provided:
- C12.8.1.1. Details of any past removal or remedial actions, including:
- C12.8.1.1.1. The degree of MEC or CA removal.
- C12.8.1.1.2. The process used to determine that degree of removal to be adequately protective.
- C12.8.1.2. Written notification that detection and removal methods are not 100 percent effective, and that residual hazards may remain in areas (e.g., MRS) that were subjected to response actions.
- C12.8.1.1. Details of any past removal or remedial actions, including:
- C12.8.2. Restrictions and Conditions. Based on potential explosive and CA hazards present and the projected use of the property, the following types of use restrictions and conditions shall be imposed, as appropriate, on such DoD property:
- C12.8.2.1. A prohibition on excavation or drilling in any areas known or suspected to contain MEC or CA, regardless of CA configuration, without appropriate permits or assistance.
- C12.8.2.2. A prohibition on disturbing, removing, or destroying any found MEC or CA, regardless of CA configuration.
- C12.8.2.3. A requirement to immediately notify local law enforcement representatives of any discovery of MEC or CA, regardless of configuration.
- C12.8.2.4. A prohibition on the construction or installation of particular improvements including utilities, roadways, airstrips, navigable waterways, pipelines, and structures, both above and below ground.
- C12.8.2.5. A prohibition on specific alterations, extensions, or expansions to such improvements.
- C12.8.2.6. A prohibition on certain types of uses, such as child care centers, housing, or farming.
- C12.8.2.7. A restriction to a specific type of use or owner, such as a state National Guard range.
- C12.8.2.8. Inclusion of DoD Component explosives and CA safety personnel and the Chairman, DDESB, in deliberations, decision making, and approvals pertaining to future munitions response activities to address MEC or CA, regardless of CA configuration.
- C12.8.2.9. Inclusion of the restrictions and conditions in the recorded land records for the jurisdiction, to the extent allowed by state law.
- C12.8.1. Notices. A recipient of such DoD property shall be provided:
- C12.1. SCOPE
- This chapter:
- C12.1.1. Establishes explosives safety standards that, when applied, will protect people and real property from explosive and CA hazards associated with:
- C12.1.1.1. Real property known or suspected to contain:
- C12.1.1.1.1. Munitions and explosives of concern (MEC).
- C12.1.1.1.2. CA in other than munitions configurations (e.g., DoD laboratory vials, CA identification sets, one-ton containers, CA-contaminated soil).
- C12.1.1.1. Real property known or suspected to contain:
- C12.2.3.2. DoD Components should, unless there is evidence to the contrary, assume the following areas present CA hazards:
- C12.2.3.2.1. Former CWM or CA burial sites.
- C12.2.3.2.2. Former CWM or CA disposal areas.
- C12.2.3.2.3. Former CWM impact areas.
- C12.2.3.2.4. Former training areas used for training with CWM or CA.
- C12.2.3.2.5. Former CWM or CA production and demilitarization facilities.
- Emergency withdrawal distances do not consider the potential flight range of propulsion units.
- C8.6.1.3. Provisions for prompt notification to emergency response and environmental agencies and the potentially affected public for an actual or potential detonation or uncontrolled release, discharge, or migration of AE that may endanger human health or the environment.
- C8.6.1.4. Provisions for complying with sections 11001-11022 of title 42, U.S.C. (commonly known as the “Emergency Planning Community Right-To-Know Act (EPCRA)”) (Reference (no))), and DoD or DoD Component implementing policies.
- C12.5.9.2. Explosives Hazards. When explosives hazards are known or suspected to exist along with CA hazards within a response area (e.g., the MRA or MRS), a submission that addresses both explosives safety (see subparagraph C12.5.8.) and CA safety (as outlined in thissection) is required
Note The DOD recognized that its Ammunition and Explosives Standards did not include Chemical Weapons and since there was an extended deadline for compliance to the Treaty of 2012 they published this revision of the 2008 edition to get the in use immediately. So it has edited cross outs of content.
Table C8.T4. Emergency Withdrawal Distances for Non-Essential Personnel

Notes for Table Table C8.T4. Emergency Withdrawal Distances for Non-Essential Personnel
Distance Violations for exploding ordnance in radiologially impacted areas making it a WMD and the Navy failed to evacuate the residents when the 81mm Mortor was found and removed.
4000 feet means every person who lives on Treasure Island were required to be evacuated when they found the 81mm Mortar in 2016, that includes the folks in the TIDA Office on the Island. This mortar was reported 3 years after the fact in the 2019 NAVFAC FINAL POST-CONSTRUCTION SUMMARY REPORT
Non-Time Critical Removal Action for Solid Waste Disposal Areas
Westside Drive, Bayside Drive, and North Point Drive,
Radiological Characterization, Building Demolition, and
Remediation, Installation Restoration Site 12 (Phase III)

The Navy was required by the Chemical Warfare Convention Treaty and US LAW to report this in the DOD Annual report to Congress on the Destruction of Chemical Weapons which is given by the Undersecretary of Defense every year: 50 U.S. Code § 1523 – Annual report on chemical and biological warfare defense
There is no mention of Navy training locations in those reports which go into great detail for the Army’s training facilities that operated at the same time as Treasure Island, using the same manuals and training.
For example Fort McClellan is usually documented with Treasure Island as training bases in the Navy Training manuals and that base has been surveyed and cleaned where each individual bottle in the (CAIS) Chemical Warfare Identifiation Sets has been accounted for, but there is no mention of the Navy’s facilities in the reports to Congress.
The Chemical Weapons Training at TI will require the Secretary of Defense to explain to Congress why the Navy is not included in the Reports to Congress violating DOD regulations, the OPCW international Treaty and US LAW.
Chemical Weapons on TI

Several examples of chemical weapons found and/or used on Treasure Island including:
- The 81mm poison gas mortar shell found buried in the ground with radioactive materials which had these options :
- Mustard Gas (H),
- Phosgene (CG),
- Sulfur Trioxide (FS)
- White Phosphorus (WP)
- Also note, Travis AFB is not an approved location for the disposal of Chemical Weapons.
- Chemical Weapon Hydrocyanic Acid which is Hydrogen Cyanide (AC) banned by the Chemical Weapons Convention Treaty found in the inventory of the 1995 BASEWIDE ENVIRONMENTAL BASELINE SURVEY REPORT FOR NAVAL STATION TREASURE ISLAND, SAN FRANCISCO, CALIFORNIA, MAY 19, 1995 p 121 of 166 in the PDF file
- OPCW Schedule 3 Chemical Weapon
- Exceeds 1 ton limit for chemical weapons treaty at an annual rate of 5 tons per year
- It was found in a toxic waste site for the island and NOT IN A REQUIRED CHEMICAL WEAPONS BUNKER!
- This means that the Navy has lost its chemical weapons bunker at TI, it would most likely be at the location of the former Chemical Weapons School – under the public housing today.
- It is on a Chemical Weapons Training School (see OPCW video Chemical Warfare Convention Treaty video on What is a Chemical Weapon )
- It was sent to Naval Air Station Alameda thus making NAS Alameda a Chemical Weapons Site subject to the Treaty, US law and DOD regulations.
- 1964 Mustard Gas Test on Treasure Island by the Naval Research Laboratory and confirmed by the Navy on May 13, 2022
- The Chemical Agent Identification Set (CAIS) which contained chemical weapons for use in training all military personnel on all bases and ships worldwide pp 197-231 Note the following list contains links to the OPCW
- Hydrogen Cyanide (AC) OPCW
- Phosgene (CG) OPCW
- Cyanogen Chloride (CK) OPCW
- ChloroacetophenoneTear Gas (CN) – Riot Control Agent
- Diphenylchloroarsine (DA) – OPCW observing the destruction of this chemical weapon in China
- Adamsite (DM) OPCW – Adamsite is a non-scheduled chemical originally developed for chemical warfare purposes. It was subsequently used as a training agent and for riot control purposes, although the latter use is no longer accepted in most countries. It has no other legitimate uses.
- Sarin (GB) OPCW
- 1949 Stowage of safe, semisafe and dangerous materials : Bureau of Ships manual, chap. 30 : Navships 250-000-30 p 4 – Hydrogen Cyanide Gas (AC) Used on the Navys Atomic, Biological and Chemical Warfare School.
- And the extensive list of training manuals, peridodicals such as “Naval Training Bulletin,” “All hands” (which lists the courses, dates when they were training and describes the training) and other documents and Naval orders that place the Chemical Warfare Training at the Chemcial Warfare Training School at Treasure Island. Note ABC warfare Defense training manual of 1960 an 1963 were photographed on Treasure Island and you can see the Golden Gate Bridge in the background. See the Chronology Page on this website

81mm Chemical Mortar found buried in the ground with radioactive materials
This is an 81 MM chemical Weapon found buried under the housing at Treasure Island in 2016 behind what was the Chemical Warfare School buried with radioactive materials and this weapon was discontinued in 1961. The safe distance for civilians to unexploded CHEMICAL Ordnance is 4000 feet making this weapon a danger all of the people of Treasure Island and the Navy failed to evacuate the people. It was found buried in the ground, not in a bunker, buried with radioactive waste which means that if it exploded, it would cause a nuclear disaster by spreading the radioactive material and that is by definition a weapon of mass destruction.


This weapon came with 4 options Mustard Gas (H), Phosgene (CG), Sulfur Trioxide (FS) or White Phosphorus (WP). The Mustard Gas (H) and the Phosgene (CG) are Chemical Weapons that are banned by the Chemical Weapons Convention Treaty that was signed in 1993 and this weapon was made obsolete in 1961. Sulfur Trioxide (FS) is a chemical weapon (see Chemical Warfare Convention Treaty video on What is a Chemical Weapon) and subject to OPCW inspection and it must be destoyed in a OPCW certified chemical weapons destruction facility. It certainly cannot be exploded at Travis AFB. If the explosve had the Phosphorus (WP) then it would have burned all the people on Treasure Island.