90 REMS of Nuclear Radiation Per Year at Treasure Island – the Spreadsheet and the laws UPDATE

60 REMS / year of radium objects, deck markers, radium dials, all by product materials that were found in the first 10 inches of soil on the ground under the housing at Treasure Island. Note the navy spreadsheet marks micro rems as mR when it should be µrem/hr

This article explains the spreadsheet of radiological items discovered in 2013 which the Navy buried in a box below the housing in 2015 then removed them in 2018 thus exposing the residents to 60 rems per year for 5 years before they removed them, thus exposing the residents to 300 REMS of nuclear radiation in violation of the law.

On May 26th of 2021 the Navy reported finding new objects in the soil and one of them is 30 REMS per year of nuclear radiation or 3500 mR/hr. This one object is a nuclear accident, it violates the immediate one hour danger level of 2000 mR/ hr exposure and it violates the 100,000 mR/year exposure by 300 times the amount of radiation for a member of the public.

I will go into more detail on the recent find in another article but I posted the initial report at the end of this article.

Spreadsheet of 684 Radium objects, numbers 596 to 1280, found in the top 10 inches of soil10 at Treasure Island California exposing the residents to 60.409 Rems of Radiation each year.

55 REMS of that total comes from one location the B-25 box where the Navy collected radioactive objects found on the site of the Radiological Training Area on Treasure Island which was demolished to build housing upon the site starting in the 1960s. There are other objects some with radiation levels higher than in this list (including one that was 3500 mR/hr (µrem/hr) or 30 REMS per year in a report published on May 26, 202112 which means the exposure of people on the Island goes up to 90 Rems per year) and I will post them in subsequent articles to be linked here. An explanation of each column is below.

The Spreadsheet shows that they knew about the radiation, the exact amounts but let it sit there on the site over many years and the amounts add up. 2 years is 120 REMS of exposure, 3 is 180 REMSs, so every object they uncover adds to the amounts exposed to the public. This is a direct violation of the law:

42 U.S. Code § 9603 – Notification requirements respecting released substances

(a)Notice to National Response Center upon release from vessel or offshore or onshore facility by person in charge; conveyance of notice by Center

Any person in charge of a vessel or an offshore or an onshore facility shall, as soon as he has knowledge of any release (other than a federally permitted release) of a hazardous substance from such vessel or facility in quantities equal to or greater than those determined pursuant to section 9602 of this title, immediately notify the National Response Center established under the Clean Water Act [33 U.S.C. 1251 et seq.] of such release. The National Response Center shall convey the notification expeditiously to all appropriate Government agencies, including the Governor of any affected State.

(b)Penalties for failure to notify; use of notice or information pursuant to notice in criminal case

If the EPA was informed of the radiation, they would have evacuated and taken over the site cleanup.

This report is the POST-CONSTRUCTION SUMMARY REPORT December 2019, full citation below. Table 7 lists the Radium objects in this report on pages 163-185.

200 Foot Boundary

200 feet is the boundary between a radiological site and the civilian residents. If a civilian lives within 200 feet of the fence of a radiological or any type of toxic waste site they are considered to be ON THE SITE. There is no boundary at Treasure Island, the residents are living ON THE SITE!

This is a direct violation of the very law cited on page 1-2 of this report where they claim compliance with the “National Oil and Hazardous Substances Pollution Contingency Plan (Code of Federal Regulations [CFR], Title 40, Part 300) and Comprehensive Environmental Response, Compensation.

40 CFR Appendix A to Part 300 – The Hazard Ranking System:
5.1.1 Resident population threat. Evaluate the resident population threat only if there is an area of observed contamination in one or more of the following locations:

• Within the property boundary of a residence, school, or day care center and within 200 feet of the respective residence, school, or day care center, or

• Within a workplace property boundary and within 200 feet of a workplace area, or

• Within the boundaries of a resource specified in section, or

• Within the boundaries of a terrestrial sensitive environment specified in section

If not, assign the resident population threat a value of 0, enter this value in Table 5-1, and proceed to the nearby population threat (section 5.1.2).

There are two levels of safe radiation, one is the immediate dose and the other is the yearly dose. The Navy decided to only list the radiation by the hour to show that it does not exceed the immediate dose but failed to place on the same chart the yearly dose which prove it is a nuclear disaster area, so I calculated it by multiplying the per hour dose by 8760 hours in a year and divided the legal dosages per year by 8760 to get the hourly amounts.

60 Rems of radiation will give you a 1 in 4 chance of getting cancer11, that is just for starters, it gets worse from there. Also the Navy discovered this for these specific objects in 2013, why did they choose to not evacuate the people, knowing exactly the danger? That’s 300 REMS of Radiation needlessly exposing the residents of Treasure Island which increased their chance of getting cancer to 74 in 10011 And we now they had radiation surveys in reports published in 2007.

The RSY Pads in the above map (page 111) of the cleanup sites for nuclear radiation were places where they removed objects from B-25 boxes to dry out the materials and you will notice the locations are within 200 feet of housing. The materials in the boxes buried under ground which were collected in the past and buried there for the cleanup, had to be dried out as the conditions under ground is the water table is very high and they had to dry out everything so they exposed everyone to these dry out locations with the 60 Rems of radiation. This is gamma radiation which requires 6 feet of lead to protect you from the exposure so the radiation buried under ground is just as radioactive as when they put them on the drying locations. So the people of Site 12 have been exposed each year with the full dose of 60 Rems from these radium objects.

The correct symbol for a micro Rem is µrem. The footnotes to the Navy Table on page 185 of the report notify that they using Micro Rems which is a millionth of a Rem but they use the wrong symbol on their spreadsheets. The Navy’s spreadsheet uses mR for microrem. mrems are mili rems or 1/1000th of a REM.

So you have

The annual doss for a member of the public is 100 milli rems designated as 100 mrem

100 mrem is 0.1 REM

100 mrem is 100,000 micro rems which in this report is designated as mR but in the real world it is µrem and the only reason the would do this is to confuse people.

In this spreadsheet Item 777 at the top of the spreadsheet (above):
Cumulative number: 777
item number: 10/21/2015-337
Description: Foil
Date Recovered: 10/21/2015
Location Identified: B-25 Box 2830 95% complete
Originating SWDA (Solid Waste Disposal Area): Westside
Item loaded into US Army JMC Waste Brooker Transfer Container-date: 2/15/2018
Radiation Level Highest Contact (mR/h)1: 260I
Highest Contact Level per year x X 8760 (hours): 2,277,600 which is 2.2776 REMS per year)
Individual Members of the public Dose 100 mrems per year value in micro rems/per hour:11.4

The Spreadsheet it also color coded:

Dark Purple exceeds the safe level of 500 mrems per year for members of the public under special circumstances see section c below

Red Exceeds the safe level of 100 mrems per year for an individual member of the public:

§ 20.1301 Dose limits for individual members of the public.

Orange exceeds the safe level of 10 mrems per year which is the level for minors and for dust contamination.

§ 20.1101 Radiation protection programs.

(a) Each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part. (See § 20.2102 for recordkeeping requirements relating to these programs.)

(b) The licensee shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is reasonably achievable (ALARA).

(c) The licensee shall periodically (at least annually) review the radiation protection program content and implementation.

(d) To implement the ALARA requirements of § 20.1101 (b), and notwithstanding the requirements in § 20.1301 of this part, a constraint on air emissions of radioactive material to the environment, excluding Radon-222 and its daughters, shall be established by licensees other than those subject to § 50.34a, such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 mrem (0.1 mSv) per year from these emissions. If a licensee subject to this requirement exceeds this dose constraint, the licensee shall report the exceedance as provided in § 20.2203 and promptly take appropriate corrective action to ensure against recurrence.

[56 FR 23396, May 21, 1991, as amended at 61 FR 65127, Dec. 10, 1996; 63 FR 39482, July 23, 1998]

Yellow exceeds 5 mrems/year

§ 20.1208 Dose equivalent to an embryo/fetus.

Light Purple exceeds 2 mrems/year

Light Orange is 1 mrems/year

Page 185 Spreadsheet notes

Table 7
Low-Level Radiological Objects
Items 961 and 962 were removed from the LLRO inventory after further evaluation that determined the material met LLRW disposition. The items remain on the inventory only to maintain cumulative numbering sequence. The material was not shipped as LLRO material.
1 Ludlum Model 19 and/or 9-3.
2 Ludlum Model 19 and/or 9-3.
3 Ludlum Model 9-3.
4 Ludlum Model 9-3.
5 Canberra Inspector 1000 and/or ORTEC Trans-Spec DX-100.
6 Developed from Genie 2000 report for each individual item analysis.
7 Field measurements match Conceptual Site Model- ROC = 226 Ra.
8 Developed using RadPro latest revision. Utilized Closed Window/12″(30cm) measurement.
9 Cross check is calculated value to compare to RadPro value (QC check of RadPro input).
bgs – below ground surface
cm – centimeter
LLRW – low-level radiological waste
LLRO – low-level radiological object
MCA – multichannel analyzer
mCi – microcuries
mR/hr – microRoentgen per hour
NSTI – Naval Station Treasure Island
QC – quality control
Ra – radium
RMSA – radiological material storage area
RSY – radiological screening yard

The Spreadsheet report:
Naval Facilities Engineering Command Southwest
San Diego, CA
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)
December 2019

10 Objects were found in the upper 10 inches of soil, “The LLROs were discovered at depths ranging from 0.5 to 0.8 feet below ground surface.”
Final, Revision 1
Technical Memorandum
Installation Restoration Site 12
Scoping Survey Follow up Investigation
Former Naval Station Treasure Island, CA
November 2020
p. 2-3

11 Los Alamos Radiation Monitoring Notebook
James T. (Tom) Voss, NRRPT, CHP
Fellow of the Health Physics Society
2015 Update p. 5


Intrusive Investigation – Radiological Areas of Interest
May 2021
p 2-2

“Anomaly A-G03/A-CDPH 1303A – Sample location 1303A lies near a concrete walkway adjacent to Building 1303. In March 2013, small discrete particles (3,500 mR/hr. on contact) were collected by CDPH during pre-remediation soil sampling and sent to the Drinking Water and Radiation Laboratory Branch (DWRLB) for analysis. The radioactive fragments were sieved out of the soil sample during sample preparation. CDPH also collected soil samples prior to, during, and after remediation activities. The post-remediation 226Ra sample result (i.e., soil sample collected from the bottom of the excavation) was 1.02 pCi/g (CDPH, 2013). However, during a subsequent investigation conducted in October 2013, LLRO #1282 was found and retrieved and a soil sample collected from the same location detected 226Ra concentrations of 2.2 pCi/g, which is above the NSTI screening criteria of 1.69 pCi/g.”

p/Ci are pico curies or a trillionth of a curie. rems and curies are not interchangeable units so the use of these on the same spreadsheet are not really helpful in determining exact exposures to compare rems to curies. but if the number exceeds the safe level, you know to get the hell out of there!

Note in this statement that the Navy sampled it in 2013 and found it was below their safe levels but when they looked at it again, it far exceeded the safe levels, so how can we trust their judgement on any of these radiological objects especially when they know they are dangerous and they allow people to live on the site for 5 years without excavating them!


6 thoughts on “90 REMS of Nuclear Radiation Per Year at Treasure Island – the Spreadsheet and the laws UPDATE

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