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:
(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 188.8.131.52.4, or
• Within the boundaries of a terrestrial sensitive environment specified in section 184.108.40.206.5.
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
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.
- (a) Each licensee shall conduct operations so that –
- (1) The total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem (1 mSv) in a year, exclusive of the dose contributions from background radiation, from any medical administration the individual has received, from exposure to individuals administered radioactive material and released under § 35.75, from voluntary participation in medical research programs, and from the licensee‘s disposal of radioactive material into sanitary sewerage in accordance with § 20.2003, and
- (2) The dose in any unrestricted area from external sources, exclusive of the dose contributions from patients administered radioactive material and released in accordance with § 35.75, does not exceed 0.002 rem (0.02 millisievert) in any one hour.
- (b) If the licensee permits members of the public to have access to controlled areas, the limits for members of the public continue to apply to those individuals.
- (c) Notwithstanding paragraph (a)(1) of this section, a licensee may permit visitors to an individual who cannot be released, under § 35.75, to receive a radiation dose greater than 0.1 rem (1 mSv) if –
- (d) A licensee or license applicant may apply for prior NRC authorization to operate up to an annual dose limit for an individual member of the public of 0.5 rem (5 mSv). The licensee or license applicant shall include the following information in this application:
- (1) Demonstration of the need for and the expected duration of operations in excess of the limit in paragraph (a) of this section;
- (2) The licensee‘s program to assess and control dose within the 0.5 rem (5 mSv) annual limit; and
- (3) The procedures to be followed to maintain the dose as low as is reasonably achievable.
- (e) In addition to the requirements of this part, a licensee subject to the provisions of EPA’s generally applicable environmental radiation standards in 40 CFR part 190 shall comply with those standards.
- (f) The Commission may impose additional restrictions on radiation levels in unrestricted areas and on the total quantity of radionuclides that a licensee may release in effluents in order to restrict the collective dose.
[56 FR 23398, May 21, 1991, as amended at 60 FR 48625, Sept. 20, 1995; 62 FR 4133, Jan. 29, 1997; 67 FR 20370, Apr. 24, 2002; 67 FR 62872, Oct. 9, 2002]
Orange exceeds the safe level of 10 mrems per year which is the level for minors and for dust contamination.
(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).
(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
- (a) The licensee shall ensure that the dose equivalent to the embryo/fetus during the entire pregnancy, due to the occupational exposure of a declared pregnant woman, does not exceed 0.5 rem (5 mSv). (For recordkeeping requirements, see § 20.2106.)
- (b) The licensee shall make efforts to avoid substantial variation above a uniform monthly exposure rate to a declared pregnant woman so as to satisfy the limit in paragraph (a) of this section.
- (c) The dose equivalent to the embryo/fetus is the sum of –
- (d) If the dose equivalent to the embryo/fetus is found to have exceeded 0.5 rem (5 mSv), or is within 0.05 rem (0.5 mSv) of this dose, by the time the woman declares the pregnancy to the licensee, the licensee shall be deemed to be in compliance with paragraph (a) of this section if the additional dose equivalent to the embryo/fetus does not exceed 0.05 rem (0.5 mSv) during the remainder of the pregnancy.
[56 FR 23396, May 21, 1991, as amended at 63 FR 39482, July 23, 1998]
Light Purple exceeds 2 mrems/year
Light Orange is 1 mrems/year
Page 185 Spreadsheet notes
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
BRAC PMO West
San Diego, CA
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)
FORMER NAVAL STATION TREASURE ISLAND
SAN FRANCISCO, CALIFORNIA
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
Installation Restoration Site 12
Scoping Survey Follow up Investigation
Former Naval Station Treasure Island, CA
THE 30 REMS PER YEAR OBJECT FOUND MAY 26 2021
12 FINAL WORK PLAN
Intrusive Investigation – Radiological Areas of Interest
FORMER NAVAL STATION TREASURE ISLAND
SAN FRANCISCO, CALIFORNIA
“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!
THIS ITEM WILL BE DISCUSSED IN A NEW ARTICLE WHICH I WILL LINK HERE