“If you drink much from a bottle marked 'poison' it is certain to disagree with you
sooner or later.” ― Lewis Carroll, Alice in Wonderland
sooner or later.” ― Lewis Carroll, Alice in Wonderland
HUNTERS POINT & THE RAD LABSDisturbing as Treasure Island’s radioactive history is, that of Hunters Point Naval Shipyard appears to be even more sordid. To begin with, it was the transit departure point for Little Boy, the atomic bomb the U.S. dropped over the civilian population of Hiroshima in August 1945, murdering hundreds of thousands of civilians.A review of the events leading up to that action seems to be in order here. Since Japan had bombed Pearl Harbor in late 1941, the military forces of the two nations had fought a furious and increasingly degenerate war.
The U.S. knew that Germany was trying to build an atomic bomb too, and the race was on. By June 1945 the fighting was over in Europe, with the Allies victorious. But the war was still raging in the Pacific, though the U.S. had the upper hand. It wanted to get it over with ASAP. In March 1945, U.S. B29 bombers firebombed Japanese cities. They dropped hundreds of thousands of napalm bombs on Tokyo. But even after horrendous conflagrations and major loss of life, Japan would not surrender. In mid-July, the Navy ship Indianapolis, which had just been repaired at Mare Island naval base in Vallejo, Calif., received orders to report to Hunters Point to pick up “special cargo.” The following account by a naval officer from July 1945 appeared in the SF Bay View newspaper on Aug. 31, 2009: “On July 15th we were ordered to go to San Francisco (Hunters Point) to take on some cargo. … We tied up there and two big trucks came alongside. The big crate on one truck was put in the port hangar. … [T]wo army officers [from the other truck] … carried a canister about 3 foot by 4 foot tall … Later on, I found out that this held the nuclear ingredients for the bomb and the large box in the hanger contained the device for firing the bomb. … “We sailed 0800 the morning of 16th July. We arrived in Tinian [near Guam Island in the Pacific, from which the B-29 carrying the A-bomb flew off] the morning of 26 July and unloaded the material and bomb which was later to be dropped over Hiroshima.” Also on July 16, the U.S. set off the first atomic bomb ever in Alamogordo, New Mexico. But that was just the beginning of Hunters Point’s involvement with nuclear operations. Hunters Point began operating as a Navy shipyard in the early 1940s. It soon became the only Navy shipyard in Northern California that could deal with large warships. After World War II ended, the U.S. wasted no time in continuing nuclear operations. In July 1946, during Operation Crossroads, it set off two A-bombs at the Bikini Atoll in the Pacific. Nearly 100 “target” and 150 “support ships” sat in surrounding waters. The Navy wanted to see how the ships would do in an atomic blast. There were animals on some of the ships, ranging from goats to rats. The Navy wanted to know how they would do too. As it turned out, neither did so well. A lot of the animals died, and a lot of the ships, those that didn’t sink, ended up contaminated with radioactive fallout from the two atomic blasts. The Navy did what it could to decontaminate them, but its efforts “revealed conclusively that removal of radioactive contamination of the type encountered on target ships cannot be accomplished successfully,” a Navy fact sheet on Operation Crossroads stated. As for the support ships, the fact sheet goes on, they “were decontaminated as necessary and received a radiological clearance before they could rejoin the fleet. This required a great deal of experimentation, primarily in San Francisco.” And primarily at Hunters Point. Community Window on the Hunters Point Shipyard reported “18 target and observation vessels were decontaminated at Hunters Point” after Operation Crossroads and that subsequently at the shipyard “the decontamination of ships associated with Pacific atomic and thermonuclear (H Bomb) weapons testing generated radiological material and waste.” Hunters Point was also the home of the Naval Radiological Defense Laboratory. This facility’s “purposes included radiological decontamination of ships exposed to atomic weapons testing,” and also “included conducting research and experiments on decontamination, the effects of radiation on living organisms, and the effects of radiation on materials,” the Navy reported, from post WWII until 1969. It became the “U.S. military’s largest facility for nuclear research,” according to the Sept. 1, 2001, SF Weekly. And, the Weekly reported, the “shipyard also consolidated radioactive waste from other facilities, including the University of California, Mare Island and McClellan Air Force Base (near Sacramento).” As a result of all these activities, substantial amounts of radioactive and other toxic wastes have been found at Hunters Point since its closure in the late ‘60s. Subsequently the EPA found “various radionuclides, primarily radium-226 and cesium-137” there. The EPA declared Hunters Point a Superfund site. How well it’s been cleaned up is still a matter of controversy, similar to that at Treasure Island. And, as with Treasure Island, at stake is a high end housing development that could destroy surrounding primarily low income African American communities. Fallout & RadWaste
How nuclear researchers handled -- and grossly mishandled -- the Cold War's most dangerous radioactive substances at a top-secret lab inside the Hunters Point Shipyard. An SF Weekly investigation of the environmental history of the San Francisco Naval Shipyard at Hunters Point -- land the city hopes to acquire and transform into a master-planned community -- has found troubling evidence that the Navy conducted nuclear research and mishandled radioactive waste on a vastly greater scale than has yet been revealed.For 23 years following World War II, the Hunters Point Shipyard was the site of the military's largest facility for applied nuclear research -- the top-secret Naval Radiological Defense Laboratory. Over the course of its life, according to government documents declassified at the request of SF Weekly, the NRDL handled nearly every kind of radioactive material known to man -- including, at one point, enough plutonium to kill 15 million people. The shipyard is also well known as a site where Navy ships were decontaminated after being irradiated in atomic weapons tests. After trying numerous methods of cleaning ships that had been deliberately exposed to nuclear bomb blasts, crews at the Hunters Point Shipyard decided sandblasting was the most effective. The Navy used the irradiated sand, which turned a shiny black that glistened in the sun, to “pave” side roads and walking paths throughout the Shipyard. Neighborhood children loved to play in it, calling it “black beauty sand.”
Yet in the early days of the Atomic Age, procedures for handling radioactive materials were shockingly lax by today's standards. The NRDL often experimented with and disposed of nuclear material with little apparent concern that it was operating in the middle of a major metropolitan area. Among other things, historical documents show, scientists at the NRDL:
- Oversaw the dumping of huge amounts of contaminated sand and acid into San Francisco Bay after they were used in attempts to clean irradiated ships. - Spread radioactive material on- and off-base, as if it were fertilizer, to practice decontamination. - Burned radioactive fuel oil in a boiler, discharging the smoke into the atmosphere. - Sold radioactive ships as scrap metal to a private company in Alameda. - Hung a source of cobalt-60, a nuclear isotope that emits high-energy electromagnetic radiation similar to X-rays, in San Francisco Bay for two weeks, apparently just to see what would happen. - Conducted human experiments that included requiring people to drink radioactive elements. - Experimented with significant amounts of a wide variety of long-lived radiological poisons, including plutonium, cesium, uranium, thorium and radium. - Studied and disposed of thousands of irradiated mice, rats, dogs, goats, mules, and pigs, among other animals. At one point, the lab owned a ranch in Contra Costa County used specifically to raise animals for radiation testing. - Sought permission to dump 1,000 gallons of liquid waste containing "small amounts of fission products" into San Francisco Bay, as an experiment to study how tidal action would dilute the radioactivity. The experiment was meant as a precursor to the disposal of 1,000 gallons of liquid radioactive waste in the bay every day. (The documents do not say whether the experiment or the daily dumping occurred.) After decades of wrangling over environmental concerns, the U.S. Navy and the San Francisco Redevelopment Agency finally agreed last fall on a method for transferring the naval shipyard in phases, or parcels, to city control. In what is known as a Memorandum of Agreement, the Navy pledged to clean up the main portion of the base -- that is, three of the six parcels comprising the shipyard property -- to certain environmental standards, and to a depth of 10 feet below the surface, at a cost of at least $120 million.
Federal law still controls the shipyard cleanup. That is to say, the Navy must clean up the site to standards that the state and federal environmental agencies agree upon, regardless of how much it costs or how long it takes. But the Memorandum of Agreement also gives the city the ability to sue if the Navy reneges on its commitments. "The EPA has never once assessed penalties against the Navy for being late," Deputy City Attorney Michael Cohen says. "We did not trust leaving the fate of the shipyard in the hands of the EPA. What we're saying is that you have to satisfy the regulators, and you have to satisfy us." To clean up much of a century-old shipyard, and the toxic solvents, metals, and other contaminants that, it's long been known, were used, spilled, and dumped there by the Navy, the city officials had no way of knowing anything close to the full history or extent of nuclear activity at the naval base. City officials did not know much about this nuclear history because, during negotiations over transfer of the Hunters Point Shipyard, the Navy has disclosed very little of it. |
Then & NowDuring the Cold War era efforts to find a method to remove radioactive contamination, which proved futile, some 17,000 people, most of them living in the Hunters Point housing adjacent to the Shipyard, worked in contact with radioactive and other dangerous toxins daily. Simply taking a shower or changing clothes after work did not protect them.
In the years since the Naval Radiological Defense Laboratory shut down in 1969, the Navy has discussed certain specific NRDL activities, including the lab's role in attempting to decontaminate ships irradiated in nuclear weapons tests in the South Pacific. But the Navy has glossed over much NRDL history, particularly as it pertains to the environmental assessment and cleanup of the Hunters Point Shipyard, and particularly regarding radioactive elements with life spans in the tens of thousands of years.
The shipyard's radiation history has garnered little more than a few paragraphs in the environmental documents guiding cleanup of Hunters Point. In those and associated documents, the Navy mostly maintains that there are few, if any, records of what took place at the shipyard during the early years of the nuclear age.
Environmental contractors hired to assess the shipyard repeatedly caution about "data gaps" in the historical record that would otherwise guide them in determining what sort of cleanup is appropriate. The RAD LABS at Hunters Point.
The Chief's active duty responsibilities with the Pacific Proving Grounds test vessels, and then later, his health 'evaluations' / radiation research and follow up often took me to Hunters Point with him.
This windowless building at the Hunters Point Naval Shipyard was headquarters for the super secret National Radiological Defense Laboratory.
Depending on the length of his meetings there, often I was asked to wait in the car or lobby of these buildings until his return.
In 1945, when this aerial photo was taken, the Hunters Point Shipyard was the nation’s center for radiological research. Some 20,000 people worked there, the majority Black people recruited from Texas and Louisiana and living in barracks on Hunters Point Hill that rises to the right, just out of view in this photo.
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The shipyard's radiation history has garnered little more than a few paragraphs in the environmental documents guiding cleanup of Hunters Point. In those and associated documents, the Navy mostly maintains that there are few, if any, records of what took place at the shipyard during the early years of the nuclear age. Environmental contractors hired to assess the shipyard repeatedly caution about "data gaps" in the historical record that would otherwise guide them in determining what sort of cleanup is appropriate. |
The FarallonsThe USS Independence, shown burning from the Bikini “Able” nuclear bomb test was sunk off the formerly pristine Farallon Islands after five years of sandblasting failed to remove the radioactive contamination.
Offshore from the rugged Farallones, shown here, the U.S. Geological Survey reports that "more than 47,800 drums and other containers of low-level radioactive waste were dumped onto the ocean floor west of San Francisco between 1946 and 1970.” T
he Farallon Islands Nuclear Waste Dump, only about 25 miles from the Golden Gate Bridge in a marine wildlife sanctuary, where the ocean floor is littered with radwaste – rusting 55-gallon barrels from the Naval Radiological Defense Laboratory at the Hunters Point Shipyard in San Francisco and the sunken USS Independence – is the first and largest offshore nuclear waste dump in the United States. – Photo: Wikimedia Commons |
Some radioactive wastes were created or received at Hunters Point, while others ended up in the ground, air and water.Still others were transported off site. Beneath the waters adjacent to the Farallon Islands, 30 miles off San Francisco, sits the Farallon Islands Nuclear Waste Site, the largest U.S. undersea radwaste dump. From 1946 until 1970 the Navy loaded an estimated 45,000 55-gallon drums of radioactive waste onto barges at Hunters Point, then dumped them in the vicinity of the Farallones. If the barrels didn’t immediately sink, sailors shot at them until they did. Several sources report that the U.S. Navy ship Independence was deep sixed somewhere in the region as well. The Independence was one of the Navy war ships exposed to nuclear fallout in a U.S. Pacific test of an atomic bomb. The ship was brought back to Hunters Point, where it was determined that it was too radioactive to salvage. According to the September 2001 SF Weekly report, the Independence was “packed with huge amounts of radioactive waste before it was sunk, very probably in the Farallones.” The Navy’s official line is that the 45,000 barrels it sunk contained relatively low levels of radiation that would be harmless to living things by now. But the SF Weekly article reported, “Two government officials say the Navy has acknowledged dumping thousands of barrels of high level, long lived ‘special’ nuclear waste at the site.” This reportedly included large amounts of uranium and plutonium. The Farallon Islands are adjacent to the Monterey Marine Sanctuary, which includes much of the coastal waters of Northern and Central California. And they are smack dab in the middle of the 1,282-square-mile Gulf of Farallones Marine Sanctuary. Half livesWhile it is true that the shorter lived radioactive wastes at Treasure Island, Hunters Point and the sea floor beneath the Farallon Islands have decayed away by now, that of the longer lived dangerous ones, like radium-226, cesium-137, plutonium and uranium will be around for hundreds of more years, if not millennia. Plutonium-239 has a radioactive life of 240,000 years. And so too will the threat of cancer and other serious diseases to living things they come in contact with, as well as the potential to cause genetic damage to future generations. When there is money to be made off of the sites, some of the radwastes may be hauled away or covered over. The Navy is supposed to be responsible for this, but it doesn’t want to spend the money to do a complete job – if there is such a thing – despite an annual U.S. military budget of over $700 billion. And there don’t appear to be any accessible health studies of people in possibly affected communities. In August 2000 multi-colored flames from an underground fire in the main landfill on the Hunters Point Shipyard burst through the ground. After the Navy was finally able to put out the visible flames (see the scorched earth), the fire continued to burn underground for months. That dump contains large quantities of radioactive waste along with countless other deadly toxins. Despite decades of community pressure to remove it, the Navy has just now made a final decision (see http://sfbayview/2014/notice-of-rod-hunters-point-naval-shipyard-parcel-e) to cap it instead. – Photo: Maurice Campbell
After a fire at the Hunters Point Shipyard in August 2000, the EPA hired the Agency for Toxic Substances and Disease Registry to study what the fire might have done to residents of the surrounding Bayview Hunters Point community. The agency reported that this was an “87 percent minority population” with “higher than the national average rates of asthma, respiratory disease, lung cancer and diabetes.”
The communities were “considered vulnerable and may be more sensitive to the effects of exposure to hazardous substances.” And these substances at the former Hunters Point Shipyard included “radiological elements, PCBs, mercury, lead and over 400 toxins that emit very high readings and adversely impact all life forms, and that includes human life,” according to Francisco Da Costa, director of Environmental Justice Advocacy, in the April 7, 2010 edition of SF Bay View newspaper. About a year later, after the fire had finally burned itself out, the Navy constructed a cap that will now be made permanent. – Photo: Maurice Campbell
Yet the agency only recommended that the communities should be notified when toxins in the air were higher than usual, so they could leave their homes.
Once again, there don’t seem to be any definitive health studies, leaving residents on their own to deal with the diseases related to environmental racism, as well as social maladies like gentrification that seek to push them out of their neighborhoods altogether, dead or alive. And leaving the “better class” that is to replace that population around the toxic sites on their own as well. Meanwhile the marine life beneath the Farallones is at the mercy of what’s in the 45,000 barrels of radwaste and scuttled A-bombed Navy ship as well. The marine sanctuaries that are supposed to help protect these living things are powerless to deal with this nuclear threat. And so the atomic war that the U.S. started almost seven decades ago continues in San Francisco and off its shores, giving the lie to its market image as a green city and continuing to threaten the lives of the innocents and unborn, just as we did in Hiroshima. All this points to the pressing need to denuclearize our city, our country and our world. The need to stop producing more radioactive wastes is paramount. Because at this point the question is: Will we outlive them, or will they outlast us? All this points to the pressing need to denuclearize our city, our country and our world. The need to stop producing more radioactive wastes is paramount. Because at this point the question is: Will we outlive them, or will they outlast us? Michael Steinberg, a veteran activist and writer based in San Francisco, can be reached at (415) 929-0671, [email protected] or www.blackrainpress.org |
Hunter’s Point Shipyard (HPS) is located along the San Francisco Bay in southeastern San Francisco, California. The U.S. Navy acquired the site in 1940 and it became a U.S. Navy base employing thousands of people. Building, repair, and maintenance of ships for the U.S. Navy were primary activities during World War II. Radioluminescent device handling, maintenance, and disposal occurred in the shipyard. Later, the U.S. Navy established the Naval Radiological Defense Laboratory (NRDL) in 1946 at HPS to study the effects of and to develop counter measures from nuclear weapons. NRDL operated until 1969 and conducted studies related to ship shielding, radioactive waste for deep-sea disposal, animal research, radiation detection instrumentation development, and other laboratory studies. NRDL also decontaminated and disposed of some ships involved in nuclear weapons tests in the Marshall Islands. During operations at HPS, the shipyard site grew in size to approximately [500 ac] by filling parts of the San Francisco Bay bordering the HPS. The site currently consists of approximately 866 acres, 446 of which are under water.
The first use of radioactive materials at HPS predated the issuing of licenses by the Atomic Energy Commission (AEC). The AEC is the predecessor of the U.S. Nuclear Regulatory Commission (NRC), which was established in 1974. Prior to 1954, AEC issued only authorizations or permits for controlled uses of radioactive material. After 1954, AEC licenses were issued to HPS and NRDL for use of radioactive materials. In the shipyard, multiple AEC licenses were issued for use of radioactive materials. The AEC licenses for NRDL were for a broad spectrum of radioactive materials for research. Radioactive materials specific to nuclear weapon testing used at HPS and NRDL are exempted from AEC, or NRC, licensing by the Atomic Energy Act of 1946. For closure of the NRDL in 1969, a license was issued by AEC for decommissioning activities. AEC licenses for the shipyard and NRDL were terminated in the 1970’s. Before termination of the licenses, extensive radiological surveys confirmed that radiological standards in effect at the time for unrestricted use were met. Following the termination of licenses, the AEC and NRC ceased exercising regulatory authority at the HPS.
In 1974, HPS was deactivated, and the site was placed on industrial reserve and portions of the site were leased to industry. In 1986, both hazardous chemical and low-level radiological contamination were identified at HPS. In 1989, the U.S. Environmental Protection Agency (USEPA) placed the site on the National Priorities List under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In 1991, the Base Realignment and Closure Program of U.S. Department of Defense designated HPS for closure. The U.S. Navy is now in the process of managing the cleanup of HPS under the CERCLA process with the objective of transferring the property to the City of San Francisco for redevelopment.
The Navy believes that the AEC-licensed material would likely be commingled with, and indistinguishable from, the atomic weapons testing material, because both types of material were used by NRDL research. According to the Navy’s 2004 Historical Radiological Assessment, the AEC-licensed material has the potential to exist base-wide in the storm drain lines, sanitary sewer lines, and septic systems, as well as in some buildings and one of the landfills. Under Superfund law, the military service that operated a base also is responsible for implementing the cleanup under CERCLA. The Navy’s cleanup at Hunters Point is done with independent oversight by USEPA and state regulatory agencies under a Federal Facilities Agreement signed in 1992. Six parcels (B, C, D, E, E-2, and F) have been identified to facilitate investigation and cleanup activities. A seventh parcel, Parcel A, was released for unrestricted use in 2004 and transferred to the City of San Francisco. The overall objective of the Navy’s remediation is unrestricted release for Parcels C and D and major portions of Parcels B and E-2. Plans currently under review also propose restricted release for the fill area of Parcel B and the existing landfill on Parcel E-2. For these restricted release areas, both institutional controls and engineering controls are planned. The current approach would result in a layered system of governmental controls including: City government ownership; legal controls using a restrictive covenant that involves the Navy, City, and State; and CERCLA-required oversight and enforcement through the Five-Year Review process conducted by the Navy and EPA.
3.0 Major Technical or Regulatory IssuesIn 2007, the U.S. Navy requested clarification whether NRC was going to exercise regulatory authority over the residual radiological contamination identified in 1986 and later years. Rather than exercising its regulatory authority for the licensable radioactive material assumed to be present, the Commission decided in June 2008 (SRM-SECY-08-0077) that NRC would rely on the ongoing Navy remediation under the CERCLA process and EPA independent regulatory oversight. The NRC staff would take a limited involvement approach to stay informed throughout the Navy’s remediation. The staff would stay informed by reading selective documents and conducting an annual site visit and progress meetings with the Navy, EPA, State agencies, and City of San Francisco. NRC would reserve the option of commenting to EPA if necessary to justify the continued reliance on the CERCLA process and EPA oversight. The staff is particularly following the plans and ongoing activities associated with the restricted areas mentioned above.
For the past six years since NRC’s decision in 2008, NRC has conducted its annual activities to stay informed about the Navy’s remediation process and issues. Based on the results of these activities, NRC decided to continue with its approach to rely on the CERCLA process and EPA’s independent oversight.
The first use of radioactive materials at HPS predated the issuing of licenses by the Atomic Energy Commission (AEC). The AEC is the predecessor of the U.S. Nuclear Regulatory Commission (NRC), which was established in 1974. Prior to 1954, AEC issued only authorizations or permits for controlled uses of radioactive material. After 1954, AEC licenses were issued to HPS and NRDL for use of radioactive materials. In the shipyard, multiple AEC licenses were issued for use of radioactive materials. The AEC licenses for NRDL were for a broad spectrum of radioactive materials for research. Radioactive materials specific to nuclear weapon testing used at HPS and NRDL are exempted from AEC, or NRC, licensing by the Atomic Energy Act of 1946. For closure of the NRDL in 1969, a license was issued by AEC for decommissioning activities. AEC licenses for the shipyard and NRDL were terminated in the 1970’s. Before termination of the licenses, extensive radiological surveys confirmed that radiological standards in effect at the time for unrestricted use were met. Following the termination of licenses, the AEC and NRC ceased exercising regulatory authority at the HPS.
In 1974, HPS was deactivated, and the site was placed on industrial reserve and portions of the site were leased to industry. In 1986, both hazardous chemical and low-level radiological contamination were identified at HPS. In 1989, the U.S. Environmental Protection Agency (USEPA) placed the site on the National Priorities List under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In 1991, the Base Realignment and Closure Program of U.S. Department of Defense designated HPS for closure. The U.S. Navy is now in the process of managing the cleanup of HPS under the CERCLA process with the objective of transferring the property to the City of San Francisco for redevelopment.
The Navy believes that the AEC-licensed material would likely be commingled with, and indistinguishable from, the atomic weapons testing material, because both types of material were used by NRDL research. According to the Navy’s 2004 Historical Radiological Assessment, the AEC-licensed material has the potential to exist base-wide in the storm drain lines, sanitary sewer lines, and septic systems, as well as in some buildings and one of the landfills. Under Superfund law, the military service that operated a base also is responsible for implementing the cleanup under CERCLA. The Navy’s cleanup at Hunters Point is done with independent oversight by USEPA and state regulatory agencies under a Federal Facilities Agreement signed in 1992. Six parcels (B, C, D, E, E-2, and F) have been identified to facilitate investigation and cleanup activities. A seventh parcel, Parcel A, was released for unrestricted use in 2004 and transferred to the City of San Francisco. The overall objective of the Navy’s remediation is unrestricted release for Parcels C and D and major portions of Parcels B and E-2. Plans currently under review also propose restricted release for the fill area of Parcel B and the existing landfill on Parcel E-2. For these restricted release areas, both institutional controls and engineering controls are planned. The current approach would result in a layered system of governmental controls including: City government ownership; legal controls using a restrictive covenant that involves the Navy, City, and State; and CERCLA-required oversight and enforcement through the Five-Year Review process conducted by the Navy and EPA.
3.0 Major Technical or Regulatory IssuesIn 2007, the U.S. Navy requested clarification whether NRC was going to exercise regulatory authority over the residual radiological contamination identified in 1986 and later years. Rather than exercising its regulatory authority for the licensable radioactive material assumed to be present, the Commission decided in June 2008 (SRM-SECY-08-0077) that NRC would rely on the ongoing Navy remediation under the CERCLA process and EPA independent regulatory oversight. The NRC staff would take a limited involvement approach to stay informed throughout the Navy’s remediation. The staff would stay informed by reading selective documents and conducting an annual site visit and progress meetings with the Navy, EPA, State agencies, and City of San Francisco. NRC would reserve the option of commenting to EPA if necessary to justify the continued reliance on the CERCLA process and EPA oversight. The staff is particularly following the plans and ongoing activities associated with the restricted areas mentioned above.
For the past six years since NRC’s decision in 2008, NRC has conducted its annual activities to stay informed about the Navy’s remediation process and issues. Based on the results of these activities, NRC decided to continue with its approach to rely on the CERCLA process and EPA’s independent oversight.