Radium-impacted drain line becomes regulatory cleanup headache

Looking east on West Tower Avenue. Buildings 5 and 400 are where radium-226 paint was applied to aircraft dials and markers. Paint waste contaminated thousands of feet of drain lines, most of which have been removed. The remaining radium-contaminated Industrial Waste Line is partially illustrated showing where it runs in front of Building 5, also known as the Naval Air Rework Facility.

The Industrial Waste Line of Operating Unit 2C

All of the drain lines containing radium-226 paint waste at Alameda Point have either been removed, cleaned, or are scheduled to be cleaned or removed, except for one:  The Industrial Waste Line in the hangar area where aircraft dials were painted.  This drain line was installed in the mid-1970s after passage of the Clean Water Act prohibited sending industrial waste into public waterways.  It sent wastewater to a treatment facility, and is now lying dormant, broken in places, and no longer in use.  The big question is what to do about it – leave it alone and create a special radiological license, a special exemption, or dig it up? 

The Navy, regulatory agencies, and the city discussed this cleanup problem at their regular cleanup team meeting on June 11, 2013, the most recent date for which meeting minutes are available.

Clean area inside Building 5 where Navy aircraft were serviced. Radium painting occurred to the left and outside of this area.

Even though radium dial painting at Building 5 and Building 400 along West Tower Avenue had ended by the time the Industrial Waste Line was installed, drain lines inside and under these two buildings contained radium that may have been released down into the waste line. 

The Navy doesn’t feel it should spend the extra money to remove the Industrial Waste Line, saying the contamination, some of which may have seeped into surrounding soil through breaks in the drain tiles, is trivial and should be left in place.  The Navy’s Lead Remedial Project Manager Bill McGinnis said,  “When risk was evaluated, the highest risk scenario was to an industrial worker at 225 days per year, 8 hours a day, for 25 years, through direct contact with soil. For the emergency worker the exposure and risk would be significantly less.”

The regulatory agencies aren’t sure how they will sign off on this waste line if it is left in place with elevated radium-226 levels inside the pipe or possibly in the soil where the pipe has deteriorated and leaked.

The city doesn’t want a perpetual worry about monitoring and digging precautions.  The East Bay Municipal Utility District (EBMUD) would also be concerned about the presence of radium.  The Navy’s Environmental Coordinator, Derek Robinson, asked the city’s engineering contractor, Angelo Obertello, if EBMUD was asked about routing around the existing industrial waste lines.  Mr. Obertello said EBMUD is looking to upsize the lines in this corridor because of fire flow pressures.  The city’s Chief Operating Officer for Alameda Point, Jennifer Ott, said that sewer and storm drain lines are planned for this area and that it is not realistic to expect EBMUD to work around existing rad-impacted lines.

The Navy is hoping to avoid the extra cleanup expense by asking the state to write a special document governing the drain line – essentially a warning label on a half-mile of two streets. 

The Navy asked the city if they could work around the lines when installing new infrastructure.  But even though the city’s new infrastructure plans call for using concrete utility corridors, or trenches, the plans drawn up by the city’s consulting engineer, Angelo Obertello, show that there would be future utility conflicts with the half-mile of the Industrial Waste Line on West Tower Avenue and Lexington Street.  The Industrial Waste Line, including its connections to Buildings 5 and 400, is about a mile in length.

Right now, the idea of writing a special radiological license or granting a special exemption is an administrative headache because not enough soil samples have been taken from around the waste line to fashion such a document.  Rob Terry of the U.S. Environmental Protection Agency pointed out that the whole licensing issue would go away if the drain line were removed.

From the meeting minutes:  “Mr. Terry agreed with Mr. Miya’s description of the process, and said CDPH [California Department of Public Health] is looking at two issues: the rad dose remaining in place, and the quantity of rad materials present. The possibility of a rad license for AP [Alameda Point] is a very real one, and under CERCLA [Comprehensive Environmental Response, Compensation, and Liability Act, commonly known as Superfund] the cleanup should be as complete as possible. If everything is removed, the need for licensing goes away.”

A similar drain line at Hunter’s Point Shipyard in San Francisco was removed.

2009 removal of radium-226-contaminated storm drains next to Building 400. West Tower Avenue is to the right. Looking west.

Questions about future emergency repairs were highlighted at the meeting.  Mr. Robinson asked if the main concern of the California Department of Toxic Substances Control (DTSC) is the “uncertainty of a license exemption.”  Karen Toth said, “DTSC’s main concern is that if an emergency arises – e.g., a sinkhole occurs in the affected streets by a water or sewer line break – this could require hiring a rad contractor to address a sinkhole or line break, either by the City or by East Bay Municipal Utility District (EBMUD).”

The meeting ended with everyone agreeing to continue working together to solve the problem of what to do about the radium-impacted Industrial Waste Line and adjacent soil.

The minutes of the Industrial Waste Line agenda item at the June 11, 2013 cleanup team meeting are below.

Meeting Minutes

June 11, 2013 Meeting minutes of OU-2C Industrial Waste Line discussion
Alameda Point Base Realignment and Closure (BRAC) Cleanup Team (BCT)
Teleconference Meeting Attendees:

Navy
Bill McGinnis – BRAC PMO-West Lead Remedial Project Manager (RPM)
Jacques Lord – BRAC PMO-West Contracted RPM
Sarah Ann Moore – BRAC PMO-West Deputy Base Closure Manager
Marvin Norman – Legal Counsel
Mary Parker – BRAC PMO-West Contracted RPM
Derek Robinson – BRAC PMO-West BRAC Environmental Coordinator
Cecily Sabedra – BRAC PMO-West RPM
Matt Slack – Radiological Affairs Support Office (RASO)

Regulatory Agencies
Isabella Alasti – California Department of Toxic Substances Control (DTSC)
Bob Carr – U.S. Environmental Protection Agency (EPA)
John Chesnutt – EPA
David Elias – Regional Water Quality Control Board (Water Board)
James Fyfe – DTSC
Chris Lichens – EPA
Ryan Miya – DTSC
Rob Terry – EPA
Karen Toth – DTSC
Xuan-Mai Tran – EPA

City of Alameda
Jennifer Ott – City of Alameda
Peter Russell – Russell Resources

Contractors
Angelo Obertello – CBG
Betty Schmucker – Trevet

“Mr. Robinson said the Navy appreciated the City’s effort in preparing drawings of the industrial waste lines. Peter Russell (City) said the drawings show potential conflicts with infrastructure/utilities (existing and future) and thus are higher priority for addressing.

“Angelo Obertello (CBG), City contractor, explained that updated figures were prepared and overlain on as-built drawings of existing utilities. Areas were identified where existing utilities fall within the industrial waste line areas. The City has also re-evaluated placement of future utility lines in West Tower Avenue, Lexington Street, and Monarch Street, and preliminarily shifted the future lines about 15 feet away from the existing industrial waste lines. Based on the drawings presented, possible conflicts could occur along approximately 3,300 linear feet of line as follows:  about 900 linear feet of 4-inch force main; and about 2,400 linear feet of gravity line feeding into the pump station in Lexington Street. This represents about 57 percent of the force main line in conflict with existing industrial waste lines and about 44 percent of the gravity line in conflict with existing industrial waste lines. The conflicts primarily in West Tower Avenue and Lexington Street are for future utilities and represent about 45 percent of the lines. 

“Dr. Russell noted that as part of the petroleum program the Navy identified former fuel lines in Monarch Street, close to the industrial waste lines. Sampling of the fuel lines was interrupted and sampling locations were adjusted to avoid the industrial waste lines. 

“Mr. Robinson asked if the City expects to put buildings on top of any the industrial waste lines.  Mr. Obertello said a 300- to 400-foot area northeast of Building 12 contains industrial waste lines and potentially falls within a future development block. Jennifer Ott (City) said the area may be residential and is identified for intensified development to support the historic district.  Dr. Russell noted this land would not be acquired until about 2019. 

“Karen Toth (DTSC) said DTSC has discussed this with CDPH licensing staff.  Until it is known what is left behind in the soil, CDPH cannot say whether a radiological (rad) license or license exemption is appropriate. Soil data are needed on what remains.

“Marvin Norman (Navy Legal) said the consensus is that the rad-impacted lines beneath the building slabs will remain in place and the question concerns the extent to which the Navy commits to removal of outlying lines.  He acknowledged the issues of licensing will need to be dealt with regardless of which option the Navy pursues.

“Mr. Robinson asked if CDPH will work with the Navy in making its determinations. Ms. Toth said CDPH is available for further consultation. This is a new process for CDPH at a CERCLA facility, and the first rad license exemption will be for HPS.  Bob Carr (EPA) said there have been discussions with CDPH and no decisions have been made yet. EPA asked for specifics and could not get them.

“Rob Terry (EPA) said he has some experience writing rad licenses and the more contamination, the harder it is to exempt a property and the more complex the license becomes. He envisioned an AP radioactive materials license and individual “storage and use areas” within the license. Ms. Toth said they are looking at the larger buildings and lines coming out of the buildings; there are two (or maybe three) areas still under evaluation. 

“Bill McGinnis (Navy) asked what legal criteria/standards/requirements CDPH is using and where the process is now. Ms. Toth said the decision criteria are still up in the air. In talking with the CDPH Radiological Health Branch (RHB), they are looking at data from specific waste lines and more site-specific data are needed in those areas being left in place. CDPH/RHB is not making “impacted” v. “non-impacted” decisions for industrial waste lines.  Ryan Miya (DTSC) explained the process for licensing/licensing exemption at HPS. RHB needs to understand what is being left in the ground to determine whether or not an exemption is appropriate. The activities remaining and boundaries in picocuries per gram (pCi/g) should be defined.

“The Navy drafted a “dose-modeling assessment” for HPS so RHB understood what it is issuing a license or exemption for. The Navy and DTSC worked together to prepare the assessment, which became a key component of the application. The assessment determined how much rad is left and how deep it is located. The City of San Francisco will file an application with a cover letter, the dose-modeling assessment, and supporting CERCLA documentation in about one month to CDPH/RHB. At HPS, a small landfill/debris area is what remains.

“If AP is proposing a buffer area for a utility corridor, then more information is needed for that buffer determination.  Dr. Russell said it seems easier for CDPH to issue an exemption for buildings with concrete slabs in place, and wondered if an issue is being created by addressing lines under buildings together with lines in the streets. Mr. Miya said yes, lines under the buildings are much less likely to offer potential exposure, while the lines in the streets offer a more likely exposure pathway.

“Mr. Terry agreed with Mr. Miya’s description of the process, and said CDPH is looking at two issues: the rad dose remaining in place, and the quantity of rad materials present. The possibility of a rad license for AP is a very real one, and under CERCLA the cleanup should be as complete as possible. If everything is removed, the need for licensing goes away. 

“Mr. Robinson said that the Navy modeled the industrial waste line exposure scenario very conservatively. The Navy is concerned about the uncertainty of a license versus an exemption.  Mr. Miya said that knowing the potential exposure of what is left behind is important; at HPS what is left is very low in concentration and is covered by three feet of soil.

“Mr. Robinson asked if DTSC’s main concern is the uncertainty of a license exemption. Ms. Toth said DTSC’s main concern is that if an emergency arises – e.g., a sinkhole occurs in the affected streets by a water or sewer line break – this could require hiring a rad contractor to address a sinkhole or line break, either by the City or by East Bay Municipal Utility District (EBMUD).

“Mr. Norman asked if it would be considered a problem if the lines were grouted and sealed. Ms. Toth said the clay (gravity) pipelines are known to have integrity problems. The implementability of the remedy becomes a problem.

“Bob Carr (EPA) said what Ms. Toth described is a very real possibility, and the reality is that a break in the pipeline requires time-critical access to the area to repair. Mr. Norman asked for clarification about whether a sinkhole would be caused by the natural geology or the possibility of breaking lines.

“Mr. McGinnis said the CERCLA Institutional Controls (ICs) and Land Use Control-Remedial Design would state that repair work is subject to a soil management plan including rad control requirements. Ms. Toth said the City and EBMUD do not have the ability to comply with this in a timely manner. Mr. Robinson said the Navy appreciates Ms. Toth’s concerns. 

“David Elias (Water Board) said that in early discussions with John West (Water Board), the project as envisioned indicated that the rad material was well defined, the risk was conservatively assessed, the lines left in the street would not be in contact with anyone, and the lines would be under concrete. However, with redevelopment the current scenario changed and the situation is different, creating small “waste management units.” With future changes it may become hard to address these issues. There is no real precedent for this approach. He said the agencies may become less comfortable with the new scenario. Mr. Robinson said it is difficult for the Navy to do things just for future development; however, the City needs to take into account the environmental disposition of the property. He suggested evaluating some options for relocating lines.

“A lot of good information was presented today and the Navy will look more closely at the drawings presented. 

“Dr. Russell said even without the City’s redevelopment, when the Navy built AP the design standards were different and construction had shorter life cycles. Regardless of future development, the current infrastructure must be repaired and maintained for several years. Mr. Robinson said the Navy appreciates this, and justifying cleanup expenditures is tied to risk. The waste lines have been evaluated in a Remedial Investigation/Feasibility Study; the risk was determined to be low and within the risk management range. It is difficult for the Navy to consider complete removal of the lines when risk has been shown to be low. 

“John Chesnutt (EPA) asked if there is a risk driver and what would make the agency members comfortable with the certainty of the risk. At HPS, after removing 20-plus miles of pipelines, breaks were found and sampling showed rad levels in catch basins were similar to intact pipeline areas. He asked if people would feel more comfortable if site-specific sampling was conducted at the breaks and data were collected that would enhance confidence in the risk level. Mr. Elias raised the issue of tarry refinery waste at AP, where it was left in place and the risk is low, but decision-makers have to manage the waste and the risk and communicate this to the public. This may be a messy issue long term. 

“Mr. Norman said CERCLA is driven primarily by long-term human-health risk and the City may not be required to comply with long-term maintenance or handling in the event of a calamity. Dr. Russell said this is not true; the City will have to conduct routine maintenance, and emergency maintenance if needed, and will require funding for long-term rad maintenance. State and community acceptance of risk are also considered.

“Ms. Ott said EBMUD may not be comfortable working near the rad-impacted industrial waste lines. Mr. Chesnutt asked if new soil samples collected showed higher risk, would rad workers have to be hired and, if this happens, are people at risk. Mr. Robinson said no. Mr. Terry said the data from along the trench line show the risk is trivial. Mr. Carr said the highest levels detected now are about 30 pCi/g, and what is not known is what criteria other agencies (e.g, California Occupational Safety and Health) have for restricting access to this area. Mr. Terry said he did not know but it would likely depend upon the volume at 30 pCi/g. 

“There was a question about whether the sediment is still present in the manholes. Mary Parker (Navy) said sediment was not removed from the industrial waste line manholes except for the small volume of sediment required for the laboratory analysis. Mr. Robinson said sediment in the manholes could be removed fairly easily and would help reduce the volume of soil.

“Mr. McGinnis said when risk was evaluated, the highest risk scenario was to an industrial worker at 225 days per year, 8 hours a day, for 25 years, through direct contact with soil. For the emergency worker the exposure and risk would be significantly less. Mr. Robinson said the Navy will evaluate the information provided today more thoroughly. He asked Mr. Obertello if EBMUD was asked about routing around the existing industrial waste lines. Mr. Obertello said EBMUD is looking to upsize the lines in this corridor because of fire flow pressures. Ms. Ott said sewer and storm drain lines are planned for this area. It is not realistic to expect EBMUD to work around existing rad-impacted lines. 

“Mr. Norman said the Navy is taking the actions it needs to take and cannot take response actions to enhance development. He understands the City will have to maintain the existing lines and this could be more costly or more risky. Further, replacement of existing lines could cost more if the Navy abandons the lines with residual rad in place.

“Mr. Chesnutt said he is not sure it is a protectiveness issue. Ms. Ott asked if the risk is negligible, would a rad contractor be needed.  Mr. Robinson said from a risk perspective, no rad contractor is needed. Ms. Ott asked if RASO concurred. Matt Slack (RASO) said he believed a rad contractor would be needed, but he agreed with the existing data and that the risk due to the sediment within the pipe is minimal.

“Mr. Terry said when something is left behind, there will always be a question whenever a hole needs to be dug in the street. Time and resources will be needed to respond to questions.

“Mr. Elias said the Navy usually looks at source control through removal, and that ICs are for residual contamination. Now, ICs are being looked at for source material and felt this is an unusual way of managing a contaminant source. Mr. Chesnutt said he was not sure this was a source area or just material left behind. Mr. Elias suggested the rad might be a de minimis source.

“Mr. Robinson asked if there are ARARs that address waste left in place with low risk. Ms. Toth said with ICs in place the area cannot be used as residential, and ICs are required if something is left in place. Mr. McGinnis said residential risk was evaluated and there is no exposure pathway for residential users.

“Mr. Miya said the pipeline was removed at HPS, which allowed free release.  Ms. Toth suggested that if a quick resolution cannot be reached, the industrial waste lines might be removed from the Record of Decision (ROD) so the rest of the site can move forward. Mr. Robinson asked EPA and Water Board members how they feel about this suggestion. Mr. Elias said he is not sure, and Mr. Chesnutt said it is worth discussing but may be premature. Mr. Robinson suggested a follow-on call on July 2 or July 8 to discuss this further.”