Contact: Mr. James B.

Sullivan Department of the Navy, Base Realignment and Closure, PMO West 1455 Frazee Road, Suite 900 San Diego, CA 921084310 James.B.Sullivan2@navy.mil

(619) 532-0966. P

James Sullivan, BRAC env. Coordinator. Base environmental cooirdinator. Manage and coordinate env. Effort. Civi. with regards to the report, and how its affecting our planning, and timeline. This technical memorandum, it supplements our already existing understanding of the TI radiological history. Its not a significant change in the direction of the program, and it will help shape the finding of suitability. The property will be transferring in phases, and theres not. This is focused on. Help shape, what property is in the finding of suitability. John Hill, base closure manager. theres a DOD policy to complete a finding of suitability to transfer. Tis a document that DOD wants it. Its a document that we do that ensures weve taken all remediatial action. Here the topic is radiological contamination as well. Were going through and Env. Cleanup program at TI that includes cercla contaminants, radioation, and we need to make sure were complying with the laws. This is a document, its a checkbox. Weve met all the requirements, and the property is ready to transfer. This tech memo augments the 2006 HRA. And it is something that will identify any other areas not previously radiologically contaminated, and any area not deemed impacted by the 2006 HRA or this tech memo, with the state concurrance, will clear. Property that will clear those concerns will be the first phase of gtransfer. We would like to get a FOST Concerrned. Sullivan.

We resolved issues with the state regarding existing projects. Their comments were regarding projects that were ongoing, and wouldnt be included in the. The focus of this tech memo is to look at areas where there is no oingoing work, and no potential for contamination. John Hill sinice the time of the april 2011 memo, the navy has been in collaborative discussion with the state, concerning the findings of suitability to transfer, and future findings of suitability to transfer, that will come. The navy and the state agree this tech memo would augment the 2006 HRA. This is our joingt agreement that this tech memo would answer a lot of the questions raised by the state with regards to roads. Since that memo, the state has given us a letter saying they no longer have concerns about roadways on treasure island proper, except for roadways already in our environmental sites. A lot of those matters and concerns, they raised them across the base. Our discussions, they narrowed concerns down relative to sites where information has come about since the time of the 2006 HRA. We had state concurrence in 2006. It wasnt that the navy issued a 2006 HRA and moved on. The state concurred on it. What happened is, since that time, new information has come about, which is not uncommon for Env. Cleanup. The state contractor activities are no. They talked about transportation of soils across roadways, Additional impacted sites. WE had a lot of discussions with them, additional information. Specific concerns were addressed. This memo is what we believe they will find to be that next step. Jim Sullivan Shaw was licensed under the NRC. There was a determination made that, instead of having an NRC license, they went through a process o fobtaining their California licens and meeting their requirement of the state, and they went through that transitional process. They were under an NRC license.

John the states requirement that they have a license came about in 2011. The state started to look at jurisdicational issues on BRAC bases. While they were involved with our radiological cleanup. They made a determination, based on jurisdiction, navy contractors on TI would require state license. That was a new. It wasnt that shaw was negligent. They were under an NRC license. Up until 2011, base don jurisdiction, they required Shaw to have a state license. On hunters point, CDPH did not require they have a license on huntres point. Its not that they felt shaw was not capable and incompetent. It was. Jim our conversations with the state of Calif. Have gone very well. We had a meeting to discuss their general concerns, wen we went throught the discussion,a dn we agreed that the tech memo was the proper approach to address all the concerns. Since they issued that memo, they issued shwa its license. The matters, and the concerns they had with sahaw and its actions were apparently resolved when the issued. John we narrowed focus of that to, work within the existing project areas. They may have concerns abougt trucking around the base in general. We explained soil is confined to work areas. Its not reused on th island. We came to the agreement that the focus is on focus within the project areas. Remainder of base where trucks may be transiting to a regulated landfill, that that was not an issue for those roads. The stae has come into our work aresw and done preliminary scanning. They didnt see anything of immediate concern. The focus was narrowed to a smaller subset of the base. That, in turn, supports that the areas where we are not working, or have no planned work, and have been assessed, will be deemed suitable for tgransfer.

Jim: some of the property we wanted to issuea fost for was yerba Buena island. We needed to issue a fost on yerba Buena island as soon as we could, and their memo raised issues about that we had our discussions, they narrowed concerns to existing sites, primarily site 12 and 6. Thats where their primary concerns are, and we are addressing roadways. John: we addressed allt he roads on yerba Buena, and outside the project areas. They said they. John: we have remediated radiological material. And we have transpor. Jim: we transport soil. Managed by a licensed contractor, and transported. We havent excavated and transported any soil. John: when we sat down with them, this has not been a topic of concern for them since those discussions. I cant speak for them on this matter. All I can say, is its not something they expressed concern to us about. Jim: non-radiologial landfills have a portal monitor, theyre scanned for any radiological material. Weve never had a truck returned. John: based on our discussions we asked them for specific information they might point us to. We walked through their concerns with them, and what. This was a high, upper management meeting. This was not the real technical experts and project managers. At a management level, we met wit the state of calif. We asked for clarity about their concerns. This was not one either party, where we felt there were any information that required us to address the concerns any further. Looks at cleanup, historical activities of contractor, and contracot actions on the base. This tech memo reports what we believe to be additional areas that need further evaluation to determin if there is radiological contamination or not. We belive state of calif, will conur with that.

They wanted us to, basically augment the 2006 HRA. That was their overall big objective. They felt the 2006 HRA was, and is, a point in time. New information has come about based on our cleanup actions on the base. They wanted us to do another base-wide review. Jim: thats referring to a south-east corner of the island. Designed to be future hangar, but never used as such, and was a big open space building. During WWII, given the intensity of the war in the pacific. Shipyards around the bay areas exceeded capacity: after the war, or shortly after the war, that was de-mobilized and removed. TIs traditional role was administration, training, housing of troops. During this brief period during the latter part of WWII -- . this wasnt ship breaking, or dismanblement. It was to provide supp. During WWII scrap metal was highly prized for the war effort. Anything that could be re0used, thats how they did it. We reviewed all available documents, looked at arial photographs. We were trying to identify storage yards we didnt identify. We did fiond a few. What the tech memo is, its an assessment. Is there a possibility there could be contamination there. The bar is set conservatively high to make sure youre not leaving out anything. This tech-memo is just the assessment step. Once weve identified areas that need further evaluation. Is there something there, or not. The survey may show theres nothing there, and the process would end. In ffact we have that going on in site 33. Buried debris identified with associated lead contamination. In agreement with ht estae, we did a radiological survey as part of the excavation: Well be going through and doing a survey of all these areas that have been identified. If something is identified in the survey, you characterizing that fur. John: radioloigcally designated sites dos not mean its contamined. One objective is to FOST all property not identified as RAD impacted. And/or, not requiring further cleanup for CER. We are very hopefule that since

their memo of 2011, weve adequately assessed to augment 2006 HRA. And we are very hopeful they will concur. We hope to be able to find suitability to transfer. This will help us complete our first fost to help us to complete our first transf. Jim: Id say approximately half the island. John its not just radiological concerns, and we have ongoing CERCLA clean up actions. And we have an agreement with the city to take petroleum adtions. Perhaps 50pct, or slightly greater, will be pohase one transfer, of treasure island. YBA is fully prepared now. City of SF and the navy have been working on a conveyance agreement, still to be signed. Schedule to convey real estate parcels defined by both parties. Real estate parcels almost mirror the env. Parcels. Thats an ongoing deliverable and negotiation. For the most part, there really is no imkpact to the conveyance plan at this time. There is some slight boundary shift based on this tech memo. Were hoping that some of these newly impacted sites, and thats why the is going to do additional surveys this fall. If they come out positiver, they will be fosted as well. As long. CCSF and Navy theyve been well aware of our progress, and continue to be well informed. They were informed of the findings in this document before it was released. Since were -- TIDA. I have close contact with TIDA. The week we released this, I gave this a heads up, we discussed newly impacted sites, and how it would impact development plans. At this time, those discussions were had, documents have been released, and at this time, their only concern is to do some initial surveys this fall. Their concerns, to my know. Either theyre not acquiring the property, and its open space, and they have no development plans, or its a late phase take-down, and they wont receive the poperty for five or six years.

Jim: all of this material was buried. In the case of the boys and girls club, the area we excavated was initially paved. All this material was in the ground. As long as when you excavated, its being properly handled, or using proper dust control, thats what prevents it from being a health issue. For all of our work dusto control. Thats written very specifically into the project plan. As long as youre controlling that material thats being exacavated within the project site, youre. The point would be the reason were exacating is, theres some kind of contamination. If were excavating, regardless of what the contaminant is, theres dust in place. All of our remedial activities. Theres always a control on the project site. No dust of any kind approached the site. John: we talked to them about their specific concerns. We did provide them theyve been out at the site with us four years. We dont do clean-up in a vacuum. They do work with us, they do have personell on the ground. They do have new personel. Theres always turnover. Some of the history gets lost with personell. We pulled out our old work plans. There were protocols. Its our goal. Our goal is to protect human health and environment. They do independent surveys. They have the ability: were not being asked, at this time to terminate our lease with the city, to have its tenants removerd. The navy, the state of California, were not in a position, and we dont have information that makes us believes there are any tenants at risk, and the stae has not said there are tenants at risk. They did nt say there are tenants at raisk, and you will need to terminate your leases with sf. They have. Jim: all of our documents, including the one you mentioned. All of that work was doine in concert with the state. There were draft plans to do the work that were submitted in that tme period. Whether or not people more currently involved with the project physically had a copy of the document, but at the time we issued draft documents for all our projects, copies went to the state of calif.

John: thats n. These are issues being raised by another source. We know who the source is. Jim: We have not found anything other than radium 226. In a nutshell what happens in the field with instruments, youre finding radiological activity youre getting raw data in the field. When necessary, yoll send data to the laboratory. What specific type of radiological material. Weve sent numerous samples to the laboratory: 100pct have returned as radium 226. Thats. John: all this information on the question youre asking have been provided to the state. Jim: I dont want to =speak too mmuch to our contractor. But there was a crew member who ran up against his annual dose. This was some years ago. John: I do recall this being discussed since I became part of the team at TI. I thought this was completel addressed. This was a matter Probably around Jim 2007, 2008 time frame. New World Technology they were a subcontractor to the navys contractor shaw. That was their only project. New worls was. The contractor, they wear dosimeters, and those are measured, and if they exceed the annual exposure, they have to stop work. Thats standard. Im only aware. Jim Im not sure what the. Plutonium things get re-quoted. We have not had any material that we suspected was plutonium, or turned out to be plutonium. Everygthing was radium 226. When you initially investigate a site, you may have some understanding of what might have gone on, and thats veified by the laboratory testing. There was no areas where we expected to see plutonium, nor was. I think there are standard protocols set up when

something occurs, and there are proper steps taken to make sure. I dont think it was considered to be a large incident. Jim: based on all the characterizeations weve done to date, and the stae has sone some of their own surveys. Material we found was buried. Surveys state has done, weve not found anything that rises to the level of a health hazard for anyone living or working on TI, including the contractors. Contractors are typically not wearing special protective gear and dosimeters, to make sure theyre meeting safety standards. Theres surveys, meter surveys done along the perimeter. Done additional surveys outside our fenced areas to make. John: Between state of calif. And the navy, we have been working collaboratively with them. They were involved with the development of this document, and when we began our original research, we met with them on a regular basis, we met with them on a regular basis. We feel this is just a supplemnt to the regular information. It is not a shift in paradigm, and we will do whats necessary to protect the future and current users of the property. It has luckily, the new information that is being documented, in our discussions wit hthe city and county of SF does not have any major impacxt on the citys overall reuise plan and projects for the base. As of today as I speak. While thgere may be some slight modifications of boundaries, theres nothing alarming, or should be nothing alarming to ghe general public.

Grasteit, Christopher cgrasteit@comcast.net GeoInvoTech 1325-D Westside Dr San Francisco, California 94130 United States (415) 509-4322

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