West Coast
Site 1 and Site 32 are annotated in the upper lefthand corner. Image Google Earth.

CA - Navy Plan to Destroy Wetlands Lacks Scientific Backing

Vital Alameda Point wetlands are slated for costly and unnecessary destruction without scientific support.

Most Alamedans have read about the Navy’s plan for upgrading and expanding wetlands at Alameda Point where a regional park is planned. Unexpectedly, however, and behind closed doors, a single advisory staff member at a state agency halted the approved wetland expansion plan. He did so as work was already underway, and over 7,000 truckloads of soil had been delivered to upgrade the site. The controversy centers on the health risk that radium-226 luminescent paint waste artifacts may or may not pose to park visitors.

Alameda Post - a scenic view of wetlands
Partial view of Site 32 wetlands in March 2019. Photo Richard Bangert.

Rajiv Mishra, the supervising health physicist in the California Department of Public Health – Radiologic Health Branch (CDPH-RHB) told the Navy and other regulators during a July 2020 meeting that a wetland above any area that might contain radiological material is not allowed. This assertion turned out to be not true.

Wetland destruction will cost millions

In a response to our inquiry about the rationale for eliminating the wetland plan, the Navy and three regulatory agencies—the US Environmental Protection Agency (EPA), the California Department of Toxics Substances Control (DTSC), and Regional Water Quality Control Board—disputed Mishra’s claim, stating, “There are no ARARs [Applicable or Relevant and Appropriate Requirements], regulations, or policy guidance that state a wetland is unacceptable.”

But that was not the end of the matter. Since the Navy and other regulators need unanimous consent on cleanup plans, Mishra’s binding advisory role to DTSC essentially gave him veto power, so he was able to compel the Navy to agree to a special and more costly radiological scanning standard for the wetlands that would’ve been expanded from 10 acres to 15 acres. The 15 acres were to be excavated to three feet, with clean imported soil used to create new wetlands at the original elevation. The Navy and regulatory agencies said that this new scanning standard would raise the cost for the entire cleanup project from $25 million to $46 million if the existing wetlands were expanded as originally planned. Thus, the Navy decided the on-site wetland plan had become financially infeasible.

In the yet-to-be-signed draft Record of Decision issued in September 2021, in which the Navy now proposes to cover the wetlands with soil and mitigate the loss at another location, the total cost is pegged at $35 million because $15 million of that number is earmarked to pay for off-site wetland mitigation. None of this makes any rational sense, especially when there are no regulatory guidelines mandating special scanning standards at the base of a wetland.

The Navy and the regulatory agencies justify the ad hoc higher standard by stating, “If wetlands were mitigated on the soil cover…the development and maintenance of deep-rooted wetland vegetation could be problematic as it may create a potential exposure pathway to residual contamination.” While it is theoretically possible for radium-226 to be absorbed by plants, the degree to which this might occur is completely dependent on local soil conditions, the type of plants allowed to grow, and the extent of the contamination, according to a study on radium in soil that relies on an EPA study.

No evidence for radium-absorbing plants

These Site 32 wetlands at Alameda Point have been sitting there for 65 years with no evidence showing that this phenomenon of wetland plants absorbing radium has occurred. In fact, the extent to which artifacts such as paint brushes and rags from the radium dial-painting shop might or might not exist more than one foot below the surface is unknown. Surface scanning equipment is accurate only to a depth of one foot.

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