The Bayview Hunters Point community, located in heavily industrialized southeast San Francisco, has historically been one of California’s high risk communities. Early research documents the region has four times as many toxins as other city neighborhoods, hundreds of polluting industries and underground petroleum storage tanks and the Federal Superfund site at the Hunters Point Shipyard.

Establishing Medical Necessity for Implementation of a Human Biomonitoring Program at the Hunters Point Shipyard — A Federal Superfund Site

View from Parcel A of the Hunters Point Shipyard where 300 homes have been built and occupied and 150 more have been constructed. A Superfund site is any land in the United States that has been contaminated by hazardous waste and identified by the Environmental Protection Agency (EPA) as a candidate for cleanup because it poses a risk to human health and the environment. These sites are placed on the National Priorities List and assigned a Hazard Index Ranking Score.

“It’s one thing to read about environmental justice. It’s another thing to see it play out before our very eyes. Case in point: the unfolding saga of the Hunters Point Shipyard cleanup, which could prove to be one of the worse environmental injustices in California history.” Hunters Point is a Textbook Case of Environmental Injustice. Leif Dautch and Theo Ellington- SF Chronicle May 15, 2018

In July of 2003, the San Francisco Board of Supervisors adopted the Precautionary Principle Ordinance of the Environment Code. The ordinance states, “Where threats of serious or irreversable damage to people or nature exist, lack of full scientific certainty about cause and effect shall not be viewed as sufficient reason for the City to postpone cost effective measures to prevent the degradation of the environment or protect the health of its citizens.”

Thus, the Precautionary Principle Policy Statement codifies a civic duty to take anticipatory action to prevent harm.

The Precautionary Principle acknowledged the role science and technology play in creating new solutions to prevent or mitigate environmental problems while recognizing the conundrum that “science is creating new compounds and chemicals that are finding their way into mother’s milk and causing new problems. A central element of the precautionary approach is the careful assessment of available alternatives using the best available science.”

Despite the adoption of the Precautionary Principle, in 2004 the San Francisco Board of Supervisors accepted the transfer of a parcel of land slated for residential development located on the Federal Superfund site at the Hunters Point Shipyard. The environmental impact review for the proposed development documented numerous unmitigated hazards to human health and safety from air borne particles and residual soil contaminants including lead and asbestos. The EIR withstood legal challenge on grounds the economic benefits of the development project to the low income minority community were overiding considerations.

From the beginning there were problems and potentially life threatening impacts to human health due to grading of asbestos laden bedrock on the Parcel A hilltop.

The Environmental Health Section of the Department of Public Health documented a surge in hospitalizations for adult and pediatric asthma, emphysema and congestive heart failure beginning in 2004.The Bay Area Air Quality Management District 2007 report card found air pollution in Bayview Hunters Point — the 94124 zipcode- ranked in the 80th percentile for particulates, carbon monoxide, nitrogen oxides and volatile organic compounds and in the 90th percentile for sulfur dioxide.

The US EPA Office of Air and Radiation identifies particulate matter as a mixture of microscopic solids and liquid droplets suspended in air made of acids, organic chemicals, metals, soil, dust particles, allergens and, in the case of the Hunters Point Shipyard where radiation contaminated soils are undergoing remediation, volatilized radionuclides.

Particulate exposure has been linked to pre-term infant births and increased infant mortality rates. In Bayview Hunters Point infant mortality rates increased from 12.5 per 1000 live births to 15 per 1000 live births — across all ethnic groups.

In October 2007, the San Francisco Board of Education voted unanimously to halt the shipyard development at a public hearing attended by parents, students, teachers, school nurses and custodians who testified about the alarming increase in asthma, earaches, sinusitis and dermatitis seen in students attending schools along the perimeter of the shipyard construction activities. The Board of Supervisors did not halt the project.

In 2009 a Civil Grand Jury investigation identified conflict of interests that arose due to adoption of Article 31 of the Health Code, an ordinance allowing the Director of Health to set a fee schedule for DPH reimbursement by the master developer Lennar for earth moving activities at the Federal Superfund site. The Board of Supervisors did not halt the project.

In 2012, computers at a Navy laboratory detected 2,500“anomalous” soil samples collected and submitted as post remediation “clean soil” from multiple radiation contaminated regions on the former naval base. The soil samples lacked the signature elevations in radioactive potassium that characterize shipyard soils and were, thereby, suspicious. Computer analysis dated collection of the anomalous samples back in time to 2008.

Employees and contractors of Tetra Tech ECI, Inc. were incriminated in the collection of the “anomalous” samples ultimately determined to be fraudulent. Two Tetra Tech radiation control technician supervisors pled guilty and were sentenced to federal prison in May of 2018. In January of 2019, four high ranking Tetra Tech officials were incriminated in orchestration of the basewide malfeasance. Ray Roberson, the RCT incriminated by Tetra Tech’s own internal investigation, died suspiciously at the conclusion of the investigation in 2014. His cause of death has yet to be determined.

Whistleblowers came forward, beginning in 2013, to report they witnessed or were forced to engage in deliberate actions to conceal radiation hazards on the base. EPA and Navy retesting identified 28 falsely cleared buildings and up to 98% falsification of radiation contaminated soils on parcels transferred to the city in 2016 directly adjacent to the Parcel A neighborhood.

On September 13, 2016 Naval Facilities Engineering Command’s Base Realignment and Closure Program, in the face of irrefutable evidence of base wide fraud conducted by Tetra Tech, issued a letter halting further transfers of Navy property at Hunters Point pending results of investigations to clarify the actual potential for public exposure to radioactive materials.

There are 1303 Federal Superfund Sites in 50 states. The Hunters Point Shipyard has one of the highest Hazard Ranking Scores assigned by the EPA with a Hazard Ranking Score of 100% for ground water migration.

On June 14, 2018, in an open letter to the Board of Supervisors, a coalition of Bayview Hunters Point community organizations called for full retesting and clean up of the Hunters Point Shipyard citing “the imperative that we do everything in our collective power to ensure the Hunters Point Superfund site remediation is comprehensive, transparent and trustworthy. In addition to the Tetra Tech issue, there are other major problems with the Superfund remediation plan that pose a serious threat to public health and the environment.

The Board of Supervisors voted to scan Parcel A where homes were now occupied by families and new homes were undergoing construction. That gamma scanning began in September of 2018 and concluded in January of 2019. It detected over 110 above background gamma emitting anomalies identified as radioactive potassium along with a radium dial buried below the soil in a region of northern Parcel A the Navy never investigated.

According to the Historical Radiological Assessment, radioactive potassium is a radionuclide of concern at HPS used in fireworks and explosives, photography and lithography. It’s ubiquitous “fingerprint” in shipyard soils cannot be solely attributed to “naturally occurring” sources. The final report by the California Department of Public Health cleared the property. Legal and medical experts disagreed with the findings.

In 2003, a network of public health, faith, labor and environmental groups known as the California Body Burden Campaign championed legislation to establish a state wide biomointoring program. The Healthy California Biomonitoring Program — SB 680- was introduced by Senator Deborah Ortiz, D — Sacramento. Meetings were conducted in Oakland in 2008 to guide it’s implementation.

On March 1, 2009, community scientists of the Bayview Hunters Point Community First Coalition, in partnership with academic researchers from San Francisco State University and the University of California San Francisco School of Medicine, applied for $2 million in funding from the National Institute of Environmental Health Sciences to conduct community exposure research drawing upon the powerful new science of human biomonitoring to establish cause and effect relationships between toxins in the environment, their detection and disease expression among members of an exposed community.

Driving the environmental health movement in southeast San Francisco is a sense of urgency and the need to protect current and future generations from an “avalanche” of toxic chemicals linked to the neighborhoods inordinate incidences of cardiopulmonary disease, cancers of the larynx, bronchi and lungs, neurological and behavioral disorders, birth defects and infant mortality rates. The investigative team included this author, Raymond Tompkins, San Francisco State University chemistry professor and NASA air monitoring researcher Peter Palmer, Ph.D. and UCSF School of Medicine Clinical Professor of Pediatrics, Carol Miller, MD.

Dr. Kim Hooper of the State of California toxic laboratory in Berkeley assisted in submission of the proposal and Lori Copan, Ph.MPH — Project Manager for the California Biomonitoring Planning Project offered consultation to the proposal. While the NIEHS proposal submitted in March of 2009 was not funded, it planted the seeds that have germinated a full decade later to advance the implementation of a community based biomonitoring program.

Biomonitoring is a research tool that measures levels of chemicals in our bodies by analyzing samples of urine, blood, tissue, hair, breast milk, umbilical cord and even baby teeth, using mass spectrometry. Mass spectrometry is a laboratory method that ionizes chemicals and sorts the ions based on their mass to charge ratio. In simplest terms,“mass spec” sorts and measures the masses within a sample.

Body burden is a popular term used by environmental scientists to describe the total accumulation of toxins in our bodies…or pollution in people! In 2002 a study called “The Body Burden” found dangerously high levels of toxic compounds in body fluids of human volunteers. By analogy, climate change and human activities are increasing the body burden of the earth.

In 2004, researchers found an average of 200 industrial chemicals in umbilical cord blood collected by the Red Cross from 10 babies born in US hospitals. These compounds included pesticides and by products of coal, gasoline and garbage.

A recent investigation by UCSF professor of reproductive medicine Tracey Woodruff, PhD, MPH used a similar methodology to detected, on average, 56 chemicals in umbilical cord blood from women who gave birth at two hospitals in San Francisco, San Francisco General and Mission Bay. The body burden was higher in women who gave birth at the county hospital.

Advances in use of biomarkers in early detection and prevention of disease have found enormous scientific and commercial success. In February of 2019, investigators presenting to the American Association for Cancer Research reported a commercial blood test called Guardant360 liquid biopsy, was as effective as a tissue sample in detecting non-small cell lung cancers and predicting prognosis in a sample of 282 people in 28 centers.

Cologuard is a non invasive stool sample DNA screening test for detecting colon cancer approved by the FDA for people over 50 at average risk of colon cancer. In a study of 10,000 people, Cologaurd detected 92% of colon cancers with a false positive rate of 13% and an 87% specificity. The $600 cost of the test is covered by most insurance plans. The cost of a routine screening colonoscopy averages $1,600.

The Hunters Point Community Biomonitoring Program launched in January of 2019 as a community led partnership with academic medicine to implement a pilot program for residents living within a one mile radius of the Hunters Point shipyard. The preliminary investigation relies on a simple urinalysis analyzed by Genova Diagnostics Laboratory using mass spectrometry.

The Comprehensive Urine Elements Profile detects 35 toxic and nutrient elements including many of the major toxic metals and radionuclides known to be present in industrial and hazardous occupations. The test also analyzes deficiencies in nutrient elements including iron, potassium, calcium, magnesium, and zinc.

The test does not expose health care providers to human body fluids. An indepth evaluation and mandatory follow up are required for entry into the pilot program. Patients are instructed how to properly collect urine samples that are mailed in a prepaid FedEx envelope and processed with a seven day turn around.

This community exposure research is ground breaking in that only one human biomonitoring investigation has been conducted in the United States, to date,that sampled residents living adjacent to a Federal Superfund site.

No biomonitoring study has been undertaken in the United States to detect multiple toxic elements in a community adjacent to a property on the National Priorities List.

Post remediation biomonitoring of marine biota is being conducted at the United Heckathorn Superfund site in Richmond, California. Investigations of Bioaccumulation investigations of shellfish, beginning in 2002, indicate the pesticide contamination in sediments continue to pose a significant risk to human health. The biomonitoring is being used to gauge the effectiveness of remediation and is currently in its sixth year.

Suk, et al. identified human biomonitoring research goals for population monitoring that highlight a clear opportunity for early detection and prevention of disease caused by exposure to environmental contaminants.

The only human biomonitoring investigation conducted at a Superfund site involved site specific urine screening data from 181 women in communities surrounding the Aerojet Superfund Site in Rancho Cordova for perchlorate exposure. The EPA funded study was designed to gauge the protectiveness of preliminary remediation goals. The biomonitoring results - published in a 2008 EPA memorandum- show every subject was exposed to perchlorate at a substantial percentage of EPA’s reference range regardless of their source of drinking water — either municipal water supply or bottled and suggest food sources of perchlorate exposure were significant.

The Hunters Point Shipyard Parcel F Human Health Evaluation Work study objective, outlined in the May 2001, work plan used an ecological biomonitoring/bioaccumulation methodology designed to measure levels of chemicals in tissues from Macoma nasuta (clams) and fish to calculate potential carcinogenic risks and non-carcinogenic hazard quotients from shellfish and fish ingestion from the vicinity of HPS for statistical calculation of risk. Data from the regional monitoring program indicate concentrations of six groups of chemicals in fish collected in San Francisco Bay are high enough to pose a potential risk to anglers and subsistence fishermen. These chemicals are PCBs, dioxins, mercury, dieldrin, DDT and chlordane.

The US Department of Veterans Affairs established the nations largest toxic registry. It offers disability compensation or benefits for illnesses or conditions believed to be caused by contact with harmful chemcials or hazardous materials while serving in the military. The list of conditions includes Agent Orange exposure during the Vietnam era, asbestos exposure, Gulf War illness and radiation exposure. As many as 60,000 veterans volunteered for medical research for the U.S. Biological and Chemical Programs between 1942 and 1975. Medical care is available through the US Army for those who volunteered for this research and sustained injury or illness due to their participation.

The VA recognizes the following diseases are caused by exposure to ionizing radiation during service: cancers, non-malignant thyroid nodular disease, parathyroid adenoma, cataracts and tumors of the brain and central nervous system. Veterans do not have to prove a connection between these diseases and their service to be eligible for disability compensation.

I served as Attending Physician for the Persian Gulf, Agent Orange, Ionizing Radiation Registry at the Palo Alto Veterans Administration Health Care System in 1997 and interviewed three “Atomic Veterans” of the post World War II era who survived the July 1946 Operations Crossroads nuclear weapons tests conducted at Bikini Atoll in the Marshall islands. Several ships were hauled back to the Hunters Point Shipyard for decontamination.

The EPA’s Hazard Ranking System is designed to screen and prioritize sites for the Superfund program, based on limited data available at the time of NPL listing. The scores are not based on a comprehensive risk assessment of the site and do not reflect conditions after initiation of clean up. Note the Hazard Ranking Score for groundwater migration at Hunters Point is 100%.

The medical necessity for implementation of a human biomonitoring program for residents living within a one mile radius of the Hunters Point Shipyard Federal Superfund site is met by understanding the scope of contamination of the property placed on the National Priorities List in 1989 and assigned a pre-clean up overall site Hazard Ranking Score approaching 80%- based on risk of human exposure, number of toxins and proximity to sensitive receptors.

Establishing medical necessity for institution of a community based biomonitoring program took on new urgency in March of 2019 with the release of a summary of findings from The Greater Bay Area Cancer Registry report: Cancer Incidence Among Residents of the Bayview — Hunters Point Neighborhood, San Francisco, California, 2008–2012. The GBACR analysis identified a 31% increase in lung cancer among men living in the 94124 zipcode, attributed by DPH to smoking.

Independent research documents an overall decline in smoking and smoking related lung cancers in the San Francisco Bay Area. Indeed, San Francisco has enforced the nations earliest and most stringent anti smoking laws, beginning in 1983, when smoking was restricted by law in private workplaces. No research exists corroborating DPH theory the incidence of smoking increased 31% in men in the 94124 zip code during the years of the GBACR analysis 2008–2012.

It is important to note the 31% increase in lung cancer rates detected from 2008–2012 corresponds exactly to the years of the Tetra Tech scandal in which fraudulently cleared radiation contaminated soils went undetected with the potential for volatilization and inhalation during that four year window of exposure.

The World Health Organization identifies air pollution as a potent carcinogen and leading cause of lung cancer in non smokers. In addition to particle pollution, a documented increase in lung cancer in men living and working in the industrialized southeast sector of San Francisco is likely contributed to by occupational exposures. Indeed, the Hunters Point Community Biomonitoring Program evaluated a heavy equipment operator living and working in the 94124 with no history of smoking or alchohol use who undergoes mandatory drug screening. He developed cancer of the larynx in 2018 following documented occupational and environmental exposures to dust, fume and chemical emissions. Laryngeal cancer is a leading cause of occupational related cancers in men.

The people of Bayview Hunters Point deserve nothing less than protection from the adverse health impacts of poverty, racism and environmental injustice. The Hunters Point Community Biomonitoring Program strives to advance environmental public health through the establishment of a voluntary toxic registry and hazard surveillance system designed to optimize nutrition and lifestyle choices to prevent disease expression through early detection and implementation of a high quality medical referral network.

Ahimsa Porter Sumchai, MD is President & Medical Director of Golden State MD Health & Wellness. She served as a Physician Specialist for the San Francisco Department of Public Health and Attending Physician for the Palo Alto VAH Toxic Registry. As an elected member of the Hunters Point Shipyard Restoration Advisory Board in 2000, Sumchai founded the Radiological Subcommittee and contributed to finalization of the Historical Radiological Assessment. Sumchai contributes to the SF Bayview Newspaper as Health & Environmental Science Editor in memory of her father, George Donald Porter, a career longshore worker at the Hunters Point Shipyard, whose contributing cause of premature death was pulmonary asbestosis.

This publication was prepared for presentation to Biomonitoring California, Office of Environmental Health Hazard Assessment on March 29, 2019.

Medical Director - Golden State MD Health & Wellness. UCSF/Stanford Author & Researcher. PI HP Biomonitoring. Certified Clinical Nutritionist. PoliticoMD!

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