CommentsENVIRONMENT POLITICS-The above map is from the Federal EPA’s Radiological Study Report.
CAL EPA has updated its website for all of its agencies. The website link for DTSC for the Santa Susana Field Laboratory can be found here.
PUBLIC HEALTH AND PUBLIC SAFETY
Human health and public safety – those are my only focuses today. My personal eyes are no longer on the “prize” – a State Park or a park under the National Park System as our local community were once discussing more than a decade ago for the Santa Susana Field Laboratory (SSFL) site. It is not clear to me with all of the ongoing litigation that the park will happen in my lifetime.
The Federal EPA (EPA), and the California Department of Toxic Substances Control (DTSC) the lead agency on the SSFL cleanup, have taken the position since at least 2003, that there was no offsite risk from the SSFL site.
Yes, when we have had fires, like the 2005 Topanga Fire, and the 2018 Woolsey Fire, vegetation burned, and there were more contaminants that migrated from the SSFL site via surface water pathways.
In 2008, the Los Angeles Regional Water Quality Control Board (LARWQCB) ordered the Boeing Company to pay for a “Storm Water Expert Panel” that they (the Regional Board) chose. The Boeing Expert Panel has been going to the SSFL site for more than a decade and has made recommendations to Boeing and NASA on remediation efforts which actually reduced the number of storm water violations that Boeing had for its “National Pollutant Discharge Elimination System (NPDES) Permit. The Boeing Stormwater documents can be found on the Boeing website.
Let’s step back and look at what the EPA said about the Santa Susana Field Laboratory back in 2003 in terms of offsite risk.
“The U.S. Environmental Protection Agency (EPA) Region 9 Superfund Program has determined that the Energy Technology Engineering Center/Area IV (ETEC) site is not eligible for inclusion on Superfund’s National Priorities List (NPL), and no further response action by the Federal Superfund program is warranted at this time. The decision is based on EPA’s evaluation of radionuclide data for ETEC Area IV. EPA’s decision does not impact ongoing remediation efforts being conducted by the U.S. Department of Energy (DOE).”
“Summary of HRS Results at ETEC Area IV In 1996, the SSFL Workgroup, requested that the EPA Superfund program evaluate radionuclide data for Area IV to determine whether Area IV qualified for inclusion on the NPL. In response, the EPA Region 9 Superfund program initiated a Site Investigation for Area IV using Hazard Ranking System (HRS) criteria.
The HRS assesses the relative potential threat to human health or the environment posed by a site and is the principal mechanism EPA uses to place uncontrolled waste sites on its National Priorities List (NPL). ETEC Area IV was determined not to be eligible for the NPL for the following reasons:
- The groundwater beneath Area IV is not currently used for drinking water. The nearest active drinking water well is located beyond the 4-mile radius required for inclusion in the HRS. Although tritium is found in the groundwater beneath Area IV, none of the concentrations of tritium exceed the U.S. EPA Maximum Contaminant Level (MCL) of 20,000 picoCuries per liter (pCi/L).
- There are no drinking water intakes, fisheries, or aquatic sensitive environment habitats as defined by the HRS associated with the surface water pathway (i.e., the intermittent creeks that drain Area IV).
- There are no residences, schools, daycare centers, or terrestrial sensitive environment habitats as defined by the HRS, on or in proximity of ETEC Area IV. Radionuclides associated with historic Area IV research are not present at concentrations significantly above background in the soils surrounding residential communities.
- No annual exposures measured are above the Nuclear Regulatory Commission annual dose limit to the general public of 100 millirem above natural background. Measurements are based on continuous ongoing outdoor ambient air sampling of radioactivity conducted within and along the perimeter of Area IV. There is no known outdoor ambient air sampling that was conducted on-site or off-site during the years that Area IV was fully operational.”
- What does this mean in the statements above? The EPA was asked by the “SSFL Workgroup” (then an agency run group – now a non-profit run website) to consider the risk from the radionuclides at the SSFL site. The EPA determined that the SSFL site did not pose a human health risk to our community based upon a radiation risk assessment and therefore it did not qualify to be on the Federal National Priorities List (NPL).
MAP OF THE 2005 TOPANGA FIRE BURN AREA – OCTOBER 10, 2005
- Why is this map important? It is important to see that the Santa Susana Field Laboratory burned during the 2005 Topanga Fire as well as during the 2018 Woolsey Fire. Yet, the media alarm, the community alarm was not as great during the 2005 fire. Why is that? The only answer I can see is the media – the media are publishing what I consider to be misinformation from various non-profits who in turn create alarm regards to radiation risk from the SSFL site.
In 2007, the Federal EPA came back to the SSFL Workgroup (which they once funded). This time, they were being asked to assess a combination of radiation risk and chemical risk for the SSFL site.
In December 2007, the Federal EPA completed its “Preliminary Site Assessment” for the SSFL site. They concluded that the site would qualify for the EPA’s National Priority List (NPL). However, the EPA did not conclude that it qualified based upon radiation risk – it qualified based on contaminated groundwater.
In March 2008, the EPA issued a FACT SHEET regarding their decision to list the site, and the decision of the State of California in regards to listing the SSFL site for the National Priorities List.
“Superfund Eligibility Evaluation of Santa Susana Field Laboratory has been Completed”:
- “In December 2007, EPA requested the State of California’s position on listing SSFL on the NPL.
- In January 2008, EPA received a letter from the State requesting that EPA defer NPL listing for six months to allow the State to negotiate a formal cleanup agreement with Boeing and fully evaluate possible impacts of NPL listing.
- In response to the State’s request for an extension, EPA will delay consideration of listing. After the six-month period, EPA will reevaluate proposing SSFL for listing on the NPL. In the meantime, EPA is working with DOE and CalEPA to plan for additional radiological assessment work.”
BACKGROUND RADIATION
In 2010, the Department of Energy (DOE) and the California Department of Toxic Substances Control (DTSC) and the National Aeronautics and Space Administration (NASA) entered into separate agreements which are often called the 2010 Administrative Orders on Consent.
The Federal EPA was asked to do a “Background Study” to determine local “Background” for the radionuclides that occur naturally “NORM” radionuclides, and from fallout from weapons and weapons tests. The map at the beginning of the article shows the three locations within the same geological formations as the Santa Susana Field Laboratory site.
“The objective of the Santa Susana Field Laboratory (SSFL) Radiological Background Study is to determine background radionuclide concentrations within surface and subsurface soils over lying the two geologic formations that are present at the SSFL: the Chatsworth and Santa Susana formations. Analytical results from these soil samples were used to estimate background threshold values (BTV) that will represent local unimpacted areas similar to the SSFL.
Background threshold values (BTV) were estimated based on established background data collected from unimpacted background (reference) locations approximately 3 to 6 miles outside the SSFL property boundaries. The analytical data from the radiological background reference areas (RBRA) have been determined to be an established background dataset by:
- Conducting exhaustive research on the RBRAs to ensure that they were unimpacted areas and in the correct geologic formation, including site visits, aerial photograph interpretation, and historical research;
- Removing statistical outliers from the dataset; and
- Comparing the RBRA analytical data to the distance test location (DTL) data and confirming that the RBRA locations have not been impacted by any activities at the SSFL.
Sampling at the DTLs was designed to determine whether surface soils at the RBRAs have been impacted by releases from SSFL. To determine if the RBRAs were representative of unimpacted background soils, the analytical data from the RBRAs were compared to the analytical data from the DTLs. This comparison revealed that the analytical data from the RBRAs were comparable to the analytical data from the DTLs; therefore, the RBRAs are considered unimpacted background locations.
Once it was determined that the RBRAs represent unimpacted background locations, BTVs were calculated using analytical data collected from all the RBRAs. Statistical evaluations were completed for each radionuclide and BTVs were calculated for 64 different radionuclides. BTVs were estimated using maximum nondetect values for radionuclides with fewer than five detections. Four different statistical limits were evaluated as potential statistics to determine BTVs for radionuclides exhibiting greater than five detections. Based on the analytical results and the uniqueness of the on-site investigation, it was determined that the 95% Upper Simultaneous Limit (USL95) was the best statistic to estimate BTVs. The statistics limits evaluated are described in detail in Section 8 of this report.
Six individual datasets were evaluated for each radionuclide: surface and subsurface soils from the Lang Ranch RBRA (Chatsworth Formation); surface and subsurface soils from the Rocky Peak RBRA (Chatsworth Formation); and surface and subsurface soils from the Bridle Path RBRA (Santa Susana Formation).”
What is important here?
- The EPA and DTSC concluded that these sites in the same geological formation were unimpacted by the radiological contamination from the SSFL site;
- The locations used – Lang Ranch and Bridal Path had the same “burn history” – for example the 2005 Topanga Fire, as the SSFL site.
- DTSC used these two locations – Lang Ranch and Bridal Path, for their chemical background study. DTSC did not use the Rocky Peak location for their chemical background study because that area had burned more recently than the SSFL site and the two other background locations. They also did not use the Rocky Peak site for chemical background due to its proximity to the 118 freeway.
The Federal EPA then worked with DTSC to do their AREA IV and the Northern Buffer Zone (NBZ) of the SSFL radiological studies.
“FINAL RADIOLOGICAL CHARACTERIZATION OF SOILS, AREA IV AND THE NORTHERN BUFFER ZONE, AREA IV RADIOLOGICAL STUDY, SANTA SUSANA FIELD LABORATORY, VENTURA COUNTY, CALIFORNIA”:
Maps of where radionuclides were found above local background can be found in this document with the EPA’s recommendations about how to move forward in the future when sampling for radionuclides for remediation of the SSFL AREA IV and the NBZ of the site. AREA IV was where the nuclear operations were historically conducted.
Where are we today? Ironically, the DOE’s Final Environmental Impact Statement (DOE FEIS) came out in December 2018, shortly after the Woolsey Fire. One of the things that was referenced in that document was the risk of future fires at the site. It had been written prior to the Woolsey Fire.
This is the link to the DOE’s FEIS website.
My goal of this and other recent articles was to show that the SSFL site has burned historically, and yet, the EPA Background locations were determined at 3 to 6 miles to be unimpacted by the SSFL site. Why is this important?
People are being led to believe that the radiation risk from the SSFL site was potentially harmful to everyone in reach of the Woolsey Fire. Some people are asking for people’s photos as far from the SSFL site as 15 miles with claims that their cancers may have been caused by the SSFL site.
People all over the world are signing a petition to clean up the SSFL site to “Background” – some people who sign this petition may know nothing about the SSFL site except what is written on blogs, posted on YouTube, or published in the media.
I support the cleanup approach to the SSFL that was suggested to NASA by the EPA for NASA’s Draft Environmental Impact Statement in 2013. In the EPA letter to NASA for their portion of the SSFL cleanup, the EPA stated:
“We agree that cleanup of radioactively contaminated soil to background is imperative. EPA and DTSC have cooperatively overseen the cleanup of radioactive contamination to background at, for example, Hunter’s Point Naval Shipyard and McClellan Air Force Base. For chemical contamination sites, EPA, as well as DTSC, typically performs soil cleanups to health-based levels, unless background concentrations exceed those health-based levels.
We are concerned about the impacts associated with NASA’s proposed removal, transport, and disposal of the large volume of soil that is chemically contaminated at levels below risk-based thresholds. At other cleanup sites, including adjacent non-federal portions of the Santa Susana site, nearly two-thirds of the soil with comparable levels of chemical contamination would be left in place. The increase in traffic and associated air emissions that would result from this action would create an unnecessary added burden to communities with environmental justice concerns near the potential receiving facilities, such as Kettleman City and Buttonwillow, as well as to the local community at the cleanup site.
Based on the information provided in the Draft EIS, NASA proposed soil removal would require 52,000 (one-way) truck trips, compared to the 19,000 truck trips that would be required for cleanup to residential standards. As the Draft EIS also notes, this would be in addition to the 40,000 truck trips that Boeing and the Department of Energy will need to haul waste to disposal facilities from their portions of the Santa Susana site. Additionally, the total volume of soil would consume a notable portion of the hazardous waste landfill capacity in the State of California. DTSC has announced a commitment to reduce by half the amount of hazardous waste disposed in the State by the year 2025, and EPA supports that effort.”
The link for the EPA letter to NASA is here.
This is the EPA May 2018 FACT SHEET on the radionuclides that they found in AREA IV and the NBZ:
“So far, EPA has not found any unexpected radioactive contamination. Radiological contamination has primarily been limited to locations in the vicinity of the Sodium Reactor Experiment (SRE), the Radioactive Material Handling Facility (RMHF), and a few other locations, all onsite.”
“Site access is restricted and therefore, the public is not exposed to this contamination.”
In conclusion, the SSFL site should be cleaned up as stated by the Federal EPA in their letter to NASA as above. Cleaning up more than is recommended by the EPA could pose greater risk to the local communities and to the receiving communities.
(Chris Rowe has been a 41-year resident of West Hills, was a former West Hills Neighborhood Council Board Member, and has a B.S. in health education. She can be reached at [email protected].) Prepped for CityWatch by Linda Abrams.
