The obvious question was, why can labs detect down to background on the background study but not be able to detect to background on the remediation?
“I don’t know,” Dempsey said. “I don’t know actually that they can’t but in my experience the analytical laboratory business kind of goes up and down as to what work they can do and what quality of work they can do. It kind of depends on how many other customers they have and how important they feel your work is to them.”
In other words, federal EPA-contracted laboratories choose just what kind of quality work they do under government obligation. That would be akin to Boeing technicians maybe not feeling like including radars or a wheel on its F-18 fighter jets when whimsy took them.
Such an explanation is outrageous on the face of it. It is what Vice President Joe Biden would call malarkey.
Some community members felt that the sham was yet another indication of Boeing’s influence on the state’s regulatory agencies.
They contend that the federal EPA and DTSC are playing the community, elected representatives and media for simpletons by trying to sell them on the notion that despite clear agreements to clean to background with new measurements establishing background and data showing where all the Area IV contamination is above background, that cleaning to background isn’t the “responsible” thing to do. It’s the laboratories which are at fault, not the EPA which was in charge of spending $41.5 million with nothing to show for it.
Now, the Department of Energy is stuck with a worthless report if implemented as planned, and is out millions with no clear and present direction to clean up its contaminated site. The tractors and trucks could have been rolling by Spring 2013 and Area IV finally getting the remediation that was agreed to and could be commenced expeditiously.
The federal EPA’s explanation at the DTSC meeting as to the reason it gutted its own detailed and well-executed sampling and lab testing doesn’t wash. Not producing the required job product that the agency was required to give to DTSC, and DTSC actually accepting this non-delivery thankfully, smacks of cronyism and contempt for the longtime community fighting to cleanup Rocketdyne.
The community believes it has been betrayed once again as has the American taxpayer. The other gooey shoe that dropped from the EPA radiation report, unfortunately for Boeing’s meltdown makeover, is just how hot the rad readings are in Area IV. With EPA’s gutting of the cleanup to background, the consequences of leaving radioactive soil, asphalt and building foundations in place could become abundantly clear if SSFL ever becomes public open space – much of the place will be hot with some of the most dangerous man-made radionuclides on the planet.
A federal appropriations law instructed DOE and EPA in 2008 to work together on a mutual radiation characterization of Area IV of SSFL in accordance with the Comprehensive Environmental Response, Compensation & Liability Act known as CERCLA. DOE then gave EPA $41.5 million to conduct a background radiological study for SSFL and a radiological contamination sweep of Area IV and the Northern Buffer Zone. Most of the money for EPA’s studies, $38.3 million, came from funding distributed to DOE under the American Recovery and Reinvestment Act of 2009.
The Department of Energy, which leases 90 acres of the 270-acre Area IV site from Boeing, charged EPA with performing this site-wide survey and producing a “Look-up Table” or LUT. A LUT lists each radionuclide’s background, which sometimes can vary from the surface to underground.
Also required of EPA was a report on the thousands of tests, including precise maps of where the contamination was so it could be dug out or remediated in place by DTSC. No more time-consuming and expensive risk assessments or arguments over the details of cleanup levels: just remediate anything over background. All told, full cleanup of the huge lab was supposed to be complete by 2017 and could have been if this simple formula, agreed on over two years ago, was followed.
An analysis of thousands of pages of the EPA study by EnviroReporter.com reveals that the company subcontracted out to do the study, HydroGeoLogic, Inc., dismissed the use of the background levels on the very first page of its report as if the AOCs didn’t exist.
“[P]roject decision levels, called radiological trigger levels (RTLs),” said the HGL introduction, “were used during the sampling events to identify locations of potential concern in the absence of defined cleanup values.” [Our emphasis]
The $41.5 million question is what part of “background levels are the cleanup levels” did HGL not understand? Instead, DOE has been handed a hugely expensive report that doesn’t delineate and map out where the poisons over background are so they can be dealt with in accordance to the deal it signed with DTSC.
HGL repeats, in various versions throughout the thousands of pages of its EPA report, complex and inscrutable explanations for why background cleanup levels shouldn’t be used because of accuracy problems. As specious an exercise as it is, the only consequence of potentially small margins of error in the actual cleanup by labs that will be contracted to do the work is that there is the small chance remediators would clean up too much by excavating an inch or two too deep in radioactive soil.
This supposed background cleanup level inaccuracy comes impudently as HGL simultaneously presents in the same report accurate backgrounds of the radionuclides of concern as well as precise detections and measurements of this suite of radioactive isotopes throughout Area IV. Shoveling through this mountain of malarkey doesn’t obscure the fact that HGL’s measurements are accurate therefore future measurements at the lab can be too.
The EPA clearly did not edit or alter the report to reflect the DOE/DTSC Agreement on Consent of cleaning to background. Instead, the reader is treated to a treatise on statistical probability and the minimum detection levels of heretofore unpicked laboratories which will test the soil excavated from Area IV someday. Those real uncertainties, introduced by HGL for the EPA, would make it impossible to even begin the cleanup until years from now.
Nothing changes the very real readings of radiation in Area IV that populate the EPA report by HGL. The huge hits over vast areas are the best characterization that Area IV has had to date. The results aren’t pretty but they sure are hot.
Plutonium 239-240’s highly elevated detection in a bore hole where the Shield Test Irradiation Reactor (STIR) provides insight into the problems of cleaning up a place as polluted as SSFL. On multiple occasions, the STIR site was declared clean and then released for unrestricted use.
The EPA-funded radiation survey found Pu-239-240 at over 92 times background 24 to 28 feet below where the STIR reactor was situated. Not only is this a high multiple of background – California Highway Patrol protocol dictates anything over 3 times background is a possible hazmat situation – the radionuclide is particularly deadly.
A pound of Pu 239-240 could kill about 2 million people through inhalation according to Bernard L. Cohen, author of “The Nuclear Energy Option, Chapter 13, Plutonium and Bombs” in 1990. Breathing in Pu 239-240 is about 23,000 times more hazardous than inhaling weapons-grade uranium and 130,000 times more dangerous when ingested.
The super hot spot was found under where the actual STIR reactor once stood. Today it looks like an inviting field to kick the ball around in a future new park or perhaps have a picnic on the level site with an incredible view of the mountains. It even has the original stone staircase leading up this field where no vegetation appears to grow.
That’s where the Pu 239-240 was found. It’s still there today and will likely remain so, since the $41.5 million was apparently only spent on establishing background for a look-up table and locating all the dirt defiled by any man-made radiation found over background.
Building 4028 was built in 1960 to “perform tests on space reactor shields,” according to the Department of Energy. “The original reactor was the Shield Test Reactor, a 50 kW reactor that operated in a pool of water from 1961 to 1964. The reactor was modified in 1964 and renamed the Shield Test Irradiation Reactor (STIR) where the 1 MW reactor operated from 1964 to 1972. Neutron radiography, a process similar to using X-rays to examine objects and devices was performed during this time. In March of 1976, STIR was decommissioned and removed from Building 4028.”