Up a River Without a Cleanup

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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?

USEPAs Gregg Dempsey

USEPAs Gregg Dempsey

“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.

HOT AIR

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.

Mule-mounted gamma scanner at Area IV

Mule-mounted gamma scanner-Area IV

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.

EPA contractor performing gamma scan of borehole

EPA contractor performing gamma scan of borehole

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.

HOT ZONES

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.

Plutonium 239-240 over 92 x BG 24 feet under reactor site

Plutonium 239-240 over 92 x BG 24 feet under reactor site

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.”

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  1. Another Simi Mom says:

    There is a story going around that a group of Bell Canyon residents deny that the reactor melt downs at Rocketdyne ever occurred, deny that radioactive contamination at Rocketdyne exists, and seek to disrupt any use of the main roads in Bell Canyon for trucks to remove radioactive soil from what is now euphamistically called the Santa Susana Field Lab aka Rocketdyne. Clearly these “radiation deniers” are being manipulated by Boeing to some extent. Clearly, DOE could require Boeing to build a new “haul road” in a location which would protect residents of all surrounding communities from radioactive dust flying off trucks as they head towards proper dump sites.

  2. Joyce norton says:

    I lived in Simi Valley from 1963-1975 and was in the first graduating class of Royal high. One of the things that struck me, growing up in Simi, was the strange diseases I saw cropping g up in different families I knew. During the years since then, I often wondered if these problems came from the continual exposure many of us faced living at the base of the mountain that housed rocketdyne. I have friends who grew up to have children born with severe abnormalities, unusual cancers and seemingly healthy people dropped dead from heart attacks. I sincerely hope that more research is done so the people living in Simi will be protected.

  3. Joan Bien says:

    It is disheartening to hear a representative from the EPA say such ridiculous and condescending things. The public does not deserve such scurrilous treatment from the very people we pay to do a job. They owe everyone a legitimate reason for utterly failing at their task. Not unlike the tobacco dwarves, this bunch needs to be called before Congress and required to reimburse the taxpayers. After which, they should be sentenced to ten years of living in Area IV, eating only what they grow in the contaminated ground and drinking only the contaminated water.

    Dream on.

    Any person who can say Michael Collins and Dan Hirsch are disingenuous, uninformed, or grandstanding is basically an idiot with an agenda. They have both given the rest of us the freedom to go about our daily lives, knowing that someone is watching the store and taking inventory.
    Boeing may believe it is all over, especially when they say so repeatedly. Boeing can lie like a rug, but the truth never changes.

    Now, it has been written down in detail.

    My heartfelt thanks to all of the citizen-soldiers who have taken up the battle at great personal cost.

  4. Troy Ng says:

    “Another Simi Mom” has got a hell of an idea — it would be awesome if Collins could rip the lid off the EPA’s performance on all these toxic sites. The EPA seems to treat the Rocketdynes and coal companies of the world as clients — not as the miscreants they are.

    Even more exposure might not help, though — it’s frustrating to read all this and to realize that despite the exposure, the polluters are getting away with it — aided and abetted by stooges and PR hacks.

  5. Margery Brown says:

    Michael,
    By the time I finished reading this final article, I was seriously nauseated and absolutely OUTRAGED!

    The Government agencies involved here, have accepted and now spent $41.5M of the tax payers’ money, and yet have not provided the agreed upon look-up table and other necessary information. Nevertheless,they seem to be planning to depart with their task undone. This just has to be illegal!

    Meanwhile, they have apparently decided that we really don’t need to excavate all of the contaminants down to background…only 1%..which means leaving 99% of it in the ground. Go figure that one!

    Meanwhile also, Boeing, the billion dollar corporation, is sponsoring a public relations campaign to get public APPROVAL for leaving the SSFL acreage still heavily contaminated with radionuclides and toxic chemicals…to be declared Open Space and a “Park” for everyone to enjoy.

    Unfortunately, this is the plot of an all too familiar story like Downey, Rocky Flats, Hanford and probably other nuclear sites. The story has to do with accepting public money, making acceptable sounding promises..but then doing a bait and switch…and finally…LEAVING when the money runs out…..leaving behind carcinogenic radionuclides and toxic chemicals…but taking with them, their army of government and corporation attorneys.

    It seems to me, that at this time, ALL of the environmental activists absolutely need to talk to each other, work with each other and make sure that the public is informed, no matter how divided their strongly held opinions may be on how deep we should dig. This needs to be done, lest Boeing have an opportunity to exploit these divisions in the Community to the detriment of everyone.

    We simply cannot afford to take this RISK!

  6. Bonnie Klea says:

    These stories are staggering. I have been an observer and been in the middle of the battle since 1995. Thank you Dan Hirsch for supporting our community. I have seen you pounded down when you accurately uncovered motives and truths to rise up stronger than ever. Michael Collins has brilliantly and silently stored data to accurately report in detail our long struggle to clean up Santa Susana. William Bowling is also brilliant in his fact finding and picture taking to capture details that most of us missed. This slip-shod cleanup of nuclear facilities is sadly going on all over the United States. Rocky Flats is one example of an “accelerated cleaup” that went wrong. The plutonium found after the cleanup was as high as precleanup numbers. Their nature park never opened and a proposed new highway would have been built on residual plutonium with high levels of breathable plutonium under houses.

    The biggest mistake that Boeing made was promoting a CAG. The thousands of letters that were sent out seeking participation only advertised the local mess in our community to new people who didn’t know about it. At the Decembe 12 meeting there were lots of new people with their own horror stories of cancer and sickness who wanted answers from the EPA thinking that the EPA would protect them.

    As a former worker and cancer survivor, I learned a long time ago that people are expendable and corporate profits are king. It is an eye opener when the corporation does everything in their power to stop sick workers from getting federal compensation.

  7. Yet Another Simi Mom says:

    Amazingly well thought out story Mr. Collins. Thanks for helping normal Simi Valley residents and alumni understand what is at stake.

    The only relevant “facts” which I can add are that Simi Valley’s new Congressman will be none other than Howard “Buck” McKeon, Chairman of the House Armed Services Committee. Buck’s resume, before entering Congress, was that he and his brothers owned a cowboy boot store in heavily contaminated Canyon Country, which ultimately went bankrupt stiffing a lot of local creditors. Buck’s major, in college, was animal husbandry. So that gives you a clue about the intellectual level of Simi Valley’s new Congressman whose principal job, theoretically, is to protect his constituents from harm at the hands of the Federal government.

    In the run-up to the November 2012 election, Buck found himself on the hot seat in the center of his District, because, in the previous 10 years, he had failed to follow through on his promise to Santa Clarita, Lancaster and Palmdale constituents that he would protect those communities’ access to the San Fernando Valley and beyond by arranging for the BLM and a Mexican gravel mining company to move their proposed “biggest gravel mine in the U.S.” away from the 14 Freeway out to the desert near Barstow. Congressman Buck following through on his promise to his constituents would have had the added benefit of protecting the air quality in Santa Clarita, which has one of the highest childhood asthma rates in the country. However, Congressman Buck couldn’t get the job done for his constituents because he was “too busy Chairing the House Armed Services Committee” and worrying about whether all of his defense contractor campaign contributors were happy and busy collecting Federal dollars.

    During the November 2012 re-election campaign, Congressman Buck’s constituents learned that one of his “Top 5″ contributors is Boeing. When interviewed on CNN about the “fiscal cliff” all that Congressman Buck could talk about was his conversations with Presidents of major defense contractors, who were very worried that under Sequestration the dollar amounts of their defense contracts would be cut.

    When asked, at a campaign forum, what he was going to do to support the remediation of Rocketdyne, Congressman Buck feigned ignorance, and tried to make his audience believe he knew nothing about Rocketdyne or its owner, Boeing.

    So it’s absolutely no surprise that Boeing is advocating a lowered remediation standard at Rocketdyne when it’s clear they will be supported by the Congressman in whose District Rocketdyne is located.

    As to DTSC’s top-to-bottom treachery towards Californians’ health, Michael Collins has told us all we need to know.

    As to the EPA, if one digs through national and local press stories, one can see EPA’s top political appointee decision makers back-peddling left and right on rigorously protecting the public health in terms of clean air, clean water and toxics remediation. Those not deluded by President Obama’s rhetorical flourishes understand that he and his staff, full of young Wall Street investment bank alumni, do not want the EPA being tough on private polluters let alone using a significant part of the Federal budget by spending money for remediation of former Federal facilities. I dare not ask Michael Collins to write one of his thorough exposes concerning EPA’s failings nationwide during the Obama Administration. Perhaps he’s told us all we need to know about EPA, by telling us they shut down their radiation monitors in Hawaii, after the Fukushima melt down began.

    To Dan Hirsch, the ladies from the Knolls, and all of the other honest activists demanding a thorough remediation at Rocketdyne, God bless. I hope 2013 becomes a successful year for you.

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