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| Runkle Canyon EIR Analysis |
Residents contend that the Runkle Canyon Environmental Impact Report (EIR) appears to be flawed for a number of
reasons including those reported on by Los Angeles CityBeat/ValleyBeat and EnviroReporter.com, and because of new
developments analyzed here. Not only were high strontium-90 findings in Runkle Canyon omitted or mischaracterized in the
EIR, the actual 2003 Miller Brooks environmental report used by the city to determine the property's safety was dismissed
by the California Department of Health Services in a Nov. 8, 2006 letter to the city.
"The Miller Brooks survey is not considered useful due to its high minimum detectable activity, which ranged from 2.0 to 2.8
pCi/g [a measure of radiation]," according to the DHS letter to the city. Yet this is the study the city of Simi Valley relied on.
"The Miller Brooks study of 2003 was truly the report that we used ... to do the EIR," said city planner Peter Lyons in our
initial expose in early 2005.
This is new information that Al Boughey, the city's director of environmental services, apparently didn't know when he wrote
August 23: "[S]ince the approval of the EIR, there has not (his emphasis) been any new information made available to the
City staff to indicate that risks from strontium-90 or perchlorate on the site have been inadequately studied or disclosed."
The new DHS conclusion that what we had already exposed is true, and that the city relied on faulty data, seems to suggest
that the strontium-90 problem in Runkle Canyon has "been inadequately studied or disclosed." Other new information
includes what we have already exposed and documented in our two-yearlong investigation.
During the Nov. 21 KCET-Channel 28 Life & Times program about Runkle Canyon, "Building on Toxic Soil?," city council
member Barbra Williamson expressed frustration that concerned residents had approached the city council about radiation
problems in Runkle Canyon long after the Environmental Impact Report was approved in the Spring of 2004. "I was
probably one of the most upset council persons only because the residents were there kicking and screaming and saying
there's a problem here," Williamson said. "My only problem was where were you three and four years ago when we were
doing the environmental document?"
The answer to that question is simple: the developer's EIR did not contain this crucial information. The residents first
became aware of the extraordinarily-high strontium-90 readings in Runkle Canyon, and the flawed EIR, with our March 10,
2005 Los Angeles CityBeat/ValleyBeat cover story "Neighborhood Threat - Runkle Canyon is poised to be Simi Valley’s
newest neighborhood. But did the city misinterpret the risk of radioactive material in the ground?"
In that comprehensive piece, we reported that, "Development critics now claim that the controversial developers of the
already-approved project, and the city of Simi Valley, may have deliberately or inadvertently neglected to adequately
address a potential radioactive dust-storm."
We analyzed how the project's developers seemed to shop their testing of the soil on the property until they got results that
suited their purposes. Residents say that lack of forthrightness about the canyon's radiation readings should in of itself
caused the city to reconsider their continuing acceptance of the EIR as valid, according to the website Stop Runkledyne.
That site says, "In our analysis, the City of Simi Valley can null and void its previous EIR approval based on the language of
the April 4, 2004 Planning Commission recommendation to certify the Runkle Canyon Environmental Impact Report. This
document is in the Simi Valley Library.
"Under the Development Agreement section called 'Default of the Developer,' it states 'If a material warranty,representation
or statement was made or furnished by the Developer to the City with respect to this Agreement which was known to be
false in any material respect when it was made… (then the City can break the agreement and)…Developer holds the City
harmless.'
"The City of Simi Valley must break this Development Agreement and save itself from the avalanche of lawsuits that will land
on the City threatening our community's fiscal well being."
That's pretty strong language. KB Homes reps speak a softer line. “As to your question regarding environmental concerns
at the site, according to stringent EPA safety standards, we are well below what is safe for residential development, which
are the highest level of environmental standards for any type of development,” wrote project representative Marlo Naber-
Mole in a late 2005 e-mail to a resident.
But just how stringent considering that KB Homes insists that the EIR is adequate? The language in Boughey's Aug. 23
report suggests that more analysis is needed especially since the US EPA reported to the city that it found that all but 9 of
126 soil samples at Runkle Canyon exceeded the EPA's "preliminary remediation goal" (PRG) for strontium-90. "The PRG
is set to indicate whether additional study is required to determine if the site is contaminated or a health hazard exist (sic),"
wrote Boughey.
EPA PRG's aim for the stringent goal of no more than one cancer million. Boughey suggests that this is the goal of the EIR
when he corrects a "typo" in the EIR's original calculation of .77 cancers in a million caused by strontium-90 at Runkle
Canyon down to .26 cancers in a million. Those numbers were based on the 2003 Miller Brooks report that the DHS said "is
not considered useful."
Therefore the EIR is in error. Should the city demand that KB Homes complete a new EIR, with new comprehensive testing
of strontium-90, as is its option, perhaps the developer's lab could actually do the "additional study" that Boughey cites and
test for radionuclides associated with massive radiation contamination, including partial meltdowns, such as several man-
made isotopes of uranium and plutonium.
"Ninety-nine percent of the time, I would think that when you're a developer and you're going to buy a piece of property,
you do your due diligence before you buy it," said Williamson on Life & Times. It will be interesting to see what the City of
Simi Valley and KB Homes consider "due diligence" in light of the new information that it now has.
reasons including those reported on by Los Angeles CityBeat/ValleyBeat and EnviroReporter.com, and because of new
developments analyzed here. Not only were high strontium-90 findings in Runkle Canyon omitted or mischaracterized in the
EIR, the actual 2003 Miller Brooks environmental report used by the city to determine the property's safety was dismissed
by the California Department of Health Services in a Nov. 8, 2006 letter to the city.
"The Miller Brooks survey is not considered useful due to its high minimum detectable activity, which ranged from 2.0 to 2.8
pCi/g [a measure of radiation]," according to the DHS letter to the city. Yet this is the study the city of Simi Valley relied on.
"The Miller Brooks study of 2003 was truly the report that we used ... to do the EIR," said city planner Peter Lyons in our
initial expose in early 2005.
This is new information that Al Boughey, the city's director of environmental services, apparently didn't know when he wrote
August 23: "[S]ince the approval of the EIR, there has not (his emphasis) been any new information made available to the
City staff to indicate that risks from strontium-90 or perchlorate on the site have been inadequately studied or disclosed."
The new DHS conclusion that what we had already exposed is true, and that the city relied on faulty data, seems to suggest
that the strontium-90 problem in Runkle Canyon has "been inadequately studied or disclosed." Other new information
includes what we have already exposed and documented in our two-yearlong investigation.
During the Nov. 21 KCET-Channel 28 Life & Times program about Runkle Canyon, "Building on Toxic Soil?," city council
member Barbra Williamson expressed frustration that concerned residents had approached the city council about radiation
problems in Runkle Canyon long after the Environmental Impact Report was approved in the Spring of 2004. "I was
probably one of the most upset council persons only because the residents were there kicking and screaming and saying
there's a problem here," Williamson said. "My only problem was where were you three and four years ago when we were
doing the environmental document?"
The answer to that question is simple: the developer's EIR did not contain this crucial information. The residents first
became aware of the extraordinarily-high strontium-90 readings in Runkle Canyon, and the flawed EIR, with our March 10,
2005 Los Angeles CityBeat/ValleyBeat cover story "Neighborhood Threat - Runkle Canyon is poised to be Simi Valley’s
newest neighborhood. But did the city misinterpret the risk of radioactive material in the ground?"
In that comprehensive piece, we reported that, "Development critics now claim that the controversial developers of the
already-approved project, and the city of Simi Valley, may have deliberately or inadvertently neglected to adequately
address a potential radioactive dust-storm."
We analyzed how the project's developers seemed to shop their testing of the soil on the property until they got results that
suited their purposes. Residents say that lack of forthrightness about the canyon's radiation readings should in of itself
caused the city to reconsider their continuing acceptance of the EIR as valid, according to the website Stop Runkledyne.
That site says, "In our analysis, the City of Simi Valley can null and void its previous EIR approval based on the language of
the April 4, 2004 Planning Commission recommendation to certify the Runkle Canyon Environmental Impact Report. This
document is in the Simi Valley Library.
"Under the Development Agreement section called 'Default of the Developer,' it states 'If a material warranty,representation
or statement was made or furnished by the Developer to the City with respect to this Agreement which was known to be
false in any material respect when it was made… (then the City can break the agreement and)…Developer holds the City
harmless.'
"The City of Simi Valley must break this Development Agreement and save itself from the avalanche of lawsuits that will land
on the City threatening our community's fiscal well being."
That's pretty strong language. KB Homes reps speak a softer line. “As to your question regarding environmental concerns
at the site, according to stringent EPA safety standards, we are well below what is safe for residential development, which
are the highest level of environmental standards for any type of development,” wrote project representative Marlo Naber-
Mole in a late 2005 e-mail to a resident.
But just how stringent considering that KB Homes insists that the EIR is adequate? The language in Boughey's Aug. 23
report suggests that more analysis is needed especially since the US EPA reported to the city that it found that all but 9 of
126 soil samples at Runkle Canyon exceeded the EPA's "preliminary remediation goal" (PRG) for strontium-90. "The PRG
is set to indicate whether additional study is required to determine if the site is contaminated or a health hazard exist (sic),"
wrote Boughey.
EPA PRG's aim for the stringent goal of no more than one cancer million. Boughey suggests that this is the goal of the EIR
when he corrects a "typo" in the EIR's original calculation of .77 cancers in a million caused by strontium-90 at Runkle
Canyon down to .26 cancers in a million. Those numbers were based on the 2003 Miller Brooks report that the DHS said "is
not considered useful."
Therefore the EIR is in error. Should the city demand that KB Homes complete a new EIR, with new comprehensive testing
of strontium-90, as is its option, perhaps the developer's lab could actually do the "additional study" that Boughey cites and
test for radionuclides associated with massive radiation contamination, including partial meltdowns, such as several man-
made isotopes of uranium and plutonium.
"Ninety-nine percent of the time, I would think that when you're a developer and you're going to buy a piece of property,
you do your due diligence before you buy it," said Williamson on Life & Times. It will be interesting to see what the City of
Simi Valley and KB Homes consider "due diligence" in light of the new information that it now has.
