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*1S. Could DTSC respond in detail to the above observations?*

1T. November 3, 2000: “Runkle Canyon_Harding_Limited Soil Sampling_Pages 1 to 171_110300” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/3165784537/Runkle%20Canyon_Harding_Limited%20Soil%20Sampling_Pages%201%20to%20171_110300.pdf

P. 9 of this 171 page PDF: Review of the applicable radionuclides results (Table 1) indicated that the concentrations of tritium in all of the samples collected were below the minimum detectable activity (MDA). In addition, the concentrations of cesium -137 in all of the samples except S-I were also below the MDA The cesium-137 concentration in sample SS-1 at 0.09 pCi/g just exceeded the MDA of 0.077 pCi/g In terms of strontium -90 results, six of the seventeen original samples submitted exceeded the MDA in concentrations that ranged from 4.756 pCi/g in SS-6 to 0.686 pCi/g in SS-16.

The cesium-137 exceeds the EPA’s Preliminary Remediation Goal for an unrestricted residential setting. The 0.09 pCi/g cesium-137 result is 151% of the PRG of 0.0597 pCi/g.

The strontium-90 ex exceeds the EPA’s Preliminary Remediation Goal for an unrestricted residential setting. The 0.686 pCi/g strontium-90 result is 297% of the PRG of 0.231 pCi/g.

The 4.756 pCi/g strontium-90 result is 2,059% of the PRG for Sr-90 or over 20 times the strontium-90 PRG.

The report goes on to compare this numbers to the Department of Energy’s “dose-based” figures for the radionuclides, which is not how the Environmental Protection Agency calculates radiation danger. The EPA uses a risk-based numerical approach embodied by the use of Preliminary Remediation Goals.

The report goes on to show that the highest numbers were the ones closest to Rocketdyne, which EnviroReporter.com maintains that it indicates that the radionuclide may have come from the lab, and that “further systematic random soil sampling should be performed.”

*1T. Could DTSC respond in detail to the above observations?*

1U. October 19, 2000: “Runkle Canyon_Miller Brooks_Phase I & Soil Smapling_Pgs 1-97_101900” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/8307798087/Runkle%20Canyon_Miller%20Brooks_Phase%20I%20&%20Soil%20Smapling_Pgs%201-97_101900.pdf

p. 9 out of 97 page PDF: The primary contaminants of concern at the SSFL Facility are TCE and cis-1,2-dichloroethylene (1,2-DCE). However, other contaminants detected in groundwater beneath the SSFL facility during 1999 and 2000 include trans-l,2- DCE acetone, 1,4-dioxane, methylene chloride, nitrosodimethylamine, tetrachioroethylene (PCE), toluene, benzene, carbon disulfide, Freon 11, Freon 113, chloroform, perchlorate, total petroleum hydrocarbons (TPH) as gasoline, radiochemicals, vinyl chloride, nickel, and selenium (Haley Aldrich Inc. 2000).

It is noteworthy that many of these contaminants are found in adjacent and down-elevation Runkle Canyon as well.

P. 13/97: During the site visit on the Subject property on September 2000 soil removal activities were being conducted on the western portion of the SSFL Facility. The soil in the removal area was reportedly impacted with PCBs, mercury and dioxin (Figure 2). In phone conversation with Mr. Art Lenox from Boeing Environmental Group, it was stated that approximately 10,000 tons of soil had been removed from the site over the past two to three months Concentrations of PCBs mercury and dioxin in the soil exceeded the Preliminary Remediation Goals (PRGs) for residential soil. This information was the basis for the soil sampling plan conducted by MBE.

EnviroReporter.com was never aware that such a large amount of contaminated dirt was removed from Area IV from this area which has an 11-acre drainage into Runkle Canyon according to Boeing maps.

P. 15/97: On September 13, 2000, two MBE personell surveyed the Rocketdyne/Runkle Canyon border area with a pancake Geiger-Mueller detector, passing it over the soil within 2 o 3 centimeters. They concluded there was no obvious sign of radiation above background. EnviroReporter.com contends that this is not a satisfactory way to conduct a radiation survey as it does not have the ability to detect the various radionuclides that may be impacting the area. The report’s finding of “no gross contamination” cannot be supported by such a limited survey.

Five soil samples were also collected the same day and a week later. EnviroReporter.com contends that a definitive soil analysis can be ascertained based upon this limited a soil sample performed without adherence to proper EPA protocol.

*1U. Could DTSC respond in detail to the above observations?*

1V. October 1, 1999: “Runkle Canyon_Foster Wheele_Invest._Vol I_Pgs 1-108_101999” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/5247556388/Runkle%20Canyon_Foster%20Wheele_Invest._Vol%20I_Pgs%201-108_101999.pdf

This report was commented on in the print, online, and online-annotated version of the Los Angeles CityBeat cover story “Neighborhood Threat” by Michael Collins, March 10, 2005.

The following comments are from the newpaper article and serve to address the report in its entirety, including the eight sections below.

In its October 25, 1999 report, Foster Wheeler states that “the exposure limit chosen was 15 mrem/year (millirems per year) above natural background, which is a value already proposed by the EPA… 15 mrem/year is generally considered to be an acceptable end point, which is considered to be protective of human health by the USEPA.”

This ‘dose-based’ number measured in millirem is not the way the EPA measures a radionuclide’s toxicity. The agency calculates the presumably safe levels of radionuclides by using “preliminary remediation goals,” or PRGs. The Foster Wheeler statement that the EPA proposed this is also apparently inaccurate.

“An EPA limit was never formally proposed and the informal suggestion was withdrawn due to, basically, Department of Energy and Nuclear Regulatory Commission pressure,” says Stuart Walker, an EPA official who specializes in Superfund radiation issues. “The PRG levels are kind of the generic concentrations for Superfund cleanup sites although when you start talking about soil, we use a risk range for cancer of one-in-1,000,000 to one-in-10,000 as the risk limit range.”

In other words, the EPA calculates a fatal cancer risk for each substance so that it would cause no more than one death per every 10,000 people exposed to that radionuclide. But the ultimate goal is no more than one death per million people exposed.

The PRG for strontium-90, and its accompanying decay product, yttrium-90, is 0.231 picocuries per gram (pCi/g). This is a measure of how much the substance decays, shooting out ions that cause cancer.

Foster Wheeler’s 58 soil samples averaged 1.39 pCi/g, or six times the EPA’s preliminary remediation goal and nearly 27 times above the typical EPA background level for Sr-90 in the area. The hottest sampling spot, and the one closest to the Rocketdyne’s Santa Susana Field Laboratory, measured 12.34 pCi/g, which is over 54 times the EPA’s PRG and 237 times the normal background for the radionuclide. Regardless, the GreenPark subcontractor gave a hardy thumbs-up to the results. “In perspective, the concentrations of strontium-90… were found to be insignificant,” concluded the Foster Wheeler report.

“That’s definitely within the risk range,” says Walker, “unless something weird is going on with the site that would kick it up but, like I said, those are conservative numbers.”

“(Foster Wheeler) found even higher rad levels in the second set of tests than the first and had to massage them through really flaky means, but the numbers don’t lie,” says longtime Rocketdyne critic, Dan Hirsch of the Santa Cruz-based Committee to Bridge the Gap.

This weird science made its way into the now-approved EIR. “This assessment found that radiation levels were within normal background levels,” it reads. “Tritium and strontium-90 were not detected in any of the soil and groundwater samples at levels above normal background levels or at levels considered to pose a health risk.”

“It is troubling that a project would be approved based on the assertion that no soil samples found strontium-90 … at any level deemed to be a health concern, when virtually all of the several dozen samples exceeded background and EPA’s preliminary remediation goals for radioactive contamination,” says Hirsch.

*1V. Could DTSC respond in detail to the above observations?*

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