Fuzzy environmental impact report proposes leaving lab contamination in place as Boeing produces new greenwashing website against cleanup
After more than four years of preparation, CalEPA’s Department of Toxic Substances Control (DTSC) debuted its massive draft programmatic environmental impact report (EIR, DEIR or PEIR) for the astronomically polluted Santa Susana Field Laboratory (SSFL) on September 7. The long overdue yet calculatingly uninformative EIR breaks the agency’s previous cleanup commitments, leaves out any risk assessments, and ultimately recommends no cleanup of the site.
Over 1,000 pages are devoted to demonizing any cleanup as being worse than leaving the contamination in place yet there isn’t a single page devoted to saying what the risks are to the public from contamination that would remain on site under varying levels of remediation. Unlike any other EIR that EnviroReporter.com has analyzed, these documents offer little information for the public to really comment on, including how much radioactive and chemical contamination DTSC will require the responsible polluting parties clean up.
Using Trumpian doublespeak, DTSC claims to have bared all and resorts to outright fabrication early in the EIR. “Advantages of a PEIR,” says one section in part one of Appendix C, “Ensures full consideration of cumulative impacts.” It is just one of many fabrications presented as fact employed by DTSC in this document prepared by a subcontractor for lab owner Boeing.
What is clear, however, is California Governor Jerry Brown’s imprimatur on his toxics department has done more to damage any chance of cleanup at SSFL than at any other time in the 19 years this reporter has written on the Cold War-era Rocketdyne lab. Long ago exposed as a tool of the polluter in EnviroReporter’s 2012 Toxic Department, DTSC has plumbed new depths in denying SSFL, and the impacted surrounding area, the cleanup it had long promised Southern California.
DTSC effectively buries any hope of any substantial cleanup of an astronomically fouled field lab sitting at the heart of Southern California. It is government against the people who elected a governor who has no intention of protecting them from the menace that is SSFL.
Boeing’s Orwellian Greenwashing Website
Since April, Boeing has debuted a slick website called Protect Santa Susana that invites the public to tell DTSC that the lab essentially needs no more clean up at all. It actually encourages the public to submit a comment to DTSC (copied to local elected officials) that says, “I am opposed to the proposed cleanup and cleanup alternatives for Boeing’s property in the draft Environmental Impact Report that assume residential development and backyard gardens at the Santa Susana site.”
That would, in effect, allow Boeing to walk away from SSFL with about 98 percent of the toxins tainting the area left in place to supposedly decay away. SSFL, which has suffered three partial nuclear reactor meltdowns and conducted over 30,000 rocket engine tests, would see no more substantial remediation before it is released with no restrictions.
The results of leaving this intense, long-lived contamination are so serious that according to analysis of Boeing’s own data, “are so high that 96 out of 100 people living at the STL-IV as it is right now would get cancer.” In nuclear Area IV, perched high above the Brandeis-Bardin Jewish camp below, “Soil sample #60540 was laced with cesium-137 which clocked in at 9,328 times its background,” according to Radiation Readings Soar at Rocketdyne in 2012. “On a scenic bluff overlooking Simi Valley next to where the SRE once stood, leukemia-causing strontium-90, which has been found at high levels at Rocketdyne-adjacent Runkle Canyon where KB Home hopes to build hundreds of homes, soil sample #60446 was assigned an RTL 6.47 times Sr-90’s BTV and tested at 284 times background.”
Facts be damned, fission forgotten, and public health protections jettisoned all the while posing as saving the environment. The Boeing website is the culmination of an elaborate and expensive “greenwashing” scheme first cooked up in 2012 with former Los Angeles Times environmental reporter-turned polluter image polisher, Gary Polakovic and his aptly named Make Over Earth, Inc.. In the Age of Trump, portraying the polluter as environmental savior with a straight face may not seem such a stretch.
“Boeing’s website only shows photos of rolling green hills and wildlife,” says Marie Mason, co-founder of the pro-cleanup Rocketdyne Cleanup Coalition. “They don’t show melted nuclear fuel rods, or burn pits, or people with cancer. Telling people that Santa Susana needs to be protected from a toxic cleanup is like telling people in a burning building that they need to be protected from firefighters. But what Santa Susana actually needs protection from is Boeing!”
Counter Campaign Says There’s No There There
In an effort to counter Boeing’s brazen website, the Rocketdyne Cleanup Coalition and other groups launched their own site, Protect Santa Susana from Boeing. The website calls out Boeing for its greenwashing campaign and rips DTSC’s EIR as equally manipulative.
“Amazingly, the EIR has a thousand pages of all the supposed negative impacts of doing a cleanup, but nothing on the negative impacts of the contamination and the health and environmental harm that would occur if the pollution isn’t cleaned up,” says the new website’s FAQ page. “By omitting cancer risk information and hyping potential negative impacts of the cleanup, the EIR presents a biased and inaccurate assessment of the SSFL cleanup. It is essentially a PR attack on the cleanup commitments DTSC itself had made.”
Indeed, DTSC’s massive DEIR doesn’t examine the greatest ecological threat at SSFL which is obviously the radioactive and chemical contamination. Instead the puzzled reader is treated to anything but the real numbers on how many people could get cancer if the former Rocketdyne complex is not cleaned up to background levels or cleanup standards dictated by Ventura County’s zoning of the site, which would be the most protective.
“DTSC’s EIR contemplates leaving large amounts of contamination in place, which it refers to as “natural attenuation” says the Protect Santa Susana from Boeing website. “This means just leaving the toxic materials and hoping they lessen over long periods of time. It also violates the AOC [2010’s Agreement on Consent to remediate to background levels of goo] cleanup agreements, which prohibit even considering leaving contamination in place.”
The new pro-cleanup website minces no words when it comes to calling out DTSC on its unprecedented EIR for SSFL. “The EIR also fails to disclose what DTSC is actually proposing to not clean up. It is absurd to release a report that gives no real information about what the proposed cleanup amounts will be. DTSC hides the ball—it keeps hidden how much contaminated soil it contemplates not cleaning up, saying that it will disclose that only after the EIR is finalized.”
Teasing out the EIR, it seems DTSC will decide to clean up nothing at all, that the cleanup is the enemy and not the high levels of radionuclides and chemicals that span SSFL from its eastern entrance in Area I all the way to its Area IV western border with Brandeis-Bardin and Runkle Canyon. That is if the department can succeed in fooling the vast majority of the public who want SSFL completely cleaned up including the political leaders that represent them.
“This flies in the face of environmental law, which is to disclose and analyze in the EIR, not shielding from public view its intentions until after the EIR is over,” says the website. “And by only giving information about supposed impacts to the environment from cleanup and excluding information on risks to health and the environment from the contamination itself and from not cleaning it all up as promised, the DEIR misrepresents all risks.”
Radiation Found and Forgotten
Evidence, however, of the lab’s widespread radiation problems can be found in the draft EIR’s “Appendix K, Draft Excavation and Offsite Disposal Volume Estimate for Boeing Areas I, III, and Southern Buffer.” Cesium-137 was found far from nuclear Area IV near the lab gates in Area I. At the Laser Engineering Test Facility/Component Test Laboratory, radioactive “heavy water” or tritium was found.
Europium-152 was found in the Area I Burn Pit at 8.7 times its background threshold value (BTV) as determined by a the US EPA’s $41.5 million radiation study of Area IV’s radioactive soil. Strontium-90 was found in 2011 in Area III’s Systems Test Lab IV at 11.1 times its BTV.
According to documentation obtained by EnviroReporter.com, the California Highway Patrol considers any material or situation over three times background to be the triggering level for a hazardous materials incident. These readings outside of nuclear Area IV far exceed that HazMat threshold.
More alarmingly is what the draft EIR didn’t include in its Appendix K and so will likely never be addressed. The 2016 EnviroReporter.com exposé Critics question safety of Boeing’s Santa Susana Field Lab hikes reported that in the Area I Burn Pit “radium-226 was actually as high as 144.2 times background according to Boeing’s own numbers.”
A Boeing-funded September 2009 study on the burn pit revealed that, as we reported, “the highest level of 2,3,7,8-TCDD in the burn pit was 2,684.4 times its BTV. This is the most potent form of dioxin. It was used in Agent Orange and is carcinogenic according to the International Agency for Research on Cancer.”
Seventeen dangerous radionuclides exceeded their backgrounds significantly. “Bismuth-214 came in at 67.5 times its BTV with lead-214 topping off at 65.5 times its background,” we wrote using Boeing’s readings compared to their respective EPA BTVs. “[P]lutonium 239/240 glowed at 5.7 times its background.”
None of these HazMat-high contamination finds are in DTSC’s draft EIR. These omissions are not happenstance or mistakes, and could have very real and negative public health implications.
The draft EIR also fails to mention the serious contamination issues in the Southern Buffer Zone (SBZ) that became known as a result of Boeing’s own sampling and testing. Close to where guided hikes have taken unwary amblers, are springs contaminated with trans-1,2-Dichloroethene, cis-1,2-Dichloroethene, vinyl chloride and trichloroethene (aka trichloroethylene or TCE).
“Nor is there any mention of the alpha and beta radiation burbling out of FDP-881’s spring hard by the side of the hiking road,” we reported. “Alpha radiation, the most dangerous and rare kind, has clocked in at 3.1 times its MCL [Maximum Contaminant Level] while usually-manmade beta radiation topped out at 9.5 times its MCL.”
How does anyone even know what DTSC has left out of this hugely important SSFL EIR save what cleanup activists and reporters can pry out of the department’s Boeing-written word salad? The public are the real losers when these serious omissions of fact are allowed to happen. It means plain and simple that massive amounts of radiation, chemicals, dioxins, furans, PCBs and heavy metals will be left all over the place at SSFL as DTSC tries to portray the cleanup as a threat to what itself calls one of the “most contaminated” sites in California.
Faking the News Media Out of the Facts
If DTSC’s disingenuous and secretive manner of releasing the draft EIR to the press is any indication, the public should expect no help from this CalEPA department now dominated by Boeing ally Gov. Jerry Brown’s appointees. A September 7 press conference call to explain the EIR with DTSC’s Mohsen Nazemi was marred by false information and incomprehensible platitudes that made little sense at all.
Having only just sent the reporters the massive EIR a couple of hours before the call, Nazemi managed to condescend in a manner that implied the journalists present clearly didn’t understand him. Nazemi’s mix of outright falsehoods and incoherent statements left even the most veteran observers of SSFL issues and EIRs scratching their heads.
“We did look at suburban residential use, garden consumption which is the most extensive cleanup activity so the analysis looked at what are the environmental consequences of doing the most extensive cleanup,” Nazemi said to one reporter. “It doesn’t have to look at every single possibility if you analyze the worst case scenario. We have looked at every single possibility as identified as foreseeable use of the site so I think I’ve kind of answered your question twice already.”
If Nazemi did look at suburban residential use, it didn’t make the EIR. And actually not even one “single possibility” was analyzed let alone “every” one. Nazemi, who was appointed by Brown to DTSC in 2016, assumed a defensive posture as he misconstrued a reporter’s question and then angled to insinuate that interrogatories about the EIR were inappropriate. One example was when this reporter asked the most important question of all: “Do you have cleanup assessments for the various risk scenarios for the people to make an informed decision about the cleanup?”
“We have looked at this risk overall relative to the alternatives which we analyzed but if your question is specific as to each area, those risk assessments will be included in the decision document for that specific area when we release that and that will go through public process,” That was Nazemi’s way of admitting that indeed the risk assessments hadn’t been done even though he conceded that the EIR had cost millions of dollars. “And I heard this twice, this is not to answer all your questions when it was released, this is more of an informative call [because] these documents have been released today so we obviously did not think you had read 5,000 pages, just to give you an overview.”
This reporter has written about SSFL since 1998 and not once has there ever been a press conference where the person holding it says “this is not to answer all your questions.” Nevertheless, EnviroReporter.com asked yet another straightforward question: “Why wasn’t there an agricultural analysis since Ventura County has it zoned agricultural?”
“I think I must not be explaining this clearly to the previous question also that we did consider agricultural [unintelligible] however we analyzed what we felt was the most extensive cleanup activity which was related to a resident at the site using backyard gardens for 25% of their total consumption of produce,” Nazemi said. “Agricultural does not have as extensive cleanup because it doesn’t go to the same percent, 100%. It is a more extensive cleanup analysis that was done and we didn’t exclude it but what would be the worst case scenario.”
This is simply word play. Of course by not including an analysis of the most protective standards, they were excluded. Agricultural is the most protective cleanup standard, followed by rural residential, both of which are allowable uses in the Ventura County general plan and zoning which DTSC said it would rely upon in 2010. Yet the most protective standard DTSC says would be considered now is, according to cleanup advocates, nearly 30 times weaker than what DTSC’s own official goals for suburban residences.
Nazemi and DTSC lean on “reasonable foreseeable uses” in justifying their exclusion of protective standards, clearly using Boeing’s talking points. Boeing says that the site will be open space, so only very weak recreational standards should be considered. Community members says that they don’t live in open space, they live in residential areas and the contamination migrates, so it should be cleaned up at least to rural residential. DTSC implies it is considering residential, but has weakened it, and justifies the weakening with “forseeable uses.” Of course, DTSC also absurdly claims that no harmful SSFL contamination gets offsite and that neighboring Brandeis-Bardin was untouched by SSFL toxins, a claim debunked by EnviroReporter.com August 14 in State toxics department white papers over Brandeis-Bardin contamination.
What was doubly puzzling about this natter is that Nazemi said at the top of the call that SSFL was one of the most contaminated sites in the state. Yet the EIR in no uncertain terms says that leaving the goo to degrade is the best option even when years of tests have shown it to not work nearly effectively or fast enough. One reporter asked if the public knows how much contamination would be left up at SSFL.
“It is not just say we’re going to leave contamination on site,” Nazemi said with no trace of irony. “It is actually a monitoring over the years of the attenuation of the contamination on site so it would be hard to make an assumption without having the data when you make that decision depending on what that degradation is at the time of the decision document, then you can determine what the volume of the soil would be but to just second guess or predict something that we don’t have all the information for.”[sic]
What Nazemi means is: ‘Nothing can be predicted so don’t even try to do what every other EIR has ever done and predict therefore the answer is to leave all the contamination in place. Any questions?’
Actually, yes, EnviroReporter.com had just one more: “What was the logic in not putting soil volumes in the EIR?”
“We said it is not in there because this is an environmental impact report,” Nazemi said perhaps thinking no one on the call knew that that is exactly what should be in the EIR. “It is not a document that specifies what the actual [volume] would look like for each area. Again, as I indicated earlier, volume of soil identified or even monitored for attenuation and those are the information that you would make a decision on when you’re issuing your cleanup order and that goes through public process again so I don’t see any, any cutting up of the public evaluation or comments from this document. We want to get all the comments we can on this document and then based on the final EIR then we will receive those sufficient documents which will have information more detail than what we have here.”
More detail? Public comments are somehow going to get the EIR to cough up the real numbers? That would appear to be the notion of someone unclear on the process. Nazemi, however, is quite clear on the goal – confuse, distract, delay and then do nothing. The surrealism of the press conference call continued along this vein before Nazemi finally admitted “We have not done risk assessment for not cleaning up or partial cleanup.”
Governor Brown’s Brownfield Legacy
Government against the people in an environmentally progressive state like California may outrage but it shouldn’t surprise. EnviroReporter.com exposed it in 2012’s Operation Astroturf where, in a letter to the then director of DTSC, 18 community members wrote:
“Boeing has purchased very powerful lobbyists and public relations consultants, including Winston Hickox, Peter Weiner, Bob Hoffman, Charlie Stringer, and Gary Polakovic, several of whom are close to the Governor. We recognize that we represent merely the “little people,” everyday folks who live near this polluted facility, whose families face the risk of cancer and other ailments from the decades during which Boeing and its predecessors have succeeded in avoiding cleanup obligations. Your actions indicate to us that in your eyes we don’t count, that it is only the powerful like Boeing that matter, that you will do what they want you to, no matter who among the unpowerful gets hurt by it.”
Revelations from Santa Monica-based Consumer Watchdog’s 2014 investigation Inside Job went even further showing how California state government pals of Brown used the system to milk it while simultaneously sabotaging the SSFL cleanup.
Ultimate responsibility for this unnatural disaster rests with DTSC’s entire SSFL team led by Mohsen Nazemi, DTSC director Barbara Lee, and Gov. Brown. This will be Governor Jerry Brown’s legacy, ‘Glow in the Dark Park’ left unremediated in the middle of millions of people and at the headwaters of the Los Angeles River. It will be a toxic bequest that will be re-exposed, should need be, when the park gates open and the public and media are allowed in to trod about one of the most contaminated sites in California.