38. Page 31/59: “Regardless, all of DOE’s contamination will be addressed as required under the 2010 Administrative Order on Consent.”
[ER NOTE: TRUE & AJU’S BEST BET – Note the word “all.” That includes Brandeis-Bardin. The report says so on this same page that DOE is responsible for Brandeis-Bardin. So far, despite all of the evidence, AJU maintains that no contamination has spread into its camp and has already used DTSC’s ‘white paper’ as proof, even as EnviroReporter.com‘s analysis finds seven pillars of prevarication that preclude it from even being taken seriously scientifically. The evidence is included all throughout this document.]
39. Page 32/59: “Table 4 – Summary of Soil and Sediment Sample Results Exceeding DTSC
Look-up Table Values for Drainages from Area IV onto Brandeis Bardin Property”
[ER NOTE: WRONG STANDARDS, AGAIN – What DTSC doesn’t say in this list of chemicals in the Northern Buffer Zone that are compared with the inflated RBSLs is that the NBZ is required to be cleaned up to background. The table is a meaningless way of minimizing the very real contamination in the NBZ which drains into the camp below. This is another way DTSC obscures how Brandeis-Bardin, if it were even ever to be cleaned up, would in no way have as comprehensive and effective remediation as Area IV and much of SSFL.]
40. Page 37/59: “Surface water discharged from SSFL is monitored and treated to standards that are generally cleaner than drinking water standards.”
[ER NOTE: FALSE – SSFL’s runoff is not canteen-ready by any stretch of the imagination, despite this false statement saying you can drink it. “Since 2002 Boeing has been fined over $1.2 million for the violation of pollution discharge limits at the Santa Susana Field Laboratory,” said the Rocketdyne Cleanup Coalition in 2016. “These fines were implemented as an attempt supposedly to force Boeing to take effective action at stopping the ongoing pollution violations at the site, but these fines have been unsuccessful in doing so.”
Also, as has been demonstrated in 4D, fluoride and manganese are in Brandeis-Bardin waters at levels exceeding their respective MCLs and nothing is being done about it, let alone acknowledging it.]
41. Page 37/59: “NASA’s report shows no contamination from NASA operations extending into Brandeis Bardin (Figure 3.0-1).”
[ER NOTE: TRUE AND FALSE – Yes, that report shows no contamination. NASA’s 2015 report is what DTSC is sourcing not the NASA 2016 report DTSC sent to EnviroReporter.com November 30, 2016 but apparently forgot about in preparing the 2017 Brandeis-Bardin white paper. “Fluoride was detected above the SSFL comparison level of 0.8 mg/L [milligrams per liter] at RD-68B and SP-29B at concentrations of 0.97 mg/L and 4.8 mg/L, respectively,” the report says.
“Artesian well SP-29B’s 4.8 milligrams/liter of water more than doubles California’s MCL for the chemical,” we reported in Brandeis-Bardin’s Toxic Denial a month before the DTSC Brandeis-Bardin ‘white paper’ release. “A reading of 4.2 mg/L in the same well in the 1st Quarter shows that the toxic level of fluoride in Brandeis-Bardin water has increased.”]
42. Page 40/59: “Combining these issues with the other above considerations (e.g., variable uptake of perchlorate observed in plants at Brandeis Bardin, ambient levels of perchlorate identified in milk from grocery stores and municipal water supply, potential past site use, etc.) it is conceivable that this variability is naturally occurring.
“The 2007 findings (laboratory report not available) indicate that the Brandeis Bardin soils were within background range.”
[ER NOTE: FALSE & FALSE – This section on Brandeis-Bardin perchlorate was preceded by “Even though no analytical report for the highest reported perchlorate value in milk (14.9 ppb) was available…” Yet even with data lacking, and the fact that the camp sits in the shadow of SSFL which conducted tens of thousands of rocket tests over decades burning tons of perchlorate, DTSC ventures that it could be “naturally occurring.” Not only is this preposterous on the face of it, it contradicts what Brandeis-Bardin’s own environmental adviser Joel Cehn had to say about this milk finding in the 2007 report’s findings: “The only significant finding this year is the perchlorate detected in milk and vegetation,” Cehn wrote. “[Milk] result indicates that area cows are grazing on grass containing perchlorate.”
That DTSC would think no one would know what Cehn said shows that the department is confident that it can make these false determinations without fear of contradiction or punishment from higher-ups in California EPA. The last sentence too is false on the face of it. The kind of perchlorate found in the milk is the same kind used up at SSFL for decades. There is no “background range” in the sense that there should be no perchlorate in Brandeis-Bardin soils, let alone in its cattle, milk and vegetables. Hence this sentence at the bottom of the page is false: “Vegetation showed low levels of perchlorate that were found to be within background levels.”]
43. Pages 43-45/59: “At the time this technical memorandum was being finalized in late March 2017, DTSC was provided with the most recent “2017 Testing Results” (Cehn, March 27, 2017). The report summarizes results of sediment and surface water samples collected within four ravines located near the Brandies Bardin/SSFL property boundary, as well as sampling results from three springs located on the Brandeis Bardin property.”
[ER NOTE: Cehn’s 2017 report, as well as all of the Cehn reports AJU posted on their website, are analyzed in the EnviroReporter.com page 1991-2017 Brandeis-Bardin Reports Analysis.]
44. Page 44/59: “The presence of low levels of perchlorate detected in crops and attributed to ambient sources is also consistent, in that extensive investigations completed to date have delineated the extent of perchlorate impacts on the SSFL property, and are not expected to impact the Brandeis Bardin Campus or its garden locations.”
[ER NOTE: FALSE AND TRUE AND MAYBE – Attributing perchlorate in Brandeis-Bardin to “ambient sources” is false. It comes from SSFL. Indeed, perchlorate from the lab has gone past the camp where “perchlorate has been found in 18 wells in Simi Valley. The highest reading was 19.2 ppb” according to this reporter’s 2002 VC Reporter cover story Rocketdyne Ranch.
“[T]here have been 17 detections of the chemical in Simi Valley groundwater, with the highest hitting 19.6 ppb,” the paper reported in 2004’s Perchlorate’s Pregnant Pause. “Elsewhere in East County, groundwater from Well #1 adjacent to Ahmanson Ranch tested at 28 ppb, the Brandeis-Bardin Bathtub Well #1 tested at 140 and 150 ppb, and the heavily polluted Rocketdyne field laboratory has registered a whopping 48,000 ppb in near-surface water.”
Wishing away perchlorate’s origins as “ambient sources” is further used by DTSC to opine that the rocket fuel oxidizer, which is especially dangerous to children and pregnant women, is “not expected to impact the Brandeis Bardin Campus or its garden locations.” Yet it already has according to years of data some of which is in this ‘white paper’.]
45. Page 45/59: “Preventing potential migration of existing SSFL contaminants from SSFL to Brandeis Bardin during heavy rains”
[ER NOTE: FALSE AND MISLEADING – DTSC wrote this suggestive paragraph title then proceeds to admit it that discharges do go into Brandeis-Bardin after being sluiced through a series of “engineered stormwater runoff controls.” Then, in perhaps the most ironic DTSC passage in the ‘white paper’, the department says “The contamination on SSFL must be removed, and the anticipated cleanup activities will remove the long-term potential for off-site migration of SSFL contaminants.”
This is the same DTSC that has fought its own cleanup now since at least 2012 as reported in Boeing’s Meltdown Makeover and 2014’s China Syndrome Town. It is perhaps fitting that the department floats this just before it reaches its Conclusions section.
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