EnviroReporter.com Findings Summary
- DTSC ignores government reports indicating Brandeis-Bardin contaminants
- Documents claim no threat based on cherry-picked reports
- DTSC claims contaminants “do not pose a threat to human health” when data differs
- Data released by DTSC itself contradicts assertion no toxin migration from SSFL to camp
- Department employs toxin standards for Brandeis-Bardin that are weaker than Area IV cleanup
- Strontium-90 standard for camp 42 times higher than DOE cleanup level for Area IV
- DTSC uses weaker standards to assert harmless levels of radiation & chemicals
- ‘White paper’ falsely claims all chemicals at camp are at background levels
- Toxic department misrepresents US EPA Area IV study to claim camp clean
- Paper discounts high hits of contamination as lab mistakes
- DTSC claims chemicals in Brandeis-Bardin “may not be from SSFL sources.”
- Suggests rocket fuel additive perchlorate in camp plants is conceivably natural
DTSC DOCUMENT ONE:
“Executive Summary of Technical Memo on the Brandeis Bardin Campus”
7 page PDF
1. Page 1/7: Title of Executive Summary page link itself shows this document summary is dated “March 2017” and summarizes Technical Memorandum, meaning that the longer document is dated no later than March 2017 as well. DTSC’s Brandeis-Bardin information was released to the public May 2, 2017.
[ER NOTE: EnviroReporter.com‘s Brandeis-Bardin’s Toxic Denial exposé and investigation was published online April 6, 2017. Our investigation included data from 2015, 2016 and 2017 government reports detailing contamination finds in the Brandeis-Bardin Campus (BBC or BBI), two reports of which DTSC had actually sent EnviroReporter.com. DTSC had a whole month to amend this error-ridden report by including this information, which EnviroReporter.com analyzed making it easy to understand, but chose not to. The person whose name is on this report is DTSC’s project manager for SSFL, Mark Malinowski. Malinowski, Ray Leclerc and other DTSC personnel are responsible for this ‘white paper’.]
2. Page 1/7: Second sentence – “The SSFL property will require soil cleanup for chemical and radiological contaminants.”
[ER NOTE: Since government-responsible soils are “required” to be clean up, and the cleanup is to background, shouldn’t Brandeis-Bardin soil over background be cleaned up to background as well if shown a result of SSFL activities, specifically NASA and Department of Energy (DOE) activities?]
3. Page 1/7: “Levels of radionuclides on the BBI campus appear to be within the natural background range”
[ER NOTE: FALSE –
3A) 1993 and 1995 Rocketdyne reports showing Sr-90 over background in 19 separate soil samples. The 1995 report showed that tests at BB-03 in 1994 found both Cs-137 and Sr-90 that would be substantially over background values derived by the EPA in 2011 and published in 2012. A cesium-137 (Cs-137) sample radiated 65.9 percent over its background.
3B) 2004 STL Richland soil report found Pu-239/240, Ur-238 at levels higher than highest in Area IV, beta at 2.18 times UC Berkeley-derived background and alpha radiation in the camp’s 2004 sludge also came in at over two times the median average according to a U.C. Berkeley nuclear expert’s “range of gross alpha.”
3C) 2005 STL Richland water report completed in 2006 found Sr-90 over double both the Los Angeles and national averages and Pu-239/240 at nearly half as high as the highest Pu-239/240 pulled and tested in Area IV groundwater by the EPA. Also found radioactive tritium at double background, though it should be zero in groundwater, as was beta radiation compared to the national average.
3D) Jan 20, 2016 DOE report sent showing trio of BBI wells all the much further down at Meier Canyon level that show Area IV nuclear fingerprints. That report stated that several Brandeis-Bardin wells close to Meier Canyon were recommended for future sampling because “Cadmium-113m neutron activation of Cadmium-112 used in reactor control rods – possibly site process related” was found in a well. Nor does DTSC divulge that DOE reported on another well in the same area that had the radionuclide tin-126 and that “Tin-126 is a fission product and is possibly site process related.” This crucial information proves beyond a shadow of a doubt that SSFL radiation has migrated down into Brandeis-Bardin groundwater.
3E) May 2016 American Jewish University (AJU) claim of “extensive” testing. Study took only 14 samples out of Brandeis’ 2,878 acres. Even so, one of those 14 samples found strontium-90 at two and half times local background.]
4. Page 1/7: “Levels of chemicals and radionuclides at the BBI campus do not pose a threat to human health”
[ER NOTE: FALSE –
4A) November 2016 NASA report shows levels of fluoride in Brandeis-Bardin artesian well SP-29B that exceed California Maximum Contaminant Level (MCL) for it in drinking water. Artesian well SP-29B’s 4.8 milligrams/liter of water more than doubles California’s MCL for the chemical. 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 increased over that period.
4B) 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.
4C) The DOE report given to American Jewish University, owner of Brandeis-Bardin, then Jewish Journal which published it December 7, 2016 showed a list of Brandeis-Bardin contaminants found above Area IV background levels with their exact Brandeis-Bardin measurements by multiple times.]
5. Page 2/7: “None of the recent data reviewed as part of this evaluation have indicated a need to initiate immediate response actions for the BBI areas or for the Northern Buffer Zone.”
[ER NOTE: TRUE – This is true because DTSC chose not to look at all of the data, even this crucial report it sent to EnviroReporter.com November 30, 2016: “DTSC-SSFL Document Upload Notification: SSFL NASA Area I LOX and Area II Groundwater Monitoring Report Third Quarter 2016” with a link to the report [1,180 PDF pages; 17.3 MB]. This report is the same one cited in ER NOTE 3 that shows fluoride repeatedly exceeding its MCL which, by law, requires an immediate response.]
6. Page 2/7: “Over the last 25 years, multiple sampling efforts have been conducted on both BBI and SSFL properties. After review and analysis of the data from those sampling efforts related to potential impacts to BBI campus, the results are all generally around or within natural background range and there is no indication of a grouping or pattern that would indicate a contaminant release on BBI’s current property.”
[ER NOTE: FALSE –
6A) This gives the impression that all the data and sampling efforts done in the last 25 years were looked at clearly when they were not as DTSC’s limited “Resources” reports shows.
6B) Results were available, and ignored, like the DOE toxic chemicals report given to AJU which sent it to the Jewish Journal which published it and was subsequently analyzed by EnviroReporter.com in 2016 DOE-AJU Summary Brandeis-Bardin Soils. That analysis of the toxins, based on DOE’s sampling results and EPA-derived Background Threshold Values (BTVs), showed:
ANTIMONY – 3.0 x BTV
NAPHTHALENE – 5.4 x BTV
FLUORENE – 5.7 x BTV
ENDOSULFAN I – 8.6 x BTV
FLUORANTHENE – 2.4 x BTV
PHENANTHRENE – 6.9 x BTV
PYRENE – 2.4 x BTV
DIELDRIN – 3.1 x BTV
GAMMA BHC (Lindane) – 4.7 x BTV
MOLYBDENUM – 5.8 x BTV
BETA-HEXACHLOROCYCLOHEXANE – 7.7 x BTV
HEPTACHLOR – 3.8 x BTV
2,4,5-TP – 2.1 x BTV
2,4,5-T – 2.4 x BTV
MCPP (Mecoprop) – 4.6 x BTV
DELTA BHC – 4.5 x BTV
FLUORENE – 3.1 times its BTV
6C) DTSC’s wholly false claim that “there is no indication of a grouping or pattern that would indicate a contaminant release on BBI’s current property” is disproven by maps and figures the department itself, as well as the DOE, has released such as this 2015 DTSC map showing contamination in Brandeis-Bardin drainages. For DTSC to make such a boldly false claim goes beyond incompetence and bad science as this analysis has already shown in just the executive summary alone. Regardless, to go through this “super-sized word salad” as it was described in the Simi Valley Acorn, is necessary to not only prove what we publish but for EnviroReporter.com to fully understand the depth of deception going on here, deception used to trumpet that the DTSC’s Brandeis-Bardin conclusions have sounded the all-clear.]
7. Page 2/7: “Typically, preliminary remediation goals (PRGs) are risk-based screening values used to identify areas and contaminants that may warrant further investigation or assessment. The US EPA has a tool called the PRG calculator that allows for development of site screening PRGs. The US EPA PRG website (https://epaprgs.ornl.gov/radionuclides/faq.html) includes several frequently asked questions (FAQs) that relate to the use of PRG values.”
[ER NOTE: BAIT & SWITCH – NASA and DOE agreed to clean up to background up at SSFL for both chemicals and radiation. This also means remediate to background anything they caused offsite that is obviously from SSFL, as EnviroReporter.com has shown to be the case in Brandeis-Bardin’s Toxic Denial. So to introduce, and mangle the science of, another system to assess contaminants at the camp is not only wrong – all detections should be measured against and cleaned up to its BTV value – it insures SSFL is cleaned up and Brandeis-Bardin isn’t.
Why are the Jewish camp’s accepted levels of SSFL radiological and chemical contamination suggested in this DTSC white paper many times those that the DTSC is required to have NASA and DOE clean up to at the lab? Has AJU signed off on this white paper concept that levels of SSFL toxins on its Brandeis-Bardin property are going to be markedly higher than those at SSFL after the cleanup to background there? Yes it has, as it has taken to using the document to dismiss all evidence of toxic impacts on its property along with its own reports, as EnviroReporter.com exposed in 1991-2017 Brandeis-Bardin Reports Analysis.
EnviroReporter.com‘s doesn’t analyze this bait and switch in the white paper where use of PRGs in all sorts of confusing scenarios is designed to do just that, confuse the reader and the rare reporter that dares look at this material in the first place. Simply put, DTSC switches standards instead of sticking to BTVs which has already been agreed upon. SSFL gets cleaned up and BBI gets ziltsh.]
8. Page 3/7: “Over the past 25 years, sample results from multiple radiological and chemical investigations on what is now BBI property have found results that are similar to local background, and no groupings or patterns have been identified that indicate a release of contamination from SSFL. The levels found pose no unacceptable health risk to people who use the current BBI campus.”
[ER NOTE: FALSE – See 6A, 6B & 6C]
9. Page 4/7: “Sample results within the SSFL Northern Buffer Zone showed most of the data does not differ from local background conditions (e.g., are naturally occurring). The results on the BBI property also showed no grouping or pattern for the limited number of samples that exceeded local background levels.”
[ER NOTE: FALSE – See 6A, 6B & 6C]
10. Page 4/7: “Together, results from the BBI and SSFL studies support the conclusion that the overall distribution of radionuclides remains on SSFL and has not migrated offsite onto BBI. Additional, more recent sampling results also confirm this.”
[ER NOTE: TRUE & FALSE – True: See 5 because the studies DTSC looked at didn’t include the ones with the recent and revealing data as exposed by EnviroReporter.com. False because the notion that no contamination got offsite is disproved repeatedly in “Brandeis-Bardin’s Toxic Denial.” One example of this is the report DTSC didn’t include in this ‘white paper’ DTSC itself sent to EnviroReporter.com in January 2016.
The 239 page study for the DOE was called “Department of Energy (DOE) RCRA Facility Investigation Groundwater Work Plan Portions of Area IV under DOE Responsibility.”
A trio of Brandeis-Bardin wells called RD-59A, RD-59B and RD-59C yielded some shocking results with Area IV’s nuclear contamination fingerprints. RD-59A, monitored from 1989 to 2011, was recorded as having a filtered reading of Cadmium-113m of 9,700 picocuries per liter (pCi/L). The well was subsequently recommended for future sampling because “Cadmium-113m neutron activation of Cadmium-112 used in reactor control rods – possibly site process related.” [Report emphasis] That means it migrated from Area IV of the Santa Susana Field Laboratory down into Brandeis-Bardin obliterating the ‘it didn’t get offsite’ misinformation. EnviroReporter.com is frankly amazed that this information wasn’t censored from the report.
RD-59B also directly tied Area IV’s radiation contamination spreading offsite in Brandeis-Bardin’s groundwater. The well tested positive for radioactive Tin-126 as noted earlier but bears repeating in this technical page. The DOE report advocated continued testing of this well too. “Tin-126 is a fission product and is possibly site process related.” [Report emphasis] Again, this goo came from Area IV according to the Department of Energy which is responsible for its cleanup should AJU emerge from its toxic denial.]
11. Page 4/7: “In 2016, American Jewish University retained an independent, third party contractor to evaluate environmental conditions at the BBI campus. Based on review of prior studies, the 2016 Brandeis Study concluded that to date, no study has ever found harmful levels of radiation or chemical contamination on the BBI campus.”
[ER NOTE: FALSE – See 3C, 3D, 3E, 4A, 6B & 10]
12. Page 5/7: “To determine the PRG for the BBI property, DTSC considered what contamination concentrations would pose a risk to people living on the property for 26 years (six as a child and 20 additional years after that) 24 hours a day, 350 days out of the years. In other words, DTSC used a health protective residential scenario that provided for much more potential exposure than the limited amount of time that visitors, campers, students, faculty and staff use the facility.”
[ER NOTE: IRRELEVANT BAIT AND SWITCH – By coming up with confusing and mysterious numbers for Cs-137 and Sr-90’s PRGs, DTSC obscures the fact that it has deviated from the simpler cleanup up to background stratagem like the agreement for remediation of NASA and DOE’s contamination on and off the SSFL site. As will be seen immediately following, this bad science makes sure Brandeis-Bardin is on the losing end of the cleanup equation because it either won’t get any or any remediation done will allow vastly more amounts of goo than background levels.]
13. Page 5/7: “DTSC calculated the PRG for Sr-90 soil to be 3.12 pCi/g.”
[ER NOTE: HUGE INCREASE IN Sr-90 LIMIT – Through a series of calculations, DTSC came up with PRGs for cesium-137 and strontium-90 and made these PRGs the ‘goal’ much like BTVs are the goal in the DOE and NASA clean ups next door in SSFL. However, that’s where the similarity ends. While the Cs-137 PRG is nearly equivalent to its BTV, the Sr-90 PRG is over 42 times its BTV.
How could that be? It’s simple math. DTSC’s PRG for Strontium-90 in Brandeis-Bardin soil is 3.12 pCi/g. The Sr-90 BTV from the EPA’s October 2011 report, on page 282 of its 286-page PDF, is 7.35E-02 pCi/g = 0.0735 pCi/g.
Therefore the DTSC Sr-90 PRG for Brandeis-Bardin is 42.6 times the EPA’s BTV for SSFL. According to the very same DTSC, it is required to remediate Area IV’s Sr-90 hotspots to background but the goal for the same deadly, manmade radioisotope at the Jewish camp is 43 times higher. Why does it matter to human health? What is known is that no amount of low-level radiation exposure is safe. In late July 2005, the prestigious National Academy of Sciences came out with a milestone report that confirmed this. “The scientific research base shows that there is no threshold of exposure below which low levels of ionized radiation can be demonstrated to be harmless or beneficial,” said Richard R. Monson, the panel chairman and a professor of epidemiology at Harvard’s School of Public Health.
In addition, the highest reading of Sr-90 found by AJU’s contractor Tetra Tech was 2.45 times its Area IV BTV. What is particularly astonishing, statistically and policy-wise, is that this high strontium-90 detection was pulled from the scant 14 samples Tetra Tech took. Yet that alarming reading rang no bells with AJU and DTSC and the reading was dismissed using the bloated PRG with this statement: “The single low-level Sr-90 soil detection (0.18 pCi/g) is below the 3.12 pCi/g residential PRG.”
13A. Page 6/7: “Based on both monitoring results and analysis of the extensive chemical sampling conducted at BBI, DTSC concludes that the low concentrations of chemicals found in drainage channels on the Brandeis Bardin property, likely represent natural background.”
[ER NOTE: FALSE – See 3C, 3D, 3E, 4A, 6B & 10]
14. Page 6/7: “The US EPA results indicate that SSFL related radionuclide contaminants are not migrating off the SSFL site. US EPA’s comprehensive radionuclide study supports DTSC’s findings that people at the BBI property are not expected to be at risk from exposure to radionuclides from Area IV.”
[ER NOTE: FALSE – The US EPA report didn’t indicate whether “radionuclide contaminants are not migrating off the SSFL site” one way or the other. US EPA also never claims whether people will be at risk or not at a site with contaminants so saying it signed off on Brandeis-Bardin is false, so DTSC, with no basis whatsoever, makes this misleading claim. Also note use of the word “expected” making the statement completely useless. DTSC can’t actually say “people at the BBI property will not be at risk from exposure to radionuclides from Area IV” because the department has no proof that this is so. Indeed, US EPA told DTSC in no uncertain terms that a representation to that effect in EPA’s name is not true. In this ‘white paper’ DTSC has again boldly lied that US EPA said Brandeis-Bardin is safe. That alone disqualifies this ‘white paper’ from serious consideration. That said, EnviroReporter.com will continue this analysis because it is necessary and contains more astonishing revelations. No other media has done this in-depth analysis which is precisely what DTSC probably counts on.]
14A. Page 6/7: “Based on analysis of the extensive off-site chemical sampling and monitoring results, DTSC concludes that in almost all cases, the results are within the range of local background.”
[ER NOTE: FALSE – See 3C, 3D, 3E, 4A, 6B & 10]
DTSC DOCUMENT TWO:
“SSFL Community Fact Sheet on the Brandeis-Bardin Campus”
2 page PDF
15. Page 1/2: “U.S. EPA 2012 sample results confirmed that contamination from SSFL is controlled at the Northern Buffer Zone and is not entering the Brandeis Bardin property.”
[ER NOTE: FALSE – See 3C, 3D, 3E, 4A, 6B, 10 & 14]
16. Page 2/2: “Cleanup actions done between 2009 and 2013 removed contaminated sediments from the SSFL drainages upstream of the Brandeis Bardin property.”
[ER NOTE: TRUE BUT MISLEADING – More contaminants have been found since 2013. As Brandeis-Bardin’s Toxic Denial details, a November 2015 DOE report found radiation in camp wells identified as isotopes that are “fission products” and “used in reactor control rods.” A November 2016 NASA report shows Brandeis-Bardin groundwater/wells chemical contamination exceeding state standards for this ‘blue stream’ drinking water source. And a December 2016 DOE report given by AJU to the Jewish Journal shows elevated Brandeis-Bardin soil toxins. Note that these three government tests were ignored by the Community Update and DTSC’s white paper, examined below in DTSC DOCUMENT THREE.
This is DTSC’s first pillar of prevarication in the ‘white paper’: Cherry-picking old reports and questionable studies while ignoring new government data that spells out Brandeis-Bardin’s impacts from SSFL toxins quite clearly.]
17. Page 2/2: “Surface water discharge requirements are very strict. In general, they are stricter than drinking water requirements. Even if exceedances of a surface water discharge standards were detected, this would not necessarily equate to a threat to human health.”
[ER NOTE: TRUE BUT MISLEADING – Literally true but an effective sleight of hand. The first sentence refers to standards, not the contaminants themselves detected coming off The Hill, as the former Rocketdyne site is sometimes called. The second sentence is devious but nevertheless doesn’t claim that SSFL discharges into Brandeis-Bardin aren’t a threat to human health. That DTSC has authored this deceptive bad science shows that the toxic department is better at concocting confusing community updates than it is doing its job protecting the public.]
18. Page 2/2: “DTSC will continue to monitor, review and evaluate information concerning SSFL and adjacent property.”
[ER NOTE: TRUE & FALSE – Of course DTSC will continue to do this, so it’s true. How else will it know what to cherry pick and what to ignore? It is false in that many of the government reports EnviroReporter.com has sourced are being brushed off by the department as if they didn’t exist.]
DTSC DOCUMENT THREE:
“Review of Radiological and Chemical Data from Investigations Conducted at and Near the Santa Susana Field Laboratory and the American Jewish University • Brandeis Bardin Campus”
“Technical Memo on the Brandeis Bardin Campus”
59 page PDF
19. Page 1/59: “The California Department of Toxic Substances Control (DTSC) Geological Services Branch (GSB) reviewed available chemical and radiological data from investigations conducted to date at and near the Santa Susana Field Laboratory (SSFL), to identify whether contamination from SSFL extends off-site to the nearby American Jewish University (AJU) – Brandeis Bardin Campus (Brandeis Bardin).”
[ER NOTE: INCOMPLETE – Note that DTSC “reviewed available chemical and radiological data” implying it reviewed all available data when it clearly did not as noted in 16. The next sentence says it a different way saying DTSC “reviewed date from a large number of investigations” which, again, doesn’t mean all investigations. Do note that two of the investigations EnviroReporter.com used in the production of Brandeis-Bardin’s Toxic Denial were sent by DTSC to us yet somehow the department didn’t “review” them. Incompetence? No, these people aren’t stupid. It was deliberate not to include the damning documents. The list of the documents used, at the bottom of page 1 and the top of page 2, shows the lack of government reports that do indeed show SSFL contamination impacting Brandeis-Bardin. Some of the most pertinent government reports were organized by EnviroReporter.com along with other pertinent documents.]
20. Pages 5-7/59: See report for large body of text analyzed below.
[ER NOTE: Large body of text under the heading “Derivation of Field Action Levels.” This section was reported by the Simi Valley Acorn newspaper as being described as a “super-sized word salad” that we do not reprint here other than to note that FAL means Field Action Levels. That doesn’t mean EnviroReporter.com hasn’t analyzed DTSC’s mangling of BTVs which, simply put, has allowed vastly higher levels of radiation and chemicals to be allowed as acceptable through the use of these FALs instead of BTVs.
Obliterating the BTVs of radiation and chemicals through high FALs is not the first time DTSC has re-written science to get away from assessments based on background levels of goo. It was done in 2012, as reported in Radiation Readings Soar at Rocketdyne, where the department fiddled about with “Radiation Trigger Levels” (RTLs) making them vastly higher than their respective BTVs:
“The RTL given cesium-137 in the PowerPoint was nearly equal to the actual background level of Cs-137 at Rocketdyne on the surface. Dig a little deeper, literally, and the the Cs-137 RTL becomes 25.78 times its “background threshold value” or BTV.”
Corrupting the numbers wasn’t limited to cesium-137. Strontium-90 was also given the DTSC treatment as the article exposed:
“Soil sample #60200 inexplicably had a strontium-90 RTL over 37 times its BTV. The dirt came in at over 71 times background radiation in a sample dug out a foot to two feet below the surface. This suggests that even after two “cleanups” the area may be facing a huge excavation job in order to bring the environment back to a state where it isn’t riddled with radiation and chemical contamination.”
In 2017, DTSC’s manipulation of the FALs, in essence codifying contamination markedly over background but passed off as ‘okay,’ is the second pillar of prevarication in the department’s bad science: Change the standards making them vastly weaker and making the amount of contamination deemed okay vastly higher.
The use of the inflated FAL values skews the whole report. DTSC observations and conclusions based on the FALS are skewed as well. The use of these phony FAL’s is DTSC’s third pillar of prevarication: Use the skewed standards to make false conclusions.
21. Pages 7/59: “The few FAL exceedances, and therefore few locations of exceedances for Pu-239/240 and the remaining radionuclides of interest, were observed in the Area IV Study Area.”
[ER NOTE: INCOMPLETE – As reported in “Brandeis-Bardin’s Toxic Denial,” a 2004 soil sampling in Brandeis-Bardin found Pu-239/240 in camp dirt even higher than in SSFL’s nuclear Area IV.]
22. Page 8/59: “Based on evaluation of US EPA’s data from their on-site study, the extent of impacts from releases at source areas have been delineated within the SSFL boundary for the air dispersion pathway. The off-site data from the 1992-1994 Multi-Media and 2016 Brandeis Bardin Studies are consistent with this finding.”
[ER NOTE: FALSE & DISINGENUOUS – The first sentence says that based on EPA’s 2012 onsite study of nuclear Area IV dirt, DTSC’s determines that no radioactive or chemically-infused gas and dust got offsite. That is false on the face of it. It also doesn’t explain what kind of barrier in the air prevented airborne contaminants from drifting over and landing on Brandeis-Bardin. Yet the sentence is written so obliquely that this double-fib is easy to miss. A closer look reveals just how ridiculous this wishful thinking is.
Adjacent Area IV’s border, in the highlands above Brandeis-Bardin, exists the infamous Sodium Burn Pit euphemistically called by the government the “Former Sodium Disposal Facility” (FSDF). The burn pit drains into Brandeis-Bardin’s southern reaches of Meier Canyon which, when running, flows through the center of the Jewish camp.
“In the old days, Rocketdyne workers would chuck barrels of sodium into two water-filled pools and fire guns at the containers to burn off wastes (sodium mixed with water ignites spontaneously),” we wrote for LA Weekly in a 1999 article called Toxic Spring. “Left behind in the process were PCBs, dioxin, mercury, the rocket fuel oxidizer perchlorate and radioactive contagions, according to DTSC.”
The Area IV employees who set the sodium burn pit alight with gun shots were not stupid people. They located the pit next to the lab’s border with the camp as far removed from the main area of Area IV and naturally waited for the winds to carry the poisonous smoke offsite.
An EnviroReporter.com-acquired photograph showing a FSDF burn with Brandeis-Bardin in the background shows this. The fire truck in the foreground provides scale revealing that radioactive plume is hundreds of feet high. No visible or invisible wall exists in the archival image suggesting that the toxic smoke was somehow stopped at the border with Brandeis-Bardin.
“At the core of the DTSC paper is the claim that models – which are in fact, Boeing models – predict that no airborne contamination (e.g., from open air burning of toxic materials or from plumes from rocket engine tests) can travel more than a few hundred feet,” says the SSFL Work Group in its examination of the DTSC ‘white paper’. “It is a ridiculous claim. The UCLA Cohen study utilized a whole team of air dispersion modelers who did very extensive work showing the plumes could travel miles with contaminants at levels above EPA levels of concern.”
Airborne radioactive goo blowing over Brandeis-Bardin wasn’t the only threat to the camp’s land, water, livestock and people. Upwards of over 30,000 rocket engine tests took place at SSFL over the decades releasing tons of chemically-contaminated smoke, gases and dust.
One such ignition at the Coca test stand complex produced huge amounts of toxic smoke belching into the night sky. Coca lies less than a mile from Brandeis-Bardin. This photo alone illustrates how preposterous it is for DTSC to claim that SSFL releases confined themselves to the lab proper. It is more than wishful thinking. It is deliberate deceit further evidenced by the obtuse wording dressed up in scientific jargon.
23. Page 9/59: “US EPA’s data indicate that contaminants related to the Radiological Areas of Interest did not migrate off site.”
[ER NOTE: FALSE – The US EPA report did no such thing. It was an onsite report, not offsite. DTSC uses the word “indicate” about this report that didn’t even test Brandeis-Bardin for radiation and chemical contamination. Furthermore, DTSC deliberately left out more current DOE data that shows that Area IV contamination has indeed migrated onto Brandeis-Bardin property as noted in 3D and 10. This greenwashing DTSC ‘white paper’ cites the wrong report to make a major erroneous claim and excludes the recent DOE data that shows just the opposite.]
24. Page 10/59: “[P]eople at Brandeis Bardin are not expected to be at risk from exposure to radionuclides from Area IV.”
[ER NOTE: MEANINGLESS YET REVEALING – “Not expected” by whom exactly? DTSC? AJU? This statement doesn’t say people are not at risk with certainty. The wording here, and throughout the ‘white paper’ seems polished by an attorney in its obliqueness.]
25. Page 12/59: “In other words, while the FAL exceedances represent ·results that may be detected, we cannot accept that the data were adequately quantified at a level that we can compare to a regulatory threshold and make a decision of exceedance. We have less tolerance for analytical uncertainty when making such decisions.”
[ER NOTE: DISQUALIFYING EXCEEDANCES – This truly amazing statement says, basically, that any exceedance isn’t valid. Then it claims it has less tolerance for analytical uncertainty but only when the hits are higher than the already skewed FALs. This is a fourth pillar of prevarication: Anything registering hot has to be a false measurement.]
26. Pages 12/59: “Based on this and other lines of evidence, the US EPA results do not indicate contaminant migration off-site from the NBZ [Northern Buffer Zone].”
[ER NOTE: FALSE ASSUMPTION LEADING TO FALSE CONCLUSION – Carefully crafting super-sized word salads justifying phony conclusions has reached a peak here. The only problem is that it isn’t true as was clearly shown in government reports ignored by DTSC as well as EnviroReporter.com‘s 13-year-long Brandeis-Bardin investigation.]
27. Pages 13/59: “To be protective, the potential false positive can be compared to a risk-based screening level in order to evaluate whether it warrants additional attention.
“Risk-based screening levels (RBSLs) can be useful for simple comparison, but they were not originally intended for use with point-by-point comparisons. RBSLs are not cleanup standards and should not be applied as such. They can be used to help identify areas, contaminants, and conditions, which may require further attention; however, just because a sample exceeds a risk based screening level does not automatically designate a site as contaminated.”
[ER NOTE: KNOWINGLY USING WRONG METHOD – DTSC introduces its fifth pillar of prevarication: Introducing another admittedly wrong set of standards to rejigger those pesky high hits of radiation and chemicals.
The department pulled this bait and switch bad science at an April 12, 2016 public meeting explaining away elevated hits of strontium-90 snaking their way down a drainage from Area IV through the NBZ and into Brandeis-Bardin. DTSC said that the hits were under the RBSL of 3.85 picocuries per gram (pCi/g) for Sr-90 when that is hundreds of times less protective than the current EPA Residential Preliminary Remediation Goal of 0.00121 pCi/g. In fact, DTSC’s false RBSL standard was 3,182 times higher (less protective) than Sr-90’s BTV.]
28. Pages 15-16/59: “Single point exceedances of Cs-137 and Sr-90 (not co-located) were identified in 1992 at Campsite 1, and a single point exceedance of Sr-90 was identified in the Campsite 1 Drainage during the 1994 sampling.”
[ER NOTE: TRUE, BUT… – That “single point exceedance,” a nifty way of implying an abnormal reading when it was actually the only reading for Cs-137 which was a significant 0.38 pCi/g making this “exceedance” 96.9 percent higher than background. Under the Agreements on Consent (AOCs) with NASA and DOE, DTSC requires cleanup of radiation and chemicals to background but at Brandeis-Bardin, no such cleanup is in the offing.
But, much more importantly, DTSC didn’t inspect this “Campsite 1” area that EnviroReporter.com determined might very well be in the immediate area of the gushing goo it verified and authenticated as gurgling away in 2004, 2005, 2006, 2007 and 2014 as seen in this YouTube video called Sludge from Rocketdyne. Yet somehow DTSC and AJU have managed to miss this spot in all their reports trumpeting that SSFL goo hasn’t impacted Brandeis-Bardin. Perhaps some of the hundreds of kids staying at Camp Alonim this summer will amble up Meier Canyon and find this spot and take a few photos or videos they would like to share with us.
EnviroReporter.com didn’t miss this hard-to-miss spot’s suspect looking soil’s test results from 2004. As reported in “Brandeis-Bardin’s Toxic Denial”: “The peak 2004 Pu-239/240 sample exceeded its BTV by 55.2 percent. This extremely toxic, cancer-causing radioisotope produced during a nuclear reaction was precisely 21.6 percent higher than the “Maximum Value Detected” (MDV) for the radionuclide found in Area IV in the EPA’s October 2011 Final Radiological Background Study Report – SSFL [PDF page 282/286; 16.5 MB].”
The water next to Campsite I was also worrisome as reported. Sr-90 measured over double both the Los Angeles and national averages and beta radiation came in “over double the national average in drinking water supplies derived by data provided by the National Research Council (US) Safe Drinking Water Committee. Beta radiation is often associated with man-made radionuclides like Cs-137 and Sr-90.”
Though we reported in “Brandeis-Bardin’s Toxic Denial” that “Tritium came in at double background according to H-3 levels cited in an April 21, 1996 Brandeis-Bardin crop testing report recently released by AJU in response to the KNBC I-Team investigation LA’s Nuclear Secret which included Brandeis-Bardin’s pollution issues,” EnviroReporter.com has obtained information from a 2014 Lawrence Livermore National Laboratory report, posted on the California State Water Resources Control Board website, that says it is actually zero.
Maps of the state in California GAMA Special Study: Geostatistical analysis of groundwater age and other noble gas derived parameters in California groundwater show no ‘background’ tritium in groundwater under the Simi Valley area where Brandeis-Bardin is. This strongly suggests the source of the tritium coming out of the Campsite 1 area pipe in 2005 – 34.6 pCi/L – is from neighboring SSFL.
It’s not like DTSC didn’t know this information when they dated their report May 2, 2017. “Brandeis-Bardin’s Toxic Denial” came out over three weeks earlier April 6, 2017, replete with all this information backed up on the spot. DTSC repeatedly visits EnviroReporter.com. This is DTSC’s sixth pillar of prevarication: Ignoring the findings from EnviroReporter.com‘s 13-year-long investigation of Brandeis-Bardin.]
29. Page 18/59: “This resulted in revised Background Threshold Values (two standard deviations on the mean) for Cs-137 (0.349 pCi/g) and Sr-90 (0.127 pCi/g).”
[ER NOTE: CORRUPTED BTVs – Cesium-137’s surface soil BTV is 0.193 pCi/g according the US EPA. So Tetra Tech’s “revised Background Threshold Values” are 80.8 percent higher. Strontium-90’s combined (surface and subsurface) soil BTV is 0.0735 pCi/g making DTSC’s inflated Sr-90 72.8 percent higher. Tetra Tech was AJU’s contractor that performed a 2016 Brandeis-Bardin study.]
30. Page 19/59: “The BTVs Tetra Tech chose to use for comparison were published as part
of the DTSC Chemical Background Study “Combined-Data Background Threshold Values and Methodology Narrative Chemical Soil Background Study” (DTSC, 2012) and the EPA radiological background study (HGL. 2011 ).”
[ER NOTE: FALSE – As just shown, Tetra Tech, inflated the BTVs for Cs-137 and Sr-90 yet DTSC chooses to make this statement two paragraphs later in its report.]
31. Page 19/59: “All of the Sr-90 samples were less than the laboratory reported MDCs except for a detection of 0.182 pCi/g in a sediment non-background sample. This value exceeded the SSFL BTV (0.075 pCi/g). The laboratory analytical case narrative indicates that while the total radio-strontium is reported as Sr-90, the presence of other isotopes of strontium may cause positive bias in the measured strontium concentration. This could potentially lead to a reported value that is higher than the actual sample concentration.”
[ER NOTE: BLAME THE LAB – Instead of investigating the site of this high Sr-90 detection, 248 percent above its real BTV, the detection is blamed on ‘lab error.’ Only the high hits. DTSC’s bad science appraisal also left out that Tetra Tech’s 523-page 2016 report shows that AJU’s testers “collected eight drainage sediment samples (drainages were dry at the time of sample collection) and ten soil samples as part of the BBC radiological and soil investigation in accordance with the methods outlined in Section 3.2,” according to the report. That’s 18 soil samples for 2,878 acres or one test for every 160 acres. Even with this small set of samples, Tetra Tech pulled soil with 248% the normal amount of strontium-90. According to a Tetra Tech map on PDF page 110 of the report, the high strontium-90 was found in the “Main BBC Area” in the heart of the Jewish camp.]
32. Pages 19-20/59: “Tetra Tech’s overall conclusion was that the environmental and radiological conditions at Brandeis Bardin pose no unacceptable human health risk to campers, camp counselors, visitors, or residents (Tetra Tech. 2016). These overall findings are reasonable and consistent with the Area IV chemical and radionuclide findings.”
[ER NOTE: FALSE – DTSC equates Tetra Tech’s 18 soil samples with the numerous Area IV studies by DOE and US EPA which spent $41.5 million assessing the place. What US EPA found was shocking as EnviroReporter.com reported in Radiation Readings Soar at Rocketdyne. Cesium-137 clocked in at 9,328 times its BTV with strontium-90 tested at 284 times background. By writing this, DTSC deliberately erases Area IV’s “chemical and radionuclide findings” in order to deceive the reader on the contamination of Area IV, falsely making the DOE site seem as benign as it has made out Brandeis-Bardin to be. This is totally false.]
33. Page 25/59: “Overall, considering the extensive number of samples collected at BBI in the 1990s, sampling conducted by Tetra Tech in 2016, and by US EPA during the Area IV Study for this pathway, the significant amount of data show no pattern indicative of a complete contaminant pathway for radionuclides.”
[ER NOTE: FALSE CONCLUSION – DTSC outdoes itself when it anchors its predetermined outcome on decades-old tests, a test by the landowner sampling 1 out 160 acres on average, and a study that didn’t look at Brandeis-Bardin at all. DTSC not only leaves out all the recent DOE and NASA data, it conveniently forgets its own chemical contamination pathway into Brandeis-Bardin map it showed at an April 28, 2015 public meeting. Radionuclides also follow these pathways as they are chemicals themselves and obey the laws of gravity and water just like the ones shown on the map do. So “the significant amount of data” DTSC refers to doesn’t include its own. This is DTSC’s seventh pillar of prevarication – Ignore your own data of Brandeis-Bardin contamination even if you’ve already made it public.]
34. Pages 26-30/59: “Risk Based Screening Levels: On-site SSFL results and Brandeis Bardin results were screened with respect to Risk-Based Screening Levels. This evaluation is not based on a risk assessment; rather, it relies on a conservative point-by-point screening of individual sample results (as opposed to area averaging of results) to their respective risk-based screening levels.”
[ER NOTE: JETTISON CLEANUP TO BTV – DTSC serves up another super-sized word salad that, once again, grossly inflates the amount of acceptable toxins for Brandeis-Bardin over the background levels of radiation and chemicals that Area IV and NASA’s areas will be cleaned to. No amount of risk analysis can explain away soil and water contaminated above background levels of goo.
The suggested levels deemed okay are astounding: The Brandeis-Bardin recreator “risk based screening level” (RBSL) for strontium-90 is 18.4 pCi/g for dirt when its BTV is 0.0735 pCi/g. That means DTSC is signing off on Brandeis-Bardin dirt having 250 times more strontium-90 than it will allow at Area IV itself according to the AOC. Plutonium-238’s Brandeis-Bardin recreator RBSL is 4,306 times its BTV and plutonium 239/240’s camp screening level allowed is 1,194 times its background.
This hyper-inflation of these radionuclides’ BTVs is why the report can subsequently say on page 30 “The highest Sr-90 result is nearly 19 times less than the SSFL residential risk based screening level and over 90 times less than the SSFL recreator risk based screening level. The Pu-238 and Pu-239/240 off-site results also were significantly less than their respective SSFL RBSLres and SSFL RBSLrec values.”]
35. Page 31/59: “Based on the results of these SSFL investigations, some chemical exceedances of the Area IV Look-up Table have been identified in surficial sediments. The sediments could migrate along drainages from SSFL into the Northern Buffer Zone, and extend into a limited number of steep drainages and onto Brandeis Bardin property. The chemicals found at the BBI property are at very low levels, which can be expected to occur across many areas of the state and may not be from SSFL sources.”
[ER NOTE: WISHFUL THINKING – As noted in 6B, DOE’s list of chemicals found in Brandeis-Bardin were several multiples of their BTVs. It is not only bad science, but ludicrous, to claim the chemicals “may not be from SSFL sources.” Where else would they be from?]
36. Page 31/59: “Likewise, because they are sporadic and at low-levels, the chemical exceedances found off-site are not at levels considered harmful to human health.”
[ER NOTE: FALSE – The California Highway Patrol’s hazardous materials protocols include considering any toxic substance at over three times background to constitute a HazMat situation. 6B clearly shows toxins at levels exceeding this tripwire. As shown in 4D, fluoride and manganese have repeatedly exceeded their respective MCL and secondary MCL – harmful by definition yet there is no indication that it has ever been recognized as such.]
37. Page 31/59: “The contaminants of greatest concern, identified through extensive soils investigation, are confined to the SSFL site and do not extend off site.”
[ER NOTE: FALSE – See 4D and 33.]
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.
DTSC BRANDEIS-BARDIN “WHITE PAPER” CONCLUSIONS
46. Page 45/59: “Chemicals investigated within the active Brandeis Bardin Campus areas are within the range of local background.”
[ER NOTE: FALSE – See 4D and 6B.]
47. Page 45/59: “Levels of radionuclides at the Brandeis Bardin property are within the range of local background.”
[ER NOTE: FALSE – See 3A, 3B, 3C, 3D & 3E.]
48. Page 45/59: “Any data demonstrating a threat to human health at Brandeis Bardin or any other areas from SSFL would result in DTSC taking immediate actions to stop that threat.”
[ER NOTE: FALSE – Even though the AOC between DTSC and DOE includes responsibility for Brandeis-Bardin cleanup of radiation and chemicals, DTSC has jettisoned even entertaining adherence to that part of the deal. Remediating Area IV’s radiation and chemicals to background levels as part of a restoration to a safe natural environment, has been the agreement since 2010 yet, as this EnviroReporter.com analysis shows, Brandeis-Bardin doesn’t get the BTV level of cleanup. What it does get is a DTSC “white paper” riddled with mistakes, falsehoods and sleights of hand built on seven pillars of prevarication dissected and analyzed in this document.]
49. Page 56/59: “Figure 3 • Strontium-90 (pCilg) Soil Analytical Data Compared to the SSFL Soil – Residential (without produce consumption) Risk-Based Screening Level (RBSL)”
EnviroReporter.com wrote of this completely misleading map in Brandeis-Bardin’s Toxic Denial:
“At an April 12, 2016 meeting, DTSC produced a presentation [pp. 28-30 PDF pages; 6.4 MB] stating that Brandeis-Bardin is safe. The presentation included maps showing both Sr-90 and Cesium-137 (Cs-137) migrating offsite into Brandeis, but declared the contamination posed no threat according to what it claimed was a residential Risk-Based Screening Level (RBSL.)
“Problem was that the standard of 3.85 picocuries per gram (pCi/g) for Sr-90 that it used, apparently provided to DTSC by Boeing, was thousands of times less protective than the current EPA Residential Preliminary Remediation Goal of 0.00121 pCi/g. DTSC falsely declared almost of all the Strontium-90 in Area IV to be to be less than a residential risk-based standard, when in fact they are almost all above it. DTSC also should not have applied any risk-based standards to Area IV, since it is under the Administrative Order on Consent (AOC) to be cleaned up to background.”