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. [S-3]
“An EPA limit was never formally proposed and the informal suggestion was withdrawn due to, basically, Department of Energy and Nuclear Regulatory Commission pressure,” says Stuart Walker, an EPA official who specializes in Superfund radiation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 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. [S-4] Regardless, the GreenPark subcontractor gave a hearty thumbs-up to the results. “In perspective, the concentrations of strontium-90 … were found to be insignificant,” concluded the Foster Wheeler report. [S-3]
“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.
The Leukemia Connection
“Increased strontium-90 contamination could only be related to nuclear fission of uranium, therefore, it’s most likely related to the Santa Susana nuclear reactor facilities,” says Dr. Robert Dodge, a Ventura-based family doctor who is also the president of the county’s chapter of the public health organization Physicians for Social Responsibility(PSR). “I think this should be an issue of concern not only to individuals in the vicinity of the proposed development, but also to anyone downwind of any construction proposal.”
Founded in 1961, PSR gained notoriety by documenting the presence of Sr-90 in children’s teeth across the U.S. This finding helped lead to the Limited Nuclear Test Ban treaty signed by President John F. Kennedy, which ended above-ground nuclear testing by the U.S. and the former Soviet Union. At the signing, Kennedy acknowledged radiation’s connection to cancer, and to leukemia in particular.
Dr. Dodge knows plenty about leukemia – his son David was diagnosed with childhood leukemia at the age of six. “He was a kid playing T-ball and he was having unusual bone aches and pains,” says Dr. Dodge. “For several nights before the diagnosis was made, he was up sitting in my lap all night crying because he was in pain.”
Initially, Dr. Dodge and his wife Joan, a school counselor, thought it was some sort of infection, and then maybe juvenile arthritis. They went to Childrens Hospital in L.A. for an examination and soon found out that David had leukemia. The reason his bones hurt was that they were impacted – full of tumor cells.
After years of utterly exhausting chemotherapy and radiation therapy, David Dodge was declared cancer-free just before his 11th birthday. Leukemia is just one of the ailments induced by strontium-90 – though it is important to note here that David’s case was not necessarily linked to Sr-90 or to Rocketdyne in any way. But Sr-90 is one of the principal elements of nuclear fallout, and children downwind of the 1986 Chernobyl meltdown disaster experienced a radical increase of Sr-90 in their teeth.
“Strontium-90 is considered to be the most hazardous bone-seeking element created in the fission of uranium or plutonium because of its long half-life of 28 years and because it resembles calcium so closely,” wrote Dr. Ernest Sternglass in 2003. Sternglass is the Professor Emeritus of Radiological Physics at the University of Pittsburgh Medical School, and has written numerous articles on low-level radiation. In 1963, he was invited to testify before the congressional Joint Committee on Atomic Energy, explaining how the exponential increase in strontium-90 in baby teeth caused by atomic bomb-test fallout was associated with increased childhood leukemia.
Radioactivity has been detected in astronomical amounts on the Santa Susana Field Laboratory, fueling concerns that it might be migrating onto the Runkle Canyon property. One of SSFL’s experimental reactors suffered a partial meltdown in 1959 with a third of the core melting and radioactive gases being vented into the atmosphere. Two other reactors suffered damage in 1964 and 1969. In 1989, the Department of Energy found widespread radioactive and chemical contamination at the site, and a cleanup program commenced which ultimately will cost approximately a quarter of a billion dollars.
City planners acknowledge that there may be a few problems with the EIR’s assessment of potential radioactive contamination at the site but toss it off as simply a matter of grammar. “You know, that sentence could have been written a little bit better, I’ll have to say that,” says Lauren Funaiole, senior environmental planner for the city of Simi Valley. “It could have been broken up into two [sentences] and it would have been a little bit clearer. The strontium-90 was above normal background levels, however, that study did find that it did not pose a significant health risk.”
“It’s a very thorough EIR,” says city planning director Peter Lyons. “We had many, many public meetings. The project received a lot of input. Some of the major concerns of this project were traffic and visibility from the valley floor. The issue of strontium-90 was not something that people were concerned with.”
Ignorantly or deliberately, the city of Simi Valley’s subcontractor charged with evaluating the EIR, Agoura Hills-based Impact Sciences, didn’t include the comprehensive data supplied by QST or Foster Wheeler in the EIR, though Foster Wheeler’s dismissive conclusion about Runkle’s high Sr-90 soil readings was included but not attributed. “The Miller Brooks study of 2003 was truly the report that we used, and Impact Sciences used, to do the EIR,” says Lyon. [U-1]
Miller Brooks took six soil samples [U-2] in the area that the Runkle Canyon residences are to be built and sent them to Casper, Wyoming-based Energy Laboratories. That lab tested the samples employing techniques that only had detection sensitivity of 2.0 to 10 pCi/g [U-3], or nine to 43 times too insensitive to even ascertain the EPA’s preliminary remediation goal for Sr-90. Nonetheless, readings of 2.1 and 2.2 pCi/g were detected [U-4], nearly ten times over the EPA goal. Regardless, Miller Brooks calculated the danger from the readings as “0.77 in a million,” [U-5] using mysterious computations not attributed to any EPA method.
This finding is particularly disturbing because the potential is high, say scientists, for offsite transport of strontium-90 in impacted dust. Airborne Sr-90 could be in particles so tiny that several thousand of them could fit on the period at the end of this sentence.
The draft EIR (DEIR), which makes up a large section of the Final EIR, seems unclear as to just how seriously to take this dust. “No fugitive dust control for the 25 percent of the development area actively being graded is being assumed,” reads the document, before later stating, “Therefore, operational-related air quality impact would remain significant and unavoidable, even with the implementation of all feasible mitigation.” Still, no mitigation was required.
During the day, the average winds blow eight miles per hour from the northwest to the southeast over the Santa Susana hills and into the western part of the San Fernando Valley. At night, and during Santa Ana winds, the wind direction and speed changes and could carry this dust into Simi Valley. “While much of the airborne dust … would settle on or near the area being graded, smaller particles would remain in the atmosphere, increasing particulate levels within and adjacent to the graded area,” the EIR states.
“So we did consider it an impact deserving enough and significant enough to require mitigation such as the dust mitigation plan with water,” says Lyons. “In the analyzing of the project, maybe there were some statements there that it wasn’t significant. In the end, in the Final EIR, we determined that it was significant and that it had to be mitigated.”
A conservative estimate of the amount of dust made airborne [during construction period], not including the golf course construction, is around one hundred tons of particulate matter launched into the air.
The fallout of this dust is just something that the Simi and San Fernando valleys will apparently have to live with. Contesting the convoluted, confusing, and counter-factual Runkle Canyon EIR is a mute point – the public and environmental activists alike have no legal recourse. “There is a very short window of opportunity to file a CEQA (California Environmental Quality Act) lawsuit,” says Dr. Joe Lyou of the California Environmental Rights Alliance, a public interest organization. “If the time to file has passed, you’re screwed.”