Submitted by Michael Collins on Nov. 17, 2005
1. What is your title as the principle for PwC on the CARES project? What does your work entail?
2. The “Stage 1 Summary Report Appendix, Site: West Los Angeles” 129pp PDF document (“report”) dated September 13, 2005 was “produced under the scope of work and related terms and conditions set forth in Contract Number V776P-0515,” according to your disclaimer on page two. Where in that contract does it require that media inquiries be made via surface mail to the VA and forwarded to you? Have other journalists had to ask PwC questions regarding the CARES project in this manner? If so, who and when?
3. The report is not available on either the VA CARES website or PwC’s website. Why? Why hasn’t PwC and the VA made this information public?
The following questions are in regards to passages in the report. I’ve copied the pertinent passages, each of which are followed by my questions.
1. Medical Waste Disposal Areas: An approximately two-acre area in area “J” along the banks of the arroyo was used as a medical waste disposal area from the 1950s until 1968. This medical waste included radioactive biomedical wastes. These radioactive medical wastes were apparently disposed of in accordance with the U.S. Department of Energy requirements that allow for burial of radioactive medical wastes. (Page 61)
I believe that the report means in area “A.” Regardless, who supplied PwC this information specifically?
2. Construction of athletic fields for the Brentwood School between 1996 and 1999 uncovered several of the disposal areas. Excavated wastes were collected and removed to an off-site disposal facility. (Page 62)
Who supplied PwC this information? Did the construction company remove the excavated wastes? Did the VA? In case, what company and/or agency had the waste removed? Where is the off-site disposal facility?
3. At this point the radioactive wastes are at approximately 10 half-lives and theoretically do not emit radiation greater than other non-radioactive materials. Testing of the waste did not detect any radiation levels above background. Off-site monitoring well sampling has not detected any radiation above back ground levels. (Page 62)
What did the radioactive waste consist of and which radionuclides were detected? “10 half-lives” of what exactly? Does this mean that there is only one radionuclide in the disposal areas? Are you presuming it to only be tritium (H-3), the most prevalent radionuclide in the disposal areas according to my research? Who concluded that the wastes emit no more radiation than non-radioactive materials? Who tested the waste and what did they test the waste with? Who did the off-site monitoring well sampling and where are those wells located?
4. Radioactive medical wastes not excavated for construction of the athletic fields remains in place in this area under 15’-to-30’ of soil fill. (Page 62)
Whose decision was it to leave the non-excavated radioactive medical wastes in place? The VA? The Brentwood School? Or both? How much waste is estimated to remain in place and where is it located under the athletic fields?
5. The biomedical, radioactive medical waste and ACM containing construction debris waste sites are all now buried under 15′ to 30′ of fill material areas leased to the Brentwood School for use as athletic fields. None of these disposal areas is considered a significant environmental hazard at this time. Radiation and ACM’s are below threshold limits. Biomedical wastes encountered during development of the athletic fields were removed to a suitable off-site disposal area. Without a potentially negative public reaction to these types of wastes this end of the site may be considered as having a “Medium” potential for development. Remediation of these wastes includes encapsulation (which has already been done) or removal to an acceptable disposal site. The fact that this area has already been developed for use as athletic fields indicates that:
1. Either the public was not informed as to the contaminates under the athletic fields, or
2. These environmental hazards did not trigger a significant negative public reaction from nearby residents (including parents of students using the fields). (Page 64)
The first sentence reads that “all” the waste sites are buried under “fill material areas leased to Brentwood School for use as athletic fields.” What fields does this refer to exactly? Does this mean that there are no other radioactive medical waste sites not underneath these fields? Who made this determination and when?
Who determined that the radiation was “below threshold limits” and when? Why were biomedical wastes encountered “removed to a suitable off-site disposal area” if they are not considered a “significant environmental hazard at this time”? What kind of “encapsulation” of these wastes took place and by whom and when?
Do the last four sentences of the above paragraph indicate that PwC does not know if the public, including parents of students of Brentwood School, were informed of contaminants under the athletic fields? Has PwC contacted the Brentwood School to see if the school has informed the parents of students regarding the radioactive waste under the athletic fields? In the course of preparing this report, did PwC have any contact with Brentwood School regarding the radioactive wastes and waste sites?