Committee to Bridge the Gap

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  Radioactive Contamination at Dayton Canyon from the Santa Susana Filed Laboratory

  Committee to Bridge the Gap and Daniel Hirsch

  "Radioactive Contamination at Dayton Canyon from the Santa Susana Filed Laboratory" was a report that was "deeply flawed" as the result of the Department of Toxic Substances Control (DTSC) "misrepresenting the underlying data", as well as "poor protection levels and an a priori assumption that there can't be contamination coming from Santa Susana Field Laboratory (SSFL). It should be rejected."

  Correspondence and context for this failed study, and the ways the Committee to Bridge the Gap and its researchers were led astray by aforementioned parties, is documented in detail here.

  This research was completed money allocated during Round 6 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu

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  Radioactive Contamination at Runkle Ranch from the Santa Susana Field Laboratory

  Committee to Bridge the Gap and Daniel Hirsch

  Runkle Ranch is the site of a proposed residential development in Simi Valley. Because it is located near to, and below, the Santa Susana Field Laboratory ((SFL), a nuclear reactor and rocket testing and development facility with significant radioactive and chemical contamination, the developer arranged for a series of tests of soil and other environmental media. SSFL is operated for the U.S. government by the Rocketdyne Division of the Boeing Company. This report examines the results of the soil testing for radioactivity.

  The Environmental Impact Report (EIR) that supported the approval of the project briefly addressed the potential for contaminants from SSFL to have impacted the Runkle Ranch land and concluded that this was not an issue. The EIR1 noted that background levels of strontium-90 are “about 0.1 pico Curie per gram (pCi/g)” and went on to describe sampling results for the Runkle property:

  "Previous assessments of strontium-90 and tritium within the vicinity of the [Runkle Canyon] Specific Plan Area included a survey conducted by QST Environmental, Inc. in 1998. This study was conducted to determine if nuclear 1 This and the following two quotes are from pp. 4.6-6 and 4.6-7 of the EIR. 2 reactor operations at the SSFL facility had impacted soil at the site through surface water runoff. Four soil samples at three were collected and analyzed for cesium-137, strontium-90 and tritium. One of the locations was within a natural drainage channel flowing from the locale of the SSFL facility towards the northeastern portion of the Specific Plan Area. The results of the survey indicated that the surface soil contained concentrations of cesium-137 and strontium-90 that exceeded background levels established by the EPA."

  Because of the initial findings, followup sampling was initiated. As the EIR states:
  
  "Consequently, further testing was indicated. Tritium was also detected in the samples, but at concentrations below the EPA background levels. A limited radiation survey was conducted during subsequent testing and analysis in the Phase I ESA for the 550-acre parcel referenced in this section. This assessment found that radiation levels were within normal background levels. 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. (emphasis added)."

  This conclusion is puzzling, because the actual measurements being cited for the proposition that none were above background nor above levels considered to pose a health risk show precisely the opposite. Rather than none of the samples being above background or health risk levels, ALL 58 of the 1999 follow-up strontium measurements exceeded the 0.1 pCi/gram background figure cited in the EIR (as we shall see, that figure is actually twice background), and virtually all exceed the EPA’s Preliminary Remediation Goals (PRGs).

  This research was completed money allocated during Round 6 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu

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  Radioactive Contamination of Water At the Santa Susana Field Laboratory

  Committee to Bridge the Gap and Daniel Hirsch

  Presentation to SSFL InterAgency Work Group Community Meeting. Contains presentation slides in pdf format.

  This research was completed money allocated during Round 6 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu

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  Nuclear Cleanup: The Standards Conflict

  Committee to Bridge the Gap and Daniel Hirsch

  The U.S. Department of Energy has recently violated a longstanding Joint DOE-EPA Policy which commits DOE to clean up all its nuclear facilities nationwide to the Environmental Protection Agency (EPA) Superfund (CERCLA) standards. The focal point of this conflict between DOE and EPA cleanup standards is the Santa Susana Field Laboratory (SSFL), a 2800- acre facility on the Los Angeles-Ventura County line in Southern California. Ten reactors, a plutonium fuel facility, and a “hot laboratory” for cutting up irradiated nuclear fuel were operated at the facility, which opened in the 1940s when it was remote from populated areas. Now large numbers of people live nearby.

  One of the reactors suffered a partial meltdown in 1959; two others experienced damage in 1964 and 1969 to 80% and 35% of their fuel, respectively. In 1989, DOE found widespread chemical and radioactive contamination at the site, and a cleanup program commenced. In 1995, DOE and EPA entered into a Joint Policy to assure that all DOE sites, whether or not they were on the National Priority List (Superfund), would be cleaned up consistent with EPA’s CERCLA standards.

  In March of 2003, DOE reversed course and, while claiming to still follow the 1995 Policy, announced it would not clean the site up to the EPA standards. It would remove only 1% of the contaminated soil and then release the site for unrestricted residential use. In December 2003, EPA issued findings that the site was not being cleaned up consistent with the 1995 Joint Policy and that under the circumstances, so much radioactivity could be left in place that residential use would be unsafe and the only safe use would be restricted dayhikes with limitations on picnicking.

  To date no detailed study has been done comparing the DOE and EPA cleanup standards. This report, supported by a grant from the Citizens’ Monitoring and Technical Assistance Fund, performs that analysis.

  The evaluation demonstrates that DOE’s decision not to comply with EPA’s cleanup standards will result in radionuclide concentrations being permitted that are hundreds, thousands, tens of thousands, and in some cases, hundreds of thousands of times higher than EPA’s primary cleanup goals. For most radionuclides, the associated risk exceeds even the uppermost permissible risk level of EPA under CERCLA. In some cases, those cancer risks rise to levels on the order of one cancer per ten people exposed, using the federal government’s official radiation risk figures.

  Should DOE proceed with acting in contravention of the 1995 DOE-EPA Joint Policy on cleaning up DOE sites consistent with CERCLA at SSFL, there would be significant ramifications for the DOE nuclear complex nationwide, and for public health.

  This research was completed money allocated during Round 4 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu