contact us at: mail@ssflcag.net                     Facebook page: SSFLCAG

 "The full cleanup advocated by Hirsh is simply a 

    


public relations fiction created by him."




This is a quote from a letter written by Abraham Weitzberg that was recently published by the Thousand Oaks Acorn. 




Click here.

Read the attached briefing made by Christopher Shubeck PE about the facts and negative consequences of the SSFL soil removal and grading. 


Large Scale Grading at the SSFL and Related Issues


Click here.


See the CAG's White Paper setting the record straight on

NBC4's Misleading Report "LA's Nuclear Secret"

 Recent CAG Meeting: Thursday December 17, 2015    

Fugitive Dust and Excavation     See presentation

Soil Removal Estimates and Impacts     See presentation

Best Management Practices         See presentation

 "2010 AOC cleanup requires from 3 to 5 times as much soil removal and areal disturbance as a risk-based cleanup."

"As cleanup requirements become more severe environmental consequences become greater."

Come visit us on Facebook - SSFLCAG and bring along any comments you may have

 ATSDR (CDC) Bows Out of Health Review at Santa Susana

" ...ATSDR will not conduct any new public health investigation as a result of the recent petitions."

 "...the clean-up should move forward without delay."

Full text

The SSFL CAG recommends that all responsible parties execute a risk-based cleanup to EPA’s suburban residential standard that will minimize excavation, soil removal and backfill and thus reduce danger to public health and functions of surrounding communities.

The SSFL CAG supports the creation of a National Monument at the

Santa Susana Field Laboratory site.

 


 "The amount of radioactivity to be removed...is an infinitesimal portion of the amount of radioactivity that will remain after cleanup." 

 Recent Posting from California Department of Toxic Substances Control (DTSC):

"Santa Susana Field Lab    Community Update: Cleanup Levels

 There is contaminated soil on SSFL that will be required to be cleaned up. Based on the available data, there is no evidence of contamination from SSFL that poses an off-site threat to human health or the environment."

West Hills Endorses Health Review Regarding Santa Susana Field Laboratory

WHNC recommends that the ATSDR, under the guidance of the Centers for Disease Control and Prevention (CDC), re-evaluate the data and determine the current health risks related to the SSFL.

 On October 6, 2015, the Ventura County Board of Supervisors voted 4-1 to urge CDC / ATSDR to

reverse its recent decision to conduct a health review of the vicinity of the Santa Susana Field Laboratory.

CDC / ATSDR in March 2015 wrote:

Ventura County has asked the CDC to NOT provide those services.

? ? ?

Read CDC/ATSDR's letter of acceptance

Read Ventura County's letter of rejection

 Agency accepts petition from CAG to complete health-risk review of SSFL:

See Petition and Response HERE

  Abe Weitzberg responds to attempt to prevent independent look at  health risk posed by contamination now known to exist at SSFL

Health Risk Calls for a Fresh Look

Dr. Dodge's column (September 6, 2015, Ventura County Star) presents misinformation with the sole purpose of trying to prevent an independent look at the health risk posed by the contamination now known to exist at SSFL.

He starts with the obligatory reference to the 1959 Sodium Reactor Experiment (SRE) accident, which is truly irrelevant to the current cleanup issue. The SRE facility was removed long ago and excavated to bedrock. EPA found very little radiological contamination and none that could be traced to the SRE accident.  Read more...

 

Abe Weitzberg responds to Toxic Teen’s attack:

Cleanup needed, but how much?

(a response to this Thousand Oaks Acorn letter)

I petitioned ATSDR to provide the community an authoritative, independent assessment of the risk that SSFL now poses to surrounding communities. Master Gortner provides no substantiation for his condemnation of ATSDR.  Read more...

Abe Weitzberg responds to attack from Rocketdyne Cleanup Coalition:

Why be afraid of another study?

(a response to this Simi Valley Acorn letter)

My petition to ATSDR to provide the community an authoritative, independent assessment of the risk that SSFL now poses to surrounding communities actually came from a discussion I had with Prof. Cohen about ways to resolve the apparent discrepancies between his report and that of ATSDR.  Read more...

 Audubon Society announces its support for 

Risk-Based Suburban Residential Cleanup at SSFL

  "SFVAS supports remediation of contamination at SSFL only to the standard for suburban residential areas. SFVAS opposes the unprecedented proposal to require remediation to background level, which would devastate outstanding wildlife habitat, extremely significant historical structures from the USA Space Age, and create significant health and safety impacts on communities near routes that trucks hauling soils offsite would pass. Background remediation would destroy Native American cultural sites, which remediation to the suburban residential standard would not."

PASSED BY THE SAN FERNANDO VALLEY AUDUBON SOCIETY BOARD OF DIRECTORS

March 23, 2015

SFV Audubon also supports a National Monument at SSFL. Details:  HERE


 We Need a Cleanup the Simi Hills Wildlife Corridor Can Live With

Do You Know If an AOC (Background) Cleanup 

Is Good for Your Community?

Recent CAG Meeting

Wednesday August 20, 2014  

Toxicity, Land Use, Exposure, Risk

Donald Greenlee PhD

Presentation Summary HERE

Recent Community Forum

Santa Susana Field Lab Forum Highlights Competing Views

Woodland Hills / Warner Center Neighborhood Council and Canoga Park Neighborhood Council sponsored 

"Santa Susana Field Lab-101"

October 20th, 2014

Details HERE and HERE

 (This was not an SSFL Community Advisory Group Meeting)

 HEALTH OF BIRDS AT SANTA SUSANA 

Mark Osokow, San Fernando Valley Audubon Society

The San Fernando Valley Bird Observatory (SFVBO), a scientific program of San Fernando Valley Audubon, has been operating for more than two and a half years at the Santa Susana Field Laboratory (SSFL). 

SFVBO counts, captures, marks and releases birds in the Field Lab to evaluate and track bird populations.

SFVBO is also evaluating the effects on birds of activities at SSFL that led to the deposition of chemical and radiological contaminants in the areas that are currently targeted for extensive cleanup. 

SFVBO has so far found no evidence of any unusual mortality, disease, mutations, or other ill effects to birds that might be attributable to contaminants. 

  SFVBO will continue to monitor bird populations at SSFL so that the acquired information will help to assure that SSFL will be cleaned up in a manner that is respectful of the biological resources in the area and consistent with the eventual use of the area as open space in which wildlife can thrive.

August 1, 2014

"Still a mess,"

but reasonableness is beginning to prevail 

 Sent: Sunday, June 15, 2014 

To: 'mhiltzik@latimes.com'

Subject:Santa Susana Cleanup Effort Is a Mess

Dear Michael Hiltzik:

I read your column this morning regarding "Santa Susana toxic cleanup effort is a mess".

You are correct. 

Unfortunately, you, like many others, have listened to a one-sided view as reported by Consumer Watchdog. Their alleged facts are very skewed and misrepresented. Past and recent testing have shown that there is not a higher cancer risk for residents living within 2 miles of the SSFL. On a personal note: My family, including three young children, in the late 1970's lived at the bottom of Runkle property in Simi Valley, the SSFL watershed area, and more recently for twelve years on Woolsey Canyon, West Hills. After living on both sides of the SSFL within 2 miles, in different time periods, my family and I are cancer-free and healthy.

The Consumer Watchdog group works on the human fear factor so that a responsible cleanup might not happen. The radical clean up to background will require more than ten years of truckloads, minimum of 80,000 truckloads, of soil and rocks being excavated and hauled out causing more health risks versus a technical remediation as Boeing has been conducting for years. Half of the San Fernando Valley is a Super Fund site because of contamination from gas stations, dry cleaners using chemicals, machine shops and aerospace industry. No one is advocating demolishing all structures and excavating the soil in the eastern half of the San Fernando Valley.

Many of us are working to stop the insanity, save a thriving and important wildlife corridor, preserve Native American historical districts and historical rocket engine test stands. We want a clean up, but a responsible cleanup that doesn't hurt the environment.

If you would like to know the real facts, not hyperbole, about the contamination, the clean up in process, and the best scenario to ensure a risk-based assessment of the cleanup, you are invited to attend the next Community Advisory Group (CAG) meeting or attend a tour of the SSFL so you can learn more about the site and this natural wonderland. Website information about the SSFL cleanup: www.ssmpa.com and www.ssflcag.net John Luker <jcluker2@yahoo.com>, SSMPA Vice President, will be happy to discuss the SSFL cleanup and advise you of the next CAG meeting and SSFL tour. 

Carla Bollinger

Affiliations:

NASA/SSFL Section 106 Consultant
Santa Susana Mountain Park Association Board Member (SSMPA) 
Associated Historical Society of Los Angeles County Member
Member of SFV Audubon Society and Southwestern Herpetologists Society

 Is Simi Valley's water supply contaminated by SSFL? 

 Recent SSFL CAG Meeting

Wednesday July 23, 2014 

Might Valley Fever be a Danger of SSFL Cleanup?

Dr. Ramon Guevara

presentation here

 Review of Studies of Health Effects Possibly Related to the Operation of the Santa Susana Field Laboratory (SSFL)

 "Based on the levels of contamination now existing at SSFL and 

the lack of any evidence of health effects attributable to SSFL,

there is no reason to treat the cleanup of SSFL differently from any similarly contaminated site in California or the United States

Therefore SSFL should be cleaned up using EPA risk-based criteria and procedures."

AUDIO

June 18, 2014

From  NASA's Comparative Analysis  of

Background versus Risk-based Cleanup Scenarios

for the Soils at Santa Susana Field Laboratory

"The more aggressive cleanup of the site that would occur under the background cleanup (more soil removal, more trucks entering the site, more emissions, more road miles, more soil to dispose of in landfills, etc.) could result in an increase in traffic accidents and spills and more habitat modification, as well as disturbance of wildlife and more impacts to archeological resources, all of which might result in reduced net benefits when compared to the risk‐based cleanup scenario." p. 5-1  

April 8, 2014

 SSFL CAG Resolution Regarding the SSFL Cleanup

Adopted by the SSFL CAG May 21, 2014

 WHEREAS the Santa Susana Field Laboratory (SSFL) site has been contaminated with chemicals and radionuclides over the past decades and requires cleanup;

WHEREAS the majority owner of the SSFL (Boeing) has announced its intention to designate the site as parkland upon completion of the environmental restoration;

WHEREAS the SSFL Community Advisory Group (CAG) representing various communities has many concerns with the cleanup of the SSFL;

WHEREAS DOE and NASA voluntarily signed agreements requiring their respective areas to be cleaned up to background (or detect) while Boeing will use a risk-based cleanup to EPA’s suburban residential standard;

WHEREAS the cleanup to background requires major excavation, soil removal, and soil replacement, and is disruptive to the environment and public health in surrounding communities;

WHEREAS the cleanup to background will remove cultural and historical items and sites including rocket engine test stands;

WHEREAS the cleanup to background will remove Native American artifacts and cultural areas in the SSFL that is Tribal sacred land; 

WHEREAS the cleanup to background will negatively affect a wildlife corridor used by endangered species;

WHEREAS the cleanup method used by the US EPA throughout the nation is risk-based with end use of the land being a major determinant;

WHEREAS risk-based cleanup is fully protective and requires only a fraction of the excavation, soil removal and backfill compared to cleanup to background and thus presents a greatly reduced threat to public health and less disruption of surrounding communities;

WHEREAS it is apparent that suitable backfill will be difficult to find and the contemplated partial or complete use of crushed rock will not restore the environment consistent with its future use;

(R1) THEREFORE BE IT RESOLVED that the SSFL CAG recommends that all responsible parties execute a risk-based cleanup to EPA’s suburban residential standard that will minimize excavation, soil removal and backfill and thus reduce danger to public health and functions of surrounding communities;

(R2) BE IT FURTHER RESOLVED that the CAG membership encourages the Boeing Company to promptly take affirmative measures to formally guarantee that the future land use of the SSFL will be open space for the benefit of the public and wildlife;

(R3) BE IT FURTHER RESOLVED that the responsible parties fully employ all dust abatement and soil containment measures;

(R4) BE IT FURTHER RESOLVED that DTSC immediately clarify the exceptions to the cleanup for “Native American artifacts” as contained in the Final Agreement in Principle attached to the 2010 Administrative Orders on Consent;

(R5) BE IT FURTHER RESOLVED that all Native American cultural and sacred sites and traditional cultural places / landscapes, including without limitation archaeological sites, at the SSFL be prioritized as to significance and determined whether they are eligible for nomination to the National Historic register and / or protected under applicable environmental laws such as NEPA or CEQA;

(R6) BE IT FURTHER RESOLVED that NASA retain representative examples of rocket engine test stands and associated structures for future generations;

(R7) BE IT FURTHER RESOLVED that all responsible parties recognize the importance of the wildlife corridor, restore their respective land areas to accommodate preservation of the wildlife corridor, and execute site benefaction programs including sowing of native plants and abatement of non-native weeds and species.

Recent SSFL CAG Meeting

Wednesday May 21, 2014    

Groundwater and Surface Water at SSFL

Presenters were:
DTSC
Boeing Co.
NASA
Dept. of Energy
LA Region Water Quality Control Board

agenda HERE

presentations HERE and HERE


Chumash Say "NO" to Casino 

HERE

Cancer Occurrence in Offsite Neighborhoods Near the Santa Susana Field Laboratory

by Thomas Mack, M.D., M.P.H. 

Keck School of Medicine 

University of Southern California 

  • It is not possible to completely rule out any offsite carcinogenic effects from SSFL.
  • No evidence of measurable offsite cancer causation occurring as a result of emissions from the SSFL was found.
  • Further, no evidence of any cancer causation by any environmental factor was found. 

See complete slide-show report HERE

April 13, 2014

 Cultural Resource Laws

What Does the Alphabet Soup of Acronyms Mean for SSFL?

A presentation by Barbara Tejada

Associate State Archeologist, California State Parks

March 20, 2014

NASA released its

Final Environmental Impact Statement 

March 14, 2014

Final Programmatic Agreement (PA) on 

NASA Cultural Resources 

NEW! summary by Mike Kuhn

full signed document

March 6, 2014

 

  Community Advisory Group's 

Comments to DOE on Scoping for EIS

"DOE is to be commended for proposing to consider the full range of alternatives identified by the community in the 2012 workshops."

April 2, 2014

 Myth Check#7

Myth 

“Cleanup to background” is scientifically the best, safest cleanup.

Check

“Cleanup to background” is not founded on science. “Cleanup to background” is a phrase in an agreement (AOC). The phrase suggests an imprecise concept of a “maximum” cleanup. The concept has had no scientific validation of feasibility, effectiveness, safety of surrounding communities, or applicability to the specific characteristics of SSFL.

 Myth Check√  #9

Myth

"The AOCs governing the cleanup of the NASA and DOE areas of the SSFL are the law."

Check√

"The AOCs are not laws. They were never legislated; that is, no body of duly elected representatives ever drafted them or voted on them. The AOCs are contracts: consensual, negotiated agreements." 

“Administrative Orders on Consent (AOCs) … issued by EPA, which are consensual, negotiated agreements pursuant to sections 104, 106(a), 107, and 122 of CERCLA, that obligate parties to perform response activity (e.g., removal, remedial investigation, feasibility study, remedial design) and/or reimburse EPA for costs incurred…"

http://cfpub.epa.gov/compliance/resources/policies/cleanup/superfund/index.cfm?action=3&sub_id=1229

See discussion of this item on Forum

  Myth Check√  #11

Myth 

“Cleanup to background” is the safest cleanup.

Check√

Cleanup to background” could be the safest cleanup, or there may be safer cleanups. But we may never know because no other alternatives are being evaluated and compared to “cleanup to background” because of compulsion to adhere to the letter of the AOCs. If no other alternatives can be recognized, no one will ever know if better alternatives were possible.

 The amount of soil to be removed from the SSFL under the proposed "cleanup to background" alternative" would fill the Rose Bowl to the height of an 80-story building. The 32-story Los Angeles City Hall is shown for comparison.

 February 20, 2014 

 How We Got Started 

 In 2012, fifty persons who were interested in the Santa Susanna Field Lab cleanup formally petitioned the Department of Toxic Substances Control (DTSC) to get permission to form a Community Advisory Group (CAG).  DTSC verified the petitioners,  approved the formation of a CAG, and promised resources to help select members and form the organization.  DTSC brought in consultants from the Udall firm and they brought examples of charter and rules to help the CAG get started.

 A small organizing committee was formed with Ron Ziman as the Chair and included Abe Weitzberg, Christian Kiillkkaa, David Karchem, John Luker and Alec Uzemeck as members. The Chair spoke to a successful CAG located in northern California and the chair of that CAG described the formation of the organization, the difficulties they experienced, and suggestions for avoiding and correcting possible problems.

   The Committee prepared a request to six professors in various colleges to form a member selection group given standards prepared by the Committee. A selection group was formed and they selected 24 members from the applications that had been submitted. The CAG members met and wrote a draft charter and formed 5 sub-committees: Executive, Rules, Communications, Technical and Finance. Chairs and members were identified for each subcommittee, goals and methods were written for each subcommittee, and preparations were made to hold the first CAG meeting. The Bell Canyon Home Owners' Association offered their Community Center to the CAG as a place to conduct our meetings.

What We Have Accomplished

 The Charter was completed and Rules were written and both were approved. The Communications Committee got a Facebook page and a Yahoo Group site established and a Yahoo group that was for CAG members only with the capability to upload conversations, communications and archival material. Press releases were sent out for announcement purposes.

  About this time NASA issued their Draft Environment Impact Statement (DEIS) for public comment and held two open meetings for the community to attend and comment on the DEIS. The majority of the CAG members wrote and submitted their own detailed and technical analyses to NASA. The CAG also wrote a group communication to NASA. The majority of the public and the CAG members were astonished by the destruction and excavation described in the DEIS and most rejected the report which was based on the requirements of the Administrative Order on Consent (AOC) that NASA had agreed to implement.  An additional complaint shared by most respondents was that the DEIS  analyzed only one cleanup method in its report (the AOC requirements), which violates the intent of the National Environmental Protection Act (NEPA). NASA's responses are expected to be made public in February 2014.

  Shortly after the submission date for comments to NASA, DTSC announced public hearings for their California Environmental Quality Act (CEQA) project and the Program Environmental Impact Report (PEIR) that will analyze the entire SSFL site that was used for production. All of these meetings were attended by CAG members and  common requests were that DTSC analyze more than one cleanup method and preserve the environment, the historical test stands and the sacred sites identified by the Santa Ynez tribe.

  In December 2013 the CAG meeting hosted representatives from DTSC, Boeing, NASA and DOE to talk about the status of the cleanup at SSFL and answer questions from the members and the public.

  Recently CAG members attended two Democrat Club meetings that were studying a resolution that, if passed, would favor  the SSFL "cleanup to background" promoted by AOC advocates of the AOC. In both instances the clubs did not approve the resolution.

SSFL Community Advisory Group (CAG)

FACT SHEET

Who is the SSFL CAG?

What is the SSFL CAG?

How did the SSFL CAG form?

September 26, 2014

NEWS:

Chatsworth

Woodland Hills

West Hills

 and Bell Canyon:  

All have publicly called for EPA Risk-Based Cleanup of the former Santa Susana Field Laboratory.


Chatsworth Neighborhood Council's letter

Woodland Hills / Warner Center NC letter

West Hills NC resolution

Bell Canyon Association resolution

"EPA risk-based cleanup" OR "AOC cleanup to background"


 Recent CAG Meeting

Wednesday January 21, 2015      

Public invited

The Chumash Tribe and End Use of

 SFFL Land after Cleanup

Presentation: Resource Preservation and Future End-Use

Presentation: State of the SSFL CAG 

Agenda

Presentation by Abe Weitzberg

SRE and More

October 22, 2014  

Is the 1959 Sodium Reactor Experiment accident relevant to the cleanup of SSFL?

SSFL CAG Brochure 

Visitors and members are welcome to post to our Facebook page SSFLCAG

Member Viewpoint Column

Items in this column are expressions of personal opinion by individual members of the Community Advisory Group and do not represent positions of the CAG as a whole.

A Member Viewpoint Item from Brian Sujata  

October 30, 2014


SSFL Cleanup Threatens Pumas


This item originally appeared in the Thousand Oaks Acorn on October 30, 2014.

________________________________________

The Acorn recently told the story of interested community members, led by Linda Parks and Fran Pavley, supporting an improved mountain lion crossing at the 101 Freeway in Agoura.

As a community member advocating for a rational cleanup of the nearby former Santa Susana Field Laboratory, I find it ironic that both Parks and Pavley support the unprecedented and needless stripping of huge volumes of mountain lion habitat and proven wildlife corridor from the former test site.

 A recent map released by the National Park Service shows how critical the former SSFL site is to mountain lion movement through our area. I wonder if Parks and Pavely have seen it.

Using GPS, the Park Service monitors mountain lion movement throughout the Santa Monica and Santa Susana mountains so their travels can be mapped and ultimately better understood.

A map released last December shows the relatively narrow Simi Hills appear to naturally limit the movement of mountain lions between the Santa Susana Mountains to the north and the Santa Monica Mountains to the south. This narrow point is where the former SSFL is located.

Both Parks and Pavley have insisted portions of the former SSFL undergo an unprecedented and exceedingly harsh environmental cleanup that will strip an estimated 2.1 million cubic yards of habitat from the site.

Road building, digging, scraping, hauling and bulldozing millions of cubic yards of scenic area will take years, and when work is done, will the site look like habitat? Not likely. It will remind us of a barren and leveled area ready for a housing development or strip mall.

The Acorn quotes Fran Pavely as saying, “Let’s protect this land for generations to come.” Ironically, she also supports this unprecedented cleanup that seriously threatens the very thing she asks for: mountain lion habitat and their free movement.

My colleagues and I at the SSFL Community Advisory Group are advocating for a cleanup that balances the benefits of contaminant removal against habitat injury at this future parkland; the current cleanup requirement forbids balancing.

Let’s clean up SSFL for a future park, not strip mall.

Brian Sujata

Thousand Oaks

  A Member Viewpoint item by Ronald Ziman, MD

September 25, 2014


Testifying about DTSC in Sacramento

 The following statement is from:

CALIFORNIA STATE ASSEMBLY OVERSIGHT HEARING

September 25, 2014

SUBJECT: California's Toxic Waste Cleanup Program: Protecting Communities at Risk

I wish to thank the Environmental Safety and toxic Materials Committee for inviting me to testify today.  My name is Dr. Ronald Ziman.  I am a physician-neurologist faculty member at UCLA and was formerly in private practice in the San Fernando Valley.  I am a resident of Bell Canyon which is immediately adjacent to the SSFL.  We are downwind, down stream and down hill from the SSFL.  90% of SSFL’s watershed flows south toward Bell Creek which runs through our community.  Bell Creek is the headwaters of the LA River.  No community is more affected or has a larger stake in what happens at SSFL or how the cleanup will be conducted.  I am the vice-president of Bell Canyon’s Homeowners’ Association and vice-chair of the SSFL CAG.  The opinions I express here today are my own and not necessarily those of every member of the CAG or the Homeowners’ Association.    

Regarding the question of DTSC’s receipt of payments from the SSFL’s responsible parties (RP’s), it is my understanding from conversations with Boeing, the DOE, NASA and DTSC that all payments are up-to-date.  

With regards to the SSFL CAG, it is unfortunate that the authors from the Center for Race, Poverty and the Environment (CRPE) didn’t fact check.  No one contacted the CAG to avoid perpetuating false rumors.  Their document, in part titled, “Building a New Vision for DTSC,” states that DTSC has “disbanded the work group.”  As a matter of fact, the work group continues to meet and is next scheduled for 10/1/14, less than a week from now.    

I am also concerned that Consumer Watchdog is cited as a source for some of the information in this report.  Recently the California state senate investigated allegations made by Consumer Watchdog and found their allegations to be unsupported and without merit.  Without going into detail, some other information presented as fact in the CRPE report is arguably inaccurate.  This document perpetuates other false rumors such as the CAG is funded by Boeing, that the CAG is Astroturf and in the hands of the polluters and we are against cleaning up the SSFL.  These and other rumors couldn’t further from the truth.  

What I am about to say is fully documented and I will be providing those documents to you today.    

First, categorically, the CAG is a community led and driven process.  It hasn’t received a penny from DTSC, Boeing, NASA or DOE.  We haven’t requested any funding from any of the RP’s.  The CAG has been self-supported by its membership.  My time and expenses to travel here today hasn’t been underwritten by anyone or any entity other than myself.  Everyone on the CAG is an un-reimbursed volunteer.  

I would also like to make this committee aware of the unbiased and even-handed selection process for the CAG membership.  The whole process was controlled and overseen by the U.S. Institute for Environmental Conflict Resolution, part of the congressionally established Udall Foundation.  The goal was the selection of a diverse and effective CAG membership.  Though DTSC obtained financial support from the RP’s to cover Udall’s expenses, it was not otherwise involved in the selection process.  Invitations to create the selection panel were inclusive and sent to the community as well as the groups most vocally opposed to the CAG.  Those groups declined to participate.  The makeup of the selection panel ultimately consisted of 3 academicians, a Native American and an environmental justice advocate.  All applications for CAG membership were widely distributed to the community by DTSC and went directly to the U.S. Institute for Environmental Conflict Resolution.  They were then forwarded directly to the selection panel.  Neither those in the community who were advocating the CAG nor DTSC were involved in this process.  

The diverse makeup of the CAG and other facts are included in the documents that I am providing you.  Once reviewed, I think you will agree that the goal of selecting a diverse group representing the broad community was successful.  

The CAG membership has and continues to go through an educational process and is now also reaching out to educate the affected communities.  Until the CAG, there was only one point of view expressed.  The community remains mostly unaware of what is being proposed for the SSFL.  Thus far these other communities and their organizations include Bell Canyon, the San Fernando based neighborhood councils, and the City of Calabasas.  Further community outreach is planned.  

The CAG has reached a consensus consistent with NASA’s Inspector General.  What has been billed as, “the most protective cleanup possible,” in the opinion of NASA’s Inspector General is, “An excessive and unnecessarily costly cleanup…NASA’s cleanup plan commits the agency to a cleanup standard not based on health risk and…less costly cleanup alternatives exist.”  In these times of budget constraints, including that of DTSC, the commitment to an unnecessarily costly cleanup without documented additional public health benefit doesn’t make sense to me.  

The CAG’s position is that the SSFL cleanup process be the same as throughout California and the Nation.  It should be a risk-based cleanup to a suburban residential standard as was agreed originally in 2007 between the parties prior to the passage of SB990.  SB990 has now been ruled unconstitutional.  The 2010 Administrative Orders on Consent (AOC) mirror SB990.  The past cannot be denied, but the cleanup should be based on what is there now and use the best, most practical cleanup processes available today.  

It is my opinion that the SSFL CAG has exceeded expectation in the first year of its existence.  I believe there is always room for improvement, but the selection process for our CAG was unbiased, free of ideology or political influence and could serve as a model for other future CAG’s.  

Having said that, the document from the Center on Race, Poverty and the Environment, I believe, makes some good points related to the environmental justice community.  DTSC should be allowed to do its job based on science, not emotion, ideology or political pressure.  My concern with the suggested creation of another layer of oversight beyond the EPA and the legislature is its necessity.  Is a “community driven oversight committee” really going to be able to eliminate conflict of interest?  How will those individuals be chosen?  What is their agenda?  Is their motivation ideological, political, economic or otherwise?  Will they really improve efficiency, reduce cost and protect the EJ community or could their motivation bring about opposite results?  How is it determined, and by whom that another third party is indeed neutral?  How do we assure accountability for these new oversight groups?  

In my opinion perhaps the Federal Government’s model of an independent Inspector General would be a more autonomous and unbiased oversight approach.  This could avoid unintentionally creating and better addressing potential conflict of interest to ensure DTSC is doing the job it was created for and truly fulfilling its mission.  

I wish to thank you once more for giving me the opportunity to testify before you today.

 A Member Viewpoint Item by John Luker

September 25, 2014


Testifying about DTSC in Sacramento


 The following statement is from:

CALIFORNIA STATE ASSEMBLY OVERSIGHT HEARING

September 25, 2014

SUBJECT: California's Toxic Waste Cleanup Program: Protecting Communities at Risk


Assembly Member Luis A. Alejo,
Chair of the Environmental Safety and Toxic Materials Committee

 Hello my name is John Luker. I'd like to thank you for the opportunity to speak here today. I'm Vice President of the Santa Susana Mountain Park Association, an advocacy group that has been one of the community leaders in preserving open space and creating parkland in the Simi Hills, where the Santa Susana Field Laboratory is located. We have been very active for over 40 years and our goal is to preserve from development, over 15,000 acres in private hands in those local mountains. I am also the Communications Chair of the SSFL Community Advisory Group. The views I express today are not necessarily the policies or views of those groups; they are the opinions I've developed after a decade of activism, working on this project. 

The day I met Debbie Raphael, she said she had been charged by the Governor to remove politics from [DTSC's] investigation [of toxic contamination at SSFL]. That was 2 years ago. I come to you today, sadly, to ask your help in trying to achieve that same goal. The most toxic thing about SSFL is the politics associated with this investigation. 

Creating a truly "independent" advocate for communities like ours, that are at risk from continuing and legacy pollution and contamination is a minefield. In the investigation surrounding SSFL, our community is split. One group is politically connected to legislators and special interests that have a political and financial agenda in the outcome of this clean up. I was part of that group at one time, but when I started questioning the information I was being given, when I saw contradictory data that brought me to believe the direction we were going was wrong, I was isolated, vilified and I found myself the target of a biased and clearly partisan investigation that has now caught the attention of the press and this legislative body.

Accountability is the most serious issue you will face when you craft legislation that you feel will "fix" the Department of Toxic Substances Control. Who watches the watchdogs? Who can I turn to for truthful, accurate information? When I ask the special interest groups for documentation of some of the most outrageous claims that are being made about SSFL, I either receive silence or I am attacked publicly for harassment. 

How are these groups financed? Who is on the payroll? What are the roles of the politicians who support those groups and insulate them from scrutiny? These are the questions I am asking now. How has money and influence dictated decisions made by regulators? How can regulatory agencies like DTSC be insulated from political interference?

Again I ask, Who watches the watchdogs? They appear to be above criticism and scrutiny. The special interests have cost the taxpayers of this state tens of millions of dollars in legal fees and they've set up obstacles to the objective investigation of this site. I sincerely doubt that at this rate that SSFL will ever be cleaned up. It's wrong! 

I believe this legislative body can solve those, almost intractable problems. Resources and budgets have been cut in critical agencies government-wide. DTSC is one of those agencies that has trouble retaining qualified and motivated experts, and they are challenged to do the job they have been mandated with the limited resources at hand.

I would hate to see a new process instituted with "Independent" special interests, instead of fixing a process that is well established and would work if the agencies are given the resources to do their jobs. I don't want to just clean up the SSFL, I want to fix it! As I want to fix the DTSC. 

I ask you for your help.

A Member Viewpoint Item by Alec Uzemeck 

September 1, 2014


The SSFL Cleanup: Risk to Humans


On August 20th, 2014, Dr. Donald Greenlee of California’s Department of Toxic Substances Control (DTSC) made a presentation at the SSFL Community Advisory Group meeting. I will use some of his numbers to make my point. Dr. Greenlee pointed out that the risk of developing cancer for the general population is one in four, or 0.25 from all causes.

The US EPA risk-based cleanup limits increased risk of developing cancer to one in a million, or 0.000001. Your total lifetime risk from visiting SSFL after cleanup consistent with its end use would therefore be 0.250001 compared to 0.250000 if you never visited SSFL.

Alternatively, if the cleanup is to be made to the non-risk-based “background” standard as proposed by some, the cleanup could at best remove one chance-in-a-million of cancer, and your total lifetime cancer risk from visiting the site could remain at the baseline one-chance-in-four, or 0.250000.

The potential reduction of 0.000001 of cancer risk with cleanup to “background,” as compared to risk-based cleanup, will require the removal of eight times as much soil, will extend the cleanup by 6 to 8 additional years, and cost 8 to 10 times as much.

So ask yourself: 

Is the reduction of a barely measurable amount of risk worth the additional excavation, time, money, and transport of soil and debris through our surrounding communities? 

The added health risk to our surrounding communities grows from the added dust, fumes, truck exhaust, and traffic. So is the cleanup to “background” a responsible and necessary choice? The SSFL CAG thinks it is not.

My conclusion is that US EPA’s risk-based cleanup methods should be used at Santa Susana, as they are throughout the USA. The added soil excavation and transport required under the cleanup to “background” is unreasonable and unnecessary.

   A Member Viewpoint Item by Tom Nachtrab

August 11, 2014


Why Should We the People Believe Anything?

  1. DTSC says it will complete its draft EIR sometime in late 2015.
  2. DTSC says that soil removal will be a multi-year operation.
  3. DTSC says that the 2010 AOCs govern the NASA and DOE cleanups.
  4. The AOCs compel the cleanup to be complete by 2017.
  5. DTSC says it's optimistic that the cleanup will be complete by 2017.

To build necessary infrastructure and remove 2.5 million cubic yards of soil in 1-2 years is not possible.

Since DTSC speaks such a self-contradiction, why should we the people believe anything DTSC says? 

The people of DTSC are not mentally deficient.

They speak in such self-contradiction because they are hobbled by political compulsion.

The time has come to stop pretending that nonsense makes sense.

The time has come to throw out the 2010 AOCs and revert to the 2007 consent agreements.

 A Member Viewpoint Item by John Luker

August 10, 2014


Analysis: Dirt-Hauling Routes

On August 7 and 9, 2014, the California Department of Toxic Substances Control held public meetings on the cleanup of the Santa Susana Field Lab. DTSC announced a dozen potential SSFL truck and conveyor-to-rail routes for soil removal.

 MAP HERE              DTSC Meeting Summary HERE

___________________________________________________ 

Here is my assessment of the haul routes that DTSC is proposing for removing waste from SSFL.


I’ll work backwards from the map DTSC provided.


Routes #10 & 9 are completely unacceptable to Bell Canyon residents. I certainly don’t speak for the home owners association, and I’m sure they will be commenting themselves, but I can’t imagine they will allow the so much truck traffic to travel through their sleepy, affluent, residential community.


Routes #8, 8A & 8B are the routes normally traveled by trucks up to SSFL. Traditionally, large semis have used this route. Woolsey Canyon Road was constructed with this type of traffic in mind and is very suitable.


Here are the DOE estimates of soil volumes that are slated to be removed.1 These figures have been validated by DTSC and are considered accurate. An upper limit of 1,667,400 cu/yds of material are to be hauled away. Each truck holds 16 cu/yds; that’s 104,213 truckloads needed. The trucks also need to drive up Woolsey Canyon, so that doubles the number of trips. The deadline for the soils cleanup is 2017. DOE is estimating 35 (70 both ways) truckloads a day, 5 days a week, 50 weeks per year… that’s 11.9 years!!! Clearly the cleanup agreements (AOCs) are flawed and need to be revised. OR, increase the truck traffic to 150-300 trucks a day and you can accomplish this by 2017.


In addition, IF the land is to be returned to its “Natural State,” as some activists insist these agreements will accomplish, an equal amount of clean soil will need to be imported in order to return the land to its original topography… that would DOUBLE the truck traffic.


These soil estimates do NOT include the 500,000 cu/yds of soil that NASA would be required to remove or the soil that Boeing will be removing for their cleanup agreements. That would add another 30,000-50,000 additional truckloads.


The residents of Lake Manor will protest most vehemently if this amount of traffic is forced on our community.


Clearly, if these agreements are to be implemented, other haul routes are going to need to be identified.


Route #7 would take the waste out the front gate of SSFL through the dirt fire road named the North American Cuttoff, to Box Canyon, up Santa Susana Pass Road to the 118 freeway. The North American Cuttoff rolls through gated private property, so permissions from land owners would have to be obtained, or the property would need to be purchased.

The road would have to be engineered, re-graded, paved and made safe for large truck traffic. It is currently a single lane dirt road through mountainous terrain. The road would need to be doubled in width. The grading and paving would be difficult, expensive and permanently mar the mountainside. It would permanently damage the viewscape in Box Canyon and the noise of construction and truck traffic would affect the residents who value their properties’ solitude and quiet. It would negatively, permanently affect property values in the Box Canyon area.


Box Canyon Road would need to be re-engineered, widened and straightened out. It is VERY windy with MANY short radius turns that are inappropriate for large trucks. Permissions would have to be obtained from land owners, property would need to be purchased for road widening.


Box Canyon is also a commuter route from Simi Valley to the San Fernando Valley. During rush hour a continuous line of cars rolls down the canyon. I live here and it is a challenge to turn onto that road during the morning commute. That traffic will be disrupted during construction. A traffic study will need to be done to assess the impacts. In my mind it is an inappropriate route.


Route #6 would take the trucks from the front gate of SSFL down Black Canyon through the little community of the Susana Knolls. It has the same issues as Box Canyon plus it is much steeper. Without major re-engineering and straightening, it would be completely unacceptable. If this road is made to be acceptable, one of the “Unintended Consequences” may be its inadvertent conversion into another commuter route from Simi to San Fernando Valley during rush hour.

Of note, some activists who are pushing these draconian clean up agreements live on Black Canyon and in the Knolls. It will be interesting to see if they will allow the traffic to move through their community. My feeling is this community will protest most strongly against this route.


Routes #1, 2, 3, 4 & 5 all have the same issues. They are narrow, unimproved dirt fire roads that lead to heavily populated communities. Routes #4 & 5 are VERY steep and would likely be rejected. Routes #1 & 2 travel through open space/parkland set aside for its natural beauty and provide essential habitat for an ever-shrinking wildland above our community.


All these routes would need to be re-engineered, graded, paved and doubled in width. The impacts to wildlife, the environment and the viewscape will be permanent. It is doubtful that the communities that live at the end of these roads will allow the truck traffic to travel through their streets. It is doubtful that the park agencies that control this property would allow the permanent damage that would occur because of construction and traffic. These routes would negatively and irrevocably affect property values and quality of life.


Conveyor Route #A would leave NASA-owned property in Area I and travel through the Brandeis/Bardin Institute, owned by the American Jewish University. This route would cut through the area set aside as a summer camp for children. That summer camp would likely be closed.

Both conveyor routes have the same issues. It is not just a matter of plopping a conveyor belt down a steep mountainside. Access roads would need to be constructed along the entire length of the system to provide maintenance and repair. These mountainsides are very unstable; seismic studies would need to be financed and carried out. Permits for grading, digging, and construction would need to be obtained from multiple agencies. Studies about how it would affect endangered species would have to be carried out and a complete archaeological survey would need to be completed with the participation of Native American tribes. These routes would need their own Environmental Impact Report, or a large portion of DTSC’s EIR would be devoted to them. Permissions would need to be obtained from property owners along the routes since both cut largely through private property. Or property would need to be purchased from those owners.


The construction, noise, maintenance and operations will permanently affect the wildlife, habitat, viewscape and quality of life for the residents and owners of the property and the people who live in the communities nearby. They will negatively, irrevocably affect the value of the property owners’ investments.


Conveyor Route #B cuts through private property on the east side of Black Canyon, and also cuts through 4 parks set aside for the protection and preservation of habitat and open space. Sage Ranch, owned by the Santa Monica Mountains Conservancy, Lilac Lane, owned by Simi Valley and Santa Susana Pass State Historic Park. Rail Site #3 is in the middle of SSPSHP and L.A. City Chatsworth Park South. The map shows a dogleg for the conveyor system running through Lilac lane and, apparently, down the Devil’s Slide, a stage coach road constructed in 1860. The State Historic Park has historic features and archaeological sites that would be destroyed and the environment, viewscape and even the entire reason for the formation of the park would be destroyed and permanently altered. The train track at this location has a single line. A siding and loading yard would need to be constructed that would permanently and irrevocably alter the habitat, viewscape and property values of the parks. It would also completely, permanently, and irrevocably change the quality of life for the people of Chatsworth. This is unacceptable to my community! We will not allow this conveyor to be constructed! Period!


Both these conveyor systems would terminate at the railroad line that cuts through Santa Susana Pass. Right of way would need to be obtained, and since this is a single track, passing through 3 single-track mountain tunnels, new sidings and loading facilities would need to be constructed, properties on either side of the tracks would be affected and permissions from property owners would need to be obtained or property would need to be purchased. Rail site #1, 2a & 2b are immediately adjacent to a movie lot whose operation will be permanently impacted by the noise of construction and operations. These conveyor systems will permanently and irrevocably impact the quality of life and property values for residents and businesses.


Right of way, permissions from property owners, environmental studies, construction and the wait for an EIR will take years. It would be impossible for any of these alternate routes to be in operation before 2017, much less enable achievement of that cleanup deadline. Financing is also a question. Since these routes are the consequence of the Administrative Orders on Consent (AOCs) that were forced on NASA and DOE, both federal agencies, and the Boeing Co has separate agreements with DTSC governing its cleanup to a lower, residential standard, it is not unreasonable to assume that the federal government will not allow this undertaking, perhaps well-intended but certainly overly complicated and overwrought, to be financed by the American Taxpayer.

All the routes suggested are lawsuits waiting to happen. It is reasonable to assume, based on past history that this will tie up the cleanup in the court system indefinitely.

Of special note is Truck Route #3, through Runkle Canyon. This Route and Conveyor Route #A are the only 2 viable routes that I can see. Of all the dirt access roads, #3 is the only one with a grade reasonable enough for use by large trucks.

Route #3 cuts through property owned by KB Homes, a developer currently constructing 450 luxury homes at the base of the canyon. Route #3 would provide direct access to Area IV at SSFL over that developers’ property. It would be the realization of concerns expressed by the Santa Monica Mountains Conservancy last year in their DRAFT comments on NASAs EIS. They stated the probable “Unintended Consequences” of this cleanup will be a series of flat compacted (home-site) pads, all connected by a heavy duty road that would save a developer millions of dollars in infrastructure costs at taxpayer expense. These comments were suppressed without discussion by the SMMC board of directors.


The Santa Susana Mountain Park Association (SSMPA) is fighting to preserve 15,000 acres of open space in the Simi Hills and Santa Susana Mountains. One of our best tools against development is the lack of necessary secondary access routes for fire and emergency. This road would provide that access for KB Homes as well as access for their construction equipment. It is my opinion that it would lead the way for development of not only SSFL but the entire ridgeline above Runkle Canyon that directly abuts Ahmanson Open Space and the National Park Service’s Santa Monica Mountains National Recreation Area.


It is my understanding that several legislators who support these extraordinary cleanup agreements also support this route. Why is that?

In short, all these alternate routes are unacceptable in my mind.


The solution to the problem is to limit the amount of soil to be removed, either through in-situ treatment, containment or by changing the cleanup to an EPA risk-based cleanup, like every other superfund site in the country, or, by all the above. The 2010 Administrative Orders on Consent are the problem. They need to be revoked, renegotiated or DTSC needs to revert to the 2007 Consent Order that the Boeing Company is subject to, cleaning the property to a fully protective Suburban Residential Risk-Based Standard.

________________________________________ 

 1 Rough Order of Magnitude Estimates for AOC Soil Cleanup Volumes in Area IV, and Associated Truck Transport Estimates p. 26

 

 A Member Viewpoint item by David Karchem

July 27, 2014


Appropriate Questions for a Sensible Cleanup

Dr. Ron Ziman poses very appropriate questions in his In Pursuit of a Sensible Cleanup” of July 26, 2014 (see below):

“So now I come full circle to ask, "What attributes can be agreed upon by all reasonable people as a starting point to find common ground to be able to come together to achieve a sensible cleanup?"

 As Ron notes, it’s important to understand the types and amounts of the past contamination, AND the current levels of contamination. The cleanup should be based on current levels of contamination, regardless of previous cancer studies findings. If a supposed-cancer-causing agent is not present at a dangerous level, cleaning it up may not be appropriate, efficacious or fundable.

ALSO, RISK TO SURROUNDING COMMUNITIES must be evaluated, (e.g. it may cause more damage and health risk to do a highly-invasive level of cleanup than an alternative method, or more risky to do that level of cleanup compared to the health impacts. This can only be determined by risk analysis, not by blindly following the background cleanup proposal defined by the AOC contracts, which totally ignore risk of cleanup alternatives).

  A Member Viewpoint item by Ronald Ziman, MD

July 26, 2014


In Pursuit of a Sensible Cleanup

To paraphrase Margaret Wolfe Hungerford, like beauty, what a reasonable or sensible cleanup is, "...Is in the eye of the beholder," and must be based upon what that eye perceives.  Those attributes that can be agreed upon by all reasonable people is a starting point to find common ground to be able to come together to achieve a sensible cleanup.

The fact that the AOCs ignore risk requires the AOCs to assume the risk to be maximal under all circumstance.  This then mandates a maximal response -- "cleaning up to the highest level possible to protect our children."  How can anyone argue against that?  On the other hand, when budget constraints and cost calculations threaten such a cleanup, when the cleanup itself threatens neighboring communities health and safety, harms the environment and erases history, "cleaning to the highest level possible" may need to be redefined because the cleanup as defined is impossible.  It is not possible to remove 100s of acres of soil and then restore the land to its original state.  It has not even been possible to find soil clean enough to replace the soil removed.   It is not possible to preserve history, archeology, or anything else while at the same time removing it.  Perhaps the real Achilles heel is that it may not be possible to fund the cleanup as proposed.  

All these irreconcilable paradoxes of cleaning to the "highest level possible" disappear when it is realized and admitted that it is impossible.  Risk must be factored back into the cleanup.  That's why the presence or absence of greater than expected cancer rates or other health and safety concerns in the surrounding communities is both relevant and important.

  Those who justify a "maximal cleanup" base it in part on cancer rates, a direct reflection of cancer risk.  To then shout down, intimidate, personally attack and try to silence those who want to talk about cancer risk is completely illogical and irrational.  The baseline lifetime rate, and therefore risk, of cancer in the US is about 1 in 4.  At present there is no way to eliminate cancer.  No matter where you live some neighbors will have cancer, perhaps you or a family member will have or currently have cancer.  There are many factors that contribute to cancer, some known, others not.  As the population ages we see more cancer.  The individual's genetics play a role.  There is even the interaction between the individual's genetics and the environment including viruses, chemicals and radiation.  During the industrial revolution exposure to particular carcinogens was much higher than today but ignored because no one even knew about carcinogens.  Cancer rates today are higher than during the industrial revolution because people live longer now.  Today we have a much greater understanding of carcinogens, have more cancer and are trying to clean up the environmental carcinogens to the extent possible and practical.  

It is reasonable to conclude that in an ideal world risk need not be considered.  Any amount of any carcinogenic chemical, whether minor or major, or radiation must be removed.  Unfortunately we don't live in an ideal world; we live in a practical world.  If there is no demonstrable increase of cancer rates to the surrounding communities (not the former workers who obviously had potential for exposure to much higher levels of whatever than the surrounding off-site communities), then the non-existent incremental risk of cancer cannot justify what some eyes perceive to be the excessive cleanup mandated by the AOCs.  The normal risk-based cleanup is designed for what is present and the risk it poses, not for what theoretically could be.  We all want a cleanup.  The SSFL cleanup should be risk-based related to what is there and ultimate land use, just like almost everywhere else in the US.

So now I come full circle to ask, "What attributes can be agreed upon by all reasonable people as a starting point to find common ground to be able to come together to achieve a sensible cleanup?"

 A Member Viewpoint item by Tom Nachtrab

March 22, 2014

Attonement Time? 

Many folks assume that: 

cleanup to Background = return to Natural.

How can the result of a technological cleanup, especially a maximally intrusive cleanup to "background," be compared to a natural result?

Unfortunately, Man made a mess of some of the Hills that Nature crafted over millennia. Can Man now be expected to (play God and) re-create in a handful of years, what Nature made?

Presumptuous, no?

Maybe we need to accept that Man screwed up here, and the best we can do is clean up to a reasonable, very low level of risk, humbly learn from our arrogance, and preserve the scene of the offence against Nature as a reminder not to screw up so bad the next time.

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 A Member Viewpoint item by Abe Weitzberg

March 7, 2014


A Physical Example of Radiological Risk

Some of you may remember that I attempted to use a banana analogy to convey a physical sense of the units of picocuries/gram that are used in the DTSC radiological lookup tables. Unfortunately, some people were offended by my use of a symbol of healthy eating for anything to do with radionuclides.  During the DOE EIS Scoping Meetings, Richard Mathews stated that his handling of radioactive Cs-137 sources** while a physics student at CalTech gave him some experience with radioactivity and that supported his claim of hundreds of thousands of likely future cancer deaths from the contamination at SSFL. Since back in the day, I handled all sorts of radioactive materials, I decided to look into just what radioactive material was contained in the sources. I remember they seemed to contain a lot more than the picocuries we were talking about for background cleanup levels, and they might provide another physical example of the significance of picocurie/gram units.

** Sample radioactive sources are for testing the functionality of a geiger counter and for performing experiments involving radioactivity.

The attached document was taken from a short web search, and the url is included in case you want to go to the original website. The site lists sources for many radioisotopes, but I just copied the Cs-137 sources since Cs-137 appears to be the major background exceedence identified by EPA. Looking at the largest Cs-137 source in their catalog you will see that it contains 10 microcuries of Cs-137. Remember that that a microcurie equals a million picocuries. Thus, when you do the arithmetic you will find that this unregulated source that anybody can buy for $125 contains roughly as much Cs-137 as about 40,000,000 grams of SSFL soil at background Cs-137 concentrations. 40,000,000 grams converts to 40,000 kilograms or about 100,000 lbs or 50 tons.

If you repeat the exercise for the single Cs-137 exceedence at 196 pC/g , you will find that one unregulated 10 microcurie source contains as much Cs-137 as 52 kg of the most radiologically contaminated SSFL soil or 112 pounds. Also, note that the EPA and NRC risk evaluations for Cs-137 show that the external dose is by far the most dominant effect, so that comparing the risk from the small sources to the SSFL soil is valid.

This all means that a lot of dirt that would need to be removed from SSFL Area IV, based on the AOC cleanup to background or detect lookup tables, to accumulate the same amount of Cs-137 as in that single source. Yet the risk is so low that sources with this much radioactive material are permitted to be sold without regulation. This is why the AOC advocates do not want a risk-based cleanup. Most of the so-called radiological contamination poses little or no risk to on-site receptors and so could be left in place in a risk-based cleanup.


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