Conejo Post

Liz Crawford is a longtime activist in the Santa Susana Field Lab cleanup, and has worked as an aide to Supervisor Linda Parks, and as environmental advisor to Physicians for Social Responsibility (PSR-LA).  Liz sent in a letter to Susan Callery of the Department of Toxic Substances Control (DTSC) and to others, on 10-1-10, in regard to the Agreement in Principle (AIP).  The AIP is between the DTSC the U.S. Department of Energy (DOE)  and NASA, to cleanup the SSFL.  (Please see previous posts, http://www.conejopost.com/?s=agreement+in+principle )  With Liz’s permission, I am summarizing some of her concerns, and you can click on to “read more” for a full copy of her letter.

First of all, Liz congratulated the parties involved in coming to an agreement on SSFL cleanup.  Then she listed the following remaining concerns.  I will post only the first sentence of a paragraph and if you want the full text, click on the “read more.”  To quote Liz Crawford on areas of concern that remain:

1.   “Please ensure that radiological constitutents are screened for throughout all areas of the SSFL and Buffer Zones, rather than just Area IV.”

2.  “Please include groundwater testing, surveying and analysis – and recommended cleanup procedures – in the AIP, as the groundwater/soil interface is a continueing source of contamination and recontamination.”

3.  “I am concerned that the only solution considered in the AIP is to remove and truck away all materials considered ‘contaminated,’ even if those materials are slightly above what is considered natural background measurements.”

4.  “I am concerned that proper balancing criteria be established and employed when beginning to dertermine the resolution to these important decisions we’ll be undertaking in this cleanup.”

Here is the text of the 10-1-10 letter from Liz Crawford, with the first 2 paragraphs removed:

“First, I would like to applaud all parties for reaching an agreement that can open the way to determining an end to the issue regarding the extent and manner of the nuclear and chemical contamination at the Boeing/Rocketdyne SSFL; skipping the Risk Assessment step allows a ‘jump-ahead’ to achievable cleanup goals while extending health protections, de facto.

However, there are several areas of concern that remain, listed below:

1. Please ensure that radiological constituents are screened for throughout all areas of the SSFL and Buffer Zones, rather than just Area IV.  I believe this is the case but I want to ensure that the potential for nuclear contamination is the considered, screened for, and eliminated as a potential residual health hazard, throughout the site and buffer zones — not just chemical contamination.  Substantial evidence exists that nuclear materials were transported, stored, used, or variously disposed of across the site and not just Area IV, and a credible cleanup will certainly consider and prevent this potential exposure to remain.

2.  Please include groundwater testing, surveying and analysis — and recommended cleanup procedures — in the AIP, as the groundwater/soil interface is a continuing source of contamination and recontamination.  In the event that soil is cleaned up to an acceptable level — and then contaminated groundwater comes into contact with it — the soil will become re-contaminated, and all efforts to remove contamination will have been wasted.  And at this point in this long, never-ending story of SSFL Cleanup — everyone will have gone away, and the case will never be reopened.  So — please include a structure for groundwater testing, analysis, and recommended cleanup and management in the AIP, or it will remain a single-solution approach to a multi-layered problem, and any ‘cleanup’ resulting will be temporary, wasteful, and tragically final.

3.  I am concerned that the only solution considered in the AIP is to remove and truck away all materials considered ‘contaminated,’ even if those materials are slightly above what is considered natural background measurements.

There are many promising treatments available for in-situ treatment of radiological and chemical contamination — phytoremediation, mycelioremediation, and bioremediation (plants, mushrooms, bio-organisms, and so on).  Much promising data has resulted from these localized treatments, and we strongly recommend that their application in the SSFL cleanup be considered, tested and applied to further extents as results may indicate.

The ‘lunarscape’ that is likely to occur from a “remove everything above background’ is of concern; the trucking movement of that much material (not all of which may pose substantive health risks) is of concern; and the stunting of developing alternative cleanup methods is of concern.  On this site, at this stage, literally all potential solutions must be on the table.

I suggest developing a list of areas of contaminants that occur within margins of ‘background,’ and then apply natural remediation technologies as much as possible, to quickly devise the best methods of in-place remediation as can be achieved.

4)  I am concerned that proper balancing criteria be established and employed when beginning to determine the resolution to these important decisions we’ll be undertaking in this cleanup.  We must develop the proper tools to be able to evaluate differing and competing dynamics in our cleanup decisions (percentage above background against removal impact against trucking impact against realistic health impacts, etc.)  We must establish some method of evaluating each dynamic and then applying a reasonable ‘balancing’ procedure so that the best decisions can be made, at each step of the way.

The only way that skipping the Risk Assessment step in this cleanup can be achieved without harm to the ultimate cleanup goal is to develop these common-sense, believable balancing criteria to justify the important decisions we’ll be making as we move forward, irreversibly, in this cleanup process.  Only then can we be assured that community health will be ultimately protected.

5)  I am concerned about the removal, classification and disposal of nuclear waste.  Waste classification should be done using EPA guidance for soil segregation and classification, not by imposing a seemingly arbitrary standard for acceptance on facilities outside the state.  

6)  Ultimately, I feel that it is imperative we devise a solution that addresses proper detection, definition and sequestering of contaminants, source removal, erosion control, runoff migration, and a comprehensive soil/contaminant handling procedure throughout the cleanup.  

7)  The AIP needs to transform into an Administrative Order on Consent to be actionable; we strongly recommend that all Responsible Parties, including Boeing, sign this AOC, and these issues need to be addressed before the acceptance of this AIP, going forward.

8)  With DTSC’s favorable response to these issues, our community can go forward confidently and support the development of a cleanup plan that follows these strictures; with the outline of an AIP/AOC as described above, our community will definitely turn to Boeing and request with full sentiment that they join us, DTSC, NASA and the DOE in accepting this long-term solution to our mutual long-term headache — the proper investigation and cleanup of the Boeing/Rocketdyne Santa Susana Field Laboratory.”
Elizabeth Crawford

Text by Liz Crawford, photo by Janna Orkney