Thousands of community members, as well as elected officials and environmental health organizations submitted comments on the Department of Toxic Substances Control (DTSC) draft Program Environmental Impact Report (PEIR) for the SSFL cleanup. The PEIR breaks years of promises that the radioactive and toxic chemical contamination would be completely cleaned up. Instead, it proposes to leave vast amounts of plutonium, strontium-90, cesium-137, perchlorate, PCBs, volatile organic compounds, dioxins, and heavy metals, where they could continue to migrate offsite and place neighboring communities at risk.
Over a thousand local residents submitted individual comments urging DTSC to keep its SSFL cleanup commitments. A petition launched by Melissa Bumstead, a parent whose young daughter had leukemia and has led advocacy efforts on behalf of families impacted by pediatric cancer near SSFL, now has over 100,000 signatures. (You can still sign and share the #1million parents petition!)
Comments from Governments and Elected Officials
- City of Los Angeles, NRDC, and CBG Joint Letter
- Ventura County Board of Supervisors
- LA County Board of Supervisors Chair Sheila Kuehl
- U.S. Congresswoman Julia Brownley
- California Senator Henry Stern
Comments from Community, Health, and Environmental Organizations
- Natural Resources Defense Council and Committee to Bridge the Gap – detailed supplemental comments. See related chemical comparison charts
- Physicians for Social Responsibility-Los Angeles (includes new report: “Analysis of Boeing’s Risk Assessments for the Santa Susana Laboratory”)
- Southern California Federation of Scientists
- LA Audubon
- Rocketdyne Cleanup Coalition
- Susana Knolls Homeowners Association
- Nuclear Information and Resource Service
Key problems with DTSC’s draft PEIR:
- DTSC’s draft PEIR is essentially a breach of the commitments DTSC had made to require a full cleanup. It includes proposals that would violate the AOC cleanup agreements it signed with DOE and NASA. For Boeing’s part of SSFL, the EIR blocks from even being considered cleanup to the standards DTSC hand long promised. Instead, it says the very best that would be done would be cleanup standards nearly thirty times less protective than DTSC’s own official residential cleanup levels, and far less than the promised cleanup to agricultural/rural residential and background standards.
- Amazingly, the PEIR has a thousand pages of all the supposed negative impacts of doing a cleanup, but nothing on the negative impacts of the contamination and the health and environmental harm that would occur if the pollution isn’t cleaned up. By omitting cancer risk information and hyping potential negative impacts of the cleanup, the EIR presents a biased and inaccurate assessment of the SSFL cleanup. It is essentially a PR attack on the cleanup commitments DTSC itself had made.
- DTSC’s PEIR contemplates leaving large amounts of contamination in place, which it refers to as “natural attenuation.” This means just leaving the toxic materials and hoping they lessen over long periods of time. It also violates the AOC cleanup agreements, which prohibit even considering leaving contamination in place.
- DTSC’s PEIR says that it intends to exempt from cleanup unspecified but apparently huge amounts of contamination for purported biological and cultural reasons, which appear to be far beyond the narrow exemptions allowed under the cleanup agreements. The real threat to the ecology – which is not examined at all in the EIR – is the radioactive and chemical contamination, which needs to be cleaned up to protect ecological features as well as people.
- Though DTSC in 2010 promised a cleanup for Boeing’s property that would be equivalent to that required for DOE and NASA, the EIR now says Boeing will be allowed to do a less protective than that in the DOE and NASA agreements. Furthermore, it excludes from consideration a cleanup to background or to the rural residential standards previously promised.
- The PEIR even excludes consideration of DTSC’s own official suburban residential standard, and puts forward instead one that is nearly thirty times less protective. In other words, the very best DTSC is now considering would leave contamination concentrations nearly thirty times higher than DTSC’s own official goals for what is safe for suburban residences, and far higher than even that compared to the cleanup levels DTSC has long promised. Furthermore, the PEIR indicates that Boeing will be allowed to also leave large amounts of contamination in place, for similar “natural attenuation” and unspecified biological and cultural exemptions.
- The PEIR also fails to disclose what DTSC is actually proposing to not clean up. It is absurd to release a report that gives no real information about what the proposed cleanup amounts will be. DTSC hides the ball—it keeps hidden how much contaminated soil it contemplates not cleaning up, saying that it will disclose that only after the PEIR is finalized. This flies in the face of environmental law, which is to disclose and analyze in the PEIR, not shielding from public view its intentions until after the PEIR is over. And by only giving information about supposed impacts to the environment from cleanup and excluding information on risks to health and the environment from the contamination itself and from not cleaning it all up as promised, the PEIR misrepresents all risks.
To make matters worse, Boeing launched an unscrupulous campaign to try and convince the public and elected officials that it will “protect” SSFL by walking away from almost all of the contamination it is responsible for cleaning up! The community fought back with a new website, Protect Santa Susana from Boeing, which counters Boeing’s outrageous disinformation. You can read the Rocketdyne Cleanup Coalition’s press release about the new website here.