NASA Flooded With Thousands of Comments Demanding Full SSFL Cleanup

Tens of thousands of rocket tests have contaminated NASA's property at SSFL.

Tens of thousands of rocket tests over decades have contaminated NASA’s property at SSFL.

Thousands of commenters on NASA’s draft Environmental Impact Statement (EIS) for the cleanup of its portion of the badly polluted Santa Susana Field Laboratory (SSFL) demanded NASA fully meet all its obligations under the Administrative Order on Consent (AOC) it signed with the State of California in 2010, which requires cleanup of all detectable contamination.

Comments included letters from  Friends of the Earth, the Natural Resources Defense Council,Consumer Watchdog, the Southern California Federation of ScientistsFriends of the Los Angeles RiverPhysicians for Social Responsibility-LA, the Susana Knolls Homeowners Association, the Rocketdyne Cleanup CoalitionTeens Against Toxins, the Committee to Bridge the GapAerospace Cancer Museum of Education, and the community representatives on the SSFL Inter-Agency Work Group, as well as thousands of members of the public.

NASA property at SSFL is heavily polluted with TCE, perchlorate, dixions, PCBs, heavy metals and other hazardous chemicals that can migrate from the site and cause serious harm to health.

Below are questions and answers regarding the NASA’s draft EIS.

Why is it important to fully clean up SSFL?

Tens of thousands of rocket tests were conducted at that NASA portion of SSFL, resulting in significant chemical contamination. Hundreds of thousands of gallons of trichloroethylene (TCE) were used to flush out rocket test engines and then allowed to seep into the soil and groundwater. The site is also contaminated with perchlorate, dioxins, heavy metals, and volatile and semi-volatile organics that can cause harm to human health. These are very toxic materials that can cause solid tumor cancers as well as leukemia, and developmental, genetic, neurological, and immune system disorders, and more. Several studies have indicated elevated cancer rates associated with proximity to the site and exposure to the contaminants.

If SSFL is not cleaned up, the site will continue to threaten nearby communities via toxic migration. There have been over a hundred exceedances of pollution standards in runoff from the site reported to the LA Regional Water Quality Control Board injust the last few years. A TCE plume extends offsite. Perchlorate has been found in numerous wells in Simi Valley and in Dayton Creek in Dayton Canyon. Strontium-90 was found at Runkle Ranch. Other contamination has been found at Brandeis Camp, where a recent well tested over 100 times background for a radionuclide, and Sage Ranch where hundreds of cubic yards of toxic soil were removed. The headwaters of the Los Angeles River are located at the NASA portion of SSFL, and have already been impacted by stormwater run off from the contaminated site.

NASA’s EIS unfortunately omits an examination of this contamination and its impact on the environment. The DEIS has no discussion of the UCLA School of Public Health studies finding that the contamination at the site resulted in excess cancers among the workers. There is no discussion of the study by the federal Agency for Toxic Substances and Disease Registry (ATSDR) finding elevated rates of cancers of the bladder, thyroid, aerodigestive tract, and blood and lymph systems in people living offsite and associated with proximity to the site. There is no discussion of the extensive other study for ATSDR by Professor Yoram Cohen and his UCLA team showing that pollution from the site migrated offsite and at levels in excess of EPA acceptable limits. All this needs to be rectified. An honest EIS would focus in detail on the environmental impacts of the contamination to be cleaned up. This doesn’t do that, but seems intent on burying the real reason for the action–the extraordinary environmental damage done by NASA in contaminating its site and the need to repair that damage.

Will the cleanup cause a lot of truck traffic?

NO. If you look carefully at the numbers, they are really insignificant — a few trucks per hour. The EIS is silent about how many trucks have been going in and out of the site for decades. How much truck traffic was there when the facility was fully operating? How many car trips for workers?

A careful review of the EIS shows a lot of exaggeration and double-counting about the trucks. For example, it counts both trucks taking out contaminated soil or building debris, and adds to that trucks that might haul in clean fill. But there is no evidence NASA will need to bring in any fill, rather than simply regrade and use soil from the site. But if NASA needs any from offsite, the trucks going up to the site to haul away contaminated soil can haul up clean fill.

The purpose of an EIS in large measure is to identify mitigation measures. So, NASA should focus on regrading and using on-site soil; but it doesn’t do that in the EIS. NASA should require the use of natural-gas or electric vehicles rather than diesel trucks to reduce air emissions and global warming. But it doesn’t’t do that. NASA should consider the use of rail, but it doesn’t do that. There is no consideration of improving a fire road leaving the site and then taking by truck some of the shipments a different route, or taking the material that way to a rail spur. Again, NASA doesn’t do that. NASA can identify additional routes once you get down Woolsey, but it didn’t do that. And even for the three routes NASA identified, it could require the trucks to be dispersed over those routes, so none gets more than one or two trucks an hour. Again, NASA refuses to do that. NASA simply refuses to consider any mitigations to the trucks at all, saying it might add time or money. But that is not a reason to refuse to consider appropriate mitigations. .

Does the cleanup hurt Native American artifacts?

NO. The AOC already provides protections for recognized Native American artifacts. For example, if the Burro Flats cave paintings could be impacted at all by the cleanup, which seems hard to believe, the AOC provides an exception to the cleanup to background requirement. The cave paintings are entirely protected! But the EIS goes way beyond the AOC provisions and seems to raise the possibility of just declaring all of the contaminated soil throughout the entire 2850 acres of the site sacred and then not comply with the AOC cleanup requirements all. This is unacceptable and would completely violate the agreement.

Should the old rocket test stands be removed?

YES. Much of the contamination on NASA’s property is located under the test stands. That is where the contamination was centered, because of the sloppy practices during the rocket tests. In order to remove the toxic chemicals, the test stands need to come down. If NASA is concerned about its legacy of achievement, it should clean up the mess it made. The AOC requires all contamination to be removed, but the EIS considers leaving in place old rocket test stands, trying to call them historical. The problem is that that is where much of the contamination is located, in the soil beneath the stands. NASA can’t clean up the soil without getting those rusty structures out of the way. There is no discussion of how NASA could possibly clean up the contamination beneath the rocket test stands without getting them out of the way. Any such consideration should be removed from the EIS.

In the EIS, NASA suggests that the old rocket test stands not be demolished and instead be considered “historical.” However, NASA is fully aware that much of the contamination is located at the test stands, and that there is no way to clean up the contamination without removing them. This is a direct violation of the AOC, and would also have impact on the surrounding communities as the contaminants continue to migrate offsite.

Will the cleanup harm the site’s natural habitat?

NO. The areas that need to be cleaned up are are not pristine areas in the first place. The contamination occurred primarily in the areas of heavy NASA activity, where the soil had already been scraped away, structures like test stands constructed, and huge amounts of pollutants just dumped in the soil. By NASA’s own estimates, only ~0.5% of SSFL will be priority conservation habitat that might get disturbed by cleanup, representing 0.05 acres of southern willow scrub and 7 acres of Venturan coastal sage scrub; and under another exception of the AOC, even this can be avoided. And even if that small amount of land is cleaned up, it would then be replanted with native vegetation.

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