State toxics department white papers over Brandeis-Bardin contamination

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DTSC skews toxics standards for Jewish children camp to declare it safe

A comprehensive EnviroReporter.com analysis of the Department of Toxic Substances Control’s “white paper” on the Brandeis-Bardin Institute finds the document gravely flawed.

The DTSC paper, released May 2 and produced due to pressure from BBI’s owners according to recent media reports, said that the 2,878-acre Jewish camp was free of radiation and chemical contamination from the bordering, and uphill, Santa Susana Field Laboratory (SSFL). Abundant evidence to the contrary was exposed in EnviroReporter.com‘s Brandeis-Bardin’s Toxic Denial April 6, three weeks before the white paper was released.

DTSC’s white paper ignored three 2016 Department of Energy (DOE) and NASA studies that showed radioactive and chemical toxins at Brandeis-Bardin. Indeed, EnviroReporter.com only knew of of two of these studies because DTSC sent them along with many others on its list serve.

So numerous and serious were the faults of the DTSC report that EnviroReporter.com has produced a line by line analysis called 2017 DTSC Brandeis-Bardin ‘White Paper’ Analysis. The analysis helps connect the confusing DTSC dots and allows the reader to better understand this taxpayer-funded debacle designed to debunk decades of data that demonstrate the extent and severity of the contamination.

DTSC “utilized all available data in the last 25 years” said DTSC’s Mohsen Nazemi at a May 11 conference call for the press explaining the white paper. (Initially DTSC denied EnviroReporter.com access to the presser but even after it did relent, failed to answer any of this reporter’s questions.)

“Based on the state and federal screening guidelines and review of the available data and sampling efforts that has been done in the last 25 years, DTSC has determined the levels of chemicals and radionuclides found on the Brandeis-Bardin Institute campus do not indicate a threat to students, faculty, campers, staff or any visitors,” Nazemi said in a statement he made opening the press conference call.

“I’ll suggest as a quick background,” Nazemi continued. “I think the issue of contamination may have been back in the ‘90s. In 1995, based on the early 1990 studies, the U.S. EPA determined that while radionuclides levels in some areas exceeded local background levels established at the time, they still did not pose a threat to human health or the environment and were below levels typically found throughout the United States. Then in 1997 Boeing purchased the area of the Brandeis-Bardin property with highest radionuclides and incorporated it in the Santa Susana Field Laboratory site and refer to it as the Northern Buffer Zone. Then US EPA in 2012 sampled those areas and confirmed that contamination from Santa Susana Field Lab is controlled at the Northern Buffer Zone and is not entering the Brandeis-Bardin property.”

Nearly nothing Nazemi said in this prelude to reporters’ questions was true. While carefully choosing his words, Nazemi later said that DTSC had looked at everything on BBI contamination. “[DTSC] looked at whole history of data that was available and did evaluation based on that data.”

But the white paper’s list of reports analyzed left out the most important recent data. Simply comparing the Brandeis-Bardin’s Toxic Denial reports page with DTSC’s thin Resources list illustrates the point.

READ THE ENVIROREPORTER.COM ANALYSES:

DTSC Brandeis-Bardin ‘White Paper’ Analysis

1991-2017 Brandeis-Bardin Reports Analysis

DTSC ignored the most obvious “available data” including a January 20, 2016 DOE report that the department had actually sent to EnviroReporter.com but did not include in its BBI white paper. That report showed a trio of BBI wells with Area IV nuclear fingerprints.

The study stated that several Brandeis-Bardin wells far from the current border with Area IV were recommended for future sampling because “Cadmium-113m neutron activation of Cadmium-112 used in reactor control rods – possibly site process related” was found. [Original report emphasis] Nor does DTSC divulge that DOE reported on another well in the same area that had the radionuclide tin-126 and that “Tin-126 is a fission product and is possibly site process related.” [Original report emphasis] This crucial information indicates that SSFL radiation has migrated down into Brandeis-Bardin groundwater. It was completely ignored by DTSC’s white paper.

Also absent from the white paper was a November 2016 NASA report showing levels of fluoride in Brandeis-Bardin artesian well SP-29B that exceeded the California Maximum Contaminant Level (MCL) for it in drinking water. SP-29B’s 4.8 milligrams/liter is more than double the MCL for the chemical. A reading of 4.2 mg/L in the same well in the 1st Quarter of 2017 showed that the toxic level of fluoride in Brandeis-Bardin water increased over that period.

Nazemi claimed that “some areas exceeded local background levels established at the time, they still did not pose a threat to human health or the environment,” ignoring a 2016 DOE-AJU Summary Brandeis-Bardin Soils report showing numerous SSFL-related chemicals exceeding their background levels by multiple times.

Nazemi said that the US EPA had said that the Northern Buffer Zone effectively “controlled” radioactive and chemical goo, preventing it from entering BBI. But US EPA never said anything of the sort and indeed told DTSC quit making this false claim.

Likewise, the NBZ does not prevent contamination from sloshing down into Brandeis-Bardin in the rain, stop polluted dust from settling in the camp below or prevent SSFL’s intensely contaminated groundwater from spurting out of seeps, springs and wells downhill of the 2,850-acre hilltop complex into BBI. EnviroReporter.com photographs, government reports and DTSC’s own maps illustrate this.

Nazemi towed DTSC’s party line again when the questioning began. “DTSC believes that the limited number of these very low level concentrations in the NBZ do not indicate a contamination migration pathway from SSFL source area into the NBZ. This information along with other multiple lines of evidence was evaluated that led to the DTSC’s conclusion that there was no migration of radionuclide contamination.”

This reporter was permitted just one question of Nazemi and was cut off while asking it. Why DTSC hadn’t included the two 2016 DOE reports and the 2016 NASA study in the BBI white paper was the gist of the query. “We are familiar with those reports and we have evaluated those reports but if you are getting into too many specifics about specific compounds then I really have to get back to you so we’ll be happy to have Rosanna communicate back with you about your specific question.”

EnviroReporter.com‘s question was never answered, which is a routine common to the controversial department throughout the last decade. Nazemi did inadvertently admit, however, that DTSC was aware of the missing reports confirming yet again that the white paper ignored the recent results of government agencies showing SSFL goo impacting the Jewish camp.

Deflecting tough questions didn’t stop EnviroReporter.com from examining the white paper in detail after the press conference. The report, authored by DTSC project manager for SSFL Mark Malinowski, is not an easy read. The longstanding community cleanup organization, the Santa Susana Field Laboratory Work Group, called it “a super-sized word salad filled with extraordinary misrepresentations of the existing data” before noting that “Numerous detailed and credible studies indicate offsite migration and harmful health risks from SSFL contamination. BBI itself even sued and settled with Boeing over the contamination. Yet none of this and other critical information was included in DTSC’s paper.”

What was included was a “risk assessment” analysis for camp visitors and staff that allows vastly higher amounts of radiation and chemicals to be considered safe at BBI versus Area IV where DOE signed an agreement with DTSC to clean up any and all contamination to background levels. NASA has an identical Administrative Order on Consent with the state EPA’s toxic department to clean up its areas of SSFL activity.

Those areas of activity include offsite zones like BBI where contamination is clearly from SSFL. DTSC and DOE have repeatedly said that they would remediate to background any toxins found offsite which, of course, includes Brandeis-Bardin. DTSC’s white paper changes all that with its convoluted risk assessment. The results, though, are shocking.

One of the two most concerning radionuclides emanating off of Area IV is strontium-90. DTSC’s standard for the camp is 42 times higher than the required DOE cleanup level for strontium-90’s BTV for Area IV which will likely end up as a park eventually. Just three times background of any toxic substance, especially a bone and blood cancer-causing radioisotope like strontium-90, is major cause for concern. According to documentation obtained by EnviroReporter.com, the California Highway Patrol considers any radioactive material over three times background to be the triggering level for a hazardous materials incident requiring a full HazMat response.

“When DTSC does concede radiological contamination above background, it falsely claims it is below the Risk Based Screening Levels for residential exposure, when in fact the readings are above those levels,” said the Santa Susana Field Laboratory Work Group. “DTSC does this by misrepresenting the residential risk based levels by factors of thousands. It claims, for example, that the EPA residential preliminary remediation goal is about 4 picocuries per gram, when in fact it is 0.0036.”

That works out to DTSC inflating the amount of radiation considered safe at Brandeis-Bardin by 1,111 times.

DTSC uses these weaker standards in the white paper to assert harmless levels of contamination at Brandeis-Bardin, going so far as to claim that all chemicals at BBI are at background. EnviroReporter.com exposed, and proved, that 21 Brandeis-Bardin soil samples exceeded their respective Area IV “background threshold values” (BTVs) for a slew of toxic substances.

The heavy metal antimony came in at triple background in the 2016 DOE report given to AJU which sent it to Jewish Journal that then published it unanalyzed. The polycyclic aromatic hydrocarbon (PAH) naphthalene, which has caused cancer in animals, topped out at 5.4 times its BTV. The PAHs fluorine and phenanthrene came in at 5.7 and 6.9 times their respective backgrounds.

When jiggering the standards weren’t enough to make high hits go away, the DTSC white paper discounts the readings as ‘lab mistakes’ providing no proof to the assertions other than they are high readings, hence automatically suspect to DTSC. Failing that, DTSC claims chemicals in Brandeis-Bardin “may not be from SSFL sources.” One farfetched explanation used for the toxic fuel oxidizer perchlorate being found in Brandeis-Bardin well water, fruits, vegetables and milk is that it somehow could conceivably be ‘natural.’

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