P. 4/63: Based on an additional statistical analysis of the 17 samples (Samples SS-1 through SS-17; Figure two) duplicate samples. Samples SS-18 and SS-19 collected on the Site the average strontium-90 concentration was calculated at 0.88 pCi/g and the 95 percent upper confidence limit of the mean was calculated at 1.4 pCi/g (Table 1). Therefore, on average, the strontium-90 concentrations detected in soil are lower than the acceptable standard for strontium-90 calculated by Foster Wheeler (1.23 pCi/g). Although the 95 percent upper confidence limit is higher than the 1.23 pCi/g the difference is not statistically significant. The incremental cancer risk associated with strontium-90 concentration of 1.4 pCi/g is 0.55 in a million which is lower than the incremental cancer risk of in million that is considered acceptable by California health and environmental protection regulatory agencies Robles 2003 and Foster Wheeler 1999.
Analysis of these 41 documents provided to DTSC by KB Home reveals a disturbing pattern: the propensity to make generalizations not based on fact and to assert risk-based conclusions without mathematically proving them. The preceding section is no exception to this pattern.
“Therefore, on average, the strontium-90 concentrations detected in soil are lower than the acceptable standard for strontium-90 calculated by Foster Wheeler (1.23 pCi/g),” is a statement not based on anything EnviroReporter.com can find in regulatory guidance or standard scientific practice. The EPA’s Preliminary Remediation Goal (PRG) for strontium-90 is 0.230 pCi/g which is exceeded by this Foster Wheeler calculated result by a factor of 5.35 times, or a cancer risk of 5.35 in a million, far exceeding the developers’ labs oft-stated goals of less than one in a million.
Likewise this unsubstantiated claim: “The incremental cancer risk associated with strontium-90 concentration of 1.4 pCi/g is 0.55 in million…” This result actually calculates to be 6.09 times the EPA’s PRG which is exceeds the 0.55 in a million figure by a factor of over 11 which is quite a mistake in our analysis of the data.
P. 6/63: Environmental investigations conducted at neighboring properties showed that strontium-90 was present in soil at concentrations that were deemed to be either within background concentrations or at levels considered to pose no significant health risk (Robles 2003).
This is incorrect. Elevated strontium-90 soil readings above background concentrations were found at the adjacent Brandeis-Bardin Institute in two dozen samples according Boeing’s 1995 McLaren/Hart report “Additional Soil and Water Sampling – The Brandeis-Bardin Institute and Santa Monica Mountains Conservancy,” which is cited in this report.
+++++++++++++++++++++++++++++++++++++++++++++++++++
September, 17, 2003: Runkle Canyon_Miller Brooks_Site Investigation of Western 350 Acre Parcel_91703
P. 3/50 pages of the PDF: The strontium-90 concentration in Sample SS- 16
(0.686 pCi/g) was found not to exceed exposure limit considered to be protective of human health (1.23 pCi/g; Foster Wheeler, 1999 and Harding ESE, 2000).
Again, it seems that Miller Brooks either ignores or does not understand the EPA’s concept of Preliminary Remediation Goals which are limits that correspond to a cancer risk of one in a million. The 0.686 pCi/g reading is nearly three times the PRG for strontium-90 and is nearly 23 times background for the area. Likewise, the reference to Foster Wheeler’s 1.23 pCi/g reading being “protective of human health” is also false.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
+++++++++++++++++++++++++++++++++++++++++++++++++++
September 17, 2003: Runkle Canyon_Miller Brooks_Site Investigation Report 550 Acre Parce_91703
P. 1 of this 102 page PDF: The average strontium-90 concentration in surface soil is about 0.1 pico Curie per gram.
This concentration is not applicable to the Simi Valley area which the EPA estimated in 1995 was 0.052 pCi/g and later determined by EnviroReporter.com to be actually 0.030 pCi/g utilizing averages for the area derived from EPA results.
EnviroReporter.com readers have asked us why the area’s background measurements for strontium-90 are about a third of the average nationwide, especially considering the proximity to Rocketdyne, site of at least two partial nuclear meltdowns. Our reply is that most strontium-90 fallout from atomic and hydrogen bomb above ground testing in Nevada made its way eastward on prevailing winds thereby not impacting areas to the west of it as much. Simi Valley and Runkle Canyon are substantially west of the now-inoperable Nevada Test Site.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
+++++++++++++++++++++++++++++++++++++++++++++++++++
September, 17, 2003: Runkle Canyon_Miller Brooks_Surface Water&Groundwater Sampling Rpt_91703
P. 6 of this 146 page PDF: In addition soil samples surface water samples from springs and seeps and National Pollutant Discharge Elimination System (NPDES) discharge samples collected by the Department of Toxic Substances Control (DTSC) and The Boeing Company (Boeing) at or near the Runkle Canyon Property as part of the Rocketdyne Propulsion and Power Santa Susana Field Laboratory (SSFL) sampling programs show no detectable concentrations of perchlorate. Perchlorate at levels ranging between 130 to 156 times less than the Environmental Protection Agency (EPA) Preliminary Remediation Goals (PRG) for perchlorate in residential soil 7.8 milligrams per kilogram was detected in two groundwater/silt samples collected at depths greater than 35 feet below the surface of the Property Based on the depth of the two silt samples impacted with perchlorate the extremely low levels of perchlorate detected in those samples the non-detectable levels found in all other samples and the lack of exposure pathways there is no indication that activities at the Property surface will be impacted by perchlorate.
Miller Brooks repeats the same misleading and deceptive information that it has in other reports regarding this sampling. The perchlorate was found in the groundwater of the groundwater/silt samples therefore to use PRGs for residential soil is not appropriate. Water standards show that the 0.06 mg/kg, or 60 ppb, exceeds the Public Health Goal in tap water by a factor of ten times.
P. 11/146: Miller Brooks testing of surface water consists solely of examining the leachate of asphaltic material found in the middle of the road. No analysis of the actual surface water in the intermittent stream or vernal pools occurred and yet, in spite of the name of this report, the lab asserts, falsely as later found out by the Radiation Rangers, that the surface water has no heavy metal contamination.
P. 53/146: Arsenic soil reading of 3.3 mg/kg exceeds its soil PRG of 0.062 mg/kg by a factor of 53.23 times.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
+++++++++++++++++++++++++++++++++++++++++++++++++++
May 21, 2003: Runkle Canyon_Miller Brooks_Asphaltic Material & Surface Water Sampling_52103
P. 7 out of this 43 page document: As we reported in the June 21, 2007 Los Angeles CityBeat cover story “The Radiation Rangers,” Miller Brooks did not test the surface water for heavy metals:
The city soon informed the Stop Runkledyne group that KB Homes had reminded them that they had already tested the surface water and had submitted that information in a comprehensive 42 page report that was already in the development’s EIR. That 2003 report by Huntington Beach-based Miller Brooks Environmental Inc. tested one asphalt sample and a nearby surface water sample.
In the body of the report, Miller Brooks writes that Title 22 metals were “below state and federal regulatory limits (see Table 1).” Indeed, Table 1 actually says that the Title 22 metals in the surface water sample were “not analyzed.” Oddly, the Title 22 metals were tested in the asphalt but not in the water.
+++++++++++++++++++++++++++++++++++++++++++++++++++
May 8, 2003: Runkle Canyon_Miller Brooks_Phase I & II_Pgs 1-120_50803
P. 23 of the 120 page document: Perchlorate was detected in groundwater/silt samples collected from 56 feet and 37 feet bgs respectively in Borings HS-25 and HS-26 at concentrations of 0.006 mg/kg and 0.05 mg/kg respectively The perchlorate was detected in the silt/groundwater samples at concentrations below the EPA PRG for residential soil (7.8 mg/kg). Therefore the perchlorate does not pose threat to human heath [sic].
As EnviroReporter.com has commented on this sampling repeatedly, using a soil standard for this result is incorrect. A water standard is correct. Also, the figure of 0.006 is a typo – the true measurement is 0.06 parts per million or 60 parts per billion for water.
+++++++++++++++++++++++++++++++++++++++++++++++++++
May 8, 2003: Runkle Canyon_Miller Brooks_Phase I & II_Pgs 121-205_50803
EnviroReporter.com has no comments on this part of this Miller Brooks report.
+++++++++++++++++++++++++++++++++++++++++++++++++++
May 8, 2003: Runkle Canyon_Miller Brooks_Phase I & II_Pgs 206-362_50803
EnviroReporter.com has no comments on this part of this Miller Brooks report.
+++++++++++++++++++++++++++++++++++++++++++++++++++
November 3, 2000: Runkle Canyon_Harding_Limited Soil Sampling_Pages 172 to 342_110300-2
EnviroReporter.com has no comments on the data section of this part of Harding report that aren’t already included in our comments on the first part of the report below.
+++++++++++++++++++++++++++++++++++++++++++++++++++
November 3, 2000: Runkle Canyon_Harding_Limited Soil Sampling_Pages 1 to 171_110300
P. 9 of this 171 page PDF: Review of the applicable radionuclides results (Table 1) indicated that the concentrations of tritium in all of the samples collected were below the minimum detectable activity (MDA). In addition, the concentrations of cesium -137 in all of the samples except S-I were also below the MDA The cesium-137 concentration in sample SS-1 at 0.09 pCi/g just exceeded the MDA of 0.077 pCi/g In terms of strontium -90 results, six of the seventeen original samples submitted exceeded the MDA in concentrations that ranged from 4.756 pCi/g in SS-6 to 0.686 pCi/g in SS-16.
The cesium-137 exceeds the EPA’s Preliminary Remediation Goal for an unrestricted residential setting. The 0.09 pCi/g cesium-137 result is 151% of the PRG of 0.0597 pCi/g.
The strontium-90 ex exceeds the EPA’s Preliminary Remediation Goal for an unrestricted residential setting. The 0.686 pCi/g strontium-90 result is 297% of the PRG of 0.231 pCi/g.
The 4.756 pCi/g strontium-90 result is 2,059% of the PRG for Sr-90 or over 20 times the strontium-90 PRG.
The report goes on to compare this numbers to the Department of Energy’s “dose-based” figures for the radionuclides, which is not how the Environmental Protection Agency calculates radiation danger. The EPA uses a risk-based numerical approach embodied by the use of Preliminary Remediation Goals.
The report goes on to show that the highest numbers were the ones closest to Rocketdyne, which EnviroReporter.com maintains that it indicates that the radionuclide may have come from the lab, and that “further systematic random soil sampling should be performed.”
+++++++++++++++++++++++++++++++++++++++++++++++++++
October 19, 2000: Runkle Canyon_Miller Brooks_Phase I & Soil Sampling_Pgs. 98-307_101900
EnviroReporter.com‘s comments on this report are following in the Miller Brooks October 19, Pages 1-97 section.
Recent Comments