ENVIRONMENT POLITICS--Why are responses to comments from the City of Los Angeles not publicly available in the associated City Council files?
- Why are comments from the City of Los Angeles to the California Department of Toxic Substances Control (DTSC) for their Draft Programmatic Environmental Impact Report (Draft PEIR) on the Santa Susana Field Laboratory (SSFL) site only found either on the Committee to Bridge the Gap website, as in the case of the comment letter from the NRDC, Committee to Bridge the Gap, and the City of Los Angeles’ City Engineer?
- Why is the only place the City of Los Angeles’ comments to the Department of Energy (DOE) for the Santa Susana Field Laboratory (SSFL) found buried deep in the DOE’s Responses to Comments for the DOE SSFL’s Final Environmental Impact Statement (FEIS)?
- Why does it appear that the comments being made in each case are by Committee to Bridge the Gap? Are the officials of the City of Los Angeles aware that one reason for the delays in the cleanup of the SSFL site, and the delays in the documents that are necessary to determine the cleanup (Final Environmental Impact Reports, Final Environmental Impact Statements, and Records of Decision) may have been held up by the ongoing litigation by Committee to Bridge the Gap et al against DTSC and the California Department of Health (CDPH)?
- Does the coupling of the City of Los Angles with Committee to Bridge the Gap create a Conflict of Interest with the City of Los Angeles’ need to independently and objectively assess the potential public health, public safety, and environmental impacts of the SSFL site cleanup when there is ongoing litigation by Committee to Bridge the Gap against DTSC and the California Department of Health (CDPH)?
When I read a comment document which was signed by the City of Los Angeles’ City Engineer, I wondered who at the City of Los Angeles had read the DTSC’s Draft PEIR in order to comment upon it. That document referenced two studies – one health study of former employees (not all of whom worked at the Santa Susana site), and one former UCLA Study on Potential Offsite Risk.
The studies referenced by the City of Los Angeles’ City Engineer in this letter to DTSC are the former worker health studies from 1997 and 1999: “Morgenstern, Froines, Ritz, & Young, UCLA School of Public Health, Epidemiologic Study to Determine Possible Adverse Effects to Rocketdyne/Atomics International Workers from Exposure to Ionizing Radiation,” June 1997; and, same authors, “Epidemiologic Study to Determine Possible Adverse Effects to Rocketdyne/Atomics International Workers from Exposure to Selected Chemicals, January 1999.” The problem is – you cannot compare former worker exposures to those of future users of the SSFL site.
The authors of this letter also reference the study by “Yoram Cohen et al., Center for Environmental Risk Reduction, UCLA, The Potential for Offsite Exposures Associated with Santa Susana Field Laboratory, Ventura County, California,” February 2, 2006; and Hal Morgenstern et al., “Cancer Incidence in the Community Surrounding the Rocketdyne Facility in Southern California, February 2007”; both prepared under contract to the federal Agency for Toxic Substances and Disease Registry.”
About a decade ago, UCLA had a website which referenced the epidemiological studies that they had done on former workers who had worked at the Santa Susana Field Laboratory (SSFL) aka: Rocketdyne site. They had a study on “Potential Offsite Exposures” (the one referenced above), and a study done by Dr. Hal Morgenstern a former UCLA epidemiologist.
On this website, there was a disclaimer that with all of these studies, the epidemiologists at UCLA could not state if an individual’s cancer was caused by any specific site.
An updated PowerPoint presentation was given of the UCLA Offsite Study at the “SSFL Workgroup” meeting via video by Dr. Adrienne Katner formerly of UCLA who had worked on the initial potential offsite exposure study.
What some people do not seem to understand is that in this presentation, Dr. Katner is only addressing Santa Susana Field Laboratory and offsite data up to 2003.
Dr. Katner states:
- “No conclusions made with regards to real risks.”
- “Report characterizes potential exposures up to 2003” and
- “No knowledge of current status of site.”
With that in mind, why was a presentation being made to the public in 2014 that does not reflect the current status of the SSFL site and the offsite risks as they are today or were at the time of the presentation?
The letter to DTSC from the City of Los Angeles’ City Engineer, the NRDC, and Committee to Bridge the Gap references these two studies, and it states: “The public that resides in the area surrounding the site will be at continued and perpetual risk if DTSC continues on this course.”
Why are these entities leading the community to believe that there is still an offsite risk from the SSFL site today when both the DTSC and the Federal EPA have made statements to the contrary?
This is from the EPA’s May 2012 Fact Sheet: “Site access is restricted and therefore, the public is not exposed to this contamination.”
A second letter from the City of Los Angeles – this time, signed by our City Attorney, Michael N. Feuer, also on letter head with the NRDC and Committee to Bridge the Gap, is only found by searching a 1786 page responses to comment document for the DOE SSFL”s Final Environmental Impact Statement which can be found here. See Volume 3 (Comment Response Document). Due to the size of that document, I have printed and scanned the letter from the Los Angeles City Attorney, NRDC, and Committee to Bridge the Gap which, with the DOE’s comments attached, is a 57-page document.
This letter to the DOE cites the SSFL Advisory Panel. It appears that the City Attorney and whoever else authorized this letter are not aware of the State of California’s statements by the California Department of Justice (DOJ) in the current litigation by CBG et al that there was no “partial meltdown” at the SSFL site. The City Attorney and his staff also are probably unaware of the inconsistencies with the summary by SSFL Advisory Panel members in summarizing the potential offsite risks from the SRE incident in 1959 as written by SSFL Advisory Panel member Dr. Jan Beyea.
Dr. Beyea has updated his comments on the Sodium Reactor Experiment numerous times since the 2006 SSFL Advisory Panel Report. His comments can be found on his website here: www.cipi.com The members of the SSFL Advisory Panel do not reference Dr. Beyea’s updates on their website.
This letter by the Los Angeles City Attorney et al cites as evidence an NBC News I-Team Report which quotes statements by a former employee who worked at the Sodium Reactor Experiment in 1959. However, the City Attorney of Los Angeles is probably unaware of the inconsistencies in the news report with this worker’s statements in a former employee interview with Federal EPA employees that is documented in the EPA’s Historical Site Assessment. Names in this report are redacted, but public statements by this former employee make his statement in this interview searchable:
One source on cancer studies that the City Attorney et al cite on page 13 of the letter referenced above is the study by Dr. Hal Morgenstern. Dr. Morgenstern is frequently misquoted. Dr. Morgenstern states:
“Results: Associations between distance from SSFL and cancer incidence differed by type of cancer outcome. Standardized incidence rate ratios were close to 1, indicating little or no association, for total cancers and radiosensitive cancers among adults; but the incidence rate of chemosensitive cancers was slightly elevated during both follow-up periods in the population living within 2 miles of SSFL. Results for the 9 specific cancers revealed some elevated incidence rates between 1988 and 1995 among persons living within 2 miles of SSFL. Specifically, the standardized incidence rate ratio was greater than 1.6 for cancers of blood and lymph tissue, bladder, thyroid, and upper aerodigestive tract. Between 1996 and 2002, the rate ratio among persons living within 2 miles of SSFL was greater than 1.6 for thyroid cancer. There were too few childhood cancers to yield informative results.”
“Conclusion: Despite the methodologic limitations of this study, the findings suggest there may be elevated incidence rates of certain cancers near SSFL that have been linked in previous studies with hazardous substances used at Rocketdyne, some of which have been observed or projected to exist offsite. There is no direct evidence from this investigation, however, that these observed associations reflect the effects of environmental exposures originating at SSFL. Given these provocative findings and unanswered questions, it is tempting to recommend further analyses or future studies to address the health concerns of the community. Unfortunately, it is not clear at this time whether such additional analyses or studies will be sufficient to determine whether operations and activities at Rocketdyne affected, or will affect, the risk of cancer in the surrounding neighborhoods.”
In conclusion, why is the City of Los Angeles using old offsite studies and old former worker studies as a justification as to how to clean up the Santa Susana Field Laboratory?
- Are our City Elected officials and staff unaware of the studies and Fact Sheets that I have mentioned?
- Why do they rely on Committee to Bridge the Gap to author letters related to the Santa Susana Field Laboratory cleanup?
- What qualifications does Committee to Bridge the Gap have to determine the risks to our community?
- Why isn’t the City of Los Angeles considering the input of the four Neighborhood Councils that are most greatly impacted by the SSFL site?
- Why isn’t the City of Los Angeles funding health studies of their own related to offsite risk with epidemiologists who do not have potential conflicts of interest with Committee to Bridge the Gap (CBG), the NRDC, and other non-profits that are currently in litigation against DTSC and the California Department of Public Health (CDPH)?
- Why doesn’t the City of Los Angeles have an Environmental Department with qualified professionals who are able to read and review technical documents related to toxic sites such as the Aliso Canyon Oil Field, the Exide Site, Sunshine Canyon and other landfills, etc., that are in the City’s jurisdiction?
Our City leaders are constantly talking about science, climate change, sustainability, protecting our trees and protecting our open space. Why aren’t they considering the potential public health, public safety, and environmental impacts to our community from the cleanup of the SSFL site to the strictest level that they are proposing?
(Chris Rowe has been a 41-year resident of West Hills, was a former West Hills Neighborhood Council Board Member, and has a B.S. in health education. She can be reached at firstname.lastname@example.org.) Photo above from Dr. Thomas Mack’s Presentation: “Cancer Occurrence in Offsite Neighborhoods Near the Santa Susana Field Laboratory” – DTSC Santa Susana Field Laboratory Open House – April 2014. Prepped for CityWatch by Linda Abrams.