Boeing’s Risky Demolition 2026

"I am very concerned that residents nearby are in harm's way,"  says Larry Yee, former Chair of the Los Angeles Regional Water Quality Control Board.

  • Boeing is demolishing five buildings at the Santa Susana Field Lab (SSFL) that were used for radioactive work, including a plutonium fuel facility.

  • The buildings have been decommissioned are “legally “non-radioactive, but this was based on outdate technology, obsolete rulings, and questionable studies.

  • Plutonium-239 has a 24,000 year half life and a 500,000 year hazardous life. Breathing trace amounts can cause cancer. It is one of the most dangerous substances on earth.

  • It has already begun. We have been told that 1 building is gone and a 2nd is in progress. We don’t know which buildings they were yet.

What can I do?

Contact your elected officials and ask them to get involved.

Electeds

Pass out flyers in your neighborhood

Single flyers
Double flyers

Sign and share our change.org petition

change.org

Sign up for our email newsletters

newsletter

Watch the Emmy-nominated documentary for free and share

Youtube

Donate to help us buy independent air monitors around the site

donate

Area IV Buildings

Boeing’s five remaining buildings at the Santa Susana Field Lab (Area IV) were used for radiological work. Several had nuclear accidents, including the former plutonium fuel facility. In the 1980s, the buildings were tested using questionable methods, now-outdated equipment, and obsolete regulations. Despite the limitations, readings above naturally occurring “background” radiation levels were observed, including 88 exceedances at the plutonium fuel facility alone. In other words, the buildings tested radioactive.

The exceedances were ruled “Acceptable Surface Contamination Levels,” according to 1974 Atomic Energy Commission (the agency no longer exists) standards. Boeing’s buildings were officially decommissioned before the rest of site was even known to be extensively contaminated with radiation — and Boeing may have walked away from all future cleanup except for Gregg Dempsey, Director Monitoring and Analytical Services for the EPA. The EPA demanded a new site-wide soil study, instead of just the buildings, resulting in a multi-year radiation soil survey. The newer study found hundreds of locations of elevated radioactivity, despite Boeing’s claims of having cleaned the site up twice before. 

Regardless, Boeing’s remaining five buildings are still legally considered “abandoned warehouses” today. A court ruling in 2023 determined that the Department of Toxic Substances Control (DTSC), who oversees the cleanup of the SSFL, and the Department of Health, will not have any oversight of Boeing’s demolition or the disposal of the debris from the five buildings.

Parents Against SSFL (PASSFL) is concerned that, without independent oversight, Boeing will not implement adequate safeguards to prevent radioactive material from reaching nearby communities through demolition dust — potentially polluting our air and water. We are concerned about worker safety. And we’re concerned that if plutonium-239 is not properly disposed of, it may poison generations of people for 500,000 years.

This isn’t the only time Boeing has tried to get away with this. In 2013, despite evidence of other Area IV buildings being low-level radioactive, Boeing sent thousands of tons of potentially low-level radioactive debris to recyclers and less protective (and less expensive) landfills that were not created to protect the public from radiation. (2013 Committee to Bridge the Gap: Demolition of Radioactive Structures and the Disposal and Recycling of the Debris from the SSFL)

After multiple requests for more information, Boeing has told us that they will follow the legal requirements for demolishing and disposing of their Area IV “abandoned warehouses,” but refuse to acknowledge any risks of exposing the public to radioactive material.

PASSFL, independent experts, and residents are fighting back because we know that just because it’s legal, it doesn’t mean it’s safe.

in order to protect the public, Boeing should:

PROVE THE BUILDINGS ARE NO LONGER RADIOACTIVE

  • Best practices for testing

    • Background levels to be determined using EPA or offsite calculations.

    • Alpha spectrometry to identify alpha-specific radionuclides

    • Wipes or smear testing and scanning methods are not sufficient alone

    • Volumetric samples to be used, not just surface

  • Radiological testing should be done before and after demolition

    1. Split samples to be shared with community

    2. Independent monitor should be allowed to watch samplers for adhering to best practices

    3. Results should be shared in a transparent and timely manner, including all lab records, data, and analysis

  • Use modern standards to determine safety levels

    • Current EPA PGA calculator for an exposure pathway including with Resident Air PRGs, using appropriate exposure duration and frequency.

-or - USE THE SAFEST DEMOLITION AND DISPOSAL METHODS FOR RADIOACTIVE MATERIAL

  • “Gold Standard” Dust Mitigation Methods

    • Construction tent with HEPA filter to be used over areas with active demolition

    • Tarp areas during nights and weekends to prevent dust

    • Lower wind thresholds to stop work

  • Radiological Continuous Air Monitors

    • Results should be shared in a transparent and timely manner, including all lab records, data, and analysis.

  • Worker radiological safety PPE

  • Improved transportation methods

    1. Better covering for trucks

    2. Ensuring material can’t be tracked offsite from construction vehicles and equipment

  • Treat all debris as low-level radioactive waste

    • All debris to low-level rad landfills only,

      1. “Non-hazardous” waste

      2. Green waste

      3. Wattles and rainwater barriers post demolition

    • No debris recycling of any kind

Faulty studies

The studies used to decommission Boeing’s Area IV buildings were done poorly for even what they knew then, and possibly on purpose.

  • The 1986 EPA test for all five buildings was conducted by Tetra Tech EC Inc., who recently reached a settlement for $97M for falsifying radiological testing studies at Hunter's Point.

  • The 1986 study used now outdated technology.

  • Poor testing methodology.

    1. EPA’s Gregg Dempsey observed poor testing methods, such as washing plants before testing them, short reading times, and holding the instruments too far away to get accurate readings.

  • “Acceptable Surface Contamination Levels,” were set under Regulatory Guide 1.86 to decommission the Area IV buildings but these levels are no longer accepted by the NRC as protective.

  • DTSC staff were concerned about the building’s potential to cause harm in an internal memo.

  • EPA demanded a new site-wide soil study, instead of just the building studies, resulting in a multi-year radiation soil survey, released in December 2012. The newer study found hundreds of locations of elevated radioactivity, despite Boeing’s claims of having cleaned the site up twice before. 

outdated standards:

  • Regulatory Guide 1.86: 1974 federal Atomic Energy Commission (the agency no longer exists) guidance containing surface-contamination release criteria. The U.S. Nuclear Regulatory Commission (NRC) withdrew Regulatory Guide 1.86 in 2016 because it relied on obsolete instrumentation thresholds and lacked a modern dose-pathway risk analysis.

  • DOE Order 5400.5: DOE radiation-protection standards, which also contained surface-contamination criteria. DOE canceled this regulation in 2011.

  • DECON-1: California DPH guidance concerning decontamination and release of facilities/equipment for unrestricted use. Not used as DPH policy since at least 2002.

  • IPM-88-2: California DPH policy memorandum concerning verification that facilities where radioactive materials had been used had been sufficiently decontaminated before release for uncontrolled use. Not used as DPH policy since at least 2002.

Current standards:

2023- Department of Energy blows up radioactive building at SSFL

Related SSFL READing

DTSC attempts to use 1974 nuclear regulations instead of current

Woolsey Fire spreads radioactive particles into local communities

Radioactive History

Buildings in Area IV

  • Building 4009 Organic Moderated Reactor (OMR) Sodium Graphite Reactor (SGR)

    • In 1967, all equipment associated with the OMR and SGR was removed. The building continued to be used for storage and testing . In the late 1980s, the west high bay was used for high-energy rate forging (HERF) that utilized depleted uranium.

  • Building 4011: Radiation Instrument Calibration Lab

    • There were three Radiological Incidents that could have resulted in a release to the environment:

      • On April 28, 1960, to the west of the building, an Organic Moderated Reactor Experiment (OMRE) shipping cask leaked during a leak test and spilled radioactive liquid on the ground (mixed fission products) (A0531).

      • On April 13, 1985, a calibration source came loose from an actuator rod resulting in an exposure of Cs-137. A radiation survey indicated no contamination on any part of the rod (A0318).

      • On December 6, 1994, the 28 Ci Cs-137 calibration source dislocated from the release pull rod. A radiation survey indicated normal background levels in the source containment box and on the release pull rod (A0658).

  • Building 4100: Advanced Epithermal Thorium Reactor (AETR); Fast Critical Experiment Laboratory (FCEL)

  • Buildings 4055 and 4155: Nuclear Materials Development (Plutonium Fuel) Facility

    • Nuclear Accidents are known to have occurred at building 4055

    • 88 “above background” radioactive detections were observed in EPA study

    • According to a July 22, 1968, internal letter regarding the in-box filter systems at Building 4055, the high-efficiency in-box filter systems for the glove box trains that were involved in the mixed oxide and carbide programs had some deficiencies with regard to nuclear material recovery, accountability, and safety.

      Two involving the release of plutonium into the glovebox room; one involving release of activity in the Process Lab.”

Lawsuits

In 2013, Committee to Bridge the Gap, Physicians for Social Responsibility - Los Angeles, and Consumer Watchdog sued the Department of Toxic Substances Control (DTSC) and Boeing over the Area IV Demolition of five radioactive buildings.

DTSC and Boeing won. Boeing will be allowed to demolish the buildings without additional radiological protections and without the oversight of the DTSC or the Department of Health.

Timeline:

Research

Buildings Testing Insufficient: Building 4500 

  • 1986 EPA test conducted by Tetra Tech EC Inc (Reached a settlement for $97M for falsifying studies at Hunter's Point). 

Testing methodologies insufficient

  • Used wipes which do not establish that the surface is free of alpha contamination. Does not get interior wall readings, only removable surface dust. 1986 "Final Radiation Survey of the NMDF" PDF page 6

  • Two of the surveys (ORNL, Tetra Tech) included gamma dose rates at 1meter above the surface in the building and surrounding area. Not alpha. 1987 ORNL Confirmatory Radiological Survey Nuclear Materials Development (FACKKY) Building 055 PDF page 10 

  • “Background” readings used for the original studies were obtained from building 4055, “First, "natural background" was determined by measurements made in an area of the building which was known to be uncontaminated,” skewing the results to lower radiation readings. PDF page Pg 21

    • MARSSIM (joint consensus document of EPA, NRC, DOE, and DOD for radiological surveys): 4.5 Select Background Reference Areas: “Background reference areas are normally selected from non-impacted areas, but are not limited to natural areas undisturbed by human activities. In some situations, a reference area may be associated with the survey unit being evaluated, but cannot be potentially contaminated by site activities. For example, background measurements may be taken from core samples of a building or structure surface, pavement, or asphalt. This option should be discussed with the responsible regulatory agency during survey planning. Generally, reference areas should not be part of the survey unit being evaluated… selecting more than one reference area may be necessary.. If the background is not well defined at a site, and [if] the decision maker is willing to accept the increased probability of incorrectly failing to release a survey unit (Type II error), the reference area measurements can be eliminated and a one-sample statistical test performed as described in Section 8.3. 

    • NUREG-1505 (NRC 1997a) 2.2.7 Reference Areas: “The distribution of background measurements in the reference area should be the same as that which would be expected in the survey unit if that survey unit had never been contaminated…“Any systematic difference in background level between the survey unit and the reference area will be indistinguishable from a difference in residual radioactivity in the two areas.” 

  • “Acceptable Surface Contamination Levels,” under Regulatory Guide 1.86 to decommission the Area IV buildings. Only measured surface and not volumetric contamination. 

Waste

Notification of Planned Removal, Non Building Area Remaining Concrete and Asphalt Located at the Former Building 4005 Boeing Santa Susana Field Laboratory, Ventura County, California.

  • Building debris from these buildings is subject to the “Governor’s Moratorium.”   Executive Order D-62-02 (2002) states that decommissioned material from former radiological facilities that meets federal and state cleanup standards cannot be disposed of to Class 3 landfills or unclassified waste management units.  PDF page 11

2013 Boeing’s SOP R3v 2

  • 9.0. Demolition Waste Recycling: In compliance with Boeing company policy and Ventura County's 60% landfill diversion Ordinance 4357, for construction/demolition debris, demolition wastes are recycled whenever possible and practical. PDF page 15

  • 9.2.1. During demolition, recoverable metal will be segregated from other demolition wastes and transported to a metal recycling facility. PDF page 15

  • 9 .3 .1. Only non-hazardous concrete and asphalt will be designated for recycling. In compliance with Ventura County's Ordinance 4357, concrete and asphalt are designated for recycling whenever the material conforms to regulatory requirements, standard industry practices, and guidelines published by governmental agencies and trade organizations. PDF page 15

  • 9.3.3. Concrete and asphalt waste that is determined to be non-hazardous may be transported off-site to a recycling facility or to a landfill that accepts Construction and Demolition (C&D) wastes. PDF page 15

  • 10.0. Demolition Waste Disposal Facilities: 10.1. Non-hazardous non-liquid wastes that are not designated for recycling may be transported to Class 2 [higher risk non-hazardous waste] or Class 3 [municipal] landfills for disposal. Boeing may also elect to transport non-hazardous wastes to Class 1 disposal facilities when this is deemed to be warranted. PDF pg 16

  • Email from Paul Carpenter (DTSC) to Steve Fischer (Boeing), “SSFL Area IV Former Radiological Building Content Disposal,” February 13, 2013. “DTSC concurs that Class I landfill [hazardous waste] disposal of former radiological building contents is acceptable, and agrees that this method of disposal does not merit additional radiological screening.” PDF pg 26

Work Action Plan: Building 4100

  • The post-demolition debris from 4100 will be radiologically acceptable for off-site disposal and/or recycling. PDF page 225

  • The California Department of Public Health (CDPH) Radiologic Health Branch (RHB) has stated in a November 9, 2007 email to Phil Rutherford (Boeing) … “The Governor's Executive Order D-62-02, does not specifically require the Department of Health Services (now the Department of Public Health) to perform verification sampling of decommissioned material or to provide approval for disposal of specific decommissioned material shipped offsite (e.g., to Class I or II landfills). The California DPH has not imposed a requirement that Boeing or the Department of Energy (DOE) seek DPH verification sampling or approval of all decommissioned material destined for Class I or II landfills in compliance with the Governor's Executive Order.”PDF page 225

Foundation/Slab

Permit says no foundations to be removed; SOP says slabs will be removed. What is the difference?

Boeing’s Ventura County Permit

The demolition involves the removal of the above ground portions of the five Boeing-owned building structures. No foundations will be removed, and no subsurface work will be performed. PDF pg 3

SOP Revision 2

  • The floor slabs and pavement will then be broken and removed. Based on this approach to demolition, near-surface soils will be exposed almost exclusively during the removal of floor slabs, spread footings, and concrete or asphalt surface paving. PDF page 16

  • 14.1. Commingling of wastes will be reduced by avoiding disturbance of underlying soil any more than is necessary to remove the demolition project related material. 

  • 14.1.1. Building structures are removed initially throughout a target demolition site to avoid potential interaction with the subsurface soil. Foundations are removed last. PDF page 21

Radiological screening

  1. Precautionary measures defined in Appendix A of the SOP have problems:

    1. Use only old detection levels and methodology instead of current EPA defined levels. 

    2. Pu-239 detections which are primarily alpha emitters with a weak gamma signal.

    3. Wipes will only detect direct surface contamination and not any potential interior wall radiation.

    4. Detection methods listed don’t include alpha spectrometry needed to determine if the alpha detection is Pu-239. Individual radionuclides must be identified to use newer EPA PGA calculator. 

SOP Revision 2

  • " ... pre-demolition radiological screening procedures [of the SOP] meet or exceed regulatory and industry standards and that surface activity limits meet regulatory standards. Both the procedures and limits provide adequate assurance that fixed and removable radiological contaminants are not present in the pre-demolition materials." PDF page 23

  • Boeing commits to the following: Provide DTSC and CDPH with current updated versions of "Radiological Status of Boeing Buildings in Area IV…” SOP Rev 2 PDF page 26

  • 8.5.1. As a precautionary measure, building structures, equipment, and materials, including road base, will undergo a pre-demolition radiation screening following the procedures outlined in Appendix A. PDF page 14

Appendix A: Radiation Screening Procedures for Non-radiological Buildings, Equipment and Debris

  • 1.0. Building surfaces, equipment and/or debris (metal, concrete, asphalt, other) shall be screened using the following techniques:

    • Gamma radiation exposure rate shall be measured using a portable Ludlum Nal gamma detector or a Bicron microrem meter.

    • Total beta-gamma surface contamination levels shall be measured using a portable Ludlum G-M meter (or equivalent).

    • Removable alpha and beta surface contamination levels shall be taken using wipes and measured on a low-background Tennelec alpha/beta counter ( or equivalent).

  • 2.0. Release criteria for surface contamination of building structures, material, equipment and debris shall be those specified in USNRC Regulatory Guide 1.86, USDOE Order 5400.5 Chapter IV, USDOE G 441.1-XX, and California Radiologic Health Branch guidance DECON-1 and IPM-88-2. Minimum detectable activities of instruments and wipes shall be less than these regulatory limits.

  • 3.0. All measurements shall be recorded on a Boeing Radiation Survey Form 732-A, including results, instrument model and serial number, instrument calibration dates, instrument efficiencies, backgrounds, and minimum detectable activities. Tennelec alpha/beta counter output shall be attached to the Form 732-A. Photos and maps shall show the locations of measurements. Page 19


Regulations and Metrics used in Studies : 

  • Regulatory Guide 1.86: 1974 federal Atomic Energy Commission (the agency no longer exists) guidance containing surface-contamination release criteria. The U.S. Nuclear Regulatory Commission (NRC) withdrew Regulatory Guide 1.86 in 2016 because it relied on obsolete instrumentation thresholds and lacked a modern dose-pathway risk analysis. Also, RG 1.86 was fundamentally a surface-contamination framework. 

  • DOE Order 5400.5: DOE radiation-protection standards, which also contained surface-contamination criteria. DOE canceled this regulation in 2011.

  • DECON-1: California DPH guidance concerning decontamination and release of facilities/equipment for unrestricted use. Not used as DPH policy since at least 2002.

  • IPM-88-2: California DPH policy memorandum concerning verification that facilities where radioactive materials had been used had been sufficiently decontaminated before release for uncontrolled use. Not used as DPH policy since at least 2002.

Today’s Standards

  • Preliminary Remediation Goals (PRG)

  • NRC 10 CFR 20.1402, residual radioactivity must be low enough that the dose to an average member of the critical group does not exceed 25 mrem/year (0.25 mSv/year), and residual radioactivity must also be reduced ALARA (as low as reasonably achievable).

  • DCGL (Derived Concentration Guideline Level) corresponding to the applicable dose criterion and exposure scenario.

  • NRC's current decommissioning guidance includes building-surface screening values in dpm/100 cm². These values represent radionuclide concentrations calculated to comply with the 25-mrem/year unrestricted-release dose criterion, subject to assumptions and ALARA. NRC says that if contamination is below these screening values, a relatively simple facility may be able to demonstrate compliance without a full site-specific dose assessment. 

    • That's why simply comparing 100 dpm/100 cm² from 1986 with a modern number without identifying the radionuclide and assumptions can be misleading.

      • For Building 4055, the old Annex B transuranic limit was:

        • Average: 100 dpm/100 cm²

        • Maximum: 300 dpm/100 cm²

        •  Removable: 20 dpm/100 cm².

    • Modern dose/risk assessment is much more radionuclide-specific. NRC explains that its modern surface screening values are for individual radionuclides and that, where multiple radionuclides are present, a sum-of-fractions approach applies.

    • Current MARSSIM explicitly describes itself as a methodology for demonstrating compliance with dose- or risk-based requirements and covers the planning, characterization, remediation and final-status-survey process.

REFERENCES

A radiation survey of the OMR high bay and supporting rooms was performed in 1988.  The grounds and drainlines were sampled in 1989.  The SGR high bay and roof were surveyed in 1995.  The California Department of Health Services (DHS) performed verification surveys of the OMR high bay in 1995 and the whole building in 1998.  Based on the results of these surveys, the DHS released Building 4009 for unrestricted use in January 1999.