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Cleanup Myths
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Cleanup Timeline
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Area I Burn Pit
Shooting Range
Completed Sections
cleanup scenarios
Cleanup Comparisons
In California and across the U.S., cleanup agreements heavily favor Responsible Parties (RPs)—such as Boeing, NASA, and the Department of Energy at SSFL—because these parties are often contracted to write the agreements. This allows them to cut corners, save money, and protect their reputation. Regulatory Agencies like CalEPA and the Department of Toxic Substances Control (DTSC) approve these agreements with little resistance due to pressure from politically and financially powerful RPs. Risk-based cleanups are cheaper and faster, making them the preferred choice of RPs, even though they leave lasting harm.
RPs frequently rely on Risk-Based Scenarios to shape cleanup agreements, using EPA models to estimate exposure risks. The standard target is to ensure no more than 1 in 1,000,000 (1 × 10⁻⁶) people develop cancer due to remaining contamination. However, these calculations depend on assumptions about human activity.
For instance, a Residential with Garden scenario requires a more thorough cleanup since it assumes people live on-site and eat food from a backyard garden. In contrast, a Recreational scenario assumes visitors spend only a few hours per year on-site, with little exposure to the site’s contamination. The Recreational scenario allows RPs to leave almost all contamination onsite with a smaller risk to the occasional visitor but not the families living next to SSFL, where pollutants migrate into their homes and environment.
Pros of Risk-Based Scenarios
Commonly used standards
Cons of Risk-Based Scenarios
Often based on the metabolism and lifestyle of a white adult male, ignoring more vulnerable populations.
Limited to considering exposure onsite; doesn’t account for contamination spreading to surrounding communities, water, or wildlife offsite.
Fails to consider long-term consequences. In 200 years, residents may rely on local groundwater, but a recreational cleanup wouldn't ensure its safety.
“It’s logical to assume that cleanups of toxic sites remove all contaminated material, but that’s rarely the case.”
A Background Scenario cleanup was designed to counteract the unfair influence of RPs in cleanup agreements. Unlike Risk-Based Scenarios, which rely on modeling and calculations, a Background Cleanup uses real sampling data. It assumes that if a contaminant on-site is man-made, it should be removed, restoring the land to its natural state before it was polluted.
To determine the site's natural condition, scientists collect data from nearby unpolluted areas. Any detected chemicals or radioactive materials naturally found in the environment, like radon or uranium, were considered "background" levels.
While a Background Cleanup scenario doesn’t require RPs to clean beyond natural background levels, it often results in a more thorough cleanup than most Risk-Based Scenarios.
Pros of Background Cleanup Scenario
Returns the toxic site to its natural condition
Protects residents, water, and wildlife near the site and at the site
Assumes man-made contamination has the potential to cause harm, even if the full extent of the harm isn’t currently known
Cons of Risk-Based Scenarios
Expensive to RPs
Take more time to implement
Removes more contaminated soil than most Risk-Based Scenarios
How background is determined
There are two “Background” values at the SSFL; one for radionuclides and for chemical constituents.
2012 EPA Radiological Background Study determined the levels of naturally existing radionuclides in nearby areas.
2011 EPA Chemical Background Study determined the levels of naturally existing chemicals in nearby areas. These levels are the basis for the SSFL’s Chemical Look-Up-Tables (LUT), which determine how much chemical contamination must be cleaned up to meet natural conditions.
Although the background studies were imperfect (values still in fell in favor of the polluters when there was a value in doubt) the 2011 and 2012 studies are sufficient for a complete cleanup and have been used as the backbone of the background cleanup for over a decade.
A burro with radiation detectors strapped to its back was used for the background study.
No Risks Myth
Because Boeing, NASA, and the Department of Energy (DOE) are more concerned about saving money than protecting lives, they’ve implemented scare tactics to keep residents afraid of the Background Cleanup scenario. This has included the threat that a Background Cleanup would strip the site’s 2,850 acres of all its topsoil, leaving it a barren “moonscape” wasteland that wouldn’t be able to support wildlife and would destroy the invaluable cultural artifacts onsite. This is completely false. See Cleanup Myths for more information.
What is also completely false is the RP's arguments that there would be no difference in health impacts if they leave all the contamination behind or clean up all the contamination. NASA used this reasoning to claim there would be no difference between their Action Alternatives “Option A” (a background cleanup) and “Option D” (a recreational cleanup) because Risk-Based Scenarios don’t account for contamination leaving the site and harming the people living nearby. In reality, the contamination is migrating into local communities and causing harm- as provided by a federally-funded epidemiological study by the University of Michigan that found a 60% higher cancer incidence rate for residents living two miles from the SSFL, compared to five miles away.
