Just because it’s legal doesn’t mean its safe
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Boeing will demolish five buildings at the Santa Susana Field Lab that were used for radioactive work, including a plutonium fuel facility.
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The buildings have been decommissioned are “legally “non-radioactive, but this was based on outdate technology, obsolete rulings, and questionable studies.
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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.
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Boeing has refused to answer our detailed questions. It is our understanding that they will not take any measures to protect the public from potential radiation exposure during the demolition or disposal.
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The DTSC August 2026 Community Update said the demolition would begin in late August 2026, but we can’t confirm if its actually begun or not. Boeing has not answered our requests for more information.
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Boeing has refused to answer our detailed questions. It appears Boeing will not send the debris to a low-level radioactive waste site, which would be the safest option.
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We want Boeing to prove to the public that the buildings aren’t radioactive -or- use the safest demolition and disposal practices.
Area IV Buildings
Boeing’s five remaining buildings at the Santa Susana Field Lab (Area IV) were used for radiological work. In the 1980s, the buildings were tested using now-outdated methodologies and standards. Exceedances (readings above naturally occurring “background” radiation levels) were observed, including 88 exceedances at the Plutonium Fuel Facility alone.
The exceedances were ruled “Acceptable Surface Contamination Levels,” according to 1974 Atomic Energy Commission standards. The buildings were officially decommissioned and are considered “abandoned warehouses” under Boeing’s current demolition permit.
In 2023 a court
they are not required implement the safest demolition and disposal measures. PASSFL believes that even though something is legal, that does not guarantee it is safe, and we are actively researching the facts to determine what, if any, additional measures should be taken.
OVerall Timeline:
CURRENT We’ve been told Boeing has not yet begun the demolition. The project is estimated to take 8-12 weeks.
2026 September DTSC mails out a Community Update announcing demolition
2026 August Boeing begins demolition (according to DTSC update)
2025 December
2023 DTSC Final Programmatic Environmental Impact Report (PEIR)
2023 Judge sides with DTSC and Boeing over technical aspects of CEQA
2017 DTSC’s Draft EIR
2013 NGOs halt Boeing Demolition after improper radioactive waste disposal
2013 Release Criteria for Boeing Radiological Buildings in Area IV, Revision 0
2013 Boeing’s Revised Standard Operating Procedure (SOP) With Amendment 2
2012 Boeing informs DTSC that it plans to demolish buildings in Area IV without CEQA
1997 EPA Letter 97RC1766 is critical of original studies and methodologies in Area IV testings
1989 EPA Rocketdyne SSFL Site Sample Analysis Report concerns about prior testing
1980s Radiological surveys of Area IV Buildings
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.
Building (4)009
Organic Moderated Reactor (OMR) Sodium Graphite Reactor (SGR)
1958 to 1967
Documents Timeline
1988 | Rockwell International | Final radiological Survey of Building 4009
Radiological survey of Building 4009/T009 intended to identify areas requiring further investigation or radiological remediation.
1995 | Rockwell International | Building 009 Radiological Survey Data Package
Survey of the SGR high bay and roof performed as part of the radiological evaluation of Building 4009 before unrestricted release.
1995/1998 | California DHS/CDPH | Verification/confirmatory survey
California DHS independently surveyed the OMR high bay in 1995 and the entire building in 1998 before concurring with release.
1999 | California DHS/CDPH | Release for unrestricted use (1)
Regulatory determination releasing Building 4009 for unrestricted use after reviewing the radiological survey results.
2002 | Tetra Tech/U.S. EPA | Final Rocketdyne Technical Support and Field Oversight — Document Review for Buildings T009, T011, T019, T055, and T100
Review of earlier radiological surveys and release documentation to assess whether previous surveys adequately demonstrated compliance with release criteria.
2003 | U.S. EPA | Independent assessment Building Survey Letter
2005 | Sapere Consulting for DOE | Historical Site Assessment
Historical assessment compiling Building 4009's operations, radioactive-material use, radiological surveys, remediation and release history.
2013 | CDPH | Radiologic Health Branch Review of documents for SSFL Area IV Building 4009
Building (4)011
RADIATION INSTRUMENT CALIBRATION LABORATORY
Documents:
4011 Historical Information
1958 to 1984 non radiological; 1984 until 1996 Radiation Instrument Calibration Lab
Radioactive sources for calibration were handled at the facility but most were sealed and checked annually to ensure no leakage occurred. The potential contaminants of concern are Cs-137, Co-60, Sr-90, Eu-152, Eu-154, thorium and uranium.1 • There were three Radiological Incidents associated with Building 4011 that could have resulted in a release to the environment: o 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). o 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).
A soil sample collected at the northwest corner of the building during the 1996 Area IV Radiological Characterization Survey found elevated Cs-137. The level was 0.53 pCi/g.4
Samples were collected from sludge in the sink traps for gamma spectroscopy analyses. The sludge was contaminated with low levels of uranium and the sink and trap were removed and disposed. An additional sludge sample was taken from a location several feet into the line and the sample met release criteria.
Building (4)100
ADVANCED EPITHERMAL TORIUM REACTOR (FAST CRITICAL EXPERIMENT LAB)
Nuclear Accidents are known to have occurred at building 4011
Ten “above background” radioactive detections were observed in EPA study
Documents TIMELINE
1998 | Boeing/Rocketdyne | Building 4011 Final Survey Data Package
Final radiological characterization/survey used to demonstrate that Building 4011 satisfied applicable radiological release requirements.
1998 | CA DHS/CDPH | Verification survey / Final Survey Data Package
California's independent verification associated with the determination that Building 4011 could be released for unrestricted use.
1998 | CA DHS/CDPH | Release for unrestricted use (1)
2002 | Tetra Tech/U.S. EPA | Final Rocketdyne Technical Support and Field Oversight — Document Review for Buildings T009, T011, T019, T055, and T100
EPA/Tetra Tech technical review of the earlier Building 4011 radiological survey and release evidence.
2002 | Tetra Tech/U.S. EPA | Final Oversight Verification and Confirmation Radiological Survey Report for Buildings T-011, T-019, T-055, and T-100
Independent EPA/Tetra Tech field measurements designed to verify previous surveys, compare measurement results and investigate areas potentially retaining radioactivity.
2005 Sapere Consulting for DOE Historical Site Assessment
Historical assessment compiling Building 4011's uses, radioactive-material history, surveys, remediation and regulatory status.
2012 | Boeing | Notification of Planned Demolition for a Portion of Boeing Building 4011
2012 | DTSC | DTSC Review of the Building 4011 Phase I Notification
2012 | Boeing | Notification of Demolition for Building 4011 Low Bay—Phase 2
Historical Information
Building Features: Building 4100 contained an experimental critical assembly located within a high bay (Room 110), special nuclear material stored within a vault (Room 112), supporting rooms, and a control room (Room 109). The facility included a ventilation system with filtered exhaust for the high bay area, a storage vault, and laboratories. The low bay contained the Radiation Instrumentation Calibration Laboratory from 1984–1996
A pit adjacent to the facility contained a liquid holdup tank system for liquid wastes. Building 4100 also had a septic tank, a leach field, a trench outside the building, and two stacks, the higher of which reached 50 feet. Building 4100 currently houses one of the largest computed axial tomography (CT) scanners in the world.
Former Use(s): Building 4100 housed the Advanced Epithermal Thorium Reactor (AETR), which was a separable-half critical experiment operating at less than 200 watts (thermal), Fast Critical Experiment Laboratory (FCEL), and Radiation Safety and Computed Tomography Laboratory. Twenty reactor core configurations were studied including thorium, uranium, and later, high-energy fast neutrons in the FCEL.3 The FCEL operated until about 1974 under NRC License No. CX-17. The NRC terminated License No. CX-17, and released Building 4100 for unrestricted use in October 1980.4 From the late 1980s until 2008, the high bay was used for high energy Computer Aided Tomography (CAT). NASA owned the scanner. The laboratories were used for radioactive sample counting and instrument calibration.
Information from Interviewees: “ It did get “hot” in that room, the radioactivity was mostly due to the Uranium-233.”
Use in 2011: Used for office, laboratory, storage, and support activities. Small amounts of radioactive materials in samples and check sources are used in Building 4100.
Previous Radiological Investigation(s) and Decontamination/Cleanup of Release(s): A chronology of radiological investigations at this building is as follows: In 1980, Rockwell conducted a radiation survey to terminate facility license CX-17. All measured levels were below 1980 acceptable levels of 20 dpm/cm2 for alpha radiation and 50 dpm/cm2 for beta-gamma radiation.
Radionuclides of Concern: The Atomic Energy Commission issued in October 1960, Facility License No. CX-17 for Building 4100 and subsequently amended it to permit the use of U-233, U-234, U-235, U-236, U-238, Th-232, Np-237, Pu-238, Pu-239, Pu-240, and Pu-241 in the AETR and in January 1972 for use in the FCEL. Decay products would include Th-228, Ra-228, Th-230, Ra-226, Pb-210, Pa-231, and Ac-227.
Final Technical Memorandum: Area IV, Subarea HSA-5C PDF page 50 - 55
Total detections :
10 above background
110 detections of radiological material
(1) Saba, V. B., Rockwell Internal Letter to Radiation Protection and Health Physics Services, re: Radiological Safety Report, Contaminated Respirator Laboratory Washer, December 17, 1991.
Building (4)055 and (4)155
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
Historical Information
2012 Site Description: The Building 4055 area is located outside the ETEC boundary and includes the Nuclear Material Development Facility (NMDF) Building 4055, a guard shack (Building 4155), a substation (Building 4755) located within the southwest corner of Building 4055, and the surrounding area located on G Street. Building 4055 was constructed in 1967 to serve for specifically for development work involving plutonium. The building [was later used for] non-nuclear laser research.
Three incidents occurred during its operation:
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.”
Final Technical Memorandum: Area IV, Subarea HSA-5C PDF page 82
Contaminants of Concern:
Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Am-241
Timeline
1986 Rockwell International Report, N704SRR990027, "Final Radiation Survey of the NMDF"
1987 Decommission Report Facility was released for unrestricted use and removed from the Special Nuclear Material License
1987 NRC Confirmatory Radiological Survey Nuclear Materials Development (FACKKY) Building 055
2002 EPA (Tetra Tech): RCRA Enforcement, Permitting, and Assistance Contract—Final Oversight Verification and Confirmation Radiological Survey Report for Buildings T-011, T-019, T-055, and T-100
2005 SSFL Area IV HSA
Total detections:
88 above background detections
Radioactive Do and do nots
Area IV decommissioning used now 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.
Boeing’s “Background” readings used for the original studies were obtained from other buildings within SSFL which may have been contaminated, skewing the results to make the Area IV buildings seem non-radioactive.
“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 for modern analysis
Current epa standards:
REFERENCES
2023 DTSC: Final Programmatic Environmental Impact Report (PEIR)
2017 DTSC: Draft Environmental Impact Report EIR
2018 CBG: Hunters Point Shipyard Cleanup Used Outdated and Grossly Non-Protective Cleanup Standards for comparison
2017 DTSC: Draft Environmental Impact Report EIR
2013 Boeing: Demolition Work Plan for Building 4100 (Area IV)
2013 CBG: Demolition of Radioactive Structures and the Disposal and Recycling of the Debris from the SSFL
2012: Boeing Attachment A: Work Scope Information for Removal of Buildings and Structures
2007 DOE’s environmental review for cleaning up Area IV was insufficient under NEPA
1986: Appendix 2 N704SRR990027, “Final Radiation Survey of the NMDF (Plutonium Fuel Facility)