Just because it’s legal doesn’t mean its safe

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 In the 1980s, the buildings were tested using now-outdated methodologies and standards.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:

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

Building (4)011

RADIATION INSTRUMENT CALIBRATION LABORATORY

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)

Documents TIMELINE

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.

(2) USNRC, Letter, “ NRC Inspection of Rockwell International’s FCEL Inspection,” from H. E. Brook (NRC) to M. E. Remley, July 11, 1980.

Building (4)055 and (4)155

NUCLEAR MATERIALS DEVELOPMENT (PLUTONIUM FUEL) FACILITY

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

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