SANTA SUSANA FIELD LABORATORY



Phil Rutherford Consulting

Offsite Impact of SSFL

For over 30 years, activists, legislators and media have misled the public about SSFL. Finally, here is a compilation of evidence that SSFL has NOT impacted the health of its neighbors.

Nuclear Decommissioning at SSFL

A major activity at SSFL has been the decommissioning of DOE-owned and Boeing-owned nuclear and radiological faciities in Area IV.

Since 2000, politics, legislation, litigation and regulatory abuse and inaction has interfered with the established decommissioning process. 

PSR-LA Petition & Complaint

PSR-LA allege that demolition debris from decommissioned former nuclear facilities should be classified as low-level radioactive waste.

Petitioners: Physicians for Social Responsibility - Los Angeles, Southern California Federation of Scientists, Committee to Bridge the Gap and Consumer Watchdog.

Respondents: Department of Toxic Substances Control and California Department of Public Health.

Real Party In Interest: The Boeing Company

 

Response to PSR-LA Petition and Complaint

Response to PSR-LA Appeal

Response to Appellants' Opening Brief in the PSR-LA Appeal

Response to PSR-LA Petition to the California Supreme Court

DTSC-Boeing Settlement Agreement

On May 9, 2022 DTSC announced a Settlement Agreement "to hold Boeing accountable to its cleanup obligations at the Santa Susana Field Laboratory."

A primary objective is for Boeing to cleanup radionuclides (but not chemicals) in soil to background, in its areas of responsibility. The following paper provides an opposing view.

Jared Blumenfeld's Conflict of Interest

Request to the California Attorney General to conduct a conflict of interest investigation on CalEPA Secretary Jared Blumenfeld.

One month later, Mr. Blumenfeld resigned as CalEPA Secretary.

Personal Communication with State Officials

The correspondence below with California State officials concerning legislative and regulatory actions related to the Santa Susana Field Laboratory (SSFL) has been prepared by myself, acting as a private citizen and community resident.

The material has benefited from the knowledge acquired during my twenty five years as Senior Manager of Radiation Safety at SSFL before my retirement. However the views and opinions expressed are mine alone, and do not necessarily reflect the views and opinions of The Boeing Company, the Department of Energy (DOE) or the National Aeronautics and Space Administration (NASA).

Neither Boeing, nor DOE, nor NASA has solicited or approved this correspondence. I alone am responsible for its content.

Senate Bill 990 (2007) and Health and Safety Code ยง 25359.20
Request for Revocation of SB 990 Language
after being Struck Down in Federal Court.
Request for Removal of SB 990 from DTSC Website.
Date Communication
November 16, 2020 Letter to Senator Henry Stern
Email transmitting above letter
November 16, 2020 Letter to Grant Cope, DTSC
Email transmitting above letter
November 16, 2020 Automated email from Senator Henry Stern's OffIce
November 17, 2020 Email from Grant Cope, DTSC
November 19, 2020 Letter from Attorney General's Office
December 4, 2020 Letter to Attorney General's Office
Email transmitting above letter
June 17, 2021 Email to Grant Cope, DTSC

No substantive response has been received from Senator Stern or the California Attorney General or others on cc regarding H&S Code 25359.20.

As of 2023, DTSC has finally removed all references to SB 990 from its web site.


2020 Amendment to Order on Consent
Opposition to Management of Non-radiological Building Debris
as Low-level Radioactive Waste
Date Communication
November 15, 2020 Questions and Issues Related to the Amendment to Order on Consent
Email transmitting above paper
November 29, 2020 Letter to Steven Becker, DTSC
Email transmitting above letter
March 11, 2021 Email to DTSC Management
Public Records Act Request for DTSC - CBG Communications
March 26, 2021 Letter from DTSC Senior Counsel, Arthur Pugsley
Response to Public Records Act Request
Email transmitting above letter
July 8, 2021 Email to DTSC Senior Counsel, Arthur Pugsley
Public Records Act Request
July 16, 2021 Email from DTSC Senior Counsel, Arthur Pugsley
Public Records Act Request
August 15, 2021 Letter to Meredith Williams, Director, DTSC
Public Records Act Request
Email transmitting above letter
August 27, 2021 Letter from DTSC Senior Counsel, Ross Colburn
PRA Final Response - DTSC/Hirsch Communications
Email transmitting above letter
August 28, 2021 Email to DTSC Management
Reply to PRA Final Response

DTSC has failed to directly address my opposition to sending non-LLRW to a LLRW disposal site.

DOE Waste Characterization at the Energy Technology Engineering Center
Review of Data Package for
FOIA EMCBC-2022-00149-F

Review of waste profiles and waste manifests for decommissioned material and debris from buildings with no history of radiological use, reveals that falsified data has been used, in a blatant attempt to mischaracterize non-LLRW as LLRW.

Data on over 400 shipment manifests were systematically inconsistent and transparently illogical. Shipping manifest radionuclide conentrations did not match waste stream profiles. Multiple different containers with significantly different waste weights were assigned identical total and individual radionuclide activities, which is physically impossible. Multiple different containers were assigned identical waste weights and identical total and individual activities, which is physically impossible. Container weighted average concentrations were derived from container total and individual radionuclide activities rather than vice versa. The apparent falsification of data and lack of any quality control of manifest data by all participants, North Wind, DOE and EnergySolutions is incomprehensible.

DOE-ETEC has failed to respond to these alleged irregularities perhaps because it has no response. The complaint is currently under investigation by the State of Utah (Complaint DRC-2023-001509) and DOE's Office of Inspector General (OIG Complaint #23-0160-C).

See correspondence below.

November 17, 2021 FOIA Request for Records - EMCBC-2022-00149-F
Letter from Michelle Farris, Office of Chief Counsel, DOE EMCBC
September 29, 2022 Response to FOIA Request - EMCBC-2022-00149-F
Letter from Melody C. Bell, Deputy Director, DOE-EMCBC
January 10, 2023 Letter to Josh Mengers, DOE ETEC Project Director
Response to FOIA Data Package
Email transmitting above letter
February 9, 2023 Letter to Doug Hansen, Director, Utah Division of Waste Management and Radiation Control
Shipments of Waste from the Former Energy Technology Engineering Center
Email transmitting above letter
February 10, 2023 Letter to DOE Inspector General
Shipments of Waste from the Former Energy Technology Engineering Center
Email transmitting above letter
April 9, 2023 Email to the Utah Division of Waste Management and the DOE Inspector General
Irregularities in DOE's Waste Shipments from ETEC to EnergySolutions
July 25, 2023 Waste Characterization by the Department of Energy at the Energy Technology Engineering Center
Presentation to the Health Physics Society Annual Meeting in National Harbor, Maryland
August 1, 2023 DOE Waste Characterization at the Former Energy Technology Engineering Center
Email to DOE, DTSC, North Wind, EnergySolutions, Utah DWMRC, and CalEPA.
Challenge to respond to allegations.

DTSC-Boeing Settlement Agreement
Opposition to the Settlement Agreement
Date Communication
May 26, 2022 Email to Chinh Sheow, DTSC
May 31, 2022 Email to Grant Cope and Steven Becker, DTSC
Attachment to above email
Opposition to Settlement Agreement
June 11, 2022 Comments on Kimberly Gettmann's Memorandum
Email to DTSC Staff transmitting above paper
June 11, 2022 Email to DTSC Staff
Unanswered Questions

DTSC has failed to directly address any of my comments on the Settlement Agreement.



The Boeing Company


Department of Energy (DOE)


National Aeronautics and Space Administration (NASA)


California Department of Toxic Substances Control (DTSC)


California Department of Public Health - Radiologic Health Branch

  • Although SSFL has had a California Radioactive Materials License since 1962, the Radiologic Health Branch maintains no online material documenting its oversight of SSFL

Los Angeles Regional Water Quality Control Board


Agency for Toxic Substances and Disease Registry (ATSDR)


National Park Service (NPS)


Environmental Protection Agency (EPA)


National Institute for Occupational Safety and Health (NIOSH)


American Jewish University - Brandeis-Bardin Campus


Other Sources

In the interest of openness and impartiality, several other organizations host websites expressing a variety of misguided opinions on SSFL.  The reader is cautioned to fact check this material against official sources above.