CBG Comments on Boeing’s Soil Corrective Measures Study & DTSC’s Statement of Basis
Unless major action is taken now to intervene, Boeing’s Draft Resource Conservation and Recovery Act Limited Corrective Measures Study Report, Surficial Media Operable Unit (CMS) and DTSC’s Draft Statement of Basis for the Surficial Media Operable Unit (SMOU) Proposed Remedy Selection in the Boeing Areas of Responsibility (SB) are the final nails in the coffin of a meaningful cleanup of the Santa Susana Field Lab (SSFL) once promised, and now betrayed, by DTSC and Boeing. The CMS and SB are the culmination of a years-long effort by Boeing to abandon the full SSFL cleanup to which it committed in 2007.
At the core of Boeing’s Corrective Measures Study Report, Surficial Media Operable Unit, Boeing RFI Subareas (“CMS Report”) is a betrayal of the original cleanup agreement, the 2007 Consent Order. Behind all the technical jargon in the CMS Report lies a stark reality: Boeing and the Department of Toxic Substances Control (“DTSC”) completely abandoned the 2007 cleanup agreement, hard-won by community members and elected officials, in favor of a wholly inadequate cleanup that puts ecological and human health at risk.
The Agreement represents the culmination of Boeing’s years-long campaign to evade its cleanup obligations by systematically weakening the Risk-Based Screening Levels (RBSLs). The Agreement also effectively erodes the most stringent cleanup standard mandated by the 2007 Consent Order and reflects DTSC’s capitulation from the more protective standards and limits it had previously established.