SSFL Final Program Environmental Impact Report (PEIR) Release – Frequently Asked Questions
FAQ Categories
To help the public understand this complex report, we have gathered the most commonly asked questions about the FPEIR below and as a downloadable PDF.
General
1. What does this PEIR do for the community and why is it so important?
An Environmental Impact Report (EIR) is an important document required by the California Environmental Quality Act (CEQA) any time a State Agency undertakes a project to evaluate and mitigate potential environmental impacts associated with the project.
CEQA defines a “project” as an activity that is a discretionary action by a governmental agency and will either have a direct or reasonably foreseeable indirect impact on the environment.
The Program EIR (PEIR) is considered a combined program-level and project-level EIR and covers the entire site and all responsible parties. A project-level EIR is a type of EIR that focuses primarily on the changes to the environment that would result from a given project, and examines all phases of the project including planning, construction, and operation. A program-level EIR offers analysis of the various conceptual remediation technologies and corrective actions that would be employed across all project sites to clean up impacted groundwater and soil. This combined EIR allows DTSC to consider broad policy alternatives and program-wide mitigation measures because activities occur in the same footprint.
The purpose of the PEIR is to inform decision makers and the public of any environmental impacts from the cleanup work and if there are measures that can be taken to substantially lessen or avoid the impacts from the cleanup. Certification of the PEIR means cleanup at SSFL can begin following the submittal, review, and approval of cleanup decision documents that detail what the final cleanup activities will be for soil and groundwater.
2. Did the community provide input on this PEIR?
Yes. DTSC received public comment on the Draft PEIR in 2017 and received approximately 2,500 comments from over 6,000 people. DTSC has prepared detailed written responses to all comments received and included them in the Final PEIR as required by CEQA.
We’ve developed the Final PEIR making several updates and clarifications to the Draft PEIR based on feedback from the community and other stakeholders as well as changes in applicable federal guidance.
3. Where can I find the answer to my comment on the Draft PEIR
Responses to comments can be found in Chapter 3 of the Final PEIR. Table 31, List of Commenters, lists all public agencies, tribes, organizations, individuals, and businesses who submitted written comments on the Draft PEIR in alphabetical order by category. The page number is provided for each commenter listed. Additional information regarding this process is provided in Chapter 3 including topical responses.
4. What type of Tribal Government Engagement has occurred with SSFL PEIR?
DTSC coordinates with Tribes in the development of policies, programs, and activities that may affect a Tribe’s community, ancestral territories, or cultural resources. The 2017 Draft PEIR was shared with respective Tribal governments, and comments were received based on the draft document. DTSC will continue our engagement efforts with local Tribal Governments regarding the release of the Final PEIR.
5. What are the next steps after the release of the PEIR?
After the PEIR is released, DTSC is required to provide 10 days for government agencies to review DTSC responses to their comments on the Draft PEIR. While CEQA requires such a review period only for government agencies, DTSC will make the PEIR available on its website to the general public as well. No further comment will be taken.
The PEIR is anticipated to be certified in June 2023. After certification of the PEIR, the responsible parties will develop cleanup decision documents for DTSC review. These decision documents will include proposed cleanup standards and will be made available for public review and comment prior to finalization and DTSC approval.
6. What does it mean to certify the PEIR?
Certification means that the PEIR has been completed in compliance with CEQA and represents DTSC’s independent judgement and analysis of potential environmental impacts associated with the project as defined in the PEIR.
7. How do the PEIR and the 2022 Settlement Agreement fit together?
DTSC and Boeing entered into a Settlement Agreement that went into effect on August 12, 2022.
The Settlement Agreement amends the 2007 Consent Order to set forth the processes and methodologies for the cleanup of the Boeing areas of responsibility at SSFL.
The Settlement Agreement resolves prior disputes about process, cleanup and decision-making, facilitates the cleanup of Boeing’s areas of responsibility using streamlined processes, and establishes a mechanism for quickly resolving any potential future disputes.
The 2022 Settlement Agreement does not select or commit DTSC to any final soil or groundwater remedy decision for Boeing areas of responsibility at SSFL. DTSC will make final remedy decisions for Boeing areas of responsibility at SSFL only after certification of the PEIR, issuance of required findings under CEQA, and completion of the required steps for remediation of Boeing areas of responsibility at SSFL, including public comment on the proposed cleanup standard. The Settlement Agreement does include enforceable commitments from Boeing not to challenge any future DTSC cleanup selection that includes requirements to clean radioactive materials to background conditions, or chemical contaminants to the resident with 100% garden scenario described above.
The final PEIR is consistent with the Settlement Agreement.
8. How is the Settlement Agreement related to the Administrative Orders of Consent (AOCs)?
The Settlement Agreement is separate and apart from the 2010 AOCs. Boeing is not a party to the 2010 AOCs. Boeing is only a party to the 2007 Consent Order. The Settlement Agreement applies only to the Boeing areas of responsibility.
The Settlement Agreement does not impact the 2010 AOCs with DOE and NASA. DOE and NASA’s cleanup responsibilities remain unchanged and are governed by the 2007 Consent Order (for groundwater only) and the 2010 AOCs (for soil).
9. How can the public offer feedback on the cleanup in the future?
DTSC is dedicated to providing a transparent process for establishing specific cleanup plans. Draft cleanup decision documents that provide project-specific cleanup requirements will be prepared at a future date for each discrete cleanup project and will be submitted to DTSC for review. The public will have an opportunity to comment on each cleanup plan. DTSC will consider public comments and incorporate feedback prior to approving each cleanup plan.
The first draft decision documents for groundwater are anticipated to be released for public review and comment in late 2023/early 2024. The draft decision documents for Boeing soils are anticipated to be released for public review and comment in 2025.
DTSC is committed to ensuring that the public is informed and involved throughout the process. We’ll use the input from our recent public survey to help design workshops, plan meetings, and share key elements of our work. These community workshops will be held as needed, based on stakeholder interest. Community updates will be released when cleanup decisions are made and periodically throughout the cleanup process to inform the public of the progress of the cleanup.
10. What is the SRAM? Why is the SRAM important?
The Standardized Risk Assessment Methodology (SRAM) is a workplan required under the 2007 Consent Order between Boeing, NASA, DOE, and DTSC that provides the risk assessment methodology for human health and ecological receptors for a risk-based cleanup at SSFL. The data in the risk assessment reports prepared pursuant to the SRAM will be used in the Boeing Corrective Measures Study (CMS) to evaluate cleanup alternatives at the Site. DTSC will evaluate the alternatives presented in the CMS in making a final remedy decision for cleanup of soil in Boeing’s areas of responsibility at SSFL.
For more information about the SRAM visit our Frequently Asked Questions on our webpage.
11. Why did the Final PEIR take so long to come out?
The highly complex and technical nature of the regulatory program and the number of interested parties have contributed to the length of time needed to complete the Final PEIR. The PEIR has also been updated to reflect changing circumstances such as the removal of buildings in Area IV per the DOE orders and increased soil cleanup volumes for Boeing areas based on US EPA’s updated guidance and in response to public input.
12. Why isn’t the public getting another chance to comment before the PEIR is finalized?
DTSC made the Draft PEIR available for public review and comment in 2017. By issuance of the Final PEIR and subsequent certification, DTSC will have satisfied the requirements for the document under CEQA, and CEQA does not require a comment period for the Final PEIR.
The public will have the opportunity to comment on each future cleanup decision document through public review and comment periods.
13. Why do the Final PEIR documents show February 2023 as the release date and the cover document lists June 2023?
Each page of the Final PEIR document indicates a prepared date of February 2023 and the cover page corresponds to the release date. The difference in dates is a result of the time needed to make the document accessible and compliant with AB 434.
Cleanup
1. When will cleanup begin?
Significant cleanup such as 15 critical soil cleanups, the removal of above ground portions of DOE buildings in Area IV, and the removal of the majority of NASA site infrastructure has already happened on the site through earlier enforcement actions.
Additionally, two soil cleanup actions are underway at SSFL under Imminent and Substantial Endangerment Orders. These include cleanup of the Former Shooting Range and the Area I Burn Pit. Vegetation clearance at the Shooting Range started on April 18, 2023, and excavation is anticipated to start at the Shooting Range in early June.
The Final PEIR marks the beginning of large-scale cleanup efforts. The cleanup project will begin after decision documents have been reviewed by the public and approved by DTSC.
A decision document or cleanup plan documents the selected alternative for a cleanup. It provides information on the need for a removal action, a description of the proposed action and cleanup levels, and the rationale for why the proposed action was selected. The first draft decision documents for groundwater are anticipated to be released for public review and comment in late 2023/early 2024, and implementation is anticipated to begin in 2025.The draft decision documents for Boeing soils are anticipated to be released for public review and comment in 2025, and implementation is anticipated to begin in 2026.
2. What is the timeline for cleanup activities?
The soil cleanup is anticipated to take approximately 15 years once work begins. The groundwater cleanup and long-term monitoring will continue as long as necessary to ensure the site does not present a danger to human health or the environment.
DTSC will continue to enforce the conditions of the 2007 Consent Order, the 2010 Administrative Orders on Consent (AOCs), and the 2022 Settlement Agreement to ensure that cleanup is being completed as expeditiously as possible, following federal, state, and local laws and regulations, and in a manner that is protective of human health and the environment.
3. What cleanup activities have been completed?
Many interim actions have occurred over the years or are ongoing including but not limited to the following:
- 15 critical soil cleanups
- Removal of above ground portions of DOE buildings in Area IV
- Removal of the majority of NASA site infrastructure for access to soil
- Interim cleanup of soils to control contamination coming from streams (done in cooperation with the LA Water Board)
- Groundwater pump and treat system removes contamination and stops groundwater migration (Active)
- Stormwater treatment system helps prevent off-site releases (Active)
- Stormwater discharge permit restricts the amount of pollutants in the runoff from the site and has compelled use of advanced treatment systems and distributed Best Management Practices to control runoff and compliance monitoring. (Active)
Additionally, two soil removal actions are planned at the Shooting Range and Area I Burn Pit in 2023.
4. What are the cleanup standards approved in the PEIR?
While the PEIR does not approve any cleanup standards, the PEIR analyzes environmental impacts based on conservative assumptions resulting in the most extensive set of cleanup activities that could occur on the project site, representing the maximum volume of soil that may potentially be cleaned up. Final proposed cleanup standards will be presented in cleanup decision documents that will be subject to public review and comment before DTSC makes any decision regarding approval of proposed cleanup standards.
5. Why are soil cleanup standards different for Boeing than for DOE and NASA?
The standard for cleanups administered by U.S. EPA and DTSC is risk-based. Consistent with that, Boeing is required to clean up soil to risk-based levels for chemicals per its 2007 Consent Order and the 2022 Settlement Agreement. In the 2022 Settlement Agreement, however, DTSC secured Boeing’s agreement to clean up radionuclides in soil to “background,” a more stringent standard that means cleanup to levels that would exist locally without industrial activity. Under their respective 2010 Administrative Orders on Consent, DOE and NASA agreed to clean up soil to background levels.
6. How is the community being kept safe during this cleanup?
DTSC’s mission is to provide the highest level of public safety, and to protect public health and the environment from toxic harm. The cleanup implementation plans will include industry best practices and mitigation measures to protect on-site workers and nearby residents, both from cleanup activities and trucks carrying contaminants off site.
The PEIR identified mitigation measures to avoid or substantially lessen significant environmental impacts of the cleanup. These measures are identified in the Mitigation Monitoring and Reporting Program (MMRP) included in the PEIR. DTSC will administer the MMRP. The MMRP establishes a framework that DTSC, Boeing, DOE, NASA, and others will use to implement the mitigation measures adopted in connection with project approval and the monitoring and reporting of such implementation
7. Who will make sure the cleanup is done properly?
DTSC field-certified, technical staff will be present on-site to oversee cleanup activities to ensure they are conducted properly in accordance with the approved decision document (i.e., cleanup plan). This will occur regularly at the beginning of each project and may be adjusted to weekly or bi-weekly as the project progresses.
8. Who do we contact if a traffic incident occurs?
The RPs will prepare for DTSC approval a comprehensive Site-Wide Traffic Management Plan that will designate an on-site coordinator for all project activities, including for incident response. The Plan will establish preventive methods to reduce the possibility of incidents and establish a framework for any incident response that minimizes risks to human health and the environment. The Plan will identify contacts such as local emergency responders that the public may use to notify on-site coordinators of any incident.
9. How will schools be protected during transportation?
Prior to the beginning of remediation activities, the RPs will prepare for DTSC approval a comprehensive Site-Wide Traffic Management Plan that identifies common traffic-control requirements to facilitate safe and efficient traffic flow on public roadways. The Plan shall avoid direct routing through sensitive habitat areas and areas with residential dwellings, schools, and bike routes unless no alternative is available. The Plan shall establish, list, and map the trucking routes, days and hours of truck operation (weekday off-peak traffic hours only), maximum number of trucks per day (96), and various requirements to provide traffic, pedestrian, and bicycle safety.
The following schools and day care centers are located within one-quarter mile of the proposed routes:
Routes 1 and 2 to SR 118:
- Casa Dei Maria Montessori School (8230 Fallbrook Avenue in West Hills along Roscoe Boulevard)
- Valley College of Medical Careers (8399 Topanga Canyon Boulevard in West Hills)
- Nevada Avenue Elementary School (22120 Chase Street in West Hills along Topanga Canyon Boulevard)
- Chatsworth Park Elementary School (22005 Devonshire Street in Chatsworth along Topanga Canyon Boulevard)
- Oakridge Preschool (10433 Topanga Canyon Boulevard in Chatsworth)
- Montessori of Chatsworth (10616 Andora Avenue in Chatsworth along Topanga Canyon Boulevard)
Routes 3 and 4 to US 101:
- Ivy Academia Entrepreneurial Charter School, 7353 Valley Circle Boulevard, West Hills
- West Hills Montessori, 24373 Vanowen Street, West Hills
- Stepping Stones Montessori, 24385 Vanowen Street, West Hills
- Hill Point Montessori Preparatory School, 6601 Valley Circle Boulevard, West Hills
- St. Bernardine Children’s Center, 24425 Calvert Street, Woodland Hills
- St. Bernardine of Siena Catholic School, 6061 Valley Circle Boulevard, Woodland Hills
- Temple Aliyah Jewish Preschool and Early Childhood Education Center, 6025 Valley Circle Boulevard, Woodland Hills
- El Camino Real Charter High School, 5440 Valley Circle Boulevard, Woodland Hills
10. What dust control measures will be taken to protect the community?
The cleanup implementation plan will include industry best practices and mitigation measures to protect on-site workers and nearby residents.
DTSC will require the use of dust controls and provide updates to the public on monitoring results. This will include spraying water on and covering soil stockpiles; monitoring upwind and downwind air; using remediation Best Management Practices; and covering soil that is being hauled offsite in trucks. DTSC will not allow the use of groundwater under the site for dust suppression purposes.
11. Will biological and cultural resources be protected?
DTSC has an obligation to protect human health and the environment, while also respecting biological and tribal cultural resources. State and federal law requires DTSC to consider exception areas. It is a tool routinely applied at cleanup sites across the country. There are a variety of cultural and biological resources at SSFL. Some include tribal areas of significance. Others include endangered plant species or animal habitat.
DTSC will identify areas of biological significance in consultation with the County, Department of Fish and Wildlife, and US Fish and Wildlife Service. It will identify areas of cultural significance in consultation with Tribes with cultural ties with the land. The public will have an opportunity to comment on proposed exception areas when DTSC circulates proposed cleanup decision documents.
DTSC must ensure that all cleanup decisions are protective of human health and the environment regardless of any applicable exceptions.
12. How will you protect cultural resources at SSFL?
Each responsible party (Boeing, Department of Energy, and NASA) is required to submit a Cultural Resources Management Plan to DTSC for review and approval. These Cultural Resource Management Plans will be implemented during cleanup activities in these responsible parties’ respective areas. An archaeologist will screen the work area prior to start of work. In addition, Native American monitors will be onsite during cleanup activities to identify, collect, and protect any Tribal cultural resources.
13. How will you protect biological resources at SSFL?
Responsible parties will be required to submit various plans, such as a Tree Management and Preservation Plan, Avian Protection Plan, Weed Management Plan, and Revegetation Plan, to DTSC for review and approval. In addition, focused surveys, which will be required for various species, will be conducted by qualified biologists in accordance with applicable protocol to identify the location of resources. DTSC will consult with regulatory agencies regarding RPs submitted plans as well as conservation plans or conditions the agencies will require. A U.S. Fish and Wildlife Service and California Department of Fish and Wildlife approved biologist will provide environmental awareness training to onsite workers prior to initial vegetation or ground disturbance as well as monitor wildlife during initial ground-disturbing activities or where work will be conducted within 100 feet of native habitats. Onsite seeds and cuttings of native plant species will be collected for propagation to be used in revegetation of the site.
14. What does a “resident with garden” cleanup referenced in the PEIR mean?
A “resident with garden” scenario means that the cleanup meets the standard for people to live onsite and safely consume homegrown produce from a backyard garden also called “resident 100% garden.”
15. What is the difference between a “resident 100% garden” exposure scenario and a “resident 25% garden” exposure scenario?
The resident with garden scenarios assume people will reside in the location and consume homegrown produce. The higher the percentage, the more stringent the cleanup. The resident 100% garden scenario assumes that 100% of all homegrown produce a resident consumes is grown in soil cleaned up to a specific cleanup level. Conversely, the resident 25% garden scenario assumes that only 25% of all homegrown produce a resident consumes is grown in soil cleaned up to a specific cleanup level. Unless otherwise specified in these FAQs, references to the “Resident with Garden” means the “resident 100% garden” exposure scenario.
Soil
1. How will soil be transported from SSFL?
All contaminated soil will be transported by trucks for offsite disposal. The trucks will be covered and travel on Woolsey Canyon Road, which is the only safe road for vehicles of that size. The trucks will then use other roads to reach the destination landfill(s) for disposal.
2. Where will soil be disposed of?
The soil removed from the site will have varying levels and types of contamination. Contaminated soil will be disposed of at a landfill that is appropriately licensed to accept the material and for which the soil meets the landfill’s acceptance criteria. Many landfills were identified in the PEIR, and the list will be narrowed down in the cleanup decision documents that will be made available for public review and comment.
The furthest potential facility by Responsible Party and by waste type was evaluated in the PEIR to conservatively estimate the potential impact to GHG emissions. Non-hazardous soil wastes (which is the majority of the waste) that can legally be disposed of within a properly licensed landfill in California and are accepted by the landfill, are anticipated to be disposed of in state as this is the most cost-effective method of disposal and lessens the environmental impacts.
Additionally, it is possible that other waste types including hazardous, non-hazardous liquids, petroleum-based contaminated waste, and non-hazardous scrap metal may also be disposed of in California. However, further analysis is required before this determination can be made. It is anticipated that low-level radioactive waste and other radioactive waste material would be disposed of out of state at an appropriately licensed facility. This is required for DOE wastes per the 2010 Administrative Order on Consent. Non-DOE radioactive wastes that are regulated under the Executive Order D-62-02 and/or the Compact Law (California Health and Safety Code Sections 115250–115270; relevant sections for disposal of “regulated radioactive material” are Section 115255, Article 2(I); Section 115255, Article 6(A); and Section 115261) would also likely have to be disposed of out of state at an appropriately licensed facility. At this time, we do not know exactly where the wastes will go. This type of information will be included in the cleanup implementation plans, which are anticipated to be submitted to DTSC for review starting in 2025. The disposal options and capacity considerations will be evaluated in more detail in the implementation plans.
It is possible that some non-RCRA hazardous waste could be disposed of out-of-state. If so, this will be reflected in decision documents and subject to public review and comment.
3. Why are trucks being proposed for soil transportation instead of conveyor-to-rail systems?
The analysis in the PEIR concluded that trucking is the most technically feasible and least environmentally impactful option for transporting SSFL soils to landfills. Because of the significant public interest in alternative transportation, DTSC did extensive, additional analysis of other alternatives. The conclusion that covered truck transport was least impactful was based on many contributing factors, such as the significant uncertainties and potential lengthy delays associated with land acquisition and permitting for a conveyor.
DTSC did not find any examples of conveyor systems that had been used for cleanups. A closed conveyor would only be appropriate for transporting non-radioactive contaminated soils off-site. It would not be feasible to transport any of the building demolition debris or radiological waste from the site, nor transport clean backfill soils back to the project site. A conveyor-to-rail alternative would result in environmental impacts to aesthetics, air quality, biological and cultural resources, health risks, hydrology and water resources, geology and soils, and land use that would be greater compared to the trucking option. A conveyor system would only reduce impacts for traffic and noise, while other impact categories would remain about the same. Higher conveyor implementation costs coupled with the lack of track record of conveyors used to transport hazardous wastes across private properties makes trucking on existing roadways the most feasible and least impactful transportation option. Lastly, the length of time required to build such a system is such that it would add no benefit during the first seven years of the cleanup.
4. Where will the backfill come from?
The PEIR evaluated the environmental impacts of trucking backfill in and DTSC is actively working with the Responsible Parties (RPs)to identify suitable backfill that is protective of human health and the environment. In October 2022, DTSC directed the RPs to develop work plans for identifying and evaluating potential backfill sources. RPs will provide draft work plans which identify potential backfill sources to DTSC for review and approval.
5. How will the community be protected during the soil transportation? What if spills occur? How will traffic issues be handled?
The cleanup implementation plans will include industry best practices to protect on-site workers and nearby residents during cleanup activities.
Most onsite excavation work will occur 5 days per week (Monday through Friday) approximately 11 hours per day between 7:00 am to 6:00 pm. Longer workdays during the summer and work on Saturdays may also occur. As the most technically feasible and least environmentally impactful option evaluated and identified in the Final PEIR, the transport of material offsite via trucks will be limited to off-peak hours (i.e., hours other than 7:15 am to 8:15 am and 4:45 pm to 5:45 pm). A comprehensive Site-Wide Traffic Management Plan outlining additional details will be developed before the start of the project as required by Mitigation Measure TRANS-1, Site-Wide Traffic Management Plan.
Soil in trucks will be covered and transported offsite for disposal. The trucks will go down Woolsey Canyon Road, which is the only safe road for vehicles of that size. The trucks will then use other roads to reach the destination landfill for disposal. Implementation of Mitigation Measures HAZ-1, Health and Safety Plan; HAZ-2, Hazardous Materials Containment; and HAZ-3, Hazardous Materials Business Plan, will ensure that hazardous materials are properly managed and transported to prevent or minimize releases. In addition, emergency procedures to be used in the event of an incident or spill and contact information will be provided in cleanup implementation plans before the start of cleanup work.
6. Why does it say “TBD” regarding dates for NASA and DOE to provide soil cleanup decision documents?
DTSC is working with NASA and DOE on selecting appropriate backfill, laboratory capability evaluation (for confirmation sampling), evaluation of cultural and biological resources. Once complete it is anticipated they will develop similar schedules to those followed by Boeing in the Settlement Agreement.
SSFL FPEIR Related Links
What is the Santa Susana Field Lab (SSFL)?
SSFL is a roughly 2,850-acre site in Simi Valley where rocket engine testing and nuclear research took place. DTSC is the lead regulatory agency overseeing the SSFL cleanup along with multiple state, federal and local government agencies. View the Final PEIR and get more information on our website.
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