From: NASA Office of Inspector General
Posted: Friday, March 22, 2019
Full report https://oig.nasa.gov/docs/IG-
WHY WE PERFORMED THIS AUDIT
Beginning in 1948, the Santa Susana Field Laboratory (SSFL), located 30 miles northwest of downtown Los Angeles, was used for nuclear energy research by the Department of Energy (DOE) and rocket engine testing by the United States Air Force and NASA. Nuclear research concluded in 1988 and rocket engine testing concluded in 2006, resulting, respectively, in radiological and chemical contamination of the soil and groundwater at the site. Today, NASA is responsible for environmental remediation of more than 450 acres at SSFL, while DOE is responsible for cleanup of about 400 acres and the Boeing Company (Boeing) the remaining 2,000 acres.
In 2010, NASA agreed to clean the soil on its portion of the site to the most stringent standard, known as Background level, despite the fact that a risk‐based cleanup typically would be less extensive. In a 2013 audit, we reported that cleaning the soil to a Background level by 2017 would cost $209 million. To date, soil cleanup has not begun, and the scope of the planned cleanup has grown significantly; NASA’s current projections estimate the cost at over $500 million for an effort that could take until 2045 to complete. Further complicating the situation, the State of California has yet to finalize the exact parameters of the cleanup requirements for the NASA and DOE sites. Meanwhile, Boeing, the majority landowner at SSFL, plans to clean the soil on its portion of the site to a less stringent Recreational level.
In light of the Agency’s inability to advance its cleanup efforts, the more than doubling of estimated cleanup costs, and the substantial disparity in planned cleanup levels between the adjoining Boeing and NASA properties, we examined the status of NASA’s environmental remediation activities at SSFL and assessed the extent to which the Agency is conducting these efforts in a cost‐effective manner. In the course of our audit work, we also examined the financial impact of the Agency’s indecision on whether to preserve or demolish obsolete test stands at the site. To complete this audit, we reviewed NASA’s remediation cost estimates and work plans, contract documents, environmental impact studies and reports, federal and state laws, and environmental policies, regulations, and procedures documentation; we interviewed NASA, California’s Department of Toxic Substances Control, U.S. Environmental Protection Agency, DOE,
U.S. Department of Justice, Boeing, and U.S. and California fish and wildlife services officials.
Towards the conclusion of our review, a major California wildfire known as the Woolsey Fire damaged almost
97,000 acres between the field lab and the Pacific coastline. A significant portion of NASA Area II burned, but estimates of the potential impact to the scope and schedule of cleanup activities in the NASA‐administered areas of SSFL were not yet available.
WHAT WE FOUND
Under the terms of agreements signed with the State of California in 2007 and 2010, NASA is responsible for remediating groundwater and soil contamination at its portions of the SSFL site. However, we question the reasonableness and feasibility of the Agency’s current agreement to clean the soil to a Background level. This cleanup approach is not based on risks to human health and the environment or the expected future use of the land—the standard practice for environmental remediation at similar sites. Further, a soil cleanup to the current levels set by the State of California is expected to cost NASA more than a half billion dollars, take as long as 25 years to complete, and significantly damage flora and fauna at the site. In contrast, soil cleanup to the Recreational level—the standard more in line with the expected future use of the land—would cost about $124 million and take approximately 4 years to complete. As such, we question a total of $377 million in unfunded environmental liability costs associated with NASA’s current SSFL soil cleanup plans as funds that could be put to better use.
Compounding our concern is the fact that soil remediation levels envisioned by the existing cleanup strategy are likely not achievable. For example, NASA is currently required to take steps to ensure contaminants in the soil are reduced to an unprecedented degree—in some cases lower than naturally occurring levels. Such a strategy would result in highly invasive and prolonged soil removal efforts and difficulty locating soil sufficiently “clean” enough to use as backfill. At a minimum, this approach will likely result in significant destruction of the property’s aesthetic value as well as its biological and cultural resources. Moreover, the significant difference in planned remediation levels between the NASA and Boeing sites coupled with the intertwined geography of the two properties will lead to continuous cross‐ contamination between the sites.
At the urging of several members of the California congressional delegation, NASA has delayed its decision on whether to demolish or preserve the remaining test stands and control houses at SSFL until soil cleanup is complete. By delaying this decision until as late as 2045, the Agency could potentially spend an additional $18.7 million for demolition or $17.2 million for preservation based on inflation alone—funds we believe could be put to better use if NASA made a more timely decision. The deteriorating physical condition of this infrastructure also represents a liability to the Agency as NASA seeks to clean up the site and prepare the property to be transferred or sold.
WHAT WE RECOMMENDED
To ensure the most effective and efficient cleanup of SSFL, we recommended that the NASA Administrator, with the assistance of the Associate Administrator for Mission Support and the Agency’s General Counsel, (1) pursue all available options—administrative, legal, or political—to ensure NASA’s SSFL soil cleanup is performed in an environmentally and financially responsible manner based on the future use of the property; and (2) decide whether to preserve or demolish the remaining test stands and related structures before soil remediation begins and take action on that decision.
In response to a draft of this report, NASA management concurred with our recommendations and described corrective actions they plan to take. We consider management’s comments responsive; therefore, the recommendations are resolved and will be closed upon verification and completion of the proposed corrective actions.
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