The Ventura County Supervisor Board voted against NASA’s nomination to list the entire Santa Susana Field Lab (SSFL) in the National Registry of Historic Places (NRHP) by expanding the boundaries of a Native American site, located on SSFL property, from 11 acres to 2,850-acres, exactly matching the boundaries of SSFL. The Supervisors saw right through NASA’s attempt to evade their legal cleanup obligations by misusing exemptions in the cleanup agreement for Native American artifacts, and they knew that if the cleanup didn’t happen first, then hundreds of thousands of people’s health could be at risk. It was a win, but the biggest fight is coming.

This coming Friday, the California State Historical Resources Commission (SHRC) will have the final vote on whether or not NASA’s scheme is approved. The SHRC says it will not take health risks into consideration.

We need everyone to send an email to the SHRC Commission asking them to reject the nomination until after the SSFL has been cleaned up. 

Because if NASA’s nomination passes, it could severely limit, or even kill, the Santa Susana Field Lab’s cleanup. Once the site is cleaned up and restored as promised in 2010, then the listing can be reconsidered. But not before that.

Send comments via email to: calshpo.shrc@parks.ca.gov by midnight, TODAY August 11, 2020. Put “OPPOSE SSFL/Burro Flats Nomination” in the subject line. Please see the talking points below to help inform your comment.

In addition to sending in written comments by Tuesday, register for the Friday Zoom meeting and ask to speak during the meeting. On the Zoom registration form, please check the option to speak on “Item IX.A.1: Burro Flats Cultural District.” Prepare comments to fit within the three minute time limit for public comment. 

Thank you for continuing to fight for the cleanup our community deserves and that NASA is legally obligated to carry out.

Sincerely,
Melissa Bumstead

THREE TALKING POINTS:

POINT ONE: NASA’s proposal to list the entire 2,850 acre SSFL on the National Register of Historic Places is a blatant effort to get out of its commitments to clean up the contamination it created at the site.  The proposal should be rejected because it doesn’t meet the requirements for listing.

• NASA’s nomination of SSFL does not meet listing criteria because it is grossly incomplete. There is not a word in it about the extensive radioactive and toxic chemical contamination, or the numerous reactor accidents and rocket tests that polluted the site.
• The nomination doesn’t meet the criteria because it is grossly inaccurate.
  It is based on the extraordinarily false assertion that the site is unimpacted and is in the condition it was in when Native Americans occupied the region hundreds of years ago. In fact, SSFL is one of the most contaminated sites in the nation. Decades of reckless nuclear activities and rocket-engine testing have damaged the land and heavily contaminated it.  Ten reactors operated at the site, one of which suffered a partial meltdown and three others experienced other accidents. Tens of thousands of rocket tests further impacted the site, with massive chemical pollutants poisoning the soil and groundwater. But NASA omitted this critical information. 

POINT TWO: The contamination on site continues to impact the integrity of the land.  NASA claims they will cleanup up the site, but may try to use their own supplemental cleanup standards that could leave up to 90% of the contamination on site, instead of using the legally binding 2010 "AOC" cleanup standards.

• Approximately one million gallons of carcinogenic TCE were poured into unlined ponds and  extensively contaminated the soil and groundwater beneath the site.
  Our community has been fighting for the SSFL clean up for over 30 years. The contaminated water and land has made some of our families sick. The contamination on site continues to impact the integrity of the land on and off-site.
• The polluted SSFL property must not be left unremediated to poison nearby communities and future site visitors

POINT THREE: The proposal for listing does not meet the eligibility requirements because it provides no defensible rationale for the proposed boundary matching that of SSFL.

• The Burro Flats Site has been listed in the NRHP since 1976 and was just reduced in size last month from 25 to 11 acres. NASA now wants to expand that 200-fold to 2,850 acres, exactly matching SSFL property lines. Nominations are not supposed to be based primarily on property lines, and NASA’s sole rationale for the dramatic expansion is that the site activities left the property unimpacted - but nothing could be further from the truth.
• By having the entire SSFL property listed on the NRHP, NASA, the Department of Energy and Boeing can attempt to get out of the cleanup by misusing exemptions in the cleanup agreement that are limited to Native American artifacts. Dispute resolution procedures and litigation to stop this could delay the cleanup essentially forever.  Without the 2010 AOC cleanup the polluters could leave virtually all of the contamination on site not cleaned up. If they approve NASA’s scheme, the site would never get cleaned up--and it would never be restored so that it would be safe for Native Americans and others to go on the site and for people to live nearby. 

NASA’s effort is a blatant effort to get out of its 2010 cleanup obligations for the site.  The proposal fails to meet the listing criteria and should be rejected.