BILL ANALYSIS                                                                                                                                                                                                    



                                                                       


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          |SENATE RULES COMMITTEE            |                  SB 1456|
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                                 THIRD READING


          Bill No:  SB 1456
          Author:   Kuehl (D)
          Amended:  As introduced
          Vote:     21

           
           SENATE ENV. QUALITY COMMITTEE  :  4-2, 5/3/04
          AYES:  Sher, Chesbro, Kuehl, Romero
          NOES:  Denham, McPherson
          NO VOTE RECORDED:  Figueroa


           SUBJECT  :    Santa Susanna Field Laboratory:  cleanup  
          standards

           SOURCE  :     Author


           DIGEST  :    This bill prohibits an owner or operator of the  
          Santa Susana Field Laboratory site in Ventura County from  
          using, selling, transferring, or leasing any part of that  
          site for residential use unless the United States   
          Environmental Protection Agency finds that radioactive  
          contamination at the site has been surveyed and remediated  
          in accordance with the federal Comprehensive Environment  
          Response, Compensation, and Liability Act of 1980 (also  
          known as CERCLA or the federal "Superfund" Law).  This bill  
          makes legislative findings and declarations that a special  
          law is necessary and that a general law cannot be made  
          applicable within the meaning of Section 16 of Article IV  
          of the California Constitution because of the unique legal  
          status and circumstances regarding radioactivity at the  
          Santa Susana Field Laboratory in Ventura County. 

                                                           CONTINUED





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           ANALYSIS  :    

          Existing law:

          1. Requires sellers and transferors of real property to  
             meet specified conditions and to make specified  
             disclosures prior to the transfer of those properties.

          2. Establishes conditions under which the State Department  
             of Health Services (DHS) may grant licenses for the  
             receipt of radioactive material for disposal on land and  
             prohibits the burial, throwing away, or disposing of  
             radioactive waste except in a manner that will result in  
             no significant radioactive contamination of the  
             environment. 
          
           Comments  

           Purpose of the bill  .  According to the author's office, the  
          Santa Susanna Field Laboratory (SSFL), on the border  
          between Ventura and Los Angeles Counties was contaminated  
          by both radioactive and chemical releases beginning in the  
          1950's.  The site has been used for rocket engine testing  
          and nuclear reactor research.  The site is primarily  
          controlled by the Department of Energy (DOE).  

          Because it is a defense facility, the cleanup standards are  
          set by DOE, although the United States Environmental  
          Protection Agency (US EPA) did serve in an advisory  
          capacity.  The DOE, however, has refused to follow US EPA  
          cleanup standards, and the US EPA has now ceased efforts to  
          work with the DOE.  EPA issued a public statement last year  
          indicating that the proposed cleanup effort by the DOE will  
          leave the site unsafe for any use other than recreation day  
          use, or other open space preservation.  This bill states  
          that the site may not be used for residential purposes  
          unless the site is cleaned up to US EPA standards for  
          residential use properties.

           Background on Radiation Exposure and Federal Clean-up  
          Standards  . According to the National Council on Radiation  
          Protection and Measurements, the United States population  
          receives a radiation dose of a little more than one-third  
          of a rem a year, mostly from background radiation.   







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          Although exposure to small amounts of radiation is believed  
          to cause fatal cancer or hereditary defects in human  
          beings, verification of this causal relationship is  
          difficult.  While roughly one in five deaths that occur in  
          the United States are from all types of cancer, the  
          estimated risk of dying from natural background radiation  
          (principally radon) in a lifetime is roughly one in 100.  

          According to the International Commission on Radiological  
          Protection, the estimated lifetime risk of cancer death  
          resulting from exposure to human-generated sources of  
          radiation (including medical sources) is much smaller,  
          estimated at one in 3,000.  Various federal laws and  
          regulations/standards have been developed and administered  
          by US EPA, the Nuclear Regulatory Commission (NRC), and  
          other agencies.  US EPA has a mandate to regulate  
          environmental contamination, including radioactive  
          contamination, while NRC has a responsibility to regulate  
          civilian uses of nuclear materials.

          The NRC issues licenses, and, in some cases, maintains  
          agreements with signatory states by which those states  
          regulate possession of certain radioactive materials for  
          certain uses (e.g., research and medical).  In California,  
          the DHS issues all of the licenses except for all federal  
          facilities and those facilities that exceed a specified  
          critical mass of special nuclear materials.  These licenses  
          include those issued for diagnostic and therapeutic medical  
          use, biomedical applications, research, and other purposes.

          Under CERCLA, "Superfund" sites are required to be  
          remediated by the US EPA to a level resulting in between  
          one in 15,000 and one in 1,500,000 additional premature  
          cancer deaths.  According to the author's office, sites  
          such as the SSFL, located on the border of the author's  
          district, are under the jurisdiction of NRC which has  
          low-level waste standards allowing for a level of residual  
          contamination resulting in a increased theoretical risk of  
          cancer death of one in 1,000.

          The exposure limits and risks associated with federal  
          radiation standards and guidelines established by these two  
          agencies differ in part due to a lack of interagency  
          agreement on the technical assumptions underlying various  







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          standards.  According to the United States General  
          Accounting Office, agencies' calculation methods often  
          differ, reflecting a major difference of philosophy and  
          giving different results. 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No    
          Local:  No

           SUPPORT  :   (Verified  5/4/04)

          Americans for a Safe Future
          California League of Conservation Voters
          Clean Water Action
          Committee to Bridge the Gap
          Concerned Citizens to Stop Outside Dumping
          Environment California
          Environmental Working Group
          Natural Resources Defense Council
          Physicians for Social Responsibility-Los Angeles
          Physicians for Social Responsibility-San Francisco Bay Area  
          Chapter
          Rocketdyne Cleanup Coalition
          Sierra Club California
          Southern California Federation of Scientists
          Susana Knolls Homeowners Association, Inc.
          Wishtoyou Foundation
          Ventura Coastkeeper

           OPPOSITION  :    (Verified  5/4/04)

          BIOCOM
          California Chamber of Commerce
          California Manufacturers and Technology Association
          California Radioactive Materials Management Forum (Cal Rad  
          Forum)
          California Space Authority
          Southern California Edison
          The Boeing Company

           ARGUMENTS IN SUPPORT  :    Supporters of this bill state that  
          the bill is a long overdue improvement to the cleanup  
          standards for the SSFL.  Supporters note that the site was  
          the location of a partial nuclear meltdown in the 1950's  
          and subsequently of other nuclear reactor incidents.   







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          Supporters state that the US EPA itself has issued a formal  
          finding that the site was cleaned up inadequately and that  
          further remediation should be undertaken to protect public  
          health and the environment.

          One proponent states:

          "It is baffling to us that this bill is necessary and that  
          Senator Kuehl is required to continue her fight to bring  
          some sanity to the management of the Rocketdyne site - a  
          former nuclear testing facility that is heavily  
          contaminated with radioactivity and other industrial  
          chemicals and that, by the U.S. EPA's own formal findings,  
          has not been adequately cleaned up to allow the land to be  
          sold or transferred for residential use or any other  
          unrestricted use.  Notwithstanding this formal finding, it  
          is our understanding that Rocketdyne, the site operator,  
          intends to open the site to uses that could include  
          unrestricted residential use, without cleaning up the site  
          or even adequately characterizing the contamination to the  
          satisfaction of U.S. EPA [and that] U.S. EPA has no  
          authority to block such unrestricted uses. 

          "If the U.S. Congress will not give the EPA the authority  
          to prohibit residential and other unrestricted uses on a  
          site contaminated with nuclear radioactivity, even after  
          the EPA has formally declared the site to be unsafe for  
          such uses, we hope the California Legislature will  
          demonstrate the necessary wisdom, common sense, and concern  
          for public health to do so." 

           ARGUMENTS IN OPPOSITION  :    Opponents state this bill  
          singles out one site for special, and more stringent,  
          cleanup requirements and imposes unreasonable requirements  
          on the site given the actual risks to public health and the  
          environment.

          Opponents state:

          "The U.S. Department of Energy and the California  
          Department of Health Services exercise regulatory  
          jurisdiction over portions of the Santa Susana site.  These  
          agencies are perfectly capable of overseeing completion of  
          the clean up,  decommissioning, and release of the site in  







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          a manner that will protect the public health and safety.   
          No portion of the Santa Susana site is a Superfund site,  
          therefore CERCLA is not applicable.

          "CERCLA uses hypothetical risk estimates which attempt to  
          extrapolate
          dose/response relationships observed at high doses at high  
          dose-rates to low doses at low dose-rates.  The U.S.  
          Nuclear Regulatory Commission (NRC) and every other state  
          use numerical dose standards plus the As Low As Reasonably  
          Achievable (ALARA) standard for remediation  
          decommissioning, and release of facilities where  
          radioactive materials have been used.

          "By agreement between the U.S. Department of Energy and the  
          Boeing Company, the numerical dose standard being used for  
          decommissioning and release at the Santa Susana facility is  
          lower than the standard required by the U.S. Nuclear  
          Regulatory Commission.  This decommissioning process has  
          been underway for many years. 

          "SB 1456 would disrupt and delay this process by attempting  
          to change regulatory jurisdiction and imposing procedures  
          that are not compatible with NRC requirements - all without  
          any benefit to the public health and safety."


          CP:mel  5/4/04   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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