Personal Communication with Federal and State Officials
The correspondence below concerning legislative, regulatory and operational actions related to the Santa Susana Field Laboratory (SSFL) has been prepared by myself, acting as a private citizen and community resident.
The material has benefited from the knowledge acquired during my twenty five years as Senior Manager of Radiation Safety at SSFL before my retirement. However the views and opinions expressed are mine alone, and do not necessarily reflect the views and opinions of The Boeing Company, the Department of Energy (DOE) or the National Aeronautics and Space Administration (NASA).
Neither Boeing, nor DOE, nor NASA has approved this correspondence, neither has it been sought. I alone am responsible for its content.
Senate Bill 990 (2007) and Health and Safety Code ยง 25359.20
Request for Revocation of SB 990 Language
after being Struck Down in Federal Court.
Request for Removal of SB 990 from DTSC Website. |
Date |
Communication |
November 16, 2020 |
Letter to Senator Henry Stern
Email transmitting above letter |
November 16, 2020 |
Letter to Grant Cope, DTSC
Email transmitting above letter |
November 16, 2020 |
Automated email from Senator Henry Stern's OffIce |
November 17, 2020 |
Email from Grant Cope, DTSC |
November 19, 2020 |
Letter from Attorney General's Office |
December 4, 2020 |
Letter to Attorney General's Office
Email transmitting above letter |
June 17, 2021 |
Email to Grant Cope, DTSC |
No substantive response has been received from Senator Stern or the California Attorney General or any others on distribution regarding H&S Code 25359.20.
As of 2023, DTSC finally removed all references to SB 990 from its web site.
|
2020 Amendment to Order on Consent
Opposition to Management of Non-radiological Building Debris
as Low-level Radioactive Waste |
Date |
Communication |
November 15, 2020 |
Questions and Issues Related to the Amendment to Order on Consent
Email
transmitting above paper
|
November 29, 2020 |
Letter to Steven Becker, DTSC
Email transmitting above letter |
March 11, 2021 |
Email to DTSC Management
Public Records Act Request for DTSC - CBG Communications |
March 26, 2021 |
Letter from DTSC Senior Counsel, Arthur Pugsley
Response to Public Records Act Request
Email transmitting above letter |
July 8, 2021 |
Email to DTSC Senior Counsel, Arthur Pugsley
Public Records Act Request |
July 16, 2021 |
Email from DTSC Senior Counsel, Arthur Pugsley
Public Records Act Request |
August 15, 2021 |
Letter to Meredith Williams, Director, DTSC
Public Records Act Request
Email transmitting above letter |
August 27, 2021 |
Letter from DTSC Senior Counsel, Ross Colburn
PRA Final Response - DTSC/Hirsch Communications
Email transmitting above letter |
August 28, 2021 |
Email to DTSC Management
Reply to PRA Final Response |
DTSC has failed to directly address my opposition to sending non-LLRW to a LLRW disposal site. |
2020-2021 DOE Waste Characterization at the Energy Technology Engineering Center
Review of Data Package for FOIA EMCBC-2022-00149-F
|
A FOIA request (EMCBC-2022-00149-F) was submitted for shipping records for the building demilition debris waste generated following the demolition of the non-RMHF decommissioned facilities and non-radiological facilities, discussed above.
Complaint to DOE Energy Technology Engineering Center
Review of waste profiles and waste manifests for decommissioned material and debris from buildings with no history of radiological use, reveals that falsified data has been used, in a blatant attempt to mischaracterize non-LLRW as LLRW.
Data on over 400 shipment manifests were systematically inconsistent and transparently illogical. Shipping manifest radionuclide concentrations did not match waste stream profiles. Multiple different containers with significantly different waste weights were assigned identical total and individual radionuclide activities, which is physically impossible. Multiple different containers were assigned identical waste weights and identical total and individual activities, which is physically impossible. Container weighted average concentrations were derived from container total and individual radionuclide activities rather than vice versa. The apparent falsification of data and total lack of any quality control of manifest data by all participants, North Wind, DOE and EnergySolutions is troubling.
A complaint was submitted to all levels of DOE management including ETEC, EM-1, and Secretary Granholm, North Wind management, EnergySolutions management, and DTSC management. All have failed to respond to, or dispute, these allegations.
Complaint to the DOE Office of Inspector General
A complaint was submitted to DOE's Office of Inspector General (OIG Complaint 23-0160-C). DOE closed the investigation at an indeterminate date stating that, "no further action was warranted." The OIG refused to say when the investigation was closed and why the complainant was not notified of the closure, citing unspecified "Privacy Act Restrictions." A FOIA request (HQ-2024-01160-F) was submitted February 8, 2024 for the investigation records. Several responses to this FOIA request were received obfuscating on issues of privacy, but failing to address the specific allegations of the original 23-0160-C complaint or the specifics of the HQ-2024-01160-F FOIA request. The OIG stated that the office of Mr. William White, the previous senior advisor to EM (aka EM-1) had provided a response to the original complaint on July 14, 2023. OIG later asked EM for approval to release that response on or before March 26, 2024. No response has been received as of September 23, 2024.
Complaint to the Utah Division of Waste Management and Radiation Control
A complaint was submitted to the Utah Division of Waste Management and Radiation Control (WMRC) (Complaint DRC-2023-001509). WMRC closed its investigation, stating that EnergySolutions had complied with its license and WAC requirements, however it did not address any of the specific allegations of the complaint, and it was unable to provide any documented evidence that any investgation of the allegattions had been conducted. A Utah GRAMA public records request was submitted, and a response confirmed that no records of the investigation existed. On April 21, 2024, a final appeal to WMRC was made to re-open the investigation of the specific alegations in the complaint. No response has been received as of September 23, 2024. No further attempts to communicate with WMRC will be pursued.
|
Date |
Communication with the DOE |
November 17, 2021 |
FOIA Request for Records - EMCBC-2022-00149-F
Letter from Michelle Farris, Office of Chief Counsel, DOE EMCBC |
September 29, 2022 |
Response to FOIA Request - EMCBC-2022-00149-F
Letter from Melody C. Bell, Deputy Director, DOE-EMCBC |
January 10, 2023 |
Letter to Josh Mengers, DOE ETEC Project Director
Response to FOIA Data Package
Email transmitting above letter |
February 10, 2023 |
Letter to DOE Inspector General
Shipments of Waste from the Former Energy Technology Engineering Center
Email transmitting above letter |
April 9, 2023 |
Email to the Utah Division of Waste Management and the DOE Inspector General
Irregularities in DOE's Waste Shipments from ETEC to EnergySolutions |
July 25, 2023 |
Waste Characterization by the Department of Energy at the Energy Technology Engineering Center
Presentation to the Health Physics Society Annual Meeting in National Harbor, Maryland
|
August 1, 2023 |
DOE Waste Characterization at the Former Energy Technology Engineering Center
Email to DOE, DTSC, North Wind, EnergySolutions, Utah DWMRC, and CalEPA.
Challenge to respond to allegations.
|
February 7, 2024 |
Complaint 23-0160-C
Email to DOE Inspector General requesting the status of the complaint
|
February 8, 2024 |
Complaint 23-0160-C
Email response from the DOE Inspector General stating that the investigation had been closed at an earlier unstated date. The OIG stated that, "no further action was warranted." A FOIA request would need to be submitted to learn of the results of the investigation.
|
February 8, 2024 |
FOIA Request for File on OIG Complaint 23-0160-C Investigation
Email to DOE FOIA Officel
|
February 8, 2024 |
Complaint 23-0160-C
Email to DOE OIG forwarding copy of the FOIA request
|
February 9, 2024 |
FOIA HQ-2024-01160-F
Acknowledgement letter from DOE FOIA Office |
February 12, 2024 |
Complaint 23-0160-F
Email containing third and final refusal of DOE OIG to tell me what date the investigation into Complaint 23-0160-C was closed and why I was not informed. OIG cited unspecified "Privacy Act Restrictions. The OIG declined tto explain why a closure date and the lack of notification to the complainant could be considered "private." |
February 22, 2024 |
Email to FOIA Office regarding HQ-2024-01160-F
Email request to the DOE FOIA Office for and estimated completion date for the FOIA request. Email also requested clarification why the investigation closure date and reason why complainant was not notified of the closure, was subject to "Privacy Act Restrictions." |
February 26, 2024 |
DOE FOIA Office Email Response
Email response from the DOE FOIA Office stating that the DOE FOIA Office will request records of the complaint investigation from DOE OIG, records that DOE OIG had refused to provide to the complainant. The DOE FOIA Office will then forward potential records to the complainant. The DOE FOIA Office was unable to provide an estimated completion date, and chose to ignore the question related to alleged "Privacy Act Restrictions." |
February 26, 2024 |
Email response to the DOE FOIA Office
Complainant questions the efficiency and transparency, or lack thereof,
of this process. |
March 6, 2024 |
Interim Letter from DOE FOIA Office HQ-2024-01160-F
Letter from DOE FOIA Office denies request for fee waiver and request for expedited response.
Email transmitting above letter. |
March 7, 2024 |
Letter to DOE FOIA Office HQ-2024-01160-F
Reply to DOE FOIA Office questioning requester status, and denial of fee waiver and expedited processing.
Email transmitting above letter. |
March 7, 2024 |
Email from FOIAOIG
Email from FOIAOIG verifying that the "FOIA request is in the search stage" and committing to "provide a response as quickly as possible."
|
March 27, 2024 |
Email from FOIAOIG
Attachments include ...
FOIAOIG also offered to provide copy of email by which complainant was notified that investigation was closed. |
March 30, 2024 |
Letter to Anthony Cruz, DOE OIG FOIA
Response to March 26/27, 2024 email and letter from FOIAOIG.
Email transmitting above letter. |
May 11, 2024 |
Email to Anthony Cruz, DOE OIG FOIA
Six week reminder of lack of resonse to March 30th letter. |
May 11, 2024 |
Email to Secretary of Energy, Jennifer Granholm
Expresses dissatisfaction over lack of meaningful response from her staff, and requests that she "rattles some cages."
Secretary Granholm did not have the common courtesy to reply. |
May 14, 2024 |
Email from Jennifer Bacon, FOIAOIG
Need to coordinate FOIAOIG and Hotline and will respond shortly.
|
May 14, 2024 |
Email to Jennifer Bacon, FOIAOIG
Suggests that FOIAOIG start with William White.
|
June 4, 2024 |
Email from Jennifer Bacon, FOIAOIG
Attachments ...
|
June 9, 2024 |
Letter to Anthony Cruz, DOE OIG FOIA
Response to 6/4/2024 email and 5/31/2024 letter from FOIAOIG
Email transmitting above letter. |
August 13, 2024 |
Telecon with Aleaander (Chris) Morris, DOE FOIA liaison. He committed to "look into" why EM's response to complaint 23-0160-C (Document 4) had not been released by EM and provided to me in response to FOIA HQ-2024-01160-F. |
August 14, 2024 |
Email from Jennifer Bacon, paralegal with DOE FOIAOIG, stated that no further communications would be forthcoming from OIG following Mr. Cruz's 5/31/2024 supplemental response, and that the whereabouts of Document 4 should be pursued with Alexander Morris. |
August 15, 2024 |
Email to Jennifer Bacon (FOIAOIG), Anthony Cruz (OIG) and Alexander Morris (FOIA) referencing my letter of June 9, 2024, and stating that the job of DOE FOIAOIG was far from over. |
August 15, 2024 |
Email from Alexander Morris (DOE FOIA Liaison) committing to chase down Document 4. |
August 31, 2024 |
Letter to DOE Office of Hearings and Appeals
Appeal to OHA for failure of OIG and FOIA Office to respond to 23-0160-C and HQ-2024-01160-F.
Email transmitting above letter.
|
September 3, 2024 |
Receipt acknowledgement from DOE OHA
Assignment of tracking no. FIA-24-0050 |
September 5, 2024 |
Letter denying Appeal FIA-24-0050
Cover letter for above denial
Email transmitting above denail |
September 8, 2024 |
Email to OHA replying to its denial of FIA-24-0050 |
September 10, 2024 |
Email from OHA, washing its hands of Appeal FIA-24-0050, and stating,
"This is the final order of the Department of Energy from which any aggrieved party
may seek judicial review pursuant of 5 U.S.C. Section 522(a)(4)(B)." |
September 23, 2024 |
Letter to U.S. Congressional Committee on Oversight and Accountability. Submiited to the Committee's online Whistleblower portal.
Email transmitting above letter to distribution |
|
Date |
Communication with the Utah DWMRC |
February 9, 2023 |
Letter to Doug Hansen, Director, Utah Division of Waste Management and Radiation Control
Shipments of Waste from the Former Energy Technology Engineering Center
Email transmitting above letter |
April 9, 2023 |
Email to the Utah Division of Waste Management and the DOE Inspector General
Irregularities in DOE's Waste Shipments from ETEC to EnergySolutions |
May 16, 2023 |
Letter from Utah WMRC
WMRC response finds that EnergySolutions complied with its license and WAC requirements, and did not accept greater than Class A LLRW from ETEC. This of course was not the allegation. None of the specific allegations in the complaint were adressed or disputed. WMRC closed its investigation. |
May 20, 2023 |
First Utah GRAMA Records Request
Request for complaint investigation records |
June 6, 2023 |
Email response to GRAMA Records Request
States that no records of the investigation exist other than those (e)mail communications between complainant and WMRC. Note that this email was not received on June 6, 2023, but was received February 9, 2024 |
July 20, 2023 |
Follow-up to Utah Complaint DRC-2023-001509
Email to Otis Willoughby, WMRC |
February 9, 2024 |
Utah GRAMA Records Request
Email to Utah Public Records Office
Attachment 2023-07-20 Email |
February 9, 2024 |
Email response from Alyssa Stringham, Utah GRAMA Records Officer
Email denying that records of investigation of Complaint DRC-2023-001509 exist |
February 9, 2024 |
Second Utah GRAMA Records Request relating to investigation of Complaint DRC-2023-001509
Email with GRAMA Records Request Form |
February 16, 2024 |
DRC-2024-004475
Letter including denial of appeal regarding complaint and GRAMA request dated May 20, 2023. Statement that specific allegations in the complaint were outside WMRC's scope of regulatory interest.
Email transmitting above letter. |
February 16, 2024 |
Response to February 9, 2024 GRAMA Records Request
Statement that no records exist of an investigation of the specific allegations of the complaint other than (e)mail communications between complainant and WMRC. |
February 17, 2024 |
Email request to Utah WMRC to re-open investigation into complaint regarding ETEC waste shipments
Requested WMRC re-open the investigation and address the specifics of the allegations of the complaint. |
April 21, 2024 |
Email to Assistant Director Jalynn Knudsen, Utah WMRC, requesting response to February 17, 2024 request to re-open investigation. |
As of July 26, 2024 no further communication from the Utah DWMRC has been received. |
|