Submitted by

G. Fred Lee, PhD, MSPH, DEE
Technical Advisor, DSCSOC
G. Fred Lee & Associates

August 12, 1995

One of the first questions that the public who reside at or use properties near the University of California, Davis - Department of Energy (UCD - DOE) LEHR national Superfund site ask is whether past waste disposal practices and activities at this site have endangered their health. One, but not the only, potential cause of health endangerment is the transport of waste-associated constituents deposited at the LEHR site by UCD and DOE from this site via groundwater to nearby neighbors' wells. Beginning in 1989, UCD initiated a bottled water program in which bottled water is provided periodically to about 10 families who, at the time that the program was initiated, were believed by those who organized the program to be in the potential sphere of influence of LEHR site contaminated groundwaters.

Also in 1989, UCD initiated a groundwater monitoring program on selected domestic and irrigation wells within the believed sphere of influence of LEHR site polluted groundwaters. In June 1995, UCD - DOE proposed to terminate providing bottled water to selected nearby neighbors. This report reviews the information that has been made available to the potentially impacted public (Davis South Campus Superfund Oversight Committee - DSCSOC) by UCD and DOE on the chemical characteristics of the groundwaters that have been sampled as part of the nearby neighbors' wells groundwater monitoring program conducted by UCD and DOE. It also discusses the appropriateness of terminating the bottled water program.

When the author of this report (Dr. Lee) first was appointed as the Technical Advisor to the DSCSOC in mid-June 1995, he, through DSCSOC, specifically requested certain information of UCD and DOE on the previous and current LEHR off-site groundwater monitoring program such as what is the current groundwater monitoring program that is being conducted by UCD - DOE on the nearby neighbors' wells. Also, has the data on the nearby neighbors' wells' groundwater monitoring program been compiled and critically reviewed? Thus far, approximately two months after this request was made, this information has not yet been made available to the DSCSOC. An area of particular concern is the compilation of data that the minutes from the June 13, 1995 RPM meeting indicated that UCD was to provide to the RPM members by the end of June 1995. Therefore, this report cannot at this time be considered a definitive report on this topic, since some of the key information that is known to exist and is needed to evaluate past and current LEHR Superfund site off-site groundwater monitoring programs has not been made available.

This report is being made available to UCD, DOE and the regulatory agencies in a draft form for their review and comment. Hopefully, the gaps that now exist in the information base on the bottled water program and the nearby neighbors' wells' groundwater monitoring program will soon be eliminated.

In the discussion of LEHR site-derived wastes, no attempt is being made to distinguish between UCD waste disposal practices that took place prior to the LEHR site program that involved the evaluation of the impact of radioisotopes on animals. UCD has operated three campus landfills in what now is considered to be the LEHR Superfund site. Also, UCD operated a campus wastewater treatment plant which potentially had sludge drying beds that could have contaminated groundwaters. For the purposes of this report, the use of the term "LEHR site-derived wastes" is intended to be inclusive of all waste disposal practices that are now being considered as a source of soil and groundwater pollution at the LEHR site.

Pollution of Groundwaters Under the LEHR Site by UCD - DOE Waste Disposal Practices

The waste disposal practices at the LEHR site have resulted in the pollution of groundwaters under this site by a variety of radionuclides, hazardous chemicals, conventional pollutants and unmeasured, unregulated non-conventional pollutants. At this time, the degree of pollution of the aquifer systems under the LEHR site waste management units is poorly understood.

Off-Site Groundwater Transport of LEHR Site Waste-Derived Constituents

At this time, the rate and aerial extent of groundwater pollution under the LEHR site and adjacent properties is not known. It appears from recently developed data, however, that some of the groundwaters under the LEHR site may be moving laterally at about 1,000 feet/year. This could mean that hazardous or otherwise deleterious chemicals derived from waste disposal practices at the LEHR site could have been transported from five to ten miles from that site in the approximately 50 years that wastes have been deposited at this site.

In addition to polluting the upper-most aquifer under the LEHR site by waste-derived constituents, it is likely that LEHR site wastes have polluted the second aquifer under the site. This aquifer is being used by the city of Davis, village of El Macero and three other water utilities as a domestic water supply, all of which have wells that are in the currently projected potential sphere of influence of groundwaters polluted by waste-derived constituents from the LEHR site. At this time, there are eight municipal domestic water supply wells and a number of private wells in the sphere of potential influence of the LEHR site waste disposal practices.

The waste disposal practices at the LEHR site will likely cause the development of a large number of finger-like plumes of hazardous and deleterious chemicals that can travel in the groundwater systems for considerable distances with limited lateral spread. The detection of these plumes will require a much more intensive groundwater monitoring program than typically conducted at Superfund or otherwise hazardous chemical sites.

Results of Off-Site Groundwater Quality Monitoring

At this time, the UCD - DOE groundwater monitoring program that has been conducted on domestic and agricultural wells located on nearby properties to the LEHR site has apparently not detected any significant pollution of groundwaters by LEHR site derived wastes. A number of wells, however, show concentrations of hazardous chemicals at or above drinking water standards (MCLs). It is not possible, however, to rule out that UCD - DOE LEHR site waste disposal practices have resulted in an increase in concentrations of constituents in off-site groundwaters and nearby neighbors' wells.

At this time, inadequate attention has been given by the LEHR Superfund site investigations and by the city of Davis, village of El Macero and others to detect incipient groundwater pollution for those municipal domestic wells and private wells that are in the potential sphere of influence of LEHR site derived wastes.

Adequacy of the Groundwater Monitoring Program

The UCD - DOE monitoring program for nearby neighbors' wells is significantly deficient compared to the program that should have been developed to provide for high levels of public health and groundwater resource protection from pollution by LEHR site wastes. An insufficient number of hazardous chemicals that are known waste constituents at the LEHR site has been reliably monitored in the groundwaters under adjacent properties. Further, inadequate attention has been given to the pollution of these waters by conventional pollutants that could render the water unusable for domestic purposes. Apparently, no attention has been given to the non-conventional pollutants in LEHR site wastes that could be hazardous or deleterious to adjacent and nearby neighbors who wish to use groundwaters for domestic and other purposes.

Appropriateness of Terminating Bottled Water Program

Based on the limited information available on the degree and extent of groundwater pollution by LEHR site derived waste and the inadequate groundwater monitoring program that has been conducted at nearby neighbors' wells, it is concluded that it would be highly inappropriate to terminate the bottled water program. If anything, because of the much larger sphere of influence of waste-derived constituents than previously thought, consideration needs to be given to possibly expanding this program to protect public health and other interests of those who rely on groundwaters down-groundwater gradient from the LEHR site as a source of domestic and agricultural water supply.

Reformulating LEHR Off-Site Groundwater Monitoring Program

The DSCSOC should initiate efforts to work with LEHR site regulatory agencies, DOE, UCD, the city of Davis, village of El Macero, Yolo and Solano County Environmental Health and others to develop a more appropriate groundwater monitoring program for off-site production wells that will detect incipient contamination of the groundwaters at these wells by LEHR site derived waste constituents.

Context of Report

This report is designed to assist the public in understanding the general aspects of the current state of knowledge of the impact of past LEHR site waste disposal practices on off-LEHR-site groundwater quality. It is important that anyone who reviews this report take the time to understand the complex issues that are addressed herein. Reviewers of this report should not take out of context statements made herein that attempt to simplify complex issues in order that the public may gain insight into the public health and other hazards associated with past LEHR site waste disposal practices.

It would be highly inappropriate to conclude from this report that past waste disposal practices at the LEHR site have caused or could, in the near future, cause significant public health harm to those municipal entities and individuals with private wells that are utilizing groundwaters within the potential sphere of influence of the LEHR site. While the current data are limited, the data are adequate to conclude that individual property owners' wells or municipal water supply wells have not been significantly impacted by LEHR site-derived wastes. There is, however, a significant public health threat that must be addressed to ensure that the hazardous and detrimental levels of chemical constituents and radioisotopes found in groundwaters immediately under the LEHR site do not cause significant pollution of off-site groundwaters.

The US EPA Superfund, State of California Department of Toxic Substances Control and State of California Water Resources Control Board investigation and remediation programs that are being conducted at the LEHR site should, if implemented in the appropriate manner, stop the further spread of polluted groundwaters arising from LEHR site waste disposal practices and should also clean up existing groundwater pollution so that further off-site impairment of the uses of groundwaters by adjacent or nearby property-owners will not likely occur.

The author of the report would be happy to meet with anyone to discuss these issues.

Introduction

Because of the potential for the University of California, Davis - Department of Energy (UCD - DOE) LEHR site past waste disposal practices to pollute groundwaters that are being used by nearby neighbors - users for domestic water supply purposes, the University of California, Davis initiated a bottled water program where bottled water was periodically provided to selected nearby neighbors. This program is currently active and has been recently assumed by DOE. In June 1995, a proposal was set forth by UCD - DOE to stop providing bottled water to nearby neighbors - users. This proposal was apparently based on the results of a UCD water quality monitoring program of the groundwaters that are used by nearby neighbors for domestic and other purposes.

This report presents a discussion of the appropriateness of continuing the bottled water program. It also discusses the adequacy of the current groundwater monitoring program that UCD has been conducting on the nearby neighbors' wells in protecting the public health and other interests of those who use this groundwater.

This report is based on examination of the data and information that UCD and DOE have provided to the Davis South Campus Superfund Oversight Committee (DSCSOC) in connection with the LEHR site investigation. The author is aware that additional data pertinent to this review exists but has not yet been made available to the DSCSOC. This report is, therefore, being made available in draft form in order that those concerned with this issue can bring to the attention of the author any information that should be considered in finalizing a discussion of this issue.

Groundwater Pollution at the LEHR Site

Past waste disposal practices by UCD and DOE at the LEHR site, as well as by UCD's three campus landfills located at this site and possibly the UCD former wastewater treatment plant that was located in this area, have caused pollution of groundwaters at the LEHR site by a variety of hazardous and deleterious chemicals which would cause a groundwater to be unusable for domestic and other purposes. Apparent pollutants in the groundwater derived from LEHR site former waste disposal practices include: various radioisotopes such as tritium, strontium-90 and radium-226; chlorinated solvents including chloroform; pesticides such as chlordane; hazardous chemicals such as chromium and nitrate; and a variety of conventional pollutants associated with municipal solid waste leachate as well as a variety of unmeasured and/or unregulated chemicals that can be significantly hazardous to public health and the environment and detrimental to those who own or use properties within the sphere of influence of the LEHR site. At this time, this sphere of influence is believed to potentially extend for a number of miles, i.e. on the order of 10 miles, generally in an easterly direction from the site. There could, however, be localized pollution of groundwaters to the south, west and north of the LEHR site.

The investigation of the various waste disposal areas at the LEHR site shows that the pollution of groundwaters is such at this time that the individual plumes, as well as any larger plumes arising from the three UCD campus landfills, have not been defined. Because of past waste disposal practices, it is likely that there are a large number of small plumes, in terms of lateral dimensions, of hazardous and/or deleterious chemicals arising from the various waste disposal areas that have been used at the LEHR site. These plumes, however, may extend for considerable distances down groundwater gradient from the site. There may also be several larger plumes arising from a grouping of waste disposal pits/trenches, dry wells, dog pens, septic tanks and associated leach fields, Imhoff tanks, landfills and sludge drying beds if they were used at the former wastewater treatment plant.

The groundwater investigations under the LEHR site have shown that some of the groundwaters under this site are highly polluted with a variety of chemical constituents that are hazardous to public health and are detrimental to the interests of those who may use these waters for domestic or other purposes. While at this time the extent and degree of groundwater pollution under the LEHR site is poorly understood, there is no question that past disposal practices have resulted in substantial groundwater pollution and that many of these pollutants may have been and will be, if corrective action is not initiated, already transported via groundwaters under adjacent properties.

There will need to be a substantial groundwater remediation program initiated to stop the further spread of polluted groundwaters, to clean up to the maximum extent practicable the pollution that has occurred thus far and to eliminate further pollution of the groundwaters by the various waste disposal sources that exist at the LEHR site.

Hydrogeological Characteristics of LEHR Site Groundwaters

Underlying the LEHR site and the region, including the city of Davis, are several aquifer systems that can be polluted by waste-derived constituents from the LEHR site. The uppermost aquifer system extends from the ground surface down to about 140 feet below the ground surface. This aquifer consists of three areas. There is an unsaturated (vadose) zone that extends to 30 to about 60 feet below the ground surface, depending on the season of the year. This zone typically does not contain any recoverable groundwater; however, LEHR site waste-derived constituents pass through this zone via temporary saturation associated with precipitation events and through unsaturated transport as a film of water on the surfaces of the aquifer particles. The water table in the uppermost aquifer varies seasonally about 20-30 feet, with the low occurring in late summer - fall and the high after the spring rains.

The upper part of the aquifer, which extends from near the surface down to about 80 feet below the surface, consists of interbedded silt, clay and sand with some sand and gravel channel deposits. The saturated part of this aquifer (referred to by LEHR site investigators as HSU-1) is characterized as having a low permeability which would impede to some extent the movement of groundwaters.

Beginning at about 80 feet and extending to about 135 feet below the ground surface is a layer of cobbles and gravel (referred to by LEHR site investigators as HSU-2). This layer has a high permeability and therefore will allow for rapid transport of any pollutants entering the layer laterally to LEHR off-site properties' associated groundwaters. There is no low permeability clay layer that separates HSU-1 from HSU-2, although HSU-1 is characterized as an aquatard (low permeability layer).

At about 135 feet below the ground surface is a clay layer. The thickness of this clay layer is not well known. It is expected to impede the vertical transport of pollutants present in HSU-2, although, as discussed below, this clay layer is apparently not preventing the migration of pollutants present in the uppermost aquifer from entering the second aquifer below the LEHR site. While the uppermost aquifer is generally used for individual neighbors' wells, information provided to the author (Dr. Lee) by the city of Davis Department of Public Works indicates that the City's domestic water supply wells, as well as those of the village of El Macero, are screened to take water from the second aquifer system. There is a possibility, however, that, since these wells are gravel-packed around the well casing into the upper aquifer, that water from the upper aquifer (HSU-2) enters the lower aquifer via the gravel-packing around the wells that penetrate through the clay layer separating the two aquifers.

It is the second aquifer that is being polluted by nitrate believed to be derived from agricultural use of fertilizers on row crops in the Davis area. At this time, a number of city of Davis domestic water supply wells that are designed to primarily take water from the second aquifer are showing steady significant increases in nitrate. This pollution indicates that pollutants derived from the surface of the soil are being transported down through the uppermost aquifer and into the second aquifer in the Davis area. Therefore, not only have LEHR site waste-derived constituents polluted the uppermost aquifer (both HSU-1 and HSU-2), but the second aquifer has likely been polluted by LEHR site waste-derived constituents as well. However, as discussed above, at this time the degree and extent of pollution of the uppermost aquifer and the second aquifer by LEHR site-derived waste is poorly understood.

While it seems from the information available that the general direction of movement of groundwater under the LEHR site is toward the northeast, at times it moves in an easterly or southeasterly direction. Further, it is not possible at this time to rule out groundwaters from the LEHR site having at some time in the past or in the future moved to the south, west or north arising from localized pumping of domestic and/or agricultural wells. It will be important to develop a program where all uses of groundwater in the region are closely monitored to determine their influence on the extent, degree and direction of groundwater pollution that has occurred at the LEHR site.

Pollution of LEHR Off-Site Groundwaters by LEHR Site-Derived Wastes

The leading edge of any groundwater pollution plumes arising from waste disposal practices at the LEHR site has not been defined, and therefore the extent of pollution of groundwaters by the LEHR site is unknown. While for several years it has been believed that the groundwaters under the LEHR site are moving at a rate of about 57 feet/year, recently DOE contractors have determined that apparently a significant error was made in estimating this value, where now it is believed that groundwaters under this site could be moving at the rate of about 1,000 feet/year. Since waste disposal at the LEHR site UCD campus landfills began in the 1940s, this means that water supply wells generally east of the LEHR site, although other directions are possible, could be contaminated by LEHR site-derived wastes to a much greater distance than previously thought. This distance could be on the order of 10 miles from the site. Until recently, it was generally concluded that the lateral spread of waste-derived pollutants from the LEHR site was no more than one-half mile from the site.

The new estimates of groundwater velocity greatly change the potential sphere of influence of LEHR site waste-derived constituents from that which was previously thought. The neighbors' wells that have been monitored by UCD are located within two miles of the site. Within the currently conceived sphere of influence of LEHR site-derived wastes are a number of additional individual neighbors' domestic and agricultural wells, three city of Davis domestic water supply wells, two village of El Macero domestic water supply wells and three private water company domestic water supply wells located west of El Macero and south of I-80. No information is available to the author (Dr. Lee) at this time on the characteristics of the three small water company wells. They are not part of the city of Davis system of water supply wells. Information is being provided to the author by Yolo County Environmental Health on the characteristics of these wells and the waters in them. This information will be incorporated into the final version of this report.

Therefore, there are several large municipal wells and a number of other domestic or agricultural wells apparently downgradient from the LEHR site that could be polluted by LEHR site-derived wastes. At this time, however, it does not appear from the limited data available that significant pollution of the nearby neighbors' wells as well as the city of Davis's and village of El Macero's domestic water supply wells has occurred because of LEHR site waste disposal practices. However, from the information available at this time, it appears that inadequate attention has been given to detecting incipient contamination of LEHR off-site groundwater by LEHR site-derived wastes. It is very important that a groundwater monitoring program be developed for all wells that take groundwaters within the potential sphere of influence of the LEHR site wastes to detect incipient pollution of groundwaters by LEHR site wastes before sufficient pollution has occurred that represents significant public health harm or detrimental impact to those who use these groundwaters for domestic or other purposes.

While the city of Davis and other communities in the region conduct the regulatory agency required monitoring of all communities providing groundwater-based domestic water supplies, the data that have been collected over the years have apparently not been critically analyzed by the City, regulatory agencies, LEHR site investigators or others for trends that would indicate that incipient groundwater contamination by LEHR site-derived wastes is not occurring at this time. This is an area that needs attention. DSCSOC should work with the regulatory agencies, UCD, DOE, the city of Davis, the village of El Macero, private water companies and others in developing a program of off-site production well monitoring that will have sufficient sensitivity and reliability to detect incipient contamination of groundwaters by LEHR site-derived wastes. Further, it will likely be necessary to significantly increase the monitoring of municipal groundwaters in order to be able to detect incipient LEHR site-derived waste contamination of the waters pumped by the various wells within the currently conceived sphere of influence of LEHR site-derived wastes.

Recently, the author (Dr. Lee) has initiated a review of the characteristics of the city of Davis groundwaters that are used for domestic water supplies. The City Department of Public Works has provided him with a set of groundwater quality monitoring data. These data show that a number of City wells are experiencing a significant steady increase in nitrate concentrations. For some of these wells, the nitrate concentrations are increasing at a sufficient rate so that, within a few years, the City will have to abandon the use of these wells because of excessive nitrate or provide expensive wellhead treatment to remove nitrate. According to the City Department of Public Works staff, the estimated cost of this treatment is about $500,000 per well.

This increase in nitrate is not associated with the LEHR site pollution of groundwater. It appears to be due to agricultural use of nitrogen fertilizers on row crops. Some of the highest concentrations and greatest rates of increase in nitrate concentrations are occurring on the west side of Davis near the UCD agricultural properties.

The increased nitrate is occurring in the second aquifer, thereby demonstrating the hydraulic connection between the upper-most aquifer and the second aquifer. It is likely, either naturally or through abandoned wells or improperly sealed wells in the vicinity of the clay aquatard between the upper-most aquifer and the second aquifer or through gravel pack around existing production wells, that there is significant potential for pollutants that enter the upper aquifer (HSU-2) to cause pollution in the second aquifer as well. It appears to the author that, thus far, the LEHR site investigation has not evaluated the pollution of the second aquifer by wastes deposited at the LEHR site in the burial trenches, pits and in UCD's three campus landfills located at this site.

The water quality monitoring program conducted by UCD of the nearby neighbors' wells has focused on the measurement of chromium, nitrate, gross alpha and gross beta radioactivity, and tritium. It appears that data have been obtained for these parameters about quarterly since the program was started in 1989. There has also been some sampling for other constituents, although from the data available this sampling has been non-systematic and is of limited value other than to indicate that, at the time of sampling, significant exceedances of drinking water standards were not occurring.

At this time, apparently the data evaluation for the groundwater monitoring program conducted by UCD on nearby neighbors' wells has only been examined to determine whether concentration of a few of the constituents that have been deposited as wastes at the LEHR site have caused domestic water supplies and some agricultural wells to exceed domestic water supply maximum contaminant levels (MCLs). From this perspective, the data that have been made available to the DSCSOC show that, while there are some concentrations of nitrate, chromium and gross alpha radioactivity in some nearby neighbors' wells that are at or near drinking water MCLs, the majority of this data shows that, for the parameters examined, the concentrations found in the well water are below MCLs. The concentrations of many of the parameters are somewhat variable for each sampling period. This variability makes the detection of incipient contamination from the LEHR site-derived wastes difficult to achieve. It is also possible that those exceedances of MCLs that are being found in some of the wells are due in part to LEHR site-derived wastes. A much more comprehensive, frequent sampling program is needed to determine whether chemical constituents in the nearby neighbors' wells are derived to any extent from LEHR site-derived wastes.

The quality of the groundwater monitoring program developed by UCD, and apparently until recently conducted by UCD, is significantly less than that necessary to protect public health and other interests of nearby neighbors - users from pollution of their groundwater supplies by UCD - DOE LEHR site-derived wastes.

Termination of the Bottled Water Program

It is inappropriate to conclude that because none of the groundwater monitoring results from the various members of the public wells who have been previously designated as potentially impacted by the LEHR site waste disposal practices by UCD and DOE have failed to show pollution by the site, that this is justification for termination of the bottled water program. At this time, the groundwater hydrology at the LEHR site is so poorly understood that it is not clear what is the direction of groundwater movement other than that it is generally to the east. There are times when the information provided by the DOE contractors indicates that it is moving to the southeast, other times directly east and other times to the northeast. There are, however, questions about how reliably previous DOE contractors evaluated water table elevation and, therefore, the direction of groundwater movement. This is an area of study at this time as part of the LEHR Superfund site investigation. It may be concluded, however, that there is a large area generally to the east of the LEHR site that is in the potential path of the groundwater pollution plumes from the various waste disposal practices at the LEHR site.

Further, with the preliminary conclusion now by DOE contractors that the groundwater may be moving on the order of 1,000 feet/year rather than 57 feet/year, there are many more wells potentially within the path of the LEHR site and UCD waste disposal operations that could have been impacted by LEHR site-derived wastes. There is no question from the data that the waste disposal operations have polluted the groundwaters at the LEHR site with a variety of hazardous and deleterious chemicals. How far this pollution has been carried at this time is unknown.

Further, even if the leading edge of the plume(s) (there certainly will be more than one plume from this site) is defined and it has passed a particular well and none of the constituents in the well exceed a drinking water MCL, this does not mean that tomorrow or some time in the future a constituent that is derived from waste disposal practices at the LEHR site or from the three UCD campus landfills at the site as well as the former campus wastewater treatment plant would not be present in a domestic well downgradient from the site. All plumes will not necessarily move at the same velocity and, most importantly, all constituents in the plume do not move at the same velocity. Those familiar with aquatic chemistry understand that there are differential rates of migration of constituents depending on the tendency for sorption and other reactions that can take place in aquifer systems which can cause waste-derived constituents to move at different rates in a groundwater system.

From a liability issue, it is the author's (Dr. Lee's) opinion and experience that it is not appropriate for UCD - DOE to stop providing bottled water to the residents, since, if someone's well does become contaminated with highly hazardous chemicals derived from the site, then UCD - DOE could be judged to have made a technically invalid assessment of the situation and to have exposed the public to hazardous conditions that would not have occurred had they continued to provide bottled water to those who are potentially impacted by past waste disposal practices at the LEHR site.

In fact, because of the uncertainty of the groundwater hydrology at the site and the various plumes that have been generated at the site due to past waste disposal operations, UCD and DOE should seriously consider expanding the bottled water program. Because of the recent conclusions that a previous DOE contractor has made a significant error in estimating groundwater velocity, many more people may be potentially impacted by UCD - DOE waste disposal at the LEHR site and UCD campus landfills than previously thought. By failing to provide bottled water to these individuals to protect them from consuming waters from their wells which have become contaminated by hazardous or otherwise deleterious chemicals, UCD and DOE are potentially accruing significant additional liability associated with the LEHR site.

It is important to understand that providing bottled water does not necessarily protect public health from contact with hazardous chemicals in the water. It is now becoming increasingly understood that there is appreciable absorption of some hazardous chemicals through the skin and through inhalation for some chemicals such as radon, arising from the decay of radium-226, and chlorinated solvents that were disposed of at the LEHR site and that are now polluting groundwaters under this site. The principal mode of transport of the radon is from the water through the gas phase (air) arising from showers, toilets, sinks, etc., where the radon is volatilized to the air and then breathed by those who are exposed to the polluted waters.

Since radium-226 was one of the radionuclides that was disposed of by UCD - DOE at the LEHR site, it is surprising that there has been no apparent recent monitoring of radon in the groundwaters at the nearby neighbors' wells. It could be that data exist that have not been provided to DSCSOC. The author (Dr. Lee) has extensive experience working on radium-226 in wastes of various types as well as natural radium and the problems associated with radium. This work has included studies in Colorado, New Mexico, Wisconsin, Illinois, New Jersey, Oklahoma and California.

The California work was done as part of the author's (Dr. Lee's) serving on the Human Health Advisory Committee for the Cal-EPA Comparative Risk Project, where he worked with others in evaluating the significance of radon in domestic water supplies in the state as a human health hazard. Those on the Human Health Advisory Committee concluded that radon in groundwater is potentially one of the most significant causes of environmental health problems in this state at this time. Anytime there is waste-derived or natural radium-226 associated with an area, concern has to be given as to whether radon-222 - a decay product of radium-226 - could represent a human health hazard. At this point, based on the author's review of the information that has been made available to the DSCSOC, the author is not certain as to whether this issue is being properly addressed at the LEHR site. This is an issue that needs to be raised with the regulatory agencies where, if it has been addressed, monitoring data on radon-222 present in groundwater should be brought to the attention of the DSCSOC.

Also, those responsible for developing the studies at the LEHR site should have an ongoing program to evaluate whether radon migration from the radium-226 disposal that has taken place at the site is a hazard to the current employees at the site through migration through the soil into buildings located near where radium-226 disposal has taken place.

Review of the Current LEHR Site
Nearby Neighbors' Groundwater Monitoring Program

As part of the author's (Dr. Lee's) review of the documents that have been made available, the author wishes to provide the following comments that are pertinent to the bottled water issue and the monitoring of the nearby neighbors' wells. Some of these comments may be modified once the information which was requested in mid-June concerning the current monitoring program on the nearby neighbors' wells is received.

From the data provided, it appears that a somewhat variable monitoring program has been conducted on the nearby neighbors' wells. While there has been fairly consistent, although it is not clear that it is regular, monitoring for chromium VI, nitrate, gross alpha and gross beta radioactivity and tritium, there have been occasional samples analyzed for selected other parameters. It is highly inappropriate to assume, as has apparently been done, that the only parameters that could pollute the nearby neighbors' wells are chromium VI, nitrate, tritium and radioactivity as measured by gross alpha and gross beta. It is well-known that gross alpha and beta are not adequate parameters for monitoring for specific isotopes. The gross alpha and beta MCLs could be met and the waters could still be hazardous, since individual components, while contributing to the gross alpha or beta, have much lower drinking water standards than gross alpha or beta, and therefore, gross alpha and beta monitoring are not adequate to ensure public health protection from the radioactive wastes that were deposited in pits, trenches and landfills at the LEHR site.

With respect to tritium monitoring, a number of the samples show the apparent presence of tritium in the groundwater at the nearby neighbors' wells. Rufus B. Howell, Chief of the California Department of Health Services Section, in a November 23, 1993 letter to Ed Ballard of DOE stated that, in reference to the LEHR site Phase II Characterization Report,

"Based on the preliminary review we conducted, the report appears to be inadequate to serve as a radiological reference for preparation of future documents."

In the accompanying document to that letter, under tritium measurements and soil moisture, it is stated,

"Typically tritium concentrations of soil moisture are below detection limit in environments not impacted by nuclear facilities. Any tritium result above the detection limit would indicate impact from a release source."

That report then provides additional references to the literature in support of that statement. It also states,

"The Phase II Report erroneously interpreted the tritium in soil results that were above the detection limit as normal levels found in the environment. Our interpretation of the data is that further investigation is warranted because either the background locations have been impacted by LEHR, or the laboratory results are invalid because tritium should not have been detectable."

The files provided to DSCSOC do not contain the response that DOE - UCD made to this letter. This situation is extremely important and obviously needs to be resolved. This raises a question as to where the responses DOE - UCD has made to comments on various studies that have been conducted at the LEHR site are filed. There should be a central file where the critique letters and the responses are kept. Further, any comments of this type made by regulatory agencies on LEHR site documents should have been, and certainly should in the future be, provided to DSCSOC.

The situation on the reliability of the tritium monitoring at the LEHR site and especially in off-site neighbors' groundwater has justifiably caused concern among the public. When the state agency concludes that either tritium is polluting the groundwater or that the data are invalid, the public justifiably becomes concerned. This concern is heightened when it is found that when the initial testing of a neighbor's well detects tritium, that that well is retested until the results show "non-detect." There is no retesting of the "non-detect" wells, however.

It is obvious to those familiar with analytical chemistry, such as the author (Dr. Lee), that errors are not always positive. For analytical procedures where there is sufficient error in the procedure to yield positive errors, there is also a possibility that low analytical results could be found for some of the samples. It appears to the public that UCD, DOE and the contracting laboratory that did the analyses have been manipulating the data collected on tritium until they get a "non-detect" value. This is what the public called the "hocus pocus" tritium data being produced by UCD on their domestic wells. This data really becomes "hocus pocus" when it is subsequently found that the laboratory that has been doing the analyses in Santa Fe, New Mexico has been indicted for falsifying laboratory results. The public justifiably does not trust the tritium analyses that have been done on their domestic water supplies.

The author will be critically watching future data that are developed on tritium to try to be sure that a more reliable approach is used than has been followed in the past for analyzing and reporting tritium data. From the information provided to the author at an August 9, 1995 meeting with DOE and regulatory agency staff, any finding of tritium in a groundwater above the detection limits that are being used for the analyses of the nearby neighbors' groundwater monitoring program is an indication of pollution by waste disposal practices at the LEHR site. Fortunately, tritium is not a particularly hazardous substance, and therefore, the problems with the analyses and data handling do not appear to have resulted in a significant health hazard to the public.

Overall, the author concludes from the information provided that the current monitoring program of the nearby neighbors' wells is inadequate to assure high degrees of public health protection. The author finds that it is essential that a much more comprehensive monitoring program be conducted of the nearby neighbors' wells in order to provide a higher degree of public health protection from hazardous or deleterious chemicals present in the wastes that UCD deposited in its three LEHR site campus landfills, in the soils and groundwater associated with the former campus wastewater treatment facility located at the LEHR site, and the wastes that UCD and DOE deposited in various pits, trenches and other disposal areas at the LEHR site.

Potential Importance of Unregulated Non-Conventional Pollutants

Under the current conditions, where the leading edge of the plume(s) arising from waste disposal practices at the LEHR site and the UCD campus landfills is not defined, it is essential that a fairly complete analysis of regulated chemicals be conducted on a periodic basis if public health protection is to be achieved. Further, and most importantly, since only about 100 to 200 chemicals are analyzed for and regulated today out of the many thousands that were in the wastes deposited at the LEHR site disposal areas, it is important that what are called the "non-conventional pollutants" be evaluated as much as possible through monitoring of the nearby neighbors' and, for that matter, others' wells and groundwater samplings that are conducted at the LEHR site.

It is inappropriate to assume that all of the hazardous chemicals that are associated with the wastes at the LEHR site or, for that matter, at any other location have been found. Those familiar with this field know that each year additional constituents are found which are now recognized as highly hazardous. There are many unregulated chemicals which fall into this category. It is prudent public health policy to recognize that any contamination of soils or groundwaters by complex, waste-derived constituents represents a potential significant public health threat that must be properly evaluated and managed. To narrowly focus only on the list of constituents specified in CERCLA guidance does not necessarily protect public health and the environment at sites where large numbers of highly hazardous or otherwise deleterious constituents are present in wastes deposited at the site.

From the data that has been made available, it appears that this is an area that has not been adequately considered thus far in the LEHR site and UCD landfill investigations. It is well known however, by those who understand public health and groundwater quality issues that a groundwater that meets all drinking water MCLs for the chemicals analyzed and/or regulated can never be considered "safe" for consumption if there is evidence of contamination of the groundwater by the unregulated, non-conventional pollutants. In order to adequately protect public health from waste disposal practices during the period when the groundwater pollution plume(s) that are occurring as a result of past waste disposal practices at the LEHR site and the campus landfills, it is necessary that a much more comprehensive groundwater monitoring program be conducted than has been conducted thus far.

Complexity of Defining Groundwater Pollution Plumes at the LEHR Site

It is important to understand that the nature of the waste disposal practices at the LEHR site and within the UCD landfills could readily result in a large number of small plumes that could travel for long distances with limited mixing and lateral spread. The work of John Cherry at the University of Waterloo and others has demonstrated that the concept of limited size source of contaminants spreading laterally creating a large fan-shaped plume is erroneous. In aquifer systems, such as that which underlies the LEHR site, the lateral spread associated with the various small sources of various types of hazardous or otherwise deleterious chemicals can generate a large number of finger-like plumes which can easily be missed by the typical groundwater sampling program of the type that is currently being conducted at LEHR. Far more sampling points will be needed to reliably begin to protect public health from wastes deposited at the LEHR site.

There are a number of aspects of the past studies associated with the bottled water issue that are of concern. The author has already mentioned the significantly deficient nearby neighbors' wells monitoring program that assumes that the only constituents that are present in the LEHR site wastes that could adversely impact nearby neighbors' groundwater resources are gross alpha and gross beta radioactivity, tritium, chromium and nitrate. While there are other analyses for other parameters on some wells, the database that has been made available to DSCSOC does not indicate that the study programs that have been conducted for the other parameters even begin to properly address the issues of concern. It is essential that a routine, periodic such as quarterly, monitoring of a wide variety of constituents be accomplished on all nearby wells that are used for domestic and other purposes. Further, because of the expected flow path for various plumes associated with the LEHR site waste disposal operations and the three UCD campus landfills, as well as the former UCD wastewater treatment plant, it is essential that a significant number of additional monitoring wells be placed in the gap between the homeowners' wells to the northeast and Putah Creek. At this time, there is a substantial gap, where according to information provided, no groundwater sampling is occurring that could detect waste-derived constituents from the LEHR site and the three UCD campus landfills.

Recently, attempts have been made to use groundwater sampling approaches, such as CPT/Hydropunch, to define the presence of polluted groundwaters. Such approaches are not necessarily reliable. The limited volume of sample typically obtained by this approach does not detect polluted groundwaters that could be in the vicinity of the sample taken. Such approaches could readily miss polluted groundwaters that are located laterally only a short distance from the sampling location or could be located under where the CPT/Hydropunch sample is taken. Great caution has to exercised in interpreting results of the CPT/Hydropunch sampling to indicate that a sample that does not show excessive concentrations of constituents compared to background is representative to any significant extent of the waters in the region where the sample was taken.

At the March 1, 1995 RPM meeting, the location of a large number of CPT/Hydropunch sampling points is delineated. While on the scale of the map shown, it would superficially appear that the CPT/Hydropunch sampling has been fairly intensive, in fact frequently there is about 200 feet between each sampling location. Since the CPT/Hydropunch sampling only takes water from a few inches from the point of sampling, plumes of contaminated groundwater of considerable size and location arising from the numerous disposal locations at LEHR could readily be present and not be detected by the CPT/Hydropunch sampling.

The limited ability of groundwater investigative techniques that are being used at the LEHR site as well as at other areas is not restricted to CPT/Hydropunch. The conventional monitoring wells that are being used typically have zones of capture of about one foot on each side of the well. With wells spaced 100's to a 1,000 or so feet apart, there could be significant groundwater pollution plumes in the vicinity of the wells and between wells that do not intercept the pollution plumes.

Eventually, each of the waste disposal areas (individual pits, cesspools, dry wells, drainage ditches, seepage lines, etc.) will have to be investigated in a detailed pollutant "gradient analysis" program to determine whether known major radioisotopes and hazardous and deleterious chemicals that were deposited as wastes at the LEHR site, as well as plumes arising from the unregulated chemicals associated with each disposal area, are moving to any significant extent in the unsaturated (above water table) and saturated (below the water table) part of the aquifers. Because of the nature of waste disposal at the LEHR site where wastes developed from short-term projects were deposited only in one or two pits/trenches or parts of a landfill, pollution plumes could occur arising from waste constituents that are not generally present in all of the pits, trenches or landfills at the site.

The gradient analysis will have to start at each disposal area and determine the vertical and lateral spread of constituents from the disposal area. Particular attention will need to be given to defining groundwater pollution plumes that arise from the disposal area by sampling from the base of the plume out to the leading edge for both horizontal and vertical extent in order to define the shape of the plume(s) and its movement.

In the author's many years of experience in investigating various kinds of hazardous waste disposal operations, the author has never encountered a situation that is more complex than that of LEHR. Usually, at an industrial site, essentially the same kinds of wastes are deposited at a particular location for long periods of time. This produces a fairly homogeneous plume of waste-derived constituents. At the LEHR site and associated with the three UCD campus landfills in that area, there can be large numbers of small, but hazardous - deleterious plumes. Any one of these plumes could transport hazardous chemicals to a nearby property owner's well rendering the groundwater hazardous to public health and/or causing the groundwater to have to be abandoned as a source of water supply. The bottom line issue is that because of the very poor records which were kept at the LEHR site associated with LEHR and UCD campus landfill waste disposal operations, each disposal area will have to be investigated in detail. It will not be possible to assume that investigation of one disposal pit will be representative of what is occurring at other pits, trenches or parts of the landfill.

Each of the pits and areas of the landfills will have to be investigated with respect to defining the presence of finger-like plumes of distinct characteristics if public health and groundwater resource protection is to be achieved. Further, eventually it will be necessary to find the leading edge of any overall, as well as individual, plumes arising from each area that has received waste. Removing or immobilizing the source of waste constituents at a waste deposition area will not necessarily eliminate the public health and other hazards from the waste disposal area since it will not address hazardous and deleterious chemicals that have left the disposal area and are already en route moving toward off-site groundwaters. This will require many years of investigation and groundwater clean up.

Further, and most importantly, it will be necessary to monitor effectively forever off-site production wells within the potential sphere of influence of LEHR site polluted groundwaters for incipient pollution for LEHR site derived waste to ensure that small but significant plumes of hazardous or deleterious chemicals that are not detected in the LEHR site studies do not arrive at a well at some time in the future thereby causing a significant public health or other hazard to the users of this well water.

At this time, the current and what is understood by the author to be the proposed groundwater pollution investigations being conducted at the LEHR site, do not adequately address the complexity of the groundwater pollution problems that can readily be occurring at this site. DSCSOC will need to work closely with regulatory agencies, DOE and UCD to ensure that LEHR site investigations of groundwater pollution are conducted in sufficient detail to adequately address the complexity of groundwater pollution at the LEHR site in order to protect off-site groundwater resources from any current as well as future pollution by LEHR site derived wastes.

Additional Areas of Concern

Listed below are a number of areas of concern that the author finds needs to be addressed as part of the LEHR off-site groundwater monitoring program.

Analyses of Chlorinated Solvents. The author is concerned that there apparently has been only a few analyses of the groundwaters sampled on nearby neighbors' wells for chlorinated solvents. From the information available, it appears that analyses for these types of pollutants are not being conducted on a routine basis. The groundwaters at the LEHR site are polluted by a variety of chlorinated solvents and their degradation products and since many chlorinated solvents represent significant public heath threats to those who use the water for domestic water supply purposes, and for that matter have contact with the water in bathing through skin absorption and through inhalation, and due to the fact that the chlorinated solvents can persist in many groundwater systems for long periods of time and are rapidly transported in many groundwater systems, it is essential that nearby neighbors' wells be monitored on a routine basis for a variety of chlorinated solvents.

Chloroform MCL. It is important to point out that DOE contractors in their previous reports, UCD, as well as the reviewers of the previous LEHR site Phase II investigations have made a significant error in listing the chloroform drinking water standard (MCL) as 100 ug/L. They have erroneously concluded that the drinking water standard for trihalomethanes is applicable to individual components of the trihalomethanes. Those familiar with how the trihalomethane drinking water standards were established know that this value is based on the balancing of disinfection versus potential cancer. The pollution of groundwaters at the LEHR site by UCD and DOE does not involve any balancing with disinfection.

The appropriate approach to establish drinking water standards for chloroform is based on the US EPA risk assessment approach. According to the US EPA "Gold Book" of Water Quality Criteria, the increased cancer risk due to chloroform of one additional cancer per 1,000,000 people who consume two liters of water per day for 70 years, is 0.19 ug/L. This is about 1,000 times lower than that listed in previous LEHR site documents. Since the "Gold Book" information is about ten years old now, it will be important to determine a risk-based "MCL" for chloroform based on the latest information on its cancer potency.

The author has reviewed the chloroform MCL situation with the California Department of Health Services management staff (Dr. David Spath, Chief, Drinking Water Branch, DHS) who supports the position that it is inappropriate to use 100 ug/L as a chloroform drinking water "MCL" for groundwaters polluted by chloroform associated with waste management situations such as occur at UCD's four campus landfills. The nearby neighbors' wells should be monitored for chlorinated solvents using analytical procedures that will detect chlorinated solvents below a risk-based drinking water standard.

Not only should there be concern for chloroform and the other chlorinated solvents that have been found in previous studies at the LEHR site to have polluted groundwaters at the site, but also there is need to consider the potential for transformation products of these various solvents to have caused groundwater pollution. The author has worked for a number of years on the issues associated with the PCE (perchlorethylene) and TCE (trichlorethylene) transformation products, and is well aware of the potential for the transformation of these chemicals under anaerobic conditions to lead to the buildup of vinyl chloride in groundwaters. Vinyl chloride is a known, highly hazardous human carcinogen.

The chlorinated solvents are among the most rapidly transported of the chemicals present in groundwaters. Often, they serve as an excellent indicator of pollution plume location for those waste disposal areas where the wastes contain the chlorinated solvents.

The author is not aware of the potential transformation products of chloroform under aerobic and anaerobic conditions. However, at this time, apparently no consideration has been given to this issue as part of the groundwater monitoring program that has been conducted at the LEHR site and in the nearby neighbors' wells. There is need to determine whether chloroform and the other chlorinated solvents that have been found to have polluted groundwaters at the LEHR site have been transformed to other potentially hazardous chemicals that could be transported in groundwaters under adjacent properties. Further, there is need to routinely monitor the nearby neighbors' wells for a variety of chlorinated solvents to ensure that the solvent-polluted groundwaters under the LEHR site are not being transported to nearby neighbors' wells. This monitoring has to be more than a one-shot or occasional sampling; it should be conducted on a routine basis to detect incipient contamination by chlorinated solvents and any significant transformation products.

One of the most important conditions present in aquifers governing the transformation of chlorinated solvents to hazardous chemicals is the presence/absence of dissolved oxygen in the groundwaters in which the solvents are located. In the absence of dissolved oxygen, bacteria are able to transform some of the solvents into more hazardous chemicals such as vinyl chloride. In a paper by Lee and Jones entitled "Guidelines for Sampling Groundwater," Journal Water Pollution Control Federation (1983), the authors recommend that because of the importance of dissolved oxygen in influencing the water quality characteristics of a groundwater rendering them more hazardous - deleterious and since many waste sources cause a depletion of dissolved oxygen that dissolved oxygen should be routinely monitored in all groundwater sampling programs.

Many groundwaters contain dissolved oxygen; however, the introduction of small amounts of oxygen demanding wastes (degradable organics) into an aquifer results in the rapid depletion of the dissolved oxygen. When this depletion occurs, a series of chemical and biochemical reactions occur which are frequently significantly detrimental to water quality. Measurement of the change in dissolved oxygen in a well water can be a very sensitive indicator of groundwater pollution by wastes of the type that have been deposited at the LEHR site. It is recommended that dissolved oxygen be used as a parameter that is routinely monitored in all off-site as well as on-site wells for those wells that are open to the atmosphere by down-borehole dissolved oxygen measurement equipment that is readily available. For production wells where it is not possible to gain access through the borehole, appropriate sampling of the groundwater pumped from the well can provide reliable measurement of groundwater dissolved oxygen.

Inadequate Reporting of Data. A problem that prevails through much of the older data is that those responsible for reporting the data list a number of ND (non-detects) but do not provide the detection limits. No one should report data of this type without providing detection limits. Without such information, it is not clear that appropriate analytical procedures were used to detect constituents at concentrations that are of potential significance. It is also important not to select analytical methods that just meet detecting a constituent at the drinking water standard (MCL) if there are analytical methods that have sensitivities significantly below the MCL. Under these conditions, then the more sensitive methods should be used since they could indicate trends in the data that are important in detecting incipient contamination of the well by constituents in the LEHR site wastes.

Information on QA/QC Procedures and Results. Another area of concern is the failure to provide information on QA/QC procedures that were used. None of the QA/QC procedures that are typically used at Superfund sites for data evaluation ensure that reliable data is generated. They do potentially detect some of the problems associated with data. The author is particularly concerned with seeing data on sampling trip blanks, analytical lab blanks, duplicate samples and spiked samples. Further, while not conventionally used, any independent analyses measurement of parameters using other analytical methods should be reported since this is the only way to potentially reliably evaluate the accuracy of analyses.

Issues That Should Be Considered in Improving Public Health and Groundwater Quality Protection from Waste Constituents Deposited at the LEHR Site on Nearby Neighbors' Groundwater Resources

There are a number of approaches that should be adopted at the LEHR site to address as best that can be done now the potential for the non-regulated, non-conventional pollutants to pollute groundwaters rendering them hazardous to public health and damaging the groundwaters' use as a resource. The most reliable approach is to define the leading edge of all plumes in all aquifers that can be generated from each of the disposal areas at the LEHR site and follow this leading edge during site investigation and remediation. This leading edge would represent the area where constituents are present in groundwaters that are moving at the fastest rate possible for the groundwater system. With this type of information, it would then be possible to determine whether groundwaters under adjacent properties have been polluted by past waste disposal practices at the LEHR site and the potential for future pollution to occur based on groundwater flow regimes that could be developed any time in the future due to groundwater transport associated with hydraulic gradients developed due to groundwater pumping and differences associated with upgradient versus downgradient heads (water table elevations).

It is very important to understand, however, that future groundwater pumping downgradient near the LEHR site could change the hydraulic regime that exists there now. Certainly adjacent neighbors have the right to use the groundwaters under their property without pollution by UCD - DOE derived wastes ad infinitum. Any remediation of the LEHR site, if it is to be effective in protecting public health, the rights and interests of those who own property near LEHR, and the groundwater resources of the region, must properly consider these issues.

The author is concerned about some of the writings in various DOE documents that have been made available to DSCSOC and some of the statements made by DOE staff concerning approaches that they feel are appropriate for remediation of this site. These include that there is only need to consider the potential for pollution from the "remediated site" for 30 years after the remediation program has been carried out, or that the public should be willing to accept pollution by conventional and non-conventional pollutants if the regulated pollutants are controlled. Neither of these approaches are valid if public health and groundwater resource protection is to be achieved.

UCD and DOE mismanaged the handling of wastes at the LEHR site. While they followed conventional approaches that were used by many for waste disposal, it has been known and well documented in the literature since the 1950s that these approaches will lead to groundwater pollution. By adopting cheaper-than-real-cost waste management at the LEHR site, DOE and UCD have now incurred a liability that will require substantial funds to be devoted to clean up of the site to stop the spread of pollution and to clean up to the maximum extent practicable the soil and groundwater pollution that has occurred. Since reliable characterization of the LEHR site and the UCD landfills is just now only beginning to occur, the magnitude of the liability that DOE and UCD have at the LEHR site and the three campus landfills associated with this site, is unknown.

In order to define whether the non-conventional pollutants are a potentially significant threat to public health and groundwater resources in a situation where the leading edge of any plumes that could arise from the waste disposal areas at the LEHR site and UCD landfills is not known, it is necessary if public health protection is to be achieved to conduct comprehensive, detailed analyses of a wide variety of constituents in the groundwaters at various locations in each of the aquifers. Of particular importance is the analysis of a variety of conventional constituents in the water samples which would move as fast as the water. These would include the alkali and alkaline earth metals, chloride, sulfate, bicarbonate, and total dissolved solids as measured by electrical conductivity at a specific temperature. Through the use of the concentrations of conservative (non-reactive) chemicals and especially their ratios, it is possible to define whether the leading edge of a plume of potentially hazardous or deleterious constituents could be at a particular well. This would then be an indication that potentially hazardous materials of the non-regulated, non-conventional type could also be present.

It is recommended that the DSCSOC work with the regulatory agencies, DOE and UCD to develop a much more comprehensive, reliable groundwater monitoring program for nearby neighbors' domestic water supply and irrigation wells than has been conducted in the past and is apparently being conducted today.

Overall Assessment

While DSCSOC has thus far not been provided with the information requested to develop a full, detailed evaluation of the bottled water issue and the associated monitoring of the wells located on nearby properties that could be impacted by wastes derived from UCD and DOE's waste management practices at the LEHR site, the UCD landfills and the former UCD wastewater treatment plant, there is sufficient information available now for the author to conclude that unless there has been a drastic change in the monitoring program of the nearby neighbors' wells, that it would be highly inappropriate for UCD - DOE to terminate providing bottled water to the owners of those wells that have previously been considered to be potentially impacted by the LEHR site waste management activities. In fact, because of the significantly greater groundwater velocity that is apparently occurring under the LEHR site compared to what has been estimated in the past by DOE, there may be need to expand the bottled water program to protect public health and the interests of those who own or use properties in the sphere of influence of the LEHR site and the UCD landfills - former wastewater treatment plant.

It is concluded that apparently at this time the current groundwater monitoring program for the nearby neighbors' wells as well as the past monitoring program is significantly deficient compared to that which is necessary to properly evaluate the public health hazard associated with waste disposal operations at the LEHR site and due to UCD's campus waste management practices in that region. There is need for DSCSOC to explore how the public can now work with the regulatory agencies, DOE and UCD to more properly address the pollution of groundwaters under adjacent properties by past waste management practices at the LEHR site and in the vicinity of LEHR to protect public health and groundwater resources from pollution by waste disposal practices in these areas.