Submitted by

G. Fred Lee, PhD, DEE
G. Fred Lee & Associates
El Macero, CA 95618

August 1996

Presented herein is a discussion of the "Technical Memorandum/Work Plan Pre-Design Activities LEHR Groundwater IRA University of California, Davis" submitted by Dames & Moore, dated July 1996.

In the cover letter dated July 15, 1996, it is indicated that Dames & Moore would like to have this Work Plan reviewed at the July 17, 1996 meeting of the RPMs. The Work Plan was not received by some of the RPMs by that date and was not made available to DSCSOC until the meeting. Therefore, DSCSOC and several of the RPMs were not in a position to discuss this Work Plan at the July 17, 1996 meeting because of the inadequate time between when it was made available and the date of the meeting.

On page 2, 1.1.1 "Hydrogeology," Dames & Moore have provided an inadequate discussion of the hydrostratographic units likely influenced by waste disposal activities at the LEHR site. Dames & Moore left out of the discussion HSU-4, the second major aquifer under the LEHR site. There is little doubt that this aquifer has been polluted by LEHR site wastes. For Dames & Moore to leave out a discussion of this issue represents a continued deliberate inadequate presentation of information that is available at this time on LEHR site groundwater pollution, where they are trying to minimize the public's and others' understanding of the extent of pollution of the groundwater aquifer systems under the LEHR site by UCD's mismanagement of wastes.

The current Dames & Moore staff have inherited a reputation from former Dames & Moore work at the LEHR site for conducting inadequate studies and for providing unreliable and inadequate reports on LEHR site issues. It is important that this organization stop allowing UCD to dictate the biased reporting of issues, such as not mentioning the significant potential pollution of HSU-4 by LEHR site wastes. It certainly is inappropriate to leave out HSU-4 in discussing this pollution as has been done in this section of the Work Plan. Until proven otherwise, HSU-4 should be considered as being polluted by LEHR site wastes where the pollution can occur both as a result of migration through the clay layer and through the wells that connect the two aquifers.

On page 3, section 1.1.2 "Distribution of Constituents of Concern," while I have not checked the PNL 1996 Annual Groundwater Monitoring report to see if it properly listed all of the constituents of concern, I know from previous discussions that both UCD and DOE are still not adequately considering the constituents of concern to the public which comprise the unregulated organics that were disposed of as wastes as well as the transformation products of organics which have been formed from the waste-derived constituents. Any listing of constituents of concern that does not include this group of chemicals is inadequate and unacceptable to the public. It should be noted that the PNL listing of constituents of concern cited in this paragraph does not represent a necessarily reliable list of constituents of concern.

The statement in the next paragraph that the primary constituents of concern are chloroform and other VOCs, chromium, nitrate and tritium is not necessarily accurate. These are constituents of concern; they are not necessarily the only primary ones.

The bottom of page 3 to the top of page 4 discusses the distribution of chloroform from HSU-1 and HSU-2. Again, Dames & Moore-UCD have provided inadequate and unreliable information on these issues. Any discussion of this issue that does not include the Nishi well situation which involves transport of chloroform from HSU-2 to HSU-4 represents a biased, unreliable, inadequate presentation of information that is a disservice to Dames & Moore's credibility.

Page 5, 1.3.2 "Groundwater Treatment Standards," discusses the use of the results from UCD2-17 as the background concentrations. As has been discussed by DSCSOC previously and has been confirmed by some of the RPMs, there are inadequate background water quality data available at the LEHR site at this time to properly characterize the site. Additional background wells are needed to do anything other than make some very general statements about the impact of the LEHR site waste disposal practices on groundwater quality.

On page 7, second paragraph, Dames & Moore state,

"The location of EW-1 was selected for groundwater extraction to restrict further downgradient migration of chloroform impacts above 100 ug/L, the maximum contaminant limit (MCL) for trihalomethanes in drinking water, as well as intercept other constituents in groundwater."

Dames & Moore must stop trying to perpetuate the error that it has made in document after document produced by this firm in connection with the UCD west landfill as well as the previous work that was done at the LEHR site. Their work contains the errors concerning stating or implying that the trihalomethane drinking water MCL of 100 ug/L has any relevance to the appropriate clean-up objective of chloroform-polluted groundwater associated with the mismanagement of wastes at the LEHR site and the west landfill.

It is time that Dames & Moore stop perpetuating the error that it has been making year after year in document after document associated with work at UCD. Both DOE and UCD have been put on notice that if either the staff directly or they allow their contractors to perpetuate the 100 ug/L trihalomethane (THM) MCL as having any relevance to chloroform issues at the UCD-DOE LEHR national Superfund site or the UCD west landfill site, formal complaints will be filed with appropriate agencies and, if necessary, with the courts to stop the misrepresentation of this issue. The clean-up objective for groundwaters polluted at the LEHR site and west landfill site is 0.5 ug/L chloroform. This is the value to be referred to; there is no need, and it is inappropriate, to refer to the 100 ug/L THM MCL as is done in the first paragraph of page 5 and in the second paragraph on page 7 of the Work Plan.

At several locations in this Plan, mention is made that the waters removed during the pump test, etc. will be discharged to the UC Davis campus wastewater treatment plant where UC Davis personnel will make a decision as to whether it is acceptable or not. This review process should be a public process in which the public has the opportunity to judge the appropriateness of the UC Davis staff's and the L. Vanderhoef administration's assessment of this situation. This is justified since errors made by this staff and the administration affect the public through impacting Putah Creek. Further justification stems from the fact that UC Davis staff in the fall of 1995 made a significant error in assessing the potential impacts of UCD's discharge of west landfill leachate-polluted groundwater to the campus wastewater treatment plant.

As I have discussed in my November 19, 1995, May 19, 1996 and August 8, 1996 letters to the Central Valley Regional Water Quality Control Board (copies are available to the RPMs upon request), UCD staff did not adequately or reliably consider impacts of increased flow on the toxic chemical discharges, such as ammonia, associated with the discharge of the west landfill leachate-polluted groundwaters to the campus wastewater treatment plant. That treatment plant is already overloaded and has been in violation of its wastewater discharge permit for toxic chemicals for a number of years. The additional flow and the presence of a variety of other hazardous chemicals in the leachate-polluted groundwaters could readily aggravate an already significant situation of the campus wastewater treatment plant discharging constituents which are detrimental to Putah Creek water quality. It is important not to cause further aggravation of the problems that exist now with UCD's inadequate treatment of its campus wastewaters before discharge to Putah Creek. It is also important that any decisions made on this issue be made after full public review.

On the bottom of page 12 is a listing of the various analytical methods that are proposed to be used in the UCD studies. Since there have been significant problems with Dames & Moore's previous work at the LEHR site with respect to selecting appropriate analytical methods with appropriate sensitivities to conduct the analyses at critical levels, UCD should be required to explicitly state, before the work is undertaken, the analytical detection limits that will be achieved for each of the parameters that are measured. These analytical methods and detection limits should be appropriate to consider aquatic life protection issues since this groundwater could be discharged to Putah Creek through a remediation program.

The list of parameters on the bottom of page 12 and top of page 13 is deficient with respect to not including total organic carbon. COD is not a suitable surrogate. From my perspective, COD can be deleted since it is not a meaningful parameter for this type of analysis. While this set of parameters may be appropriate for this location at the LEHR site, there will be locations at LEHR where ammonia should be added to the list, especially near organic waste sources. Another parameter that should be added is electrical conductivity at a specified temperature. When the data are recorded, the temperature at which the measurements are made should be indicated. If corrections are applied for the temperature dependence of electrical conductivity, then the correction factor used should be indicated.

On page 14, first full paragraph under 3.1 "Groundwater Conceptual Model," I am concerned about Dames and Moore's groundwater modeling ability since it is my understanding that it was Dames & Moore that made the significant errors in estimating the groundwater velocities under the LEHR site. It is important that errors of this type do not continue to occur in further work on groundwater hydrogeology at this site.

Considerable discussion is presented on the various groundwater flow modeling approaches that will be used. From my perspective, I want to see, once the model has been developed, how it will be verified through proper field testing. Far too often, curve-fitted models are developed which fit the existing data but have limited predictive capability for new or altered situations. UCD-Dames & Moore must develop an independent model verification program that demonstrates that the predicted zones of capture are, in fact, what are achieved during the groundwater extraction operation.

On page 16, 4.1 "Air Stripping," it states that air stripping is not effective in removing nitrate, chromium and TDS. Added to this list should be a wide variety of other pollutants in the groundwaters at the LEHR site derived from LEHR site wastes.

On page 16, mid-paragraph under 4.1, item 2, in addition to the parameters mentioned, alkalinity, pH and CO₂ data are needed to begin to reliably predict fouling and scaling.

Page 16, bottom of the page, as I commented on the previous draft of this document, TOC data are needed since TOC will significantly influence the removal of chloroform by activated carbon.

Page 17, 4.2.2, item 2, discusses properly preserving samples for shipment to Pennsylvania. Before this is undertaken, the method of preservation that is proposed to be used should be reviewed by the RPMs and DSCSOC.

It is important to understand that the testing of various treatment processes where the water that will be extracted from the groundwater at a particular location may not be applicable to other locations where similar extraction programs could be undertaken, especially those closer to the waste sources.

Page 18, item 2 at the top, again mentions properly preserving the samples before shipment to Minnesota. This has to be reviewed beforehand to be certain that the preservation does not alter the characteristics of the sample and thereby provide incorrect results for the pilot testing.

Page 18, last paragraph, states that the RO unit wastestream would be high in chromium, nitrate and TDS. Again, Dames & Moore-UCD should acknowledge that there could be a wide variety of other constituents in this rejectate that represent potential adverse impacts that have to be evaluated in managing the rejectate.

On page 19, top paragraph, under the four items, no mention is made of organic fouling of membranes. TOC as well as other organics need to be evaluated since they will affect the performance of these treatment processes. Failure to make proper evaluations can readily result in UCD buying into a treatment process that does not work.

On page 19, 5.1 "Reinjection into the Second HSU Aquifer," the statement is made that treated groundwater can be reinjected into the aquifer from which it was pumped if the three criteria listed are met. A review of these criteria shows that they are not adequate to protect the public's interests. From a DSCSOC-public's perspective, any reinjected treated water must not result in the groundwaters leaving the LEHR site being of impaired use compared to upgradient groundwaters. This will require consideration of all constituents that can impair groundwater quality, not just the few regulated hazardous constituents.

On page 20, second paragraph, the discussion of the constituents that need to be considered is inadequate and must be properly redone. As discussed herein and in my previous comments, UCD must consider all of the pollutants and their transformation products as part of any management of its landfill leachate-polluted groundwaters. The organic constituents that must be considered must include far more than just chloroform. The inorganics include far more than nitrate, chromium and TDS.

On page 20, bottom paragraph, item 5, the public must be an active participant in reviewing the results of the findings and in the approval process for reinjection. I have discussed in another statement to DSCSOC the issues that need to be considered in reinjection of any treated groundwaters.

Page 21, second paragraph, discusses UCD's wastewater treatment plant meeting all applicable regulatory standards. UCD's wastewater treatment plant does not now meet all applicable regulatory standards. The Central Valley Regional Water Quality Control Board has been allowing UCD to operate this treatment plant without proper monitoring of its impacts. The monitoring that has been done, however, does potentially show adverse impacts on Putah Creek water quality. The public will not allow UCD to continue to operate its wastewater treatment plant out of violation of its permit. This matter is under review by the Central Valley Regional Water Quality Control Board.

Page 21, third paragraph, discusses the local limits issue for the wastewater treatment plant. As discussed herein, these local limits were not reliably developed and are not appropriate for protection of Putah Creek water quality.

Page 21, fourth paragraph, states, "Engineering analyses conducted by WWTP personnel indicate that suspended solids removal will ultimately limit capacity." It should be noted that the analysis of the ability of the wastewater treatment plant to provide treatment was based on a flawed approach that involved a 1960s level of mentality on the operations of domestic wastewater treatment plants. It did not consider toxics. As flow increases, the likelihood of greater violation of toxic discharge requirements will increase since many of the toxics are not adequately or reliably removed by the treatment processes used. It is important that UCD and Dames & Moore not make the mistake of assuming that the assessment of the ability of the current wastewater treatment plant to adequately treat leachate-polluted groundwaters discharged to this plant, much less additional leachate-polluted groundwater discharge arising from the LEHR site wastes, has been done correctly. This issue has been discussed above.

On page 22, item 2, the public should be involved in the review of any decisions made with respect to discharge of the polluted groundwaters to the wastewater treatment plant to be sure that this analysis is done correctly.

Page 23, second paragraph, represents an inadequate discussion of the issues pertinent to discharge of leachate-polluted groundwater to Putah Creek. The conditions set forth in Order 95-187 will not stand as the discharge limits that will be allowed for such a discharge. The public has made it clear that they will appeal any Order resembling this approach to the State Board and, if necessary, to the courts to protect Putah Creek water quality from inadequately treated UCD landfill leachate-polluted groundwaters.

Table 1 lists the units for nitrate as ug/L. It appears that UCD-Dames & Moore has made an error of a factor of 1,000 in reporting the results. There is also some inappropriate typing for sulfate. The specific conductance data must have the temperature at which the measurements were made listed.

As I have discussed, UCD2-17 is not an appropriate upgradient well to judge the characteristics of the waters upgradient of the site. At this point there are too little data for the region where samples need to be obtained to describe any groundwater clean-up objectives or even constituents of concern. Additional data must be collected from the region before such an analysis can be conducted.

Table 3 contains the same error that Dames & Moore has perpetuated for years of an MCL for chloroform; there is no MCL for chloroform. Dames & Moore and all UCD-associated activities must stop presenting incorrect, unreliable and deliberately distorted information of this type. Further, with respect to chloroform, the assumed estimated concentration for remediation should be 0.5 ug/L, not 1 ug/L. Similar errors occur for the bromodichloromethane. The chromium VI assumed estimated concentration for remediation should be 10 ug/L, not 16 ug/L. This is the discharge limit necessary to protect Putah Creek water quality. This same limit applies to total chromium. The 50 ug/L total chromium level will not stand as an acceptable discharge limit. The reinjection limit for nitrate of 16.8 mg/L is too high and will not be acceptable.

In Table 3 (continued), the units for electrical conductivity or specific conductance are micromhos/cm. The proposed reinjection limit for electrical conductivity of 1,330 micromhos/cm is too high and will not be acceptable. It appears that Dames & Moore made an error on the calcium listing for the Assumed/Estimated Concentration for Remediation. Dames & Moore and UCD need to get somebody involved in reviewing chemical data who understands them and can detect the errors that have occurred in the previous and current report.

Figure 8 presents a schedule for completion of this program. It is my experience that this schedule is overly-optimistic in terms of being able to be accomplished in accord with the timetable presented.

Table C-1 presents numeric local limits for the UCD wastewater treatment plant. Information should be provided to the RPMs and DSCSOC on how these limits were developed. It appears that a number of them are in error and therefore are not protective of Putah Creek water quality. Further, there apparently is no local limit on constituents that cause chronic aquatic life toxicity. This is a key parameter that must be included.

Appendix D provides a copy of a June 1995 Waste Discharge Requirement for UCD's west landfill leachate-polluted groundwater. That discharge requirement was appealed to the State Board. There is no question that it would not have been allowed to stand. That permit expired and as of August 9, 1996 UCD has been issued a new permit to discharge leachate-polluted groundwaters to Putah Creek. While that permit eliminates some of the highly significant deficiencies that were present in the previous permit, it is still highly deficient in protecting Putah Creek water quality. That permit is being appealed to the State Board for review based on its technical inadequacies. If the RPMs are interested in receiving a copy of a discussion of these inadequacies, please contact me.

Overall, I recommend that DSCSOC indicate that at this time they have no problems with the preliminary plans for characterization of the hydrogeology of the area to the east of the source of the chloroform plume. There are, however, significant problems in the Technical Memorandum/Work Plan discussions of water quality aspects of this work which must be corrected. Hydrogeological investigations, insulation of pumping and monitoring wells, and the groundwater modeling can and should proceed. The interpretation of the results with respect to any clean-up objectives and the appropriateness of the pilot testing treatment processes, however, are in need of considerable additional review before it will be acceptable to DSCSOC.

This report fails to address the very important issue of the existing off-site pollution of groundwaters by LEHR site-derived wastes. Even though DSCSOC has indicated to UCD and DOE that as a very high priority not only must the off-site groundwater plumes be defined, but also the program should be implemented in the immediate future to begin to clean up these plumes in accord with current state of California regulations. Thus far, apparently UCD and DOE have failed to even begin to address this issue. It appears that a behind-the-scenes agreement has been reached where the off-site pollution of groundwaters by UCD's and DOE's mismanagement of wastes at the LEHR site is not to be addressed until some indefinite future time. It is time now that not only must UCD and DOE determine the magnitude of the off-site groundwater pollution plume, but also develop and implement a groundwater clean-up program that would clean up in accord with current state of California regulations the off-site polluted groundwaters.

It is my recommendation that DSCSOC notify UCD and DOE that they must immediately begin to develop and implement a groundwater clean-up program for all off-site pollution (impairment of use of groundwaters) that is attributable to LEHR site wastes. With respect to the chloroform and other VOC plumes, the clean-up objective shall be to non-detect in accord with current state of California regulations which for chloroform is 0.5 ug/L. It is suggested that by the October RPM meeting, UCD and DOE must present the preliminary plan for further investigation and remediation of the off-site polluted groundwaters arising from the LEHR site.

DSCSOC should notify DOE and UCD that from the public's perspective this is a much higher priority item than continued on-site waste characterization and remediation. If UCD and DOE fail to act in an appropriate manner within the next few months on this issue, then DSCSOC should file formal complaints with the regulatory agencies management on the violation of current state of California regulatory approaches for addressing the off-site pollution of groundwaters by LEHR site wastes.