Comments on August 18, 1997 RPM Meeting
Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
530-753-9446
fax 530-753-8220
e-mail [email protected]
http://www.members.aol.com/dscsoc/dscsoc.htm
September 2, 1997
Remedial Project Managers
LEHR Superfund Site
University of California, Davis
Davis, CA 95616
Via e-mail
Dear RPMs
I have attached Dr. G. Fred Lee's comments on some aspects of the August 18, 1997 RPM meeting he prepared on behalf of DSCSOC. Dr. Lee has specifically focused on some aspects of the overall remediation plan that is currently being developed for the LEHR site.
Dr. Lee has stated that scheduling meetings when the DSCSOC technical advisor cannot attend may result in a delay of DSCSOC's comments on issues by several months due to the slow rate at which the minutes of the RPM meetings are made available. This could be detrimental to DOE's accelerated clean-up program. DSCSOC asks that future RPM meetings be scheduled at times when Dr. Lee will be available to attend.
If you have any questions regarding Dr. Lee's comments, please contact him.
Sincerely,
Julie Roth, Ex. Dir.
cc: DSCSOC's Ex. Board
Dr. G. Fred Lee
PRPs for LEHR site
William Taylor
Jane Riggan
Brian Shafer
G. Fred Lee & Associates
El Macero, California 95618-1005
Tel. (916) 753-9630 · Fax (916) 753-9956
e-mail [email protected]
web site: http://members.aol.com/gfredlee/gfl.htm
September 1, 1997
Julie Roth, Exec. Director
DSCSOC
Route 2, Box 2879
Davis, CA 95616
Dear Julie:
Presented below are my comments on some aspects of the August 18, 1997 RPM meeting. I have specifically focused these comments on some aspects of the overall remediation plan that is currently being developed for the LEHR site. Since the next RPM meeting was knowingly scheduled by DOE at a time when I have a previous commitment where I will be participating in an invited American Chemical Society sponsored lecture tour in Indiana and Kentucky, I want to provide DSCSOC with my comments on these issues in the event that they are discussed at the next meeting.
Scheduling meetings when the DSCSOC technical advisor cannot attend, as occurred for the September 24, 1997 meeting, does not relieve DOE, UCD or, for that matter, the RPMs from considering DSCSOC's comments on issues. Knowingly scheduling RPM meetings when I cannot attend could prove to be significantly detrimental to DOE's accelerated clean-up program, especially in light of the fact that DOE often takes several months from the time when a meeting is held until the minutes are available for review. This means that DSCSOC's comments on issues may be delayed by several months due to the fact that the meeting was scheduled when its technical advisor could not attend and the slow rate at which the minutes are made available.
Overall Remediation Plan for the LEHR Site
One of the major topic areas discussed at this meeting was the potential cost for various clean-up levels for DOE areas which based on preliminary estimates could range from $6 to $18 million for part of the DOE areas of responsibility. We are now just beginning to see the initial aspects of the costs that are associated with UCD's mismanagement of LEHR site and campus wastes that were deposited in the landfills at the LEHR site.
D. Austin raised the question about UCD and DOE coordinating their efforts, especially with respect to the low-level radium-contaminated soils that would be removed to achieve various risk-based levels from 10-4 to 10-6. The $18 million was associated with a 10-6 risk-based level. It should be noted that the state of California has adopted a 10-6 risk-based level for the protection of public health. Therefore, the 10-4 level is not an acceptable clean-up level in accord with the state's requirements.
D. Austin raised the question about the possibility of rather than hauling the low-level radium-contaminated soil that is essentially at background with respect to radium content to Hanford at $35 per cubic foot, possibly it could be used in the UCD landfills that will be developed as part of remediation of the campus landfills at the LEHR site. This approach appears to be a possible way of managing such soils provided that an intensive, ad infinitum groundwater and vadose zone monitoring program is conducted by UCD/DOE associated with any on-site landfilling of wastes. However, such an approach does not appear to be compatible with the rates at which UCD and DOE are conducting their site investigations and clean-up.
A UCD representative indicated that it is likely to be several years before UCD proposes an approach for managing the radioactive hazardous and deleterious wastes at the LEHR site in their areas of responsibility. Meanwhile, DOE, in accord with an accelerated remediation schedule, wishes to start to remediate during the summer of 1998. While DOE is apparently attempting to accomplish the remediation of certain waste management units in one summer, it appears that such an approach is not in the best interest of the public in terms of the wise use of public funds and the adequacy of clean-up. While, as I pointed out at the meeting, the initial clean-up of the wastes and obvious contaminated soils associated with each waste management unit could proceed this summer, the final clean-up of these areas may have to wait for a year or more until the site is properly characterized. It is beginning to appear that DOE-Oakland is taking an inappropriate approach toward implementing the accelerated clean-up where its characterization will be superficial and result in leaving waste-derived constituents at the LEHR site above background.
DOE-Oakland representatives attempted to assert that it was essential that once the waste management unit pits were opened during the summer of 1998, the complete clean-up of the soils contaminated by the wastes in these pits be done at the same time. One of the justifications for this is that it did not want to over-winter with the pits open because of the potential for rain water to enter the pits. However, if it is not possible for DOE-Oakland to properly characterize the contamination of the soils associated with each waste management unit during one summer, then it will be necessary to provide protection of the pits from direct precipitation and runoff.
The discussion that took place at the RPM meeting by DOE contractors about how it is not possible to distinguish between radium 226 added in the waste and the natural background apparently relates to trying to do this in the field vs. in the laboratory and does not consider the potential differences in the character of the radium 226 added to the wastes from that of the geologically present radium. It is my recommendation that DOE should be required to properly measure the radium 226 using the best laboratory procedures available to detect the increases in radium 226 that occurred because of UCD's mismanagement of LEHR site wastes in order to remove as much of the waste radium from the area as possible.
As I discussed, DOE-Oakland is still attempting to operate without adequate aquatic and geochemistry expertise in its site investigation and remediation. It is inappropriate to assume that all radium 226 is identical with respect to aquatic chemistry behavior. This is especially true when considering mobility and threat to public health and the environment. The mobility and threat to public health and the environment is dependent on the specific chemical species in which the radium 226 is located. The natural background radium 226 almost certainly is of different chemical characteristics than the radium 226 added to the LEHR site as a waste. While there is a tendency over geological time to equilibrate, this equilibration can take place over very long periods of time.
I have been involved in this type of situation previously where in the state of New Jersey, the state DEP attempted to dispose of radium watchdial painting wastes in a sand and gravel pit that was hydraulically connected to a cavernous limestone region. The state staff attempted to assert that if they achieved the background radium 226 of the region by dilution of the wastes with low radium sand and gravel, the radium would not represent a threat. The background to which they were comparing was radium 226 in granitic rocks. I pointed out to the DEP commissioner that it was technically invalid to assume that the chemical behavior of radium 226 in the background rocks would be the same as in the wastes diluted with sand and gravel. The DEP commissioner chose to ignore elementary principles of aquatic chemistry and proceeded with this approach. I assisted the town of Vernon, New Jersey in litigation on this matter where the judge ruled based on my testimony that the DEP approach was technically invalid and contrary to appropriate public health and groundwater resource protection.
DEP withdrew its proposed approach for disposal of the radium 226-containing wastes, even though it was possible to achieve background. The DEP-proposed approach was obviously technically invalid. The same kind of situation could readily occur at the LEHR site. At this time we know nothing about the relative mobility of the radium 226 present in the wastes vs. the natural background radium 226 in the area. Until this is known, clean-up to background must be required.
If you or the RPMs have questions about these matters, please contact me. If the RPMs decide to reschedule the September 24, 1997meeting, please check with me to see whether I have previous commitments.
Sincerely yours,
Fred
G. Fred Lee, PhD, DEE
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