July 4, 1997

Julie Roth, Exec. Director
DSCSOC
Route 2, Box 2879
Davis, CA 95616

Dear Julie:

I wish to follow-up on the June 10, 1997 RPM meeting by discussing several issues of importance to DSCSOC that developed from this meeting.

Groundwater Pollution of HSU-4

As Dennis Parfitt predicted several years ago, the polluted waters in HSU-2 arising from the mismanagement of wastes at the LEHR site associated with UCD's campus waste management activities have polluted the main primary aquifer of the region, HSU-4. As you know, DSCSOC has been trying for several years to get UCD - DOE to address this issue. When I first became involved with the LEHR site issues and I learned of the general structure of the aquifer systems underlying the LEHR site, it became clear that there was a significant potential for groundwater pollution of HSU-4. From the information presented at the last RPM meeting, it is now clear that UCD's mismanagement of campus wastes has now created two apparently major plumes of hazardous, carcinogenic chemicals in off-site groundwaters. At the meeting, Duncan Austin suggested there was need to fairly rapidly develop four monitoring wells to begin to assess the magnitude of the pollution of HSU-4. I strongly support his suggestion, with the understanding that a minimum of four wells will be needed and many more could be required.

I made a suggestion at the meeting that an analysis of the factors that could influence the direction of migration of HSU-4 polluted groundwaters should be undertaken. I suggested that an attempt be made to assess the potential magnitude of pumping groundwaters from both municipal and ag wells in the region to project how this pumping could draw the plume in HSU-4 to a particular direction, such as toward your property. As it stands now, while it appears that there is limited potential for the pollution of HSU-2 to affect you and others to the south and west of the LEHR site, the pollution of HSU-4, especially because of the large ag wells located near your property, could potentially pull the polluted groundwaters in your direction.

It is my understanding that the owner of those wells indicated to UCD that the wells were available for monitoring during normal operation of the wells. It is also my understanding that UCD has not conducted such monitoring. These and other wells that are taking water from HSU-4 should be monitored when they are operating to check for chloroform and other pollutants.

Groundwater Pollution of HSU-2

It is important to note that, as of yet, UCD has not defined the full extent of off-site pollution that has occurred in HSU-2. While there is some indication from the last round of hydropunch data that it may not extend as far as originally predicted by previous DOE contractors, the recent finding that HSU-2 has low concentrations of chloroform where it has been found to be high in the past, i.e. near the Nishi well, points to the cyclic nature of the pollution of HSU-2 where the sampling at the off-site hydropunch stations could be in one of the valleys of the pollution cycle that occurs associated with the pollution of groundwaters by UCD landfill No. 2. The finding that HSU-2 near the Nishi well has low concentrations of chloroform compared to other previous samplings is of concern in that it could mean that the off-site hydropunch sampling that showed low concentrations, indicating that the plume had not moved as far as previous DOE contractors had predicted, could simply be a reflection of a valley in the expected cyclic production of groundwater pollution from the LEHR site. There is need to greatly expand the sampling of HSU-2 along the lines that I have previously suggested where hydropunch and off-site monitoring wells are installed in HSU-2 to define the extent and degree of off-site pollution.

It is highly disconcerting that we have entered the third year of DSCSOC's involvement at the LEHR site and still have not defined the magnitude of groundwater pollution by LEHR site wastes and UCD's campus landfills in either HSU-2 or HSU-4. This area needs much greater attention that it has been given by UCD. Until the full extent of these plumes are known, it is not possible to rule out the possibility of people being adversely impacted by hazardous chemicals derived from the LEHR site through pollution of groundwaters in HSU-2 and/or HSU-4.

Use of Nishi Well Waters

After the RPM meeting, you, Mary and I were discussing the issue of Mary's use of the Nishi well for irrigation where questions were raised again about the potential for off-site spread of pollution by irrigation practices. Previously, I have suggested that studies should be conducted to determine whether the use of the Nishi well represents a potential spread of groundwater pollution. A monitoring program should have been developed and now should be developed to determine the chloroform content of the Nishi well water that is used for irrigation and its fate. Does it penetrate through the aquifer system into HSU-1 and ultimately HSU-2? While the use of the Nishi well for irrigation will not, as I have discussed, likely spread groundwater pollution over what has already occurred over the years through its use, it is important to understand this situation since Mary has had proposals in the past to use Nishi well water at other locations on the property where there could be spread of the pollution to new areas. Work should be done yet this summer during the irrigation season to determine whether the irrigation using the Nishi well results in the introduction of chloroform into the aquifer in areas where it is not naturally occurring due to the chloroform plume from UCD landfill No. 2.

Landfill No. 3 Pollution of Groundwaters

I am still concerned about the adequacy of investigating groundwater pollution by UCD landfill No. 3. From my perspective, the previous sampling of groundwaters to the east of this landfill has not been adequate to define the pollution of HSU-2 and possibly HSU-4. Associated with this situation is what did UCD do with its waste chloroform from when it stopped dumping it into landfill No. 2 and when it started dumping it into landfill No.4, i.e. the "west" landfill. Was there a period of time when waste chloroform was dumped into landfill No. 3? This seems highly likely. As you may recall, in our discussions with Ralph Virgin, he indicated that there was dumping of wastes into pits at landfill No. 3. There has been no follow-up to that disclosure, even though DSCSOC has requested that a follow-up be undertaken. This is an area that needs to be revisited by UCD, DOE and the RPMs.

Site Clean-Up Approaches

It appears now that DOE is entering into a crash program to try to establish site clean-up approaches where, based on the schedule passed out at the last RPM meeting, there is not likely to be adequate time to properly review the various approaches that are suggested by DOE for remediation of the various waste management units. I am particularly concerned about some of the comments DOE representatives made at the meeting where they want to use a regional "background" concentration to establish clean-up objectives. While this approach may have been used at other sites, it is not appropriate for the LEHR site as it is being developed. As I have discussed on several occasions, there is not adequate background information at this time to establish clean-up objectives other than removal of the wastes and contaminated soils to background. I hope DOE management is not deluding itself into thinking that this extremely noisy background that exists for certain parameters is going to allow leaving pollution that represents a threat to on-site and off-site users of the LEHR site and associated groundwaters that impairs the use of these groundwaters.

For two years, I have been trying to get UCD and DOE to address the issues of clean-up objectives relative to compliance with the Central Valley Regional Water Quality Control Board's Basin Plan objectives of no impairment of use of groundwaters due to past waste management activities. The UCD administration conducted research at the LEHR site and disposed of the campus wastes in what was obviously at the time an inappropriate manner that would have expected to and has polluted groundwaters. The true cost of this research will now have to be borne by the people of California through paying the full cost of remediation and ensuring that whatever remediation approaches are taken are, in fact, protective from further pollution of off-site groundwaters and a threat to future on-site users of the LEHR site at any time in the future while the wastes left at the site represent a threat.

As I have discussed in previous correspondence on these matters, this will include using some of the assimilative capacity that off-site groundwater users would have available to them if UCD had not mismanaged is campus wastes associated with landfilling them at the LEHR site as well as the waste management activities of the LEHR site. Using up some of the assimilative capacity for pollution from other sources is itself pollution - impairment of uses that must be addressed. At this time, DOE and UCD have not characterized the extent or degree of hazardous and deleterious wastes in the various waste management units, much less the contaminated soils and aquifer systems associated with each unit. Without such characterization, it will not be possible to do anything other than conclude that complete removal of wastes and all contaminated soils to background is the remediation approach that must be followed. Even with respect to this issue, we still do not know the full extent of soil contamination near various waste management units. These are issues that will need to be addressed at future RPM meetings.

If you or others have questions on these comments, please call. Please feel free to submit these comments to the RPMs for their review and comment. If they find that my assessment of any aspect of these issues is inappropriate, they should provide a written technical discussion of the issues so they can be peer-reviewed.

Sincerely yours,

Fred

G. Fred Lee, PhD, DEE

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