February 12, 1998

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

Dear Julie:

Please find presented below my comments on DOEs Phase C Addendum to Final Work Plan for Western Dog Pens" dated February 6, 1998. This Addendum provides a proposed plan for investigating of the western dog pens as part of defining the remediation of this area.

Overall, I find this proposed study plan inadequate. It should be revised before the work is undertaken. Failure to do could result in DOE having to reinvestigate this area due to the inadequate planning of this study.

A disturbing aspect of this situation is that the draft Addendum was only made available one day before RPM meeting which was two days before Weiss Associates wanted comments on the study plan. It appeared that I may have been the only one who had read the Addendum prior to the RPM meeting. Several of the RPM made comments based on the brief overview review that was presented at the meeting that raised important questions about the study plan.

Page A-6 mentions in the third paragraph that the soil samples will be analyzed for organochlorine pesticides, mercury, nitrate, chromium VI and radionuclides. Total organic carbon, organic nitrogen and ammonia as well as total chromium should be added to the list of parameters that are measured in the soil samples. While Weiss Associates staff said a the RPM meeting the parameters were selected based on past studies. As I indicated just because the previous studies were done incorrectly is not justification for continuing to follow inadequately planned studies.

At one time, appreciable organic nitrogen and ammonia and were present in the dog pen soils. This, in turn, led to the formation of nitrate through nitrification reactions. There is need to know whether there is still organic nitrogen in the soils that are sources of nitrate that could lead to groundwater pollution. TOC measurements are part of identifying whether there is any significant amount of potentially hazardous, but uncharacterized or unregulated, constituents in the soils. The groundwater samples planned for these studies should be analyzed for the same suite of parameters mentioned above.

Table 1 presents the proposed sampling depths which include a surface sample, sample taken two to three feet below the surface, eight to nine feet, 20 to 21 feet and 25 to 26 feet below the surface. These sampling depths are not adequate. There could readily be bands of waste-derived constituents that would not be detected by the sampling program. It is well known that relatively narrow bands of waste-derived constituents can accumulate in the soil profile at depth in climatic and hydrogeological situations of the type that exists at the LEHR site. A much closer-spaced sampling will have to be done in at least half of the sampling locations to detect potential problems of this type.

In my previous comments on the dog pen situation, I mentioned that previously DOE and its contractors have failed to consider an important factor that would influence the migration of waste in the soil column associated with the dog pens, namely the water that was sprayed over the area to cool the dog pen area. Depending on where this water ponded and since the distribution pattern would not be even, there could readily be significant differences of soil residues found at various locations dependent on the water addition pattern and its infiltration into the soil column. This issue should have been examined and discussed since it was brought to the attention of DOE as a factor that should be considered in planning these studies.

At the RPM meeting, Weiss staff indicated that they wanted to avoid having the soil borings enter the groundwater table. Duncan Austin, Susan Timm and I all indicated that just the opposite approach should be followed where a sample of the groundwater should be taken at the bottom of the soil boring in order to see if this water is contaminated. If this water is found to "clean" then this is an indication that no current pollution is occurring. If the water the top of the water table is contaminated then there is an indiction that there is waste in the soil column that is contributing waste constituents to the groundwaters. In addition to analyzing the samples for the above mentions parameter and those in the study plan a fairly complete analysis of the samples should be conducted to detected possible other pollutants

Since it is not possible through the approaches being used to detect all potential waste areas that could be a significant source of existing or future groundwater pollution, groundwater monitoring wells should be installed. In addition to sampling the soil profile, on the order of half a dozen monitoring wells or hydropunch samples should be taken with in and just down groundwater gradient of the dog pen area to determine whether the surface groundwaters in this region have been contaminated by dog pen-derived wastes.

During the discussions of the need for groundwater sampling, I understood Christine Judal to say that the monitoring well just downsteam from the western dog pens was polluted with nitrate. If my understanding is correct then this is good evidence that the dog pens have, as expected, polluting groundwater with nitrate and possibly other constituents such as salts, etc. This type of situation is an example of highly inadequate investigative approaches that UCD and DOE are following in investigating the LEHR site. Large amounts of public funds have been and continue to be spent investigating groundwater pollution at the LEHR site. To conduct an investigation of a waste management area such as the dog pens without examining the existing groundwater data base for wells that are likely to influenced by the area is an inadequate site characterization approach.

The monitoring wells that are established to check on dog pen waste pollution of the groundwaters should be added to the set of wells that are operated ad infinitum to ensure that undetected waste bands are not now contributing and in the future do not contribute to groundwater pollution.

Please pass these comments onto the RPMS and the PRPs - UCD and DOE, indicating that if they have questions on these comments to please contact me. Since you are way for several weeks and since Weiss Associates wants comments by today I am forwarding these comments to the RPM and PRPs including Weiss Associates. I would caution DOE about going ahead with the propoased site investigation without have an adequate review by the RPMs

Sincerely yours,

Fred

G. Fred Lee, PhD, DEE

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