Review of the US Department of Energy Oakland Operations Office's
Annual Site Environmental Report
Calendar Year 1994
for the
LEHR National Superfund Site
at the
University of California, Davis

Submitted by

G. Fred Lee, PhD, DEE
Technical Advisor, DSCSOC

February 1996

On page 1, last paragraph, mention is made about coordination among various regulatory agencies and the PRP's. However, no mention is made about public involvement. While the public was not initially allowed to participate in this process, beginning last summer this situation began to change. The public through DSCSOC plans to be an active participant in LEHR site investigation and remediation issues.

The statement on page 2 under Section 1.2, "Overview of 1994 Monitoring Results," mentions a few of the constituents that are waste constituents polluting the site. This discussion should be expanded to include the variety of other constituents, such as TDS, etc., conventional pollutants and non-conventional pollutants which are present in the wastes that were mismanaged by UCD and DOE that are a threat to groundwater quality. Mention should have been made of the pollution of groundwaters by conventional and non-conventional pollutants as well as by the regulated pollutants that have been the focus of the UCD - DOE site investigation thus far. This executive summary tends to understate the potential significance of past UCD and DOE waste disposal practices at the LEHR site on public health and the environment.

Page 7, in Section 2.4.2, "Local Population," does not discuss the close proximity of a number of individual homeowners. It should, since these are the individuals who will be most likely impacted by the past waste disposal practices and radioactive experiments that were conducted at the LEHR site.

The statement on page 7 under Section 2.5.1 on "Land Use" is somewhat misleading with respect to south of Putah Creek. While there is a narrow band of land that is the Putah Creek Reserve, there are considerable agricultural lands immediately adjacent to Putah Creek which are owned by private individuals. This should have been mentioned.

On page 7, under Section 2.5.2, "Meteorology," the second paragraph states that the Sacramento Valley Air Basin "...has a very high air pollution potential at times....". The issue is not air pollution potential, but actual air pollution.

Page 14, under Section 3.8, "Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)," only mentions the herbicide use. There are pesticide residues such as chlordane and other chlorinated hydrocarbons on the site. They should have been mentioned?

Page 14, under "Endangered Species Act (ESA)," should mention that, thus far, there has been no work to examine the potential for transport of radioactive and other waste materials from the burial locations through plant uptake to the environment, which could be adverse to wildlife. This is a gap in the current site investigation that has not yet been addressed.

On page 20 and elsewhere in various recent DOE documents there is discussion about how various activities at the LEHR site are in accord with the RI/FS. There needs to be clarification of the status of the draft RI/FS that was submitted in September 1994. There is confusion about what is being said in various other DOE documents vs. what is being said about the status of the September 1994 draft RI/FS.

Page 25 presents a "Summary of Radiological Results in Surface Water." One of the significant deficiencies with the surface water investigations being conducted at the LEHR site is the failure to analyze aquatic organisms in Putah Creek downstream of the UCD wastewater discharge for accumulations of radioisotopes and other constituents. It appears that there is highly limited sampling of the stormwater and wastewaters discharged from the LEHR site to the UCD wastewater treatment plant to see what radioisotopes and waste components are now being transported off-site via this mode of transport. This is a potentially significant deficiency that should be corrected.

Page 35, under "Nonpoint/Diffuse Source Emission" discusses the radium-226 seepage system where past disposal practices occurred under a paved area. Have there been any studies of the radon-222 build-up under this area due to the radium-226 waste disposal? This should be done.

Page 37, Table 6.1A lists the various parameters that have been measured. "BOD" should be added to this list.

Page 39, Table 6.1B presents incorrect units for specific conductance. It should be µmhos/cm. Further, through the DOE documents for the LEHR site there is no specification of temperature at which specific conductance is measured. Since specific conductance is highly temperature dependent, the proper way to report results for specific conductance is at the temperature of the measurements. If the values are corrected to some specific temperature, then the correction process used should be defined.

Page 39, "On-site Soil Borings," presents information on the on-site soil borings where it indicates that samples were taken under the western dog pens at 0, 5, 20 and 40 foot depths. The data from these samples are not yet available as of June 1995. The spacing that was used is not adequate to define potential build-up of radionuclides in the soil below the dog pens. There could be appreciable accumulation of radioisotopes between two sampling depths. Further work needs to be done to more properly define the build-up if it has occurred at all in the soils below the dog pens.

Page 42, under "CPT/Hydropunch Results" the word should be "nitrate" not "nitrates." It is inappropriate to include an "s" on "nitrate" unless the same approach is used for all other parameters, such as "sodiums." Further, in the last sentence it states that the data indicate very little or no off-site migration of these parameters. The data that have been collected thus far do not provide an adequate database to reliably make that statement. Actually, the data that have been generated do show that there is a plume proceeding east from the site that has already passed under adjacent properties.

Page 43 presents the "Summary of 1st HSU Groundwater Sampling Results Chloroform." Whenever data of this type are presented, "ND" should be defined as some less-than value. Figure 6.3B shows that chloroform is migrating off-site directly east at concentrations of potential significance compared to chloroform concentrations that would be considered to be adverse based on a risk assessment evaluation.

Page 45 presents the hexavalent chromium for the 1st HSU, again showing a plume moving to the east. A similar plume may exist for Figure 6.3D and for nitrate in 6.3E and 6.3F.

Table 6.3A presents the parameters that have been analyzed for at the LEHR site. Of the general parameters, "DO" should be added. "Phosphorus" should be spelled consistently with "--us," not "--ous."

Table 6.3B on page 50 contains a number of inaccurate MCL's, such as for the individual THM's. Under the metals there is no listing for lead. Was lead not determined in 1994? There is a secondary drinking water standard for iron and manganese. The ammonia nitrogen MCL is not 45 as listed in this table. The units on calcium carbonate are CaCO3. The "O" should be capitalized. Units on specific conductance are umhos/cm. "Eh" should be small "h." The same errors occur in the following tables.

On page 53, "Summary of Hydrogeologic Conditions," third paragraph, mentions that the estimated groundwater velocity is 1.6 ft/year. This is lower than any value that I have seen in the past. Is it a value that was at least once believed to be appropriate? From the groundwater pollution on the eastern edge of the property, it appears that that value may be very low compared to what is actually occurring.

Page 54, first paragraph, mentions the updated value for groundwater velocity for HSU #2 of 600 ft/year to 1170 ft/year. The fact that the groundwater velocity of HSU #2 could be 1,000 ft/year should be discussed in this report in terms of potential significance for the magnitude of the pollution that has occurred at this site over the last 50+ years that the site has received wastes.

Page 54, "Uses of Groundwater in Vicinity," fails to mention that the second aquifer under the site is used for domestic water supply purposes. This is a significant omission that should have been discussed.

Page 55, "CPT/Hydropunch Investigation," mentions the CPT/Hydropunch investigation. One of the issues that needs to be resolved is how reliable is CPT/Hydropunch for characterizing an area for further groundwater monitoring. It is my understanding that over-reliance on CPT/Hydropunch can lead to inaccurate assessments of the potential pollution in the region. There is need for information on how CPT/Hydropunch data were actually obtained. What is being sampled in each case, the sphere of sampling compared to the region being sampled? The reliability of multiple samples taken from the same location and the reliability of the Hydropunch and CPT data compared to groundwater monitoring wells should be established. The hydropunch and CPT data could significantly skew the results so that major plumes occurring from various waste management units will not be detected which at some time in the future could pollute someone's well downgradient from the site.

Page 55, in "Summary of Trends in Analytical Results 1990-1994," the second sentence states, "Chloroform has been detected at low levels in 5 site wells and at consistently higher levels in UCD-12." This is another of the comparative statements that are made throughout this and other DOE documents that has no meaning as to what high-low mean relative to the author's view of issues. Since the author is speaking on behalf of DOE, independent reviewers have to be skeptical as to whether these values are really high and low. This is especially true since a significant error was made in assessing the water quality significance of chloroform in groundwater. If the chloroform data is examined in terms of the risk-based assessment, the chloroform levels would be judged to be high.

With respect to the finding of phthalates in the laboratory and field blanks, this indicates sloppy sample handling that needs to be corrected. It is possible to properly collect samples without contaminating the samples with phthalates.

With respect to page 56, comparing upgradient to downgradient wells, there is an insufficient number of upgradient wells to properly characterize upgradient water quality. This comparison is highly inappropriate and should not have been made, or at least it should have been qualified to indicate that the upgradient water quality has not been reliably determined thus far.

Page 56, under "Radiochemicals," where it is stated in the first sentence, that gross alpha, gross beta, and gamma suggest that groundwater samples collected at the LEHR site do not have elevated alpha, beta, and gamma activity relative to upgradient conditions, again a number of specific isotopes have been found to contaminate groundwaters under the site. What should have been said is that this points to the fact that gross alpha, beta and gamma are not sensitive parameters for detecting potentially hazardous conditions. This report fails to present a balanced discussion of issues that should be presented in a report of this type.

Table 7.3 indicates that BOD was a "requested" parameter as were bacteriological count and dissolved oxygen. I have seen no data for any of these parameters. Where are the data?

Since the radionuclides that could be present in LEHR site stormwater and wastewaters go to the UCD wastewater treatment plant, it would be important not only to measure the concentrations of radionuclides in the Putah Creek discharge waters as has been done, but also in the sludge of the wastewater treatment plant.

James T. Davis, Assistant Manager, Environmental Support, on July 10, 1995 approved the release of this LEHR site report. Further, Dr. S. Attiga on July 10, 1995 certified that the information presented herein is true, accurate and complete. As discussed above, this report falls far short of being a credible discussion of the issues that should have been discussed in a report of this type. There is need for DOE to develop a different review and certification procedure than was used in connection with developing the 1994 Annual Site Environmental Report.

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