Comments on May 16, 1996 PRM meeting minutes

August 19, 1996

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

Dear Julie:

Please find below my draft comments on the May 16, 1996 RPM meeting minutes. As you may recall, I could not attend this RPM meeting because J. Littlejohn scheduled it at a time when I had a previous commitment.

On page 2, first paragraph, it is stated that "The RPMs concurred to issue the draft 1995 Water Monitoring Report as final." This means that yet another water monitoring report is issued from the LEHR site which contains numerous, obvious errors and likely many other errors that were not detected by my casual reading of the report. It is strongly recommended that all copies of the draft 1995 Water Monitoring Report contain a permanently affixed statement which includes my comments on the significant deficiencies in these reports in order to warn future users that the reports were not adequately and reliably prepared and reviewed prior to finalization.

In all of the work that I have ever done on water quality projects, I have never seen a more inappropriate approach for finalization of a data report. To finalize a report which contains obvious significant errors is contrary to all basic premises of science and engineering and the public's interests.

As I have indicated previously, it may be necessary for UCD and DOE to hire an independent, third party to do a proper review of the data reports. While DOE and UCD object to this approach, it is now clear with the handling of the 1995 data report that the RPMs are not going to take the time to critically review and require correction of the data reports to at least address the obvious errors. I can appreciate that the RPMs may not have time to do this, however since UCD and DOE are not fulfilling their responsibilities in developing a credible data report, then there is need to hire a third party who understands water quality issues for both surface and groundwaters to critically review the data reports before finalization. Not only should they address the 1995 report, but also the 1994 and 1993 reports. They all contain significant errors that must be corrected.

It is important to note that the data reports are not just data reports. In addition to the obvious errors in presentation of data, there are also significant errors in data interpretation that cannot be allowed to stand. This type of inappropriate approach of handling data reports has been going on for several years at the LEHR site. It must now stop. Since UCD, DOE and the RPMs have chosen not to address the concerns expressed by DSCSOC, DSCSOC has no alternative but to file a complaint on the inadequate approaches being following in developing data reports for the LEHR site.

I suggest that DSCSOC file a formal complaint with Felicia Marcus, US EPA Region IX administrator; Carol Browner, US EPA Administrator; J. Strock, Cal EPA; and Hazel O'Leary, DOE Secretary of Commerce, concerning the inappropriate approaches being followed in developing and finalizing data reports for the LEHR site. If this is of interest, I will work with DSCSOC in formulating the complaint on this issue for review by the heads of the administrative agencies responsible for the review of the data reports that should have taken place.

On page 2, first paragraph, of the minutes there is discussion about the stormwater runoff sampling program where S. Attiga stated according to the draft minutes, "...the program is meant to monitor impacts from the site, past and present, and is not structured to do studies...". While I cannot be certain that this is what S. Attiga stated, if it is, and it likely is since I have heard him make similar inappropriate statements at other meetings, it is time to put a stop to this type of highly inappropriate approach toward conducting studies. It appears that he may be one of the key people responsible for the poor quality stormwater monitoring program that has been conducted at the LEHR site over the years.

It became clear at the last RPM meeting that he and DOE representatives such as J. Littlejohn do not know the elementary basic principles of how to evaluate stormwater runoff impacts on the beneficial uses of waters such as Putah Creek. No one knowledgeable in water quality issues would ever make the distinction that S. Attiga made between monitoring and studies. What is the purpose of monitoring except to evaluate whether there are potential water quality problems associated with stormwater runoff from the LEHR site? If the monitoring is done incorrectly, as has been the case, then it is impossible to assess whether there are potentially significant problems that require further evaluation. S. Attiga's distinction between monitoring and studies as needed at the LEHR site to evaluate surface water runoff potential impacts is totally inappropriate and reflects a lack of understanding of basic water quality issues. Basically, S. Attiga is stating that in order to do proper monitoring with appropriate analytical detection limits, appropriately measured parameters, etc. it has to be classified as a study. This is foolishness.

On page 2, end of the first paragraph of the minutes, it is stated, "CVRWQCB indicated that upon further review of the information, the analysis for Manganese is not needed." As I indicated at the meeting where this issue first came up, manganese is a parameter that could be important in the groundwaters. I am interested in learning more about what information was reviewed that would indicate that manganese is not an important parameter at the LEHR site. DSCSOC should specifically request this information so that it can be reviewed for its adequacy and reliability.

On page 2, mid-paragraph, is a discussion of whether it is appropriate to incorporate UCD west campus landfill issues in discussions with the LEHR site. A year ago, I indicated that from the information available I was very concerned that LEHR site wastes had been deposited at the west landfill. My concern has continued throughout this period since, thus far, I have seen nothing that convinces me that wastes from the LEHR site were not deposited at the west campus landfill. The recent discussions with Ralph Virgin have eliminated the ambiguity of this situation; there is no question now that the UCD west campus landfill should be part of the LEHR site Superfund site investigations and remediation. DSCSOC should contact the US EPA to have them get involved in this matter.

Page 4, second paragraph, continues to discuss the DOE Box work. Again, this is an inappropriate area for funding compared to the importance of defining the degree of pollution of the first and second aquifers by LEHR site wastes.

If there are questions about these comments, please contact me and please pass these comments on to the RPMs for their review and comments.

Sincerely yours,

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


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