Comments on
Water Monitoring Plan LEHR Environmental Restoration
Davis, California
January 1994
Prepared by Dames and Moore

Comments submitted by

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

December 1996

BACKGROUND

In the summer of 1995, Dr. G. Fred Lee (the author) was appointed the US EPA sponsored Technical Assistance grant supported Technical Advisor to the Davis South Campus Superfund Oversight Committee (DSCSOC). Upon reviewing data reports for the UCD/DOE (University of California-Davis/Department of Energy) LEHR national Superfund site, the author found significant deficiencies in the monitoring approach being used for LEHR site evaluation with respect to assessing the potential public health and environmental problems that could be caused by past waste management practices at the LEHR site. Many of these deficiencies were reported to DSCSOC and through DSCSOC to UCD, DOE and the Remediation Program Managers (RPMs) for the LEHR site. On several occasions over the next year and a half, the author submitted similar reports in the deficiencies in the LEHR site investigation with particular emphasis on the significant deficiencies in the surface water monitoring program. Also reported were deficiencies in the groundwater monitoring program compared to what should be conducted in order to adequately and reliably investigate the potential adverse impacts of the "hazardous", radioactive and deleterious chemicals present at the LEHR site that could be adverse to public health, the environment and the beneficial uses of the receiving waters (Putah Creek) for stormwater runoff from the LEHR site.

UCD, DOE and the RPMs largely ignored the author's (DSCSOC's) repeated comments on the deficiencies in the LEHR site water monitoring program and continued to waste substantial amounts of public funds by collecting data that was inadequate or unreliable to properly characterize potential impacts of LEHR site waste to offsite water quality - beneficial uses. In the summer of 1996 this situation ultimately lead to DSCSOC notifying UCD, DOE and the RPMs that if this situation was not adequately and reliably addressed by the first fall stormwater runoff event of 1996, that DSCSOC would file a formal complaint on the highly significant deficiencies in the stormwater runoff monitoring program with DOE headquarters in Washington, D.C. and with the administrative heads of the regulatory agencies for the LEHR site.

J. Littlejohn of DOE-Oakland proposed a RPM meeting agenda for September, 1996 that did not include the DSCSOC requested discussion of the deficiencies in the LEHR site stormwater runoff water quality monitoring program. J. Roth of DSCSOC, in response to J. Littlejohn's request for potential items for discussion at the September RPM meeting, indicated to J. Littlejohn that stormwater runoff water quality monitoring issues should be addressed at this meeting. J. Littlejohn responded that there were no problems with the stormwater runoff monitoring program at the LEHR site. This lead to the author pointing out again in a memorandum to the RPMs, a number of significant problems with the DOE/UCD stormwater runoff monitoring program for the LEHR site. This caused the RPMs to notify DOE and UCD that they must revise their stormwater runoff monitoring program to address the issues that DSCSOC raised.

The RPMs' November 20, 1996 review (as presented in the H. Ficklin letter) of the Water Monitoring Plan that was submitted to DOE and UCD, with copies to DSCSOC and others, included a list of issues that they recommend that DOE address as deficiencies in this plan. Upon review of these comments, the author found reference to the 1994 Water Monitoring Plan for the LEHR site. Until that time he was unaware of this document. This is another of the situations that occurred where shortly after the author was appointed as the DSCSOC's Technical Advisor in June 1995, DSCSOC on his behalf requested that J. Littlejohn make available all pertinent background documents on the LEHR site. According to the author's records, he did not make available on of the most important documents for the LEHR site--the Water Monitoring Plan. Upon learning of this Plan onn November 24, 1996, the author requested a copy of this plan which was received on December 12, 1996. Presented herein are comments on the technical deficiencies in the January 1994 Water Monitoring Plan surface water issues associated with the LEHR national Superfund site stormwater runoff water quality monitoring program.

COMMENTS ON 1.0 INTRODUCTION

Page 1.1 last paragraph states, "The purpose of the Water Monitoring Plan is to document the procedures used to characterize and monitor surface water and groundwater quality at the LEHR site." As discussed herein, those who developed and reviewed this plan have approved a plan that falls far short of achieving this purpose. The focus of the stormwater runoff water quality monitoring program is on chemical constituent concentrations in runoff waters. Those familiar with real water quality issues know that chemical constituent monitoring, as has been practiced by DOE and UCD, is not a reliable approach for assessing potential real water quality issues of concern to the public in the off-site receiving waters from a hazardous waste/hazardous chemical impacted area such as the LEHR site.

Those who understand water quality know that water quality is a social issue, namely how the constituents in the water impact the designated beneficial uses of a waterbody of concern to the public. The US national water pollution control policy established in 1972, requires that each waterbody be designated with respect to its beneficial uses such as water supply, fish and aquatic life, groundwater recharge, wildlife habitat, etc. and that any discharges to a particular waterbody do not impair the designated beneficial uses of that water. While some, like those responsible for surface water runoff from the LEHR site monitoring program, attempt to translate water quality to a few chemical constituent concentrations, it is well known that this approach can and usually falls far short of addressing the full range of the important beneficial use impairments that should be addressed in a technically valid, credible stormwater runoff monitoring program.

Because of the significant deficiencies in the LEHR site stormwater runoff monitoring/evaluation program, the author proposed, and has had accepted, a paper devoted to a discussion of the development of a credible stormwater runoff monitoring program from a hazardous chemical site which will be presented at the ASTM National Risk Assessment conference to be held in San Diego, California in January, 1998. The author has recently provided DSCSOC and UCD/DOE and the RPMs (through DSCSOC) with an overview report which served as the basis for the paper that will be presented at this meeting and appear in the proceedings of this conference. This overview report and the paper provides a discussion of many of the key issues which should be addressed in the development of a reliable stormwater runoff water quality monitoring program for the LEHR site that will achieve the objectives set forth on the last paragraph of page 1.1 of the Water Monitoring Plan.

Page 1.3 first paragraph under section 1.2 Approach states,

"The components of this Water Monitoring Plan include monitoring points, sample collection frequency, and data quality objectives (DQOs), which have been developed using the general requirements of the DOE Order 5400.1 and applicable federal and state regulations."

The fact that the monitoring plan has ignored Putah Creek aquatic life protection issues makes it clear from the data that has been developed from this Plan, that the those who prepared and reviewed this Plan and those who approved it did not and do not understand the basic water quality regulatory approach that is used for surface waters in the United States and in California as well as by the Central Valley Regional Water Quality Control Board.

As the author has repeatedly pointed out, the implementation of this Water Monitoring Plan has been highly deficient in presenting the monitoring results in the quarterly, as well as annual data reports for the LEHR site where the data for surface water monitoring has been compared only to drinking water MCLs. Putah Creek has a fish and aquatic life designated beneficial use. Those familiar with elements of water quality assessment know that for many constituents, fish and aquatic life are far more sensitive to many chemical constituents than humans, with the result that the water quality criteria, state standards and Basin Plan objectives are significantly lower for surface water quality protection than for drinking water consumption. When the author first reviewed the data reports that were made available to DSCSOC, he commented that with respect to surface water issues, these data reports were technically invalid in that the concentrations of the constituents measured in the stormwater discharges and wastewater runoff to Putah Creek which were only compared to drinking water MCLs and ignored aquatic life water quality criteria.

When data reports continued to be generated which consistently made inappropriate assessments of the critical concentrations of constituents in stormwater runoff from the LEHR site, the author pointed out these deficiencies again. It became clear in the spring of 1996 that UCD, DOE, and their consultants did not know about the US EPA Gold Book of water quality criteria released in 1987. This document is the "bible" for those working on water quality issues. It contains a listing of the critical concentrations of the chemical constituents in water that can be adverse to various types of designated beneficial uses of waters. At the request of J. Littlejohn at a spring 1996 meeting, the author provided UCD/DOE and the RPMs with information on how to obtain a copy of the US EPA Gold Book of water quality criteria. However, those who prepared the spring 1996 LEHR site data report, which was released in August 1996, again ignored the Gold Book criteria in presenting the critical concentrations of chemical constituents in surface waters for protection of aquatic life.

Page 1.3 under section 1.3 Organization of Water Monitoring Plan, does not mention the key issue that should have been addressed in the Plan, namely real water quality issues. Real water quality issues such as the basic approach used to regulate water quality were originally developed by Congress in 1972 and have been reaffirmed by Congress with the reauthorization of the Clean Water Act periodically since then. This plan should have had an upfront section discussing what is legally required to conform to DOE Order 5400.1 which specifies the regulatory framework water quality criteria and standards and Basin Plan objectives which this plan is supposed to provide data for, in order to conform with federal and state regulations as set forth on Page 1.1 paragraph 2 of the Plan.

COMMENTS ON 2.0 BACKGROUND

Page 2.4 first paragraph states,

"Because of the limitation of scope and Data Quality Objectives (DQO) of the previous investigation, data obtained from these activities may not be reliable or sufficient to draw conclusions regarding the nature and extent of contamination at the LEHR site."

The same situation applies today, three years after this Plan was adopted. Several components of the basic elements of this Plan coupled with the way it has been implemented by UCD/DOE and its contractors have failed to adequately and reliably characterize stormwater runoff from the LEHR site with respect to the impacts on the designated beneficial uses of Putah Creek.

Page 2.6 last sentence of the second paragraph states, "Additional HSUs (greater than 150 feet bgs), known to exist on a regional basis, have yet to be investigated below the LEHR site." That situation still prevails today. UCD and DOE still have not addressed, in a credible way, even the planning for investigating the pollution of HSU 4 that has likely occurred at the LEHR site. This is the primary aquifer for domestic water supply in the region. Failing to address HSU 4 pollution by the LEHR site which can occur both through natural migration from HSU 2 through HSU 3 and through interconnecting wells between HSU 2 and HSU 4 is one of the current, most significant deficiencies in the UCD/DOE investigation of the LEHR site. It should receive the highest priority for funding.

Page 2.6 third paragraph states that "The average flow velocity estimated for the first HSU is 1.6 ft/yr." Page 2.9, first paragraph states, "...the average flow velocity value estimated for the second is HSU is 71 ft/yr." As was brought out by PNNL after Dames and Moore was no longer the contractor for DOE at the LEHR site, the 71 ft/yr estimate was in significant error and was based on flawed evaluation approaches. The actual flow velocity of HSU 2 is more than a factor of ten greater than that estimated by Dames and Moore and accepted by the RPMs as set forth in the Water Management Plan of January 1994.

Page 2.9 second paragraph states,

"The results of the numerical modeling and the groundwater gradient information suggest that the creek acts as a continual source of recharge to the first HSU. This recharge area creates a groundwater high in the first HSU beneath the creek. The modeling indicates that recharge from the creek has a direct impact on the second HSU only at regional steady-state periods."

The fact that Putah Creek recharges groundwater in the region has been largely ignored by UCD and DOE in conducting LEHR site investigations. It was only incidently that, in the winter of 1996, DOE, through its contractors, indicated that wastewater components discharged by UCD from its campus wastewater treatment plant were polluting the groundwaters along Putah Creek with VOCs. This issue should have been addressed previously as one of the potential consequences of the discharge of wastewaters and stormwater to Putah Creek from the LEHR site. Based on the recent draft Environmental Impact Report prepared by the L. Vanderhoef administration, UCD is attempting to claim that the pollution of groundwaters by Putah Creek derived constituents is not of significance. However, this pollution is a direct violation of the UCD campus wastewater NPDES permit requirements and the Regional Water Quality Control Board Basin Plan objectives.

Page 2.9 last paragraph discusses the stormwater runoff system at LEHR. This discussion shows that those who prepared and reviewed this report did not, prior to reporting on the system, walk through the sight during a rainfall runoff event. If they had, they would not have ignored the stormwater runoff from the LEHR site that could potentially contain radioactive and hazardous wastes. It is clear that those responsible for developing the stormwater runoff monitoring components of this Plan did an inadequate evaluation of stormwater monitoring points. They ignored three important monitoring points that should have been identified and routinely monitored since the 1980s when pollution of the environment by LEHR site waste was first documented.

The monitoring of stormwater runoff from the LEHR site should include, in addition to monitoring the stormwater runoff from the west part of the site that is pumped under Old Davis Road, the monitoring of the stormwater runoff that enters Putah Creek near the Raptor Center as well as that which enters the stormwater runoff channel that UCD cut through the top of Landfill No. 3. Further, the discharge from this channel should be monitored as it enters Putah Creek.

There are still continuing problems with whether stormwater from the LEHR site enters the campus sewerage system. Until this past summer, UCD/DOE reported that stormwater from the LEHR site entered the sewerage system. However, this past fall UCD/DOE now claimed that no stormwater from the LEHR site enters the campus sewerage system. From DSCSOC's perspective, this has not yet been properly evaluated. The RPMs recommended modification of the Water Monitoring Plan as set forth in a November 20, 1996 letter from H. Ficklin to UCD and DOE which included termination of the wastewater discharge monitoring from the campus sewage treatment plant, since new information has indicated that stormwater runoff from the LEHR site does not enter the campus sewerage system. The author recommends that the monitoring of wastewater discharges not be terminated until this has been properly documented by monitoring flows during runoff events in the sewerage system conveying LEHR site wastewaters to the campus sewerage system to see if they increase as a result of infiltration of stormwater. The termination of this monitoring point would be inappropriate and should be vigorously opposed by DSCSOC.

COMMENTS ON 3.0 EVALUATION OF
EXISTING WATER MONITORING SYSTEM

Page 3.3 third paragraph states "The existing surface water monitoring program at the LEHR site also began in November 1990 and is conducted quarterly at three locations along the South Fork of Putah Creek." Since the monitoring program of Putah Creek was ill-conceived and inadequately implemented and reported, large amounts of public funds have been wasted by UCD/DOE and its contractors in developing a credible assessment of Putah Creek water quality as it may have been impacted by stormwater runoff and wastewater discharges to the creek associated with LEHR site activities. This issue is discussed further herein.

Page 3.3 third paragraph last sentence states, "Monitoring at these locations [Putah Creek] is conducted quarterly, and for the same list of analyses as groundwater samples." This sentence exemplifies the basic problem with the LEHR site investigation in that those responsible for developing and approving these investigations do not understand the difference between groundwater quality and surface water quality. Those who understand these issues would not normally use the same list of parameters for both surface and groundwater. Surface water issues are significantly different than groundwater issues. They have to be approached differently if a proper monitoring program is to be developed and implemented. This difference arises from the fact that critical concentrations of constituents to protect real water quality (beneficial uses of surface waters) is different than groundwaters.

Table 3.2 which begins on page 3.6 and extends over the next several pages lists the various parameters that have been monitored and the methods used as well as the monitoring points. Significant errors were made in the selection of the analytical methods used for the surface water monitoring in that methods have been selected and are still being used that do not have adequate sensitivity (sufficiently low detection limits) to measure constituents of concern derived from the LEHR site to adversely impact the beneficial uses of Putah Creek. This table is also deficient in failing to list the detection limits for the constituents and compare these detection limits with the purpose of the monitoring program, mainly to comply with federal, state and local regulatory requirements.

Table 3.2 has a number of errors which reflect the fact that those who developed the table and those who reviewed it do not understand the basic element of water analysis. For example, chromium (hexavalent) is not determined by CAA. Further (on page 3.7) T.S. is not determined by a spectrophotometer.

Page 3.7 indicates that a portable meter was used for measuring electrical conductivity. As the author has repeatedly pointed out, there is something drastically wrong with either the electrical conductivity or the T.S. measurements. While the problem was pointed out when the author first saw the data reports in the summer of 1995, unreliable data continues to be reported in data reports including the first quarter of 1996 where there is an obvious significant error in the data reported for T.S. and electrical conductivity.

Focusing the monitoring program on a few chemical constituents as is done for the parameters measured with respect to surface water issues is inadequate in properly characterizing the impacts of stormwater runoff and wastewater discharges from the LEHR site. The chemical constituents are of concern because of their potential to be toxic to aquatic life or bioaccumulate to excessive concentrations in aquatic life tissue causing the organisms to be a public health hazard to those who consume them as food. Focusing on a few regulated chemical constituents rather than constituent impacts (toxicity and bioaccumulation) can and usually results in an unreliable assessment of water quality impacts of a hazardous chemical site such as the LEHR site. This is due to the fact that only a few of the over 75,000 chemicals that are in use today are regulated. Typically less than 100 chemical constituents are monitored out of the many tens of thousands of hazardous or deleterious chemicals that are present at a hazardous chemical site such as the LEHR site that could be present in stormwater runoff and wastewater discharges from the site. There could readily be, and almost certainly is, constituents in stormwater runoff from the LEHR site that are toxic to aquatic life in Putah Creek that are not measured by chemical constituent monitoring as set forth in this plan and as implemented by UCD and DOE.

The only way to reliably assess whether the unregulated chemicals and combination of regulated chemicals have additive or synergistic effects that are adverse to receiving water beneficial uses (aquatic life) is through direct toxicity measurements using a suite of sensitive forms of aquatic life that are now routinely used for monitoring wastewater discharges and ambient water quality. These are US EPA standardized procedures that can and should have been used and now should be immediately implemented into the stormwater runoff monitoring program.

Further, since stormwater runoff from the LEHR site contains constituents that tend to bioaccumulate, such as chlordane, to excessive concentrations in aquatic life tissue rendering the fish a threat to cause cancer in those who consume the fish, it is essential that bioaccumulation of hazardous chemicals in fish tissue be monitored. It is mandatory that any credible monitoring program designed to address stormwater impacts from the LEHR site include periodic monitoring of Putah Creek aquatic life tissue to determine if there are excessive concentrations of constituents in aquatic life that could cause human health hazards to people who utilize the fish from Putah Creek as a source of food as well as wildlife (animals and birds) that utilize Putah Creek aquatic life as food.

A significant problem in developing the water monitoring plan which reflects a lack of understanding of basic water quality issues became evident from review of the draft RI/FS for the LEHR site developed by Dames and Moore in the Fall of 1994. It is stated in that draft RI/FS that bioaccumulation studies would be done if potential toxicity from chemical constituents is detected. This approach reflects a lack of understanding of basic water quality issues with respect to toxicity versus bioaccumulation for the chemicals of greatest concern with respect to bioaccumulation. A review of the US EPA Gold Book shows that for these chemicals, the concentrations which is toxic to aquatic life or for that matter, the concentration that is excessive for drinking water based on MCLs, is far greater than the concentrations that can be present in a water that leads to excessive bioaccumulation that represents a health hazard to those who use the fish as food. An example of this situation is chlordane.

The data reports for chlordane show that at least on one occasion chlordane is found in surface water runoff at concentrations that represent a significant threat to bioaccumulation in aquatic life in Putah Creek compared to US EPA water quality criteria for chlordane. However, the data reports for the sample that contained the elevated chlordane compared the concentrations of drinking water standards and thereby ignored the issue of bioaccumulation which is the primary mode of adverse impacts for chlordane arising from LEHR site wastes. Further, even if these elevated concentrations of chlordane had not been detected, there are still many constituents both regulated and unregulated such as mercury where the concentrations measured by the analytical methods which are reported as non-detect in the data reports could readily be causing excessive bioaccumulation in Putah Creek fish. It is essential that because of the inability to measure concentrations of constituents at critical levels with respect to preventing bioaccumulation that actual bioaccumulation measurements be made periodically on Putah Creek tissue.

Page 3.9 last paragraph states, "Low concentrations of organochlorine pesticides were also reported in surface water samples..." Although the organochlorine pesticides of concern are not specifically delineated in this statement review of those analyzed show that many of them tend to bioaccumulate.

Another significant deficiency with the monitoring program is the fixed period quarterly monitoring approach for Putah Creek. In order to credibly evaluate LEHR site stormwater runoff as having an adverse affect on beneficial uses of Putah Creek, it would be necessary to adjust the Putah Creek monitoring to periods when runoff is occurring as well as other times when no runoff is occurring. There could readily be pulses of constituents in runoff waters that are toxic to aquatic life that are not measured immediately during stormwater runoff monitoring or in the Putah Creek monitoring due to the inappropriate sampling period or sampling times. The monitoring of stormwater runoff impacts on Putah Creek must include monitoring Putah Creek for aquatic life toxicity at several locations above, at and downstream of the LEHR site for several storms per year.

There is also a potential problem with the location of the sampling sites on Putah Creek. Figure 3.1 shows that the PCD (downstream) sampling station on Putah Creek was above the channel that the University of California-Davis cut through the top of Landfill No. 3. The issue of the pollution of Putah Creek by Landfill No. 3 derived waste constituents which are exposed in the bottom of this channel are still present, approximately 10 years from when this potential source of pollution was first documented in DOE documents, is still not resolved. The potential impacts of the stormwater passing through the exposed waste in the bottom of this channel has still not been reliably monitored. The monitoring that was done in February 1996 by UCD was, as discussed in previously submitted comments by the author, done incorrectly. Many of the same errors that have been discussed in previous comments as well as herein occurred in that monitoring program.

When DSCSOC toured the site July 1995 with the DOE site manager, they were informed that the location of the downstream sampling point on Putah Creek was, as indicated upstream of the channel cut through the top of Landfill No. 3. DSCSOC pointed out that this sampling would not detect the potential Putah Creek impacts of the discharge of stormwater through the channel. DOE site staff changed recording of the position of the monitoring point to some point downstream of the channel. They indicated that the previous reporting of the location of PCD was incorrectly presented in their report maps and while not discussed, incorrectly reported by the site manager to DSCSOC (J. Roth and Dr. G. Fred Lee) in July 1996. This issue raises the question as to where the sampling point was and where the sampling point samples were actually taken by the site staff.

Finally, and most important, samples were taken on a fixed period quarterly sampling irrespective of stormwater runoff. Such sampling would not necessarily show the impacts of the constituents present in stormwater runoff through the UCD cut channel exposing wastes in the top of Landfill No. 3. It is important to note that Landfill No. 3 has received LEHR site hazardous chemical wastes and radioactive wastes as well as campus waste which contain a variety of hazardous and deleterious constituents and therefore the waste in this landfill as well as those exposed in the channel could readily be detrimental to Putah Creek beneficial uses.

Another issue that must be addressed in any sampling of Putah Creek downstream of the LEHR site is whether the sampling point and sampling methods would properly sample the mixed runoff waters and Putah Creek waters impacted by the LEHR site stormwater runoff. Often stormwater runoff does not mix well within the receiving water for considerable distances downstream of the point where it first enters the waterbody such as a small creek. Even if it were properly collected to coincide with runoff events, it would not properly represent the mixture of constituents in Putah Creek and its stormwater runoff that is entering through the top of the exposed wastes in Landfill No. 3.

Another factor to consider in the sampling locations is that about halfway between Old Davis Road and PCD locations on Figure 3.1 is another LEHR site stormwater runoff location that was not known to DOE LEHR site and UCD personnel. This site was discovered in a walk through the site by D. Austin during the summer of 1996. J. Roth has confirmed with the first stormwater runoff event of the fall 1996 season that runoff from the LEHR site landfill areas enters Putah Creek through this source - a pipe cut through the levee near the Raptor Center.

It should also have been noted that stormwater runoff from the LEHR site waste management areas has been occurring for years through a drainage ditch and pipe system that dumps stormwater from the LEHR site into the drainage channel cut by UCD through the top of Landfill No. 3. Therefore, even if there was no release of constituents from the exposed waste in the bottom of the channel, there still could be LEHR site derived waste present in stormwater runoff from the main body of the LEHR property that has been transported via the ditch and pipe through the drainage channel to the Landfill No. 3 drainage area. As of yet the characteristics of the runoff through this ditch and pipe into the channel have not been adequately and reliably determined with respect to their potential impacts on Putah Creek water quality.

Another factor to consider in the sampling of LEHR site stormwater runoff is that UCD/DOE(?) personnel have not adequately evaluated whether stormwater runoff is occurring from the LEHR site. This was exemplified through discussions at the last RPM meeting where UCD/DOE(?) personnel reported that the first major stormwater runoff event of the fall 1996 season did not result in runoff to Putah Creek. They reported at the RPM meeting that there was no runoff occurring in the drainage ditches and channel at 11:00 am of the morning following the major runoff event. J. Roth, however, visited the same area at 4:00 pm that same day and took pictures of the significant runoff that was occurring. This means that UCD/DOE have again failed to comply with regulatory requirements of monitoring first flush runoff events for a new precipitation season. In the LEHR site setting, this is likely to be the most important time for monitoring because this is when the constituents would have built up to the greatest concentrations. It is essential that UCD/DOE establish a more reliable approach for assessing whether stormwater runoff is occurring from the LEHR site than was demonstrated for the first storm of the fall 1996 season.

Table 3.3 presents a summary of the previously collected data as of the time of developing this Plan. This data presentation represents an inappropriate approach for data presentation that has prevailed through the LEHR site data reports. Basically, this approach of presenting the number detected, number sampled, lowest detection and highest detection does not adequately and reliably convey the information collected at the site with respect to water quality impacts. One of the issues that has be included in any presentation of data of this type is what are the detection limits that were used to determine the levels of detection. The heavy metal data presented in this table is suspect to the lowest detection since the numbers presented are frequently 1 g/L for many of the parameters. Further, a number of the parameter analytical results are presented with far more significant figures than can be justified by the sampling and analytical methods used.

COMMENTS ON 4.0 WATER MONITORING PROGRAM

Chapter 4 presents the water monitoring program. The comments presented herein are restricted to the surface water issues. No discussion is presented herein on the groundwater aspects of this program. There are significant problems with the groundwater monitoring program, as well, especially with respect to data reliability to try to use the approach that DOE and its contractors are using of comparing upgradient groundwater composition to LEHR site and downgradient composition to determine if pollution of the groundwaters has occurred. There is not an adequate, reliable database to make this kind of comparison with anything more than the grossest aspects of pollution. Many of the issues of concern have been discussed previously in comments that have been submitted to DSCSOC which have been passed on to UCD, DOE and the RPMs. As discussed in these comments, there is an urgent need to significantly improve the reliability of the groundwater monitoring program if UCD/DOE plan to try to detect subtle differences between upgradient and LEHR site composition as part of determining the need for remediation for LEHR site groundwater.

Page 4.5 last paragraph, discusses the surface water monitoring locations. Presented above is a discussion of the significant deficiencies in the surface water monitoring locations associated with the LEHR site, including failing to monitor all locations where stormwater runoff from the LEHR site is occurring.

Page 4.7 first paragraph, discusses monitoring parameters and schedule where it mentions that samples are collected quarterly. As discussed herein, the arbitrary quarterly sampling program for surface water impacts cannot reliably evaluate LEHR site-derived stormwater runoff -associated constituents' impacts on Putah Creek water quality. Some of the LEHR site constituent-derived potential pollution conditions which could result in deteriorated water quality in Putah Creek, such as aquatic life toxicity, will be of short duration and therefore would not be detected by the monitoring program that has been and continues to be conducted. Even though the toxic conditions may only exist for a short time, they can be highly detrimental for the fisheries and other aquatic resources of the Creek.

The monitoring parameters and analytical methods selected are highly deficient with respect to detecting adverse impacts of chemical constituents on aquatic life-related beneficial uses, especially for some of the regulated constituents such as chromium VI which can be toxic to aquatic life in concentrations at a factor of 10 or more below the analytical detection method used in these studies. Further, another significant deficiency for the regulated chemicals monitored is the failure to address the toxicity due to additive or synergistic effects for these chemicals in the stormwater runoff from the LEHR site alone, as well as in combination with upstream-derived constituents. There could readily be toxic situations arising from a combination of chemicals that are not detected by individual constituent monitoring. This is especially true for the highly inadequate monitoring program that UCD and DOE have conducted at the LEHR site.

Further, the failure to monitor bioaccumulation of hazardous chemicals in Putah Creek aquatic life tissue is another significant deficiency in the past stormwater runoff water monitoring program for the LEHR site.

Also, this monitoring program has failed to address the potential toxicity and bioaccumulation of unregulated chemicals derived from the LEHR site. These issues can only be addressed through conducting a comprehensive aquatic life toxicity monitoring program of several stormwater runoff events at several locations in Putah Creek above, near and downstream of the LEHR site. Also, periodically fish and other aquatic organisms should be taken from Putah Creek and analyzed for aquatic life tissue content for the hazardous chemicals that are typically of concern because of their bioaccumulation in fish tissue.

Page 4.7 second paragraph, discusses stormwater runoff monitoring where mention is made that two sampling points are to be used. As discussed herein, there are five principal sampling points that should be monitored in any credible stormwater runoff monitoring program from the LEHR site. Those who developed this plan failed to properly evaluate the surface water hydrology associated with the LEHR site.

Page 4.8 Table 4.2, lists the chemical parameters monitored in the water samples. In addition, aquatic life toxicity using a three standard US EPA test species as set forth in Lewis et al. "Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms," Environmental Monitoring Systems Laboratory-Cincinnati, July (1994), should be monitored for chronic toxicity in the runoff waters and at several locations in Putah Creek for at least one storm in the fall, mid-winter and late winter/early spring of each year. The aquatic life toxicity measurements should be made in conjunction with runoff events as well as during non-runoff periods.

Further, bioaccumulation monitoring of Putah Creek aquatic life should be conducted for the chlorinated hydrocarbon pesticides, PCBs and dioxins as well as mercury each late summer/early fall of the year.

Page 4.9 represents a February 1996 revision which shows, in response to DSCSOC's request, that a stormwater monitoring program has been added at the end of the UCD channel that was cut through the top of Landfill No. 3 . The stormwater discharge point just to the west of the Raptor Center is not shown. Further, the stormwater monitoring point at the point of where LEHR site stormwater enters the UCD drainage channel at Landfill No. 3 is not shown. Both of these points should have previously been identified and monitored.

Page 4.10 first paragraph, states, "Monitoring will be conducted during two separate rainfall events per year for the parameters listed in Table 4.3. The first storm water runoff sampling event will occur at the first precipitation event of the rainy season that provides enough runoff for sampling." Because of inappropriate assessment made by UCD/DOE(?) staff, the first rainfall runoff event of the fall 1996 was not sampled in accord with this plan. This is a highly significant deficiency in implementation of the plan by UCD/DOE(?) staff that must be addressed so that future sampling of rainfall runoff events is more reliably done in order to detect the first flush runoff of the first major storm of the fall of the year than was done in the fall of 1996.

The number of sampling periods should be increased to three stormwater runoff events, including the first major event in the fall, mid-winter and late winter/early spring. The characteristics of the stormwater runoff in each of these periods could be different due to a variety of factors, including the translocation of hazardous constituents in the waste management units and soils through the plants' roots, leaves, flowers, etc. to the surface.

Further, the proposed plan of reducing the sampling of runoff that involves addressing surface or near-surface contamination that could be incorporated into stormwater runoff should not be implemented until several years after all remediation of the LEHR site has been completed. When the site has been shown to be "stabilized" with respect to the characteristics of the stormwater runoff from sampling three storms per year, then it would be possible to reduce the frequency of sampling to one major first flush storm runoff event in the fall of each year. That sampling program should continue for at least ten years after the site has been officially closed (remediated). A site can be judged to be stabilized when it is possible, based on past data, to predict with a high degree of reliability the analytical results that will be obtained from the next round of sampling. If such predictions cannot be made, then the stormwater runoff is not adequately characterized to permit reduction of the sampling frequency.

The information provided in Table 4.4 should include the anticipated analytical detection limits that will be achieved for the procedures listed. Further, a discussion should be provided of these detection limits relative to the stated purpose of the monitoring plan, namely to evaluate the impacts of stormwater runoff-associated constituents on Putah Creek water quality - beneficial uses as defined by federal, state and local regulatory requirements. Further, the data reports should list the actual detection limits that were achieved at the time of analysis of the sample that is being reported in the data report.

COMMENTS ON 5.0 FIELD METHODS AND PROCEDURES

Page 5.1 last bulleted item, mentions the calibration of the conductivity meter. As discussed herein, either the conductivity meter or the T.S. measurements have frequently been in significant error as evidenced by the data reported in the data reports for the past several years. Further, the reporting of specific conductance data must include the temperature at which the measurements were made or corrected to. If a correction procedure was used, it should be delineated in each report as to the magnitude of the correction made and how the correction was implemented. Reliable T.S. - electrical conductivity data are extremely important in detecting different water masses, incipient pollution and other characteristics of the surface and groundwater. The inadequate attention that has been given to this issue by UCD, DOE and the RPMs should be terminated. Justification for properly measuring T.S. - electrical conductivity has been provided in several of the author's previously submitted comments to DSCSOC which have been passed on to UCD, DOE and the RPMs.

Figure 5.1 contains the error on the location of the PCD sampling point that was detected by DSCSOC in their review of the data. This figure also fails to show the two other stormwater runoff locations that occur from the LEHR site to Putah Creek as well as the location of LEHR site stormwater runoff that occurs by the ditch and pipe that discharges to UCD's stormwater drainage channel that cuts through the top of Landfill No. 3.

Page 5.6 is the first page of the several-page Table 5.2. On page 5.6 the analyte Eh is listed. The author does not remember seeing that data. He knows from UCD's presentation at the September 20, 1996 hearing for the CVRWQCB that UCD staff and evidently their consultant, Dames and Moore, do not understand how to properly interpret Eh data with respect to establishing the thermodynamically stable species of chromium that should occur in Putah Creek. Eh data as collected are not a reliable measure of thermodynamically stable conditions, but instead reflect some unknown measure of mixed potentials of certain, but not all, redox couples. Additional information on appropriate use of Eh data is provided in introductory aquatic chemistry texts such as Stumm and Morgan, Aquatic Chemistry, Third Edition, Wiley (1996). The author has discussed this issue in detail in his comments to the State Water Resources Control Board on the highly significant deficiencies in the University of California, Davis' September 20, 1996 presentation to the CVRWQCB on the Putah Creek chromium issues. A copy of these comments is available upon request. Those familiar with proper uses of Eh measurements know that they can only be used to describe general Eh conditions such as oxidizing, reducing or transitional between oxidizing and reducing. Any attempt to be more precise than this is technically invalid and can readily lead to erroneous conclusions such as has occurred by the UCD staff in predicting the thermodynamically stable species of chromium in Putah Creek.

One of the analyses that should be added to this monitoring program for both surface and groundwater is dissolved oxygen (DO). Many of the key issues of the thermodynamically stable form of a constituent which impacts the transport and transformations of constituents in groundwaters and surface waters/sediments, as well as their impacts on water quality, is dependent upon whether oxygen is present or not. Similarly, one of the requirements for protection of Putah Creek water quality is dissolved oxygen concentrations in the Creek. Dissolved oxygen should be measured on each of the samples of surface water and groundwater taken as part of the field procedures. This is a far more important parameter in water quality than redox potential. In any sample where DO is low or near zero, then the measurement of hydrogen sulfide should also be conducted. The presence of hydrogen sulfide should be examined nasally, with one's nose. It can be detected at potentially significant concentrations by most individuals and therefore does not have to measured chemically.

Page 5.9 in the continuation of Table 5.2, the hexavalent chromium detection limit of 10 ug/L is far too high to address toxicity issues. This should be set at 1.0 ug/L. This is the value routinely used by the USGS in their surface water water quality studies. The detection limit for total chromium is also too high. Since chromium III converts to chromium VI, the detection limit for total chromium should be set at 1.0 ug/L as well.

The arsenic detection limit of 2 ug/L could readily be too high compared to US EPA proposed water quality criterion for arsenic which includes a 0.2 ug/L value. Each of the analytical procedures used for each of the LEHR site constituents of potential concern should be examined with the adequacy of the detection limits of the methods used compared to the critical concentrations that could influence water quality in surface and groundwaters. Where the methods being used do not have adequate detection limits, then alternative, acceptable methods should be used. If this is not possible, then alternative approaches should be adopted to address the detection of water quality problems associated with LEHR site-derived wastes.

Page 5.10, Table 5.2 lists the detection limits which include 0.2 ug/L for mercury. This value is not adequate to detect potential problems due to mercury bioaccumulation in fish tissue. There are more sensitive procedures which are readily available to determine mercury at at least one to two orders of magnitude lower. These methods should be used since the critical concentration of mercury is well below the detection limits of the methods used here to avoid bioaccumulation issues. Further, direct measurement of mercury in aquatic life tissue should be practiced to determine if all of the sources of mercury, including the LEHR site, are adversely impacting the use of Putah Creek fish as a source of human food.

Table 5.2 on page 5.12, lists the detection limit for phosphate as 1.0 mg/L (P or PO4?). This is far too high to address water quality issues associated with phosphate. Phosphate can cause adverse water quality problems at about 10 ug/L P. Analytical methods are readily available down to about 5 ug/L P.

Page 5.14 first paragraph, indicates that "The sample containers will be labelled including various information including, site name, location identification,..." etc. Essentially for each set of data in a LEHR site data report there are at least one and sometimes two and three samples in which the data report indicates that it appears that the sample containers were mislabeled. It is readily possible to collect samples without mislabeling the sample containers. Many use a bar code to identify and distinguish samples. The UCD/DOE sampling team needs to improve its handling of samples to eliminate the problems it is having with sample labeling.

Page 5.14 under Storm Water Sampling Procedures, the author has previously commented on the inadequacies of taking two samples per year at two locations. All five locations should be sampled at least once during the first fall runoff event, mid-winter and late winter/early spring at the point where it is pumped across Old Davis Road where it runs off to Putah Creek, at the storm drain from the LEHR site near the Raptor Center, at the point where it enters Putah Creek trough the UCD channel cut through the top of Landfill No. 3, and the point where it runs into this channel from the LEHR site which drains the eastern part of the LEHR site. Also, until convincingly demonstrated otherwise by reliable monitoring of the domestic wastewater flow from the LEHR site to the campus sewerage system, the outfall of the sewage treatment plant discharge to Putah Creek should be sampled to evaluate the potential impacts of LEHR site-derived stormwater impacts on UCD wastewater discharges to Putah Creek.

One of the issues that should be addressed in connection with LEHR site sampling, sample handling and analysis is whether "clean" sampling and sample handling techniques are used. The poor reproducibility between some duplicate samples presented in data reports indicates that inadequate attention is being given to sampling and sample handling techniques in the field and/or in the laboratory. This is especially important for heavy metals but is applicable to other parameters, as well. The US EPA has developed guidance on how to sample using clean techniques. These procedures should be followed to avoid contaminating samples. The US EPA Region IX should provide UCD/DOE with a specific set of directions on how to sample with clean techniques.

COMMENTS ON 6.0 QUALITY ASSURANCE/QUALITY CONTROL
AND 7.0 DATA MANAGEMENT PLAN

Sections 6.0 and 7.0 deal with quality assurance/quality control and data management planning. For each of the data reports that the author has reviewed, he has found significant problems in at least one and often several sets of data where the data have not been reliably reported in the data report. As the author has suggested in the past, there is an urgent need for someone who understands water quality data to critically review the data reports before they are released. Since, based on past reports, there is no one on the UCD/DOE staff and their former consultants, it is likely that this will likely require UCD/DOE to hire additional personnel directly on the staff or have their consultants hire personnel who understand water quality data and can readily spot the errors that the author has picked up by casual review of the data reports, to eliminate these kinds of problems. At this point, the author cannot comment on whether Weiss Associates has staff associated with the LEHR project that has sufficient understanding of water quality issues to address these issues since Weiss Associates has not yet submitted any data for review.

COMMENTS ON 8.0 DATA EVALUATION

Page 8.1 second paragraph under Data Evaluation, states the second objective "... of both graphic and statistical analyses are:... 2) to define impacted areas of the site and impacted monitoring points..." It is not clear what "impacted" means. This should be defined as to whether the term is referring to chemically impacted or water quality impaired.

Page 8.1 third paragraph, discusses Graphical Data Presentation. Far too much emphasis is placed on geochemical approaches as opposed to water quality evaluation of the data. This is not a geochemical project; it is a water quality evaluation and protection project which should be the focus of data manipulation and evaluation.

This discussion in section 8.0 is highly deficient in that it does not address the overall purpose of the monitoring program, namely water quality evaluation. A section should be added to this monitoring plan describing how UCD/DOE are going to evaluate the data with respect to water quality impacts. These are the issues that should be addressed. Apparently, the reason that it is not included is that no one in the group involved in the development of this Plan, as well as the implementation of the Plan, have demonstrated sufficient understanding of water quality to be able to carry out this type of review. There is need to get someone involved who can do this on behalf of UCD/DOE.

COMMENTS ON APPENDICES

Appendix A of this report presents a Quality Assurance Project Plan. Page 3.8 of Appendix A under section 3.3 Data Uses lists a number of potential uses for these data. The last three bulleted items are "Defend data in a court of law; Perform a risk assessment; and Evaluate remedial alternatives." As someone who has spent over 36 years of his professional career working with data of this type and who has made frequent presentations in legal and administrative proceedings, the author can unequivocally state that the data reports presented by UCD/DOE would be judged to be extremely limited in their value in a court of law. There are far too many problems with these data reports to be accepted as a credible presentation of water quality issues pertinent to the LEHR site in an adversary system. It would be a trivial exercise to demonstrate in a court of law that those who have generated and reviewed the Water Monitoring Plan as well as the individual data reports have not adequately and reliably collected and presented pertinent data to evaluate the impact of the LEHR site wastes on public health and the environment.

In Appendix C, Standard Operating Procedures, on page C2-4 is a discussion of measurement of electrical conductivity. At no place in this discussion or elsewhere, to the reviewer's knowledge, is there a presentation on the temperature compensation approach used. This must be specified so that its reliability can be examined. Further, a summary of the key issues pertinent to electrical conductivity measurement, and especially temperature compensation, should be specifically discussed in each data report so that those reviewing the data will have information readily available that they need to critically examine as part of any credible data review.

OVERALL ASSESSMENT

Overall, the Water Monitoring Plan released in January 1994 contains a number of significant deficiencies that should be addressed before any further data are collected from the LEHR site. There are significant problems with the stormwater runoff monitoring in addressing the objectives of the sample collection program. While not discussed in these comments, comments have been provided to DSCSOC and through DSCSOC to the RPMs, UCD and DOE on similar deficiencies in the groundwater monitoring program. At this time, as discussed previously by the author, the reliability of the groundwater monitoring data, particularly with respect to upgradient background characteristics, has not been properly addressed.

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