July 4, 1997

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

Dear Julie:

Presented below are my comments on the US DOE "Final Work Plan for Data Gaps Investigation" for the LEHR site dated June 1997

Overall Comments

As discussed herein, this study plan is a necessary first step for beginning to investigate the magnitude and extent of pollution by the LEHR site septic tanks. It should be understood that this study program will almost certainly require follow-on studies which would be based on what is found in these studies. Specific comments on problems or areas of concern with respect to the study plan are presented below.

Specific Comments

There is concern about the title of this document. This is not the final work plan for data gaps investigation for the LEHR site as indicated in the title, but only deals with a work plan to investigate the initial phase of pollution by septic tank systems. The LEHR site DOE and DOE waste management units and contaminated soils are far from being adequately investigated to even define the data gaps that exist, much less issue a final work plan for data gaps investigation unless DOE is prepared to excavate and take off-site all waste management units and contaminated soils to background.

The statement on the bottom of page 1-1, last paragraph, "Although domestic sewage is not usually considered hazardous, the LEHR septic tank systems may have received influent from laboratory sinks and floor drains." Those familiar with this topic area know that domestic wastewater septic tank disposal systems often contain a variety of hazardous and deleterious chemicals that can impair the beneficial uses of groundwaters and soils. Further, the Central Valley Regional Water Quality Control Board's Basin Plan objectives are not restricted to just what are somewhat arbitrarily classified as "hazardous" wastes. They include all materials that are deleterious to the beneficial uses of groundwaters.

Page 1-2, first paragraph, the statement is made,

"Because sandy gravel is not characteristic of typical septic tank contents, it appeared that the original tank contents had been removed, and the tank backfilled with clean, sandy gravel. Therefore, no sediment samples were collected from Septic Tank 1 during the LFI."

While there has been some removal of tank contents, there still could have been and certainly likely was some sludge in the bottom of the tank. It is highly doubtful that the tank was scrubbed clean so there were no residues; therefore, a significant error was made by not sampling the sludge at the bottom of the tank.

Page 2-3, under section 2.1.2.2, first paragraph, the same mistake that was made earlier of failing to sample the sediments just above the base of the septic tank should not be made in this investigation. Just because it is filled with sandy gravel does not mean that there is not some sludge left in the tank at the time of filling. This material should be sampled and analyzed.

Page 2-5, first paragraph, mentions that Septic Tank 5 is known to be underneath the main office building so no attempt will be made to locate it. It will likely become necessary to do some horizontal drilling to see what pollution has occurred from this septic tank.

Page 2-5, under 2.2.2.5 Septic Tank 6, the same issues with respect to sampling of the contents of the tank apply here as discussed previously.

Pages 4-4 and 4-5 list the parameters that are proposed be analyzed. Ammonia and organic nitrogen should be added to this list since they can both convert to nitrate. These are likely constituents in septic tank wastewaters.

I do not understand why the various heavy metals are not being analyzed in the radium leak systems. There could readily be heavy metals in these systems that are of potential concern.

Total organic carbon should be added to the parameters analyzed since it will be important in predicting the transport of some other constituents.

It appears from the parameters listed that there is going to be no attempt to analyze for the suite of Priority Pollutant organics. These analyses should be conducted. One or more of these constituents could readily be present in the septic tank waste disposal system leachfields.

The total dissolved solids - specific conductance under a standard leach test of the soil should be analyzed.

Page 6-2, Section 6.2 Identification of Decisions, second paragraph, the data that have been collected thus far in the EE/CA is far from adequate to develop remediation clean-up objectives, evaluate threats to groundwater, etc. The work done thus far is largely exploratory and far more comprehensive studies will have to be done to justify leaving wastes in waste management units or associated contaminated soils at the site.

Page 6-4, Section 6.8 Sampling Process Design, states,

"The rationale for sample collection at each of the subject work areas is to provide the minimum environmental data necessary to assess the following:

Whether the domestic septic and radium treatment systems have contributed to subsurface contamination at LEHR;"

That is not an issue. There is no question that there has been subsurface contamination by the septic tank systems. The magnitude, degree and significance of this remain to be determined. This study will not provide the data necessary for that purpose. It will provide data necessary to begin to plan more comprehensive studies. This program will also not provide the information necessary to assess the vertical migration contaminants in the vadose zone. The sampling proposed is far from adequate to address that issue. A more in-depth, comprehensive vertical sampling is necessary to make such an assessment. Basically, this, like the previous sampling of this type, is the first phase of what will have to be a much more comprehensive sampling program. This sampling program is a good start on the more comprehensive program, and it is necessary to begin to develop that program.

Please contact me if you have questions about these comments. Please submit these comments to the RPMs for their review and comment.

Sincerely yours,

Fred

G. Fred Lee, PhD, DEE

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