G. Fred Lee & Associates
________________________________________
27298 E. El Macero Dr.
El Macero, California 95618-1005
Tel. (916) 753-9630 · Fax (916) 753-9956
e-mail [email protected]
web site: http://members.aol.com/gfredlee/gfl.htm

 Via e-mail

October 16, 1997

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

Dear Julie:

Please find attached my comments on the DOE's "Final Work Plan for Western Dog Pens, Background, and Off-Site Investigations." In general, I am supportive of the Work Plan under the conditions where it is understood that this Plan represents the first step in what could readily become multiple steps to properly define the degree of contamination that exists within the western dog pens and for off-site background characterization.

I have noted a number of significant technical deficiencies in proposed approaches such as apparently ignoring the potential influence of the water that was added to the dog pens through above-ground sprays which would influence to different degrees at various locations the transport of constituents from the dog pen surface in the soil column.

I have also noted that there is no proposal to include the analysis of a number of parameters such as organic nitrogen and ammonia which are precursors to nitrate which is a potentially significant pollutant of groundwaters in the region.

The background sampling should include the complete suite of parameters, not just metals and radionuclides.

Also, some gradient analysis sampling should be done near various waste management units to see how the background varies near the waste management unit as a function of distance from the unit. This is a more reliable approach to establishing local background than the approach proposed by DOE for this type of setting.

If you or others have questions on these comments. Please contact me. Please pass them on to the RPMs and the PRPs, indicating that if they have questions or wish further information on any aspect of these comments, they should contact me.

Sincerely yours,
Fred
G. Fred Lee, PhD, DEE

GFL:oh
Enclosure

Comments on
"Final Work Plan for Western Dog Pens,
Background, and Off-site Investigations"
Prepared by Weiss Associates for the US Dept. of Energy
Dated October 3, 1997

Submitted by

G. Fred Lee, PhD, DEE
DSCSOC Technical Advisor

G. Fred Lee & Associates
El Macero, CA 95618
PH: (916) 753-9630
FX: (916) 753-9956
e-mail: [email protected]
http://members.aol.com/gfredlee/gfl.htm

October 17, 1997

Page 1-1 of the Introduction, first paragraph, states that one of the objectives is to refine background radionuclide and metals levels. There are other constituents of concern for which there is need to refine background values. This Work Plan is deficient since it only deals with radionuclides and metals.

On page 1-2, second paragraph, it states, "Annual usage of chlordane is estimated between 25 and 50 gallons..." That statement has little meaning unless the percent composition of the liquids which contain the chlordane is provided.

Page 1-2, Section 1.1.2 "Existing Data," second paragraph, states that nitrate was among the constituents analyzed. No mention is made of ammonia or organic nitrogen, both of which would have been excreted by the dogs and are the precursors to nitrate. It is essential that the organic nitrogen and any residual ammonia present in the soils associated with the dog pens be determined since this represents a reservoir for nitrate which can lead to groundwater pollution.

On page 2-1, Section 2.1 "Western Dog Pens Investigation," it states as one of the options, "Because of high disposal costs, complete removal may not be a reasonable option." DOE should have been more closely supervising UCD's management of the wastes at the LEHR site while the site was active. It is inappropriate to now claim high costs as a reason for not cleaning up the site to background when it was DOE's lack of adequate supervision that led to the problems of the site. These costs are part of the true costs of UCD's research. At the time the dog pens were active, it was obvious that the approaches being followed for management of dog pen-associated wastes would lead to environmental pollution that would ultimately have to be cleaned up. The hazards of radionuclides, high nitrogen-containing wastes and organochlorine pesticides have been known since the late 1950s - early 1960s. These hazards were ignored by UCD administrations and project managers, the Regional Water Quality Control Board, the Department of Health Services, Yolo County Department of Health, Solano County Department of Health and others that had responsibility for control and regulation of LEHR site activities. Since UCD plans to continue to use the LEHR site, future users of the LEHR site are entitled to clean up to background to ensure that the residual wastes do not represent a significant threat to these users as well as to off-site property owners.

The discussion on pages 2-2 to 2-3 outlining the overall approach seems to ignore what could be an important issue in the vertical migration of dog pen-associated wastes. This is the water that was sprayed over the area to keep the dogs cool. As part of planning the studies, consideration should be given to the fact that certain areas of the dog pens would receive much higher hydraulic loading than others. These areas would be expected to have greater vertical transport of constituents than those that receive lesser amounts of moisture. This issue should be thoroughly investigated and attempts made to ascertain where the greatest moisture inputs to the dog pens occurred. Unfortunately, DOE, in its attempts to demonstrate removal activities at the LEHR site, took down the dog pens and the watering system as part of a cosmetic effort where now it may not be possible to reconstruct the distribution of moisture from the overhead spray systems that were used in the dog pens.

Page 2-4, Item 1, the issue of cost/benefits analysis comparing costs of additional sampling to the costs of limited soil removal will be carefully scrutinized to fully consider the true costs of the inappropriate waste disposal that was practiced by UCD and allowed (ignored - looked the other way) by DOE and the regulatory agencies as part of the LEHR site operations. Proper sampling to define hazards must now be done to address the significant deficiencies in waste management practices that occurred at the LEHR site to ensure that future generations of LEHR site and off-site property users do not continue to be exposed to hazardous conditions.

Page 2-4, Item 4, mention is made of possibly not doing Phase C sampling. It is highly unlikely that that situation will be allowed.

Page 2-5, first full paragraph, discusses some aspects of the depth sampling. It is quite possible that the approach proposed will not be reliable in areas where there was high hydraulic loading due to the spraying of the dog pens. The surface layers could be depleted based on the flushing where high concentrations of pollutants could be found at some depth below the surface.

One of the significant problems with the previous studies is that the depth intervals used in previous sampling were not adequate to detect relatively thin layers of constituents which will likely occur in this climate. The dry season periods tend to cause upward migration of moisture from considerable depths which brings with it in a chromatographic concentration effect which concentrates constituents in relatively narrow bands. This situation is well known for nitrate and other mobile constituents in climates of this type. Thus far, there has been no indication that those doing the work on behalf of DOE and UCD recognize this situation and have appropriately sampled for it.

Page 2-6, Section 2.2. "Background Investigation," the background investigation must be expanded beyond metals and radionuclides.

Page 2-7, replicate sampling within a few feet of each other should be conducted to determine how well samples taken at such proximity duplicate each other. If there is high variability at any given depth, then the possibility of reliably defining the difference between background and a contaminated area will be significantly impaired.

One of the issues that will ultimately have to be addressed is gradient analysis from waste disposal areas in order to determine localized background. The general background of the region using the approach proposed by DOE may not reliably determine the background in the vicinity of the waste disposal site. As discussed previously at RPM meetings, and in correspondence provided to the RPMs and PRPs, gradient analysis will ultimately need to be done near waste disposal areas in order to determine the true background in the vicinity of a waste disposal site. Samples should be taken at various depths from various waste disposal areas to see how the concentrations of constituents of concern vary with distance from the disposal area. This is a far more reliable approach to establishing background at the disposal area than the approach that is being proposed by DOE, especially in areas, such as the LEHR site, where the background is highly variable due to natural as well as activities of man.

It should be understood that the proposed program for establishing background represents the initial phase of what could be a number of phases of additional background sampling.

I am concerned about the relatively large intervals between sampling as a function of depth that are proposed by DOE. Such sampling could readily miss bands of materials that have concentrated at specific depths. Much closer sampling intervals should be practiced on a number of locations to ensure that both background and waste areas are properly characterized.

Page 2-8, Section 2.2.4 "Statistical Analysis,"states that the background levels will be defined as 80% of the lower confidence level on the 95th quantile. This issue needs further discussion as to whether it is appropriate for the situations that are encountered at the LEHR site.

The bottom of page 2-8 mentions that sample collection will be focusing on soils. It would be appropriate to collect some vegetation sampling, as well.

There is still a tremendous gap in LEHR site investigations due to the fact that DOE and UCD have continued to ignore the translocation of materials from soils through plant systems to the surface. This sampling will ultimately have to be done before the site can be declared adequately investigated.

I am assuming that the RPMs will critically review Section 7 "Investigation-Derived Waste Management" and Section 8 "Health and Safety Considerations" to ensure that these are adequate to protect the workers and future users of the site. I also assume that they will examine the other boiler plate, included as appendices to this report for its adequacy.