Comments on
University of California, Davis
Dames & Moore
"50% Design Submittal for Groundwater Interim Removal Action,
LEHR Environmental Restoration, Davis, California"
Dated May 23, 1997

Davis South Campus Superfund Oversight Committee
Rt.2 Box 2879
Davis, CA 95616
Phone 916 753-9446
fax 916 753-8220
email [email protected]

January 25, 1997

Remedial Project Managers
DOE/UCD LEHR Superfund Site
University of California, Davis
Davis, California 95616

Dear RPMs,

Dr. G. Fred Lee has provided DSCSOC with his comments regarding UCD's public announcement of their "Groundwater Interim Remedial Action" and I am enclosing his report for your review.

Dr. Lee's comments raise many issues of concern to the public about UCD's IRA for the groundwater remediation at LEHR. DSCSOC, as representatives of the public, will not accept this approach as appropriate for the remediation of the polluted groundwaters at the LEHR site. This IRA can only be considered the first, experimental action taken in addressing only a limited portion of UCD's responsibilities for the remediation of the groundwater at LEHR. Addressing the chloroform plume is only a part of the ultimate groundwater remediation that will need to be undertaken by UCD in order to protect the current and future offsite groundwater resources. UCD should not be allowed to pollute groundwaters with a variety of waste-derived constituents that impair the use of the groundwater for domestic and other purposes. UCD must also adequately evaluate the degree of additional pollution arising from implementation of the IRA that will occur.

The investigation of HSU-4 must be addressed and a plan put in place to address the off-site pollution by chloroform and other constituents that are now under adjacent properties as a result of LEHR wastes. The proposed IRA is not the comprehensive approach for the remediation that is necessary to address the pollution of the off-site groundwater by LEHR site wastes, and UCD must submit plans to begin to address these issues.

Any actions by UCD must conform to the Central Valley Regional Water Quality Control Board's Basin Plan and provide protection from the unregulated, potentially hazardous and deleterious chemicals that are present in the groundwater arising from UCD's mismanagement of the wastes at LEHR.

UCD's approach must be respective of the regulatory requirements, public health, environmental protection and the responsibility of a waste management entity to manage wastes in a technically valid, cost-effective manner that fully complies with current regulatory requirements.

I request that a discussion of the issues raised in Dr. Lee's comments be included on the agenda for the January 30th RPM meeting.

As always, Dr. Lee invites you and others who have questions or comments regarding his comments to please contact him.

Sincerely,

Julie Roth, Ex. Dir.

cc: DSCSOC Ex. Board
William H. Taylor
Jane Riggan
Brian Shaffer

Comments on
University of California, Davis
Dames & Moore
"50% Design Submittal for Groundwater Interim Removal Action,
LEHR Environmental Restoration, Davis, California"
Dated May 23, 1997

G. Fred Lee & Associates
27298 E. El Macero Dr.
El Macero, California 95618-1005

July 14, 1997

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

Dear Julie:

I have reviewed the "50% Design Submittal for Groundwater Interim Removal Action" report and find that most of it relates to contractual requirements associated with developing the experimental, initial groundwater remediation program. Most of the materials presented in this document are of limited concern to DSCSOC. I understand from the June 10, 1997 RPM meeting that DTSC and possibly the US EPA will be critically reviewing the design features of this submittal to be sure that the proposed design will achieve the desired objectives in a technically valid, cost-effective manner. Since this is being done by others, I will not conduct an independent review of these issues.

The key issues concerning this initial experimental IRA have been discussed in my previous correspondence, namely that UCD is not using this opportunity to evaluate the removal of many other constituents that will have to be removed in a full-scale groundwater remediation program. UCD should not continue to delude itself into believing that it will only be allowed to remove some VOCs from the groundwaters that have been polluted by the LEHR site. It will have to ultimately clean up these groundwaters so the past waste management at the LEHR site does not impair their use for domestic or other purposes. Further, this clean-up will have to remove constituents from the groundwaters that while in themselves do not cause exceedance of drinking water standards use up assimilative capacity for natural or ag unregulated derived pollutants, such as chromium and nitrate, that could be adverse to off-site down groundwater gradient groundwater users. By conducting such a limited scope investigation, UCD is ultimately going to cost the taxpayers more money than if it had set up a proper, initial investigation of the various issues that will ultimately have to be addressed as part of groundwater remediation at the LEHR site. These will include the use of reverse osmosis and the investigation of removal of waste-derived pollutants that are not air-strippable from the groundwaters. Based on the June 10, 1997 RPM meeting, the UCD report that is supposed to be released on June 20, 1997 may address many of the issues that need to be addressed associated with UCD's exploratory initial phase IRA.

Specific comments on the May 23, 1997 "50% Design Submittal" pertinent to several areas which are of potential interest to DSCSOC are provided below.

Table 1 presents a series of "NDs" for effluent concentrations. I would hope by now that UCD would have stopped presenting materials of this type. "ND" should be presented in terms of an actual anticipated detection limit, rather than simply presenting the materials in a form that is not interpretable. UCD should be required to redo Table 1 with the proper detection limits listed.

Table 1 should also list "unregulated constituents" which are or could be pollutants that are derived from waste management activities at the LEHR site and UCD's landfills with the estimated influent concentrations "unknown" and estimated unregulated constituents in the air-stripped effluent concentrations "unknown." The unregulated hazardous and deleterious chemicals should be listed as a category of constituents of concern since ultimately they will have to be addressed as part of the groundwater remediation in order to conform to CVRWQCB Basin Plan objectives.

UCD - DOE should stop using COD as a parameter to characterize the miscellaneous organics that are present. They should be working with total organic carbon; this is a more reliable estimate of constituents than COD.

Section 01011 SUMMARY OF DESCRIPTION OF WORK, Part 1-General, 1.01 PROJECT DESCRIPTION A. should include a discussion of the presence of unregulated hazardous and deleterious chemicals that have not yet been identified.

I do not understand why Table 1 lists the chloroform influent characteristics at 100 g/L, yet page 11201-5 lists the influent concentration of chloroform at 200 g/L. Further, the same page lists the effluent concentrations at less than 1 g/L for the various constituents. If these are the required performance characteristics, why were they not listed in Table 1?

If you have questions about these, please contact me.

Sincerely yours,

G. Fred Lee, PhD, DEE

GFL:oh

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