Additional Comments on UCD Groundwater IRA

Submitted by

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

On July 2, 1997, a conference call was held between the UCD/DOE LEHR national Superfund site RPMs, responsible parties (UCD and DOE) and DSCSOC representatives to discuss the UCD 50% Design Submittal for the Groundwater Interim Removal Action (IRA). Previously, Dr. Lee had submitted comments on this document and the proposed action in which he had pointed out the significant deficiencies in UCD's proposed approach for treatment of the pumped groundwaters before reinjection. Presented below are additional comments that developed as a result of the discussions held during the conference call.

Importance of Recognizing Unregulated Hazardous and Deleterious Chemicals as Constituents of Concern for LEHR Site Groundwater Remediation

In Dr. Lee's previous comments on the 50% design IRA, he pointed out that UCD had again failed to acknowledge that it will have to address as constituents of concern unregulated hazardous and deleterious chemicals that could readily be present in the groundwaters polluted by UCD campus landfills and the LEHR site activities. It will be highly detrimental to UCD and the taxpayers of the state to continue to try to ignore the fact that UCD's mismanagement of wastes at the LEHR site has polluted the soils and groundwaters with a variety of chemicals that can be detrimental to the beneficial uses of these waters. Rather than trying to ignore this issue, evidently hoping it will go away, appropriate leadership on the part of UCD would be to face the issue and work with the RPMs and DSCSOC in developing approaches that would provide a high degree of certainty that a comprehensive investigation of all of the constituents of concern is conducted at the LEHR site and the associated groundwaters. Dr. Lee has previously provided detailed discussions of this issue including how this issue should be addressed.

It is important to note that the California Department of Health Services (DHS), as part of its efforts in accord with the US EPA Safe Drinking Water Act amendments devoted to water supply source water protection, has recognized that wastes of various types contain a variety of unregulated hazardous and deleterious chemicals that are threats to domestic water supplies. DHS has recognized for a number of years that complex mixtures of waste materials, such as domestic wastewaters, landfills, etc., can readily contain hazardous and deleterious materials that would cause a water supply to experience an impaired use of a groundwater system. Such an impaired use would be in violation of the CVRWQCB's Basin Plan requirements. For years, DHS has been addressing this issue through measuring the presence of dissolved organic carbon in the groundwater system that is attributable to waste sources as an indicator of the unregulated chemicals that need to be managed as part of protecting water supplies.

As Drs. Lee and Jones-Lee have published ("Groundwater Pollution by Municipal Landfills: Leachate Composition, Detection and Water Quality Significance," Proc. Sardinia '93 IV International Landfill Symposium, Sardinia, Italy, pp. 1093-1103, October, 1993 - available from their web site,, landfill leachates contain a wide variety of hazardous and deleterious chemicals which are not now regulated. To assume, as UCD is evidently attempting to do, that the only chemicals of concern in regard to impairing the groundwaters impacted by the LEHR site where the hundred or so chemicals that are now regulated out of the over 75,000 chemicals that are in use in the US today are the only chemicals that can impair the use of groundwaters that are derived from LEHR site and UCD mismanagement of its campus wastes is at best naive and strongly contrary to the public's interest. Ultimately, UCD will have to address this issue. If it persists with its current approach of trying to ignore it, it will have to redo much of the work that is now being done in the IRA in order to properly consider this issue. This will be more wasted public funds associated with inappropriate approaches adopted by the UCD administration in adequately and reliably investigating the pollution of groundwaters by the LEHR site derived constituents and UCD's campus landfills. It is far more cost effective to conduct these investigations of the various constituents of concern at one time rather than on a piecemeal basis as is now being done.

Diversion to Sewer

There was confusion about the reliability of the drawings provided in various UCD documents with regard to diversion of the pumped and treated groundwaters and descaling operations of the air stripper to the UCD campus sewerage system. The drawings need to be corrected to show the proper location where diversions could take place .

Another problem that came to light during the conference call was potential problems of diverting the air stripped groundwater to the sewer during startup and associated with problems in operations. It appears from the comments received that inadequate attention has been given to the ability of the sewerage system to handle the flows that could be received from the IRA activities. The staging of these activities may have to be done at times of low sewage flow from the LEHR site to avoid overloading the sewerage system. This issue needs to be more carefully evaluated than has apparently occurred thus far.

While the comment was made by UCD representatives during the conference call that UCD Campus sewage treatment plant personnel had indicated that the diversion of untreated, polluted groundwaters pumped as part of the IRA to the campus sewerage system would not cause any problems with respect to its NPDES permit compliance, great caution must be exercised in accepting UCD personnel's comments on such issues as being appropriately developed and reliable. UCD has had and continues to have significant problems with inadequately treating its wastewaters before discharged to Putah Creek. One of the areas of concern is chloroform and other VOCs in the wastewater treatment plant effluent that apparently have polluted groundwaters along Putah Creek associated with groundwater recharge that naturally occurs downstream of the campus sewage treatment plant discharge. Adding additional chloroform to the campus wastewater treatment plant could aggravate an already inadequately managed effluent and lead to further groundwater pollution by VOCs derived from UCD's campus wastewaters that are discharged to Putah Creek.

A formal request has been filed with the Central Valley Regional Water Quality Control Board (CVRWQCB) to force UCD to investigate this matter as part of issuance of a revised NPDES permit for its campus wastewater discharges to Putah Creek. If the Regional Board fails to act on the public's request, then action will be taken to the State Board on this matter. UCD will not be allowed to continue to pollute Putah Creek with VOCs arising from inadequate campus wastewater treatment that leads to groundwater pollution in violation of the CVRWQCB's Basin Plan requirements.

There could also be problems with other constituents associated with the IRA pumped and VOC stripped groundwaters when discharged to the UCD campus sewerage system. Of particular concern is chromium. UCD has failed to properly monitor chromium in its campus wastewater discharges to Putah Creek in order to prevent violation of the Basin Plan objectives and its current NPDES permit limitations of not discharging toxic constituents in toxic amounts. It is now well documented that chromium VI at 0.5 g/L is toxic to several forms of zooplankton. UCD has been using analytical methods for chromium for its discharges that can only detect concentrations above 10 g/L. Since the IRA pumped groundwaters are being inadequately treated before reinjection to remove both regulated and unregulated constituents, including chromium, the discharge of IRA water to the sewer system could aggravate the pollution of Putah Creek by UCD's inadequately treated wastewaters. All discharges of IRA associated waters to the sewerage system must be carefully documented and monitored for flow and chemical characteristics using appropriate analytical methods to ensure that UCD's discharge of IRA associated wastes to the sewerage system does not cause further pollution of Putah Creek.

Scaling Problems

From the comments made during the conference call, Dr. Lee is not convinced that adequate attention has been given to the potential for scaling problems to occur in the reinjected groundwaters. It is inappropriate to rely on an assessment of potential problem of scaling by the air stripper manufacturer within the air stripper to estimate the potential problems associated with the precipitation of calcium carbonate within the stripper and downstream of the stripper within the plumbing and within the aquifer at the point of reinjection.

Over the past three years, Dr. Lee has been a member of an American Society of Civil Engineers (ASCE) committee that is developing guidelines for artificial recharge of groundwaters. This committee has completed a manual that is currently being printed by ASCE devoted to discussion of the issues that should be considered in recharging surface waters, including wastewaters of various types, into groundwaters. Dr. Lee's responsibility associated with the committee's activities was devoted primarily to water quality and aquatic chemistry issues. Based on his many years of experience in serving as a consultant and in teaching graduate environmental engineering courses in industrial water conditioning, he finds that there could readily be significant problems with post-precipitation of calcium carbonate beyond the air stripper within the plumbing system and/or within the aquifer. Someone who understands aquatic chemistry and these issues should critically review the potential for this problem to occur, and if it appears to be potentially significant, recommend approaches to control it before large scale problems occur that will be expensive to correct. The seat of the pants approach that UCD is now following of running the system until a problem develops could lead to large scale problems which could cause the IRA to be found to have been inadequately designed.

Operation and Maintenance

Another area that was brought up during the conference call that has not been adequately addressed in the development of the IRA is how the operations of the IRA will be conducted with respect to detecting potentially significant problems. Of particular concern is the frequency of visual inspection by knowledgeable personnel to see that the system is functioning properly and that there are no major changes in the characteristics of the influent waters to the air stripper. As discussed in previous correspondence, there has been inadequate characterization of the chemical characteristics of the aquifer to be certain that new, yet undetected, plumes of hazardous and deleterious chemicals are not pumped from the aquifer at some time in the future during the IRA that could significantly impact the treatment and reinjection operations.

While not a subject of the July 2nd conference call, Dr. Lee has reviewed the draft work plan provided by UCD associated with the IRA and finds it to be significantly deficient in both monitoring of the pumped and reinjected waters and the aquifer that will be impacted by the IRA. A significantly expanded monitoring program will have to be developed and implemented by UCD before the IRA can be allowed to proceed. In order to save everyone's time, UCD should reconsider its proposed IRA monitoring program and develop a more appropriate program than it has proposed as part of the work plan.

The situation with respect to this monitoring program is of concern in that this is another example of where UCD proposes an approach which is obviously deficient and, thereby, relies on the RPMs and DSCSOC to correct the deficiencies. Such an approach is not compatible with UCD's proposed tight time frame for implementation of the IRA. UCD must stop its proposal of inadequate monitoring, etc. and develop appropriate monitoring and other programs for review by the RPMs, DSCSOC, etc. if it hopes to meet its proposed IRA implementation schedule. Every time UCD proposes what is obviously a deficient program, such as it has with the IRA work plan, there will need to be additional review time allocated for re-review of documents and approaches.

Questions or comments on these comments should be directed to Dr. G. Fred Lee.

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