Comments on
the University of California, Davis LEHR Newsletter
dated May 1997

Submitted by
G. Fred Lee, PhD, DEE
G. Fred Lee & Associates
El Macero, CA

July 1997

A review of the University of California, Davis LEHR national Superfund site Newsletter issued by the University of California, Davis in May 1997 shows that the UCD L. Vanderhoef administration is continuing to provide inadequate, unreliable information on the potential threat that the LEHR site represents to public health, the environment and the interests of the people in the vicinity of the site, as well as the progress being made towards eliminating this threat.

In column one, second paragraph, a discussion is presented of the Groundwater Interim Removal Action (IRA). This discussion fails to address the issues raised by the RPMs on the inadequacy of the UCD IRA. While the statement is made, "This action will effectively remove chloroform, the primary constituent of concern, from the treated water and limit its spread within the aquifer." there is no discussion of the fact that this action will not address the wide variety of other constituents in the polluted groundwaters and will spread pollution by these other constituents to waters that are not now polluted by them.

DSCSOC and the RPMs found that UCD's proposal for the IRA was significantly deficient with respect to adequately monitoring the additional pollution that would occur and will require additional monitoring to determine the degree of pollution caused by the inadequate treatment of the groundwaters pumped from the polluted zone before re-injection into the aquifer.

With respect to the next paragraph regarding the CEQA Initial Study for the project, the negative declaration does not adequately and reliably discuss the potential problems with the IRA approach and the eventual need for the University of California, Davis to clean up the off-site groundwater pollution that is caused by the spread of this pollution through the proposed IRA action. The IRA as proposed, while significantly deficient compared to what UCD should be undertaking at this time with respect to evaluating the potential of various approaches for clean-up and treatment of the polluted groundwaters, is being allowed to proceed as an experimental information gathering activity that could be useful to design more appropriate groundwater remediation approaches. However, the additional pollution caused by this IRA will ultimately have to be cleaned up.

While UCD has asserted that it is not cost-effective to remove all of the pollutants that it introduced into the groundwater through its mismanagement of the campus wastes at the LEHR site, such assertions are highly inappropriate. The previous and current UCD administrations have been conducting research and campus activities at less than what was obvious real cost through management of the wastes associated with the campus by procedures that were and continue to be known to lead to groundwater pollution. For the current UCD administration to try to claim a lack of cost-effectiveness in failing to properly clean up the polluted groundwaters represents a highly convoluted approach in which UCD expects its neighbors to accept the burden of inadequate waste management so it can continue to practice cheaper-than-real-cost research and campus waste management activities. The neighbors of UCD should be entitled to use the groundwaters associated with their property without any pollution by UCD's mismanaged wastes. This will mean that UCD will have to pay the full true cost of cleaning up the groundwaters associated with inappropriate waste management activities.

On page one, column two, with respect to surface water monitoring, no mention is made that the surface water monitoring program conducted by the University of California, Davis has been found to be significantly deficient compared to that needed for adequately assessing the water quality impacts of stormwater runoff from the LEHR site on the beneficial uses of Putah Creek water quality.

With respect to page one, column two, "DOE Streamlines Approach to Cleanup," all of the bulleted items are premature with respect to adequately and reliably addressing issues of concern to the regulatory agencies as well as the public. Thus far, UCD and DOE have failed to provide adequate site investigation, much less characterization for determination of proposed clean-up methods.

Page two, column one, the first item discusses data gaps. It is important to understand that the initial data sets that are discussed herein are considered preliminary and inadequate to characterize the pollution of soils and the potential significance of remaining waste constituents in the various waste management units at the LEHR site.

With respect to page two, column one, first paragraph, where the statement is made, "Mercury and lead concentrations in water and sediment were not found at level of health concern." that statement is inappropriate with respect to sediments. There are no concentration levels for which one can judge excessive concentration in sediments. The sediments could readily be the source of the constituents which are leading to excessive bioaccumulation within aquatic life in the vicinity of the University of California, Davis wastewater discharges and stormwater runoff near Old Davis Road.

With respect to the statement that ATSDR determined that a variety of constituents listed were not present at levels of concern in fish waters or sediments, it should be understood that ATSDR did not use adequate analytical detection limits for a number of key constituents such as PCBs, and therefore it cannot be certain that these are not present at excessive levels in fish and water in the region of UCD's wastewater discharges and stormwater runoff.

Page two, column two, first full paragraph, the UCD L. Vanderhoef administration is trying to confuse the public with respect to the statement, "Mercury is a contaminant found in fish in many water bodies in the region, including Lake Berryessa, Clear Lake and Cache Creek, so it is not clear if these results may be consistent with regional trends." This is more of the distorted information that the L. Vanderhoef administration presents in an attempt to provide a smokescreen on issues. If they had properly discussed these issues, they would have discussed the fact that the ATSDR studies showed that sampling upstream and downstream of the point where UCD's campus wastewater treatment plant effluent and some of the stormwater runoff enters Putah Creek did not show excessive concentrations of mercury or lead in fish. It is just at the point where the campus wastewaters are discharged that excessive mercury and lead were found in fish. This situation has no relevance to what is found in Cache Creek, Lake Berryessa or Clear Lake. Those are different situations.

The Newsletter states on page two, column two, second full paragraph,

"This sampling was only intended as an initial screening and there is not enough data to evaluate the actual health threat or the possible sources of these results. Because of the sampling method, fish of various sizes and species were mixed together to obtain a sample, resulting in a sample data that does not reflect the variation of different species, sizes or age of fish."

What should have been stated in connection with this statement is that the initial results which show a potential health threat are likely low with respect to estimating the actual magnitude of this health threat to those who consume fish caught in the vicinity of UCD's campus wastewater discharges to Putah Creek. Because of the sampling methods used, the actual health threat will likely be higher since the fish that are normally used for food, i.e. the older, larger, higher trophic level fish tend to bioaccumulate mercury, lead and other constituents to a greater degree than the smaller, younger fish that were sampled in the initial screening study.

Page two, column two, "Background," is a discussion of the fact that research was conducted on long-term effects from low-level radiation. What is not said is that this research was conducted at less than real cost with respect to waste management. Waste management practices which were adopted as part of this research by the University of California, Davis were clearly known by professionals in the field at the time to lead to groundwater pollution. This situation was ignored by the University of California, Davis administration as part of attempting to conduct research. The inadequate implementation of these research projects is now costing the taxpayers of California and the US many tens of millions of dollars because of inadequate consideration of the potential impacts of waste management practices on public health, groundwater resources and the environment.

For further information on the public's perspective on the adequacy and reliability of the University of California, Davis Department of Energy LEHR site investigation and remediation, please contact Julie Roth, Executive Director, Davis South Campus Superfund Oversight Committee, at 916-753-9946. Further information on these and related issues is available at the DSCSOC web site (http://members.aol.com/dscsoc/dscsoc.htm).

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