Overview Of The Adequacy Of
The LEHR Superfund Site Investigation and Remediation:
The Public's Perspective
G. Fred Lee, PhD, MSPH, DEE
Technical Advisor, DSCSOC
October 1997
Status Of The LEHR Superfund Site Investigation And Remediation
Areas Of Concern
LEHR Superfund Site Issues Background Landfills Nos. 1, 2 And 3 Polluting Groundwaters By Campus Wastes Known At Time Of Waste Disposal Or Should Have Been Known Based On Literature That The Campus Landfills Would Pollute Groundwater-Cheaper-Than-Real-Cost Campus Solid Waste Management UCD Dumped Campus Waste Chloroform In LEHR Landfill UCD Campus Waste Chloroform Groundwater Pollution Plume Extends Well Beyond UCD/Neighbors' Property Line in HSU-2 Neighbor Had to Abandon Agricultural Well UCD (Public) Paying For Replacement Well Groundwater Pollution At LEHR Site Known Since 1987 UCD Put Groundwater Pollution Investigation and Clean Up "On Hold" Inadequate Regard For Public Health and Environmental Protection Last Year Reported That UCD Had Not Determined Whether HSU-4 Was Polluted-Predicted To Be Polluted Issue Raised by DSCSOC in Summer 1995 UCD Refused to Acknowledge That HSU-4 Pollution Could Occur As Predicted Two Years Ago, HSU-4 Found To Be Polluted By Chloroform Plume-No Evidence Yet Of Municipal Well Pollution Magnitude Of Pollution Of HSU-4 Unknown Will Require Large-Scale Investigation To Determine Full Extent Of HSU-4 Pollution (continues)
Interim Removal Action (IRA) For Groundwater Pollution by In 1997 UCD Finally Stopped "On Hold" Approach To Correcting the Groundwater Pollution By Mismanaged Campus Wastes Beginning To Start To "Clean Up" Part Of The Site Groundwater Pollution Problems With IRA
UCD's Mismanagement of Campus Landfilled Wastes
Ignores Other Pollutants In Chloroform Plume
VOC (Chloroform) Stripped Polluted Groundwater Being Re-Injected For Waste Disposal-Cause Pollution In New Areas
Only Part Of The Reinjected Pollution Will Be Recaptured
UCD Should Clean Up The Chloroform Plume Groundwaters For All Constituents That Are A Threat To Public Health And Groundwater Quality
Ultimately Will Have To Address The Removal Of Other Pollutants
Should Conduct Needed Studies Now As Part Of Current IRA-Less Expensive
DSCSOC's Areas Of Concern
Constituents of Concern
UCD and DOE Primarily Considering Priority Pollutants In Defining the Constituents of Concern for LEHR Site Remediation
US EPA CERCLA Does Not Necessarily Require Cleanup of All Pollutants that Impair Beneficial Uses of Water
Focus Is On a Few Of The "Hazardous"/Deleterious Chemicals In Wastes And Contaminated Soils - Groundwaters
State of California Chapter 15 Regulations Requires Cleanup To Background All Chemicals That Impair The Beneficial uses of Water
Abandon A Well Because of Taste and Orders, Increased Hardness, TDS Etc. Because of LEHR Site pollution of Groundwater - Important Loss of Resource
Only About 100 Chemicals of the Thousands of Chemicals in LEHR Site Wastes Regulated - Have Drinking Water Standards - MCL's
There Are Many More Hazardous And Deleterious Chemicals At LEHR Site Than Being Investigated By DOE and UCD
DSCSOC's Position That UCD and DOE Must Protect Groundwaters and Surface Waters From Impaired Uses From All Chemicals Not Just The Few Chemicals Currently Being Investigated
Use Surrogate Chemicals to Estimate Potential Hazard to Public Health, Groundwater Resources And The Environment
Inadequate Groundwater Quality Investigation
Still Do Not Know Extent Of On-Site And Off-Site Groundwater Pollution
Conflicting Results in Extent Of Groundwater Pollution By Chloroform Plume From Landfill No. 2
Little Information On Groundwater Pollution At UCD Landfill No. 3 And In HSU-4
Inadequate Stormwater Runoff Investigation
Should Have Been Controlled Two Years Ago
Represents Violation Of CVRWQCB NPDES Stormwater Permit
Still No Information On This Issue
Concentrations Of Hg And Pb in Fish Taken From Near West Side Of LEHR Stormwater Runoff To Creek Hazardous For Human Consumption
Likely Source Of Pb and Hg Is UCD's Campus Wastewater Treatment Plant Discharge To Putah Creek
Inadequate Monitoring Of Hg And Pb In Stormwater Runoff From LEHR Site
Inadequate Sensitivity Of Analytical Methods
Technically Invalid Data Interpretation
UCD Refuses To Post Putah Creek To Warn People That Eating Fish Taken From Near the Wastewater Treatment Plant Discharge And LEHR Site Stormwater Runoff May Be Hazardous To Health
Could Be Source Of Subsurface Constituents From Stormwater Runoff
DOE Has Refused To Correct The Obvious Errors In Past Years' Data Reports
DOE's Approach Toward Site Remediation
After Years Of Doing Little To Adequately Define And Begin To Remediate LEHR Site Pollution, DOE Now Has Initiated An "Accelerated" Approach For Site Remediation
Significant Problems Are Developing With This Approach
Inadequate Database To Characterize Current Hazards At Site
Thus Far, DOE Has Only Conducted A Limited Investigation Of The Wastes In Various Burial Pits And Trenches And The Associated Contaminated Soils
DOE Warned By RPMs and DSCSOC That Its Proposed Waste Management Investigations Were Not Adequate For Waste Characterization
Now DOE Trying To Use Inadequately Characterize Waste Areas As Basis For Making Decisions On Hazards That Waste In Pits, Trenches And Soils Represents-Not Technically Valid (continues)
Vadose (Unsaturated Part Of Aquifer) Zone Contains Waste Constituents That Are A Threat To Groundwater Quality
Must Understand The Transport Of Waste In Vadose Zone To Water Table To Determine Whether There Is Need To Remove Waste Constituents To Prevent Groundwater Pollution
DOE's Vadose Zone Modeling Not Technically Valid
Assumed Inappropriate Transport Conditions
Cannot Reliably Predict Transport Of Pollutants From Waste Areas To Groundwater Based On DOE Vadose Zone Modeling
Need Field Verification Of Model
DOE's Hazardous Chemical Risk Characterization Technically Weak
Inadequate Database Upon Which To Properly Develop Reliable Estimate of Health and Environmental Risk
UCD And DOE Have Still Not Defined Site Clean-Up Objectives
Imply Site Should Only Be Cleaned Up To CERCLA Standards
Previously DOE Stated Would Clean Up To Meet Local Standards
Local Standards Are Clean Up To Background
Both UCD And DOE Claiming Economic Hardship-Lack Of Cost-Effectiveness In Clean Up To Background To Fully Protect Future LEHR Site Users And Neighbors From The Threats Of Residual Wastes Left At The Site
Validity of Economic Hardship in Establishing
LEHR Site Clean-Up Objectives
DOE And UCD Should Have Properly Managed The Campus And LEHR Site Research Wastes Rather Than Trying To Conduct The Research And Campus Waste Management Activities At What Was Obviously At The Time, A Cost Less Than The True Long-Term Cost Of Waste Management
Now Many Tens Of Millions Of Dollars Of Public Funds Will Have To Be Spent Cleaning Up The LEHR Site And The Campus Landfills Because Of The Short-Sighted Approaches Used By Previous UCD Administrations In Managing Campus Wastes
This Problem Is Continuing Today Under The L. Vanderhoef Administration, i.e.
Proposed Fifth Campus Landfill
Approach For Developing New Campus Wastewater Treatment Plant
Approach For LEHR Site Groundwater Pollution Investigation And Remediation
Future Users Of The LEHR Site And The Neighbors Of UCD Should Be Entitled To High Quality, Adequately Documented Through Monitoring, Protection of Public Health And The Environment From Any Residual Waste Left At The LEHR Site
Conventional Superfund Site Clean Up Under CERCLA Does Not Provide This Level Of Protection
UCD Should Finally Begin To Become A Good Neighbor To Those Who Own Or Use properties Near The Campus - Stop Propaganda
DOE Remediation Approach Continue To Practice Cheaper-Than-Real-Cost Campus Waste Management And LEHR Research Waste Management Leave Some Wastes At Site- In A LEHR Site Landfill In Place With Cover Over Waste Reduce Infiltration Isolate Wastes From Surface Contact While Used At Other Superfund Sites, Not Reliable for Protection Of Public Health, Groundwater Quality And Environment For As Long As Wastes Are A Threat Will Only Keep Moisture Out Of Landfill For Short Period Of Time UCD "West" Landfill UCD "West" Landfill Should Be Part Of LEHR Superfund Site Investigation And Remediation Substantial Evidence For Deposition Of Radioactive Wastes And Hazardous Chemical Wastes From LEHR In "West" Landfill Inadequate Investigation Of "West" Landfill For Existing Pollution And Potential For Future Pollution During Past Year As The Result Of DSCSOC Activities, CVRWQCB Has Required That UCD Conduct Additional Investigations Of Groundwater Pollution At The "West" Landfill Still Unknown Fate Of LEHR Site Radioactive Waste Sludges-Deposited on Local Farms? Needs To Be Investigated
UCD Campus Wastewater Treatment Plant Important To LEHR Site Issues Since The Campus Wastewater Treatment Plant Discharges To Putah Creek At The Same Location As LEHR Site Stormwater Runoff At Times Creek Waters 100% "Treated" Sewage Plant Discharge While UCD Administration Claims UCD Is An "Environmental University" In Managing Campus Wastes-Recalcitrant Polluter Does Least Possible Just To Meet CVRWQCB Staff's Interpretation Of Regulations Long History Of This Approach e.g. LEHR Site Waste Management In Campus Landfills All Pollute Groundwater Inadequate Wastewater Treatment Prior To Discharge To Putah Creek CVRWQCB Staff Admitted Looks The Other Way In Enforcing Regulations At UCD UCD Threatened to Sue State If Regulations Fully Enforced Using Approaches Required By US EPA Problems With Inadequate Wastewater Treatment Violation Of Current CVRWQCB Discharge Permit Public Had Enough-Through Governor's Office Forced CVRWQCB To At Least Partially Enforce Toxicity Control Regulations Assistance of US EPA Region 9 Comments On CVRWQCB Proposed Revised Wastewater Discharge Permit Burden Of Proof Of Harm Is Still On The Public And The Environment Rather Than The Discharger Cheaper For UCD To Discharge Campus Wastewaters To The City Of Davis Sewerage System Develop Regional Treatment Works Campus Expanding-Need Extraordinary Treatment To Protect Putah Creek Water Quality Likely Have To Appeal The CVRWQCB Wastewater Treatment Discharge Order To The State Water Resources Control Board To Gain Full Compliance With Regulations
Imminent Offsite Public Health Hazard Has The Inadequate, In Some Instances Unreliable, Excessively Slow LEHR Site Investigation Resulted in Significant Damage To Public Health Due To Directly Caused Illness, i.e. Have Offsite People Become Ill Due To LEHR Site Wastes? No Evidence for Such Direct Illness There Has Been Significant Emotional Stress Due To Threat Of Chemicals And Loss Of Property Value UCD Is Not A Good Neighbor Public Health Threat Due To Pollution Of Groundwater By UCD And DOE Wastes At LEHR Site Still Unknown LEHR Site Wastes Likely Have Damaged Aquatic Life In Putah Creek May Still Be Causing Harm To Aquatic Life
Conclusions
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