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

diagram of LEHR site area

schematic cross section hydrostratigraphic units of LEHR site

LEHR Superfund Site Issues


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)

concentration contour pllume of chlorofrom in HSU

winter particle tracking - LEHR site

Interim Removal Action (IRA) For Groundwater Pollution by
UCD's Mismanagement of Campus Landfilled Wastes

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

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

paper: development of a stormwater runoff water quality evaluation and management program for hazardous chemical sites

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

Lee & Jones-Lee, Does Meeting Clean-up Standards Mean Protection of Public Health & the Environment?

Lee & Jones-Lee, Superfund Site Remediation...

Lee & Jones-Lee, Hazardous Chemical Site Remedition Through Capping...

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


DSCSOC main web page




Return to Document List

View Related Document List

Return to DSCSOC Home Page