Davis South Campus Superfund Oversight Committee
Rt 2 Box 2879
Davis, CA 95616

Friday, June 6, 1997

RPMs
LEHR
University of California, Davis
Davis, CA 95616

Dear RPMs,

Enclosed please find Dr. G. Fred Lee's discussion of stormwater issues that rose out of the July 17th RPM meeting. As I have indicated previously, DOE-UCD need to immediately develop a credible stormwater and surface water program which can be implemented with first storm event of this season.

If you have any questions regarding Dr. Lee's comments, please contact him.

Julie Roth, Ex. Dir.

Enclosure

cc: DSCSOC's Ex. Board
Dr. G. Fred Lee
Dennis Parfitt
William H. Taylor
Brian Shafer

Comments on Stormwater Issues Discussed at the July 17, 1996 UCD-DOE LEHR National Superfund Site RPM Meeting

January 2, 1997

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

Dear Julie:

I wish to follow-up on the July 17, 1996 UCD-DOE LEHR national Superfund site RPM meeting to provide DSCSOC with some comments on the discussions on stormwater issues that took place at this meeting.

Over the past year that I have been involved as a DSCSOC advisor, I have repeatedly pointed out the highly significant deficiencies in the stormwater runoff water quality evaluation approach that has been conducted by UCD and DOE at the LEHR site. I have reported in my previous correspondence on this issue to DSCSOC which has been passed on to the RPMs that this program is ill-conceived, poorly implemented, poorly reported and in many cases is an inadequate and inaccurate assessment of the potential impacts of stormwater runoff from the LEHR site on Putah Creek water quality. Several of the analytical procedures that have been used are not sufficiently sensitive to detect concentrations of constituents at critical concentrations for impacting aquatic life. Parameters that should have been measured have not been measured. The data have been misinterpreted. There has been inadequate and unreliable sampling of stormwater runoff from the LEHR site. Further, the DOE LEHR site management did not as of last summer and evidently, based on the tour of the site last week, still do not understand the movement of stormwater from the LEHR site to Putah Creek.

It is now clear that UCD and DOE management and operating staff do not understand surface water quality issues with respect to determining the concentrations of constituents that could affect the designated beneficial uses of Putah Creek waters by LEHR site stormwater runoff. The reporting of the results in the various data reports in some cases has been inaccurate, inadequate and unreliable. Basically, the taxpayers' funds have been wasted and, thus far, there has not been a reliable assessment of the potential for LEHR site stormwater runoff-derived constituents to have been or currently be adversely impacting the beneficial uses of Putah Creek.

My previous comments submitted through DSCSOC finally led to a review of these issues by the RPMs where UCD and DOE were required to conduct a review and report back to the RPMs. At the July 17, 1996 RPM meeting, S. Attiga presented the results of his review of the chlordane in stormwater runoff situation. In the discussions that ensued from this presentation, it became clear that he, J. Littlejohn and Dames & Moore through their past reports do not understand basic surface water quality issues. They are not familiar with the standards that are used to evaluate excessive concentrations of chemical constituents as they may impact the aquatic life-related designated beneficial uses of Putah Creek. When I mentioned the "Gold Book" as a source of information on appropriate information on the potential critical concentration of chemical constituents to various types of beneficial uses of waterbodies, it became clear that the group was not familiar with this US EPA listing of water quality criteria. Anyone familiar with the elements of surface water quality issues is familiar with the "Gold Book." By admitting that they are not familiar with the "Gold Book," S. Attiga, J. Littlejohn and others are the equivalent of admitting that they are preaching Christianity without being familiar with the Bible, or even knowing that it exists.

At the July 17, 1996 meeting I indicated to Mr. Littlejohn that I would take the time to find out how he and others associated with the LEHR site could obtain a copy of the "Gold Book." It is available through NTIS as publication number PB-87-226-759. Its title is "Quality Criteria for Water 1986." It carries the US EPA number 440/5-86-001. NTIS can be contacted by calling 1-800-553-6847.

I have previously commented that UCD and DOE need to get somebody involved in the LEHR site stormwater runoff evaluation and management program who understands the elements of water quality. This suggestion brought a protest from S. Attiga, J. Littlejohn and others that my assessment of the significant deficiencies in the stormwater runoff water quality program at LEHR was inappropriate. It is now clear that my assessment was 100% correct. There is an urgent need to get individuals involved in the stormwater quality evaluation situation at LEHR who understand the basic elements of water quality. This understanding has been totally lacking in the recent past with the LEHR site and UCD management and contractors. This lack of understanding has wasted large amounts of public funds in inappropriately conducted monitoring programs. At this point, I do not know if the new DOE contractor has staff that will become involved in the LEHR site who have a 1990s level of understanding of aquatic chemistry, aquatic toxicology and water quality as applied to stormwater runoff evaluation and management. If they do not, then there is immediate need for this firm/DOE to acquire this expertise.

At the July 17, 1996 RPM meeting, Hedy Ficklin reported that the US EPA Region IX plans to finally start to collect some samples of aquatic life from Putah Creek to check for bioaccumulation of hazardous chemicals. When I first became aware of the fact that DOE and its contractor, Dames & Moore, were not checking for bioaccumulation of constituents that could be present in Putah Creek aquatic life, I pointed out over a year ago that this is one of the significant deficiencies in the current LEHR site investigation. I discussed this situation with ATSDR staff during our meeting in July 1995. They, too, concurred that this was a significant deficiency in the past and current LEHR site investigations.

Last summer as part of my review of past documents developed for the LEHR site by DOE and its contractor, Dames & Moore, I found that DOE and Dames & Moore did not understand the relative potential for a potentially bioaccumulatable chemical to bioaccumulate in aquatic life without causing aquatic life toxicity. The draft RI/FS for the LEHR site developed by Dames & Moore stated that bioaccumulation studies would be conducted if the concentrations of constituents are found in Putah Creek water that could cause aquatic life toxicity. Those knowledgeable in the elements of this topic area and who are familiar with the US EPA "Gold Book" of water quality criteria know that the critical concentrations in water for those chemicals that tend to bioaccumulate are often many orders of magnitude below the concentrations that are toxic to aquatic life. This is a fundamental basic issue associated with bioaccumulation. If a chemical is toxic to the organism that is accumulating the chemical, then bioaccumulation to higher trophic level organisms that use this organism as food is generally not of significance. If, however, which is the case, hazardous levels of chemicals occur in organisms that are a threat to higher trophic level organisms including man and wildlife that use the organism as food without toxicity to the organism, then this is of concern since higher trophic level organisms could be damaged by bioaccumulation.

While a brief presentation was made at the July 17, 1996 RPM meeting by a Region IX representative on the US EPA proposed bioaccumulation sampling of Putah Creek, there was insufficient information provided at that time to be able to judge the appropriateness of the proposed approach. Region IX is supposedly going to develop a detailed sampling and analysis plan that can be reviewed by the RPMs and DSCSOC for its appropriateness.

There are a number of aspects of the bioaccumulation assessment situation that need to be addressed. First, it is my impression that US EPA Region IX plans only to do the sampling for bioaccumulation as a one-shot operation. Such an approach is invalid. The activities associated with LEHR site investigation and remediation mandate that a comprehensive stormwater runoff water quality management program be conducted until the LEHR site is declared cleaned up-remediated. This will require aquatic life toxicity for the water column and sediments and properly conducted bioaccumulation monitoring into the indefinite future. Further, since H. Ficklin indicated that the US EPA is not addressing as part of the bioaccumulation studies the measurement of chemical constituents in water and sediments, this is an area that needs to be addressed. All of these areas should have been and now should be part of the LEHR site surface water impacts monitoring program.

While at the meeting the US EPA Region IX representative claimed that he did not know of any way to determine whether the current LEHR runoff was causing excessive bioaccumulation problems, if excessive bioaccumulation is found I can readily provide guidance on how this could be done through forensic analysis. During the past year I have been working on developing what is called the "evaluation monitoring" approach to determine whether stormwater runoff from a particular source represents a real, significant water quality use impairment in the receiving waters for that runoff. I have recently presented two invited papers on that work. They include:

Lee, G.F. and Jones-Lee, A., "Assessing Water Quality Impacts of Stormwater Runoff," North American Water & Environment Congress, Published on CD-ROM, Amer. Soc. Civil Engr., New York, 6pp (1996),

and

Lee, G.F. and Jones-Lee, A., "Aquatic Chemistry/Toxicology in Watershed-Based Water Quality Management Programs," In: Proc. Watershed '96 National Conference on Watershed Management, Water Environment Federation, Alexandria, VA, pp. 1003-1006 (1996).

These papers focus on using stormwater runoff water quality monitoring funds to examine the receiving waters for real water quality use impairments. Where such impairments are found, then determine the cause of the use impairment and the source of the constituents responsible for the use impairment. While this approach is different from the traditional end-of-the-pipe monitoring that UCD and DOE have been conducting, it is a technically valid, highly cost-effective approach that specifically addresses the issues of what, if any, real water quality problems are associated with stormwater runoff from an area.

The evaluation monitoring approach is in accord with current US EPA national policy and US EPA Region IX policy which de-emphasize end-of-the-pipe mechanical monitoring of runoff and focus on evaluation of water quality impacts in the receiving waters for the runoff. As part of the work that I have been doing in Upper Newport Bay in Orange County, I have developed an about 50-page report discussing details of how this approach can and should be implemented on a site-specific basis for any particular area of stormwater runoff concern.

At the July 17, 1996 RPM meeting, B. Oatman from UCD presented the results of the sampling that UCD conducted of the stormwater runoff through landfill #3 that was taken last February. You may recall that last January I reported to the DSCSOC and the RPMs that the information that S. Attiga had provided to you and me the previous summer about there being no flow from the ditch that UCD cut through the top of landfill #3 to Putah Creek was in error. At that time, I documented what was obvious--that there was significant flow through the top of the exposed wastes in landfill #3 to Putah Creek associated with major stormwater runoff events. As it turned out, neither UCD nor DOE had sampled this flow to see what, if any, constituents were being leached from the exposed wastes. These wastes have been found to contain hazardous as well as radioactive components and therefore are a potential threat to Putah Creek water quality.

At the July 17, 1996 RPM meeting, Mr. Oatman presented summaries of the data for the samples collected from the February sampling. As I indicated, summaries of data of this type often can be misleading and do not provide an adequate technical base to properly judge water quality issues. I asked at that time for the data set. Mr. Oatman made the data available to me on August 14, 1996. Presented below are comments on the February 26, 1996 data set.

The data set that Mr. Oatman provided included the detection limits, the results of a single analysis on three different sites, drinking water MCL and the LEHR surface water concentration range for 1995. The three sites sampled were: 1) an east-west ditch draining the LEHR site that discharges into the north-south drainage ditch that cuts through the top of landfill #3; 2) the drainage ditch above landfill #3; and 3) the drainage ditch below landfill #3. A review of these data is presented below.

The electrical conductivity data should have the temperature at which the conductivity measurements were made or to which they were corrected as part of reporting the results. Further, electrical conductivity should be rounded off for site #1 to two significant figures. There is no justification to provide three significant figures for this analysis; it is not that reliable.

The total organic carbon data for the three sites where measurements were made are of concern. This concentration of TOC represents a significant problem for domestic water supplies with respect to trihalomethane formation. While the US EPA does not now have a standard for TOC, the Agency is in the process of developing an approach for addressing TOC issues for domestic water supplies. The stormwater runoff from LEHR and the UCD property north and west of LEHR that drain to the drainage ditch concentrations would be of such magnitude as to require control in order to protect domestic water supplies from excessive THM precursors.

The arsenic analyses are listed as having a detection limit of 0.1 mg/L. These analyses were conducted with inadequate sensitivity for domestic water supply analyses under the current drinking water standard of 50 ug/L, much less a new potentially proposed drinking water standard which will likely be on the order of about 2 ug/L. The analyses for arsenic must use an analytical method which detects arsenic at around 1 to 2 ug/L. Such methods are available.

The cadmium analyses which had a detection limit of 10 ug/L are not adequate to protect aquatic life or for drinking water analysis.

The chromium analyses had detection limits of 10 ug/L. That is the chronic criterion for chromium for protection of aquatic life. The analytical method detection limit for chromium should be decreased to about 5 ug/L.

It is of concern that chromium in surface water runoff from the LEHR site area and other UCD properties that drain through the ditch cut through the top of landfill #3 is being found at 30 to 60 ug/L. Studies need to be initiated to determine what is the source of this chromium in surface waters from the LEHR site and the UCD property that drains into Putah Creek through the ditch that was cut through the top of landfill #3. These concentrations of chromium could represent highly significant adverse impacts to aquatic life in Putah Creek.

The copper analyses had a detection limit of 10 ug/L. The data sheet, however, is highlighted as though there were excessive concentrations of copper where the concentrations are listed at 19, 30 and 29 ug/L. These concentrations are not excessive concentrations for drinking water. It is also doubtful that they are excessive for aquatic life because of the hardness of the water. There seems to be an error made in highlighting the copper row on the data sheet.

The lead analyses were conducted with inadequate sensitivity for drinking water. The detection limit used was 50 ug/L; the drinking water "MCL" for lead is 15 ug/L. There could readily be lead problems for drinking water, much less aquatic life, and not be detected by the analytical methods used.

The mercury detection limit is 0.2 ug/L. This analysis is not adequate to detect the potential of bioaccumulation of mercury in aquatic life. It is of concern that mercury in the downstream side of landfill #3 was found at 0.7 ug/L. That concentration could readily result in excessive accumulation of mercury in fish in Putah Creek. It appears from these limited data that landfill #3 is contributing mercury to the stormwater runoff through the trench cut in the top of landfill #3 by UCD.

There is need to better understand why there are significantly elevated concentrations of nickel in the stormwater runoff from the UCD property.

The silver analyses apparently have been done with an analytical procedure that does not have adequate sensitivity to detect potential impacts of silver on aquatic life. Analytical methods should measure the concentrations of a parameter at less than the critical concentration. Without this sensitivity, it is not possible to reliably determine whether excessive concentrations are present. Further, there appear to be elevated concentrations of silver in stormwater runoff from the LEHR site and UCD property compared to the concentrations that could be adverse to aquatic life.

There are high levels of vanadium and zinc in the stormwater runoff from the UCD property. There is need to investigate the sources of this high zinc and vanadium.

In Mr. Oatman's presentation in which he summarized the data from the stormwater runoff which caused my inquiry into this issue, he mentioned that the VOC detection limits were variable. Subsequently, Mr. Oatman provided me with the individual data sheets from the lab. A review of these data sheet detection limits shows that some of the VOC analyses such as for vinyl chloride which has a detection limit of 2 ug/L is far higher than it should be. The DHS limit on vinyl chloride in drinking water is 0.5 ug/L. Determining VOCs with inadequate detection limits is a common error made by those not familiar with drinking water standards in California.

The detection limits used for the chlorophenols were several ug/L. In general, these are above the concentrations that will cause tastes and odors in domestic water supplies and that may cause fish flesh tainting problems.

The detection limit for chlordane at 0.05 ug/L is not adequate to detect chlordane at concentrations that will bioaccumulate in fish. This is similarly true for a number of other chlorinated hydrocarbon pesticides as well as PCBs. There can readily be problems of excessive concentrations of these chemicals in fish due to their bioaccumulation from water derived from the LEHR site that would not be detected by the analytical methods and approach being used. It is because of this situation that bioaccumulation monitoring should be done in order to determine whether excessive concentrations are occurring in fish tissue compared to acceptable risk assessment evaluations for these chemicals.

The US EPA has developed a series of manuals devoted to providing "Guidance for Assessing Chemical Contaminant Data For Use In Fish Advisories." I have enclosed a cover page for volume one of these manuals. I believe they can still be ordered from the US EPA Resource Center at 202-260-7786.

The person responsible for setting up the analytical procedures for these analyses made significant errors in selecting the analytical methods for even domestic water supply, much less aquatic life. As discussed above, the detection limits were not adequate to detect the compounds at potentially significant levels and are therefore highly misleading. The reporting of a non-detect value without specifying the actual detection limit for each of the chemicals, the critical concentrations for water supply use and the critical concentrations for aquatic life considering both chronic toxicity and bioaccumulation can give the impression to someone not familiar with the situation that there are no water quality problems due to stormwater runoff from the LEHR site and UCD property. In fact, the monitoring program was set up incorrectly, with the result that inappropriate analytical procedures and monitoring approaches were used to detect potential problems.

The problems of inappropriate monitoring of surface waters at the LEHR site have been a chronic problem with the LEHR site studies. There is need for UCD to get someone involved in this issue who understands surface water quality issues and the appropriate measurement of chemical constituents in surface waters in order to determine whether there is an excessive concentration of constituents in stormwater runoff from LEHR and other UCD properties to be adverse to the designated beneficial uses of Putah Creek.

Unfortunately, in their presentation at the July 17, 1996 RPM meeting UCD (B. Oatman) made the same kinds of errors that have been made over the years by DOE and its contractor, Dames & Moore, in conducting stormwater runoff studies from the LEHR site. Not only were the analytical procedures used by UCD in the February 1996 sampling of stormwater runoff that occurred through the top of landfill #3 inappropriate, inappropriate measurements were made, key parameters were not measured, the worst-case conditions associated with stormwater runoff were not examined, inadequate sensitivity was used in the analytical procedures and, most importantly, the concentrations of constituents found were compared to drinking water standards rather than aquatic life standards. As I indicated after Mr. Oatman's presentation, neither UCD nor DOE have yet to come to grips with initiating and implementing a meaningful stormwater runoff water quality evaluation program at the LEHR site. They both are continuing to waste substantial amounts of public funds in conducting these studies. As I have indicated in my previous correspondence, there is an urgent need for both UCD and DOE to get somewhat involved in these areas to understand the basic elements of surface water quality.

At this meeting, S. Attiga reported on the stormwater flow regime that exists at the LEHR site. You may recall that when you and I toured the site with S. Attiga a year ago, I specifically asked for information about this system. Of particular concern was the origin of the water that was pumped across Old Davis Road from the LEHR site as well as whether there was any flow through the top of the exposed wastes in landfill #3. S. Attiga did not know the origin of the water pumped across Old Davis Road and informed us that there was no flow through the ditch cut through the top of landfill #3. We subsequently learned through my inspection of the ditch during a stormwater runoff event last winter that there is appreciable flow through the top of landfill #3. Further, we now better understand the flow regime for the stormwater that is pumped across Old Davis Road.

During the LEHR site visit on August 14, 1996, D. Austin noted what appeared to be the headworks for a stormwater drain apparently to Putah Creek in the area just to the west of the Raptor Center entrance. This is the area that drains a significant part of the LEHR site. Further studies need to be done to evaluate whether the concrete structure in the corner of the LEHR site just to the west of the Raptor Center entrance is, in fact, a headworks for a drainage pipe that penetrates the levee and drains stormwater from the LEHR property to Putah Creek. If it is, then this needs to be sampled as part of the stormwater runoff monitoring program.

Since to date UCD and DOE have not yet come to grips with developing a technically valid, appropriate stormwater evaluation program, DSCSOC should submit a formal request to the RPMs that this issue be addressed so that a credible program is initiated with the first stormwater runoff event of this winter. UCD and DOE should be required to acquire the necessary technical assistance so that they formulate by the mid-September RPM meeting a credible stormwater runoff water quality evaluation program for review by the RPMs and DSCSOC. If such a program is not developed and implemented, then DSCSOC should file a formal complaint with the Central Valley Regional Water Quality Control Board, the US EPA Region IX and Washington, D.C., if necessary, and DOE headquarters. The public should not experience another year of wasted funds in continuing to conduct technically invalid stormwater runoff assessments of the type that have been practiced by both UCD and DOE for many years in the case of the DOE studies.

This situation is part of the problem that I tried to get J. Littlejohn and J. McNeal to address as part of my comments on the lack of technical validity of a number of aspects of the LEHR site investigation. You may recall that they asserted in their March 5, 1996 letter to you in response to my suggestion that they conduct an internal review of these issues by individuals knowledgeable in the topic area that they knew of no problems with the work that was being done at LEHR. As I indicated in response to this highly inappropriate response on their part, I would, as time permits, again discuss these problems as they occur and if they are not adequately or reliably addressed, suggest that DSCSOC file formal complaints with DOE headquarters on the technical inadequacies of some of the work being done at the LEHR site.

The stormwater runoff water quality issue is just one of the issues where DOE and now UCD have shown a lack of technical competence that I have previously pointed out in my comments on the data reports that have been generated at the LEHR site over the past several years. It is now clear that if J. Littlejohn and J. McNeal had taken a more appropriate approach towards addressing this issue and conducted the internal review that I suggested they would not now have wasted the additional taxpayers' funds and would have avoided me having to take the time to document the technically incompetent approaches that they have followed, in this case the stormwater runoff water quality evaluation by DOE and UCD.

J. Littlejohn and J. McNeal may wish to reconsider their highly inappropriate response to my suggestion of an internal review of technical competence. There are still a number of other issues that I have previously raised in my comments of last fall and winter that need to be addressed that have not yet been re-addressed by me on the adequacy and quality of the work being done at the LEHR site in investigating the potential for this site to cause adverse affects on public health, groundwater resources and the environment by LEHR site wastes.

I have been working on stormwater runoff water quality evaluation and management from urban areas since the mid-1960s and have published extensively on these issues. If there is interest, I would be happy to provide anyone with a set of my graduate students' and Dr. Jones-Lee's and my papers and reports on these issues. They provide guidance on how to more appropriately investigate stormwater runoff impacts than is being conducted today by UCD and DOE.

I also wish to mention that I have prepared a short-course on this topic which I have presented a number of times at various locations. If there is interest, I could make this course available. I would suggest that DOE and UCD develop a financial arrangement with DSCSOC where they would provide DSCSOC with funds to cover the course presentation. These funds would be used by DSCSOC in support of their activities and not be paid to me. I would make my time for the presentation of this course available at no cost. This course would provide the attendees with the necessary background to begin to recognize the significant problems that exist with the way in which DOE, its contractors and UCD have proceeded to evaluate stormwater runoff issues at the LEHR site.

I have submitted a paper to the ASTM Third Symposium on Superfund Risk Assessment that will be held in January 1998 in San Diego devoted to evaluating water quality significance of chemical constituents in stormwater runoff from Superfund sites. The situation that has developed at the LEHR site will serve as a basis for this paper. This paper discusses not only the kinds of problems that I have observed in evaluating stormwater runoff that occur at Superfund and other similar sites but also how stormwater runoff from such sites should be monitored/evaluated in a technically valid, cost-effective manner. Enclosed is an abstract of the paper that I have submitted for this conference.

If you or others have any questions on these comments, please contact me. If you wish, please pass them on to the RPMs indicating that I would be happy to address any questions they have about them.

Sincerely yours,

G. Fred Lee, PhD, DEE
Technical Advisor, DSCSOC

GFL:oh
Enclosure