UCD's Replacement of M. Rust's Irrigation Well
as the Result of Chloroform Pollution
October 15, 1997
Julie Roth, Exec. Director
DSCSOC
Route 2, Box 2879
Davis, CA 95616
Dear Julie:
On September 11, 1997, Susan Timm sent Mary Rust a letter regarding construction of the new well on their property to replace the well that had been polluted by UCD's mismanagement of its campus chloroform wastes in which she indicated that "Based on available hydraulic and water quality data, the proposed well should not significantly affect plume migration or UCD's ability to remediate the plume." I wish to point out that at this time DSCSOC has inconsistent information with respect to how far east of the UCD property line the chloroform plume has proceeded. Originally, the DOE contractor (Battelle Northwest) concluded that it was likely to extend a mile or more beyond the property line. Subsequently, under pressure from DSCSOC, additional hydropunch work was done which apparently showed that it did not proceed as far as the previous DOE contractor had projected. However, I have previously pointed out that the hydropunch sampling may not be representative of the actual plume position from several perspectives.
The first of these is that the discharges of chloroform and its movement are likely cyclic, dependent on the precipitation pattern. The hydropunch sampling that took place which led to the conclusion that the plume has not gone as far as originally predicted may have hit a valley-low point in chloroform where there could be higher concentrations on either side of the sampling points. Further, since hydropunch takes a sample from a specific location, it is possible that even at the position of sampling the plume is not at the point where the samples were taken.
Overall, hydropunch is not a reliable tool for delineation of plumes, especially in a setting such as that associated with the LEHR site. If the hydropunch finds chloroform, then it has found at least part of the plume. Failing to find chloroform or other constituents by hydropunch, however, is not adequate information to indicate that the plume does not exist at that point. A far more comprehensive sampling program is needed to make that determination.
With respect to Mary's situation, it is my understanding that UCD is paying for the replacement well that was caused by UCD's mismanagement of its campus waste chloroform. It should be understood that if chloroform is found in the new well, UCD should have to construct yet another new well to provide Mary with irrigation water that is free of chloroform and other LEHR site-derived wastes. UCD has known about the off-site pollution of neighbors' groundwaters by chloroform for almost 10 years. Several years ago the administration put on hold a proper investigation and remediation of chloroform and other wastes. UCD is still proceeding far slower than it should in investigating the off-site pollution caused by its mismanagement of its campus wastes. Its slow rate at which it is beginning to meet its obligations under current regulatory requirements could readily prove to be further significantly detrimental to Mary and other neighbors as well as to the taxpayers of the state by constructing wells that still tap the part of the aquifer that contains chloroform or other plumes.
Another issue that still has not been addressed by UCD that I have raised on several occasions is whether using groundwaters that contain chloroform causes a spread of the plume through infiltration of the chloroform in the irrigation water. Another irrigation season has passed without UCD, DOE or others doing the studies that need to be done to determine whether the chloroform in the irrigation water causes additional groundwater pollution. We know from previous studies that the chloroform in UCD's campus wastewater treatment plant discharges is polluting groundwaters along Putah Creek. A similar situation could be occurring with irrigation water containing chloroform.
If you have any questions on these comments, please contact me. Please submit this to the RPMs for their review and comment.
Sincerely yours,
Fred
G. Fred Lee, PhD, DEE
Copy to: M. Rust
GFL:oh
|
|
|
