VIA e-mail

 August 1, 1997

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

 Dear Julie:

 I am following up on the last RPM meeting where Susan Timm asked about DSCSOC's position with respect to supporting UCD's proposed IRA groundwater cleanup project. As I understood the situation, Susan must make a presentation to the CVRWQCB covering gaining Board approval for this IRA. Please find presented below a summary of my recommendations to DSCSOC on this issue.

I continue to recommend that DSCSOC support UCD's proposed IRA as an experimental initial data gathering effort. This program, as proposed, can provide important information on the aquifer hydraulic characteristics that are needed to plan a full-scale remediation program for the pollution of the groundwaters by chloroform and other constituents by waste materials deposited in the northern part of UCD campus landfill No. 2.

The CVRWQCB should understand however, as discussed in my previous comments, that this IRA falls far short of addressing the ultimate cleanup of the groundwaters at the point where UCD proposes to pump from HSU-2. It is my assessment that UCD's proposed approach, of only removing the VOCs from the pumped groundwater before reinjection, is highly short sighted and ultimately will cost the taxpayers of the state of California more money than if this IRA had been properly planned to include the use of reverse osmosis to remove many of the regulated as well as unregulated pollutants that are present in the groundwaters that are being pumped as part of the IRA.

I continue to be highly concerned that UCD's IRA will only recapture part of the reinjected groundwaters. At certain times substantial parts of the pollutants that originally pumped by UCD in the IRA will be introduced into the aquifer and pollute new areas of the aquifer with landfill No. 2 derived waste, which are not now polluted by this landfill. I understand that the RPM's have required that UCD install several more monitoring wells as part of this IRA to define the amount of additional pollution that will occur because of the IRA. As I have discussed, it is important for UCD and the CVRWQCB to understand that all pollutants introduced into new areas of the aquifer by the IRA will ultimately have to be cleaned up by UCD to background. This should be a condition set forth in the CVRWQCB's approval of the IRA.

I recommend that DSCSOC vigorously oppose any attempt by UCD to claim a lack of cost effectiveness in cleaning up any existing, as well as new pollution associated with the IRA, or for that matter, any of UCD's past waste disposal practices that have caused groundwater pollution at the LEHR site. UCD should understand that cleaning up to drinking water standards for regulated chemicals will not be adequate to protect the health, welfare and interests of the off-site public, whose groundwater resources are polluted by UCD's mismanagement of its campus waste. The ultimate groundwater cleanup program that will have to be implemented at the LEHR site must protect off-site groundwater users from hazardous and deleterious chemicals that impair the use of the groundwaters. This protection must address both the regulated and unregulated chemicals, including tastes and odor compounds, TDS, etc. Further, UCD should not be allowed to use up the chemical constituent assimilative capacity of the aquifer which would cause down gradient groundwater users waters to be impaired by natural and ag-derived pollutants which cause the waters to exceed health hazard-based standards, as well as causing other problems for the use of the water, such as shortening plumbing and fixtures life, etc.

UCD and the CVRWQCB should also understand that this IRA is addressing a small part of the groundwater pollution that will ultimately have to be addressed by UCD from all three campus landfills located at the LEHR site. The groundwater clean up must address all LEHR waste disposal practices, including septic tanks, etc. At this time much of the pollution from these other areas has not been adequately investigated to define its extent and degree.

Further there still is the issue of the potential pollution of the groundwaters by the former campus waste water treatment plant that was located in the LEHR area. There is concern that UCD's operations of this plant resulted in pollution of groundwaters by constituents associated with the sludge drying beds and/or lagoons. UCD still has not initiated investigation in this area.

The recent confirmation of the long suspected pollution of HSU-4 by UCD's LEHR site waste will require a comprehensive investigation of the full extent of HSU-4 pollution and cleanup to background.

While not a LEHR site issue per se, the pollution of groundwaters by UCD existing campus waste water treatment plant through the discharge of chloroform and other VOCs in the treated effluent to Putah Creek must be investigated and cleaned up. This creek down stream of the treatment plant recharges groundwaters which carry with it the pollutants discharged by UCD in its inadequately treated waste waters. UCD will have to immediately start to investigate the full extent of groundwater pollution via Putah Creek recharge and begin to clean up this pollution to background in accord with CVRWQCB Basin Plan objectives.

I suggest that if DSCSOC supports my recommendations on these issues that you develop a cover letter for this letter and e-mail these to Susan Timm, the other RPMs, the PRPs (UCD and DOE) and G. Carleton, executive officer of CVRWQCB. Please indicate that if any of these parties have questions about these recommendations, they should contact me. Please call if you have any questions.

Sincerely yours,
Fred
G. Fred Lee, PhD, DEE

GFL:cst