DSCSOC's Position on UCD's Proposed IRA Groundwater Cleanup Project

Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
fax 916-753-8220
e-mail [email protected]

August 1, 1997

Remedial Project Managers
UCD-DOE LEHR Superfund Site
University of California, Davis
Davis, CA 95616

Dear RPMs:

Dr. G. Fred Lee, DSCSOC's technical advisor, has provided DSCSOC with his recommendations on DSCSOC's position with respect to supporting UCD's proposed IRA groundwater cleanup project in his letter to DSCSOC attached to this letter. While DSCSOC will follow Dr. Lee's advice and support UCD's proposed IRA as an experimental initial data gathering effort, DSCSOC is concerned about UCD's failure to address the many groundwater pollution issues associated with its mismanagement of waste at the LEHR site and its former and current wastewater treatment plant raised in Dr. Lee's letter.

There is need for UCD to begin to immediately address all issues regarding UCD's groundwater pollution so that the impacts from the proposed IRA and UCD's other sources of groundwater pollution at the LEHR site as well as its existing wastewater treatment plant will not be allowed to cause further groundwater pollution and environmental damage. UCD has known since the early 1980's that its landfills were leaking and that groundwater pollution was occurring. UCD has known for many years that its wastewater treatment plant was inadequate and chloroform and other VOCs were being discharged in the treated effluent to Putah Creek. UCD chose to ignore its obligations to investigate and remediate its sources of pollution until the public's demand for a Superfund site investigation succeeded in forcing UCD to begin to address the groundwater pollution at the LEHR site.

DSCSOC has grown impatient with UCD's slow paced, inadequate and unreliable LEHR site investigation. In the almost three years since DSCSOC received its EPA TAG grant, UCD has made only a minimal effort to investigate the extent and degree of groundwater pollution compared to the magnitude of the problem that exists. Now UCD proposes to only partially remediate a small portion of the groundwater pollution with its proposed interim remedial action. This IRA falls short of addressing the cleanup of the groundwater pollution in HSU-2 and fails to use taxpayers' money wisely.

UCD's claim of a lack of cost effectiveness in properly cleaning up the existing as well as new pollution associated with the proposed IRA is an attempt by UCD to unfairly pass the cost and the burden of UCD's failure to properly manage its campus waste to the off-site public. UCD must be required to take the necessary actions to protect the groundwater, including protection from hazardous and deleterious chemicals that impair the use of the groundwaters, in order to fully protect the off-site public's health, welfare and interest in accord with Central Valley Regional Water Quality Control Board Basin Plan objectives.

Dr. Lee requests that if any of the parties have questions about his recommendations, to contact him.


Julie Roth, Ex. Dir.

cc: DSCSOC's Ex. Board
Ed Schnabel
Gary Carlton
William Taylor
Jane Riggan
Brian Shafer
L. Vanderhoef
Dr. G. Fred Lee

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