UCD's Draft Long-Range Plan for Remediation of the
UCD/DOE LEHR National Superfund Site
G. Fred Lee & Associates
February 9, 1998
Julie Roth
Executive Director
DSCSOC
Route 2, Box 2879
Davis, CA 95616
Dear Julie:
I have reviewed the February 6, 1998 letter from B. Oatman to the RPMs which presents "Long-Range Plan, Environmental Restoration Activities, South Campus Disposal Site, UC Davis, Davis California" and have the following comments.
First, it appears that the UCD L. Vanderhoef administration is trying to disguise the fact that it has a national Superfund site on its campus by calling it the South Campus Disposal Site(SCDS). UCD's so-called South Campus Disposal Site is part of the LEHR national Superfund site that arose because UCD conducted research at what was obvious at the time to be far less cost than what would ultimately be needed to manage the research-generated wastes in a technically valid, cost-effective, public health and environmentally protective manner. Also associated with this Superfund site are the mismanaged campus solid and liquid wastes arising from UCD's attempts to manage part of its campus waste by landfilling in UCD landfills. Obvious inadequate waste management activities that were practiced by UCD which saved the University a small amount of funds in waste disposal at the time of deposition are now costing the taxpayers of California many tens of millions of dollars in site remediation.
Page 2, first sentence, states that the purpose of this Plan is to outline the activities that will be used to close the UCD area of responsibility LEHR Superfund site in accord with "...the requirements of CERCLA and the NCP." UCD should understand that it will also have to close this site in accord with the requirements of the Central Valley Regional Water Quality Control Board which are more protective and comprehensive than those dictated by CERCLA.
Waste Burial Holes
It appears that UCD plans to follow the approach that DOE has adopted in removing all wastes and associated contaminated soils for off-site disposal from the waste management areas where LEHR wastes have been disposed. The same issues will ultimately have to be faced by UCD as are being faced now by DOE of the degree of contaminated soil clean-up associated with the waste burial holes and the associated monitoring program that will arise from the remediation program chosen by UCD for these areas.
Landfill Unit #3
UCD states in the second paragraph under "Landfill Unit #3" that the initial remedial activities will address the exposed wastes in the drainage ditches as a non-critical removal action. Thus far, UCD has been highly derelict in meeting its responsibilities associated with protecting public health and the environment arising from its highly irresponsible actions of cutting a drainage trench through the top of Landfill #3, leaving exposed wastes that are washed with stormwater runoff from the LEHR site and other UCD properties. Thus far, UCD has not conducted a credible stormwater runoff monitoring program for the stormwaters that pass through the exposed wastes. As discussed in correspondence of over a year ago, the stormwater monitoring program that UCD has conducted failed to properly monitor the stormwater runoff for Landfill #3 waste-derived constituents. Duncan Austin pointed out in review of the data that while the data are inadequate, they tend to show that there is release of constituents from the exposed waste. Rather than being a responsible entity and immediately addressing this issue, the UCD L. Vanderhoef administration has continued its recalcitrant polluter approach of doing the minimum necessary to just get by regulatory oversight. In this case, the regulatory oversight has not been adequate to protect public health and the environment. It is still my position as formulated over a year ago that the RPMs should be requiring UCD to place a high priority on stopping stormwater runoff from passing through exposed wastes at Landfill #3 until such time as UCD has developed and credibly implemented a reliable stormwater monitoring program for the stormwaters passing through the top of Landfill #3 in UCD's drainage ditch that shows that there is no release of hazardous or deleterious substances from this landfill to Putah Creek.
UCD proposes that capping or containment of the remaining portions of the landfill will be the remedial approach followed. As discussed in previous correspondence for this and the other landfills, conventional capping will not be an acceptable method for remediation of the LEHR site. Leak detectable caps with on-going reliable monitoring and maintenance will be required.
Southern Trenches
UCD states that there have been no significant results reported in any media from the samples collected from the southern trenches and proposes that a "no action" alternative is possible for this area. Thus far, UCD has not adequately or reliably characterized the existing wastes and their potential to cause surface and groundwater pollution. A much more detailed characterization will be necessary before consideration can be given to a "no action" alternative.
Groundwater Plan
UCD states that the focus of the groundwater investigation activities over the next two years will be on source area investigation. UCD further states that the need for additional monitoring wells on- or off-site will be addressed in 1999. This approach is unacceptable. UCD has still not adequately and reliably characterized the off-site groundwater pollution that has occurred due to mismanagement of wastes at the LEHR site. UCD must, as a high priority item, devote substantial resources to reliably defining the full extent of off-site groundwater pollution that has occurred by LEHR site wastes in both HSU-2 and HSU-4. UCD in its draft Long-Range Groundwater Plan fails to address the pollution of HSU-4. This must be a high-priority item for immediate attention. If there is a shortage of funds, the off-site pollution of HSU-2 and HSU-4 should take priority over the near-source investigations. UCD should have in place by 1999 a specific plan to remediate the off-site pollution of HSU-2 and HSU-4 which can be implemented within the following year.
I am sure that additional deficiencies in UCD's current draft Long-Range Plan will surface at the RPM meeting that is scheduled for February 11, 1998. I will likely be providing additional comments on these issues after that meeting.
If you have questions about these issues, please contact me.
Sincerely yours,
Fred
G. Fred Lee, PhD, DEE
GFL:oh
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