Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
530-753-9446
fax 530-753-8220
e-mail [email protected]
http://www.members.aol.com/dscsoc/dscsoc.htm

April 14, 1998

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

Dear RPMs

I have attached for your review Dr. G. Fred Lee's comments on recent UCD reports he prepared on behalf of DSCSOC. The attached comments include:

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

Sincerely,

Julie Roth, Ex.Dir.

cc: DSCSOC's Ex. Board
PRPs
William H. Taylor
Jane Riggan

Comments on
"Waste Burial Holes Data Transmittal Data Gaps
Limited Field Investigation South Campus Disposal Site, Davis, California"
prepared by Dames & Moore for the University of California, Davis
dated March 30, 1998

G. Fred Lee, PhD, DEE
G. Fred Lee & Associates
El Macero, CA
ph: 530-753-9630
fx: 530-753-9956
[email protected]
http://members.aol.com/gfredlee/gfl.htm

April 14, 1998

Basically, this is a data report on the results of the limited field investigation associated with trenching or sampling of wastes in various waste management units under UCD's responsibility. It is important to recall that this is a limited field investigation and therefore not a proper characterization of the wastes present in any of the waste management units for which samples were obtained. UCD should not attempt the same approach that DOE has followed of trying to use a limited field investigation to attempt to characterize the hazards of the waste in a human health and ecological risk assessment. A proper detailed sampling of the wastes is necessary for such characterization purposes.

On page 6, mention is made in the second paragraph under "Results" that the WET analysis was used. As far as I can tell, the WET analysis procedures are not defined. If this is the DTSC WET analysis for hazardous waste classification, then this study program for this study is deficient since it should have included also the DTSC required aquatic life-based bioassay testing as well as the US EPA TCLP analysis. It has been found by DTSC that TCLP, i.e. the standard US EPA procedure, for some constituents extracts materials from wastes to a greater extent than the WET procedures. It mentions in this data report that a discussion of the data will be provided at a later date. Without such a discussion, it is not possible to comment further on this report.

Comments on
Old Wastewater Treatment Plant Data Transmittal
Data Gaps Limited Field Investigation
South Campus Disposal Site
Davis, California prepared by Dames and Moore
for the University of California, Davis dated March 1998

This report is basically a data report covering samples that were taken by UCD related to the potential for the "old UCD campus wastewater treatment plant" located along Putah Creek to cause pollution of soils and groundwaters in the vicinity of the plant. This study was initiated at a result of DSCSOC's recommendations to the RPMs that the former wastewater treatment plant located at the LEHR site should be investigated for the potential to have caused pollution of soils and groundwaters by the management of wastes at the plant. This study was conducted without prior review of the proposed study plan by the RPMs/DSCSOC.

This study is characterized in this report as a "limited field investigation" which is certainly appropriate based on the characteristics of this study. The Study Plan is inadequate to determine whether the former wastewater treatment plant sludge drying beds have caused and continue to cause groundwater pollution at the site.

It is stated on page 2, Section 2.1 "Purpose," "to assess whether those residuals present a threat to groundwater." The residuals in question are the residues of sludge drying beds.

It is stated on page 2, Section 2.2. "Scope," that one soil boring was drilled through the former drying beds and one soil boring was drilled approximately 100 feet downgradient of the former drying beds. It is presumed that downgradient refers to groundwater gradient, not surface water gradient. This should have been stated. It is stated in that same paragraph that the soil borings were drilled to just above the average high groundwater elevation. The borings should have been extended into the groundwater and samples taken. This would have provided far more reliable information about the potential for groundwater pollution by existing residues than the current study.

On page 2, last paragraph, "Observations," mention is made that a concrete slab was encountered in the soil borings. This situation greatly complicates the sampling of the soil profile for potential to cause groundwater pollution since the leakage through the concrete slab was likely at joints or cracks. Therefore, a single soil boring or several soil borings or even 20 soil borings of this type would not detect the pollution of the soil column as well as the groundwaters of the region.

Table 1 presents the analytes that were determined. Examination of this Table shows that hexavalent chromium was determined. Total chromium should have also been determined. The listing of pH in this table again reflects a lack of understanding of typical data reporting since pH should never be reported as a "Ph." It is "pH." This has specific chemical meaning.

In Table 2b, pH is presented as "PH."

Table 3a, presents the results of the two soil borings where samples were analyzed at five and fifteen feet. Even if there had been leakage through cracks at the point of sampling, sampling only at 5 and 15 feet is inadequate to detect residues. A much closer sampling grid must be used in the Davis area climate to detect chromatographic bands of constituents.

Overall, this study provides no useful information on whether the old wastewater treatment plant has been and continues to pollute groundwaters. The study was ill-conceived by UCD and its consultants. It basically represents a waste of public funds. Work will have to be done in which the near surface groundwaters just downgradient from the old wastewater treatment plant are sampled to determine whether the groundwaters in this region contain elevated concentrations of constituents that represent a threat to both on-site and off-site groundwater.

Comments on
Data Transmittal Off-Site Monitoring Well Installation
Fourth Hydrostratigraphic Unit
LEHR/SCDS Environmental Restoration, Davis, California
prepared by Dames and Moore
dated March 1998

This report covers the installation of three groundwater monitoring wells located off-site from the UCD - DOE LEHR national Superfund site which were installed as the result of DSCSOC's insistence that the pollution of the fourth HSU be investigated at the LEHR site. For years, UCD has been unwilling to admit that the fourth HSU could have been polluted by LEHR site wastes. UCD has developed report after report which ignores the fourth HSU. This has been a deliberate attempt to deceive the public and others into believing that the only pollution of groundwaters at the LEHR site has occurred in the third HSU. However, it is obvious upon examination of the characteristics of HSU-3 as well as the presence of various agricultural and municipal wells which serve as conduits between HSU-2 and HSU-4, that pollution of HSU-4 has likely been occurring for many years. UCD in its typical recalcitrant polluter approach toward addressing issues of this type has been grossly negligent in failing to conduct the studies on their own initiative to investigate the pollution of HSU-4 by LEHR site wastes. It was only as a result of DSCSOC's insistence and the support of the RPMs that HSU-4 pollution has begun to be documented.

Page 1, "Introduction," second paragraph, states that this report does not present a discussion of the groundwater analytical data for the sampling of HSU-4 and that this discussion will be included in the 1997 Annual Groundwater Monitoring Report for LEHR/SCDS. It is now mid-April and the 1997 Annual Groundwater Monitoring Report has still not been made available for review. If this report is of similar character as previous reports prepared by UCD and its contractors, it will be significantly deficient in properly presenting and discussing the data obtained as part of the groundwater monitoring at the LEHR site. Hopefully, the detailed comments that DSCSOC has provided on the deficiencies in the previous LEHR site data reports will be addressed in the 1997 data report.

On page 2, first paragraph, line 5, it states that the purpose of the sampling of the HSU-4 monitoring wells is to "...evaluate HSU-4 groundwater chemistry." The term "groundwater chemistry" is inappropriately used. The proper terminology is "groundwater chemical characteristics." "Chemistry" involves an investigation of chemical reactions that control concentrations; it is not a listing of concentrations. No work has been done by UCD, DOE or their contractors on the actual chemistry of groundwaters at the LEHR site. This is one of the significant deficiencies in how UCD and DOE have conducted the LEHR site investigations in that they fail to properly address chemistry issues as opposed to chemical characteristic issues.

Page 3, first line, presents a Dames & Moore HSU-2 transmissivity value. It is not clear whether this value has been properly corrected for the significant error that was made by Dames & Moore in the early and mid-1990s in estimating the rate of transport of constituents from the LEHR site to off-site groundwaters. The error made by Dames & Moore in evaluating the rate of horizontal transport of pollutants from the LEHR site has been significantly detrimental to protecting off-site property owners' groundwater resources from further pollution by LEHR site wastes.

Page 4, first paragraph under "Observations," presents the results of the drilling with respect to the positions of HSU-1, 2, 3 and 4. It would have been informative for UCD to present how the results at this location compare to information obtained from other locations. One of the issues of concern with respect to the various 'HSUs is the potential for significant changes in their characteristics just off-site of the LEHR site. Previous reports have indicated that certain components of the HSU disappear just off-site of the LEHR site which apparently are just to the south of the investigations presented in this report.

Page 6 under "Observations" indicates that the turbidity present in the samples still reflect an appreciable contamination by the well installation and development methods.

Page 7, first full paragraph, discusses the results of the slug tests. Because of the significant errors made by Dames & Moore in previous reporting of results of this type for the LEHR site, these results need to be independently evaluated to be sure that these tests were reliably conducted and presented.

This report is significantly deficient in failing to provide the chemical data that were collected at the time of these studies. These data have been available for some time prior to the release of the March 1998 report. It should have been presented.

DSCSOC is highly concerned that UCD failed to include investigation of the pollution of HSU-4 by LEHR site wastes as a high priority item for its on-going investigations of the pollution of groundwaters at the LEHR site. UCD should understand that it is DSCSOC's position that if the off-site pollution of groundwaters in HSU-4 is not a high priority for further work, that DSCSOC will take this matter for full, public, formal review to the state and federal agencies locally and nationally. If these agencies refuse to provide appropriate support for determining the extent and degree of pollution of groundwaters off-site by UCD's mismanagement of its campus and LEHR site wastes, then this matter will be taken to elected officials for full public review. DSCSOC has made it clear over the past three years that it has been active at the LEHR site, that the extent and degree of off-site groundwater pollution by UCD's mismanagement of its campus waste and LEHR site waste must be of the highest priority for UCD/DOE's attention.

UCD and DOE have both neglected common-sense public health protection of appropriately investigating the extent and degree of off-site groundwater pollution as it may impact domestic and agricultural wells over the past nine years that off-site groundwater pollution by the LEHR site wastes has been known. This is the ultimate in gross negligence on the part of both UCD and DOE in protecting the public's interests. For UCD now as the Responsible Party for groundwater pollution at the LEHR site to continue to act in a highly irresponsible, recalcitrant polluter approach of ignoring off-site groundwater pollution by failing to place as the highest priority for the available funding, determination of the degree and extent of pollution of HSU-2 and HSU-4 further represents inappropriate approaches for addressing issues of greatest concern to the public. If neglecting the public's interest continues, then DSCSOC will be left with no alternative but to take action to force UCD to become a responsible public entity in addressing these issues.