Remedial Project Managers
DOE/UCD LEHR Superfund Site
UC Davis Campus
Davis, CA 95616

August 16, 1999

Dear RPMs,

Attached please find DSCSOC's additional comments submitted to ATSDR for the LEHR Superfund site risk assessment. The enclosures I am providing to ATSDR are documents you already have.

If you have any questions regarding this information, please contact me.

Julie Roth
Executive Director
Davis South Campus Superfund Oversight Committee

Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
fax 530-753-8220
e-mail [email protected]

August 16, 1999

Wayne Henry
Agency for Toxic Substance and Disease Registry
1300 Clifton Road, E-56
Atlanta, GA 30333

Dear Wayne,

Thank you for your update on the status of ATSDR's LEHR Superfund site risk assessment. I appreciate your keeping me informed and letting DSCSOC know that additional comments can be provided to ATSDR. DSCSOC is concerned that ATSDR may be planning to complete its risk assessment of the LEHR site before a number of key health and environmental issues have been adequately addressed. Until each of the major pathways for human exposure at the site are assessed, ATSDR's health and environmental risk assessment cannot be adequately completed. Health and environmental risk pathways such as the bioaccumulation of hazardous chemicals such as mercury and chlorinated hydrocarbon bioaccumulation in Putah Creek aquatic life, the translocation of hazardous wastes through vegetation root uptake and release to the atmosphere and surface soils need to be adequately assessed as part of a comprehensive risk assessment for the LEHR site.

I have enclosed copies of Dr. G. Fred Lee, technical advisor for the Davis South Campus Superfund Oversight Committee, Kathy Setian, Remedial Project Manager for the US EPA and Susan Timm, Remedial Project Manager for the Central Valley Regional Water Quality Control Board, comments on UCD's 1998 Annual Water Monitoring Report. These comments point to the inadequacy of the site investigation that has been conducted thus far in several key areas. I suggest that these comments be included in ATSDR's LEHR risk assessment. Dr. Lee, Ms. Setian and Ms. Timm comments raise important risk assessment issues regarding hazardous chemicals in the groundwater and surface water runoff at LEHR which UCD has not adequately assessed and addressed. The groundwater plumes represent a significant pathway at the site. The RPMs are planning a special technical meeting to have UCD respond to these comments on September 8, 1999.

Dr. Lee raised the issue that an investigation of the vegetation translocation of hazardous waste pathways needed to be conducted as part of the LEHR site investigation three years ago. He suggested that vegetation and wildlife be sampled to determined if this pathway had been completed. His suggestions were ignored by the responsible parties at LEHR. Recently, UCD removed some pine trees at the site which were impeding UCD's Waste Burial Removal Action planned for August. In the process, UCD tested the trees and found tritium in the samples ranging from 1,900 to 15,400 pCi/g (19,700 pCi/g in duplicate sample). Unfortunately, UCD did not include the pine cones produced by these trees in its sampling so the samples are less than adequate for a comprehensive risk assessment. Also, UCD did not sample for a number of hazardous non-radioactive chemicals that are present in the wastes that could be translocated from the soils to the environment. The sampling results confirmed that the translocation pathway has been completed, where animals and possibly humans are being exposed to elevated concentrations of hazardous chemicals.

DSCSOC requests that an adequate investigation of the translocation risks be conducted at LEHR before ATSDR's risk assessment is completed. I have enclosed a copy of the UC Davis Update for the August 12, 1999 RPM meeting which contains the tritium sample information. UCD's RPM meeting information needs to be included in ATSDR's risk assessment.

On May 25, 1999, Dr. Lee gave a presentation, "Summery of Putah Creek Mercury Bioaccumulation Issues," to the Cache Creek Mercury Group. I have inclosed a copy of his presentation to be included in ATSDR's risk assessment information. Dr. Lee's presentation included a review of ATSDR's fish studies and raised concerns that UCD/LEHR may be contributing to the excessive mercury bioaccumlation in fish and the excessive bioaccumulation of chlorinated hydrocarbon in Putah Creek aquatic life. Until an adequate investigation of mercury and chlorinated hydrocarbons has been completed, UCD/LEHR cannot be eliminated as a contributor to the excessive bioaccumulation concerns in Putah Creek aquatic life. ATSDR's risk assessment will be incomplete without this information.

As discussed in Dr. Lee's report on the inadequacies of UCD's monitoring of the LEHR site, the full extent of groundwater pollution by LEHR site wastes is still unknown. The groundwater monitoring program that has been conducted at LEHR falls far short of a credible monitoring program for characterizing the risk that past UCD waste disposal practices at the LEHR site represent to public health and the environment.

DSCSOC asks that ATSDR consider the enclosed information and requests that all health and environmental risk pathways at the LEHR superfund site be adequately investigated before ATSDR completes its risk assessment. The LEHR site potentially impacted public is entitled to a risk assessment which adequately addresses all of their health and environmental risk concerns at the site.

Please contact Dr. Lee for additional information on any of these issues. Phone: 530-753-9630; E-mail: [email protected]


Julie Roth
Executive Director

cc: RPMs
Jane Riggan, CDHS

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