History of UCD/DOE LEHR Site
The Laboratory for Energy-Related Health Research (LEHR) Superfund Site occupies approximately 15 acres on the south campus of the University of California, Davis (UCD) in Solano County, California. (The main portion of the UCD campus is in Yolo County). The LEHR facility was founded in 1951 by the U. S. Atomic Energy Commission (AEC) which later became the Department of Energy (DOE). The facility was operated by UCD for AEC and DOE. Portions of the area that were leased by AEC-DOE for the facility were used by UCD as campus landfills for radioactive, chemical, and solid wastes.
Activities at the Site
In 1957 a major project at the LEHR site was initiated by the AEC to study the biological effects of chronic, low-level exposure of the skeleton to beta particle irradiation from deposits of the bone-seeking radionuclide, strontium-90. More than 1,000 beagles were used over the course of that study. The beagle was chosen as the experimental subject because they could be studied in sufficient detail to scale the results to human populations that might be exposed. To assist in the scaling of the results from tests on beagles to expected risks in humans, a parallel study was conducted utilizing the bone-seeking radionuclide radium-226. In those studies, one group of beagles was fed a diet containing strontium-90 or intravenously injected with strontium-90, and another group of beagles was intravenously injected with radium-226.
The Radiobiology Laboratory at the LEHR site grew as the main project expanded, and the research interests of the laboratory broadened to consider all aspects of the radiobiological effects of irradiation of the skeleton. Special interest in cellular biology focused on the blood-forming and immunological functions of bone marrow cells and their alteration by ionizing-radiation. In the early 1970's, an outdoor cobalt-60 Irradiation Field was constructed for study of the effects of chronic exposure to penetration of gamma rays on bone marrow cells of beagles. In 1985, the decision was made to permanently suspend the use of the outdoor irradiator after an investigation revealed that there was no feasible corrective action that could be taken to reduce possible exposure of humans at the LEHR boundary to radiation levels below the DOE 25-millirem-per-year action level during continued outdoor use. The cobalt-60 irradiator continued to be used for indoor irradiation of specimens until 1989.
In 1975 the Radiobiology Laboratory at LEHR initiated a program in basic aerosol science to evaluate the relationship of airborne materials and the laboratory study of these materials utilizing cellular and animal models. Research activities in that program focused on the potential health effects of release to the atmosphere of combustion products from fossil fueled power plants, with emphasis on coal fly ash.
In 1983, the Toxic Pollutant Health Research Laboratory (TPHRL) was developed at the south campus site for the study of highly toxic and carcinogenic agents, including both radioactive and chemical materials. Using laboratory animals, impacts from exposure to toxic materials by dermal, intravenous, oral-gastrointestinal, intratracheal, and inhalation routes were studied. The work at TPHRL included the impact of plutonium-241 and americium-241 on the behavior of beagles and monkeys; radioactive and toxic gas-particle mechanistic aerosol studies; monodisperse aerosol inhalation deposition studies; intratracheal applications of carcinogen-coated particles; and an organic vapor uptake study, utilizing beagles.
At the LEHR site, UCD maintained three campus landfills, numerous waste disposal seepage pits, waste disposal trenches and pits, and a chemical dispensing area. Much of the waste from the LEHR projects, some of which was highly toxic, was disposed of on-site in these various unlined landfills, trenches, and pits.
Characteristics of the Surrounding Area
Much of the storm and surface water runoff from the LEHR site goes directly to Putah Creek. In this area, the Creek is used by local citizens for swimming, fishing, and other forms of water recreation, and by local farmers to irrigate their fields. The aquifer beneath the LEHR site is used as a primary domestic water supply for the city of Davis and other communities in the region, as well as an agricultural water supply.
Early Investigations of LEHR Site Pollution
In March 1988, DOE’s Environment Survey Preliminary Report on the LEHR site was released. That study concluded that that facility was affected by a number of "chronic environmental problems" which varied in terms of their magnitude and risk. In 1989, DOE announced it was terminating its operating contract with UCD. DOE and UCD implemented a site characterization study to assess the potential environmental problems associated with the past operation practices. The US Environmental Protection Agency (US EPA) (through its contractor: Ecology and Environment, Inc.) began its assessment of the site for inclusion on the National Priorities List (NPL) of Superfund Sites. In 1990, the US EPA issued its recommendation for the LEHR site, which included calling for a "High-Priority Superfund Site Investigation." In May of l994, the LEHR site was listed as an NPL Superfund Site.
Citizen Involvement
Prior to the site’s becoming a Superfund Site, area citizens were concerned about the impact of the wastes at the LEHR site on area surface and groundwater resources, and public health. The affected citizens protested that DOE and UCD were not adequately or reliably investigating the portions of the site that impacted groundwater quality and posted a health risks to the citizens of the area. Instead, the majority of the investigation/remediation work at the site was being done on the DOE facilities so DOE could be relieved of further responsibility for the site and return it to UCD for its use. It was not until the LEHR site received the Superfund designation that the US EPA and the other Remedial Project Managers (RPMs) (Department of Public Health, Department of Toxic Substances Control, and Central Valley Regional Water Quality Control Board) became the lead agencies, that DOE and UCD began to respond to the public's concern about the impacts of LEHR and UCD waste management practices, and initiated efforts to investigate the areas of primary concern to the public.
There is a high potential for release of LEHR contaminants to surface water and stormwater, much of which goes directly to Putah Creek. Because the Creek in this area is used for contact and non-contact recreation and irrigation, concerned citizens asked, to no avail, that the Creek be posted to warn the public of possible pollution.
When LEHR received its US EPA Superfund Site designation, the Davis community's affected citizens became eligible for the US EPA's Technical Assistance Grant (“TAG”) program to provide funds for citizens to hire an independent technical advisor to evaluate US EPA Superfund investigation/remediation documents. The affected citizens organized as the Davis South Campus Superfund Oversight Committee (DSCSOC) and applied for a TAG Grant, which it was awarded in April 1995. In June 1995, DSCSOC hired Dr. G. Fred Lee as its technical advisor. Since that time, the potentially impacted citizens have had an opportunity for an independent review and evaluation of the UCD/DOE and RPM-developed LEHR documents.
General Findings and Problems with LEHR Site Investigation and Remediation
Some of the waste from the various unlined landfills, trenches, and pits has migrated to soil and groundwater; the groundwater under the site has been polluted by radioactive and hazardous wastes, and other deleterious chemicals. Polluted groundwater has moved off-site where it has affected near-by properties. While the full extent of the groundwater pollution is still under investigation, it is known to extend more than a mile under adjacent properties.
An effective monitoring program has not been instituted for assessing all the potential impacts of the site on stormwater runoff characteristics or on surface water, including near-by Putah Creek. The potential public health risks to the citizens are still being evaluated. The Agency for Toxic Substance and Disease Registry (ATSDR) conducted a health risk assessment at LEHR, including a bioaccumulation study focusing on the accumulation of hazardous chemicals in fish and other aquatic life in Putah Creek to levels that would represent a threat to the health of those who ate the organisms. ATSDR found that fish taken from Putah Creek contained excessive concentrations of mercury compared to human health guidelines. Stormwater runoff from LEHR has been found to contain sufficient mercury to add to the excessive mercury bioaccumulation in Putah Creek fish. A stormwater runoff management program is being developed to prevent excessive mercury in stormwater runoff from LEHR.
Problems with LEHR Site Investigation and Remediation
TAG citizens’ groups and their technical advisor(s) are not allowed to do independent investigations at a Superfund Site, nor do they have any enforcement powers. At the LEHR site, all DSCSOC can do is present its concerns to the responsible parties (DOE and UCD), and the RPMs in the hope that they will consider them. Until recently, DSCSOC has had limited success. Not only are the two responsible parties both taxpayer-supported institutions, but also UCD is the dominant economic power in Davis and Yolo County. It has not been easy to get those powerful institutions to effectively address the public's concerns.
The investigation of the environmental quality impacts of the site has been inadequate and unreliable in many respects. Errors have been made, and work has had to be repeated. Deadlines have been missed, and time-lines have been repeatedly extended. Taxpayers’ money has been wasted. The sloppy mismanagement of waste that caused this site to be a Superfund Site continues, yet there have been no fines, penalties, or sanctions issued for the creation of the mess or for the wasteful investigation. The no-fault agreements between DOE and UCD seem to have removed responsibility, accountability, motivation, incentive, quality, and care at this site. Overall, the investigation at this site has not been adequate or entirely reliable, and has been excessively slow.
Availability of Information Developed by DSCSOC on the LEHR Site
DSCSOC pledged to make the information developed by its technical advisor available to the affected citizens and others. In addition to making those documents available to be downloaded from its website, DSCSOC held Town Meetings at which its technical advisor reported to the Davis community his review of the past year's site activities. DSCSOC also invited other agency representatives to report on issues of concern to the citizens at those Town Meetings. Additional information on theAt the close of 2008, the LEHR site had been investigated for pollutants normally considered at Superfund sites, and DOE and UCD were in the process of preparing remediation plans for the site. However, due to the US EPA’s obstruction in the renewal of the TAG grant for the LEHR site in the winter of 2009/2010, DSCSOC was disbanded, and the technical oversight of the activities at the LEHR site that DSCSOC had been providing on behalf of the public, ceased; a discussion of this situation has been provided. Questions still remain about presently unknown, unrecognized, and unregulated pollutants at the site that may need remediation in the future.
While DSCSOC has been disbanded, G. Fred Lee & Associates, with permission of the former Executive Director of DSCSOC, maintains the DSCSOC website in order to preserve the public’s access to the substantial amounts of information and insight produced through the efforts of DSCSOC into the investigation and remediation of the LEHR site. Further, Dr. G. Fred Lee may be contacted at [email protected] for information concerning his former technical oversight activities at the LEHR site.
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