When KB Home signed a Voluntary Cleanup Agreement with the Department of Toxic Substances Control on April 14, 2008, the company subsequently released 41 documents for DTSC inspection.
EnviroReporter.com analyzed these 41 documents and presented its findings to DTSC on July 3, 2008. We also provided detailed analysis of other critical documents including the sampling and tests done in the canyon by the Radiation Rangers and the city of Simi Valley.
The department did not respond to either. We even went to the effort of making these analyses easily accessible on our Runkle Canyon Interactive Timelines page. It seemed that almost none of this work was looked at by DTSC as evidenced by the department’s October 17, 2008 instructions to KB Home to come up with a Response Plan.
DTSC’s process didn’t allow comment on this document. The public, and the media, can only comment on the KB Home’s Response Plan. In the case of Runkle Canyon, significant contamination has been simply ignored.
When we began the “Railroading Runkle Canyon?” series, DTSC’s Norman E. Riley was the Project Manager for Runkle Canyon. Now he is gone and we quoted the acting director of the department, Maziar Movassaghi, in “Coup de Goo” as saying “This department takes the public comments very seriously. We’re going to look at Runkle Canyon with clean eyes.”
EnviroReporter.com’s Runkle Canyon Response Plan Comments concentrate on these 41 reports and the information in them that, in most cases, was ignored in DTSC’s instructions to KB Home and as reflected in the developer’s draft plan.
Will the new Rocketdyne and Runkle Canyon Project Manager, Rick Brausch, look at these comments, and the others we’ve posted and analyzed in this series, and glean from them important information that will assist in assessing the problems in the canyon? Will Brausch have competent team members ready and willing to tackle these data and incorporate them into the final cleanup plan?
If history is any teacher, the answer is no. The reporting on this website regarding Runkle Canyon, Aerojet Chino Hills and Corporate Pointe at West Hills, shows a repeated pattern of incompetence, unsound science and ignorance of environmental law.
Yet a glimmer of light now shines as DTSC has made a major move to right the listing ships that are called the Rocketdyne and Runkle Canyon cleanups. Perhaps Brausch will seize the opportunity to use these analyses which his department has so far failed to do.
Following are EnviroReporter.com’s Runkle Canyon Response Plan comments:
February 13, 2009
Mr. John Naginis, DTSC Senior Engineering Geologist
9211 Oakdale Avenue
Chatsworth, CA 91311
Regarding: Michael Collins’ comments and questions regarding the Runkle Canyon Response Plan
1. There are a number of very important problems with the developer’s 41 submitted reports that are analyzed on my website EnviroReporter.com at http://enviroreporter.com/files/KB41docs.pdf and I request that DTSC closely examine these documents and incorporate any information therein into their final determination of environmental conditions at Runkle Canyon.
These documents have and will impact DTSC’s decisions about Runkle Canyon. I have clipped the relevant sections and, as is our practice above, put our questions to DTSC in italics bracketed by *asterisks*.
Please answer our questions as they are relevant and crucial to a full understanding of environmental conditions in Runkle Canyon as related by these 41 documents KB Home supplied DTSC.
1A. October 30, 2007: Runkle Canyon_Larry Walker_Water Quality Issues Lttr_103007
Larry Walker Associates’ Tetra Tech analysis for Simi Valley deems Runkle Canyon safe. “None of the surface waters in the Simi Valley area,” the analysis says, “are designated as having a [Municipal and Domestic Supply] beneficial use. Therefore, the State drinking water standards do not apply to Runkle Canyon or downstream surface waters.”
However, the very Tetra Tech report it was supposed to analyze says “Potential human consumption of surface water is reasonably possible under the Municipal and Domestic Supply, Water Contact Recreation, and Non-contact Water Recreation beneficial use scenarios. In these types of situations, water quality criteria, such as the MCLs, PRGs, PHGs, and NLs, may be used as screening values to determine whether further evaluation of surface water may need to be considered.”
*1A. Is DTSC aware of this City analysis and the appropriateness of it? Please explain and comment.*
1B. August 10, 2007: “Runkle Canyon_Geocon_Summary of Arsenic and Other Metals Results_81007” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/4707166373/Runkle%20Canyon_Geocon_Summary%20of%20Arsenic%20and%20Other%20Metals%20Results_81007.pdf
KB Home’s consultant, Geocon Consultants, Inc. 1) mischaracterizes the amount of heavy metals found in Runkle Canyon by using a set of standards not as protective of public health as the EPA’s “preliminary remediation goals” (PRG). 2) The consultant incorrectly compares background values from various reports instead of utilizing the benchmark Kearney report on California soils partly written by DTSC. 3)Also, Geocon does not include the Radiation Ranger’s May 18, 2007 report in its analysis even though the lab used by the Rangers, Pat-Chem, was the same lab the city of Simi Valley used on July 2, 2008, the report of which is included in the consultant’s analysis.