[KB Home’s Runkle Canyon development is now called Arroyo Vista at the Woodlands]

This timeline presents an analysis of information generated by licensed laboratories that should trip DTSC guidelines to precipitate further soil, surface water and subsurface water testing in Runkle Canyon. This information was submitted to DTSC on July 3, 2008.

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SUMMARY
In an e-mail to Simi Valley resident Frank Serafine dated May 20, 2008, Norm Riley, Department of Toxic Substances Control (DTSC) Project Manager for the cleanup of the Santa Susana Field Laboratory (SSFL or Rocketdyne), wrote, “We understand there are concerns about contamination [in Runkle Canyon], but those have yet to be substantiated by scientific proof. We are continuing with our evaluation and will keep the public informed.”

EnviroReporter.com and other citizens of Simi Valley (primarily the residents group “Radiation Rangers”) respectfully disagree. Information has been generated by licensed laboratories that, while not comprehensive enough, should trip DTSC guidelines to precipitate further soil, surface water and subsurface water testing at the site.

For example, in the first analysis presented herein, “Rock with White Evaporate,” heavy metal levels found at Runkle Canyon exceed the Department of Energy’s own levels that call for further investigation.

The Rangers have always maintained that the developer’s Environmental Impact Report (EIR) is inadequate and needs to be done over. After examining the 41 documents supplied by KB Home as well as the additional testing and information related to the site, EnviroReporter.com concurs.

Furthermore, there is evidence contained herein that the developers’ and the city of Simi Valley’s labs utilized inappropriate testing methodologies and either inadvertently or deliberately misinterpreted results or didn’t test at all for certain contaminants.

This document looks at the data already generated on the site, data that DTSC has either not inspected, inspected closely, or has already dismissed out of hand even when the data is a result of DTSC’s own lab results as was the case with the “rock with white evaporate” sample given to Riley by Serafine May 18, 2008.

This analysis covers material included, and not included, in KB Home’s 41 documents given to the Department of Toxic Substances Control as part of the agreement the company and agency signed by DTSC’s Norm Riley April 23, 2008. According to the agreement, a report on these documents is/was due 75 days after the signing of the agreement which would be July 7, 2008. Those documents are analyzed under a separate document entitled “KB Home 41 document analysis.”

EnviroReporter.com endeavored to submit this analysis to DTSC well before that deadline, as well as posting it on its website, however was delayed by analyzing the results of DTSC’s laboratory testing of rock with white evaporate. DTSC’s report on this evaporate contains lab testing results but no other analysis other than to characterize the material as a “salt evaporate” two weeks before the lab results were obtained. We feel that the delay is justified especially considering that our analysis of the white evaporate revealed regarding alarmingly high levels of chromium and other heavy metals.

This document contains information not provided to DTSC by KB Home, some of which is not analyzed by EnviroReporter.com because the information itself does not need our analysis or interpretation. Other material does include our analysis including various reports submitted by KB Home that overlap with the “KB Home 41 document analysis.”

This document/web page contains a summary that includes our focus and materials, the contents of the analysis with supporting documentation, and our conclusions.

EnviroReporter.com was not compensated by any person or entity for this work which took several weeks to complete and was submitted to DTSC on July 3, 2008 and posted on our website thereafter. It is our hope, however, that the department actually exercise due diligence inspecting these materials and not simply dismiss them as seems to be the case with the rock with white evaporate lab results which showed high heavy metal concentrations including chromium which was not further analyzed for valences.

Focus and materials

This investigation of Runkle Canyon pollution issues began in 2004 and is ongoing for several newspapers and EnviroReporter.com. Comprehensive analysis of a large number of known Runkle Canyon-related environmental documents is provided in order to further this investigation and to educate and inform our readers.

This examination will also provide assistance to California-EPA’s Department of Toxic Substances Control as they investigate Runkle Canyon, the first phase of which is analysis of written documentation provided to the department by the developer. These documents were provided DTSC by KB Home as part of their April 11, 2008 agreement that we reported on in our April 24, 2008 Ventura County Reporter article “Reassessing Runkle.”

The agreement also states that DTSC will be examining the developer-related documents “as well as additional reports and appendices, tables and figures, correspondence, and other documents.” Our analysis falls into this later category.

EnviroReporter.com is also completing this ongoing work at the request of the Simi Valley citizens group, the Radiation Rangers, who have provided material assistance to us, in the form of photographic documentation, sample collection and lab analysis. The Rangers have requested that this analysis be included in DTSC’s documents investigation as part of their public comment in this process.

This document examines environmental data, much in the form of 41 reports, provided to DTSC by the developers, KB Home. We address those documents as well as those not included in the KB Home portfolio including the Radiation Rangers May 18, 2007 Pat-Chem report that focused on heavy metals that the developer’s Environmental Impact Report failed to test. We examine the subsequent July 2, 2007 City of Simi Valley Tetra Tech report which also found higher levels of some heavy metals than the Rangers’ test and additional ones of concern. We also include studies and data relevant to Runkle Canyon that are not included in the aforementioned material.

Contents

See timeline

Conclusions

The information analyzed in this document demonstrates that the developer’s Environmental Impact Report, approved in 2004 and previously reported on extensively by EnviroReporter.com, shows abnormally high strontium-90 soils readings. A retesting of Sr-90 in the soil by the developer last year came in over 100 times less than previously and averaged less than a quarter of the area’s normal background for the substance. The Rangers questioned these results and pointed out that the city of Simi Valley’s split samples, which yielded the same results, was in fact an outdated testing technique from 1967 and therefore unreliable.

* The Rangers maintain that a new EIR must be performed with the soil again retested under the supervision of DTSC with samples tested at DTSC’s laboratory to ensure accuracy utilizing current testing methodology. EnviroReporter.com concurs.

* The KB Home-provided documents show that the developer did not test for heavy metals in Runkle Canyon’s soil or water other than on a small patch of asphalt. Not included in the documents, but provided herein, are the results of limited tests for heavy metals conducted by the Rangers and the city of Simi Valley which show high levels of arsenic, nickel, vanadium, cadmium, chromium and lead. Water running down Runkle Canyon ends up in the Arroyo Simi watershed which currently supplies 20% of Simi Valley’s blended tap water.

* The Rangers maintain that more extensive tests of Runkle Canyon’s soil and surface water for heavy metals is necessary to assess the potential threat to human, animal and plant life. The city’s lab also recommends additional testing for these heavy metals and to determine where they came from. EnviroReporter.com concurs with the recommendation that the in-situ sampling be under the supervision of DTSC and that DTSC provide lab analysis.

* Additionally, the Rangers recommend that the local water purveyor be told of the vanadium in the surface water which exceeds the Notification Level. They also suggest that the water purveyor inform its customers of this contaminant threat and how it deals with it before it reaches the consumer. EnviroReporter.com agrees that the law be followed in this matter but has no position otherwise.

* The Santa Susana Field Laboratory’s former nuclear testing Area IV borders Runkle Canyon and has 11-acre drainage into it. On December 13, 2007, lab owner Boeing submitted an Offsite Data Evaluation Report for the Santa Susana Field Laboratory to DTSC that includes evidence that toxic trichloroethylene (TCE) had been detected in Runkle Canyon groundwater.

* However, the report says that “Runkle Canyon and the SSFL do not share a common property boundary,” when maps in the document show that it clearly does. The document goes on to say “No environmental investigations have been performed by Boeing, NASA, or DOE on the Runkle Canyon property” when the map showing the TCE hits in Runkle groundwater is on page 184. Perhaps ironically, the last page of this report combines the two falsehoods, showing the groundwater sampling spot on Runkle Canyon and the common Rocketdyne border and says, in conclusion, “Offsite sampling sufficient with no data gaps.”

* The Rangers recommend that DTSC investigate these discrepancies and also determine whether Runkle Canyon’s contamination is result of lab off-site migration. They also recommend that if DTSC determines that radiological and/or chemical pollution found in the canyon, using as sources all the reports cited in EnviroReporter.com’s analysis and further testing as the department decides and orders, that Boeing pay for any past and/or additional sampling, lab analysis and any short-term, medium-term and long-term remediation. EnviroReporter.com concurs with the recommendation to determine if the lab is the source of the radiological and/or chemical contamination in Runkle Canyon.

* On March 27, 2008, Rangers Frank Serafine and Rev. John Southwick espied extensive white evaporate on an area where it had not previously been seen since the last time they had visited the area, which was before the winter rains. Nothing was growing where this unusual distribution of white evaporate/precipitate occurred. The two men gathered some of this material and gave it to DTSC’s Norm Riley at that evening’s quarterly Santa Susana Field Laboratory Workgroup meeting. DTSC tested this material and shared the results with the Rangers who then imparted them to EnviroReporter.com for analysis.

* Abnormally high amounts of chromium, iron, molybdenum, nickel and potassium were found in the white precipitate. The chromium registers over 20 times the Department of Energy’s Preliminary Action Levels for “industrial” zones, of which Runkle Canyon is not, over 6 times EPA Region 9’s Preliminary Remediation Goal for the metal, and over 35 times the average amount of total chromium found throughout SSFL’s soil.

* The Rangers recommend that DTSC retest this white material to determine the valence ratio of trivalent and hexavalent chromium. They also recommend that the material be tested for other possible contaminants and that DTSC try to “fingerprint” the source of such material. EnviroReporter.com concurs and further recommends that corrective action and remediation take place if the material is found to contain dangerous amounts of hexavalent chromium and, if it does, direct that KB Home and the city of Simi Valley immediately post warning signs by the contamination as well as on the perimeter of the Runkle Canyon property. EnviroReporter.com also recommends that DTSC investigate the substrata hydrogeologic conditions that may have transported this material off of SSFL and resulted in this phenomenon.

* The Tetra Tech report notes that the July 2, 2007 city of Simi Valley sampling yield surface water vanadium readings up to9.33 times the OEHHA’s Notification Limit (NL) for vanadium and 2.8 times the CDHS vanadium NL. The average reading of these four samples is 0.102 which is 6.8 times the OEHHA NL for vanadium and double the CDHS vanadium NL. Geocon itself collected a surface water sample that contained the highest amount of vanadium sampled in Runkle Canyon to date: 0.17 mg/kg. The Geocon vanadium result is 12.67 time OEHHA’s NL and 3.4 times the CDHS vanadium NL. The Radiation Rangers request that the local water purveyor be informed of these facts so it can inform its customers of the presence of vanadium in a source for their drinking water and what the local water purveyor is doing about it. EnviroReporter.com concurs.

* A reading of 330 parts per billion of perchlorate was detected in Runkle Canyon’s groundwater, five times higher than any detection there before. The Rangers request that wells MW-1 and MW-2 be reactivated in order to further test the groundwater. EnviroReporter.com concurs.

* There has been benzene in a tarry material found in Runkle Canyon that is nearly 55 times its PRG for residential soil, the limit of which is 0.62 mg/kg and that, according to the EPA’s 2004 PRG list for contaminants, exceeds the chronic, 100% chance of contracting a cancer from this substance which is 33 k/g/mg. The Rangers agree with the developer’s lab that the substance should be removed and deposited in a proper dump.

* Test results of Polynuclear Aromatic Hydrocarbons include a result of 24.3 mg/kg for benzo(a)antracene which is 39.19 times its PRG of 0.62 mg/kg. The Rangers and EnviroReporter.com recommend further investigation of this contamination.