June 13, 2016

Mr. Robert Romero
DTSC Project Manager
5796 Corporate Avenue
Cypress, CA 90630-4732

Re: Second Public Comment Period, Draft Corrective Measures Proposed For Portion of Former Aerojet Facility

Dear Mr. Romero,

Thank you for this opportunity to comment on and ask a few questions about the Draft Corrective Measures Studies [CMS] for the Aerojet-Rocketdyne facility [AR] and the site’s future as noted in them. Following and attached please find our comments and questions.

In accessing DTSC’s AR website AEROJET CHINO HILLS FACILITY (80001476) (http://www.envirostor.dtsc.ca.gov/public/profile_report.asp?global_id=80001476), EnviroReporter.com [ER] found a number of reports related to the CMS and related, pertinent topics. Since DTSC’s Second Public Comment Period Notice did not specify which reports to comment on, we attempt herein to address the CMS at hand and the site in general considering the CMS covers the entire AR site and DTSC’s stated goals include full, unrestricted ‘clean’ closure for AR.

In submitting these comments and questions, we take note of the ER comments and questions submitted to DTSC May 1, 2009 (http://www.enviroreporter.com/files/Aerojet_OB-OD_report_COMMENTS-EnviroReporter.comx.pdf). ER never heard back from DTSC regarding these comments but in 2014, an ER reader told us that DTSC had responded in April 2010 (http://www.envirostor.dtsc.ca.gov/public/hwmp_community_involvement/5683164298/aerojetrtcfinalapril2010.pdf) nearly a year after submittal. A number of DTSC’s responses to ER’s 2009 comments are relevant to ER’s comments submitted here.

In general, ER’s comments include approval of your latest plan to excavate MEC-impacted soil much as we did in our online news organization’s media coverage of the mostly successful 2009 OB-OD cleanup at AR. As failure to inform ER of your response to our 2009 comments may indicate, DTSC could improve its communications with both the media and public that have shown expressed interest, such as ER has as evidence by our print and online coverage of AR since May 11, 2000 (http://www.enviroreporter.com/livingnexttoawarfactory).

ER addresses several of DTSC’s statements regarding radiological contamination at AR as it is brought up in these germane CMS reports. We also address what appears to be significant radiological contamination of sub-surface and surface waters at AR, the latter draining off the property into a ‘blue-line stream’ into a drinking watershed, all of which is protected by the Clean Water Act which DTSC has ignored or dismissed.

We also address apparent decisions not to adhere to keeping the risk of an individual living at the site from an individual contaminant causing a fatal cancer to one in a million or less. This is contrary to representations made about the site in earlier reports as our comments will indicate.

Our bottom line is that DTSC has missed or ignored radiological implications at the site that preclude it from becoming residential property under its existing Rural Agricultural zoning. It’s just too hot. ER does believe, however, that if the current CMS is carried out without modification, and radiation runoff is allowed to continue with no further action to remedy it, the AR site is still probably suitable for open space future use and, as well, a cemetery.

Our comments and questions, following, are organized by sourcing information, and sometimes underlining it, followed by italicized questions if necessary.

Thank you again for this opportunity to comment on this important topic that we will also be reporting on.

Michael Collins & Denise Anne Duffield
EnviroReporter.com

Comments of EnviroReporter.com Draft Corrective Measures Proposed For Portion of Former Aerojet Facility

COMMENT 1:

The CMS shows that this ‘portion’ of AR is, in fact, all of AR making issues relevant to the entire site relevant to these comments on the CMS. (http://www.envirostor.dtsc.ca.gov/public/community_involvement/4555103898/Aerojet%20Initial%20Study_Final_10292015%20with%20signatures.pdf; P. 3/31: MAs 1 and 2 consist of the northern and southern portions of the former AR facility and several adjacent properties
(Figure 3; Area and Management Unit Designations, Amec Foster Wheeler, 2015). [ER emphasis]

P. 6/31 of this DTSC PDF says that “The project includes excavation of approximately 14,600 cubic yards (yd3) of potential MEC-containing soil (13,000 yd3 from the Ordnance Fuze Test Unit/Area West of HEI Pond and 1,600 yd3 from Area 10) and transport to a temporary holding area (Area 1C) located in the central portion of the Facility. This would require the use of scrapers, water truck, excavator, and a crawler tractor (bulldozer) over a 16-day period as noted below:”

ER thinks this is a sound idea and will be successfully undertaken much like the well-done work done remediating the OB-OD in 2009.

COMMENT 2:

The 56-page PDF dated September 23, 2015 entitled “COMMUNITY ENGAGEMENT PLAN, AEROJET CHINO HILLS… (EPA ID NO. CAD981457302)” at http://www.envirostor.dtsc.ca.gov/public/community_involvement/4246839225/Signed%20CEP.pdf is the subject of several comments and questions:

Background Comment 2
The above linked DTSC public community involvement document is germane to comments/questions on the CMS as it explains it in detail. [We refer to page numbers based on which page(s) it is based on the PDF’s pages, not the original documents, for clarity and ease of access.]

P. 21/56 says – “Aerojet Rocketdyne performed a complete facility investigation, taking more than 2,200 soil and water samples. Sampling results showed there were no levels of chemicals posing risk to human health or the environment in surface waters inside the facility or migrating beyond the facility boundaries.”

Comment 2
This is false. Uranium is a chemical as well as a radionuclide. Also, as DTSC’s 2009 response to ER comments confirms, 0.0885 mg/L of uranium has been found in surface water leaving the AR site via Soquel Canyon Creek, which drains the site according to numerous DTSC reports and other authorities. It is a ‘blue line’ stream and protected by the Clean Water Act. It also is a drinking water source as it flows into one as ER proved in 2009 comments.

“The Soquel Canyon Creek streambed is considered a riparian habitat. It is mapped as an intermittent blue line stream on the United States Geological Survey (USGS) map (USGS,
2014).” (CORRECTIVE MEASURES STUDY FOR MUNITIONS AND EXPLOSIVES OF CONCERN MANAGEMENT AREA 1; Page 30/151 pages; http://www.envirostor.dtsc.ca.gov/regulators/deliverable_documents/1395022332/Corrective%20Measures%20Study%20Management%20Area%201%20Text%20Tables%20Plates%20and%20Appendices.pdf)

According to the federal Department of Energy, to convert mg/L to pCi/L of natural uranium, one multiples mg/L times 675.7 to obtain the correct result, something that DTSC did not do in its 2010 response to ER’s 2009 comments (http://www.lm.doe.gov/Fernald/2010ASER_unitsconversns.pdf)

Therefore, 0.0885 mg/L x 675.7 = 59.8 pCi/L which is 3.0 times the State of California’s Maximum Contaminant Level (MCL) for uranium in drinking water. This MCL violation is in conflict with the above-cited statement.

The following DTSC comment on page 21/56 of the community involvement report is also false: “[C]hemicals/materials of concern identified at the facility have been removed to levels below residential cleanup criteria, with the exception of MEC.”

Will DTSC address this high uranium periodically leaving the AR site and going down Soquel Canyon Creek since a 2014 USGS document proves it is a blue-line stream?

COMMENT 3:

Background Comment 3
Citing same 56-page PDF dated September 23, 2015 entitled “COMMUNITY ENGAGEMENT PLAN, AEROJET CHINO HILLS… (EPA ID NO. CAD981457302)” at http://www.envirostor.dtsc.ca.gov/public/community_involvement/4246839225/Signed%20CEP.pdf

P. 22/56: Under “Future Site Use” is “Reuse alternatives would likely consider former land uses on the site and clean up. For example, outlying buffer lands and administrative areas where ordnance activities did not occur may be identified for potential residential reuse. The small canyons that served a testing areas could be excavated to bedrock and backfilled with verified clean fill, thereby providing locations to place the roads that would serve residential resuse.”

Comment 3
The idea of filling small canyons with clean dirt for new residential roads ignores geologic considerations such as sinkage and drainage. Modifying canyons in such a manner does not seem wise.

COMMENT 4:

Background Comment 4
Citing same 56-page PDF dated September 23, 2015 entitled “COMMUNITY ENGAGEMENT PLAN, AEROJET CHINO HILLS… (EPA ID NO. CAD981457302)” at http://www.envirostor.dtsc.ca.gov/public/community_involvement/4246839225/Signed%20CEP.pdf

Page 28 (&32)/56: “The Chino Hills Community Engagement Website, created and maintained by Aerojet Rocketdyne, and developed as part of this CEP, can be found at www.rocket.com/chino.”

Comment 4
This is false. There is no such website nor has there ever been.

Why is there no website or community participation group as claimed in this 2015 DTSC report?

COMMENT 5:

Background Comment 5

Citing same 56-page PDF dated September 23, 2015 entitled “COMMUNITY ENGAGEMENT PLAN, AEROJET CHINO HILLS… (EPA ID NO. CAD981457302)” at http://www.envirostor.dtsc.ca.gov/public/community_involvement/4246839225/Signed%20CEP.pdf

P. 42/56 PUBLIC INVOLVEMENT FACT SHEET #3 AUGUST 2005 (P. 43-44/56): “DU cleanup activities were conducted under the regulatory oversight of the State Department of Health Services, Radiologic Health Branch (DHS). Cleanup standards were based on radiologic health risk (cancer endpoint) and the final report was submitted to DHS in July 2003. In September 2004, DTSC concluded its review of a DU Health Risk Assessment. Levels of DU at the site in soil, surface water and groundwater were found to be within acceptable human health based levels.” [ER emphasis]

Comment 5
This is confusing. This says there was a health risk report “submitted to DHS in July 2003” yet no such report exists on its DHS/now CDPH website.

Where is that radiologic health risk report and DTSC’s DU Health Risk Assessment. Levels of DU at the site in soil, surface water and groundwater?

COMMENT 6:

Background Comment 6
In an October 17, 2000 DTSC report entitled “NOTICE OF DECISION FOR
APPROVAL OF CORRECTIVE MEASURES FOR THE AEROJET ORDNANCE –
CHINO HILLS FACILITY,” that used to be available at
http://www.envirostor.dtsc.ca.gov/public/hwmp_community_involvement/1269406974/Aero%2520CEQA%252Epdf.pdf, it read on page 50 of the 75-page PDF:

All contamination exceeding cleanup levels will be removed such that the site-wide
carcinogenic risk will be less than 1 x 10(-6)
and the site-wide hazard index for a child
will be less than 1 0 for a future residential land use scenario.” [ER emphasis]

Comment 6
Clearly, a health risk assessment is far laxer than the site-wide 1 x 10(-6) cleanup level which ER has seen promised in the “NOTICE OF DECISION FOR APPROVAL OF CORRECTIVE MEASURES FOR THE AEROJET ORDNANCE – CHINO HILLS FACILITY” and in other reports and declarations. If AR is to be released for unrestricted use with allowed residential building, the public and City of Chino Hills better be very clear on just which and what level DTSC and Aerojet-Rocketdyne are really cleaning the radionuclides and chemicals up to.

So which is it? Is AR going to be cleaned to a health risk level or to the oft-promised 1 x 10(-6) cleanup level? Do you plan to make this abundantly clear to the public exactly what that means in terms of chances of developing cancer from living at the site depending on the differing cleanup levels?

COMMENT 7:

Background Comment 7
The October 15, 2008 DTSC AR report “CORRECTIVE MEASURES COMPLETION REPORT ADDENDUM” at http://www.envirostor.dtsc.ca.gov/public/community_involvement/1884229362/CM%20Completion%20Addendum%202008.pdf is 150 PDF pages and states on page 37/150:

4.2.1 Test Range 16 Soil Sampling and MEC Screening Activities
To assess whether demilitarization activities conducted after 2001 resulted in new impacts to
soil in the eastern portion of Test Range 16, two grab-type samples (C-AC05-S-03-N-0.5 and
C-AC05-S-04-S-0.5) were collected on May 10, 2006 at a depth of 0.5 foot from backfill
material subject to these demilitarization activities (see Figure 12). Duplicate sample SW10-05
was also collected from sample location C-AC05-S-03-N-0.5. These soil samples were
analyzed for explosive compounds and metals. Analytical results were reported as follows:
• RDX was detected in sample SW10-05 at a concentration of 0.68 mg/kg.
• HMX was detected in sample C-AC05-S-03-N-0.5 and duplicate sample SW10-05
at concentrations of 1.0 and 0.86 mg/kg, respectively.
Metals barium and cobalt were detected at maximum concentrations of 110 and 7.3
mg/kg, respectively, which is above background levels (see Section 6.1) but not at
levels that pose a threat to human health (see Section 6.2.1.3).
Calculations of the cumulative effect of the explosive compounds and the metals barium and cobalt detected in Test Range 16 backfill soil demonstrate that they do not pose a threat to human health (see Section 6.2.1.3).
The AOC No. 5 – Test Range 16 soil sample analytical results are summarized in Table 4. [ER emphasis]

Comment 7
ER looked at the high levels of metals found in AR soils and compared them to the Background Threshold Values (BTVs) of the heavy contaminated Santa Susana Field Laboratory (SSFL) in Ventura County http://www.dtsc-ssfl.com/files/lib_cbs%5Cresults_report%5Ctables/65396_SSFL_Chemical_Background_Study_Table_7_Chemical_Analytes_-_Summary_of_Background_Threshold_Value_Results.pdf. These BTVs were derived during a $41.5 million EPA study of the site and are well matched to represent the background levels of said metals in AR soils.

In Rural Residential zoning in general, the BTV of a contaminant is as close as one will get to assuring a safe 1 x 10(-6) cancer risk. Yet here at AR, massive amounts of dangerous metals are contaminating the soils yet are getting a “no further action” pass by DTSC.

For example, in the “CORRECTIVE MEASURES COMPLETION REPORT ADDENDUM” cited in this comment above says:

Cadmium, molybdenum, and selenium were detected in sample C-AC05-S-01-N
and duplicate sample C-MHJ-S-16N at concentrations significantly higher than
background
levels.
Arsenic, cadmium, chromium, molybdenum, selenium, and vanadium were detected
in sample C-AC05-S-02-S at concentrations significantly higher than background
levels
. [ER emphasis]

Then it says “no further action” status for this area. That is unacceptable and not what you’re telling the community.

On P. 71/150 page DTSC PDF cited above, ER found that the highest level of perchlorate found in the “SWMU 2-former landfill” was : 0.69 mg/kg or 852.9 times SSFL’s perchlorate BTV. In the “concrete block area,” perchlorate was 395.6 x SSFL perchlorate BTV. The “stockpiles in Test Range 1C” were 123.7 x SSFL Perchlorate BTV. All three areas were declared safe with “no further action.”

ER comments that these levels of heavy metals and perchlorate in soil are unacceptable and must be remediated should this land ever be used for residences. We find it astonishing, but sadly not surprising, that DTSC would find so much contamination and do so little about it.

COMMENT 8:

DTSC and AR would do well to level with the citizens of Chino Hills and surrounding communities the levels of chemicals, including radioactive ones like uranium, will be left behind once this CMS is completed. The health and well-being of future residents and the environment are at stake.

ER’s comments herein show that uranium in surface water running off of AR is three times the State’s Maximum Contaminate Level for the radioactive heavy metal chemical. DTSC’s 2010 response to ER’s 2009 comments revealed that subsurface water at AR hit 0.404 mg/L, or 147.8 pCi/L of uranium. That’s 7.4 times the States Maximum Contamination Level.

That untreated water, which could be removed with existing uranium-removal technology (http://www.eai-labs.com/assets/docs/radioactive_in_water.pdf), flows into the aquifer that provides drinking water for millions of Southern Californians. That may prove unacceptable to many of the folks who learn of the ‘hot water’ Aerojet-Rocketdyne in Chino Hills is in.

Thank you again for this opportunity to comment.