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Geocon’s analysis of heavy metals found in Runkle Canyon surface water is disingenuous and misleading. In part, it states:

Vanadium was the only metal present in the water samples at concentrations exceeding MCLs or PRGs. There is no established MCL for vanadium. Concentrations of vanadium exceeding the PRG of 0.036 milligrams per liter (mg/l) were reported for two of the surface water samples collected at the Site. However, PRGs are screening levels for use in evaluating tap water. Because the proposed development for the Site does not currently include plans to supply drinking water to the development from onsite sources it is our opinion that further evaluation with respect to the concentrations of vanadium in the surface water is unwarranted. Should plans for the development change to include use of the surface water for water supply, the Client is advised that continued monitoring for metals and treatment for vanadium may be required prior to delivery of the water to consumers.

The first two sentence of the preceding paragraph are obviously contradictory. In addition, the rest of the paragraph paints a false picture. EnviroReporter.com failed to note in previous analysis that the Notification Level (NL) for vanadium is 0.015 mg/l according to the Office of Environmental Health Hazard Assessment (OEHHA).

The NL is a tripwire level where the local water purveyor advised to warn consumers of “presence of the contaminant and about the health concerns associated with its exposure,” according to California Department of Health Services (CDHS) which has a higher level for vanadium’s NL. This has not occurred in Simi Valley.

According to OEHHA:

Staff of the Office of Environmental Health Hazard Assessment (OEHHA) have reviewed the Department of Health Service’s proposed action level of 50 ug/L of vanadium, derived from the U.S. Environmental Protection Agency’s (U.S. EPA) Health Effects Assessment Summary Tables (HEAST), fiscal year (FY) 1997 (U.S. EPA, 1997). OEHHA does not concur with this proposed Notification Level, and recommends that the Notification Level be set at 15 ug/L of vanadium.

The Tetra Tech report notes that the July 2, 2007 city of Simi Valley sampling yield surface water vanadium readings of 0.096 mg/kg, 0.062 mg/kg, 0.14 mg/kg and 0.11 mg/kg.

The highest reading is 9.33 times the OEHHA’s 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.

Despite these facts, Geocon goes on to anecdotally compare Runkle Canyon’s surface water vanadium levels to the background concentrations of the contaminant in the groundwater of 12 California Air Force Bases. This is specious and misleading.

In the “Document Summary” of this Geocon document, the consultant continues to misuse CHHSLs and mischaracterize background values for arsenic. However, it is notable that 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 times OEHHA’s NL and 3.4 times the CDHS vanadium NL.

*1B. Could DTSC respond in detail to the above observations?*

1C. July 26, 2007: “Runkle Canyon_Geocon_ Surface Water and Soil Sampling Results_72607” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/7789243400/Runkle%20Canyon_Geocon_%20Surface%20Water%20and%20Soil%20Sampling%20Results_72607.pdf

EnviroReporter.com’s analysis of this sampling event is contained in the discussion above, dated August 10, 2007 and entitled “Runkle Canyon_Geocon_Summary of Arsenic and Other Metals Results_81007.”

As it did in its summary, Geocon 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).The consultant again incorrectly compares background values for heavy metals instead of utilizing the benchmark Kearney report on California soils.

There are a number of details in this July 26, 2007 report worth noting. On page 4 of 42 pages total, the Geocon document correctly states the following:

Notification Levels are advisory levels for water purveyors and are not enforceable standards. If a chemical is detected above its Notification Level, then a water purveyor is required to notify the local government agency. Further, if a Notification Level is exceeded, then the CDHS recommends that the water purveyor inform its customers and consumers of the presence of the chemical and the potential health concerns associated with exposure to it. Vanadium is the only metal detected for which there is an established Notification Level. The concentrations of vanadium of 0.064 and 0.17 mg/l, respectively reported for the two water samples Creek 1 and SW-2 exceed the Notification Level of 0.05 mg/l.

There has been no indication as of the time of sending this EnviroReporter.com analysis to DTSC, July, 3, 2008, that the water purveyor has fulfilled this recommendation.

On page 24 of this report, there is a notation under “Special Instructions/Comments” that says “LAB TO FILTER METALS SAMPLES” which is not explained. EnviroReporter.com cannot determine at this time if this filtering skewed the results lower than they actually are. We would recommend that DTSC ask Geocon Project Manager, Michael Conkle, why these samples were filtered. This filtering is again referred to on page 42, the last page of this report, also by Conkle.

*1C. Could DTSC respond in detail to the above observations?*

1D. July 13, 2007: :Runkle Canyon_Geocon 70207 Surface Water and Soil Sampling_71307” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/1761045157/Runkle%20Canyon_Geocon%2070207%20Surface%20Water%20and%20Soil%20Sampling_71307.pdf

This report, as noted above, Geocon again 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).The consultant again incorrectly compares background values for heavy metals instead of utilizing the benchmark Kearney report on California soils.

There are a number of details in this July 13, 2007 report worth noting. On page 3 of 26 pages total, the Geocon document says:

The laboratory was directed to filter and preserve the water samples we collected (“Downstream A,” and “Upstream A”) upon receipt.

Geocon does not state who directed it to filter the water samples or why.

On the same page, 3, of this report, Geocon states:

None of the four water samples submitted were reported to contain concentrations of arsenic equal to or greater than the laboratory reporting limit of 0.010 milligrams per liter (mg/l).

The four water samples Geocon analyzed were “split-samples” that the sampling lab, Pat-Chem also analyzed with arsenic results ranging up to 0.18 mg/l. This means that Geocon’s result is less than 1/18th that of Pat-Chem’s result for the same water sample. Another lab, AETL, also tested these same split samples and had two identical results of 0.12 mg/kg. Geocon’s result is less than 1/12th that of AETL’s result for the same water sample.

These significant discrepancies bring into serious question the accuracy of Geocon’s lab analyses. These discrepancies also extend to their analysis of other heavy metals in the split-samples of surface water and soils.

Indeed, the Geocon and Dade Moeller reports seem to fit a pattern of contamination results that are either a fraction of the split-samples they have tested and/or are just a fraction of previous developers’ labs results. The Radiation Rangers maintain that this is more than enough reason for KB Home to be required to perform an entirely new Environmental Impact Report. EnviroReporter.com concurs with this opinion.

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