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1N. February 26, 2004: “Runkle Canyon_RWQCB_Request for Historical and Current Site Information_22604” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/1295774161/Runkle%20Canyon_RWQCB_Request%20for%20Historical%20and%20Current%20Site%20Information_22604.PDF

Miller Brooks’ attempt to characterize the perchlorate in Runkle Canyon groundwater as a ‘soil’ event warranting the use of soil standards is disingenuous and suspicious considering what the RWQCB says on page 1 of this 4 page PDF: Information obtained by the Regional Board indicates that activities with the potential to release Perchlorate to soil and groundwater may have occurred on your property.
The Regional Board believes that it is important to accurately know the distribution of Perchlorate in the vicinity of your site. Therefore we are requiring that you install properly designed and constructed shallow groundwater monitoring wells at the two locations where Perchlorate was reported in groundwater/silt samples. The samples must be analyzed by laboratory utilizing rigorous QA/QC protocols.

Based on the persistent and mobile nature of Perchlorate soil conditions the depth to groundwater the suspected release of hazardous materials at the site may have contaminated soil and groundwater. Pursuant to section 13267 of the California Water Code you are hereby directed to submit historical and current site information to be used to determine specific sources of the groundwater pollution detected at your site and to document your efforts in technical reports.

EnviroReporter.com finds that Miller Brooks’ attempt to characterize the perchlorate as existing in soil/silt versus groundwater not only is false, but it thwarts the will of the RWQCB. Subsequently, however, the RWQCB seems complicit in what could be accurately characterized as a charade on the part of the developer’s lab.

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

1O. September, 17, 2003: “Runkle Canyon_Miller Brooks_Site Investigation of Southern 715 Acre Parcel_91703” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/6386975944/Runkle%20Canyon_Miller%20Brooks_Site%20Investigation%20of%20Southern%20715%20Acre%20Parcel_91703.PDF

P. 2/63: No detectable concentrations of strontium-90 were found in surface soil and shallow soil samples at the Site or in the offsite background samples Based on the results of this and previous investigations strontium-90 poses no residential health risk at the Site.

Miller Brooks took these soil samples and sent them to Casper, Wyoming-based Energy Laboratories. That lab tested the samples employing techniques that only had detection sensitivity of 2.0 to 10 pCi/g, or nine to 43 times too insensitive to even ascertain the EPA’s preliminary remediation goal for Sr-90.

P. 2/63: Two water samples were collected at the Site and analyzed for tritium. Concentrations of tritium detected in water at the Site are below the EPA standard for drinking water and are within normal background concentrations. The levels of tritium detected in water at the Site are most likely associated with recent recharge of groundwater from rainfall.

EnviroReporter.com disagrees with this speculation that the tritium comes from rainfall recharge, whatever that means. Rocketdyne’s Area IV, where the lab nuclear work was done and which has an 11-acre drainage into Runkle Canyon, has a major tritium groundwater plume. Indeed, the Jewish day camp Brandeis-Bardin sued Boeing over tritium contamination on its land in the 1990s and won a confidential settlement that included Boeing buying a large tract of land contaminated by tritium from Brandeis-Bardin. That land is now labeled “undeveloped land” on maps of SSFL on the northwestern and northern borders of Rocketdyne. Activists assert that when Boeing officials claim that no tritium contamination has migrated “offsite,” the officials are being disingenuous because they purchased that offsite land as part of the lawsuit settlement.

EnviroReporter.com does not disagree with the activists’ analysis. Considering this obvious source of tritium contamination, we disagree strongly with the relatively benign-sounding explanation for tritium detections that Miller Brooks utilizes here.

P. 4/63: Based on an additional statistical analysis of the 17 samples (Samples SS-1 through SS-17; Figure two) duplicate samples. Samples SS-18 and SS-19 collected on the Site the average strontium-90 concentration was calculated at 0.88 pCi/g and the 95 percent upper confidence limit of the mean was calculated at 1.4 pCi/g (Table 1). Therefore, on average, the strontium-90 concentrations detected in soil are lower than the acceptable standard for strontium-90 calculated by Foster Wheeler (1.23 pCi/g). Although the 95 percent upper confidence limit is higher than the 1.23 pCi/g the difference is not statistically significant. The incremental cancer risk associated with strontium-90 concentration of 1.4 pCi/g is 0.55 in a million which is lower than the incremental cancer risk of in million that is considered acceptable by California health and environmental protection regulatory agencies Robles 2003 and Foster Wheeler 1999.

Analysis of these 41 documents provided to DTSC by KB Home reveals a disturbing pattern: the propensity to make generalizations not based on fact and to assert risk-based conclusions without mathematically proving them. The preceding section is no exception to this pattern.

“Therefore, on average, the strontium-90 concentrations detected in soil are lower than the acceptable standard for strontium-90 calculated by Foster Wheeler (1.23 pCi/g),” is a statement not based on anything EnviroReporter.com can find in regulatory guidance or standard scientific practice. The EPA’s Preliminary Remediation Goal (PRG) for strontium-90 is 0.230 pCi/g which is exceeded by this Foster Wheeler calculated result by a factor of 5.35 times, or a cancer risk of 5.35 in a million, far exceeding the developers’ labs oft-stated goals of less than one in a million.

Likewise this unsubstantiated claim: “The incremental cancer risk associated with strontium-90 concentration of 1.4 pCi/g is 0.55 in million…” This result actually calculates to be 6.09 times the EPA’s PRG which is exceeds the 0.55 in a million figure by a factor of over 11 which is quite a mistake in our analysis of the data.

P. 6/63: Environmental investigations conducted at neighboring properties showed that strontium-90 was present in soil at concentrations that were deemed to be either within background concentrations or at levels considered to pose no significant health risk (Robles 2003).

This is incorrect. Elevated strontium-90 soil readings above background concentrations were found at the adjacent Brandeis-Bardin Institute in two dozen samples according Boeing’s 1995 McLaren/Hart report “Additional Soil and Water Sampling – The Brandeis-Bardin Institute and Santa Monica Mountains Conservancy,” which is cited in this report.

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

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