The most notable aspect of the Department of Toxic Substances Control’s (DTSC) October 17, 2008 letter to KB Home wasn’t what was in the letter, but what wasn’t. While the memorandum directing the would-be developer of 461 homes in Runkle Canyon covers the possibility of additional radiation sampling for strontium-90, it doesn’t go much further other than than requiring the developer to remove seeps of the toxic and tar-like benzo(a)anthracene from two giant slag heaps in the canyon.
The letter addresses the chromium found in Runkle Canyon in rocks delivered to DTSC by the Radiation Rangers, rocks that the department didn’t realize were high in chromium until we wrote “White Blight – Runkle Canyon’s Chromium Conundrum” which was also a Ventura County Reporter cover story.
DTSC directs KB Home to come up with a way to clean up the benzo(a)anthracene tar-like substance that was found in several areas in two huge slag piles. The developer’s proposed 37-page Response Plan came back with a plan that is stunning in scope:
“Other areas of the channel walls within the vicinity of the seeps have been reported to contain similar material,” but assures that “Development plans for the Site include the mass grading and removal of the aggregate piles in the ‘Fish Tail’ area. If additional tar material is discovered during future grading activities it will be managed appropriately.”
We reported on this amazing plan, that seems in direct odds with DTSC’s presumption that removing the benzo(a)anthracene this will take little work to remove, in “Mountains of Goo – KB Home promises mass grading of Runkle Canyon” and also in the Ventura County Reporter.
But other than that, DTSC says it has looked at all the available reports on Runkle Canyon and that its direction to KB Home to clean up the place is adequate.
The Radiation Rangers heartily disagree.
“I sometimes wonder if were talking about the same place,” says the Reverend John Southwick of the Radiation Rangers. “Not only are DTSC’s orders to KB Home inadequate, unless the instructions for more radiation testing are significant; the department missed the most important stuff.”
EnviroReporter.com supplied the department an extensive Runkle Canyon contamination analysis of the 41 KB Home-supplied reports in July 2008, months before it came up with its own take on the canyon. This despite assurances inserted into the DTSC-KB Home cleanup agreement that the department would look at all information available.
Ignoring the vast majority of this analysis has the Rangers and other residents wary of DTSC’s impending Response Plan decision. They have told EnviroReporter.com that they doubt the department will even look at their comments, let alone respond to them.
“They try to talk a good game but it’s pretty clear they don’t take our input seriously,” says “Toxic Terry” Matheney of the Rangers. “But our comments are sound and have one objective – making sure that Runkle Canyon is safe for any people that may use the place whether they live there or not.”
EnviroReporter.com has selected some of the most salient points from the Radiation Rangers Runkle Canyon Response Plan comments to highlight while the final decisions are being made about this property we first wrote about over four years ago. They may not be considered by DTSC, as Southwick and Matheney say, but they are a comprehensive look at the contamination issues in the canyon:
1. Radiological Health Risk Assessment:
The Response Plan, prepared by KB Home’s Dade Moeller & Associates is inadequate in several areas including using the wrong radiation standards, faulty radiation analysis that includes blame on earlier developer labs for previous high strontium-90 soil readings, and a sampling plan that would only test one sample per 19 acres.
1A. Dade Moeller’s “Radiological Health Risk Assessment,” on page 10 of the Response Plan, states, “The parameter values and approaches of this assessment were generally consistent with those the National Committee on Radiation Protection and Measurements (NCRP) used to derive suburban and no food suburban (no home-grown vegetables soil screening limits in Report 120 (NCRP 1999).”
The methodology used by Dade Moeller is faulty as the NCRP relies on “dose-based” radiation limits versus the system of the Environmental Protection Agency (EPA) Preliminary Remediation Goals (PRGs) for radionuclides that DTSC uses for this development site. This misapplication of dose-based limits is unacceptable and must be corrected.
In the very next sentence, on page 10 of the Response Plan, Dade Moeller states, “The EPA Preliminary Remediation Goal (PRG) default scenario (EPA 2004) does not apply to Runkle Canyon because the proposed land use is well known and does not fit the default scenario.”
This is false – PRGs are absolutely the proper form of measurement used at Runkle Canyon and at a property like this. Furthermore, this is codified by DTSC in its Notice of Exemption for Runkle Canyon, at
_involvement/7937146842/RunkleNOE%5F2%2EDOC, where it states in part, “[C]oncentrations in soil do not exceed the United States Environmental Protection Agency Region 9 Preliminary Remediation Goal (PRG) which has been confirmed as a site specific cleanup level for this location.”
What is puzzling about the preceding is that Dade Moeller must certainly be aware of that PRGs are the “site specific cleanup level for this location.” To base their analysis of strontium-90 levels in Runkle Canyon on dose-based levels either suggests a failure to understand this concept adequately or something worse. This isn’t acceptable.