2019 UPDATE
EnviroReporter.com analysis of Runkle Canyon documents and tests – KB Home-supplied 41 reports
This timeline analyzes 41 reports that KB Home supplied to DTSC as part of their “Voluntary Cleanup Agreement” of Runkle Canyon in December 2007. DTSC is the lead agency to oversee a new agreement that would clean up the Santa Susana Field Laboratory up to strict EPA Superfund standards. EnviroReporter.com submitted a partial analysis of these documents to DTSC on July 3, 2007 followed by a complete analysis of them on July 6, 2007.
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December 18, 2007: Runkle Canyon_Dade Moeller_Sr 90 Sampling Report_121807
Dade Moeller’s tested 63 soil samples from Runkle Canyon for strontium-90. Test results are so low that they average a quarter of normal background for strontium-90 in area. On January 7, 2008: Radiation Ranger Rev. John Southwick questioned the city of Simi Valley as to how both Dade Moeller and the city’s lab, Environmental Inc. Midwest Laboratory, could have come up with such low results for strontium-90 in Runkle’s soil.
Southwick wrote:
“KB Homes has tried to assure the citizens of Simi Valley that the land is safe from Sr-90 contamination and generated their own Dade Moeller report which shows an average of 0.014 pCi/g for the 63 soil samples collected during the October 2007 sampling. This average is just 26.9% of the EPA’s background number for strontium-90 in the area – over 100 times less than what was tested for in 1999 by the developer’s lab.
“The Dade Moeller report, shared with us after you provided it to Collins, also deserves explanation as it is just 10 pages and does not show, among other things, the kind of laboratory analysis that was performed. We request that you ask KB Homes for the entire report and that they provide it in the spirit of openness and trust that KB Homes claims to be attempting to create with the citizens of Simi Valley.”
EnviroReporter.com concurs with these concerns noted in Southwick’s following/linked letter:
Southwick demands explanation of suspect strontium-90 readings.
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October 30, 2007: Runkle Canyon_Larry Walker_Water Quality Issues Lttr_103007
Larry Walker Associates’ Tetra Tech analysis for Simi Valley deems Runkle Canyon safe. “None of the surface waters in the Simi Valley area,” the analysis says, “are designated as having a [Municipal and Domestic Supply] beneficial use. Therefore, the State drinking water standards do not apply to Runkle Canyon or downstream surface waters.”
However, the very Tetra Tech report it was supposed to analyze says “Potential human consumption of surface water is reasonably possible under the Municipal and Domestic Supply, Water Contact Recreation, and Non-contact Water Recreation beneficial use scenarios. In these types of situations, water quality criteria, such as the MCLs, PRGs, PHGs, and NLs, may be used as screening values to determine whether further evaluation of surface water may need to be considered.”
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October 26, 2007: Runkle Canyon_L33278_Report of Analysis_1026207
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above.
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October 26, 2007: Runkle Canyon_L33276_Report of Analysis_102607
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above. Project ID# KB001-3EREG-07
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October 26, 2007: Runkle Canyon_L33284_Report of Analysis_102607
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above.
Project ID# KB001-3EREG-07
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October 26, 2007: Runkle Canyon_L33277_ Report of Analysis_102607
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above.
Project ID# KB001-3EREG-07
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October 25, 2007: Runkle Canyon_L33275_Report of Analysis_102507
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above.
Project ID# KB001-3EREG-07
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October 24, 2007: Runkle Canyon_L33274_Report of Analysis_102407
This Teledyne Brown Engineering, Inc. document contains a section of the data that makes up the Dade Moeller report dated December 18, 2007 commented on above.
Project ID# KB001-3EREG-07
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August 10, 2007: Runkle Canyon_Geocon_Summary of Arsenic and Other Metals Results_81007
KB Home’s consultant, Geocon Consultants, Inc. 1) 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). 2) The consultant incorrectly compares background values from various reports instead of utilizing the benchmark Kearney report on California soils partly written by DTSC. 3)Also, Geocon does not include the Radiation Ranger’s May 18, 2007 report in its analysis even though the lab used by the Rangers, Pat-Chem, was the same lab the city of Simi Valley used on July 2, 2008, the report of which is included in the consultant’s analysis.
1. Geocon compared the heavy metal results to the California Environmental Protection Agency (Cal-EPA) California Human Health Screening Levels (CHHSLs) for residential land use. The developer’s consultant fails to note CHHSL’s disclaimer which reads in part:
This document is not intended to establish policy or regulation. The Human Health Screening Levels presented here are not to serve as: 1) a stand-alone decision making tool, 2) a substitute for guidance for the preparation of baseline human health risk assessments, 3) a rule to determine if a waste is hazardous under the state or federal regulations, 4) a rule to determine when the release of hazardous chemicals must be reported to the overseeing regulatory agency, 5) set of final cleanup or action levels to be applied at contaminated sites or 6) a guarantee that an oversight regulatory agency will determine that a project is adequately studied or agree with the conclusions of the site investigation and risk assessment report.
[snip]
The CHHSLs should NOT be used to determine when impacts at a site should be reported to a regulatory agency. [their emphasis]
Yet the report notes that “Arsenic is the only metal reported for the soil samples and asphaltic material sample at concentrations in excess of CHHSLs. The CHHSLs for arsenic, which are 0.07 milligrams per kilogram (mg/kg) for residential land use…”
However, the EPA’s PRG for arsenic in residential soil is 0.062 mg/kg meaning that the Ranger’s result of 34 mg/kg was 548 times this and the city of Simi Valley’s lower result was still more than 20 times the PRG.
As we have noted below and in our articles, there were significantly high amounts of nickel, vanadium, barium, cadmium, chromium and lead found in both the Rangers’ and the city of Simi Valley’s tests as well.
2. Geocon used the wrong background numbers for comparison to the Runkle Canyon results. According to the Kearney report, for example, arsenic averages 3.5 mg/kg in California soil making the 34 mg/kg result nearly ten times that. According to the September 2005 “Soil Background Report” for the Santa Susana Field Laboratory for Boeing, NASA and the Department of Energy, Table 4.1 shows the lab’s average reading for arsenic, from 41 samples tested, is 5.246 mg/kg which the 34 mg/kg result exceeds by over six times. These are more accurate background comparison values than the ones Geocon used.
3. By not including the Rangers’ Pat-Chem report, Geocon has skewed the results even though the lab’s limited sampling was just as valid as the city of Simi Valley’s limited sampling.
The preceding information, and the information of our Runkle Canyon Investigation, EnviroReporter.com maintains that Geocon is making a false conclusion at the end of the soils part of its report that isn’t based on sound science and also ignores an obvious possible source for the contamination – Rocketdyne:
Based on the reported historic use of the Site there does not appear to be a potential man made source of the arsenic reported in the soils. Because the reported concentrations of arsenic fall within the published ranges of naturally occurring arsenic, and the fact that a potential man made source for arsenic at the site is not apparent from the reported historical use of the property, it is our opinion that the arsenic reported in the soil is naturally occurring and does not warrant additional investigation.
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.
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