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 time OEHHA’s NL and 3.4 times the CDHS vanadium NL.
July 26, 2007: Runkle Canyon_Geocon_ Surface Water and Soil Sampling Results_72607
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.
July 13, 2007: Runkle Canyon_Geocon 70207 Surface Water and Soil Sampling_71307
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.
April 5, 2007: Runkle Canyon_RWQCB_Approval to Abandon Wells_40507
According to this report:
In addition to perchlorate all samples were analyzed for n-nitrosodimethylamine (n-NDMA). Initial groundwater samples were also analyzed for volatile organic compounds VOCs. One groundwater sample collected from M\V-2 in March of 2006 contained 2.8 nanograms per liter ng/L n-NDMA.
The [NDMA] detected concentration is also below the DHS Notification Level 10 ng/L and the California Office of Environmental Health Hazard Assessments Draft Public Health Goal 3 ng/L.
EnviroReporter.com considers the RWQCB decision to abandon these wells to be a mistake considering the perchlorate, trichloroethylene and now NDMA that has been detected in Runkle Canyon groundwater. The Radiation Rangers concur and recommend that the wells again be monitored for these and other contaminants.
November 29, 2006: Runkle Canyon_RWQCB_Army Corp of Engineers Notification Letter_112906
The RWQCB’s Executive Officer Jonathan Bishop states in this document:
The results of prior sampling and analysis were provided the Regional Board in earlier reports. The wells were installed in May 2004, at the request of the Regional Board, to permit groundwater sampling, with correct field techniques, to determine if perchlorate was present in groundwater beneath the site. No significant perchlorate has been detected in groundwater.
This statement is false. The July 22, 2004 Los Angeles CityBeat/ValleyBeat cover story “Two Mile Island” addresses this issue:
Despite the failure of the Ahmanson Ranch development and the fierce opposition to Rocketdyne ever being developed for housing without a stringent cleanup, three developments are springing up within two miles of SSFL. The drainage for the dioxin-polluted Old Conservation Yard at the lab heads down toward a newly approved housing project in Runkle Canyon. The project is slated for 461 homes within a mile of the radiological area of SSFL – much closer than Ahmanson Ranch. Samples collected January 8 during an environmental review of a 550-acre portion of the 1,595-acre site, indicated levels of perchlorate at 50 ppb and 60 ppb in two of four groundwater/silt specimens. This is approximately double the 28 ppb reading of perchlorate found in the groundwater under Ahmanson Ranch.
The above article snip is based upon the results of a January 8, 2003 groundwater sampling done by Miller Brooks, on page 15 of the 146-page PDF that is linked and analyzed in the September, 17, 2003: Runkle Canyon_Miller Brooks_Surface Water&Groundwater Sampling Rpt_91703 entry analyzed below.
June 6, 2005: Runkle Canyon_Miller Brooks_March 2006 Groundwater Sampling Activities_60605
Note: DTSC has this report listed as March 6, 2005 (instead of 2006)
P. 1/70: EnviroReporter.com does not agree with Miller Brooks recommendation, later agreed to by LARWQCB, that wells MW-1 and MW-2 be no longer tested and abandoned because there is ample evidence that the groundwater of Runkle Canyon should be monitored for the foreseeable future due to the high levels of perchlorate previously found, and the verified presence of TCE, NDMA and other potential contaminants of concern.
September 6, 2005: Runkle Canyon_Geocon_Phase I & Limited Sampling_90605
P. 5/150: “Analytical results of surface water samples collected from East and West Seeps in Fishtail Area that are not produced in a report. Samples were collected by Miller Brooks on April 5, 2005.”
P. 7/150: “Perchlorate was detected at a concentration of 0.33 micrograms per liter (μg/l) in a duplicate sample during the first sampling event. According to the laboratory this reported concentration should be considered suspect based on retention time drift and potential co-elution of an interfering constituent. None of the other samples or duplicate samples were reported to contain perchlorate.”
That equals 330 ppb in groundwater. Ahmanson was 28 ppb therefore Runkle is over 11 times more.
According to OEHHA at http://www.oehha.org/public_info/facts/perchloratefacts.html the Public Health Goal is 6 ppb in drinking water.
Runkle Canyon groundwater has tested as high as 55 times the Public Health Goal for perchlorate.
P. 7/150: “Historic pumping depressions at Rocketdyne have limited the movement of degraded groundwater beneath the property and have essentially confined the extent of known groundwater contamination to the area beneath the facility. Offsite migration of degraded groundwater has been identified in isolated areas along the northwest and eastern property boundaries. The perchlorate plume reportedly extends offsite of the facility to the east and southeast (southeast of the Runkle Site). The TCE in groundwater is reportedly present in several well-defined plumes that remain predominately beneath the Rocketdyne facility with a limited area offsite to the north of the western end of the property (west of the Runkle Site).
The preceding contradicts itself on one of the biggest points – offsite migration of degraded groundwater. Which is it? If the lab doesn’t know, or does and decides to mischaracterize the situation even while contracting itself, the lab’s veracity is questionable.