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P. 21/150: “Based on the odor, appearance, and the analytical laboratory results, the tar appears to be a petroleum-based substance; most likely “asphalt” or “asphalt cement”, a heavy petroleum product containing compounds with as many as 150 carbon atoms resulting from distillation of crude oil. Because the TPH extended range analysis is terminated at compounds containing approximately 40 carbon atoms, the reported analysis accounts for only 10% of the total mass of the sample.

The asphalt may have been used at the former aggregate mining operation to create asphaltic concrete for surfacing haul roads. The asphalt exposed in the stream channel is of limited lateral and vertical extent, though it may be possible that other deposits could exist elsewhere within the undocumented fill in the canyon. Geocon estimates that the volume of asphalt is approximately 12 cubic yards or less. Based on the analyses performed and the quantity of material, it is our opinion that this material does not represent an REC. In its present condition, the asphalt would not be suitable for use in fill and should be removed from the site and disposed of at a recycling facility or possibly at a Class III landfill if in solid form.”

EnviroReporter.com recommends that the petroleum-based substance, with high benzene content, be analyzed for the approximately 110 other carbon atoms, or 90% of the total mass of the sample that remains unaccounted for. We also concur with Geocon that this material be removed from the site and disposed of properly after it is correctly analyzed in DTSC’s lab and characterized in situ to determine its lateral and vertical extent.

P. 77/150: Test results of Polynuclear Aromatic Hydrocarbons include a result of 24.3 mg/kg for benzo(a)antracene which is 39.19 times its PRG of 0.62 mg/kg.

August 1, 2005: Runkle Canyon_Dade Moeller_Supplemental Soil Sampling for Strontium-90_82005

The results of this testing were analyzed in the January 19, 2006 article for Los Angeles ValleyBeat entitled “Hot Property.” As the article notes:

The retested locations were all radically lower in Sr-90 than in the previous tests conducted by GreenPark Runkle. In one spot tested, the state lab’s results were 490 times lower for Sr-90 than when it was tested in a 1999 survey. Oddly, the CDHS results for Sr-90 were from two-to-19 times less than the exact same split samples analyzed by Dade Moeller.
Each one of Dade Moeller’s readings is above Sr-90’s natural background at Runkle Canyon and even though that lab’s reading for the previously known hottest spot on the property is lower by nearly 30 times, it is still over eight times the background and nearly twice the EPA’s preliminary remediation goal for Sr-90.

EnviroReporter.com maintains that this Dade Moeller report not only was based on too few samples, but that it is highly inaccurate as well.

July 22, 2005: Runkle Canyon_Miller Brooks_June 2005 Groundwater Sampling Activites_72205

EnviroReporter.com has no comments on this sampling other than to note that they were conducted at the direction of the Regional Water Quality Control Board, Los Angeles (LARWQCB), to test for perchlorate and, interestingly, NDMA, neither of which was detected according to the report even though a reading of 330 μ/l was detected.

June 9, 2005: Runkle Canyon_Miller Brooks_Converse Soil & Groundwater Sampling Oversight_60905

EnviroReporter.com has no comments on this sampling.

April 1, 2005: Runkle Canyon_Dade Moeller_Sr-90 Radiological Health Risks Assessment- 042005

On page 14 of this 32-page PDF states “[The] risk to a typical Runkle Canyon resident would be much less than the target 1 x 10(-6) risk level and even less than 1 x 10(-7).” On page 15, Dade Moeller claims the result for residents who do not ingest soil or eat homegrown produce would be “closer to 2 x 10(-8). On page 16, the report states that an “open space” user’s “risk would be less than 1 x 10(-8).” On page 17, Dade Moeller asserts that for neighbors exposed to the dust of Runkle Canyon construction “would be 3.1 x 10(-10).

These estimations, not fully calculated in Dade Moeller’s report, do not jive with CDHS’ response to questions posed by the Radiation Rangers to the department. In an April 10, 2007 letter, CDHS states “[T]his soil concentration equates to approximately 5E-6 (5 in a million] cancer risk for future site residents using the EPA PRG…”

This means that, despite the unexplained math, Dade Moeller underestimates the cancer risk that CDHS calculates by factors ranging from 50 to 16,129 times. EnviroReporter.com maintains that Dade Moeller’s estimations are highly inaccurate and should not be used to estimate cancer risks for residents, open space users or neighbors exposed to construction dust of Runkle Canyon’s proposed development.

February 9, 2005: Runkle Canyon_Miller Brooks_Supplemental Rpt for Groundwater Sampling_20905

This report notes that chloroform was detected in two samples at 1.1 and 1.2 micrograms per liter (μ/l). EnviroReporter.com is not prepared at this time to determine the relevance of these results.

July 29, 2004: Runkle Canyon_Miller Brooks_Supplemental Site Assessment Rpt Groundwater_72904

On page 3 of this 93-page PDF, the report states: The samples collected from Well MW-I (MW-1 and DUP- 1 were reported to contain concentrations of NDMA at 3.2 nanograms per liter ng/L and 3.5 ng/L respectively. The data assessment stated that the concentrations of NDMA reported in the samples collected from Well MW-I should be considered suspect based on method blank contamination and internal standard failures.

EnviroReporter.com observes that this lab, and other labs used by the developers, have repeatedly discounted positive hits for contaminants as laboratory error which we find highly questionable.

March 31, 2004: Runkle Canyon_Miller Brooks_Source Evaluation Report_33104

Page 2 of this 50-page PDF state that the “SSFL facility is located at a higher topographic elevation than the [Runkle Canyon] Property; however, a steep ridgeline separates the facility from the Property (EDR, 2003).”

This is highly misleading. While indeed a steep ridgeline separates some of the lab from Runkle Canyon, a well-established 11-acre drainage leads off of Area IV of Rocketdyne leading directly down into Runkle Canyon.

This report does contain an excellent historical summary for Runkle Canyon stretching all the way back to the time of the Chumash.

March 31, 2004: Runkle Canyon_Miller Brooks_Groundwater Investigation Workplan_33104

On page 3 of this 26 page PDF, it states: No concentrations of perchlorate were detected in any of the water samples analyzed. Perchlorate was only detected in two groundwater/silt samples collected from Borings HS-25 and HS-26 samples HS-25-56 and HS-26-37. The concentrations detected were at 0.06 milligrams per kilogram (mg/kg) and 0.05 mg/kg respectively These levels are below the EPA’s Preliminary Remediation Goals for perchlorate in residential soil (7.8 mg/kg USEPA 2001/2002).

This is highly misleading and deceptive. The perchlorate was found in the Runkle Canyon groundwater of the groundwater/silt samples therefore to use PRGs for residential soil is not appropriate. Water standards show that the 0.06 mg/kg, or 60 ppb, exceeds the Public Health Goal in tap water by a factor of ten times.

February 26, 2004: Runkle Canyon_RWQCB_Request for Historical and Current Site Information_22604

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.

November 5, 2003: Runkle Canyon_Miller Brooks_DOGGR Files Review_110503

EnviroReporter.com has no comment on this report.

September, 17, 2003: Runkle Canyon_Miller Brooks_Site Investigation of Southern 715 Acre Parcel_91703

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.

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