This timeline presents an analysis of information generated by licensed laboratories that should trip DTSC guidelines to precipitate further soil, surface water and subsurface water testing in Runkle Canyon. This information was submitted to DTSC on July 3, 2008.
In an e-mail to Simi Valley resident Frank Serafine dated May 20, 2008, Norm Riley, Department of Toxic Substances Control (DTSC) Project Manager for the cleanup of the Santa Susana Field Laboratory (SSFL or Rocketdyne), wrote, “We understand there are concerns about contamination [in Runkle Canyon], but those have yet to be substantiated by scientific proof. We are continuing with our evaluation and will keep the public informed.”
EnviroReporter.com and other citizens of Simi Valley (primarily the residents group “Radiation Rangers”) respectfully disagree. Information has been generated by licensed laboratories that, while not comprehensive enough, should trip DTSC guidelines to precipitate further soil, surface water and subsurface water testing at the site.
For example, in the first analysis presented herein, “Rock with White Evaporate,” heavy metal levels found at Runkle Canyon exceed the Department of Energy’s own levels that call for further investigation.
The Rangers have always maintained that the developer’s Environmental Impact Report (EIR) is inadequate and needs to be done over. After examining the 41 documents supplied by KB Home as well as the additional testing and information related to the site, EnviroReporter.com concurs.
Furthermore, there is evidence contained herein that the developers’ and the city of Simi Valley’s labs utilized inappropriate testing methodologies and either inadvertently or deliberately misinterpreted results or didn’t test at all for certain contaminants.
This document looks at the data already generated on the site, data that DTSC has either not inspected, inspected closely, or has already dismissed out of hand even when the data is a result of DTSC’s own lab results as was the case with the “rock with white evaporate” sample given to Riley by Serafine May 18, 2008.
This analysis covers material included, and not included, in KB Home’s 41 documents given to the Department of Toxic Substances Control as part of the agreement the company and agency signed by DTSC’s Norm Riley April 23, 2008. According to the agreement, a report on these documents is/was due 75 days after the signing of the agreement which would be July 7, 2008. Those documents are analyzed under a separate document entitled “KB Home 41 document analysis.”
EnviroReporter.com endeavored to submit this analysis to DTSC well before that deadline, as well as posting it on its website, however was delayed by analyzing the results of DTSC’s laboratory testing of rock with white evaporate. DTSC’s report on this evaporate contains lab testing results but no other analysis other than to characterize the material as a “salt evaporate” two weeks before the lab results were obtained. We feel that the delay is justified especially considering that our analysis of the white evaporate revealed regarding alarmingly high levels of chromium and other heavy metals.
This document contains information not provided to DTSC by KB Home, some of which is not analyzed by EnviroReporter.com because the information itself does not need our analysis or interpretation. Other material does include our analysis including various reports submitted by KB Home that overlap with the “KB Home 41 document analysis.”
This document/web page contains a summary that includes our focus and materials, the contents of the analysis with supporting documentation, and our conclusions.
EnviroReporter.com was not compensated by any person or entity for this work which took several weeks to complete and was submitted to DTSC on July 3, 2008 and posted on our website thereafter. It is our hope, however, that the department actually exercise due diligence inspecting these materials and not simply dismiss them as seems to be the case with the rock with white evaporate lab results which showed high heavy metal concentrations including chromium which was not further analyzed for valences.
Focus and materials
This investigation of Runkle Canyon pollution issues began in 2004 and is ongoing for several newspapers and EnviroReporter.com. Comprehensive analysis of a large number of known Runkle Canyon-related environmental documents is provided in order to further this investigation and to educate and inform our readers.
This examination will also provide assistance to California-EPA’s Department of Toxic Substances Control as they investigate Runkle Canyon, the first phase of which is analysis of written documentation provided to the department by the developer. These documents were provided DTSC by KB Home as part of their April 11, 2008 agreement that we reported on in our April 24, 2008 Ventura County Reporter article “Reassessing Runkle.”
The agreement also states that DTSC will be examining the developer-related documents “as well as additional reports and appendices, tables and figures, correspondence, and other documents.” Our analysis falls into this later category.
EnviroReporter.com is also completing this ongoing work at the request of the Simi Valley citizens group, the Radiation Rangers, who have provided material assistance to us, in the form of photographic documentation, sample collection and lab analysis. The Rangers have requested that this analysis be included in DTSC’s documents investigation as part of their public comment in this process.
This document examines environmental data, much in the form of 41 reports, provided to DTSC by the developers, KB Home. We address those documents as well as those not included in the KB Home portfolio including the Radiation Rangers May 18, 2007 Pat-Chem report that focused on heavy metals that the developer’s Environmental Impact Report failed to test. We examine the subsequent July 2, 2007 City of Simi Valley Tetra Tech report which also found higher levels of some heavy metals than the Rangers’ test and additional ones of concern. We also include studies and data relevant to Runkle Canyon that are not included in the aforementioned material.
March 2008: Rock with White Evaporate — Material collected in Runkle Canyon by the Radiation Rangers and tested by DTSC. EnviroReporter.com article, analysis and photographs are included in our investigation of this disturbing phenomena.
January 10, 2008: Southwick receives Environmental Inc’s laboratory techniques for detecting strontium-90. The techniques are from 1967 by a federal agency that is no longer in existence.
January 10, 2008: Simi Valley’s assistant city manager Laura Behjan sends a letter explaining Dade Moeller’s activities and confirming that the outdated Environmental Inc. laboratory techniques were the same ones that had been used to test the Runkle Canyon soil samples.
January 7, 2008: Radiation Ranger Rev. John Southwick questions 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 demands explanation of suspect strontium-90 readings.
December 27, 2007: Simi Valley’s Laura Behjan sends Southwick the Environmental Inc. report on the ten “split samples” that the city took to cross check Dade Moeller’s results. They also read only a quarter of typical background.
December 18, 2007: Dade Moeller radiological report on 63 soil samples from Runkle Canyon tested for strontium-90. Test results are so low that they average a quarter of normal background for strontium-90 in area.
December 14, 2007: MWH “Offsite Data Evaluation Report – Santa Susana Field Laboratory – Ventura County, California” for Boeing, Department of Energy (DOE), and NASA shows trichloroethylene (TCE) found in ten percent of Runkle Canyon groundwater samples taken. Report claims, however, no sampling in Runkle Canyon had taken place.
October 30, 2007: 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.”
September 20, 2007: Simi Valley letter to Larry Walker Associates asks for “expert opinion” on its Tetra Tech report. “Do the test results indicate that contact with the water and/or soil presents a risk to the public,” the letter asks. “Is there any action the City is obligated to take (e.g., reporting to regulatory agencies) in view of the test results [?]”
August 23, 2007: Ventura County Reporter article “Spin Cycle” shows how city’s testing revealed higher levels of heavy metal pollution. “[A]rsenic found in one soil sample, about a quarter of what was detected by the Rangers,” the article says. “[E]ven the lower reading was more than 20 times the federal Environmental Protection Agency’s “preliminary remediation goal” (PRG) for arsenic in residential soil.”
The reading for arsenic, which causes bladder and lung cancers as well as diabetes, developmental problems, gastrointestinal illness and heart disease, was 25 percent higher. That translates to 26,478 times tap water’s PRG and 47,000 times California’s “public health goal” for the toxin in drinking water.
Another regulated heavy metal found by the Rangers in Runkle Canyon water, barium, was detected at levels 233 percent higher than the citizens’ sampling. Nickel came in 33 percent higher and vanadium 55 percent more elevated than the earlier tests. That is 2.8 times the “notification level” which are “health-based advisory levels for chemicals in drinking water … when a chemical is found in or threatens drinking water sources,” according to California’s Office of Environmental Health Hazard Assessment.
Chromium …was detected at 20 percent higher than the state’s “maximum contaminant level” (MCL) for tap water. Cadmium was found at nearly three times more than the PRG for tap water and 700 times the public health goal… Lead was also discovered in the city’s water samples with the highest reading 33 percent higher than the state’s MCL for the metal.
August 20, 2007: EnviroReporter.com‘s Tetra Tech report analysis highlights important passages of reports and its mistakes.
August 14, 2007: The city of Simi Valley’s Tetra Tech report gives contradictory signals on the safety of Runkle Canyon. While getting many key facts wrong, the 88-page document recommends further and more expansive testing. (Note: the Tetra Tech report is 22 MB and takes a few minutes to load.)
July 26, 2007: The Radiation Rangers’ website StopRunkledyne.com’s “Runkledyne Arsenic” analysis which shows that Pat-Chem’s arsenic result is many times over Rocketdyne’s arithmetic mean and should warrant “further investigation” according to Boeing’s lab.
June 21, 2007: Analysis of Pat-Chem report by EnviroReporter.com included in Los Angeles CityBeat cover story “The Radiation Rangers”:
Surface water readings for arsenic are 15 times the MCL for drinking water, over 21,000 times the EPA’s “preliminary remediation goal” and 37,500 times the agency’s “public health goal” for potable water.
The mud sample was laced with arsenic as well, coming in at over 548 times the EPA’s preliminary remediation goal for the contaminant in soil. That amount of the toxin is also 213 percent of the Department of Toxic Substances Control (DTSC) arsenic “field action level,” where further investigation is warranted.
Nickel was over 12 times the EPA’s public health goal in water and vanadium came in at 1.8 times the notification level which is a threshold at which the most local government entity should be informed.