To: Director, Office of Regulation Policy and Management (00REG)
Department of Veterans Affairs
810 Vermont Avenue NW
Room 1063B
Washington DC 20420
Comment URL: https://www.regulations.gov/comment?D=VA-2018-VACO-0001-7030

Subject: Public Comment Regarding Notice of Availability of the Draft Programmatic Environmental Impact Statement (PEIS) for the West Los Angeles Medical Center Campus Draft Master Plan
AKA
“Environmental Impact Statements; Availability, etc.: West Los Angeles Medical Center Campus Draft Master Plan; FR Doc. 2018–27126” at https://www.regulations.gov/document?D=VA-2018-VACO-0001-7030

Commenter: Michael Collins EnviroReporter.com at https://www.enviroreporter.com/ Email:
mlc@enviroreporter.com

Dear Director,

Thank you for this opportunity to comment on the Draft Programmatic Environmental Impact Statement (PEIS) for the West Los Angeles Medical Center Campus Draft Master Plan.

My comments concern the “Arroyo Area” where the “Historical medical waste disposal areas are located at the WLA Campus” according to the PEIS. These comments are informed by clarifying statements made by VA representatives at the January 17, 2019 public meeting on the West LA VA PEIS that the Arroyo Area was not being considered for any development and that it would remain locked and left alone.

Short of remediating the Arroyo Area completely, leaving it alone is the best alternative. That the PEIS recognizes that the low-level biomedical nuclear and chemical dump should be left alone removes the threat of releasing its toxins through haphazard development of the Arroyo Area.

These comments include corrections to mistakes in the PEIS’ assessment of preliminary remediation goals. While the threat posed by radiation and chemicals in the dump area is greatly reduced by leaving it alone, getting the numbers right on what is in the dump is important.

The form of my comments is to identify a part(s) of the PEIS by the name of the section it appears in (including the URL), the page number(s) of that section, and the text to be commented on followed by my comments/recommendations.

Thank you again for this opportunity to comment on this PEIS. I do hope that corrections to the draft are made to make sure it is entirely accurate especially in the assessment of the dump.

Michael Collins
EnviroReporter.com
mlc@enviroreporter.com

Michael Collins COMMENTS:

COMMENT 1:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 121/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

Historical medical waste disposal areas are located at the WLA Campus within the northern portion of the arroyo. Waste included biological wastes, animal carcasses, medical isotope waste, and other miscellaneous medical debris believed to be disposed on site in the 1960s. Subsurface investigation activities were completed in 2007 and 2010, respectively. The results of these studies concluded that contaminants and radionuclides found in the soil and water did not exceed preliminary remediation goals established for soil and tap water by EPA Region 9. Additionally, contaminant and radionuclide concentrations in groundwater did not exceed maximum contaminant levels established for drinking water by the California Department of Public Health (Allwest Geoscience Inc., 2010). GLAHS is required to obtain approval from the Nuclear Regulatory Commission (NRC) for any change in status of this historical waste disposal area (Section 3.12, Solid Waste and Hazardous Materials, contains additional details). [My emphasis]

Comment 1: While it is correct that “contaminants and radionuclides found in the soil and water did not exceed preliminary remediation goals established for soil and tap water by EPA Region 9,” that does not hold true for gases. Two passive gas samples for benzene and 17 passive gas samples for chloroform greatly exceed their PRGs.

Benzene gas was 83.3 times and 91.7 times its PRG. Chloroform gas was between 208.3 times and 700.0 times its PRG throughout the range of the 17 samples taken.

PROOFS – BENZENE:

Utilizing the “Regional Screening Level (RSL) Resident Ambient Air Table (TR=1E-06, HQ=1) November 2018” available at https://semspub.epa.gov/work/HQ/197426.pdf:

In column “Carcinogenic Target Risk (TR) = 1E-06”

Benzene: 3.6E-01 ug/m3 = 0.36 ug/m3

Benzene vapor results from Arroyo Area (adjacent southern athletic field leased by Brentwood School are on PDF page 14 of the 156 page PDF available at https://www.losangeles.va.gov/documents/GLA-Phase-II-Study-12-10-10-VOLUME-1.pdf and entitled:

INITIAL VOC & RADIOLOGICAL SUBSURFACE INVESTIGATION REPORT VETERANS ADMINISTRATION GREATER LOS ANGELES HEALTHCARE SYSTEM 11301 WILSHIRE BOULEVARD LOS ANGELES, CA 90073
VOLUME 1
PROJECT NO. 02-3454EI-3
December 10, 2010

On page 14 it reads:

9.2 Passive Soil Gas Survey Analytical Results
Only three (3) VOC analytes were detected in soil beneath the ‘Ball Field’ and the ‘Arroyo/Eastern Canyon’. Chloroform was detected in seventeen (17) passive soil gas samples at masses ranging from 25 ųg to 84 µg, benzene was detected in two (2) passive soil gas samples at masses of 30 µg and 33 µg, respectively, and toluene was detected in three (3) passive soil gas samples at masses ranging from 25 µg to 16 µg. A copy of the PSG Survey report is included in Appendix 4. [My emphasis]

THEREFORE the benzene detected was 30/0.36 = 83.3 times its PRG and 33/0.36 = 91.7 times its PRG. Both benzene samples greatly exceeded its PRG.

PROOFS – CHLOROFORM:

Utilizing the “Regional Screening Level (RSL) Resident Ambient Air Table (TR=1E-06, HQ=1) November 2018” available at https://semspub.epa.gov/work/HQ/197426.pdf:

In column “Carcinogenic Target Risk (TR) = 1E-06”

Chloroform: 1.2E-01 ug/m3 = 0.12 ug/m3

Chloroform vapor results from Arroyo Area (adjacent southern athletic field leased by Brentwood School are on PDF page 14 of the 156 page PDF available at https://www.losangeles.va.gov/documents/GLA-Phase-II-Study-12-10-10-VOLUME-1.pdf and entitled:

INITIAL VOC & RADIOLOGICAL SUBSURFACE INVESTIGATION REPORT VETERANS ADMINISTRATION GREATER LOS ANGELES HEALTHCARE SYSTEM 11301 WILSHIRE BOULEVARD LOS ANGELES, CA 90073
VOLUME 1
PROJECT NO. 02-3454EI-3
December 10, 2010

On page 14 it reads:

9.2 Passive Soil Gas Survey Analytical Results
Only three (3) VOC analytes were detected in soil beneath the ‘Ball Field’ and the ‘Arroyo/Eastern Canyon’. Chloroform was detected in seventeen (17) passive soil gas samples at masses ranging from 25 ųg to 84 µg, benzene was detected in two (2) passive soil gas samples at masses of 30 µg and 33 µg, respectively, and toluene was detected in three (3) passive soil gas samples at masses ranging from 25 µg to 16 µg. A copy of the PSG Survey report is included in Appendix 4. [My emphasis]

THEREFORE the chloroform detected was between 25/0.12 = 208.3 times its PRG and 84/0.12 = 700 times its PRG. All 17 chloroform samples greatly exceeded its PRG.

Recommendation 1: Amend this section to reflect and add these exceedances of passive soil gas PRGs. VA might consider further investigation of these overages perhaps funded by Brentwood School since it uses the land the gas is emanating from.

AND

COMMENT 2:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 205/743-PDF total pages
Text/Figure to be commented on and/or impart recommendation(s):

MAP OF “Figure 3.12-1. Locations of Hazardous Materials and Waste Operations on the WLA Campus”

Comment 2: This map of the Arroyo Area’s dump shows the extensive knowledge of where the dump is situated. VA is to be commended for using such and apparently accurate map. However, it fails to include the two benzene and 17 chloroform passive soil gas readings that exceed their respective PRGs. A map of those PRG exceedances of benzene and chloroform is available at https://www.enviroreporter.com/wp-content/uploads/2015/12/Chloroform-gas-lower-Brentwood-School-athletic-field.jpg and included here:

Recommendation 2: Include the above passive soil-gas survey maps for chloroform and benzene in the PEIS.

AND

COMMENT 3:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 210-212/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

In December 2010, VA completed the Initial Volatile Organic Compound (VOC) and Radiological Subsurface Investigation Report and concluded that VOC contaminants and radionuclides found in the soil and water of the disposal sites did not exceed preliminary remediation goals established for soil and tap water by EPA Region 9. Additionally, contaminant and radionuclide concentrations in groundwater did not exceed maximum contaminant levels established for drinking water by the California Department of Public Health (Allwest Geoscience Inc., 2010). Based on the completed site investigations, no potential health risks were identified. However, the NRC and VA had previously entered into agreement, as a Letter of Understanding, that VA will seek NRC approval for any change in the status of the land from undeveloped/restricted access. On May 4, 2011, the NRC provided VA acknowledgment of their review of results of the 2010 sampling event. NRC agreed with VA’s interpretation that the site is not a risk to human health. VA has not made a request to NRC for permission to redevelop the site (U.S. Department of Veterans Affairs, 2014).] [My emphasis]

Comment 3: This is not true. The 2010 study report showed that Radium-226 (Ra-226) and Radium-228 (Ra-228) in dump groundwater exceeded California’s Maximum Contaminant Level (MCL) for drinking water by 60.6 percent. The VA was required to notify state water authorities of the MCL violation as the VA’s groundwater has beneficial users and is protected at the source. That did not happen which is not that big a deal in this circumstance. But it should be noted in this section of the PEIS that Ra-226 and Ra-228 are in the groundwater.

Also, in this section is “NRC agreed with VA’s interpretation that the site is not a risk to human health.” It is not clear that this means the site as it is, undisturbed by any activities at all other than weed abatement.

Recommendation 3: Include in this passage the fact that Ra-226 and Ra-228 exceeding the MCL are in the groundwater. Also make abundantly clear that “NRC agreed with VA’s interpretation that the site is not a risk to human health while it remains undisturbed which is the intention of the PEIS.”

AND

COMMENT 4:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 125/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

A small area on the northwest boundary of the WLA Campus is an arroyo with an adjacent bluff. The area is open space and retains some native species such as arroyo willow (Salix lasiolepis) and mulefat (Baccharis salicifolia). Much of the area is covered with non-native and invasive plant species, such as the heavily overgrown giant reed (Arundo donax). Trees, such as blue gum eucalyptus and plants and grasses, such as mustard weed (Brassica sp.), pampas grass (Cortaderia sp.), and Goldenrod (Solidago sp.), grow throughout the arroyo (Figure 3.6-2). [My emphasis]

Comment 4: This is part of the Arroyo Area and within the perimeter of the dump. “Open space” is the wrong characterization of this place and could lead to future misunderstandings.

Also, this section correctly characterizes the plants, weeds and trees, especially the blue gum. These flora are highly flammable.

Recommendation(s) 4: Remove the designation “open space” and replace it as well as making it abundantly clear that the area is part of a closed, no-access part of the VA.

Also, weed abatement and locked, maintained locks on the closed gates to the Arroyo Area are crucial in order to prevent another fire like the one that happened January 26 as I reported in “Brentwood nuke dump burns as VA finalizes draft master plan” available at https://www.enviroreporter.com/2016/02/brentwood-nuke-dump-burns-as-va-finalizes-draft-master-plan/ A fire through the west arroyo could possibly ignite condominiums and cause immense smoke damage. More weed abatement and VA security patrols keeping people out of the site would be relatively easy and very proactive in environmental threat reduction. The missing northern gate should be replaced. The unlocked gate from the Arroyo Area to the dog park should be locked.

AND

COMMENT 5:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 362/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

There is a small wetland area on the northwestern side of the WLA Campus within the fenced open space south of Veterans Barrington Park (Figure 3.9-1). This area is not included in any Proposed Action activities. [My emphasis]

Comment 5: VA is to be commended for making this decision. It protects public health.

Recommendation(s) 5: Make it clear that “This area is not included in any Proposed Action activities and is a closed historic disposal area.”

AND

COMMENT 6:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 512/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

No impacts are anticipated to floodplains, wetlands, and California coastal zone, and no recommended mitigation measures for this resource area. The WLA Campus lies outside the 100-year and 500-year flood hazard zones. No development is proposed near the wetland.
[My emphasis]

Comment 6: Again, VA is to be commended for making this decision. It protects public health.

Recommendation 6: Make it clear that “No development is proposed near the wetland and is a closed historic disposal area.”

AND

COMMENT 7:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 568/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

“ARROYO PARK” SHOWN AGAIN ON P 703/743 FOR NOVEMBER 2018-DATED MASTER PLAN

Comment 7: This map shows development plans in the Arroyo Area. This and other maps no longer represent VA development plans according to Glenn Elliott, NEPA implementation officer for VA, at the public meeting I attended and recorded January 17, 2019.

Recommendation(s) 7: Either reconfigure this map to remove any development from the Arroyo Area or remove the map from the EIR entirely.

AND

COMMENT 8:
Regarding Document: Draft Programmatic Environmental Impact Statement and National Historic Preservation Act Section 106 Consultation
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/Draft_PEIS_WLA_Medical_Center_Master_Plan_Nov_2018.pdf
Document Page(s): PDF page 597/743-PDF total pages
Text to be commented on and/or impart recommendation(s):

MS. HAWKMAN: Hi. I am Judie Hawkman. I have been living in Brentwood for about 30 years. And I heard the following information. I would like to know if it is true or not true that there is radioactive material underneath this area that you are talking about and that it is in concrete. Okay? If that is true, then what is going to happen when they start to rebuild? How do they know where that radioactive material is/ And how will they stop it from escaping?
MR. MUSA: Thank you.
I will turn it over to Mr. Glenn Elliott.
MR. ELLIOTT: So there is low-level contamination in some of those areas. It is below the thresholds. That is set forth by EPA. One of the things is anything moving forward. And part of the studies that we are performing associated with the EIS is to look at those areas at what is available for activities that can happen there.
So your question about like what will be done or what could be done, everything will be done in accordance with EPA and cleanup regulations. So it is not like those areas will be disturbed haphazardly. It is going to be studied and analyzed as to the potential impacts of doing construction projects in those specific areas.

Comment 8: These comments by Mr. Elliott contradict what he said at the January 27, 2019 public meeting and contradicts other parts of the PEIS, such as those referred to herein as Comments 5 and 6. This is a very disturbing comment that “It is going to be studied and analyzed as to the potential impacts of doing construction projects in those specific areas.” If that’s the case, then VA needs to put in this PEIS that it will do the very same study and analysis to determine the impacts of removing the dump entirely before any development is allowed.

Recommendation(s) 8: VA needs to make it abundantly clear that the Arroyo Area will remain undeveloped, undisturbed and completely locked up securely for the life of this Master Plan. All maps and images of the Arroyo Area as part of some redevelopment idea in the Master Plan should be removed.

AND

COMMENT 9:
Regarding Document: “11. WLA_Transportation_Appendices”
Document URL: https://draft-master-plan-assets.s3.amazonaws.com/media/uploads/2018/12/06/WLA_Transportation_Appendices.pdf
Document Page(s): Multiple pages with maps
Text to be commented on and/or impart recommendation(s):

P 1463/1519

Residential developments are proposed in the farthest northern portion of the North Campus. Therefore, the extension of Bonsall Avenue to the north past Patton Avenue will provide access to these permanent supportive housing uses, and facilitate the expansion of the Campus shuttle service that would appropriately serve the residents in this portion of the site. In the center of the North Campus, a series of administrative uses are being proposed as part of a Town Center. As the existing road network in the central portion of the North Campus is more developed than in the open-spaces in the northern portion, more extensive modifications in the northern portion are proposed in order to provide access to the future buildings, which are yet to be articulated.

The extension of Bonsall Avenue in the northwest direction, providing connectivity to the T1D4 NEC Veterans Park permanent support housing development.

The addition of a roadway surrounding the western edge of the T1D1 MacArthur Field to serve the permanent supportive housing development.

P 1468/1519

“PROPOSED NEW/REALIGNED ROADWAY”

OPTION 1

P 1469/1519

OPTION 2

&

P 1472/1519

SHUTTLE ROUTE GOES THROUGH DUMP


ABOVE PED/BIKE MAP DATED 8/03/18

WITH

P 1475/1519

PEDESTRIAN/BIKEPATH INCLUDING ONE THROUGH DUMP THAT SAYS “CONSTRUCTION OF NEW PATH FOR PEDS & BIKES”

WITH

WHAT THIS PATH CROSSES RIGHT THROUGH:

ROAD CROSSES DOZEN MYSTERIOUS MOUNDS

Comment 9: All of these plans must be removed from the PEIS as Mr. Elliott, and other parts of the Master Plan, say the Arroyo Area will not be developed.

Recommendation(s) 9: Unless the Master Plan makes it abundantly clear that none of these plans are going to happen before the Arroyo Area dump is studied for its removal in entirety, they must be removed from the PEIS.