Description
<A HREF="http://www.enviroreporter.com/"><em>EnviroReporter.com's</em></A> 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.
<p><strong>SUMMARY</strong>
<p>In an e-mail to Radiation Ranger Frank Serafine dated May 20, 2008, Department of Toxic Substances Control (DTSC) Project Manager for the cleanup of the Santa Susana Field Laboratory (SSFL or Rocketdyne) Norm Riley 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.”
<p><em>EnviroReporter.com</em> and other citizens of Simi Valley (primarily the resident 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.
<p>For example, In the most recent analysis 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.
<p>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, <em>EnviroReporter.com</em> concurs.
<p>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.
<p>This timeline 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.
<p>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. <u>Those documents are analyzed under a separate document and timeline entitled “KB Home 41 document analysis.”</U>
<p><em>EnviroReporter.com</em> 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. This proved prudent as our investigation of the white evaporate revealed high levels of chromium, nickel, molybdenum, potassium and iron.
<p>This timeline contains information not provided to DTSC by KB Home, some of which is not analyzed by <em>EnviroReporter.com</em> 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 over lap with the "KB Home 41 document analysis."
<p>This timeline contains a summary that includes our focus and materials, the contents of the analysis with supporting documentation, and our conclusions.
<p><em>EnviroReporter.com</em> 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 the same day. 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.</p>
<p><strong><em>Focus and Materials</p></strong></em>
<p>This investigation of Runkle Canyon pollution issues began in <A HREF="http://enviroreporter.com/neighborhoodthreatproof.html">2004</A> and is ongoing for several newspapers and <em>EnviroReporter.com</em>. 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.
<p>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 an 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 <A HREF="http://www.vcreporter.com/cms/story/detail/reassessing_runkle/5903/">“Reassessing Runkle.”</A>
<p>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.
<p><em>EnviroReporter.com</em> is also completing this ongoing work at the request of a 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.
<p>This timeline examines environmental data, much in the form of <A HREF="http://www.envirostor.dtsc.ca.gov/public/profile_report.asp?global_id=60000899&cmd=community_involvement">41 reports</A>, 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.</p>
<p><strong>CONTENTS</strong>
<p><strong><A HREF="http://www.dipity.com/user/enviroreporter/timeline/Runkle_Canyon_Documents_Analysis">See Timeline</strong></A>
<p><strong>CONCLUSIONS</strong>
<p>The information herein shows that the developer’s Environmental Impact Report, approved in 2004 and previously reported on extensively by <em>EnviroReporter.com</em>, shows abnormally high strontium-90 soils readings. A retesting of Sr-90 in the soil by the developer last year came in over 100 times less than previously and averaged less than a quarter of the area’s normal background for the substance. The Rangers questioned these results and pointed out that the city of Simi Valley’s split samples, which yielded the same results, was in fact an outdated testing technique from <A HREF="http://enviroreporter.com/files/EnvironIncLabTechinques1-17-08.pdf">1967</A> and therefore unreliable.
<p><li>The Rangers maintain that a new EIR must be performed with the soil again retested under the supervision of DTSC with samples tested at DTSC’s laboratory to ensure accuracy utilizing current testing methodology. <em>EnviroReporter.com</em> concurs.
<p><li>The KB Home-provided documents show that the developer did not test for heavy metals in Runkle Canyon’s soil or water other than on a small patch of asphalt. Not included in the documents, but provided herein, are the results of limited tests for heavy metals conducted by the <A HREF="http://enviroreporter.com/files/5-3-07_Full_Pat-Chem_Runkle_Cyn_toxic_repor
t2.pdf">Rangers</A> and the city of <A HREF="http://enviroreporter.com/files/8-14-07_Tetra_Tech_SV_report.pdf">Simi Valley</A> which show high levels of arsenic, nickel, vanadium, cadmium, chromium and lead. Water running down Runkle Canyon ends up in the Arroyo Simi watershed which currently supplies 20% of Simi Valley’s blended tap water.
<p><li>The Rangers maintain that more extensive tests of Runkle Canyon’s soil and surface water for heavy metals is necessary to assess the potential threat to human, animal and plant life. The city’s lab also recommends additional testing for these heavy metals and to determine where they came from. <em>EnviroReporter.com</em> concurs with the recommendation that the in-situ sampling be under the supervision of DTSC and that DTSC provide lab analysis.
<p><li>Additionally, the Rangers recommend that the local water purveyor be told of the vanadium in the surface water which exceeds the Notification Level. They also suggest that the water purveyor inform its customers of this contaminant threat and how it deals with it before it reaches the consumer. <em>EnviroReporter.com</em> agrees that the law be followed in this matter but has no position otherwise.
<p><li>The Santa Susana Field Laboratory’s former nuclear testing Area IV borders Runkle Canyon and has 11-acre drainage into it. On December 13, 2007, lab owner Boeing submitted an <A HREF="http://enviroreporter.com/files/12-07_SSFL_Offsite_data-MWH.pdf">Offsite Data Evaluation Report</A> for the
Santa Susana Field Laboratory to DTSC that includes evidence that toxic trichloroethylene (TCE) had been detected in Runkle Canyon groundwater.
<p><li>However, the report says that "Runkle Canyon and the SSFL do not share a common property boundary," when maps in the document show that it clearly does. The document goes on to say "No environmental investigations have been performed by Boeing, NASA, or DOE on the Runkle Canyon property" when the map showing the TCE hits in Runkle groundwater is on page 184. Perhaps ironically, the last page of this report combines the two falsehoods, showing the groundwater sampling spot on Runkle Canyon and the common Rocketdyne border and says, in conclusion, "Offsite sampling sufficient with no data gaps."
<p><li>The Rangers recommend that DTSC investigate these discrepancies and also determine whether Runkle Canyon's contamination is result of lab off-site migration. They also recommend that if DTSC determines that radiological and/or chemical pollution found in the canyon, using as sources all the reports cited in <em>EnviroReporter.com's</em> analysis and further testing as the department decides and orders, that Boeing pay for any past and/or additional sampling, lab analysis and any short-term, medium-term and long-term remediation. <em>EnviroReporter.com</em>
concurs with the recommendation to determine if the lab is the source of the radiological and/or chemical contamination in Runkle Canyon.
<p><li>On March 27, 2008, Rangers Frank Serafine and Rev. John Southwick espied extensive white evaporate on an area where it had not previously been seen since the last time they had visited the area, which was before the winter rains. Nothing was growing where this unusual distribution of white evaporate/precipitate occurred. The two men gathered some of this material and gave it to DTSC’s Norm Riley at that evening’s quarterly Santa Susana Field Laboratory Workgroup meeting. DTSC tested this material and shared the results with the Rangers who then imparted them to <em>EnviroReporter.com</em> for analysis.
<p><li>Abnormally <A HREF="http://enviroreporter.com/files/Rock-White_Precipitate--heavy_metal_results">high amounts of chromium, iron, molybdenum, nickel and potassium</A> were found in the white precipitate. The chromium registers over 20 times the Department of Energy’s Preliminary Action Levels for “industrial” zones, of which Runkle Canyon is not, over 6 times EPA Region 9’s Preliminary Remediation Goal for the metal, and over 35 times the average amount of total chromium found throughout SSFL’s soil.
<p><li>The Rangers recommend that DTSC retest this white material to determine the valence ratio of trivalent and hexavalent chromium. They also recommend that the material be tested for other possible contaminants and that DTSC try to “fingerprint” the source of such material. <em>EnviroReporter.com</em> concurs and further recommends that corrective action and remediation take place if the material is found to contain dangerous amounts of hexavalent chromium and, if it does, direct that KB Home and the city of Simi Valley immediately post warning signs by the contamination as well as on the perimeter of the Runkle Canyon property. <em>EnviroReporter.com</em> also recommends that DTSC investigate the substrata hydrogeologic conditions that may have transported this material off of SSFL and resulted in this phenomenon.
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