{"id":236,"date":"2014-08-06T03:52:00","date_gmt":"2014-08-06T03:52:00","guid":{"rendered":"https:\/\/esconeighbors.wpenginepowered.com\/?p=236"},"modified":"2014-08-06T03:52:00","modified_gmt":"2014-08-06T03:52:00","slug":"escondido-neighbors-united-responds-to-more-recent-chatham-monitoring-report","status":"publish","type":"post","link":"https:\/\/escondidoneighbors.org\/?p=236","title":{"rendered":"Escondido Neighbors United Responds to more recent Chatham Monitoring Report"},"content":{"rendered":"
\nEscondido Neighbors United<\/i> filed a comment letter on the most recent submittal of the PRPs for the Chatham Barrel Yard Waste Site.  We have made many recommendations for additional information, clarification and improvements to the report.  We will keep you informed on this important issue.  <\/span>
\nPlease email us with any questions at info@escondidoneighbors.org. <\/span><\/div>\n
\n<\/div>\n
\nEscondido Neighbors United<\/span><\/b><\/p>\n
\nAn alliance of engaged residents working for the benefit of
\nrural, urban, and natural communities in the Escondido Area. <\/o:p><\/span><\/i><\/div>\n
\n<\/div>\n
\nJuly 31,
\n2014<\/o:p><\/span><\/div>\n
\n<\/div>\n
\nMr. Stewart
\nBlack, <\/span>Department of Toxic
\nSubstances Control<\/span><\/o:p><\/span><\/div>\n
\nMr. Hossein Nassiri, Department
\nof Toxic Substances Control<\/o:p><\/span><\/div>\n
\nMr. Jimmy Smith, Regional
\nWater Quality Control Board <\/o:p><\/span><\/div>\n
\nMr. Craig Carlisle, Regional
\nWater Quality Control Board<\/o:p><\/span><\/div>\n
\nMs. Julie Macedo, State
\nWater Resources Control Board<\/o:p><\/span><\/div>\n
\nMr. Kevin
\nHeaton, San Diego County Department of Environmental Health<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n<\/div>\n
\nRE:  Escondido
\nNeighbors United<\/i> requests, comments, and questions on the Chatham PRP Group
\nAnnual Monitoring Report submitted July 11, 2014 <\/o:p><\/span><\/b><\/div>\n
\n<\/div>\n
\n<\/div>\n
\nDear Madam
\nand Sirs:<\/o:p><\/span><\/div>\n
\n<\/div>\n
\nWe have had
\nthe opportunity to review the July 11, 2014 submittal from the PRP Group and
\nhave the following comments, questions, and requests for additional information
\nand analysis.  We expect to have
\nadditional comments but wanted to offer these observations as we understand
\nthat your agencies are discussing this issue now.  We hope you will take these comments into
\nconsideration in creating any future fact sheets as well.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n1.    
\n<\/span><\/span><\/b>Report
\nshould state remedial objectives in full <\/o:p><\/span><\/b><\/div>\n
\nThe report
\nengages in unhelpful \u2018creative mis-summarization\u2019 with respect to the remedial
\nobjectives.  What is presented as a
\nsummary accurately summarizes neither the actual objectives nor the \u2018practical
\nobjectives\u2019 from the Remedial Action Plan (RAP).  For example, the requirement that off-site
\nconcentrations meet maximum contaminant levels (MCLs) is different than the
\nsummarized requirement to monitor contaminants over time to demonstrate
\nimprovement.  The summary should be
\nremoved and the real objectives should be stated in the report or, at a
\nminimum, re-worded (but still accurate) for easier reading as has been done by
\nthe Water Board in previous letters.[1]<\/span><\/span><\/span><\/a>  For the record, we repeat the exact wording
\nof the relevant Soil and Groundwater Remedial Action Objectives from the
\nRemedial Action Plan.<\/o:p><\/span><\/div>\n
\na.       <\/span><\/span>Prevent
\nmigration of VOCs from unsaturated soil into groundwater or surface water in
\nconcentrations that could cause groundwater or surface water not to comply with
\nRAOs for the media.<\/o:p><\/span><\/div>\n
\nb.      <\/span><\/span>Prevent
\ningestion of groundwater that contains contaminants listed in the RAP (Table
\n5-1) at concentrations at the MCLs also listed in the Table 5-1. <\/o:p><\/span><\/div>\n
\nc.       <\/span><\/span>Remediate
\ngroundwater within the Property to HBCLs and the groundwater outside of the
\nProperty to MCLs for contaminants listed in Table 5-1.<\/o:p><\/span><\/div>\n
\nd.      <\/span><\/span>Prevent incidental
\ningestion, dermal contact, or inhalation of vapors from groundwater that
\ncontains contaminants listed in Table 5-1 at concentrations exceeding the HBCLs
\nwhich are also listed in Table 5-1.[2]<\/span><\/span><\/span><\/a><\/o:p><\/span><\/div>\n
\nWe also
\nrequest that all requirements of the Basin Plan, Porter-Cologne, and Prop 65 that
\nmust also be met be listed here as well.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n2.    
\n<\/span><\/span><\/b>SWRBTLs are
\nexcessive and should be revisited and reduced to levels comparable with
\nexisting regulations, or abandoned.<\/o:p><\/span><\/b><\/div>\n
\nThe current
\nSurface Water Risk Based Threshold Levels (SWRBTL) proposed by the PRP Group
\nand used for notification[3]<\/span><\/span><\/span><\/a>
\nand action are simply excessive.  We do not believe that we should wait to notify
\nor take action until TCE in surface water reaches 1,700 ug\/l<\/b> when the MCL
\nis 5 ug\/l.  It is interesting to compare
\nthe effluent limits in the Waste Discharge Requirements for groundwater
\ndischarges to surface waters for human health which are 2.7-5.4 ug\/l for
\nmunicipal beneficial use and 81-160 ug\/l for Non-MUN[4]<\/span><\/span><\/span><\/a>.   In addition, vinyl chloride is one of the
\ncontaminants found in the surface water yet no threshold has been set for it.  Last, we are incredulous that the SWRBTL for 1,4,-Dioxane is
\n8,900-340,000ug\/l.<\/b>[5]<\/span><\/span><\/span><\/a>
\n yet the OEHHA Public Health Protection
\nLevel is 3.0 ug\/l and the state Source Removal level is 35 ug\/l.[6]<\/span><\/span><\/span><\/a>  FC-4 is at a historic high at 31 in April of
\n2014.[7]<\/span><\/span><\/span><\/a>  We have related questions to this issue
\nlisted below.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>The notification action levels for creek pollution should be no
\nhigher than the MCLs, effluent limits, or state standards for these priority
\ntoxic pollutants.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>An action level should be set for vinyl chloride since it has been
\nfound in the creek surface water. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request that notification be triggered by the MCLs.<\/o:p><\/b><\/span><\/div>\n
\n<\/div>\n
\n3.    
\n<\/span><\/span><\/b>Maps should
\naccurately show extent of contamination and recap its movement<\/o:p><\/span><\/b><\/div>\n
\nThe maps on
\npage 41, while dramatic, are misleading. 
\nThey fails to show the full extent of the contamination in April 2014
\nand would lead a reader to think this is the extent of the pollution in
\n2014.  It is not.  Years ago, the leading edge of the plume as
\nMW-54 (just north of the southern boundary of Felicita Park) with a monitoring
\nresult below the MCL.[8]<\/span><\/span><\/span><\/a>  Now we have pollution extending to Fleet 1 over
\ntwice the MCL[9]<\/span><\/span><\/span><\/a>
\nand the plume has moved out on both sides and to previously unimpacted sites.  This movement should be documented for the
\npublic.  Further, as is now clear, the
\nVOCs are just moving and not biodegrading so that the maps on page 41 should
\nalso include the deep plumes which still appear to connected by the results of
\nTCE and PCE in MW-39 and TEW-02[10]<\/span><\/span><\/span><\/a>
\neven though not indicated as such on the figures.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request the regulators require all maps to show the full extent
\nof the contamination.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request the regulators require a map in each report of the
\nmovement of the plumes over time. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n4.    
\n<\/span><\/span><\/b>Maps should
\nreflect all results<\/o:p><\/span><\/b><\/div>\n

The testing of the surface waters show that five
\nother types of contaminants, including vinyl chloride, in addition to TCE have
\nbeen found in the creek yet only TCE is shown on a map.  1,4-Dioxane was found in all three samples taken
\nfor it at historical high concentrations in surface water, yet not presented on
\na map.[11]<\/span><\/span><\/span><\/a>
\n Other contaminants present in
\ngroundwater include <\/span>1,1,2-Trichloro-1,2,2-trifluoroethane (CFC113, Freon
\n113) in MW 64, MW 67, MW 69, MW72 which should also be mapped.[12]<\/span><\/span><\/span><\/a><\/o:p><\/p>\n

\n\u00b7        
\n<\/span><\/span>We request the regulators require individual maps of PCE, 1,4 Dioxane,
\nvinyl chloride, cis-1,2 DCE and 1,2 DCA, total VOCs, and CFCs in addition to
\nthe TCE map of contamination in surface water.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request the regulators require individual maps of all
\ncontaminants found in groundwater.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n5.    
\n<\/span><\/span><\/b>Report
\nshould \u2018spin\u2019 less and report facts more objectively<\/o:p><\/span><\/b><\/div>\n
\nWe do not
\nfind this report an objective presentation of the results. We understand the potential
\nbenefits to some stakeholders of a report written to make the facts appear
\nbenign.  However, this is a disservice to
\nthe process and the public who rely on the reports required by regulatory
\nagencies to inform those actions needed to protect the community.  The focus on the reductions and the
\nsoft-pedaling on the increases is inappropriate.  Yes, the pollution is decreasing\u2014except where it is increasing<\/b>.    For example, there are significant increases
\nin MW-72, Platt 1, and Grubbs1.[13]<\/span><\/span><\/span><\/a>  Interestingly, these are on the east, west,
\nand southern edge of the plume.  If the
\npollution really was naturally attenuating, the outer edges of the plume would
\nnot be increasing\u2026they would be decreasing. 
\nFurther, we do not call an increase of total VOCs by 500% (Platt 1 increased
\nfrom 4.7 to 30) and 400% (MW 34-N5 in the park increased from 7.5 to 35.5) [14]<\/span><\/span><\/span><\/a>
\nsince October 2013 a \u2018slight\u2019 increase. Further, MW- 72 now exceeds its historical maximum by almost 45 ug\/l<\/b>. [15]<\/span><\/span><\/span><\/a>  Grubbs 1 and Platt 1 are also at historical
\nhighs[16]<\/span><\/span><\/span><\/a>
\nand MW-66 and 39 are trending consistently upward.[17]<\/span><\/span><\/span><\/a><\/o:p><\/span><\/div>\n
\n<\/div>\n
\nThe other
\nexample where we must object is the repeated editorializing that \u201cany increase in the downgradient footprint
\nof the plume is more than offset<\/b> by
\nthe reductions in concentrations and plume footprint\u2026\u201d<\/i> [18]<\/span><\/span><\/span><\/a>
\n(emphasis added)  We disagree.   If
\none\u2019s life savings are in a home not previously located over a contaminated
\nplume but is now, or if your well used to be clean but is not now, or you live
\nnear a well that continues to increase in contamination, then reductions
\nelsewhere decidedly do not<\/u><\/b>
\nmore than offset the problem.  In fact,
\nit is not working. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators are urged to ask the report writers to stop
\neditorializing and just report the results, including a focus on where
\nconditions are worsening.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request that the consultants doing the work be funded by the
\nPRP Group but directed<\/b> by the
\nregulators.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n6.    
\n<\/span><\/span><\/b>Report should
\npresent and address all of the results not just selected results that minimize
\nthe problems at the site. <\/o:p><\/span><\/b><\/div>\n
\nWe object to
\nthe use of TCE as a stand in for all of the contamination from the site.  Using Platt 1 as an example, using TCE
\nresults only, the \u2018slight\u2019 increase of over 100% (from 6.1 to 14 ug\/l) in one
\nyear.[19]<\/span><\/span><\/span><\/a>  However, the total VOC results are as stated
\nearlier are increased by 500%   in one
\nyear.  Yet, the statement in the report
\nis \u201cVOC concentration data for deep
\ngroundwater south of Hamilton Lane indicates a decline in some wells with a
\nlong record of monitoring history.\u201d  <\/i>[20]<\/span><\/span><\/span><\/a>  Yes, in some, but others are increasing and
\nthe plume is moving into previously uncontaminated areas.  The fact that the report fails to focus on this
\nis manipulative and demonstrates extreme bias.  
\nFurther, different contaminants move at different rates, have different
\nhealth effects, and turn into different things which may be missed if only TCE
\nis tracked.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require that ALL trends be summarized in the
\nreports.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We disagree with using TCE alone as the \u2018indicator\u2019
\ncontaminant.  The full suite of
\ncontaminants should be discussed.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We disagree with the Report\u2019s finding that the distribution
\nprovided good correlation with previous distribution.[21]<\/span><\/span><\/span><\/a>  The plume is moving south, east, and west and
\ndischarging into Felicita Creek[22]<\/span><\/span><\/span><\/a>
\nwhere people and wildlife are exposed to multiple contaminants from the Chatham
\nBarrel Yard. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n7.    
\n<\/span><\/span><\/b>Off-Yard soil
\nvapor analysis must be done and reported to the public<\/o:p><\/span><\/b><\/div>\n
\nThe highest off-Yard
\nlevel of TCE this monitoring round was 280 ug\/l[23]<\/span><\/span><\/span><\/a>and
\ntotal VOCs were 645.2 ug\/l[24]<\/span><\/span><\/span><\/a>  at MW-69.   The MCL for TCE is 5 ug\/l.  This location is right underneath homes,
\nadjacent and upgradient of a proposed housing development, the Duck Pond, and
\nFelicita Creek.  A major concern with VOC
\ncontamination of groundwater is the vapor intrusion into homes and yards.  This is also a major concern of our
\nmembers.  <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request, again, that soil vapor analysis be done for homes
\nlocated on the plumes so that potential health risks, if any, can be known. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span> We would also like to know
\nwhy this common sense action has not previously been conducted.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n8.    
\n<\/span><\/span><\/b>Chloroform
\nin MW-74, MW-76  and VOCs in MW-26 should
\nbe explained<\/o:p><\/span><\/b><\/div>\n
\nThe report
\ndismisses chloroform in two wells as being unrelated to the site without an
\nexplanation or identification of another source.  There is chloroform in many wells and it was
\na contaminant of the Chatham site. 
\nPerhaps, the chloroform in the plume has traveled all the way to MW-74
\nto the southeast and to MW-76 to the northeast. 
\nThe report states that VOCs in MW-26 do not appear to be site related[25]<\/span><\/span><\/span><\/a>
\nbut with no explanation. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require a plume contour to be drawn for
\nchloroform as well as all other contaminants unless the PRPs have identified
\nanother source.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n9.    
\n<\/span><\/span><\/b>Previous
\nresults should not be considered to be this year\u2019s results.<\/o:p><\/span><\/b><\/div>\n
\nThe failure
\nto monitor Chernish 1[26]<\/span><\/span><\/span><\/a>
\nis a major failing of the report.  This
\nwell would demonstrate whether or not the plume has moved even farther to the
\nsoutheast.  We also do not support reporting
\nlast year\u2019s results on this year\u2019s maps. 
\nIf a well is not sampled then NS should be stated.  For example, we do not know if the level has
\nrisen in the Chernish 1 well because it was not sampled yet it appears as a
\n<1 and <2 for various contaminants.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n10.<\/span><\/b>Report
\nshould include report on uncontrolled discharge from the treatment system<\/o:p><\/span><\/b><\/div>\n
\nWe do not
\nsee the discussion of the break in the groundwater system that resulted in a
\ndischarge of vinyl chloride contaminated effluent to land near the Chatham site
\ndiscussed in the report. [27]<\/span><\/span><\/span><\/a>
\n <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require this upset should be included in this
\nreport.  <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n11.<\/span><\/b>  Claim of Natural Attenuation is highly
\nsuspect and does not comport with the normal definition.<\/o:p><\/span><\/b><\/div>\n
\nWe were surprised to read that \u201cadsorption
\nand biodegradation are not expected to be significant natural attenuation
\nprocesses.\u201d[28]<\/span><\/b><\/span><\/span><\/a><\/i>  In our understanding and experience, natural
\ndegradation through biological or chemical processes is what natural
\nattenuation is supposed to be.  According
\nto the USEPA Website,<\/o:p><\/span><\/div>\n
\n<\/div>\n
\nMonitored
\nnatural attenuation (MNA) is a technique used to monitor or test the progress
\nof natural attenuation processes that can
\ndegrade contaminants in soil and groundwater. <\/b>It may be used with other
\nremediation processes as a finishing option or as the only remediation process
\nif the rate of contaminant degradation<\/b>
\nis fast enough to protect human health and the environment. Natural processes
\ncan then mitigate the remaining amount of pollution; regular monitoring of the
\nsoil and groundwater can verify those reductions.<\/span><\/i>
\n[29]<\/span><\/b><\/span><\/span><\/a>
\n(emphasis added)<\/o:p><\/span><\/i><\/div>\n
\n<\/div>\n
\nGWERD
\nscientists have led the way in developing EPA’s approach for applying and
\nassessing monitored natural attenuation (MNA) as a cleanup tool for organic and
\ninorganic contaminants in groundwater.  MNA can work with other more active remedial
\ntools at some sites where biogeochemical
\nconditions favor natural processes that degrade <\/b>or immobilize harmful
\ncontaminants.[30]<\/span><\/b><\/span><\/span><\/a>(emphasis
\nadded) <\/o:p><\/span><\/i><\/div>\n
\n<\/div>\n
\nDissipation and degradation are not the same thing.  If degradation is not occurring, then we are
\nleft with, essentially, just watching the pollution spread out in all
\ndirections for \u201ccenturies\u201d.[31]<\/span><\/span><\/span><\/a>   This is hardly a remedy.   <\/o:p><\/span><\/div>\n
\n<\/div>\n
\nThe evidence that it is occurring is likewise questionable.  That the monitored mass is thought to have
\ndecreased but not broken down means that the contamination just went
\nelsewhere\u2014either flowed into new area or volatilized in an uncontrolled manner
\ninto the environment.   And, where is it volatilizing to?  Into people\u2019s homes, the creek, the park?  This question needs to be answered.  We do not agree that \u2018gradual dissipation\u2019 or
\nuncontrolled volatilization is natural attenuation or acceptable.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request regulators reject the claim that natural attenuation is
\nworking and achieving the Remedial Action Objectives and require additional
\naction.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n12.<\/span><\/b>  Upward flow of deep groundwater is a
\ncontinual source of exposure<\/o:p><\/span><\/b><\/div>\n
\nWe have been
\ntold several times not to worry because the pollution is in a deep groundwater
\nplume.  Now we read that some components
\nof the deep VOC plume is \u201cflowing upward
\nin to the shallow zone under the influence of upward hydraulic gradients.\u201d[32]<\/span><\/b><\/span><\/span><\/a>
\n<\/i>and that \u201chigher concentration VOC
\nmass in the deep zone contributes to the VOC mass in the shallow zone thorough
\nlocalized upward gradients\u201d[33]<\/span><\/b><\/span><\/span><\/a><\/i>.  Further, \u201csurface
\nwater flow in Felicita Creek is fed by groundwater<\/i>\u201d.[34]<\/span><\/span><\/span><\/a>  This is bad news.  To us, it means that the deep plume will
\ncontinually feed the shallow plume and drive contaminant exposure to human
\nhealth and the environment.  However,
\nthese site of upwelling would be prime locations for pump and treat wells along
\nthe plume to expedite cleanup.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require pump and treat systems along the plume
\nand evaluate upwelling sites as potential strategic locations.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n13.<\/span><\/b>  Report admits more downgradient migration of
\nVOCs is occurring but more clarity and information is needed.<\/o:p><\/span><\/b><\/div>\n
\nWe appreciate that the report acknowledges what is obvious\u2014the
\nplumes are migrating into new areas.  However,
\nwe would suggest that statement that certain wells have half-life rates that
\ncannot be calculated because a \u201cconsistent
\ndownward concentration trend at those locations has not yet been established\u201d<\/i>
\nbe revised to state why those downward trends have not been established.  It is
\nbecause they are increasing as the plume passes through them!<\/b>   Finally, the conclusions on page 50 should
\nbe revised to note which wells have increased to historic highs, those that
\nhave not significantly decreased in 17 years, and their locations.  Because the plumes are moving south and
\nwidening out, it is not reasonable to expect that there would be a 1:1 reading
\nof VOCs from one end of the mile long plume to the other.  As the plume moves east, south, and west, the
\npollution spreads out over a wider area contaminating previously uncontaminated
\nareas.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should seek revisions to the report. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should reject the claim that the plumes have been
\nadequately contained and should require additional action.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should requires a map that shows all exceedances of
\nMCLs from RAP Table 5-1 for all chemicals on the same list. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n14.<\/span><\/b>Human and
\nEcological Health Risk Assessment must be redone to reflect new conditions,
\nstandards, and future proposals.   <\/o:p><\/span><\/b><\/div>\n
\nWe repeat our request that the HRA be redone to reflect all new
\ninformation, site conceptual models, weather and other conditions, standards
\nand listings, and future proposals.  We
\nhave many disagreements with how the assumptions have been made regarding the
\nexposure.  We expect to submit additional
\ncomments on this issue.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\nWe also request to understand the current status on what levels
\nare relevant and if new data has been used.  
\nAs one example, in the RAP Table 5-1 the MCL for vinyl chloride is
\nlisted as 5 ug\/l however in the EPA Technical Fact sheet for vinyl chloride it
\nis listed as 2 ug\/l. [35]<\/span><\/span><\/span><\/a>  Additional issues such as the 1,4-Dioxane
\nissue, have been raised above.  If it
\ndoes not already, the report needs to incorporate the 25 new US EPA IRIS
\ntoxicity values for trichloroethylene (September 28, 2011).[36]<\/span><\/span><\/span><\/a>   The latest assessment characterizes the
\nchemical as carcinogenic to humans and as a human non-cancer health hazard and TCE
\nwas added to Prop 65 effective January 31, 2014, known to the State of California
\nto cause reproductive toxicity.[37]<\/span><\/span><\/span><\/a><\/o:p><\/span><\/div>\n
\n<\/div>\n
\nLast, the HRA and site model that have been done to date reflect
\ncurrent land use patterns.   However, a
\nnew Senior Housing Center is under construction, the City is considering a
\nlarge development on the Homeland\/Oak Creek site, and other proposed projects are
\nproceeding that will alter current conditions, change water flows, infrastructure,
\nexposure routes, and use patterns.  With
\ndevelopment encroaching on the Chatham plumes and site, the HBCLs should also
\nbe reconsidered to assess if they are protective of water quality and future
\nuses. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>The HRA should be redone to reflect current and future conditions
\nand reevaluate the adopted cleanup levels.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>HBCLs should be re-evaluated against future conditions. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require information to be developed regarding
\nhow changed land uses will impact pollution in the groundwater and surface
\nwater and how such impacts will be prevented. 
\nNew development in this area and new well installation should be prohibited
\nuntil this is known.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n15.<\/span><\/b> Use of
\nimpacted wells should cease until treatment is installed.<\/o:p><\/span><\/b><\/div>\n
\nThe report
\nnotes our sad news that our friend and neighbor Yolanda Fleet passed away this
\nyear.  We are all extremely saddened by
\nher passing.  The report states that the
\nPRP Group is in discussions with her estate, however it does not state whether
\nthe well will be in use during this discussion time although it is well
\ndocumented that it is contaminated.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should not allow this or any impacted well to continue
\nto be used without wellhead treatment. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Regulators should require well-owners to be compensated for the
\nloss of the use of their groundwater.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n16.<\/span><\/b>  Regulators should direct a plan to address
\nother analytes in surface water as a separate action if not related to Chatham.<\/o:p><\/span><\/b><\/div>\n
\nThe reported
\nhigh levels of TDS, Total coliform, and turbidity are stated to be unrelated to
\nthe Chatham pollution.  If so, the County
\nmust immediately develop a response to address these contaminants as they are
\nin violation of the water standards and protected beneficial uses.  However, the presence of these contaminants neither
\nmitigates nor negates the seriousness of the presence of Chatham contaminants
\nin the creek.   <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request that Felicita Creek be added as a High-Priority water
\nquality issue in the Water Quality Improvement Plan for San Dieguito Watershed
\nand establish an action plan to address both Chatham and non-Chatham issue in
\nthe creek.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request the County do the necessary five testing events[38]<\/span><\/span><\/span><\/a>
\nto establish the coliform levels as outlined in Water Board protocol. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n17.<\/span><\/b>Please
\nrespond to these questions from our members and request for additional
\ninformation about the program.<\/o:p><\/span><\/b><\/div>\n
\na.       <\/span><\/span>We
\nunderstand that the PRP Group developed SWRBTLs.  Are they peer-reviewed and established in the
\nregulations?  Is it accurate that DTSC
\nwould not require any notification or action until they are exceeded?[39]<\/span><\/span><\/span><\/a>  Why wouldn\u2019t the effluent limitations for
\ngroundwater discharges under the Waste Discharge Requirements of 2.7 ug\/l be
\napplicable here? Would a discharge of TCE at 1,600 ug\/l into Felicita Creek be
\nacceptable to the regulatory agencies?  Would
\n340,000 ug\/l of 1,4, Dioxane?  <\/span><\/o:p><\/span><\/div>\n
\nb.      <\/span><\/span>Why has the
\nmonitoring of MW-<\/span>3-E2 (Iki) not been sampled
\nin 2013 or 2014.  When did this sampling stop? It used to be every 4
\nmonths.  Then, last year the owner was notified that it would now be
\nsampled once every 6 months, however, the latest April 2014 report shows NS for
\nboth 2013 and 2014.  Well owners have
\nbeen on record since 1997 requesting testing and never asked that it be removed.<\/span><\/o:p><\/span><\/div>\n
\nc.       <\/span><\/span>If the
\ntreatment is working so well, why are water table wells near the site MW-62 and
\nMW-64 still at historical highs or the high end of measurement after 17 years
\nof treatment?[40]<\/span><\/span><\/span><\/a><\/o:p><\/span><\/div>\n
\nd.      <\/span><\/span>Why is BTEX analyzed
\nfor the industrial water discharge but not analyzed in the groundwater
\nmonitoring program? According to the record, benzene, methylene chloride,
\ntoluene, xylene, and other contaminants were found at the Chatham site in the
\ngroundwater. [41]<\/span><\/span><\/span><\/a>  <\/o:p><\/span><\/div>\n
\ne.       <\/span><\/span>Why is FC-3
\n(Duck Pond) not regularly monitored as part of the surface water and
\ngroundwater programs?<\/o:p><\/span><\/div>\n
\nf.       
\n<\/span><\/span>The report notes that these results are reflective of the
\nunusually dry winter of 2013-2014.[42]<\/span><\/span><\/span><\/a>  Will more flows carry contamination further
\ndownstream?  What will this mean for the
\narea of upwelling of the deep VOC plumes?  
\n<\/o:p><\/span><\/div>\n
\ng.       <\/span><\/span>What does
\n\u201cgaining stream\u2019 mean?<\/o:p><\/span><\/div>\n
\nh.      <\/span><\/span>If
\nactual breakdown of TCE and PCE was really occurring, wouldn\u2019t we see higher
\nlevels of cis-1,2-DCE (a breakdown product)[43]<\/span><\/span><\/span><\/a>
\nand decreasing levels of VOCs?<\/span><\/o:p><\/span><\/div>\n
\ni.       
\n<\/span><\/span>How
\ndo they decide which well to place on the cross section maps?<\/o:p><\/span><\/div>\n
\nj.       
\n<\/span><\/span>What
\nis the \u2018separate source\u2019 of VOCs mentioned on page 31?  Who is responsible for remediation of that
\ncontamination?<\/o:p><\/span><\/div>\n
\nk.       <\/span><\/span>Would
\nregulators allow an industry to discharge the volume of water present in
\nFelicita Creek with the contaminant load documented in 2014 into a drinking
\nwater body? <\/b><\/o:p><\/span><\/div>\n
\n<\/div>\n
\n18.  <\/span><\/span> Not contaminating MWs-68
\nand 75 is not the measure of success.<\/span><\/b><\/o:p><\/span><\/div>\n
\nRepeatedly
\nin the report, it notes that contamination has not yet reached MW-68 and75[44]<\/span><\/span><\/span><\/a>
\n(the first wells south of Via Rancho Parkway) as an apparent means to
\nreassure.  We, of course, hope it never
\nmakes it to MW-68\/75 but, given history, we need to know what the plan is when
\nit makes it there. We do appreciate that there is good news that the pump and
\ntreat on the Barrel Yard itself appears to have been somewhat successful in
\naddressing pollution on the Yard.  What
\nhas not worked as well is containing the groundwater plumes as required in the
\nRAOs. <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>The RAP environmental analysis evaluated additional measures such
\nas Alternative #GS-5:<\/i> Pump and Treat Along the Length of the Plume<\/i>.[45]<\/span><\/span><\/span><\/a>  Regulators should require this alternative be
\npursued now. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\n19.<\/span><\/b>Please
\nimprove the access to information and documentation<\/o:p><\/span><\/b><\/div>\n
\nUnrelated to
\nthe content of this report, we request that the access and distribution of information
\nbe improved.  We only received a copy of
\nthe CD because one of our members received one and shared it, but others who
\nhave requested information did not receive a copy.  <\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>Several of the important documents on ENVIROSTOR such as Community
\nRelations Plan, Imminent Endangerment Order, and the Remedial Action Plan are
\nmissing pages.  We request that these be
\nreposted in complete form and all documents be complete when posted.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We know that a full set of records is maintained at the library however,
\ngiven the state of technology, we request that the PRPs and regulators create
\nan interested persons list and send all documents to that list as well as
\nmaintain the hard-copy files.<\/o:p><\/span><\/div>\n
\n\u00b7        
\n<\/span><\/span>We request that the regulators create one website or one-stop-shop
\nwhere all the documents can be found in an easily searchable manner.  As it stands now, both Envirostor and
\nGeotracker are somewhat difficult to navigate and contain different documents
\nso piecing together what is happening is very difficult.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\n<\/div>\n
\nIn closing,
\nwe can\u2019t help but be somewhat haunted by Yolanda Fleet\u2019s statements on the
\nrecord in July 17, 1997 when she said,<\/o:p><\/span><\/div>\n
\n\u201cMy well, I\u2019ve been told, will be
\nthe next one to be contaminated.  I don\u2019t
\nwant a contaminated well.  I have a
\nhabitat that I want to be kept clean in there. 
\nI really prize that water that goes down through my property, it means a
\nlot to me, and so I am really concerned. 
\nWhen are you going to stop this thing from going south?\u201d[46]<\/span><\/b><\/span><\/span><\/a>
\n<\/span><\/i> <\/o:p><\/i><\/span><\/div>\n
\n<\/div>\n
\nSeventeen
\nyears later, Yolanda Fleet\u2019s well is now contaminated.  The remedy has failed to contain the Chatham groundwater
\ncontamination. <\/o:p><\/span><\/div>\n
\n<\/div>\n
\nSomething
\nmore must be done.<\/o:p><\/span><\/div>\n
\n<\/div>\n
\nSincerely,<\/o:p><\/span><\/div>\n
\nLaura Hunter<\/o:p><\/span><\/div>\n
\nRon Forster<\/o:p><\/span><\/div>\n
\nCarolina
\nValder<\/o:p><\/span><\/div>\n
\nTina Iki  <\/o:p><\/span><\/div>\n
\nFor
\nEscondido Neighbors United<\/o:p><\/span><\/div>\n
\n<\/div>\n
\ncc. <\/o:p><\/span><\/div>\n
\nMr. Steve
\nMacDonald, PRP Group<\/o:p><\/span><\/div>\n
\nMr. Jay
\nPetrek, City of Escondido<\/o:p><\/span><\/div>\n
\nSupervisor
\nDave Roberts, County of San Diego <\/o:p><\/span><\/div>\n
\n
<\/p>\n
\n

<\/p>\n

\n
\n[1]<\/span><\/span><\/span><\/a>
\nRegional Water Board to PRP Group, November 1, 2012, p.2-3<\/o:p><\/div>\n<\/div>\n
\n
\n[2]<\/span><\/span><\/span><\/a>
\nChatham Remedial Action Plan, 1998, pp. 6-1, 6-2<\/o:p><\/div>\n<\/div>\n
\n
\n[3]<\/span><\/span><\/span><\/a>
\nMonitoring and Contingency Plan, November 12, 2012, p.27<\/o:p><\/div>\n<\/div>\n
\n
\n[4]<\/span><\/span><\/span><\/a>
\nGeneral Waste Discharge Requirements and NPDES Permit for
\ndischarges from groundwater extraction waste to surface waters within the San
\nDiego Region except for San Diego Bay. P.23 (Order No. R9-2008-0002, NPDES No.
\nCAG919002) Waste Discharge Application\/NPDES Permit.<\/o:p><\/div>\n<\/div>\n
\n
\n[5]<\/span><\/span><\/span><\/a>
\nRevision to Monitoring and Contingency Plan Updates to Surface Water Risk-Based
\nTrigger Levels, October 18, 2012, p 5 (found in Monitoring and Contingency
\nPlan) <\/o:p><\/div>\n<\/div>\n
\n
\n[6]<\/span><\/span><\/span><\/a>
\nState Water Resources Control Board, GAMA, Fact Sheet,1,4,Dioxane http:\/\/www.waterboards.ca.gov\/gama\/docs\/coc_1_4_dioxane.pdf<\/a>  <\/o:p><\/div>\n<\/div>\n
\n
\n[7]<\/span><\/span><\/span><\/a>
\nH+A, Table 8<\/o:p><\/div>\n<\/div>\n
\n
\n[8]<\/span><\/span><\/span><\/a>
\nChatham RAP, p 3-3. <\/o:p><\/div>\n<\/div>\n
\n
\n[9]<\/span><\/span><\/span><\/a>
\nH+A, Figure 6<\/o:p><\/div>\n<\/div>\n
\n
\n[10]<\/span><\/span><\/span><\/a>
\nH+A, Figure 9<\/o:p><\/div>\n<\/div>\n
\n
\n[11]<\/span><\/span><\/span><\/a>
\nH+A, p.20<\/o:p><\/div>\n<\/div>\n
\n
\n[12]<\/span><\/span><\/span><\/a>
\nH+A, Table 4<\/o:p><\/div>\n<\/div>\n
\n
\n[13]<\/span><\/span><\/span><\/a>
\nH+A, Table 2<\/o:p><\/div>\n<\/div>\n
\n
\n[14]<\/span><\/span><\/span><\/a>
\nHargis +Associates, July 11, 2014, Table 2.<\/o:p><\/div>\n<\/div>\n
\n
\n[15]<\/span><\/span><\/span><\/a>
\nH+A, Table 2<\/o:p><\/div>\n<\/div>\n
\n
\n[16]<\/span><\/span><\/span><\/a>
\nH+A, Table 2<\/o:p><\/div>\n<\/div>\n
\n
\n[17]<\/span><\/span><\/span><\/a>
\nH+A, Table 3<\/o:p><\/div>\n<\/div>\n
\n
\n[18]<\/span><\/span><\/span><\/a>
\nH+A, p.45<\/o:p><\/div>\n<\/div>\n
\n
\n[19]<\/span><\/span><\/span><\/a>
\nH+A, Table 3<\/o:p><\/div>\n<\/div>\n
\n
\n[20]<\/span><\/span><\/span><\/a>
\nH+A p.10<\/o:p><\/div>\n<\/div>\n
\n
\n[21]<\/span><\/span><\/span><\/a>
\nH+A, p.7<\/o:p><\/div>\n<\/div>\n
\n
\n[22]<\/span><\/span><\/span><\/a>
\nH+A, p 34<\/o:p><\/div>\n<\/div>\n
\n
\n[23]<\/span><\/span><\/span><\/a>
\nH+A, Table 3<\/o:p><\/div>\n<\/div>\n
\n
\n[24]<\/span><\/span><\/span><\/a>
\nH+A, Table 2<\/o:p><\/div>\n<\/div>\n
\n
\n[25]<\/span><\/span><\/span><\/a>
\nH+A, p.7<\/o:p><\/div>\n<\/div>\n
\n
\n[26]<\/span><\/span><\/span><\/a>
\nIbid, p.5<\/o:p><\/div>\n<\/div>\n
\n
\n[27]<\/span><\/span><\/span><\/a>
\nPRP report to DTSC, September 16, 2013<\/o:p><\/div>\n<\/div>\n
\n
\n[28]<\/span><\/span><\/span><\/a>
\nH+A, p.39<\/o:p><\/div>\n<\/div>\n
\n
\n[29]<\/span><\/span><\/span><\/a>
\nhttp:\/\/www.epa.gov\/oust\/cat\/mna.htm<\/a>  <\/o:p><\/div>\n<\/div>\n
\n
\n[30]<\/span><\/span><\/span><\/a>
\nhttp:\/\/www.epa.gov\/nrmrl\/gwerd\/gw\/mna.html<\/a>
\n<\/o:p><\/div>\n<\/div>\n
\n
\n[31]<\/span><\/span><\/span><\/a>
\nH+A, p.40<\/o:p><\/div>\n<\/div>\n
\n
\n[32]<\/span><\/span><\/span><\/a>
\nH+A, p.43<\/o:p><\/div>\n<\/div>\n
\n
\n[33]<\/span><\/span><\/span><\/a>
\nH+A, p.32<\/o:p><\/div>\n<\/div>\n
\n
\n[34]<\/span><\/span><\/span><\/a>
\nH+A, p.34<\/o:p><\/div>\n<\/div>\n
\n
\n[35]<\/span><\/span><\/span><\/a>
\nhttp:\/\/www.epa.gov\/ogwdw\/pdfs\/factsheets\/voc\/tech\/vinylchl.pdf<\/a>
\n<\/o:p><\/div>\n<\/div>\n
\n
\n[36]<\/span><\/span><\/span><\/a>
\nhttp:\/\/www.epa.gov\/iris\/subst\/0199.htm<\/a> <\/span><\/o:p><\/div>\n<\/div>\n
\n
\n[37]<\/span><\/span><\/span><\/a>
\nhttp:\/\/www.oehha.org\/prop65\/prop65_list\/013114P65list.html<\/a> <\/span><\/o:p><\/span><\/div>\n<\/div>\n
\n
\n[38]<\/span><\/span><\/span><\/a>
\nH+A, p.34<\/o:p><\/div>\n<\/div>\n
\n
\n[39]<\/span><\/span><\/span><\/a>
\nDTSC letter to PRP Group, March 26, 2013, p.5<\/o:p><\/div>\n<\/div>\n
\n
\n[40]<\/span><\/span><\/span><\/a>
\nH+A, Table 2<\/o:p><\/div>\n<\/div>\n
\n
\n[41]<\/span><\/span><\/span><\/a>
\nConsent Decree,p.6, para 13, December, 18, 1998 <\/o:p><\/div>\n<\/div>\n
\n
\n[42]<\/span><\/span><\/span><\/a>
\nH+A, p.19<\/o:p><\/div>\n<\/div>\n
\n
\n[43]<\/span><\/span><\/span><\/a>
\nH+A, p.9<\/o:p><\/div>\n<\/div>\n
\n
\n[44]<\/span><\/span><\/span><\/a>
\nH+A, pp. 8,9,11<\/o:p><\/div>\n<\/div>\n
\n
\n[45]<\/span><\/span><\/span><\/a>
\nRAP, p.6-8<\/o:p><\/div>\n<\/div>\n
\n
\n[46]<\/span><\/span><\/span><\/a>
\nCertified Transcript, Chatham Public Meeting, July 17, 1997, p 47<\/o:p><\/div>\n<\/div>\n<\/div>\n<\/div>\n
\n
\n
\n<\/o:p><\/div>\n<\/div>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Escondido Neighbors United filed a comment letter on the most recent submittal of the PRPs for the Chatham Barrel Yard Waste Site.  We have made many recommendations for additional information, clarification and improvements to the report.  We will keep you … Continue reading →<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-236","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"featured_image_src":null,"featured_image_src_square":null,"author_info":{"display_name":"Escondido Neighbors United","author_link":"https:\/\/escondidoneighbors.org\/?author=1"},"_links":{"self":[{"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=\/wp\/v2\/posts\/236","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=236"}],"version-history":[{"count":0,"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=\/wp\/v2\/posts\/236\/revisions"}],"wp:attachment":[{"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=236"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=236"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/escondidoneighbors.org\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=236"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}