1P. September, 17, 2003: “Runkle Canyon_Miller Brooks_Site Investigation of Western 350 Acre Parcel_91703” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/1246061027/Runkle%20Canyon_Miller%20Brooks_Site%20Investigation%20of%20Western%20350%20Acre%20Parcel_91703.PDF
P. 3/50 pages of the PDF: The strontium-90 concentration in Sample SS- 16 (0.686 pCi/g) was found not to exceed exposure limit considered to be protective of human health (1.23 pCi/g; Foster Wheeler, 1999 and Harding ESE, 2000).
Again, it seems that Miller Brooks either ignores or does not understand the EPA’s concept of Preliminary Remediation Goals which are limits that correspond to a cancer risk of one in a million. The 0.686 pCi/g reading is nearly three times the PRG for strontium-90 and is nearly 23 times background for the area. Likewise, the reference to Foster Wheeler’s 1.23 pCi/g reading being “protective of human health” is also false.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
*1P. Could DTSC respond in detail to the above observations?*
1Q. September 17, 2003: “Runkle Canyon_Miller Brooks_Site Investigation Report 550 Acre Parce_91703” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/1246061027/Runkle%20Canyon_Miller%20Brooks_Site%20Investigation%20of%20Western%20350%20Acre%20Parcel_91703.PDF
P. 1 of this 102 page PDF: The average strontium-90 concentration in surface soil is about 0.1 pico Curie per gram.
This concentration is not applicable to the Simi Valley area which the EPA estimated in 1995 was 0.052 pCi/g and later determined by EnviroReporter.com to be actually 0.030 pCi/g utilizing averages for the area derived from EPA results.
EnviroReporter.com readers have asked us why the area’s background measurements for strontium-90 are about a third of the average nationwide, especially considering the proximity to Rocketdyne, site of at least two partial nuclear meltdowns. Our reply is that most strontium-90 fallout from atomic and hydrogen bomb above ground testing in Nevada made its way eastward on prevailing winds thereby not impacting areas to the west of it as much. Simi Valley and Runkle Canyon are substantially west of the now-inoperable Nevada Test Site.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
*1Q. Could DTSC respond in detail to the above observations?*
1PP. September, 17, 2003: “Runkle Canyon_Miller Brooks_Surface Water&Groundwater Sampling Rpt_91703” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/2949491202/Runkle%20Canyon_Miller%20Brooks_Surface%20Water&Groundwater%20Sampling%20Rpt_91703.PDF
P. 6 of this 146 page PDF: In addition soil samples surface water samples from springs and seeps and National Pollutant Discharge Elimination System (NPDES) discharge samples collected by the Department of Toxic Substances Control (DTSC) and The Boeing Company (Boeing) at or near the Runkle Canyon Property as part of the Rocketdyne Propulsion and Power Santa Susana Field Laboratory (SSFL) sampling programs show no detectable concentrations of perchlorate. Perchlorate at levels ranging between 130 to 156 times less than the Environmental Protection Agency (EPA) Preliminary Remediation Goals (PRG) for perchlorate in residential soil 7.8 milligrams per kilogram was detected in two groundwater/silt samples collected at depths greater than 35 feet below the surface of the Property Based on the depth of the two silt samples impacted with perchlorate the extremely low levels of perchlorate detected in those samples the non-detectable levels found in all other samples and the lack of exposure pathways there is no indication that activities at the Property surface will be impacted by perchlorate.
Miller Brooks repeats the same misleading and deceptive information that it has in other reports regarding this sampling. The perchlorate was found in the 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.
P. 11/146: Miller Brooks testing of surface water consists solely of examining the leachate of asphaltic material found in the middle of the road. No analysis of the actual surface water in the intermittent stream or vernal pools occurred and yet, in spite of the name of this report, the lab asserts, falsely as later found out by the Radiation Rangers, that the surface water has no heavy metal contamination.
P. 53/146: Arsenic soil reading of 3.3 mg/kg exceeds its soil PRG of 0.062 mg/kg by a factor of 53.23 times.
Our comments, above, regarding Miller Brooks assessment of the 750-acre parcel apply to this report as well.
*1PP. Could DTSC respond in detail to the above observations?*
1R. May 21, 2003: “Runkle Canyon_Miller Brooks_Asphalitc Material & Surface Water Sampling_52103” available at http://www.envirostor.dtsc.ca.gov/public/community_involvement/8803418815/Runkle%20Canyon_Miller%20Brooks_Asphalitc%20Material%20&%20Surface%20Water%20Sampling_52103.pdf
P. 7 out of this 43 page document: As we reported in the June 21, 2007 Los Angeles CityBeat cover story “The Radiation Rangers,” Miller Brooks did not test the surface water for heavy metals:
The city soon informed the Stop Runkledyne group that KB Homes had reminded them that they had already tested the surface water and had submitted that information in a comprehensive 42 page report that was already in the development’s EIR. That 2003 report by Huntington Beach-based Miller Brooks Environmental Inc. tested one asphalt sample and a nearby surface water sample.
In the body of the report, Miller Brooks writes that Title 22 metals were “below state and federal regulatory limits (see Table 1).” Indeed, Table 1 actually says that the Title 22 metals in the surface water sample were “not analyzed.” Oddly, the Title 22 metals were tested in the asphalt but not in the water.
*1R. Could DTSC respond in detail to the above observations?*
1S. May 8, 2003: Runkle Canyon_Miller Brooks_Phase I & II_Pgs 1-120_50803
P. 23 of the 120 page document: Perchlorate was detected in groundwater/silt samples collected from 56 feet and 37 feet bgs respectively in Borings HS-25 and HS-26 at concentrations of 0.006 mg/kg and 0.05 mg/kg respectively The perchlorate was detected in the silt/groundwater samples at concentrations below the EPA PRG for residential soil (7.8 mg/kg). Therefore the perchlorate does not pose threat to human heath [sic].
As EnviroReporter.com has commented on this sampling repeatedly, using a soil standard for this result is incorrect. A water standard is correct. Also, the figure of 0.006 is a typo – the true measurement is 0.06 parts per million or 60 parts per billion for water.
Recent Comments