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RIALTO -- A defense industry contractor has agreed to pay $700,000 or more annually for the operations and maintenance costs of a perchlorate removal system which uses microbes to break down the harmful chemical. West Valley Water District made environmental cleanup history late last year by shipping water directly to customers from a $23 million specialized treatment plant at its headquarters. The agreement with Goodrich Corp. authorizes funding for 100 percent of operations and maintenance costs for up to $700,000 annually for the first year and no cap for subsequent years in the life of the project, West Valley said in a statement. Negotiations have been going on since 2014. The talks were the result of a judicial consent decree which requires Goodrich, under the EPA’s oversight, to fund clean-up facilities, said Matthew H. Litchfield, WVWD general manager. Perchlorate has polluted portions of the Rialto-Colton water basin, the result of past military, industrial and agricultural activities above it ...
Following the discovery of perchlorate in portions of the Rialto-Colton groundwater basin in 1997, WVWD and the city of Rialto shut down wells in the impacted area. Following years of testing and review by regulatory agencies, WVWD began, in September 2016, using bio-remediation to remove perchlorate and restore water for potable use. The plant has the capacity to provide the water needs for about 16,000 of West Valley’s 66,000 customers. WVWD has begun working on perchlorate destroying plant number two, called a fixed-bed biotreatment plant, which takes a slightly different approach to treatment with the same naturally occurring microbes. The second plant is expected to deliver water sometime in 2019, Litchfield said. The operational costs of this second treatment technology will also be paid for by Goodrich, he said.
Jim Steinberg
San Bernardino County Sun
February 13, 2017
Currently the [Spring Valley FUDS] Groundwater Remedial Investigation is in the preliminary draft and internal Baltimore District review phase of the Feasibility Study (FS). USACE plans to submit the draft FS to USACE Environmental and Munitions Center of Expertise (EM/CX) for review before the holidays. Response to CX comments and revising the document will likely take a month or two before the draft final FS can be submitted it to the Partners. The draft final should be completed by April 2017. At that time, USACE will submit the draft final to the Partners. USACE has been following EPA guidance for evaluation of the various alternatives.
After screening all alternatives, the selected alternatives are as follows: no action alternative, land use control and long term monitoring alternative, in-situ alternative, and a pump-and-treat alternative. The details will be in the Groundwater FS. EPA noted that the regulators do not prefer the land use controls with monitoring alternative because of the monitoring aspect. If there is something unacceptable in the groundwater, the regulators prefer to have a plan for that to be remediated over time. USACE understands that the Partners’ position is the main issue with the Groundwater RI. USACE will receive those comments when the Groundwater FS is submitted for Partner review.
Spring Valley FUDS
Partnering Meeting Minutes
December 6, 2016 (pgs. 2 - 3)
US EPA recently agreed in federal court to engage in a rulemaking process over the next three-plus years which would culminate in the promulgation of final perchlorate regulations by December 19, 2019. Perchlorate remains the only unregulated contaminant for which EPA has made a final determination to regulate since the Safe Drinking Water Act (SDWA) was amended in 1996. Perchlorate is a highly soluble chemical in water and can move quickly from soil contamination into groundwater. It has been used by the US Department of Defense as an oxidizer in munitions and missiles since the 1940s, and 90 percent of its manufacturing is for the defense and aerospace industries. In a February 2011 declaration, EPA determined that it should regulate perchlorate in drinking water — giving itself 24 months from that date to propose regulations and another 18 months thereafter to finalize them under the SDWA. However, due in part to the Scientific Advisory Board’s rejection of the model EPA submitted for perchlorate regulation, these self-imposed deadlines were missed. As a result of the delay, the Natural Resources Defense Council (NRDC) filed a complaint in the US District Court for the Southern District of New York against EPA in February 2016 to enforce the deadline for proposed perchlorate regulations for public comment.
In the NRDC case, the Agency acknowledged that it failed its legal obligations to propose and promulgate a maximum contaminant level (MCL) and maximum contaminant level goal (MCLG) as a national primary drinking water standard for perchlorate ... Under the proposed agreement, EPA will: complete an “external peer review process” by October 18, 2017; propose limits by October 31, 2018; and finalize a rule by December 19, 2019. Given the amount of delay that has already occurred in promulgating federal regulations, it is somewhat surprising that NRDC accepted the length of the proposed schedule ... It is noteworthy that, in likely response to national attention paid to the Flint Michigan crisis, two US House of Representatives resolutions (H.R. 6116 and H.R. 6140 ) were introduced on September 22, 2016 that, if passed, would require the EPA Administrator to publish an MCLG and promulgate a national primary drinking water regulation for perchlorate no later than 12 months following the law’s date of enactment. This proposed legislation amending the federal SDWA has the potential to expedite the rulemaking process outlined in the settlement agreement reached between EPA and NRDC.
Jonathan S. King
National Law Review
December 26, 2016
During World War I, the U.S. Government established the American University Experiment Station (AUES) to investigate the testing, production, and effects of noxious gases, antidotes, and protective masks. The AUES, located on the current grounds of AU, used additional property in the vicinity to conduct this research and develop chemical warfare materiel (CWM), including mustard (HD) and lewisite (L) agents, as well as adamsite, irritants, and smokes. After the war, these activities were transferred to other locations and the AUES property was returned to the owners ...
Early in the SVFUDS groundwater study, much of the SVFUDS groundwater was noted to flow westward toward the natural valley currently occupied by the Dalecarlia Reservoir. The reservoir water elevation (typically about 150 feet mean sea level (ft msl) was also noted to be similar to the water table elevation along the eastern reservoir shoreline, indicating the potential for groundwater seepage into the reservoir along the eastern reservoir boundary ... The maximum arsenic and perchlorate concentrations ever measured in groundwater proximate to the eastern reservoir shoreline are orders of magnitude less than the threshold concentration (3,906 part per billion) that would increase the reservoir concentration by 1 ppb. Thus, the reservoir water quality is not threatened by possible groundwater seepage into the reservoir ...
Chemical releases from historical AUES activities have impacted groundwater and surface water proximate to the Lot 18 Debris Area and Glenbrook Road Disposal Areas. The impacts are due to arsenic and perchlorate in groundwater ... The perchlorate detected in groundwater along Glenbrook Road and in East Creek could partially, or in total, originate from the nearby upgradient area proximate to AU’s Kreeger Hall where perchlorate-impacted shallow and deep groundwater has been confirmed. The source of the groundwater perchlorate contamination on AU near Kreeger Hall, originally evidenced by groundwater perchlorate monitoring data for several locations (PZ-4S, PZ-4D, and PZ-5) is not known precisely ...
For the future scenarios, the arsenic cancer risk is 1E-04, and the perchlorate non-cancer target organ-specific HI [Hazard Index] exceeds the non-cancer threshold of 1. Arsenic and perchlorate are groundwater EU2 [Exposure Unit 2] chemicals of concern. Actions to control exposure to arsenic and perchlorate in groundwater EU2 would warrant consideration, if groundwater is to be used for potable water ... Chemical releases from historical AUES activities have impacted groundwater and surface water proximate to the Lot 18 Debris Area and Glenbrook Road Disposal Areas. The impacts are due to arsenic and perchlorate in groundwater ... A Feasibility Study is recommended to determine the best alternative to remediate the groundwater risk to future residential users.
Spring Valley FUDS
Groundwater Remedial Investigation Report
September 2016
The U.S. Army Corps of Engineers, Baltimore District is extending the public comment period for the recently released Site-Wide Proposed Plan for the Spring Valley Formerly Used Defense Site (FUDS), offering the public an additional 30 days to provide feedback. This extension means public comments will continue to be accepted through September 28, 2016. The Proposed Plan outlines the recommended cleanup actions to address any remaining unacceptable risks posed by soil contamination resulting from chemicals of concern and potential unacceptable explosive hazards due to munitions and explosives of concern. The Proposed Plan is based on the Remedial Investigation and subsequent Feasibility Study.
The RI detailed the history of the site, including the previously completed investigations and work, such as removals of arsenic contaminated soil and munitions related items that have taken place at the Spring Valley FUDS since the 1990s. The Feasibility Study evaluated various clean-up alternatives, providing the basis for the preferred remedial alternatives identified in the Proposed Plan. The public is encouraged to review the Proposed Plan in the public record and submit comments on the Proposed Plan, which can be found online under Project Efforts/Proposed Plan. Written comments can be sent to the following mailing address: U.S. Army Corps of Engineers, ATTN: Chris Gardner, Rm. 11400, 10 South Howard St., Baltimore, MD 21201; or by e-mail to: christopher.p.gardner@usace.army.mil no later than midnight September 28, 2016.
Public Notice
Spring Valley Formerly Used Defense Site
August 29, 2016
I strongly disagree with the Corps’ conclusion that no further investigation is necessary under the house at 4835 Glenbrook Road NW [Site-Wide Proposed Plan] ... In addition to lingering explosive hazards ... [the] area [is] up-gradient of the entire Spring Valley community, thus contaminating the groundwater from the ridge at the formerly used defense site’s boundary along Nebraska Avenue NW all the way down to Sibley Memorial Hospital ... At a September 2011 community meeting with Advisory Neighborhood Commission 3D, project manager Brenda Barber was asked by then-commissioner Kent Slowinski whether the Corps had talked to the workers at 4825 and 4835 Glenbrook who — in several videotaped interviews — identified precisely where munitions and chemical-filled bottles were buried during construction of those buildings. At that time, Barber replied: “Our legal counsel is actively engaged in trying to find out the names of those employees so that we can do additional interviews with them.”
For the next five years, the Army Corps evidently tried in vain to find these witnesses to the burials, yet three of those missing workers unexpectedly showed up at the May 2016 Restoration Advisory Board meeting to publicly repeat their claims. In an interview after the meeting, one of them reported that the “worst” contamination was still under the house at 4835, claiming: “There’s all kinds of stuff under it, stuff that could explode under you” [“Workers recount Glenbrook Road hazards,” May 18]. Whether or not the Corps believes these reports are credible, it’s indisputable that the plan was drafted and circulated to the cleanup partners for review well before May.
If the Army Corps had been searching for those workers since 2011, now that they’ve actually been located, isn’t it obligated to at least consider these eyewitness reports somewhere in its plan? Does anyone care that project manager Dan Noble admitted on numerous occasions that the only intrusive investigation ever conducted beneath the footprint of 4835 Glenbrook was a solitary borehole in the center of the basement? Since the Army has launched a “potentially responsible party” investigation to identify the developers of 4835 Glenbrook ... (in order to recoup added cleanup costs), isn’t it the Corps’ fiduciary responsibility to determine what the price tag will be by actually remediating [this] site as soon as possible?
Allen Hengst
Northwest Current
August 10, 2016 (pg. 7)
To address possible disposal areas, a generic MEC HA [Munitions & Explosives of Concern Hazard Assessment] that conservatively assumed a worst case disposal area/burial pit scenario was completed ... Unknowns associated with the identified possible disposal areas ... suggest the need for response actions to mitigate unacceptable explosive hazards that could exist in these areas. The AU Public Safety Building (PSB) is considered one of these possible disposal areas. As the PSB is an active building on the AU campus, so long as it remains in place, it effectively acts as a cap or control to contain any potential explosive hazard (that is, it prevents interaction between source and receptor). However, when the PSB is removed, the preferred explosive hazards mitigation alternative will be applied to the area and any burial pits will be properly addressed.
Spring Valley FUDS
Final Proposed Plan
June 7, 2016 (pg. 8)
The Partners discussed how to address the remedial action for the debris under the building during the unspecified period of time between the Decision Document (DD) and the removal of the building ... AU asked whether the university would have to wait after the building was removed, possibly years, until the AUES-related debris could be excavated and removed from the campus. USACE confirmed that if the remedy is specified in the DD, the Army is required to fund implementation of it; however when it can be implemented based on the availability of funds for any given year is unclear ... AU explained that the building is expected to be no longer used for Public Safety operations once the new development on the East Campus is completed [March 2017]. The potential for unclear timing of a future remedy may influence the university’s plans for the building and whether a new office operation would be relocated to the building.
Spring Valley Partners
Meeting Minutes
November 3, 2015 (pgs. 7 - 8)
Allen Hengst: Have you discussed AU's future plans for that building, because it's falling apart?
Dan Noble: We have indications from American University that the removal of that building is probably going to happen sooner rather than later. So we are planning within our budgetary cycle to have the funds available to implement that portion of the remedy.
Restoration Advisory Board
Meeting Minutes
July 12, 2016 (pg. 10)
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