Industrial Waste – Completed Exposure Pathways

From 1965 to 1 December 1981 (16 years), the Air Force dumped 5,578,400 gallons of industrial waste containing known carcinogens into the sanitary sewer, which emptied into the sewage treatment plant (STP), and the STP discharged directly into the STP’s percolation ponds. However, the Air Force determined that the unlined percolation ponds, the soil, and the groundwater were NOT contaminated based on one (1) sample. The Air Force failed to explain why only one sample point was used, and what happened to the 5,578,400 gallons of industrial waste that were indirectly dumped into the unlined percolation ponds. Source: IRP Phase I Record Search, Table D-1 “Master List of Industrial Operations,” CH2M Hill, January 1982

Exposure Pathway (EP): Industrial Waste → Sanitary Sewer → Sewage Treatment Plant (STP) → STP’s Percolation Ponds → STP’s Percolation Ponds effluent (outflow) → Chlorinator → Golf Course Irrigation → Aquifer → Supply Wells for George AFB, Adelanto, several homes, and the former Victor Valley Country Club → contaminated drinking water  → civilians, military personnel and their family members

This contaminated drinking water provided the following Completed Exposure Pathways (CEP)

The Department of Defense (DOD) and Air Force failed to notify the Agency for Toxic Substances and Disease Registry (ATSDR) of this potential exposure pathway for the Health Assessment of George AFB.

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History

1. 

   The Air Force dumped approximately 5,578,400 gallons (4) of a toxic cocktail containing acids, chemicals, cleaners, degreasers, detergents, developer, fuel, grease, herbicides, lubricants, medical wastes, oils, paints, pesticides, process chemicals, solvents, strippers, [TCE], waste oil, and wax into the sewer at George AFB (5).

2. The effluent (outflow) from the sewage treatment plant’s percolation ponds containing this toxic cocktail was used to irrigate the golf course (a.k.a. S-12, OT-22) from 1965 to 1 December 1981 (6).
3. The golf course is within 500 feet to a ¼ mile adjacent/upstream of the cluster of high volume production wells for George AFB and Adelanto, and smaller wells for private homes, and the former Victor Valley Country Club (7).

4. 

   The groundwater flows northeast under the golf course to the “Zone of Contribution” (ZOC) for the well fields for George AFB, Adelanto, and private homes, and the former Victor Valley Country Club, and therefore considered upstream of these supply wells (8).

• The DOD claims that the source of the TCE contamination plume at the old sewage treatment plant’s percolation ponds is unknown even though the DOD acknowledges that it dumped [approximately 5,578,400 gallons of a toxic cocktail containing TCE] into the sanitary system (3).
• The Air Force would have us believe that there is/was NO contamination plume extending off base from the golf course, that the contamination at the golf course posed NO threat to the nearby high volume production wells for George AFB and Adelanto, and the smaller wells for private homes, and former Victor Valley Country Club.  This is why this potential completed exposure pathway was NOT assessed (1).
• However, volatile organic compounds (VOCs) were detected in the private wells of homes located at 18401 and 18499 Shay Road (2).  These homes are about a ½ mile downstream of the golf course.  The groundwater flows northeast under the golf course to these wells. Despite finding VOCs in these wells, the DOD chose not to implement an environmental assessment of the golf course’s contamination plume.
• The ATSDR relied on the DOD to supply ATSDR with the relevant documents and information for the Health Assessment for George AFB (9).  Because the DOD did NOT supply the relevant documents and information to the ATSDR, the ATSDR did not fully understand the nature and extent of the contamination, locations of the Installation Restoration Program (IRP) sites, hydrology (direction of the groundwater flow, north-east), and the location (within 500 feet to a ¼ mile upstream) of the water supply wells for George AFB, Adelanto, private homes, and the former Victor Valley Country Club (10).
• The DOD knew that the ATSDR came to a flawed conclusion in their 1 December 1998 report “Health Assessment for George AFB,” section “Evaluation of Groundwater Exposure Pathway” (11).
• Because the DOD did not correct the ATSDR during the Peer Review / Public Comments period or after the report was published in 1998, (12) the Department of Defense (DOD) lied by omission.

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References

1. The potential golf course contamination plume was not assessed – AF
   The golf course was not included in these IRP Phase II (Stage 2) investigations – AF
2. Volatile organic chemicals (VOCs) were detected in two private wells – AF
       Volatile organic chemicals (VOCs) were detected at 18401 and 18499 Shay Road – AF
3. TCE was detected in the groundwater at old sewage treatment plant percolation ponds – EPA
4. 348,650 gallons a year x 16 years = 5,578,400 gallons
5. Appendix D Industrial Facilities – AF
6. Effluent used to irrigate the golf course from 1965 to 1 December 1981 – AF
7. George AFB and Adelanto Water Production Wells – map – AF
8. The aquifer below the base flows northeast – EPA
       The groundwater flows to the northeast at George AFB – AF
9. References – Health Assessment – ATSDR
10. No source of potential contamination could be identified for the Golf course – ATSDR
11. Conclusions – on-site and off-site groundwater does not represent a public health hazard – ATSDR
12. Peer Review / Public Comments of the ATSDR Health Assessment – ATSDR

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Definitions

Complete Exposure Pathway

Definition: “A complete exposure pathway is how a chemical can be traced, or expected to travel, from a source to a plant or animal that can be affected by that chemical.” – EPA

Zone of influence 

Definition: “A zone of influence is the distance from a well in which a cone of depression and drawdown can be measured.  Ground water within the zone of influence flows to the well.”

Zone of Contribution

Definition:  “The area surrounding a pumping well that encompasses all areas and features that supply groundwater to the well is called the zone of contribution.  The zone of contribution of a well is different from the zone of influence.  The zone of contribution includes all areas that contribute water to a well, while the zone of influence only includes the area within which water levels are lowered by pumping.  While the zone of influence usually is smaller than the zone of contribution, it may not lie entirely within the zone of contribution.  For example, if regional flow velocities are high, flow along the outermost and downgradient portions of the zone of influence may be carried beyond the well; this flow lies within the well’s zone of influence but not its zone of contribution.  It is important to remember that the zones of influence and zones of contribution are three-dimensional, volumetric entities.  In cross-section, they will extend from the water table (or top of the aquifer, in a tightly confined aquifer) to the elevation of the bottom of the well’s screened interval.  If the well does not extend to the bottom of the aquifer, portions of the aquifer below the screened interval will also contribute flow to the well.”

Lying by omission:

Definition:  “A lie of omission also known as a continuing misrepresentation, a lie by omission occurs when an important fact is left out in order to foster a misconception. Lying by omission includes failures to correct pre-existing misconceptions”