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PCE or Tetrachloroethylene in Drinking Water Supply Well F-KIM1 (groundwater) in Fullerton, California was featured in the Orange County Water District (OCWD) Groundwater Management Plan 2004 Dated March 2004 (see Page 6-16 {at pdf 99} and the document attached hereto-167 pages in length). It appears well F-KIM1 was shutdown in 2001 for the PCE concentration was almost at 5 ug/L (ppb) which steadily increased during the eleven years since 1990 as shown in Figure 6-9. The impact of PCE, a chlorinated solvent, was featured in this report in a chapter entitled “Groundwater Quality Management” or Chapter 6. Here is a paragraph from the previous page, page 6-15, that gives an overview(Note-VOC is volatile organic compound):

“The VOC plume is primarily confined to the shallow most aquifer, which is generally less than 200 feet deep; however, hydrogeologic data indicate a potential for VOC-impacted groundwater to move down into deeper aquifers tapped by existing production wells. In fact, within the past several years, two City of Fullerton production wells were removed from service and eventually destroyed because of increasing PCE concentrations. Figure 6-9 shows the PCE concentration at one of these production wells before it was removed from service. To minimize the spread of VOC contamination, which may put additional production wells at risk, OCWD is implementing the Forebay VOC Cleanup Project. The primary objective of the proposed Forebay VOC Cleanup project is to prevent further spread of groundwater contaminated by VOCs.”



Well F-KIM1 was located adjacent to 1550 East Kimberly Avenue in Fullerton which was at the northwest corner of a large battery manufacturing plant, which operated from the early 1960’s up through the mid-2000’s or throughout the period of record shown in Figure 6-9 (1990-2001) at this location. The address of this location now, where the well was located, is 1400 Kimberly Avenue, Fullerton. Please see attached presentation entitled “Cleaning Up Someone Else’s Plume, Orange County Water District’s North Basin Groundwater Protection Project” dated May 2008 (14 pages) that shows the rapidly increasing PCE concentrations, on page 7, that were drawn into the active production well, F-KIM1. Various extraction wells are shown on page 10 of this presentation which was part of a remediation effort led by OCWD. PCE is much heavier than water and tends to go deep into the ground as a result, i.e. it sinks. As a resident of Orange County, I am curious what the effects of pumping at EW-1 through EW-4 had on the movement of PCE. Is it possible this large amount of pumping made the chlorinated solvent problem worse by spreading the sources of contamination into deeper and wider areas? What about the effects of pumping F-KIM1 for over 11 years when there were known PCE sources in the vicinity of this well?

It appears a replacement drinking water well for F-KIM1 was installed from January 2002 through May 2002 (Well Completion Report for Kimberly 1A attached hereto). This well is 1,243 feet deep in a boring that extended to a depth of 1,353 feet in depth. The new well is F-KIM1A and was most likely installed to a much greater depth than the original groundwater drinking water supply well, F-KIM1. The stated address on the well completion log is 1400 Kimberly Avenue. How deep was the original well that was destroyed in January 2002, F-KIM1? It stands to reason the well was much shallower than the replacement well, F-KIM1A. Was the new well installed to dilute the contamination with clean water from deeper in the earth? If the original well was 700 feet deep, we know it was pumping large amounts of water for decades and then it sucked in PCE from various sources in the area. The closest source would be from the adjacent site and, if this site had released a large amount of PCE, that PCE was likely pulled down to a depth of approximately 700 feet for F-KIM1 was pumping large amounts of water. The new well, F-KIM1A, was, let’s say installed to twice the depth of the original well, F-KIM1. That would mean that there was 700 feet of clean water column that could dilute out contamination that had originally been sucked into this vicinity/F-KIM1. It appears that F-KIM1 and the replacement well, F-KIM1A used the same pumping infrastructure for they were located in the same area. Why would you install a new drinking water well right through an area that is known to have contamination and the area adjacent to this well, F-KIM1A, was not cleaned up to pristine conditions? Who paid for this new, deeper well, F-KIM1A? It seems the quantity of water from this well was necessary to provide adequate supply for OCWD. The large amount of groundwater pumping that is going on near a known source(s) of PCE contaminated soil&groundwater could be contributing to the problems in the North Basin.

The battery manufacturer, Johnson Controls, is not listed in the Jan 2018 HRS. I’m concerned this site was not investigated thoroughly and the rapid cleanup in late 2006/early 2007 was inadequate. Both groundwater supply wells, F-KIM1 and F-KIM1A, were located at the northwest corner of Johnson Controls’ parcel (see attached aerial photos from 1995&2003 that show Johnson Controls close proximity to F-KIM1 and F-KIM1A, respectively). Why was a huge battery manufacturing plant not included in the Jan 2018 HRS (as a PRP) for most people who have worked in the North Basin know that this site used large amounts of PCE/other chlorinated solvents (removed over 2,200 pounds of VOCs, including PCE, with their limited soil vapor extraction system)? The US Army Corps of Engineers(USACE) states, regarding chlorinated solvents found in the soils to a depth of 100 feet, at this battery manufacturing site “highest hits found in clayey materials”. See attached slides “Fullerton-CSMpresent.compressed” entitled Johnson Controls, Fullerton CA Conceptual Site Model Presentation prepared by USACE. These 55 slides were obtained from The Triad Resource Center website https://triadcentral.clu-in.org/ . My examination of the slides show the slides were created on September 8, 2006 or over 11 years and eight months ago.

The language on the website states:


”A Smarter Solution to Site Cleanup. The Triad is an innovative approach to decision-making for hazardous waste site characterization and remediation. The Triad approach proactively exploits new characterization and treatment tools, using work strategies developed by innovative and successful site professionals. The Triad Resource Center provides the information hazardous waste site managers and cleanup practitioners need to implement the Triad effectively.”
 

I’m concerned that the chlorinated solvents “Highest hits found in clayey materials” found to a depth of 100 feet underneath that site (Johnson Controls, Fullerton, CA, “the JC site”) are a significant long term source of regional groundwater contamination. The chlorinated solvents were not substantially removed from the JC site by a short-term vapor extraction system and were not investigated thoroughly across that site (see USACE slide 40). You will also find the following language on page/slide 40  “Clayey materials does not appear to be an impermeable aquitard”. I see three closed PCE contour lines on USACE slide 39 that indicates at least two known PCE sources in the soils on the JC site. I also note on USACE slide 42 that those PCE sources: a. extend/reside in the clayey materials, b. are widespread, c. have not been thoroughly investigated and d. extend to significant depths. A site that was once “closed” by State Regulatory Agency or who may have settled with a water district does not, in any way, eliminate that site from being a potentially very large source of on-going regional chlorinated solvent contamination. Some of the sites listed in the Jan 2018 HRS were either closed by a state/local regulatory agency and/or paid money to the water district. How is it that some of these sites are included in the Jan 2018 HRS and others not?   On USACE slide 54, how can the Army Corps of Engineers state on this slide entitled “Property Transfer” that “Turn over clean, dirt site to Lowe” if they previously stated there is a large amount of PCE (other chlorinated solvents) extending down to a depth of 100 feet in clays (vapor extraction has very limited, if any effectiveness, removal efficiency in clay) in the very same presentation?  It appears to me there was an abundance of publicly available information on this site, Johnson Controls, that was readily available for detailed examination. Any entity charged with examining possible chlorinated solvents sources in Orange County North Basin would undoubtedly come to the same conclusions and questions above.

Attachments:

  1. OCWD Groundwater Management Plan 2004
  2. Cleaning Up Someone Else’s Plume, OCWD North Basin Groundwater Protection Project 2008
  3. 2002 Well Completion Report
  4. Aerial Photographs:1995 and 2003
  5. 2006 US Army Corps of Engineers, Johnson Controls, Fullerton CA Conceptual Site Model Presentation
  6. 1955 Well Completion Report