Despite nearly three decades of clean-up efforts at a central Palo Alto Superfund site, groundwater contamination from a leaky underground chemical tank has dramatically concentrated in some small areas, according to a new water-quality report.
None of the contamination is threatening homes but it is causing some concern about vapors penetrating commercial buildings.
Underground contamination from the “Hewlett-Packard 620-640 Page Mill Road Superfund Site” has increased in some areas, according to a five-year review released Sept. 30 by the California Regional Water Quality Control Board San Francisco Bay Region. It is the third five-year study.
Inspectors have noted a slow decrease in contamination in many areas, but dramatic rises in some areas, the report states.
The contaminated plume emanates from the former HP site and combines with contamination from two other locations: the former Varian Medical Systems, Inc., facility at 601 California Ave. and the former HP facility at 395 Page Mill Road.
The plume, which contains heavy metals and toxic chemicals known as volatile organic compounds (VOCs), has affected groundwater under parts of Stanford Research Park, the Palo Alto Mayfield soccer complex, Palo Alto Square, Fry’s Electronics and the Palo Alto Courthouse, among numerous other businesses.
Contamination has not spread into the adjacent residential area, the report said.
The Regional Water Board approved decommissioning groundwater monitoring and extraction wells at the former Mayfield School site in 2005. That site was redeveloped by Stanford University into the Stanford/Palo Alto Community Playing Fields soccer complex in 2006.
In some areas, contaminated water in close proximity to the soil’s surface has brought toxic vapors into buildings, according to the report, which was created from monitoring done by Stantec, a company hired by HP and Varian.
HP has reported a cumulative cost of $6,788,253 through October 2009 to clean up the contamination. The clean up has been ongoing since 1982. The company detected a toxic leak from a 1,000-gallon underground solvent-storage tank in 1981 and began remediation to remove the contamination from soil and groundwater in 1982. The company left the site in 1986 but continued its lease until 2007.
The site contains contaminants in the soil including arsenic, gallium, trichloroethene (TCE), trichloroethane (TCA), 1,1 dichloroethene (DCE), tetrachloroethene (PCE) 1,2,4 trichlorobenzene and phenol. It was added to the federal Superfund site list in 1990.
The plume extends 1,500 feet northeast under Oregon Expressway and runs from the HP 620-640 Page Mill Road site northward in a finger to California Avenue under the former Varian site. It flows east along Grant Avenue to Alma Street and the Oregon Expressway underpass, then south along Portage and Lambert Avenues, just shy of Matadero Canal, according to report maps.
Inspectors have seen a slow decrease in toxic levels in many areas within the plume area. During the last five years, 880 pounds of VOCs were removed from the 620-640 Page Mill site. The off-property study area, which includes the Oregon Expressway Underpass area, removed 1,267 pounds of VOCs.
But contamination levels have risen dramatically in some areas. Water Quality Control Regional Water Board inspectors want more monitoring and a better analysis of the extent of the contamination and if some areas are emitting vapors from underground.
An area just south of the 620-640 Page Mill Road buildings showed TCE levels in groundwater increased by 75 percent.
TCE concentrations increased by 20 percent from 2005 to 2009 in a monitoring well near El Camino Real and Page Mill Road. But water collected from two bore holes near the well site at 2875 and 2865 El Camino Real (the northeast corner of El Camino Real and Page Mill Road, respectively), indicated TCE levels have increased nearly 800 percent, according to the report.
The groundwater is not used for drinking or bathing and so does not pose a risk of off-gassing vapors from showers and baths, but inspectors expressed concern about air vapors that could seep into buildings. Rising groundwater levels in some areas have re-saturated soils.
The effectiveness of vapor barriers is also still not completely known, according to the report. In the Stanford Research Park, HP installed a vapor barrier under portions of the replacement building in 1994 and added a grated entrance to an underground parking area for increased ventilation. The current occupant, Wilson Sonsini Goodrich and Rosati, took indoor air samples in 2009 and found volatile organic compounds on the first-floor level at one location. None were detected on the second floor. Wilson Sonsini plans to conduct more indoor sampling to confirm its findings at the end of 2010, according to the report.
Groundwater TCE concentrations have also increased in the area at the northwest corner of El Camino and Pepper Avenue. The groundwater is close to the surface and there is potential for contaminating vapors to enter buildings, inspectors said.
The Regional Water Board also wants to determine if the contaminated area has spread due to rising groundwater levels. The extent of contamination should be fully defined in the so-called A1, A1 Upper and A2 zones (from the western edge of the pollution site and north and east along portions of California Avenue, Page Mill Road, Grant and Sherman Avenues to Park Boulevard and the Oregon Expressway underpass.)
The potential for vapor intrusion cannot be determined until the extent of groundwater contamination in these areas is defined, according to the report.
The study determined the potential vapor-intrusion areas should be reevaluated within 18 months. HP should submit its next five-year report to the water board by Feb. 1, 2015, inspectors said.
This article would be enhanced by providing a URL for the report that is described. The article is vague on specific information. I would like to read the actual report.
Eureka!
http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dc283e6c5d6056f88257426007417a2/351973b3feacb7a8882577af0073b60e/$FILE/HP%20620%20640%20PMR%20FYR%209%2030%202010%20Final.pdf
A door to door prevalence count of various cancers should be quickly done to consider the possibility that this pollution site has already caused health problems for residents. The proof may already exist. This is not a difficult pilot study to rapidly complete.
Carly says the government should butt out and let the individual home owners fend for themselves.
Queen Meg says “ditto” to Carly: Let the mere mortals eat cake (laced with cancer-causing chemicals, of course)!
New Title 24 ventilation requirements will probably insure against any harmful concentrations.
Carly’s company created this pollution so she has a vested interest in limiting corporate liability.
Kudos to Sue Dremann for an important piece of reporting. Sue it would be very helpful if you could include the following for Palo Alto Online readers:
1) The URL for the complete original report for residents to read
2) A map illustrating the sites and the flows
3) A list of reputable testing organizations that residents can contact to test air vapors, ground water and soil.
4) A list of City and State contacts for residents to demand timely testing of air, water and soil.
5) A list of corporate contacts responsible for the sites so that concerned residents may contact them to demand payment for reputable testing.
This would make a good bit of reporting much more helpful and impactful for residents.
Thank you.
The Article state: “(the plume) … has affected groundwater under <some sited deleted> Fry’s Electronics and the Palo Alto Courthouse, among numerous other businesses. “
Then says:
“Contamination has not spread into the adjacent residential area, the report said.”
How can this be? There are houses between the two.
Gee, and people haven’t even thought about the former ROMIC plant to the east, yet!
It’s time to co-ordinate ALL the toxic waste sources in the SFBA and the reports on what is being done about them. There are probably far more places that dumped waste on the ground or buried it locally than people realize.
http://www.elandar.com/toxics/stories/neighborhood.html
Silicon Valley is among the most toxic regions in America. Santa Clara County alone houses 23 Superfund sites – sites the Environmental Protection Agency (EPA) has declared the highest priority for environmental clean-up because of their health hazards. No other county in the nation has more of these sites. On the Environmental Defense Scorecard, Santa Clara County ranks in the top 10 percent most polluted counties in the United States.
I lived near the “ Rust Bucket “…..but no one talks about that site….
Ditto on EJ’s ‘Kudos to Sue Dremann’. I also agree that additional urls and info posted would help.
Question: Agilent took over the HP building (not sure if it is same address), when they split off from HP. And Agilent moved out since then? So does that affect who owns the clean up?
“Carly” and “Queen Meg”:
As some teacher must have said to you at some time in your life, “Show your work.” That is, actually provide evidence that Fiorina and Whitman think that industrial pollution shouldn’t be cleaned up, or that Palo Altans should eat cancer-causing food.
Sorry, but unsubstantiated insult doesn’t fly anymore here.
When I started learning about Palo Alto city government and following how the city handles development projects, I was shocked to discover how lax and unconcerned the city is when it comes to identifying, understanding and addressing the impacts of this type of contamination. Bob Moss had to sue the city because it approved a project at 195 Page Mill (a dense housing and research office project) without considering the impacts of this contamination (as required by state law). (Bob Moss won the lawsuit, and the city had to pay a share of his court costs and attorneys’ fees, so Palo Alto taxpayers ended up having to pay for the city’s negligence).
Palo Alto continues to target part of the area affected by this underground contamination for high density “low income” housing without regard to the contamination. Palo Altans should be ashamed of their city government and the way that the city has been moving away from integrated BMR units to segregated, dense “low income housing” that is s clustered in areas where low income residents are exposed to higher levels of pollution (air pollution, noise pollution and underground chemical pollution). Palo Alto’s elected officials even brag about their accomplishments in diverting BMR monies to build segregated, high density “low income” projects such as 801 Alma St. (This project won’t even provide adequate open space for its residents because it was more important to squeeze in a larger number of units than to provide suitable open space).
City staff leads Palo Alto’s City Council by the nose, and the City Council allows this.
When I started learning about Palo Alto city government and following how the city handles development projects, I was shocked to discover how lax and unconcerned the city is when it comes to identifying, understanding and addressing the impacts of this type of contamination. Bob Moss had to sue the city because it approved a project at 195 Page Mill (a dense housing and research office project) without considering the impacts of this contamination (as required by state law). (Bob Moss won the lawsuit, and the city had to pay a share of his court costs and attorneys’ fees, so Palo Alto taxpayers ended up having to pay for the city’s negligence).
Palo Alto continues to target part of the area affected by this underground contamination for high density “low income” housing without regard to the contamination. Palo Altans should be ashamed of their city government and the way that the city has been moving away from integrated BMR units to segregated, dense “low income housing” that is s clustered in areas where low income residents are exposed to higher levels of pollution (air pollution, noise pollution and underground chemical pollution). Palo Alto’s elected officials even brag about their accomplishments in diverting BMR monies to build segregated, high density “low income” projects such as 801 Alma St. (This project won’t even provide adequate open space for its residents because it was more important to squeeze in a larger number of units than to provide suitable open space).
City staff leads Palo Alto’s City Council by the nose, and the City Council allows this.
Exposed: you make some great points. I suggest you email your comments to the city council at city.council@cityofpaloalto.org
Does anyone know if the water that continually seeps into the Oregon underpass has ever been tested?
When you consider the organic and inorganic natural toxins that flow beneath all of us everywhere, It would seem a showing of harm should precede any panic. As for who profited from these polluting actions, I believe most of the polluting ended before we chased them away to China and definitely before Carly came aboard.
Good to know your kids are playing soccer on a superfund site with levels of TCE, PCE, DCE, PCA, and other unknown contaminates exceeding all known groundwater standards. If toxic vapors are emitted through a concrete slab in a building, what toxic vapors are being emitted on a field covered with plastic grass? Perhaps some type of signage on the property notifying that the site is a superfund site with possible toxic vapors present and noted health hazards would be appropiate.
Post a proposition 65 sign on both sides of your front door. Since Adam was evicted the world has been a place of danger. You huddle in your cave or you go out and whack something edible to drag home and eat. If there is a clear and present danger, re-mediate it. If the hazard is evanescent, stay in your cave [and worry about Radon.]
I agree with exposed about the incompetence and “overreaching” (my word) of the Palo Alto city council. I vote Democratic mostly, but I am very conservative, in the old meaning of the word, ie. do not do something you do not understand and break something that works or cause more problems than we now have … and especially just to line the pockets of people who are not here long term and just do not care about anything but money.
The stupidity of allowing the Palo Alto Foothills, something that should belong to all of us forever, to be raped and plowed under instead of developed as a long term natural resource is a crime against humanity as far as I am concerned. We go to South American and say they must conserve their rain forests as a natural legacy of humanity when we, and especially the hypocritical jerks who run our country, state and city the exact opposite. It is time the US, CA and Palo Alto stopped being such a hypocrite and started to realize where the real value for all of us comes from, and it is not in giving huge amounts of money to people and expecting them to look after our best interest, create local jobs, or help anyone but themselves.
Isn’t this site owned by Stanford?
For some background, I am a membr of the Barron Park Association FOundationwhich had 2 grants from EPA to oversee investigatoina and remediation of the Superfund sites in Palo Alto, including the 640 Page Mill, 1501 Page Mill, and COE extension of 640 site. We wond national awards for our oversight of the contamination and remediation and even though the grants expired we still oversee the toxics and cleanup at the sites.
Both the groundwater and soil at the COE site as well as 640 are contaminated with toxic levels of TCE as well as other toxins. TCE is considered the worst because it is prevelant, a known carcinogen, and suspected of a number of other diseases such as Parkinson. Yes the water that flows into the Page Mill underpass is contaminated.
There are a number of mustifamily buildings in the COE area. Most are not at serious risk because even where they have underground garages the garages are open to the air so VOCs escape into the outside air and not into buildings. EPA considers this a safe type of construction and I agree. However there are 2 residential buildings that have serious danger potential from TCE entering living and working spaces. The worst is 200 Sheridan where a 2 level underground garage penetrates the contaminated aquifer, and at times water from that aquifer leaks into the garage. The other is 345 Sheridan where the underground garage is sealed from outside air and subject to transmiting TCE via the stairways and elevators into living spaces. BPAF has been trying for 7 years to get the Water Board which oversees these Superfund sites to require indoor air testing to see if people are exposed to dangerous levels of TCE or other VOCs. They refused. Last year they did ask HP if they would pay for indoor air sampling and HP refused to test voluntarily.
As for 395 Page mill, HP is still the responsible party for the site unless the sales agreement explicitly transferred responsability to the new owners which is extremely unlikely – who will buy liabilities?
I argued with the Water Board in September that many parts of COE and 640 sites show a leveling of contamination levels and the old pump and treat approach no longer works as the cleanup seems to leveled off so new treatments are needed. They didn’t seem convinced.
It is possible to add vapor barriers under existing building to prevent future VOC entry, but of course that costs. Any new building must have both full membrane barriers and active vapor barriers, per the latest EPA guidelines. Unfortunately EPA regulations don’t apply in Palo Alto where the Water Board has oversight. My friends in Mountain View say how happy they are to be under EPA regulation not Water Board.
Bob, what would be the problem requiring continuous ventilation of lower spaces as required by the new Title 24. This might help the Radon problem, too. Just remember, the dose defines the poison.
Regarding continuous ventilation, that is what is achieved by approaches such as putting residential buildings on podiums so that natural airflow sweeps the VOCs away for entering the living spaces. It also can be done when the underground garage has extensive open space at the roof plus fans that blow any VOCs comming up from the aquifer outdoors. I actually examined all the residential buildings in the COE area and most have shallow or shallow and open garages so natural air flow plus ventilation should make them likely to be safe. However as EPA now says, the only way to be certain the ventilation works is to test the indoor air, and that is exactly what they are now requiring in the MEW contaminated site in Mountain View.
For awhile EPA considered any building that had a ventilation and air conditioning system, like most offices, to be safe and not need testing, but after public comments they realized it was impossible to know that the HVAC system actually was turned on or that it ran at odd hours like evenings or weekends when most but not all people would be gone, so they now require testing in addition to ventilation.
“TCE is considered the worst because it is prevelant, a known carcinogen, and suspected of a number of other diseases such as Parkinson”
Bob Moss, can you please provide the evidence that TCE, at the levels measured, causes Parkinson or cancer? Thank you.
> evidence that TCE, at the levels measured, causes Parkinson or cancer?
Because if there is not undeniable evidence that TCE causes cancer it must be fine to saturate the ground water with it and ridicule those who don’t want to imbibe toxic chemicals with their water.
“if there is not undeniable evidence that TCE causes cancer it must be fine to saturate the ground water with it”
Anon, where is the evidence that TCE has reached saturating levels in the local ground water?
Anon, please provide evidence that the ground water is, was, or might become saturated with TCE.
Kevin, OK, I’ll spoon feed you. My first comment was a sarcastic reaction to your question, “Bob Moss, can you please provide the evidence that TCE, at the levels measured, causes Parkinson or cancer?”
The point being, what difference does that make? Whether TCE is saturating the ground water or not, your implication is that it is not a concern TCE doesn’t matter unless it can be proven that it causes cancer.
I simple Internet search will tell you about the health effects of TCE.
The broader meaning of your statement seems to be that the environment has a certain carrying capacity of toxic chemicals and that the correct thing to do is to carefully manage and spread this stuff all over the environment until it is full of toxics, but just under the level that we think affects humans, or at least can prove it.
This peculiar vision of a just barely toxic world I find ludicrous and I cannot image many other people would be excited about even if some biologists assured us it was perfectly healthy – hence my sarcasm and tone. Perhaps there is scientific doubt as to the relationship of TCE and Parkinson’s or cancer for some, but what is that the issue.
Why is the default position that anyone can dump whatever they want into everyone else’s environment that we share and that is OK unless it can be proven, scientifically and politcally that is some kind of “assault”, and only then is there even an effort to stop it or clean it up.
In today’s world, the countries that are going to move ahead on all dimensions are the ones that have the vision of closed loop manufacturing systems where wastes do not get put into the environment at all but are reused or stored, or not created in the first place.
I too appreciated this coverage. Several months ago I witnessed kids playing in the discharge of one of the cleanup wells at the University Club. As my own professional practice relates to long-term “stewardship” of these plumes, I was alarmed at this siting. I got the kids out of the water that was ponding at the club’s entrance.
While testing later showed that the kids had not been exposed to unsafe levels, it revealed multiple weaknesses in the cleanup systems, their maintenance and the communication of their presence. Seeing some of our community’s key watch dogs monitoring this post, I wanted to share the link to my analysis of these events.
http://blog.terradex.com/2010/07/13/learning-lessons-from-failure-of-a-recovery-system/
I have come to believe that the hazards associated with maintaining these pumping systems in certain public places posed greater hazard that the toxics they seek to mitigate. In the case of the recovery wells and piping the responsible party has placed on the grounds of the University Club, they have failed and overflowed numerous times exposing folks to the waters they seek to clean.
My own professional practice at Palo Alto-based Terradex has shifted from cleanup toward long-term management of plumes and contamination that will persist for decades. While it is important that the practical cleanup be completed, the newer challenge has been the long-term stewardship of these plumes within a community. How do we prevent a daycare from operating where volatile organics my travel, how do we prevent an excavator from pumping the toxic groundwater, how do we asure that offsite property owners are not inadvertently impacting or worse disturbing these toxic plumes. We have been working to build one tool called LandWatch that several states including California are now employing. (It is not being applied at this plume, however, much to my disappointment.) The link as an overview as it is rare that the relevance of the service our company Terradex is revealed in the local paper (the web page uses the term “institutional controls” as this is a term of art to reflect land use and activities that should not occur where residual contamination risk might exist).
http://terradex.com/PublicPages/Services/LandWatch.aspx
In the history of “pollution” our Silicon Valley will be known as an area that caused some of the biggest spills, but also has helped lead the way toward development of measures to prevent their recurrence (i.e. secondary containment ordinances) , to guide their cleanup, and then to provide safe long-term stewardship until they finally disapate. Again, the article showed the public a glimpse of a problem most did not know existed, and likely one that will be found to exist in 50 years.
Anon, thanks for the pablum. I just wish it had some real meat on the bone.
TCE ‘contamination’ appears to be some mass hysteria scare. In case you do not know, TCE was used, for many years, as an anesthetic during childbirth. It was eventually replaced by halothane. The toxicty data on TCE is extremly thin, and cannot possibly be a reason to support a superfund site. Additionally, TCE is broken down by intrinsic bioremediation (just to spoon feed it to you, Anon, that means it breaks down in the natural environment due to natural soil bacteria.
If one is scared about children playing near water outfalls with some TCE levels (in the parts per billion range), one should be peterified if they see children playing on a lawn in which mushroom have ever been spotted. Those mycotoxins are deadly!
Come on guys, this is truly a ridiculous (and very costly) scare campaign. Get real. Being declared a superfund site can be very lucrative for those who are involved in the business.
Kevin, I appreciate you can be as sarcastic as I, but sarcasm in the service of death does not make “toxic” notions and more pleasant.
http://www.cdphe.state.co.us/hm/tcefs.pdf
http://www.cdphe.state.co.us/hm/tcefs.pdf – Trichloroethylene Health Effects Fact Sheet January 2005
They used to use a lot of things for medicine that we know now are toxic – I guess you think you can prove a point by this logic?
Come on guy.
Anon, exactly what ‘facts’ were shown in your link to a “Fact Sheet”. That thing is psudoscience at its worse. Speculation and wild guesses is not a basis to set exposure levels (to anything).
As I said, get real. Palo Alto nearly succeeded in chasing HP out of this town, based on this nonsense. There IS a cost to hysteria!
I suggest we discuss mycotoxins, if we want to get hysterical.
> Fact Sheet”. That thing is psudoscience
Sure, we need to all live in your world and be guided by your authority because you can judge science from pseudoscience … what would the world do without you? 😉
Anon, my ‘vote’ is no more important than yours, in a democracy. However, I did work for over 20 years as a biochemist, with much experience with toxicologists. I can read a tox report as well as the average trained toxicologist. Specifically, associative data, multiple parameters, high-dose animal data (and so forth) is a VERY questional basis upon which to make a general recommendation. Such recommendations are often the result of political pressure, resulting from hysterical claims from voters (or those with agendas).
TCE, from the data I have seen, and at the levels measured in our ground water, is a non-issue. Time to move onto those nasty mycotxins. Maybe we can mount a campaign to outlaw mushrooms, or at least quarantee all sites on which mushrooms have been recorded, like all of our school yards and preschools (and front yards of our homes).
> I did work for over 20 years as a biochemist
How many years ago was that?
> …. is a VERY questional basis upon which to make a general recommendation.
The problem with you “experts” has been that if you are working for the wrong side you impeach ANY source of making a general recommendation because your recommendations change with dependence on what brings in business or money. The only thing that matters is whatever the industry says at the moment, usually in favor of least costs and regulation and greatest profits and risk and cost externalization.
Anon, I retired ten years ago. I have never worked for an industry or government agency that uses/used TCE. What is your expertise?
Anon, may I ask who started this toxic scare sham? Hysterical witchhunts are nothing new, but it is important to trace it back to its source, in order to put a stop to it. Very importantly, it would be essential to figure out how much money and time has been wasted on it, including HP’s expenses, City of Palo Alto expences, federal government expenses. The logical follow up would be to try to collect damages from the perpertrators.
Were you one of those on the launch of thing, Anon?
I worked in the electronics industry for a long time when this was found in the groundwater at the Fairchild location, as well as with it used as a solvent. It was labelled as very toxic to the liver at the time. ie. Poison labels on the barrels. You sound like a real fool.
I did not start any toxic scare, and I am not hysterical. I think people like you are just trouble makers, you react every time you hear anyone talking about pollution or toxic waster with the same tactic – by calling people hysterical and then pretending there is no problem whatever the substance is. There were people who were poisoned by this, and I don’t really care to pretend to discuss the fact of this with someone as disingenuous as you.
If you want to drink it or use it as medicine good luck, but pretending expertise and saying TCE is harmless and non-toxic is irresponsible.
There are both toxic chemicals and chemicals that people are misinformed about, but people who exaggerate either way depending on money are people I don’t care to listen to.
“If you want to drink it or use it as medicine good luck, but pretending expertise and saying TCE is harmless and non-toxic is irresponsible.”
Anon, if I wanted to avoid pain, such as in childbirth (if I were a woman), I would not hesitate to be anesthetised with TCE. If I do not want to get drunk on the stuff, I would not drink it. However, there is probably more toxicity in a glass of wine (alcohol), than in all the potential exposure to TCE in the ‘plume’ of this toxic scare scam.
My question, at this point, is a simple one: Who initiated this scam? There is a lot of expense caused by it, possibly resolved by civil legal action. Who will stand up and own it?
> if I wanted to avoid pain, such as in childbirth (if I were a woman),
> I would not hesitate to be anesthetised with TCE
Kevin … so your argument goes we should fill groundwater up with medical anesthetic because they help women in labor and so surely cannot be a toxic problem or threat? You further assume you can predict every dose that someone may get … do you have a crystal ball or something?
> there is probably more toxicity in a glass of wine (alcohol),
> than in all the potential exposure to TCE in the ‘plume’ of
> this toxic scare scam.
“Probably” is not very scientific language. People at least choose to drink or not to drink wine and where and when and what quality. People like you if you are responded to just never end your rambling “fertilizer”.
Cow manure is not toxic either but we see what it does to our rivers
and streams with there is so much of it that it overflows everywhere.
That is what is happening to discourse in this country when people
don’t have the good sense not to say the silly things you have been
saying.
Yes, request information as to measurements made and why it is considered a threat, but don’t blindly assume it is something to laugh about and try to laugh it off.
“but don’t blindly assume it is something to laugh about and try to laugh it off.”
Anon, I’m not laughing, not at all. I just want to know who launched this witchhunt. Was it you? If so, what the scientific basis of it? Do you understand the costs invovled for making false claims?
If you actually have some real facts to add to this – and adding some kind of value to your posts … then what is it you have to say about:
> Do you understand the costs invovled for making false claims?
What are you talking about and be specific please?
Anon, I have already stated that the levels of TCE reported do not support a scientific claim of a public health hazard. I have also stated that this thing is a hysterical witchhunt. I have also surmised that there is a very high cost to such false claims, and that there could well be some legal liability.
I am simply asking who launched this witchhunt. Whoever it is should be a standup guy, and try to defend it.
I am well aware that you have made some unrealistic, alarmist claims (the latest being, “ fill groundwater up with medical anesthetic “), so I am not trusting you to make any balanced scientific claim. I am just asking you if you know who lauched this thing. That is a pretty simple question, and you should be able to handle it.
> reported do not support a scientific claim of a public health hazard
> this thing is a hysterical witchhunt.
> is a very high cost to such false claims
> there could well be some legal liability
I think these statement are masquerading as serious arguments when they are in fact handwaving generalities. At least when I’m exaggerating for effect I am clear and obvious about it and not trying to fool anyone.
I challenge anyone to make a good case for TCE causing cancer in humans exposed to TCE in the drinking water. For example:
“Concentrations up to 212 ìg/l of trichloroethene (TCE) and 180 ìg/l of tetrachloroethene (TeCE) were found in the drinking water from two villages in Finland. To evaluate a possible exposure, urine samples from 95 and 21 inhabitants in these villages and from two control groups of 45 and 15 volunteers were collected. Dichloroacetic acid (DCA) and trichloroacetic acid (TCA), the metabolies of TCE and TeCE, were also analyzed. The individuals using contaminated water in one of the villages excreted TCA an average 19 ìg/d (<1–110 ìg/d) and in the other 7.9 ìg/d (<1–50 ìg/d), while the controls excreted an average 2.0 ìg/d (<1–6.4 ìg/d) or 4.0 ìg/d (<1–13 ìg/d). No increased incidence rates were found in the municipalities in question for total cancer, liver cancer, non-Hodgkin’s lymphomas, Hodgkin’s disease, multiple myeloma, or leukemia.” ( http://cfpub.epa.gov/ncea/hero/index.cfm?action=search.view&reference_id=631124 )
TCE does NOT cause cancer in rats and, except for one substrain, not in mice either. And this is about acute exposure.
Workers directly exposed to TCE, such as dry cleaners, have only a small increase in overall cancers, and there are many confounding factors in the published studies (this means that noone knows if TCE is responsible, or some other factor(s)).
Palo Alto does not get its drinking water from the shallow ground water that is of concern in this local Palo Alto case.
HP has been forced to spend millions of dollars, and required to move thousands of yards of soil. How much additional pollution was caused from all this unnecessary effort? Palo Alto homeowners are now required to install expensive vapor barriers, if they put in a new basement.
This entire sham should never have been allowed in the beginning. It now has a life of its own, with many people making money (and reputations) off the ‘cleanup’. Time to stick a fork in it.
Once again, who launched this thing, back in the early 1980s?
The Precautionary Principle, and the no minimum safe dosage remnant of the rabid anti-nuke days have cast aside the dictum that “The Dose Makes the Poison” and seemingly endorsed homeopathic science when it serves their purpose. The Precautionary Principle should be applied with caution.
To be strictly in line with the law, Californians should post two Proposition 65 warning signs, one on the inside of their front door and one on the outside.
I remember when there were air strippers all over the plume, stripping “contaminants” out of the water and DISPERSING THEM IN THE AIR. I remember the surprise of the control people when gasoline was eaten by bugs naturally selected to eat gas. I believe funds. public and private, are best spent where the benefit is real and define”Saving” one child out of a million while impoverishing a thousand families is a poor bargain to me.
We need to validate minimum safe exposures and find means to monitor them, and as suggested, sic the pollution control board onto the airborne pollens that cause far more grief than do any remaining chemical toxins in the biosphere.
I’m hearing a lot of innuendo, slogans and talk and precious few facts.
if private industry did not have such a bad track record maybe things could be so simple. For example the Mississippi delta where the toxic waste and sewage of half the country flows through has higher frequencies of sickness and yet how to sort that out.
This tactic of pointing out a few excesses on the part of the environmentalists and using it to dismiss the whole question is just more of the same, an attempt to bypass any regulation at all and grab more money.
Walter, yes it is always about dose and duration in the realm of toxicology. It is also about yhe model, acute vs. chronic, linear vs. threshold. The problem is that toxicology, related to chemicals and population(s), is a matter of opinion, since the studies are so complicated, and thus too expensive to run properly. This means that demagogues can control the agenda, as has happened with the Palo Alto “plume” sham. Yes, same thing with nuclear issues, and look where that got us.
With the exception of the war years, when priorities were not available to civil works, the United States has kept up with the waste treatment problem. Today most areas return waste streams in a better condition than the receiving stream. In the Hudson River currently they are dredging up previously dumped industrial wastes that are currently benignly lying under protective sediments, thus returning them to the biosphere. The conversion of the S.P. Shops in Sacramento to use has been delayed for years because the residue from a century of boiler washing and cylinder blows has – what – left detectable residue that has negatory chance of harming the biosphere. Right here in River City, oops Badgag By the Bay [Sorry, Herb,] we have the folly of spending millions of defense dollars to “preserve” a historic building threatened because of the runoff from that building [the same as the runoff from half the roofs in this cachement area] with no demonstrated hazard to the biosphere. That’s why I don’t defer to crap science and regulatory pioneering. Get it right or get a real job.
Bob Moss,
Are you one of the launchers of this thing? I cannot tell for sure. The only thing I can be confident of is that “Anon” doesn’t have a clue.
Your have stated, in this blog, “TCE is considered the worst because it is prevelant, a known carcinogen, and suspected of a number of other diseases such as Parkinson”, I asked you to supprt that statement, but you have yet to do so.
Two questions for you, Bob:
1. Can you scientifically support your assertion?
2. Were you part of the launch of this withchhunt? If so, why? If not, who was?
Kevin, I guess it is easy for you to accuse everyone who disagrees with you as being in some vast conspiracy against you personally, and to bully people with words by accusing them as not being as knowledgable as you supposedly are, yet when I linked to the toxic page on TCE all you did was scoff like you know better than everyone.
Quit trying to point the finger at other people, and if you have something to say, say it and back it up, with some facts, not innuendo and trying to attack people who disagree with you.
Nony, when an attack becomes personal then the shield of anonymity becomes inappropriate. The “conspiracy” you scoff at is against reason and proportion. I am not dismissive of toxic materials, having lost workmates to carbon tetrachloride and bromine, but I believe expending money and effort to reduce a threat below ambient is misdirection of effort.
>> expending money and effort to reduce a threat below ambient is misdirection of effort.
That is a no-brainer. How does the public ensure that this happens or doesn’t happen.
Bottom line is that even though it might be unfair or unwarranted, there is a lot of information out there or that we can know is difficult to get or trust. The reality may be that if there is a draconian punishment for those companies that have demonstrably behaved anti-socially, for example by dumping TCE into the environment, it may be the only input that we have to mediate the behavior of these companies. It is clear that these companies will try to use any argument they think is logical to escape paying for or being punished for their anti-social behavior.
If the nature of reality is that we have to err, I don’t think it is quite the major error to force companies to be responsible for their messes, unless of course they can do more than just imply that there is no danger. It’s also not fair to characterize this as a witchhunt.
In almost every case going, in my experience, to Love Canal, it was generally accepted that dumping was a benign disposal method at the time it happened. Often, the later disinterment order was unjustified by any rational process, and the money spent and fears raised were wasted. The disinterment was selective – the Murky Turkey was not ordered to recover all its discarded issues when their PCB content was discovered. I believe the remediation measures have caused more rather than less exposure to substances of concern. I believe future remediation must do cost-benefit analysis.
“The reality may be that if there is a draconian punishment for those companies that have demonstrably behaved anti-socially, for example by dumping TCE into the environment”
Anon, can you name the company that “dumped” TCE into the environment?
You seem to be willing to punish a company, like HP, because you define it as “anti-social”. I think most people find HP to be a benefit to humanity. If you were one of the originators of this witchhunt, and you were to publicly admit your motive (as you have just expressed anonymously), you would likely be open to legal liability.
Kevin, will you quit trying to imply that I am part of a witch hunt. Whatever I say would not make you happy, so just take my comments and other’s at face value. If you were able to prove HP was being unfairly burdened that would be something different from your innuendo and attacks.
I also continue to resent your distortions of comments here. I never said I wanted to punish HP because I thought it was anti-social, but if it has been established that anyone dumped pollution into the groundwater I think that is anti-social and as incentives for other companies to be more responsible it makes sense to require those who polluted to clean it up.
You are paranoid and obsessive on this. I am reacting to this as a long time resident of the Palo Alto community, and one who was involved in the electronics industry including HP for a while. I know Fairchild is at least one of the companies that contaminated the groundwater with TCE. I don’t know as much about HP’s culpability, but why are you defending HP with your insinuations, are you a shareholder or officer of HP?
The simplistic notion that because any average dosage or exposure that someone gets is so small as to be below toxicity limits is not an argument that has any weight in my book. There is no way to tell about concentrations of long terms exposures or when or where. It never should have been there, but now we have to make the best of it with whatever best practices there are. Just telling people that according to you it is not a problem and laughing at them for being naive in your own probably biased opinion, I HOPE, is not something that can get traction with people anymore.
Hi Bob Moss,
Thank you for the excellent work you’ve done in researching the problem and forcing the City and other agencies to follow up properly. It is absolutely unacceptable that no testing is planned for another 18 months with residential areas in the immediate area affected.
I’d sincerely appreciate it if you could share:
1) A link to EPA-recommended vapor barrier materials for placement under foundation floors.
2) Reputable firms that can test indoor air, soil and ground water.
3) Explain what you mean by an active barrier – do you mean vents or powered vents to air the foundation or parking garage of a building?
I’d also like to follow up with you in organizing all the neighborhoods surrounding the area to force HP, the City and State to do the necessary air testing. There are a lot of residential sites at great risk. There are enough of us to force timely and thorough follow up by the government and those responsible for the toxic waste. Online networking sites and petitions will make this much easier than it would have been years ago. City and state office holders have a tendency to listen and take action when enough people make their voices heard.
Thank you,
EJ
I’d sincerely appreciate it if someone could recommend reputable indoor air quality testing firms in our area.
Bob Moss, any idea?
Hi Bob Moss,
Trying to reach you by email but your AOL email posted online bounces back. Where can you be reached?
EJ, I am also waiting for Bob Moss to reply on this thread, in order to defend his original statements. I will ring the bell, once he decides to show up, again.
Witchhunts are a hard thing to defend, once the facts are demanded. Still waiting….
EJ, if you want to waste your money on vapor barriers, to protect against TCE vapors, that is your free choice. However, you might want to consider that there are a number of local non-profits that could benefit from your donations, instead of enriching the plastics manufacturers and bureaucrats making a name for themselves by hunting toxic witches.
>EJ, if you want to waste your money on vapor barriers, to protect against TCE
>vapors, that is your free choice. However, you might want to consider that
>there are a number of local non-profits that could benefit from your donations,
> instead of enriching the plastics manufacturers and bureaucrats making a
>name for themselves by hunting toxic witches.
This is nonsensical fear-mongering, just as bad as the position you are attacking with your sarcasm, but you offer only the foggiest of facts.
If you want to do a public service point out of the EPA can do better and get the law changed for everyone for the better, because what you are doing here does not seem productive or in the public interest to me.
And the constant refrains of “witchhunt” are ridiculous.
>> Until that case is made, at the detected levels, there is no issue, other than a witchhunt.
Whether TCE is dangerous or not according to you is not the issue.
From: http://www.cdph.ca.gov/programs/hesis/Documents/tce.pdf
> Cancer: TCE causes cancer in mice, and there is some evidence that it may also be a weak carcinogen in rats. Humans exposed to TCE have not been studied well enough to give much information, but the human studies also suggest that TCE may cause cancer. You should treat TCE as a likely cause of human cancer.
Genetic Changes: There are many ways to test whether a chemical causes genetic mutations. In most tests, TCE causes little or no mutation.
When you look at different states MSDS they contradict each other … most likely because of industry influence, but there is no doubt that TCE is toxic, and contaminants commonly found with it and in it are toxic as well.
Why are you so persistent in claiming that TCE is harmless and this is a witchhunt, what a ridiculous notion.
I wish I had confidence in public science.
> I wish I had confidence in public science.
I hear you, but what other process is there? It’s one reason we need a lot of real quantifiable information, debate, and good education, all of which seem to be markedly trending in the wrong direction. We need models for the kind of behavior we want, and right now we have cartoon characters on TV that can sway masses of people based on emotion, enough to declare it reality. This is a very dangerous time.
“Whether TCE is dangerous or not according to you is not the issue.”
That is correct. However, it is also true that MSDS warnings, aimed at the workplace environment, with direct exposure to TCE, should not be considered relevant to environmental spills. Spills get diluted by the environment, bioremediated by the environment and expose the public to immensely lower levels of TCE. MSDSs also are driven by political forces to overreact via the old-fashioned half-truth trick. For example, the MSDS that you provided states, “TCE causes cancer in mice”. The truth is that TCE only causes cancer in one strain of mice, but it does not cause cancer in all other strains of mice tested. It required immensely higher levels of TCE to casue cancer in this one strain of mice, compared to what is present in the current plume in Palo Alto. The MSDS you provided, Anon., is irrelevant to the question of whether “TCE is considered the worst because it is prevelant, a known carcinogen, and suspected of a number of other diseases such as Parkinson”, as stated by Bob Moss.
Our water supply and our exposure to TCE is not a threat to us, because the potential exposure is below ANY level of concern, and we do not drink that water. However, this witchhunt HAS caused HP to seriously consider leaving Palo Alto. ALZA was already forced out some years back by a similar toxic witchhunt. The loss to our tax base is real, and could get much worse.
Those who foist fear on us should be held accountable for the real costs that result from such fear. By this, I mean mean legal liable, with real punitive costs (in dollars).
Still waiting to hear back from Bob Moss.
> Spills get diluted by the environment, bioremediated by the environment and expose the public to immensely lower levels of TCE.
Yeah, sure, out of sight, out of mind.
Whether Bob Moss’s comment is totally accurate or not is also not the question, anyone can make a mistake or misspeak, it does not prove the opposing point of view.
You simply cannot say you know for sure that the TCE exposure everywhere all the time is safe, and if you do it tends to lessen the incentives for companies to be responsible, they will all claim that whether it is true or not.
And your witch-hunt to threaten people because they are concerned about the environment and their own property rights and health is outrageous!
You are more likely to receive an answer to your questions when you post your real name that can be verified just as Bob Moss has done.
“You are more likely to receive an answer to your questions when you post your real name that can be verified just as Bob Moss has done.”
That is an illogical comment, Herb. Bob Moss said, “TCE is considered the worst because it is prevelant, a known carcinogen, and suspected of a number of other diseases such as Parkinson”. I didn’t make that statement. It is up to Bob to defend his own statement, made under his own name, when it seemed to him convenient to make such a statement. I am only challenging him to defend his own words.
Or perhaps you would like to defend Bob Moss’s statement, Herb?
“> I wish I had confidence in public science.
I hear you, but what other process is there?”
There is the dispute resolution where the plaintiff and respondent place their case before an impartial arbiter or panel. We know, now, that government scientists are just as paycheck oriented as any industry scientist and just as susceptible to fads. Glory goes to the New York Times front page, not to “interesting, but so what?”
I am quite surprised that people doubt the clear findings of EPA in Nov. 2009 that TCE is not a suspected carcinogen but an actual one, at which time they reduced the levels at which exposure to TCE in water and air are considered carcinogenic. BTW, a chemical is considered carcinogenic if there is one chance in 1 million that the specified exposure level over a time period (I think it is 20 years) will cause cancer. TCE fits that profile. You also can contact Lennie Siegal of CPOE in Mountain View who oversees the Superfund sites in Mountain View and has national experience with toxic exposure and the risks of exposure to not only TCE but other toxic chemicals. Lenny Siegel
E-mail Address(es):
lennysiegel@gmail.com
I attended the National Stakeholders Conference in San Diego last March where dozens of papers were presented by both government agencies and organizations. Nobody doubts that TCE is toxic. Unfortunately I don’t have e-mail addresses for the presenters. If you want to ask the local EPA person that I work with most, her name is Alana Lee. Lee.Alana
E-mail Address(es):
Lee.Alana@epamail.epa.gov
The baseline vapor barriers were discussed both at the conference at at other meetings include a series of perforated pipes inside an impermeable sheet that is laid under the building foundation. If the pipes have no active pumping system they are supposed to collect the vapors from the soil or groundwater and pass it up the side of the building into the air. If an active system is used (my preference) pumps pull the air and vapors from the pipes into the outside air.
To answer a couple of other questions, identification of the SUperfund sites in Palo Alto and elsewhere was done in the 1980s by EPA. We were informed of it when an EPA representative knocked on the door of the then BPA president and informed him of the problems. The BPAF was created by the BPA to seek EPA grants to oversee the Superfund activity, which we have done for more than 20 years.
BTW, recent soil gas sampling at 195 Page Mill revealed TCE concentrations of 25,000 to 150,000 ppm, far higher than the highest concentration given in the 5 year summary report. That area was not tested for soil gas before this year.
“However, these biological responses, although they serve as precursors for tumor formation in rodents, are not expected to lead to tumors in humans at any environmentally relevant exposure situations” ( http://www.informaworld.com/smpp/content~db=all~content=a727073121~frm=abslink
)
The above article discusses the major metabolites of TCE, using the available data, which the EPA also used. A minor metabolite may have a possible carcinogenic effect, but again, there is no demonstrated effect, just a theoretical effect.
The EPA is a hugely politicized federal department, and is very sensitive to activist pressures. If Lenny Siegel is the same guy who was at Stanford in the late 1960s, I know him. He was a rabid anti-capitalist. If he is not, then ignore my ‘guilt-by-name-association’ charge. However, if he is the same guy, then he is hardly one I would put any faith in, about toxic issues affecting American corporations, like HP.
Bob Moss, did your “National Stakeholders Conference in San Diego “ include representatives from HP? Or from Palo Alto citizens that want to retain HP in Palo Alto, without harrassment? I have never heard about such an august organization. Did Lenny Sigel attend with you? Or is it, as I assume, an activist group with an agenda, which speaks to and for itself?
Also, Bob, please let us all know where TCE has been shown to cause Parkinsons. Did you hear that at your conference in San Diego?
Who was the “EPA representative (who) knocked on the door of the then BPA president and informed him of the problems”. Clearly, you should be able to name this ‘representative’. Your BPA must have records, right?
> but again, there is no demonstrated effect, just a theoretical effect.
And how does anyone know this is not the same kind of thing the country heard about smoking for 20 years while people died of cancer. Theoretical threat, not proven, no evidence, etc?
Just ignoring something until it has gone way past being proven 9 out of 10 studies to be harmful is not a workable position as far as I’m concerned.
“And how does anyone know this is not the same kind of thing the country heard about smoking for 20 years while people died of cancer. Theoretical threat, not proven, no evidence, etc?”
Answer: Noone knows. The issue is whether or not you want to spend enormous sums of money, based on the possbility of a low risk. It goes beyond this, though, since it also can have a major effect on the Palo Alto tax base.
Anon., you have MUCH more to worry about with mycotoxins. Should we shut down all local environments in which mushrooms have been found? At a certain point, Anon., you have to use a common yardstick of risk, then decide the price you want to pay to keep us all safe.
“I’m good at going back to original sources,” Moss says. “You’d be amazed at how many people will just take something because it’s been printed and assume that it’s correct without ever going back and checking the original sources” ( http://www.queeg.com/bobmoss/hell-raiser.pdf )
Bob Moss, those are your own quoted words. So why don’t you go back to the original studies that claim that TCE is a carcinogen in humans, at levels found in the general environment? More particulalry, what are the data that show that TCE causes Parkinsons?
Bob, if you want to play hardball, I am your worst enemy, because I insist on hard evidence. I don’t tolerate witchhunts. I am calling you out, Bob. Prove your case, from original sources. Thank you.
When I see one in a million I tend to wonder how such a number was weeded out of the background. When I see one in a million from an advocate I hold my wallet. At one in a million I would want to know what good was accomplished by using the suspect material – were 5 people able to afford cancer treatment that otherwise wold not have been able to?
Cost-benefit where life is concerned? There more than anywhere else.
This witchhunt has a silver lining, because it provides, from the public record, the anatomy of a political shakedown.
http://articles.sfgate.com/1996-07-05/news/17778767_1_hewlett-packard-polluting-waste-cleanup
This link to a 1996 SF Gate article shows the major players, as well as the strategies involved in getting monies to shakedown a major American corporation (HP).
Note that one of the early players was Susan Covey:
“”It made me uncomofortable to know that there had been leaks,” said Susan Covey, a Palo Alto attorney and association (Barron Park Association, BPA) member. “I wanted to find out the impact and to see how safe it was””.
Note: Sue Covey did not live in Barron Park at the time, she lived in College Terrace. I called a couple of friends who live over in CT, and they tell me that she was an activist in CT in the early 1980s. Thus it should be no surprise, that:
“Other residents felt the same way, and began exploring ways to become involved in the cleanup”.
Activist groups tried to get the Stanford Industial Park, now the Stanford Research Park, to put unrealistic toxic limits on research corporations. For example, ALZA came under severe criticism, and it finally left Palo Alto, along with its jobs and tax base.
“State and Hewlett-Packard investigoators later (than 1982, when a leak in a tank and pipes was found by HP) determined that the contamination at both sites posed no immediate danger to resisents. But the sites had to be cleaned up to fulfill state environmental requirements.”
This is the opening required for the shakedown groups: There is no real danger, but there IS a requirment to clean up the leak. Does anyone smell money here? Well, BPA certainly did, since they pressured the federal govenment to give them two ‘grants’ (aka shakedown payouts), to “monitor” the cleanup. What did BPA do with their booty?:
“The money was used to hire an independent technical consultant, who helped school residents in the intricacies of toxic waste cleanup”. Another way to read this sentence is, “If the masses don’t get scared about your witchhunt, then hire a professional witch, using U.S. taxpayer money”.
Perhaps Bob Moss can tell us who the “independent technical consultant” was. Of course there should also be a public report issued for that kind of money. If so, Bob, please tell us where we can find it in the public record.
The more interesting thing is that HP wanted avoid the kind of fight that ALZA went through, so it did a ‘community relations’ response to the shakedown:
“There were times when the association and HP disagreed on how the cleanup should proceed. For example, residents asked the company build further extraction wells that HP technical staff considered unnecessay. Such issues were resolved, Thark (HP community relations specialist)said, becasue the residents believed in the company’s commitment to the cleanup.”
It got even better, because the BPA shakedown became a model for much larger shakedowns, nationwide:
“The federal program has distributed about $6M in grants to grassroots groups nationwide” (citing the BPA as the model for such largesse).
“Lenny Siegel, a Mountain View-based environmentalist, believes it could be a model for other communities dealing with toxic waste…”
Quite a model, where a relative non-issue, such as the HP leak, gets ginned up into a toxic mass scare, with neighbors fearing cancer and newborns with three heads, a small group of activists with agendas drive the shakedown directly into a by-off by the very businesses that they originally targeted. Then the model gets expanded nationwide into new levels of government power, controlled by the very same activists who created the witchhunt in the first place.
Neat trick. But a very costly one for those of us who live in Palo Alto, and who would like the the HPs of this world to come and stay here.
It is time that Bob Moss, and BPA come clean on this issue: Name the names of the original movers, the EPA investigaor who knocked on the door of BPA, the consultant hired with our money to “school” us, as well as proof (original sources only, Bob) that there is any realistic cause for concern from the HP leak.
– Kevin states
“Our water supply and our exposure to TCE is not a threat to us, because the potential exposure is below ANY level of concern, and we do not drink that water. However, this witch hunt HAS caused HP to seriously consider leaving Palo Alto. ALZA was already forced out some years back by a similar toxic witch hunt. The loss to our tax base is real, and could get much worse.”
I disagree…
1) The groundwater from the many of our shallow aquifers can be used as an emergency water supply in the event of an earthquake where our water supply main, from Hetch Hetchy, or local piping systems rupture. Because of our thick clays, the water is drinkable at levels as shallow as approximately 34 feet. And if your house is burning down and you are dying of thirst, a slightly elevated level of barium and/or possibly nitrate will not concern citizens.
2) There are many more volatile compounds other than TCE that are involved in the COE plume. Some of these are high levels of inorganic compounds (metals) that were used in manufacturing. TCE, and other volatiles are known to be toxic. The EPA, State Regional Water Board, and Santa Clara Valley Water District know this.
3) The assertion that this “witch hunt” has caused HP to seriously leaving Palo Alto is absolutely untrue.
http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dc283e6c5d6056f88257426007417a2/351973b3feacb7a8882577af0073b60e/$FILE/HP%20620%20640%20PMR%20FYR%209%2030%202010%20Final.pdf
Folks here is the complete final report.. Please go through it..
http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dc283e6c5d6056f88257426007417a2/351973b3feacb7a8882577af0073b60e/$FILE/HP%20620%20640%20PMR%20FYR%209%2030%202010%20Final.pdf