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OCR for page 120
7
Ground Water Contamination Issues
in Santa Clara County, California:
A Perspective
RONALD R. ESAU AND D. J. CHESTERMAN
In the last few years, Santa Clara County has been the focus
of state and federal attention in the area of hazardous materials
regulation. The discovery of major ground water contamination
in 1981 set in motion a local regulatory response that has been
the pattern for similar action throughout the state of California.
Responsible agencies have also forged new ground with regard
to remedial actions associated with existing incidents of contam-
ination. Millions of dollars have been spent by private industry
on cleanup activities while a cooperative relationship has been
maintained between industry and government to the extent that
expensive and time-consuming litigation has been avoided in al-
most all cases. Now that cleanups are in progress at over 125 sites
in the county, difficult decisions with regard to the level of cleanup
required must be faced. In addition, it is becoming more evident
that funding for cleanups will be a major hurdle in the very near
future. Efficient mechanisms must be in place to permit a rapid
response to high-priority cases of contamination.
BAClIGllOUND
The Santa Clara Valley Water District is a public agency es-
tablished by special act of the California legislature to provide
overall flood protection and supply water to Santa Clara County
residents. The county comprises 15 cities, the largest being the city
of San Jose. The district's flood protection responsibilities include
120
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GROUND WATER CONTAMINATION
121
the planning and construction of facilities to prevent floodwater
damage to the county's expanding urbanized areas; its water sup-
ply functions include the planning, construction, and operation of
facilities to provide an adequate supply of water for the growing
municipal and industrial demand. The district is also responsi-
ble for contracting with appropriate state and federal agencies to
import additional water to supplement the available local supply.
Funding for flood control is generated from property taxes,
benefit assessments, and some federal assistance. Funding sources
for water supply responsibilities include revenue from taxes, water
sales, and ground water extraction charges. In terms of direct sales
the district is essentially a wholesaler, providing treated water to
several private and municipal entities distributing within Santa
Clara County. Figure 7-1 shows the boundaries of the various
water retailers located in the county.
The total quantity of water needed to supply the approxi-
mately 1.4 million county residents is currently 400,000 acre-feet
per year. This requirement is satisfied by a combination of treated
surface water and ground water, with ground water accounting
for about 60 percent of the total consumption countywide. The
ground water basin underlying the county is relied on heavily, not
only for its natural yield but also to treat, store, and distribute a
major portion of the imported water the county uses, along with
water conserved in local reservoirs.
It was recently recognized that authorities were literally over-
looking a serious threat to the water quality of that basin arising
from activities associated with a major industry in a part of the
county popularly referred to as Silicon Valley." In 1981 a large
electronics firm reported to the San Francisco Bay Regional Water
Quality Control Board (Bay Regional Board) the loss of about
60,000 gallons of waste solvents and water from an underground
storage tank farm. A week later, on December 7, 1981, a nearby
well of a water utility company was shut down after detecting
contamination with trichIoroethane (TCA) at a concentration of
5,800 ppb.
During the next year, the Bay Regional Board conducted
extensive surveys of all industry that might have underground sol-
vent storage tanks on their property. Fuel products were omitted
from the initial survey. Solvents were considered a higher priority
because of their extreme toxicity, their higher solubility in wa-
ter, their specific gravity, and their persistence, or resistance to
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GROUND WATER CONTAMINATION
123
biochemical degradation, as compared to petroleum products. In
the survey, it was found that a significant number of the compa-
nies had leaks or spills on their property that warranted further
investigation.
This discovery concurrently set in motion a response from local
regulatory agencies that resulted in the adoption of the nation's
first hazardous materials storage ordinance (HMSO), which went
on to become the mode! after which the California state regulations
were patterned. The HMSO had two primary purposes: (1) to
ensure the safe storage and onsite handling of hazardous materials
and (2) to protect the quality of the underlying ground water. The
ordinance requires soil sampling around all tanks to detect past
leaks as well as periodic monitoring to detect future leaks at an
early stage before major soil and/or ground water contamination
can occur. Through the implementation of the HMSO, a number
of new cases of solvent contamination have been discovered, along
with numerous instances of petroleum product contamination.
Today, the Bay Regional Board ~ overseeing the investigation
of over 125 ground water contamination cases. In addition, there
are over 350 cases of petroleum product contamination uncovered
so far that are receiving essentially no response at all because of
a severe lack of staffing. As the remedial actions at the solvent
contamination sites proceed the Bay Regional Board is rapidly ap-
proaching a most difficult set of decisions that is, to what levels
should contamination in the soil and ground water be reduced.
These decisions are not only technically complex but are further
complicated by economic, political, and value considerations in-
troduced by a concerned public rightfully involved in the process.
It is the purpose of this paper to consider these issues and how
they are currently addressed in the existing regulatory framework.
Portions of case studies are provided for examples, as appropriate.
REGUI:ATORY AGENCY llOlES An RESPONS~UIT~S
Because the roles and responsibilities of regulatory agencies
may vary from state to state, a brief outline of the regulatory
framework governing remedial actions for ground water contam-
ination in Santa Clara County follows. This is by no means an
exhaustive review but rather an attempt to describe succinctly
those responsibilities that directly relate to the cleanup opera-
tions.
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HAZARDOUS WASTE SITE MANAGEMENT
Regional Water Quality Control Board
There are nine regional boards In California with surface and
ground water quality responsibilities covering the state's various
surface drainage basins. Portions of Santa Clara County lie within
the jurisdiction of boards in two different regions: the San Fran-
cisco Bay Region and the Central Coast Region. The regional
boards have responsibility for the oversight of remedial actions,
which includes issuing cleanup and abatement orders after the ini-
tial definition of the extent of the contamination, as well as issuing
permits for the discharge of polluted or contaminated water to
streams. The boards derive their authority from the state's 1969
Porter-Cologne Water Quality Control Act, which provides "that
the statewide program for water quality can be most effectively
administered regionally, within a framework of statewide coordi-
nation and policy." The State Water Resources Control Board,
under whose policy guidance the regional boards operate, is the
mechanism to provide the framework of Statewide coordination
and policy.
California State Department of Health Services
The California State Department of Health Services (DHS)
has some responsibilities that overlap those of the regional boards
in the area of soil contamination. DHS is primarily concerned with
the levels of contamination permissible in case of human contact
with the soil. The regional boards' concern, on the other hand, is
with the leaching of contaminants from the soil down to ground
water.
DHS also has oversight responsibilities for the transportation
of hazardous materials. Therefore, all removal of soil or other
contaminated materials from a site is done under DHS-issued
permits.
Finally, DHS administers a state Superfund program similar
to the federal Superfund. One function of the state Superfund is to
provide 10 percent matching funds to federal Superfund sites. In
addition, it provides emergency cleanup for surface spills requiring
immediate action, as well as funds for relatively small ground
water contamination investigations.
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GROUND WATER CONTAMINATION
125
Environ~nental Protection Agency
EPA adrn~nisters the federal Superfund provided for in the
Comprehensive Environmental Response, Compensation, and Li-
ability Act (CERCLA). This fund provides for the ranking of sites
on the National Priority List. Funds are subsequently encumbered
for the cleanup of contamination at sites with no identifiable re-
sponsible party (so-called orphan sites) or at sites at which the
responsible party fails to cooperate with the regional board in a
timely manner. Such recalcitrant parties are usually prodded into
action by the threat of EPA's expending funds for remedial ac-
tions that it will later recover from the responsible party through
litigation.
The EPA has had another role in the ground water contam~na-
tion in Santa Clara County through a special study called the In-
tegrated Environmental Management Plan (lEMP). The purpose
of the plan has been to evaluate public health risks from ground
water contamination, along with risks from contamination in other
media, to compare the relative risks and make recommendations
on how best to minimize them in a cost-effective manner through
better management practices. In the study, EPA addresses many
of the same issues to be discussed in this paper.
1lEMEDL`1 ACTION STRATEGIES
The primary goal of any remedial action is to enable the
continued safe use of the ground water basin, both as an important
source of water as well as an efficient mechanism for treatment,
storage, and distribution of local and imported water recharged
into the basin. With this in mind, two general approaches toward
remedying ground water contamination can be presented: the
active versus the passive approach.
Active Approach
The active approach, as used herein, refers to specific steps
taken, first of all, to define the extent of a particular plume of
contamination and then to proceed to effectively reduce levels of
contamination while maintaining hydraulic control of the plume.
Reducing the level of contamination can either be accomplished
by some sort of in situ treatment technology or by removing the
contaminated soil and/or water for treatment or disposal.
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126
HAZARDOUS WASTE SITE A~4NAGEM:ENT
In situ treatment of soil can mean aeration of contaminated
soil by injecting air into the ground to volatilize the contaminants.
In situ treatment of ground water refers to the encouragement
of biochemical degradation by creating a more favorable environ-
ment for the natural degradation processes to occur. Because
these treatment technologies are in a more experimental state of
development, the method of choice is, almost exclusively, the latter
method noted in the previous paragraph: removal and treatment
or disposal.
Generally, the grossly contaminated soil will be removed and
disposed of in a Class ~ landfill. Contaminated ground waters are
removed by extraction wells located in the center of the plume. The
extracted water is then treated to acceptable levels and discharged
to nearby streams. By hydraulically controlling the contam~na-
tion, the extraction wells also prevent the plume from spreading
further and threatening nearby drinking water wells. Another
method of controlling the plume is to introduce a physical barrier
at the contamination source usually a bentonite slurry cutoff wall
in the ground. This procedure is economically feasible only when
extremely- high concentrations are present in a relatively small
area. The method wit! almost always be used in combination with
extraction wells.
Passive Approach
The passive approach involves essentially allowing the plume
of contamination to spread and dealing with it at the water ex-
traction wells that are affected. The water from these wells is
then treated to some technically feasible levels that are accept-
able to the public, the ultimate consumers. WelIhead treatment
includes either air stripping or activated carbon adsorption of
contaminants- essentially the same procedure used in the active
approach at wells within the plume.
Discussion
In considering these two approaches to ground water contam-
ination, it is important to recognize first that, because of technical
considerations, the solution will necessarily be some combination
of both alternatives. That is, it is widely accepted that concen-
trations of contaminants in ground water cannot be reduced to
OCR for page 127
GROUND WATER CONTAMINATION
127
zero or to nondetectable levels within any practicable amount of
time. This is due to the reasonably well-documented physical
processes that govern the movement of contamination in ground
water. Therefore, with active cleanup measures, when an accept-
able contaminant level is attained and the extraction wells cease
pumping, the remaining "plume" can eventually migrate to nearby
drinking water wells and result in some measure of low-level con-
tamination.
As discussed earlier, however, this scenario is quite different
from the passive approach in the extreme case, in which poten-
tially high levels of contamination would be rn~grating to any
nearby drinking water wells. There are many unknowns inherent
in this approach that make it very difficult to evaluate, both tech-
nically and economically. Technical unknowns include the rate of
movement of the plume, the number of wells that might ultimately
be affected, and the concentration of contaminant that might be
involved. Solute transport models have been used to attempt to
predict these unknowns, but they are very often combined with a
limited knowledge of important parameters. The resultant predic-
tions, therefore, are subject to criticism or very often found to be
of little value.
Economically, the cost of reducing relatively low levels of con-
tamination to "acceptable levels must be evaluated. It is well
documented in the literature that techniques for the removal of
volatile organic chemicals from water are less effective at lower
concentrations. Therefore, the cost-effectiveness of treating much
higher quantities of water at low levels of contamination suggests
that the passive approach could potentially cost much more over
the period of time that surrounding wells require treatment. More
research is in progress in this area, specifically through the EPA
lEMP study mentioned previously.
In addition to the such technical and economic considerations,
there are other issues that must be weighed when considering the
passive approach. First of all, some mechanism-a local ~Super-
fund," if you will-would be necessary to rennburse the drinking
water well owner who has been damaged, in a legal sense, by one
or more incidents of contamination. Also, in our litigious society,
it would seem naive to think that this situation would not provoke
a barrage of civil actions, not only from aggrieved well owners but
from adjacent property owners as well, citing alleged effects on
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128
HAZARDOUS WASTE SITE MANAGEMENT
property values. Lawsuits of this nature could require costly hy-
drogeologic investigations to determine liability or relative liability
in cases with more than one responsible party involved. Therefore,
hidden costs could increase the total cleanup "cost to the nation"
significantly.
Finally, there are social factors to consider; that is, what is the
social value of being able to extract uncontaminated water from a
generally pristine ground water basin, as presently exists in Santa
Clara County? Will a public with keen awareness of the risks
associated with the consumption of these toxic chemicals tolerate
a policy allowing the degradation of what is considered to be an
important local resource?
In contrast, the active approach when strictly applied prevents
the migration of contaminants to nearby wells and helps ensure
that the "owner" of the plume will continue to assume liability for
the cleanup. It also results in a more efficient operation because
it treats water with the highest concentrations of contaminants.
Critics might argue that this approach results in a significant waste
of water. Yet during periods of average to above average rainfall
a major ground water basin can perhaps afford to ~waste" the
relatively small quantities of water required to effect the hydraulic
control of a plume. Responsible parties are currently investigating
the feasibility of treating and recharging extracted waters to reduce
or eliminate such discharges to local streams and, ultimately, to
San Francisco Bay.
This discussion has noted only the extremes of each approach
and ignored various qualifying hydrogeologic factors. It hap also
disregarded the issue of what constitutes, in either case, an ~ac-
ceptable" level of contamination. Whereas the "acceptable" level
in the passive case might be the applicable drinking water stan-
dard, appropriate objectives for ground water cleanup are not as
simple to define.
Case Studies
As mentioned earlier, there are over 125 cases of ground water
contamination currently being investigated under Bay Regional
Board oversight. Two of the cases that have been subject to inten-
sive cleanup efforts are briefly described as examples of the active
cleanup technology. A third case one without an identifiable re-
sponsible party is discussed as an example of a case in which a
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GROUND WATER CONTAMINATION
129
combination passive/active approach is appropriate, at least until
the source of contamination can be identified.
IBM, San Jose
The IBM case, first reported in October 1980, is one of the
earliest cases of contamination in Santa Clara County. It is lo-
cated near the middle of the county in a part of the basin that
is particularly sensitive because of the relatively coarse-grained
geologic materials underlying the site. For this reason the gen-
eral area Is used extensively for artificial and natural recharge of
the ground water basin. The primary contaminants include TCA,
trichloroethylene (TCE), and freon 113, all of which have various
associated adverse health ejects.
IBM responded to the urgency of the situation in an exemplary
fashion and to date has expended in the vicinity of $40 million on
remedial actions at the site. The boundaries of the contamination
plume have been defined to a point about 3 miles downgradient
at which concentrations decrease to less than 10 ppb at a narrow
geologic constriction. A few wells downgradient of that point have
shown trace levels of 2 ppb but are essentially considered beyond
the plume area, which measures about 3 miles long and a maximum
of 400 feet in width.
The cleanup method being used- an active approach is to
create a situation of hydraulic ground water control by extracting
contaminated water from wells located near the center of the flow-
path to create a cone of depression toward which tainted water will
flow. The plume is gradually decreasing in size and concentration
as contaminated water is extracted.
The extracted water is treated either by passing it through
activated carbon or by air stripping; it is then discharged to the
nearby storm sewer. The Bay Regional Board was at first allowing
the discharge of water with a contamination of 100 ppb, but recent
evidence that the recharge of that water is causing contamination
in a distant well has caused it to revise those requirements. Dis-
charged water in areas of potential recharge now must be treated
to a concentration of 1 ppb.
IBM is currently extracting water at the rate of about 10,000
acre-feet per year-about 7 percent of total ground water extraction
countywide. The company has recently submitted, by request, a
draft comprehensive plan, which addresses final cleanup objectives
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130
HAZARDOUS WASTE SITE MANAGEMENT
for the site. Because of concerns regarding the amount of water
"wasted" to complete the cleanup, IBM has proposed treating to 1
ppb and delivering the treated water to district-operated recharge
facilities.
Fairchild Camera ~ Instrument Corporation, San Jose
In 1981 Fairchild reported the loss of about 60,000 gallons of
TCA and water, which resulted in the shutting down of a nearby
water supply well contaminated at a level of 5,000 ppb TCA. The
Fairchild site is locater] less than 2 miles southeast of the IBM site
in the same sensitive area of the basin. Fairchild has displayed an
equivalent level of effort in defining the boundaries of the plume of
contamination and proceeding with interim cleanup efforts. The
plume extends about 1 mile offsite with high-level contamination
remaining in the soil and ground water directly underlying the
property.
The cleanup approach has been similar to that of the IBM
case in that hydraulic control has been maintained by means of
strategically located extraction wells. Problems were encountered,
however, when shallow aquifer materials became dewatered be-
cause of the rate of extraction from deeper aquifers. In order to
flush the contaminated shallow aquifer soils, Fairchild reinjected
treated water into wells perforated in the shallow zone.
This procedure eventually proved to be too time consum-
ing, however, and the company subsequently proposed and imple-
mented an additional measure to enhance the cleanup operation.
A bentonite clay slurry wall has been installed around the perime-
ter of the property to encapsulate the onsite heavy contamination
down to a natural clay layer at a depth of about 100 feet. Although
the construction cost about $4 million, the company decided that
the potential benefits justified the cost. The physical barrier al-
Tows Fairchild to extract water at a much lower rate within the
containment to maintain an inward gradient at the walls of the
containment. The offsite operation is also enhanced by ensuring
that additional contamination will not migrate from the heavily
contaminated area to continue "feedings the plume. Fairchild will
soon be submitting a comprehensive plan to propose final cleanup
objectives for the site.
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GROUND WATER CONTAMINATION
131
California Water Service Company Well, Los Altos
In 1982 it was discovered that a 400-foot-deep standby well
owned by California Water Service Company (Cal Water), an area
water purveyor, was tainted with carbon tetrachIoride at a con-
centration of about 10 ppb. The source of the contamination to
date is unknown. After consultation with the responsible regula-
tory agencies and public meetings with neighborhood residents,
it was determined that the well water should be treated by air
stripping at the welihead. By spraying the water into a holding
tank, concentrations have been effectively reduced to about 1-2
PP ).
A 111~ ~ i~ ^;~at.anrPa-t.h~ 1lnknown contamination
~lUllUU6ll L11= ~__~ ~
source obviously create the need for a passive approach, there
remains a concern about finding the source of contamination and
defining the plume to protect other wells in the area that are more
critical to the water supply. Based on existing and historical land
use in the general vicinity, certain landowners are being asked to
conduct relatively inexpensive soil gas surveys of their property to
identify possible sources of contamination. In addition, DHS will
be using the state Superfunds to investigate the area around the
subject well by installing monitoring weld to begin defining the
extent of the plume. As the investigation proceeds, the approach
may be changed to one of active cleanup.
CLEANS OBJECTIVES-HOW CIEAN?
When considering to what extent concentrations should be
reduced in cases of ground water contamination, the regulatory
agency has the unenviable task of balancing the cost of remedial
actions against the public health risk associated with consumption
of tainted drinking water. Even for those chemicals for which
drinking water standards or action levels exist, the decision is not
an easy one. There are many uncertainties associated with the
standards that must be considered when applying drinking water
criteria to ground water restoration activities.
Current Cleanup Policies
As noted previously, there are three agencies-the Regional
Water Quality Control Board, DHS, and EPA that have respon-
sibility for the oversight of remedial action activities. Although
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HAZARDOUS WASTE SITE MANAGEMENT
each has a different methodology for addressing cleanup objec-
tives, there are basically two schools of thought: (1) cleanup
to predetermined standards or (2) cleanup to criteria based on
an evaluation of site-specific circumstances. The predetermined
standards approach simply requires the cleanup to proceed until
concentrations in ground water are reduced to applicable drinking
water standards or state "action levels."
In the case-by-case approach, which has been applied by the
Bay Regional Board, cleanup to standards is considered a m~ni-
mum level of effort. Beyond that the discharger is asked to prepare
a report estimating the cost of three higher levels of effort: cleanup
to action levels, cleanup to nondetectable levels, and cleanup to a
third level at some intermediate point. The board then considers
each case in a public forum to allow comments to be heard from
all interested parties. The cost of each cleanup alternative is used
as a guideline in deciding on overall cleanup objectives. Other
factors, such as the underlying hydrogeology, the areal extent of
contamination, and the proximity of drinking water wells, are used
to evaluate the risk of contamination spreading to nearby wells or
affecting significant portions of the underlying aquifer.
Discussion
When standards exist for the chemical contaminants in a par-
ticular case, the simplest approach, administratively, is to require
cleanup to those standards. In sensitive regions of the basin,
however, this approach may be inadequate to satisfy not only
legislative mandate but also the concerns of the public who are
ultimately affected.
The Bay Regional Board, in its strategy for establishing
cleanup objectives, is attempting to incorporate all relevant infor-
mation into its decisionmaking. In the hearing process, the state's
nondegradation policy Is used as a starting point for subsequent
discussion. That policy requires the maintenance of preexisting
water quality unless the board finds that, because of economic
and technical considerations, some level of water quality degra-
dation is "consistent with maximum benefit to the people of the
state" and "will not unreasonably affects beneficial uses. This
policy is necessarily quite broad and leaves much interpretation to
the board members. There are many important factors for their
consideration in reviewing a case.
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GROUND WATER CONTAMINATION
133
The location of the contamination is of primary importance.
In Santa Clara County, there are widely varying hydrogeologic
conditions that affect the way contamination can move once it
is released into the ground water basin. The Bay muds, existing
along the edge of San Francisco Bay, provide an example of a
nearly complete natural containment; contamination at the sur-
face would, for all practical purposes, never reach deeper aquifer
materials used for water supply. Therefore, in that region of the
basin, removing only the heavily contaminated soil may be ac-
ceptable. In the forebay zone of the basin, however-the area that
recharges the deeper confined aquifers much greater efforts are
required. In that area, there are direct hydrogeologic connections
between the surface soils and deeper aquifer materials, and the
contamination of nearby wells is almost certain unless extensive
extraction of contamination is mandated.
In addition to the relevant technical aspects of a case the pub-
lic hearing process permits input from all concerned parties the
retail water agencies, the water district, and, most importantly,
the public. The public in Santa Clara County and throughout Cal-
ifornia is very aware of and concerned with water quality issues.
Statewide public opinion was strongly voiced by the overwhelm-
ing passage of a recent ballot proposition imposing, among other
things, stringent notification requirements on any designated pub
kc official with knowledge of any potentially hazardous discharge
to waters of the state. Clearly, the public is demanding account-
ability on the part of public officials and therefore should certainly
be included in any decisions involving health considerations.
Retail water agencies are equally concerned in that local liabil-
ity, with respect to serving unsafe water, must be taken seriously.
In the wake of a recent multimillion-dolIar lawsuit, at least one
local water retailer has refused to pump ground water with any
detectable level of organic chemicals.
Finally, the district, with management responsibility for the
ground water basin, takes a very conservative view on cleanup
requirements. One concern is that many of the chemical standards
are based on a relatively short time span of data collection and
research. As more is learned about the proven or potential effects
of these chemicals, a gradual lowering of the standards can be
expected. In that case, welihead treatment may be required for
what was once considered safe contaminant levels in ground water.
Ultimately, the question of equity arises as to whether the resultant
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134
HAZARDOUS WASTE SITE A~4NAGEM:ENT
liability and costs are those of the public or of the responsible party.
It would seem inequitable to require the public to bear the cost
of such treatment when a responsible party was once assuming
liability for the contamination.
CREAM COSTS TO IS RESPONSIVE?
As experience in Santa Clara County has shown, the costs
associated with remedial actions to remove ground water contam-
ination can be staggering. In general, responsibility for most of
the cases of organic solvent contamination in Santa Clara County
is being assumed by the company involved in the illegal discharge.
The ideal situation is one in which (1) a responsible party can be
identified and (2) the identified responsible party has the resolve
and financial means to undertake the necessary remedial actions.
It has been fortunate that some of the largest incidents in the
most sensitive areas of the ground water basin have been caused
by large, responsive corporations. In general, they have cooper-
ated with the regional board and proceeded with remedial actions
in a timely manner. This is not an assured situation, however.
In an increasingly competitive business world, there are ob-
viously strong economic disincentives for companies that have
caused contamination to proceed in a timely manner or even to
proceed at all with remedial actions. Furthermore, there are a
growing number of cases being discovered in Santa Clara County
for which the owner sunply does not have the necessary financial
means to remove the contamination. Most of these latter types
of cases are small businesses storing motor fuels in underground
tanks that have been found to be leaking. Other such contami-
nation is caused by small businesses who illegally or negligently
handle or dispose of toxic solvents. The threat to the public health
from incidents such as these can be as serious as from those caused
by larger companies with greater resources. Therefore, because
cleanup of these incidents must proceed expeditiously, alternative
funding sources must be available.
SUMMARY
The Santa Clara Valley Water District, as a wholesaler of wa-
ter and the management agency of the ground water basin, has a
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GROUND WATER CONTAMINATION
135
responsibility to ensure that the basin remains usable as an im-
portant element of the water supply in Santa Clara County. As
discussed earlier, recent contamination, primarily from leaking un-
derground tanks, has threatened that vital resource. In response,
regulatory activity in recent years has greatly reduced the possi-
bility that future leaks might cause serious problems. The various
regulatory agencies involved in cleaning up past contamination
have sorted out their respective roles, and an effective working
relationship has evolved.
Two approaches to remedial action have been discussed: the
active versus the passive approach. Although only the extremes
of these cases were discussed, various permutations are possible.
The consensus of the affected parties the public, the retailers,
and this agency-has been that the passive approach is definitely
not acceptable. Only when a situation arises in which the source of
contamination is unknown has welThead treatment been considered
a feasible solution.
In their oversight responsibilities the regulatory agencies are
faced with difficult decisions with respect to ultimate cleanup
objectives. The Bay Regional Board, as a lead agency in cleanup
oversight activities, has forged an effective policy for determining
cleanup objectives. Its approach considers economic, technical,
and public health risk factors in a process aimed at achieving a
cost-efl3ective cleanup that is safe and acceptable to the public.
Funding for the increasing number of contamination cases
being discovered is a growing problem in Santa Clara County.
Hundreds of fuel leaks have received little or no oversight due to
understaffing in regulatory agencies. As a result, these cases are
receiving an unknown level of cleanup effort from facility owners
who may or may not have the technical and financial means to
address these problems adequately.
CONCIUSIONS
This paper has attempted to outline the current situation and
describe issues that have been faced and continue to be faced in
Santa Clara County. Perhaps the primary conclusion reached by
responsible agencies in this area is that an informed public input
must continue to be an integral part of decisions affecting the
public health and environment. Public education and involvement
mechanisms must be incorporated into the process not only to
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HAZARDOUS WASTE SITE MANAGEMENT
allow public input on decisions affecting human health but also
to enlighten the public with regard to the difficult trade-o~s sur-
rounding environmental decisions. This kind of process will enable
mutually acceptable solutions to be reached with much greater
ease.
A final conclusion that becomes more evident as the techni-
cal realities of ground water contamination become more widely
understood not only by the regulatory community but also by
the public at large is that there is necessarily some degree of
risk that simply must be accepted. Various preventative programs
are now in place to drastically reduce the possibility of future
incidents causing serious ground water contamination. Yet exist-
ing contamination caused by past handling and storage practices
will be present for many years. The reality is that even if suffi-
cient funds were available, it would prove technically impossible
to remove all of the contaminants from the ground. The obvious
result is that some trace level of contamination in the water sum
ply in some areas may, unfortunately, be inevitable. Admittedly,
the health risk associated with consuming tainted water may be
minimal in comparison to other environmental risks with which
we live. It continues to be important, however, to strive for ways
to reduce those risks as much as is technically and economically
feasible.
BlBlIOGllAPlIY
California Department of Water Resources. 1975. Evaluation of Groundwater
Resources: South San Francisco Bay, vol. 3. Sacramento. December.
California Regional Water Quality Control Board, San Francisco Bay Region.
1986. South Bay Site Management System Reports. Oakland, Calif.
May.
Ford, J. 1978. The Story of the Santa Clara Valley Water District, San Jose,
Calif.: Santa Clara Valley Water District.
Himmon, K., D. Schwartz, and E. Soffer. 1986. Santa Clara Valley In-
tegrated Environmental Management Project, Revised State I Report.
San Francisco, Calif.: Environmental Protection Agency. May.
Suffet, I. H., and M. J. McGuire. 1980. Activated Carbon Adsorption of
Organics from the Aqueous Phase, vole. 1 and 2. Ann Arbor, Mich.:
Ann Arbor Science Publishers, Inc.
TRY Consultants, Inc. 1984. South Bay Groundwater Contamination Task
Force, Agency Coordination Project. San Francisco, Calif. December.
U.S. EPA. 1984. Groundwater and Drinking Water in Santa Clara Valley:
A White Paper. San Francisco, Calif.
OCR for page 137
GROUND WATER CONTAMINATION
137
PROVOCATEUR'S COMMENTS
N orb ert Dee
~ would like to make some general comments about the paper
and about other related issues. First, the paper is very good in
discussing risk management and the hazardous waste management
issues facing a water district. What we have learned over the last
5 years of RCRA and Superfund implementation is that not all
ground water is equal. In addition, we have learned that we can
make very costly and technical mistakes by going in with a shove!
just to do something.
In the Superfund discussion earlier, the point was made that
not all ground water is equal and that therefore, in making cleanup
decisions, consideration must be given to the use, value, and vul-
nerability of ground water. This is a differential protection policy,
which is not accepted by everyone. At present, EPA has a cIassi-
fication system based on differential protection that has been sent
out for public review and comment. In the example discussed in
the paper, $40 million was spent cleaning up a site. Should we
do the same level of cleanup if the site had no effect on a pub
kc water supply? The Safe Drinking Water Amendments of 1986
also protect drinking water from contaminants that could affect
human health by protecting the weDhead area. This is a form of
differential protection.
Earlier, some arguments were made against the macro ap-
proach of classification and data collection and in favor of a micro
approach. My response to that brings to mind an incident from
Alice in Wonderland. Alice was walking down a path when she
reached a fork. She asked the Cheshire Cat which way she ought
to go. The cat responded by asking where she wanted to go, and
when Alice said she didn't know the cat said, "Then it doesn't
matter which way you go." We need to do better than Alice, and
a macro policy can direct us. This, to some degree, has been the
problem we have had over the last 5 years. If we focus our atten-
tion on priority areas based on classification, then we know which
path we are taking and the issue of specific data will be answered
by the implementation of the policy.
OCR for page 138
138
HAZARDOUS WASTE SITE MANAGEMENT
~ would like to make a few more comments on the paper. Be-
cause ~ do not know the specifics of the Fairchild or the IBM sites,
the question ~ pose may be unanswerable. The question is this:
Would or should California have proceeded differently if the areas
were not vulnerable, if they did not have an irreplaceable water
supply, or if a public water supply had not been threatened? In
other words, if the site had been in another location in California,
would we have made or should we make the same decision? This
is a risk management question.
Another point about the cleanup at the Fairchild site also
concerns risk management. If the cleanup of the site requires air
stripping and we are in a nonattainment area on volatiles, is this
good management? In addition, the pump-and-treat method used
in these site cleanups did not look at the depletion of the ground
water resource by discharging the treated ground water to the San
Francisco Bay. Again, are we looking at the full picture, managing
our risk properly? This is the same question David Miller asked
earlier. What are we trying to do?
The last point ~ would like to address is that the approach
followed in the paper ~ differential protection and risk manage-
ment. Yet the state has a nondegradation policy. How are these
two compatible?
Representative terms from entire chapter:
water contamination
