Olin Corp. must present a new feasibility report, accept
responsibility for perchlorate pollution found in wells northeast
of the Tennant Avenue plant and use perchlorate numbers
correctly.
Perchlorate has been in the news a lot recently. Even though the topic can be scientific and dry, it’s critical to protecting South County’s water supply that residents, elected officials, and regulators stay on top of developments.
First the good news: Olin Corp. completed its cleanup of soil at its now-closed road flare factory on Tennant Avenue a year ahead of schedule. The source of perchlorate that is snaking its way through South County ground water has been removed.
“Cutting off the source of contamination is a major accomplishment in any groundwater cleanup effort,” Central Coast Regional Water Quality Control Board engineer Hector Hernandez told reporter Tony Burchyns.
We couldn’t agree more, we congratulate Olin on getting the job done ahead of schedule and remind South County residents that this important goal was accomplished much more quickly than in many other communities that are dealing with similar perchlorate contaminations.
But it’s not all good news, and the bad news is centered on a required feasibility study that Olin recently released.
Morgan Hill officials are protesting the study because Olin does not take responsibility for perchlorate pollution found in wells northeast of the Tennant Avenue plant.
Olin has argued that groundwater in the area travels south and has avoided responsibility for the northerly contamination. However, the city has hired its own consulting engineers who have come to a different conclusion.
“We believe there is one basin, there is one major source of perchlorate, and that [Olin] should be held responsible for cleaning it up,” City Manager Ed Tewes said.
The city’s consulting engineers reached this conclusion based on analysis of Olin’s own data, Tewes said.
Morgan Hill has spent $3 million on perchlorate-related expenses – and rate payers have had to foot $900,000 of that bill.
We applaud Morgan Hill officials for pressing their case with the regional board.
But that’s not the only problem with Olin’s feasibility report, which was supposed to fully evaluate all possible cleanup options. Armed with a complete and accurate feasibility study, stake holders could evaluate the options based on cost effectiveness and how well each would return the area’s ground water to its background perchlorate level. The background perchlorate level is the natural level of perchlorate that was in the area’s water before the pollution occurred.
But Olin’s feasibility report fails to do that in several ways; we detail just two here.
First, it uses perchlorate numbers incorrectly. Olin was charged with determining the background perchlorate level. They picked a number – 4 parts per billion – but didn’t substantiate how they arrived at it.
Also, throughout the report, Olin referred to two irrelevant perchlorate levels, the state public health goal of 6 ppb and the EPA reference dose of 24.5 ppb. Those numbers have nothing to do with determining background perchlorate or long-term cleanup levels.
Second, it failed to fully consider all options. Instead, it really considered just two: monitored attenuation, which means monitoring only, and no further action, which means just what it says – not even monitoring is done.
Olin’s preference, not surprisingly, is the no further action option.
Many other options besides the two variations of “do nothing” are available and Olin must be required to fully evaluate all of them.
Olin has hired bonafide experts on the subject. They have the data already on hand to put together an accurate and complete feasibility study.
The regional board must reject as utterly unacceptable Olin’s feasibility report and direct the company to present another one in 30 days.
South County residents deserve more than what Santa Clara Valley Water District board member Rosemary Kamei rightfully called this “infeasibility report.”
