CAMP DTSC STREAR Answers to DS questions Nov.

29, 2016
FROM Jay Strear to Deborah Schoch, received November 29, 2016

Starts here:

In an effort to ensure that Ive answered all of your questions, Ive included a list of
questions youve asked me over the past week and my response to them:

From your email dated Thursday, November 17, 2016 12:04 PM:

1. Information on low levels of chemicals in soils on the Brandeis Property (BBI) were
provided at public meetings in 2014 and 2015. Evaluation of the data indicates that the
impacted soils do not pose a threat to human health.

Q: Do you have the information that DTSC mentions here? If so, can you send it to me or
guide me to it on your website? (I know that you have considerable information there, and
have sent me much of it, but I need to review that information quickly, for obvious reasons.)

DTSC stated to you that Information on low levels of chemicals in soils on the Brandeis
Property (BBI) were provided at public meetings in 2014 and 2015. I asked DTSC what
exactly was reported in 2014 and 2015. While we went over this information together
in a recent conversation, I think its important to share it with you again.

First, the information referenced in the DTSC statement comes from the April 2014 and
April 2015 bi-annual community update meeting and is available online. These biannual presentations generally include progress reports on current studies or
investigations, preliminary findings, or indicate to the public where additional
information is needed, why this new information is needed and how the Responsible
Parties intend to close those gaps in their data.

During the April 2014 bi-annual community update, DOE reported on where additional
data were needed to more fully characterize Area IV and the Northern Buffer Zone for
chemical analytes. As is indicated in the report below, given the fact that the detection
levels used for the AOCs is so low, additional investigation was needed to differentiate
between organic and non-organic substances using EPA methods. See:
http://www.dtscssfl.com/files/lib_pub_involve/meeting_agendas/meeting_agendas_etc/66368_DTSCDOE_Phase_3_GoBacks_2.pdf It must be noted that information in this presentation
has been negated through further analysis and the final determination about
impact and potential mitigation will be included in the DOE Environmental
Impact Statement, when released.

During the April 2015 bi-annual community update, DTSC presented a preliminary map
showing Chemical Look Up Table Exceedances for Area IV (DOE). According to DTSC,
the results of the further investigation said to be needed in the 2014 update (as
discussed above) are not necessarily reflected in the relevant map (page 15 of the
presentation found here: http://www.dtscssfl.com/files/lib_pub_involve/meeting_agendas/meeting_agendas_etc/66578_04-28-

15_SSFL.pdf). Here too, final determination about both the relevance of soil
samples and the need for mitigation, if any, will be addressed in DTSCs
Environmental Impact Report.

Most significantly, BOTH the 2014 and the 2015 report to the public included
preliminary information that is not relevant to assessing the safety of the Brandeis
Bardin campus because the information, even if accurate, does not indicate that there is
any constituent found on BBC at levels which would render the site in any way unsafe.

2. Based on analysis of the extensive off-site sample and monitoring results obtained since the
1980s, DTSC has concluded that low concentrations of chemicals in drainage channels on
the Brandeis Bardin property do not pose a threat to human health risks for students, faculty,
staff or visitors on BBI.

Q: Do you know specifically what DTSC is referring to as "low concentration of chemicals in
drainage channels on the Brandeis Bardin property"? If you have a report on these
findings that gives specifics on locations, types of chemicals and test results, could you send
it to me?

We have independently reviewed the DOE soil sample data for our own assurances and
have concluded that this data does not raise any issues regarding the healthy and safety
of any users of the site. First, as we have discussed, the chemicals detected on the site
are ubiquitous and not different from what would be found in almost any area that has
been used for agriculture or has experienced historic fires. The levels of concentration
of these substances are well below typical action levels. Second, none of the sample
sites is near activity areas on the BBC. Each location is approximately 2 miles from the
center of camp, nearly 600 feet up a mountainside in an area of camp that is effectively
inaccessible. Below is a snapshot of three maps showing the same area (unfortunately,
these maps are not to scale):


Map 1 - Far southwest corner of BBC property on former ranchland:

Map 2 - Same area as shown from a scanned copy of soil sample locations from DOE:






Map 3 - same area as Maps 1 and 2, as shown on a DTSC map titled Area IV-Where are
the chemical contaminants:

DOE also provided AJU with the actual sampling data that relates to Maps 2 and 3, as
follows:


The notes in red are my writing and reflect conversations with DOE and DTSC officials.
The circled red 1, 2 and 3 correspond to grouped sampling locations on Map 2.

3. In addition, DTSC reviewed the NASA chemical data summary report and have not found
any data that shows exceedances leaving NASA-managed property onto BBI property.

Q: Do you have what DTSC refers to as the NASA chemical data summary report, and, if so,
could you send it to me?

Based on information provided to me by DTSC and NASA (information presented in the
link that follows and which is in the public domain), the NASA data within this Project
Description was simply wrong. Please see: http://www.dtscssfl.com/files/lib_NASA/DataSummaryRpt/NASADataSummaryReportpp481603_FIGURES.pdf (see page 3). The information on page 3 has been verified by
NASA, shows no needed mitigation on AJU property and further underscores the
preliminary nature of the working draft document you were provided.

4 Q. Did Mark Malinowski tell you yesterday that the "spaceholders" mentioned below
specifically include the AJU soil acreage listed for removal on p. 2-3 of draft Ch. 3?

I was told by DTSC that the information in Table 3-1 of the Project Description
should be seen as placeholders. As we were both told, this information is found

in a preliminary administrative draft containing data that are known to be

incorrect.

5. Q. When did you first hear that DTSC and the RPs were discussing removing soil in the
northern drainages as part of the SSFL cleanup?

To date, I have not heard that DTSC and the RPs were or are discussing removing
soil in the northern drainages. Ive only heard this from you and that information,
as I understand, comes solely from the preliminary administrative draft EIR.

5. Q. Can you tell me where this land - estimated at 1 acre, and at less than an acre - is
located?

Neither DTSC nor the RPs had ever informed me that cleanup was being
considered on any portion of the BBC. After you provided me with the project
description from the preliminary administrative draft EIR, I immediately
contacted all three agencies (DTSC, NASA and DOE). As noted above, NASA
informed me that the one-acre cleanup attributed to NASA was factually incorrect.
DOE did not delineate an area but instead provided the sample results discussed
above. DTSC gave me the same information they gave you that the cleanup
contemplated in the draft is a placeholder and no decisions have been made at
this time. I can only surmise that the <1 acre cleanup area that the
administrative draft refers to is in the vicinity of the DOE sample results, but that
is only an educated guess. I interpret the fact that no cleanup area has been
delineated (or even communicated to the owner of the property where such
cleanup would take place) as further evidence of the extremely preliminary
nature of the information in the administrative draft EIR.

From your email dated Wednesday, November 23, 2016 4:07 PM:

On another topic: DTSC has sent me a map (attached) that I'm sure you have already, I had
asked DTSC to locate where the contaminants were found. Here is what DTSC responded:

"The attached chemical characterization figure shows areas where samples exceeded
DOE Look-up table values (pink areas). These locations are primarily associated with
a limited area of drainages, thus the limited acreage listed."

The drainages look more lavender than pink, but they appear to correspond roughly with
the DOE sampling map that you sent me yesterday. Do they match what you've heard from
DOE?

On the Map you provided me (Map 3 above) there are grey triangles. These grey
triangles correspond to sampling locations that can be seen in the DOE report
presented in 2014, as discussed above, and also correspond to the sampling
location on Map 2 and the sampling data in the chart above. The pink areas
shown in the map you sent me are estimated areas labeled on the DTSC map as
Preliminary Remediation Areas (PRA). The 2015 presentation was ALSO
preliminary as is the information on this map. It is critical to understand that the
pink denotes area for further analysis, NOT area for remediation.

Finally, can you give me a description of where these drainages are, including proximity to
specific Brandeis landmarks? I've attached a Joel Cehn aerial map that shows the drainages
better than most. Let me know if it's readable - if the yellow boxes are askew, I'll look for a
better version.

I know from the two tours you gave me that we're talking about hard-to-reach, remote
areas, and I will describe that in the article.

As referenced above, the drainages where the DOE samples were taken, and
where the pink is presented on the DTSC map (Map 3 above) can be see below, as
indicated by the yellow arrows:

Map 1 from above - Far southwest corner of BBC on former ranchland: