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Howard Carlip’s Comments on the Riverside Report 6-13-96.
Revised 8-13-96
Animals as Ammonium sources
Bio-solids disposal
Conclusions
Existing
Surfactant pollution
Fertilizers
and Ammonium sources
Humans
as Ammonium source
Nitrate
increases after the 50-year storm
The Pratty
Pig Farm.
Pristine
sites
Surfactants
in the Water
TAC
Community representatives.
Test
Drill Sites
Transport
mechanism theory
By Howard Carlip © 8-13-96
The Aqua Dulce Town Council approved this report on June 12 for submission and comment by California Regional Water Quality Board, Los Angeles Basin.
The University of Riverside (Riverside) came to the conclusion stated at the May 8, 1996 meeting that "All nitrate pollution is from human sources" with no possible doubt, though in the report they discussed the unreliability of their most modern testing equipment. This data can be lost in such a large report, covering their collective positions from future actions taken against them.
Their conclusions are flawed. This paper will disclose the errors in the Riverside report.
Abstract ii-3 "Results of transport modeling of natural rain fall recharge conditions clearly indicate that vertical movement of natural soil Nitrate under these conditions is exceedingly slow. These facts along with the observed point-source, Nitrate contamination style of much of the Sierra Pelona, lead to the conclusions that natural soil Nitrate was not the dominant contributor to highly observed concentrations". "Transport modeling at Anthropogenic environments providing large constant recharge water fluxes (Septic systems, irrigation) convincingly show rapid vertical transport of such anthropogenic, organic nitrate toward the water table."
See discussion on transport mechanisms.
Abstract ii-4 "Isotopically moderate to heavy Nitrate indicates that septic sources and ancient (SIC) modern animal contaminant sources as most likely contribute significantly to the point source".
In this report nitrate-is expressed as NO3 (MCL of 45mg/l) instead of nitrate as nitrogen (MCL 10 mg/l), because most agencies use this scale. The Riverside report seems to use both scales in a confusing manner. Also, mg/l can be expressed as Parts Per Million (ppm).
Chapter 3-5 3 Sampling and analysis of groundwater for nitrate and major elements indicated that the nitrate contamination in the Sierra Pelona basin is complex. At least three distinctive types of nitrate enrichment were observed in our investigation of the region.
The TAC Community representatives. The Agua Dulce community was represented on TAC, by Tom Soper and Art Babcock.
Chapter 1-7-1 This TAC included representatives of the Agua Dulce community. The TAC met at critical points in the project (initiation, drilling site selection, and data evaluation) to discuss and comment on procedures, results and reporting)".
Riverside came to town and chose the area downstream from a 10-acre pig farm as their only "pristine" site. The TAC representatives failed to correct Riverside’s choice of a "pristine site".
Chapter 3-8-5 "A site around the A.D. Airport was suggested by the project manager. Since that site met the requirements for a pristine site, a communication was initiated with the landowner, however permission to drill at this site was never granted by the landowner".
The CH2M-Hill report went into detail about this and other animal waste sites. The Riverside paper critiques the CH2M-Hill report, which indicates that it was thoroughly read. Test data shows a well near the airport runway at around 75 Mg/l, clearly not pristine, but thoroughly contaminated.
Chapter 1-5-6 "We also acknowledged the skepticism of members of the community toward previous investigations and attempted to carry out this project without preconceptions. To this end, the design of our sampling and analysis program was carried out prior to any compilation or re-interpretation of results from prior investigations".
The airport wells are directly down the main blueline stream from the ten-acre pig farm waste dump. The representatives from this town on the TAC committee were well aware of this information. The draft was issued including this gross mistake. This mistake has been in the data for four years.
Nitrate increases after the 50-year storm. The Riverside report states (abstract page 1) in March, 1993, one month after the "50 year rain" (2-1), which they called "Flood Condition (24.8"). The second highest total in half a century. "2-1-1. The wells with over 90 mg/l as NO3 increased from 2% of the wells tested (92 wells) to 14%.
This points out that their premise will prove their theory of ever increasing levels of nitrates contaminating the groundwater in the Sierra Pelona basin. They then state six months later, in September, that the percentage decreased to 6%, a net increase of only 4%.
From this data alone one could conclude that in 25 years, each consisting of a 50-year storm, all wells would be over 90 mg/l as NO3.
According to their basin discussion on climate - precipitation - vegetation, the average rainfall is about 6.8" per year. Every 8-10 years "abnormal", high rainfall seasons (greater than 18") occur. This would now date the time that all wells remaining > 90 mg/l as NO3 to some time around 72.5 years from now.
The average rainfall of one year at 24.8", and nine years of 6.8", is 8.6" per year. If there was a net 4% increase of nitrates during the 24.8" year, then a normal 6.8" year would be 27.4% of the 24.8" year, or a 1.1% increase of nitrates in wells over 90 mg/l as NO3, nine years out of ten. This would be average all ten years at a 1.387% increase.
The second premise on page i of the abstract. 33% of 235 wells in 1992 had concentrations over 45 mg/l as NO3. One month after the fifty-year rain they tested again and concluded that wells at that level increased to 34%, a total change of 1% . The second test (3-93) consisted of only 92 wells.
For better data, they should have tested at least 200 wells, instead of only 92. Their data is based on only 39% of the original wells tested. Even at the high levels after the flood season, only 14% of 92 wells (13 wells) were over the levels of 90 mg/l as NO3. In the fall of 1993, when levels went back down again, only 6% of the 92 wells (6 wells) stayed over 90 mg/l as NO3. This is not a representative cross section to prove their conclusions.
Riverside and TAC should have inspected the high level wells, if possible, and diagnosed individual mitigation with the aid of the LA County Health Department staff if they were really interested in proving the "Source" of the nitrates. They only mention possible well contamination due to construction problems or old age. They don’t have any counts or locations of the claimed bad wells, but conclude that there are lots of them. Riverside needs to find and disclose at least 10 wells as proof.
The chain of custody issues has already been raised, questioning the integrity of their gathering. They had the well tests from the CH2M-Hill report, therefore, one could conclude that they could pick any wells they saw fit to test for their deserved conclusions. The results could have gone either way. They could have picked any wells they wanted to and state that these were a "random sampling".
Test Drill Sites. Four drill sites chosen were already known as high nitrate sites in the CH2M-Hill report. Riverside failed to drill at a pristine site. They based the soil and rock chapter on only these four tests of the known "dirtiest" sites. Even though they stated earlier that the community was bothered by previous reports, it was Riverside's mission to investigate other sources of nitrates.
Chapter 1-4-3 "Concern has been raised relative to the number of wells sampled by CH2M-Hill, the accuracy of their results and the apparent lack of investigation of other sources of nitrates in the basin".
Chapter 3-9-2 Sampling Procedures "Initially, continuous cores were taken from the surface to termination of four locations (DS 1, DS 2, DS 3, DS 4)."
DS 1 is just north of Vasquez Rocks Park. This area was used heavily for horses and cattle during the 1910 to 1940 period.
Chapter 3-5 5 "The third distinctive mode of nitrate contamination identified in the Sierra Pelona basin is a very extensive region of moderate to high concentrations (greater than half of the MCL). This somewhat contaminated region covers much of the deep alluvial aquifer of the basin, which underlies the most densely populated portion of Agua Dulce. This area is referred to as the "Agua Dulce region". In contrast to the "Fire station region", this area shows good correlation between nitrate concentration and that of other major solutes. This indicates a different nitrate source and/or a different mode of contamination."
‘
DS 2 - Fire station. Sierra Highway was old US 6, the only route to the mining areas in the eastern Sierras and the Great Basin area from Los Angeles until 1960. Based on the chemically distinctive reports, a more likely explanation is that it is from an old chemical spill.
Abstract i-4 "A tight cluster of strongly "Contaminated" wells in the vicinity of the fire station on Sierra Highway appears to produce chemically distinctive waters. These wells have unusually low concentrations of dissolved chlorine and sulfate, but high concentrations of Nitrates."
Chapter 3-5 4 "The second mode of occurrence of nitrate contamination is a more extensive region producing waters of high nitrate concentration and unique major element chemistry. This region is located near where the Agua Dulce Canyon crosses the Sierra Highway and is referred to as the "Fire station region". Water wells at the Agua Dulce fire station lie within this contaminated area and have been repetitively sampled, always producing high nitrate waters with otherwise low concentrations of other major ions. The geochemistry of this region is unique in that the contamination of the groundwater is apparently not linked to high concentrations of other soluble compounds which might also be leached at the surface and be transported with the nitrate into the groundwater."
DS 3 - Anthony Road near Hierba Road.
Chapter 3-8-2 "Drill site 3 (DS 3): Near surface nitrate loading at this site (if any) may be dominated by animal waste from pens located just uphill from the proposed site".
DS 4 - The Pig farm
Abstract ii-2 "Soil core samples from a site known to have supported pig production in the past had heavy isotopic compositions as well as high Nitrate concentrations."
Chapter 3-8-3 "Drill site 4 (DS 4): A drill site was selected in a region with relatively thick alluvium, a relatively thick vadose zone and a distinctive historical land use as agricultural/animal pens. The "pig farm" site was located somewhat north of the airport in an unpopulated valley. This site was selected to provide a nitrogen isotopic "signature" representing animal sources of nitrogen."
All of these drill sites were known for high nitrates in wells.
Pristine sites. Every one of Riverside’s maps of the Sierra Pelona basin shows testing only to one mile north of Sierra Highway. The true boundaries of the basin are located on previous maps (CH2M-Hill). The Riverside report has 25% of the basin missing. Although they speak of the northern boundary at Mt. McDill, (2-1-3, they refer to it as Mt. Dill), none of these maps show it. Why? Two miles of the northern territory has disappeared and along with it so have six wells below 1 mg/l as NO3. These were in the CH2M-Hill report, but not in the Riverside report. Are these the pristine sites?
Chapter 3-8-4 "Pristine site: The final site proved to be the most elusive. This site was planned to represent "pristine" natural conditions in the Sierra Pelona Valley. Because of the long history of agriculture, animal use and residential use in the alluvial portions of the valley, it was difficult to find an accessible site with sufficient alluvium to make drilling worthwhile."
These might have been "elusive" to the TAC committee, but in referring to Plate 5 from the CH2M-Hill Report, over 14 wells had less than 1 mg/l as NO3.
Chapter 3-8-6 "Because of the lack of a single accessible and suitable "pristine" site, an alternative approach to evaluate multiple "pristine" sites was followed. This approach involved sampling basement rock exposures (R-) and associated soils (S-) from a number of locations in the watershed (figure 3-2)."
The June 10, 1996 report by Allan E. Seward, registered Geologist 571 and Engineering Geologist 246, states in part in paragraph 6.
"The Riverside study has no data base relative a pristine ground water source. Therefore their conclusions relative to the source of the nitrates is questionable." And later "the primary source of the existing nitrates in the ground water is still unknown."
Registered geologist Seward disagreed with the Riverside report in his independent findings.
Surfactants in the Water. Washing products contain, among other ingredients, organic surface-active compounds (surfactants). The most common used are anionic alkyl Benzene sulfonate, linear alkyl sulfates (LAS), and linear ethoxy sulfates (Van Nostrands Scientific Encyclopedia, 5th edition, pg. 772). These constituents were never detected in any well water samples.
Chapter 3-11-2 "A subset of well samples were also analyzed for MBAS and non-ionic surfactants. However, these constituents were never detected in any well water samples. Thus, the presence of these constituents could not be used as evidence of well contamination.."
Riverside tested 15 wells almost 2 years apart. The second test was one month after that 50-year rain. That's when some wells’ nitrate levels spiked. They used two tests, without success, to try to find surfactants.
The standard (Methylene Blue Active Substances (MBAS) test's sensitivity level is 0.050 ppm. The second test, NID, measures above 0.3 Parts per million (ppm). None were found. Assuming a family of four does one load of laundry every other day, you would put 4 ounces of detergent in an average washing machine with roughly 33% (or more) of non-ionic surfactants. This is 2.64 oz per load or 1.32 oz of surfactants per day. Now let's add in an average homeowner's use of the bathroom and other household uses. The average household uses about 200 gallons a day, if they don't own a dish washing machine. Concentration of surfactants in the 200-gallon output of the septic system per day is calculated:
1.32 oz / 128 oz/gal / 200 gal =0.0000515 or 51.5 ppm
Non-ionic surfactants break down slowly, and since they also float on the surface, they should quickly exit from the septic tank into the leach field.
The septic output is 1000 times the minimum level traceable by Riverside's tests. With 51 parts per million (or 51mg/l) the MBAS test will detect surfactants at 0.05 parts per million. They found none. The septic contains 75 to 200 ml/l nitrates as No3. This is the first way to show that nitrate pollution is not from septic sources.
Add in all the other cleaning products you dump down the drain, some with ammonia, chlorine, alcohol, bleach (Sodium Hypo Chlorite), phosphates (still used in some washing powders), and suds suppressers (silicon based anti foaming agents which do not break down). This paper is not about pollutants, because all of these products are safe for the environment when used properly and are allowable in waste systems. So, if you pour them down the drain in L.A. or Agua Dulce, some will breakdown eventually, some like non-ionic surfactants will not.
Most dishwashing products contain about 1.6 grams of phosphate per wash. Assuming they wash one load per day and ignoring all other sources of phosphate used, we get:
1.6 gm/ (200 gal x 7.46 lb./gal X 2.2 Kg/lb) = 0.00000047 or 0.47ppm
This is 10 times the minimum level traceable by Riverside's tests, which showed none found. This also clearly shows our nitrate pollution is not from septic sources.
Existing Surfactant pollution. The annual water quality report for 1995 shows that California State Water Project water from the Sacramento Delta is delivered through MWD and AVEK. Even after treatment the water still contains 0.05 ppm surfactants (MBAS test) which can't be removed in the treatment plant. They are not harmful in small quantities and they degrade very slowly and serve as clear indicators of human septic source contamination.
Bio-solids disposal. LA City Sanitation District plans to take tons of sewage sludge called bio-solids and dump it on the ground in Palmdale. In reality, it is a biohazard so toxic the EPA prohibits the past practice of dumping it in the ocean. It is to be spread over 200 to 4000 acres at the Palmdale Airport. The water table is about 200 feet deep. The Lauhatan California Regional Water Quality Board (which covers the eastern Sierra and the Antelope Valley) said that this sludge will not transport into the groundwater, even though it will be irrigated at the equivalent level of 120 inches of rain a year.
In Agua Dulce, where the water table ranges from 10 to 800 feet, they claim that septic tank output will reach the groundwater, but thousands of tons of sewage sludge will not, 30 miles away in Palmdale.
Allan Seward in his report in paragraph 7 states: "until a pristine ground water base and a detailed study relative to the presence of surfactants [and] boron and phosphorous) are established, the primary source of the existing nitrates in the ground water is still unknown".
Fertilizers and Ammonium sources.
Chapter 3-14-2, "It should be noted that no well water samples were found to contain significant quantities of Ammonium".
The Riverside report states that at its test’s sensitivity level of 0.5 ppm, they still found no ammonium.
A fertilizer such as "Stern's Miracid" is rated at 30-10-10. The 30% is nitrogen as 27% urea which is CO (NH2)2 or ammoniacal (not nitrate) based nitrogen and 3% straight ammoniacal nitrogen).
One envelope of 30-10-10 is 1.25 lb. and will make approximately 40 gallons of dilute fertilizer.
(1.25 lb. /40 gal X 7.46 lb./gal) X 30% = 0.001257 or 1257 ppm
The instructions call for 1 gallon of this solution per 10 square feet every two weeks. One envelope will feed 400 square feet this solution.
The area fertilized will be watered, flushing the ammonium toward the ground water. If crops are fed all the way into the end of autumn, cooler weather will slow down the breakdown mechanism of the nitrogen.
Horticulture science states the denitrification pathways changing ammonium into nitrates. A lot of these changes respond to temperature, bacteria, plant uptake, rain, evaporation, and groundwater recharge. As no ammonium was found in the well tests, the contamination was not from fertilizers as they were bound to the soil.
Animals as Ammonium sources. Another ammonium source is large animals (Horses, CoReturn to Index
ws, Pigs, Llamas, Ostriches, Buffalo, Asses, half Tigers-half Lions, Elephants etc.).
Current zoning allows 8 horses per acre, or 20 per 2.5 acre parcel. Sometimes manure is dumped into the flood plain. During the big rains the flood takes the manure, full of nitrates, downstream to the neighbors.
Humans as Ammonium source. Human waste has considerable ammonium. Riverside states that septic effluent is a continuous output and is the only possible transport mechanism to the ground water. The ammonium from the leach lines is flushed into the groundwater and if their conclusions are correct then ammonium would have been found in the ground water.
This also clearly shows our nitrate pollution is not from septic sources.
Transport mechanism theory. Riverside claims the septic effluent under the leach lines is flushed into the groundwater during heavy rains. They also claim that the Natural nitrates, fertilizer and manure at surface level doesn't flush down. How did the rain water get from the surface bypassing the first four feet of earth. Why didn’t the rain water flush out all the soil including the first four feet which covers the leach lines?
The recharge means that the soil is saturated all the way down to the groundwater.
Conclusions. The claim has been made that "Surfactants in the wells prove septic contamination, but the absence of them proves nothing".
Only High Nitrate Wells Tested. Riverside chose the high nitrate test wells from the CH2M-Hill report to give them a sufficient source for their isotope analysis, which is the primary testing method of their study. There was no reason to test low reading wells because there was insufficient nitrogen to test for isotopes. Therefore, low reading wells would not be tested because of the low sensitivity of the testing equipment. They even stated:
"Because of the complex array of chemical and physical processes in which nitrogen participates, isotope "fingerprints" are rarely well defined, instead appearing as a range of composites described best by a statistical probability".
Chapter 1-4-3 "Concern has been raised relative to the number of wells sampled by CH2M-Hill, the accuracy of their results and the apparent lack of investigation of other sources of nitrates in the basin".
This shows that the entire study is flawed.
Transport Mechanism. It would be proper to retest the 13 wells that spiked in March, immediately after a record heavy rain and every two months to chart their rate of decrease, thus disputing their "Transport mechanism theory". What they seem to prove is that there is nitrate contamination after a heavy rain. Their claim that the extra 4 feet above leach lines blocks natural, fertilizer, and human nitrates from getting into the water table is wrong, as the rain soaks in from the top down.
The true sources of nitrate pollution. At the 5-8-'96 meeting enlarged copies of the 1988 CH2M-Hill report Plate 5, titled "1988 Nitrate Values", were posted. It showed:
The Pratty Pig Farm. This is the primary nitrate pollution source for Agua Dulce. It is an old (1950), large landfill located up the blueline stream, 1/2 mile northeast of the airport. One of our consultants, Dr. Carl Austin, (Former chief geologist of the NWC China Lake) stated, "Pig farm waste when placed underground never dissipates and water flowing through the pig dump will leach out large quantities of nitrates". Further he states, "the material is so toxic any animal eating the waste will quickly die from nitrate poisoning.
One of the airport wells is located 100 yards north of the end of the runway and tested at 74 mg/l as NO3. 1/4 mile directly north of the airport well is a well testing 3.6 mg/l as NO3. 450 yards due west of the airport a well tested 9.1 mg/l as NO3. Half way down the airport runway is a well tested at 31.2 mg/l as NO3.
At the south west end of the runway and down the blue line stream is a 75.9 mg/l as NO3 well. Then, 220 yards more in the same direction it drops off to 21.6 mg/l as NO3. Due south 300 yards it reduces to .05 mg/l as NO3.
If you follow the blue line stream from the southern end of the airport, it goes southeast 1000 yards to a well at 87.7 mg/l as NO3, that well is exactly 220 yards due east from the well of .05 mg/l as NO3. 300 yards due east of that 87.7 well, out of the water table, it drops down to 18.1 mg/l as NO3 and 15.3 mg/l as NO3 at the next two wells and southeast 400 yards is a 0.0 mg/l as NO3 well. Continue southeast to the next well of 2.1 mg/l as NO3, 300 yards more.
This clearly shows a nitrates plume from the Pratty pig farm dump.
Animal Farm north of Sierra Highway near Agua Dulce Canyon. This is a rectangular parcel about 1/3 the size of the Pratty Pig Farm. On the eastern border of the pig farm, is a well testing at 62.5 mg/l as NO3,. 100 yards east is a well at 7.7 mg/l as NO3. Downstream, to the southwest is a well at 31.5 mg/l as NO3 and downstream southeast is a well at 22.3 mg/l as NO3. Directly north of the well at 22.3 mg/l as NO3 are three wells, one at 30. mg/l as NO3, and 2 at 0.0 mg/l as NO3. The well at 30 mg/l as NO3 might have a specific contamination problem, and that should be looked at.
Aside from that, all well results mentioned so far completely fit my argument of contamination downstream from a known animal farm dump site.
Fire station. This area is peculiar because there is no documentation of what existed previously at this site. Additional research and testing need to be done to prove what went on here. The polluted wells are in a circle from the fire station levels at 66.5, 43.8, 46.5, 31.1, and 24.5 mg/l as NO3.
The surrounding area, in all directions, drops off to 12.6, 0.0, 0.18, 7.8, 0.0, 0.38, and 0.04 mg/l as NO3. These localized problems must be investigated. It shows that the wells surrounding the high nitrate wells are very low to the outside of the area. The Riverside study pointed to it being from human septic sources, and overlooked the low reading at the next door neighbors.
Dusty Drive. Another high area at 38.3 mg/l as NO3 is approximately around Dusty Drive. This should be examined as a possible point source for much contamination from an unknown cause.
Vasquez Rocks. This is our area of naturally occurring nitrate rock. Around the Vasquez Rocks tests shows: 88.9, 73.1, 67.4, 22.7, 87.0, 33.0 mg/l as NO3. The Riverside report blames these values on contamination by man; from septic, upstream towards the center of town, in other words the three large business centers. They claim that all this human waste is going down the stream to Vasquez Rocks, yet no surfactants or ammonium were found in these wells. We have enclosed Riverside’s data showing 797 ppm naturally occurring nitrates in Vasquez Red Sandstone.
Allan Seward states in Paragraph 1. " The Sierra Pelona ground water basin is underlain by rocks of the Tick Canyon and Vasquez formation which were originally deposited in a closed volcanic basin. Paragraph 4 shows the entire area contains heavy amounts of natural occurring nitrates.
This shows that Riverside knew about the high levels of the naturally occurring nitrates but failed to disclose this fact in the report and only stated it in the appendix, which was not given to the Aqua Dulce Town Council.
Natural pollution sources. See the attached charts from the drilling and core samples.
Clearly this proves that the conclusion of the Riverside report, "All nitrate pollution is from human sources", is wrong and not supported by their own data.
Howard Carlip
To the Agua Dulce Nitrate Problem
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