Howard Carlip's 3rd response to the Riverside Report.

Revised 8-13-96

Note this was delivered to The Water Quality Board. 30 copies were passed out to the community. Lillian Smith refused to print it.

Geology Land Ho Chlorides Sodium
Surfactants CalMat My all time favorite quote
Isotopes Love Letter from Lanny
Modeling (Just stand there and look cute)
Another Bad Area Water Animal Husbandry
Beating a Dead Horse Final Chapter Conclusions To the Agua Dulce Nitrate Problem index


This Is Positively My Final Comment On The

UCR Report On Nitrite Sources In Agua Dulce!

By Howard Carlip © 8-13-96
This report uses the data from the Riverside report to prove the final conclusion of the Riverside report - "That humans are the primary source of nitrates in Agua Dulce" is completely false and unsupported by any data in the UCR.

These are a few of my favorite things:


1. Geology

The Riverside report should have reached different conclusions. This is why they did not. Their theory that the area with the highest concentration starts at the downtown area at the north and goes south to Vasquez Rocks just is not true because they've only tested seven wells. These wells, 6S at 26.9, 3H at15.0 ppm, 4G at10.9 ppm, 3J at-19.2 ppm, 1C at-29.1 ppm, 6F at 26.9 ppm, and 3I at 24.7 ppm, are very low in nitrates and it would be impossible to condemn this area based on this information. What they did instead was take the measurements at well 4-Y and Drill Site-1 (Exhibit A) and conclude that the populated business center of town contaminated the Vasquez Rocks site, across the street from the meadow. These two test sites are high in nitrates, but here's the reason why. This well tested at 33.7 ppm on 6/18/92, 40.6 ppm on 8/31/92, then moved up to 51.2 ppm in March 1993 after the 50 year rain. This is to be expected, except it really jumped up on 9/23/93 to 90.7 ppm. This is most peculiar because it is one of the few wells that went up in September, because most of the other wells settled down by then. This source is not from the fifty year rain.

The soil core sample showed 1845 mg/L one foot deep, 374mg/L two feet deep, 63 mg/L three feet deep. This does not point to groundwater contamination from septics. This surface contamination would very well show fertilizer activity. I called the people living there and they confirmed that it was a permanent naturalized alfalfa pasture going back along time, ending around 1990. This would prove naturally occurring nitrates, especially because of the Nitrate Fixing Bacteria present in the roots of alfalfa and other legume crops. In other words, farmers plant these types of plants to add massive amounts of nitrates to the soil for future crops. This would show up as organic soil nitrates and even though their isotope testing proved this (+3 to +6), UCR still concluded it was from septics.

The Riverside report shows the pattern of high nitrates on the top soil gradually decreasing at ten feet, then increasing again the next 5 to 10 feet, where it stops and collects at the basement rock. Three drill sites at this property proves this.

They had three core samples drilled close to each other on the property, one near septic lines, one away from septic lines and the third across the yard from septic lines (1-0, 1-1, 1-2). What is surprising from the results is that they had two distinctly different kinds of isotope levels in the same yard. One fell into the +3 to +5 range which could be from fertilizer and soil, or rock and soil. The other was +4 to +6 which would be more towards organic soil nitrates with some small quantities from fertilizer or rock. As the drilling gets deeper, it tends to go toward the lighter isotopes, heading toward less human influence. It is still an unknown, unproved source according to the isotope chart (Fig. 5-10 p. 5-14), because the three categories overlap so closely. What is missing from their conclusion is that none of the heavier isotope trends (animal and septic) are present, which would be anything from +8 to +30. They still conclude it's from septics only.

What is also completely missing, and this is very important, is the fact that the theory of downtown business contamination was not questioned by one important member of the Riverside TAC. Jack Petralia is in charge of Public Wells. A Public Well is defined as a well used by more than 25 people in a 90 day period, or a restaurant.

Since these wells are monitored by law, four times a year, special attention is paid to the results. After visiting with Cathy Goldsberry at the Valencia County Health Office, she stated that out of the dozen or so public wells in Agua Dulce none went over the 45 mg/L mark. All were safe and legal.

These are five of the largest public wells in the area, going from the north at Darling Road to Vasquez Park in the south. They are all low testing wells and the County knows this! Also, the two wells tested directly north from DS1 tested at 24 and 19 ppm, only. How the TAC could conclude that there is a health problem with nitrate contamination seems to point out only one thing: Mr. Petralia has stated publicly to us that he strongly feels that the only solution for Agua Dulce and all other communities is a public sewer system.

In a 1989 Santa Clarita Infrastructure Report, the LA County Health Department said that even though the area could operate on septics at maximum build out, they still want regional sewer systems.

For years we have pointed out to his office the problems we have been having with people dumping sewage directly into the groundwater and illegal trailers with no septic hook-ups. His reply was that he had never heard about our previous complaints and that this was the first time he knew about a certain problem that we brought to his attention four years ago. This was not true because we have on file copies of all the correspondence sent. He also said that monitoring and mitigation will not work in Agua Dulce because he has neither the money nor the manpower to enforce even existing laws. I am sorry, but this excuse is not good enough! This is why we are contacting the State Representatives to have the County enforce the laws that they already have on their books. They had no problem spending one quarter of a million dollars on the Riverside study, and that report did nothing to solve the real problems of Agua Dulce nitrates!

I refuse to shell out $100,000.00 of my money because the government is lazy! They will require every homeowner to spend about that much for sewers and water.

The only fair solution is to rigorously monitor wells. Fifty or sixty wells is not enough. 200 would probably be a good start, and after one year of quality testing we could isolate the real problem areas and solve the source of the problems. I guarantee that after our town spends $100,000,000.00 on this unnecessary sewage treatment plant, the pig farms will still be polluting the groundwater at the rate of 2,138 ppm two feet deep, going all the way to the basement of 38 feet at 1,197 ppm (B 2-8 site 4). This occurs in a 10 acre area!

We have located the plume areas downstream at all of the hazardous animal waste sites on our map. Even the Riverside report shows that the hot spots are similar to the Ch1M-Hill report eight years earlier, even though they bent over backwards to ignore the pig farm site and no testing was done anywhere in the blueline stream. We, however, see no plume patterns anywhere in the UCR report (Exhibit B) because they did not test in the CH2M-Hill plume areas. They still refer to the plumes even though none are shown on their maps.

This next information is crucial! Looking at 4-34-2, the quotation is: "Inorganic NO3 N from Vasquez source rocks could conceivably be leached directly into percolating groundwaters." On the next page, 4-35, is table 4-Y with the soil and rock sample taken of "Tertiary Vasquez Formation (Red Sandstone)". It has the nitrate measurement of 797 ppm! "Nitrate-Nitrogen concentrations in sedimentary rocks ranged from 0.8 mg/kg (3.6 ppm) to 177 mg/kg (797 ppm), with the high concentrations found in the more iron rich, red samples." (4-27).

Maybe the Riverside group did not want to include this fact in a chapter called "Sources of Naturally Occurring Nitrates" because they feared that the government would want to bulldoze down Vasquez Rocks!

Or maybe you could conclude that the Riverside group did not know how to test for naturally occurring nitrates.

After all, it is a difficult subject to pinpoint. It seems that even the isotope testing that they did could not really differentiate between the different types of nitrates. They even conclude that 50% of the nitrates found in their testing were unidentifiable. They did not even speculate that these could be naturally occurring nitrates from the volcanic basin.

They just could not commit to the possibility.

Lanny Lund is one of the authors of a 1980 paper (Exhibit C) entitled "Geologic Nitrogen: A Potential Geo-chemical Hazard In The San Joaquin Valley, CA. This paper discusses that in the middle of farm country (where agribusiness basically dumps all the chemical fertilizer it wants) the authors, including Lund, try to prove that the nitrate source is from native rocks and soils only, to the tune of 2000 ppm, none from fertilizer. They go into great detail in their geology and stratigraphy theory showing ten layers of earth, during six prehistoric time sections, to absolutely prove what is going on down there. They dug deep enough to find a T. Rex there, but could not find the extinct volcanoes in Agua Dulce. They also do a complete geological breakdown on nine types of soils that occur in that area. They even give the pathways in which ammonium components breakdown into nitrates from the different types of rocks. If you had asked them, they would say that the same ammonium compounds probably do not break down the same way here, but they do. This is one of the sources of the of nitrates in Agua Dulce's ground water!

I would bet that if we were an agri-business town and could pay the big bucks, we too might get a different kind of report!

I will tell you this, they did not use any of these theories or types of chemical tests in our report! Maybe Professor Lund forgot how to, thirteen years later.

Enclosed is the geologic map of the entire area showing the true locations of the nitrate bearing volcanic rock. This map, prepared by our Engineering Geologist Allan E. Seward, was taken from the 1958 study by Muehlberger, (Exhibit D). and the 1961 and 1996 Dibblee Studies (Exhibit E). The Riverside map is not even close to being similar, even though they claim that they used the same study on page 2-32. They completely redrew it! (Exhibit F).

The correct map shows that the entire area 1 mile south of Sierra Highway down to Soledad Canyon Road contains volcanic high nitrate rock. They modified their map to show only a sliver of an area containing Vasquez Volcanics occurring only at Vasquez Rocks. Even this sliver area does not contribute to their conclusions that Volcanic Nitrates (797 ppm) do not contribute to site 1 contamination.

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2. Land Ho!

"Samples from the 'abandoned pig farm' site 4 show universally heavy isotopic compositions as well as high nitrate concentrations, perhaps indicating a significant continued presence of manure derived nitrates in the soil column". (4-36-1). (Ya Think?)

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3. Chlorides

The fifth chapter illustrates a beautiful point source of contaminated data!

This gives clear cut proof that the testing data is fixed to give a different conclusion than one would reach, based on early claims to back up the argument. This is the "Riverside New-Speak" that I will now explain.

We will first start with a scientific position, one that would work backwards and forwards. For example: Septic systems contain human waste materials that have high levels of chlorides. If you find high levels of chlorides in the well tests, you can conclude that it might be caused by humans (or, of course, animals or rocks in different examples).

That should work out just fine, but it does not. In chapter 5-9-5 (Part 3) it states, (1) "A cluster of moderately high to high nitrate groundwater wells producing from... the Agua Dulce Town Center. In this region, enrichment in nitrates appear roughly correlated with enrichment in chloride, a feature expected from contamination by waste materials such as manure and sewage."

So far, so good. (2) Go back one paragraph to 5-9-4 (Part 2), " A cluster of high nitrate wells in the region of the fire station. These waters are otherwise very low in dissolved constituents, indicating that the NO 3-N rich contaminant source is low in other soluble constituents, including both chloride and sulfate." No, that does not indicate that the contaminant source is low in chlorides, it indicates that the nitrate source is not from septics, which is what they should be concluding, but they purposely do not. (3) They then cover their butts with a disclaimer: 5-1-1 which states, "The fire station wells produce waters having very low concentrations of both chloride and sulfate and high NO 3-N. It is quite possible that other regionally distinctive chemical sub-groups could be isolated and mixing/flow patterns detailed." They, of course do not look for anything else. This now raises many doubts as to their ability to research and process data.

So if you read it in my order you get: 1) chlorides in wells means human contamination, but 2) we have wells with high nitrates but no chlorides, meaning we are not sure of the nitrate source, so 3) it's very possible that these nitrates are from completely other sources. It makes sense.

Now let's read it the way they wrote it. 1) There are other chemicals that occur in this area bringing in high nitrates. 2) We conclude that there are high nitrates with low chlorides in this area. 3) Since another area has high nitrates and high chlorides, we conclude that all the areas of contamination must be from manure and sewage. Now you see it, now you don't! Then on page 5-11 they conclude that during heavy rains, nitrates and chlorides went up in some wells, proving their point. They do not give an explanation for the rest of the wells which did not go up.

They now conclude that they can prove that the downtown area is polluted from human sewage with the simple test for chlorides. Even though they gave up on proving why chlorides are not present at the fire station area, they are still "Gung-Ho" on the business center area. They are lying.

Our survey says - fire station wells test for chlorides at : 6-K at 40.3 ppm, 3-E at 28.3 ppm, 2-X at 31.1 ppm, 4-O at 30.2 ppm, 3-C at 29.4 ppm, 5-S at 27.3 ppm, and 5-T at 18.8 ppm.

Our business district wells test at: 5-C at 72.9 ppm, 6-F at 45.5 ppm, 6-S at 30.5 ppm, 3-H at 61.3 ppm, 4-G at 45.4 ppm, 3-J at 40.8 ppm, and 3-I at 52.5 ppm. Why would they say that they are high at DS-1, but low at the fire station. The levels are very similar.

At 4-Y the first test was 59.8 ppm, then it spiked in 9/93 to 124.4 ppm, showing the same peculiar spike in September that was present in the nitrate test. It's the same well that was unique in going up in nitrates in September rather than down. Of course, calcium, sulfur, magnesium, sodium, TDS, and EC went up too. The chloride tests at the business area do not show a complete difference in style and make-up from the fire station, only the two wells 5-C at 126.3 ppm and 4-Y at 124.4 ppm went up a lot ( + 85 ppm and +60 ppm). The wells directly north and up stream from them did not jump radically. 6-S not tested in 9/93, 3-H went up 20 ppm, 4-G not tested, 3-J went down 7 ppm, and 3-I went up 14 ppm. This does not prove the source is from the business center, it only proves a point source area that should be tested and examined further.

If you want to see a "Distinctive Chloride Difference", look at wells 1-B at 159.6 ppm (outside the basin, but included in the averages!), 1-H at 120.3 ppm, 1-K at 113.2 ppm, 1-P at 102.8 ppm, 1-Q at 103.5 ppm, 1-T at 292.8 ppm, 1-Z at 133.9 ppm and 132.5 ppm, 2-A at 133.6 ppm, 2-F at 147.4 ppm, 2-N at 150.6 ppm, and of course, the grand champion, 3-B at 450.2 ppm on Davenport Rd. There are others: 3-M at 150.4 ppm, 4-C at 212.9 ppm, 6-O at 279.6 ppm (not on map), 7-A at 135.6 ppm (small pig farm), 7-I at 169.9 ppm (not on map), 9-A at 155.6 ppm (not on map), and 9-B at 154.9 ppm (not on map).

Here are some other funny wells. These well tests are for chlorides: 1-H at 120.3 ppm, 5-A at 85.4 ppm, 5-Z at 71.0 ppm, 6-B at 21.8 ppm, 6-J at 105.9 ppm, 1-U at 31.7 ppm, 5-W at 42.7 ppm, 3-U at 52.8 ppm, and 4-X at 75.0 ppm. The odd part is that they are much higher than the business center wells. These are to the east, one block from Agua Dulce Canyon Road. What makes this really important is that they all are in the blueline stream, down stream from the airport and the pig farm. This is the same plume shown in the second part of my report on the nitrate plume from the 1988 CH2M-Hill map.

Wells 2-T at 17.2 ppm, 2-Z at 17.6 ppm, 6-V at 52.6 ppm, 3-Z at 36.4 ppm, are directly east, one block from the last tests in the previous paragraph and they are much lower. These are not in the blueline stream. The high levels of chlorides around DS-1 are from the pig farm and not the business center.

While you are looking at the map sites around 4-Y, you can now see that compared with the 1988 CH2M-Hill report the entire stream is missing! No one tested there. What they would like you to believe is that they asked to test at the airport property, were refused, and gave up looking. What is missing is the entire street called Tyndall Road going south from the airport runway, an area with probably 20 homes. No one asked to test wells there. That might prove the downstream plume from the pig farm. That's why I believe that they ignored this area, because of the previous knowledge of the data from CH2M-Hill!

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4. Sodium

This chapter will prove that two more components tested by Riverside were misused in their conclusions. We will start with sodium. Remember, their claim about chloride contamination as proof of animal and human contributions is only half true. They left out the other important half of the chloride compound in humans and animals. The only way chlorides will get into the groundwater is through salt (sodium chloride) Cl 60.7, Na 39.3. The ratio is 60/40 which means if you have 60 ppm chloride, you will have to have 40 ppm sodium.

If you look at the wells tested at DS-1 (well 4-Y), the chloride levels average out to 79.5 ppm and the sodium levels are at 49 ppm. This is almost 60/40. This is to be expected because this well is 20 feet away from a cow pen and this was discussed as having a high nitrate source from animals. So far, so good.

Let's look at some odd wells. 1-I in 8/92, the nitrate level was 2.5 ppm. The chloride level was 17.2 ppm, but the sodium level was 89.5 ppm. This is not 60/40, but it shows a different sodium source. They gave no explanation. This well is one of the over 90 ppm nitrate wells, so I used this as an example.

In March, after the big rain, the nitrates jumped up to 151.1 ppm. The chloride went to 59.7 ppm, but the sodium went down to 45.7 ppm. Now the ratio between chlorides and sodium is 60/40.

Six months later, the nitrates went down to 52.9 ppm, the chlorides went down to 27.5 ppm, and the sodium went up to 47.6 ppm. The sodium source is independent of chlorides, so this is not sodium from septic sources.

Another odd well is 1-T which is south of Escondido on Agua Dulce Highway. It had, in March, 18.9 ppm nitrates, 292.8 ppm chlorides and 57.4 ppm sodium. No, I do not think they drained a swimming pool. They also had a high sulfur level of 113.7 ppm.

Well 1-U, in 9/93, had 17.7 ppm nitrates, 31.7 ppm chlorides and 144.6 ppm sodium. This was not from septics.

Well 1-Y had 2.4 ppm nitrates on 8/92, 30.5 ppm chlorides and a whopping 323.1 ppm sodium.

As usual, the Riverside gang did not do any chemistry studies on sources of other elements, they did not even do sources of nitrates.

Now, here are some high chloride, low sodium wells. 3-B tested 9/93 had 84.5 ppm nitrates, 450.2 ppm chlorides, and 102.6 ppm sodium. That's not 60/40. The fire station well was tested 20 times, and I hope that was taken out of the averages. They had, on average, 64.9 ppm nitrates, 29.4 ppm chlorides and 30.5 ppm sodium. Also, there was one more well, 6-O, in 3/93, with less than 0.5 ppm nitrates, 279.6 ppm chlorides and 86 ppm sodium.

The report discussed the fact that certain areas had high nitrates and low chlorides. What they did not conclude is that if septics are truly the source of nitrate contamination, then all wells would have sodium chloride at minimum levels everywhere, and they would be close to the 60/40 ratio. Otherwise, chlorides are not strictly an indicator of septic contamination.

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5. Surfactant

(The Government Denies Knowledge)

This is the real cloak and dagger chapter. It seems that every time I talk on the phone to anyone in the detergent industry, I get the exact same explanation. I do not mean the same answer to the same question. It means that I got the same answer to every question. What is even more weird is that I get the exact same answer from other companies.

The phone call will start out like this. First, I will describe my situation. This is a town with septic systems, not a city with a waste treatment plant. I ask them how long it takes for surfactants to break down in a septic system. You have to remember that in a treatment plant they add chemicals like ferric chloride (which strips the copper from electronic circuit boards, it's that strong!) and others to break down sewage. In septics you just have bacteria to do the job.

All of the written data from all of the books I could get my hands on describe how surfactants break down after two days in a sewage treatment plant. Of course, everything else does, too. What is not described is the life span of these chemicals in a septic system.

After talking to the experts, they seem to believe that it takes longer here to break down, therefore that's why they can test for them. That's also why their tests do find them. It basically proves septic contamination of the groundwater. Usually it's in a situation where the leach field is too close to the well or the water table has risen too high. That's why they test with the MBAS test. It's very accurate and it is a good indicator of human contamination.

What I get on the phone, in discussions with these experts, is that it would take probably 30 days or longer in septic systems for surfactants to completely break down, if the product has anionic or nonionic surfactants.

If they contain cationic surfactants, they are harder to break down. Also, on the long chain branching types, the comment made to me was that these kinds do not break down at all! Of course, then they say that they stopped manufacturing them 15 years ago.

Would my 20 year old septic system produce 15 year old soap that would have contaminated the ground water with measurable levels of the old type of surfactants that could still be traceable today?

I do know that if I dumped ammonium persulfate over at the Space Ordinance Systems plant in town, that that's still measurable today, after closing down 12 years ago! As no ground water was tested, this area must be tested in the future. There should be ammonium there!

What now proves my point on the subject of surfactants is that the textbooks state that the three types of surfactants presently used can be made with the following derivatives: phosphates, potassium salts, or in the case of cationic types, quaternary ammonia.

I am going to say this one more time: None were found in any wells tested in Agua Dulce! Now did I finally make my point, or do you want me to write another 30 pages for you to sit through?

It's very clear that UCR is not being straight with the state of California, or with our town.

I tried very hard to get something in writing to show an honest timetable of surfactant bio-degradation in septics. After talking on the phone and getting mysterious comments, I ask these experts to send a letter stating these time estimations of 30 days. They agreed, but then they sent a different type of letter.

They all start with: "After talking to the manufacturer, they state that every one of their products are completely biodegradable and pose no problem to the environment". Also, "our suppliers have extensive experience with these chemicals and groundwater contamination has never been found in any area, soil type, or use pattern". (This is a recording!)

We all know that this is a lie and they should all have their mouths washed out with soap! As stated in my report (#2) dated 6/13/96, I discussed that even after going through the water treatment plant, the AVEK delivered water from up north had detectable levels of surfactants (Exhibit G). That means that: 1- They do not break down in water. 2- There had to be an awful lot of them to be that measurable, especially after that much dilution!, 3- The detergent industry will not disclose the facts on these products. I called the LA Department of Water and Power and asked them where the possible contamination of delivered water from the Aqueduct could come from. They said that they did not know.

Maybe the California Regional Water Quality Control Board should worry about this real situation of groundwater pollution! I volunteer to assist in reading the next report that they have UCR write, and I guarantee it will be a doozie! I saw some graffiti on the wall at the Canyon Market the other day. It said "Why is the water so bitch'in in Agua Dulce? -- Its 'cause we don't Surf Acton!". Those crazy teenagers, I guess they read my paper too!

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6. CalMat

I've enclosed the Cal Mat strip mining application (pg. 9) (Exhibit H) showing their geology description, and they have pointed out the names of the two types of rock formations that they will be mining. They will take out, in a 30 year period, 184 million tons of gravel, leaving 73.5 million tons of Fines. This was discussed in my first paper on 5/8/96.

The first type is the "Vasquez Formation", which of course, Riverside documented. They described the "Red Sandstone" rocks containing approximately 800 ppm nitrates.

The "Mint Canyon" area is known to contain the same nitrate bearing rocks. The fines will be compacted and watered down. This will pollute the entire Santa Clara River with toxic levels of nitrates. This mess will effect over 100,000 water drinkers, all the way to Ventura.

On 7-2 under the sub heading sources of contamination it states "Red iron oxide cemented sandstone and conglomerates of the Vasquez and Tick Canyon formations have been shown to contain significant, even large quantities of nitrates. This nitrate appears to be easily leached and could serve as a natural inorganic nitrate source."

If I have to, I will send each of them a copy of this report!

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7. My all time favorite quote

Chapter 4-34-2: "The data from nitrate and ammonia analysis in rock and soil cores indicates an isotopic range similar to that observed in the groundwater samples (From -3 to +15 0/00) and [sic-Ed.] spanning the ranges of 'inorganic', 'soil', and 'septic manure' sources " (See figure 5-10).

As accurate as their isotope testing is supposed to be, it still cannot tell the difference between nitrate from rocks and nitrate from humans and pigs! It's all over the chart (Exhibit I) from the very top to the very bottom. It covers every category!

Yet, they conclude everywhere that Agua Dulce's nitrate problem is caused by septics only, not the pig farms and not by approximately 26 square miles of above ground and even more underground uncharted (Allen Seward, P.2-3) volcanic nitrate rock!

Like I've said all along, even at my very first water committee meeting, "Excellent data, totally bogus conclusions, Dude!"

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8. Isotopes

This chapter is really about drill sites. In the isotope chapter (5) the discussion turns to soil core drilling. This raises the following questions:

"(5-15-3) Septic system wastes (+6 to + 15%), on the other hand, are not exposed and thus not affected as greatly by ammonia volatilization." This means they do not evaporate. Why does UCR's transport theory say that ammonia gas will travel more than 4 feet up through solid, dry soil, but 25" of heavy rain, will not go through the same 4 feet. This is not scientific fact at all! Their transport modeling theory is made up!

There was no ammonia in wells, again. This whole report is based on septic contamination of groundwater. No evidence was found!

In chart 5-10, page 5-14 and 5-15, septic isotopic levels are from +2 to +25 on average, with a weird spike from -8 to +30. This spans the entire chart.

What is also wrong with the isotope testing, besides what was previously stated about the unreliability of the tests (described best "as a statistical probability"), is the fact that on 5-23, figure 5-16, the pig farm's drill site #4 measurements only go between +7 to +15. This range could also be from soil nitrates as shown again in chart 5-10, page 5-14.

They even explain the possibility on 5-27-3 that it is partially from "soil nitrates". Now they finally discuss other naturally occurring nitrate sources. Too bad it's still a pig farm, 38 feet deep.

Looking at figure 5-15, page 5-22, (Exhibit J) on the four small drill sites, the most nitrates occur in the +4 to +6 range, at around the level of 350 ppm to 425 ppm. These two areas are drill site #1 and #3.

I drove over to these two sites (their location is only shown in the appendix). Drill site #1 is located two houses north of the meadow at Vasquez Rocks Park.

They conclude on 5-26-2 that out of the 3 drill tests done at this property, the one marked 1.0 is higher in nitrates because of it's close proximity to the leach lines. They of course do not explain why the nitrate level is 1845 ppm only in the first foot of soil (which means it is not from septics, as leach lines are at least four feet deep). Then it gradually reduces at 10 feet and picks up again to 200 ppm at the basement of 17 feet. What is shown in chart 5-16, page 5-23, is that the isotopic range is only +3 to +6 which would only be from soil nitrate sources. They claim it is from the septic leach lines, even though the isotopic levels never went over +6. Septic levels start at +7 and go to +30. This is obviously not from human contamination.

I spoke to the owner on 7/24/96, who said that after the first drilling the Riverside group remarked that they did not find the levels that they needed, so they had to drill again. They made a total of five drill sites on the property. One particular drill site was on the north side of the property just ten feet south of his well. He asked them to drill there because of the problem he was having with increased nitrates in this well. They usually tested around 21 ppm, but since his immediate neighbor to the north put in a pen approximately 100' X 100', with 20 cows, twenty feet from his well, his nitrate levels mysteriously increased from 33 ppm to over 45 ppm, and then to around 90 ppm within a year and a half.

He was concerned with the nitrate level of his well, as is everybody else up here. The Riverside testers were well aware of the cows standing there, but they vanished completely out of the report again. (This is getting a little old by now? Did they really think we were a bunch of dumb hicks who would not notice any of this garbage going on? Well, I did, Pilgrim! So did a lot of other folks up here.)

Now let's see what the TAC concluded. On page 4-16-4, they just plain lied, there is no other way to put it. "The NO 3-N concentrations at depths greater than 5 feet were highest near the septic line (Hole # 1.0), and were very low at # 1.2, which was across the yard from the septic line."

When I look at the chart (B-2-1), I see site #1.0 to be at 1845 ppm in the first foot, 37 ppm at two feet, 108 ppm at four feet, 95 ppm at five feet. This is not caused by septic contamination. The nitrate concentrations were not the highest directly under the septic lines at four feet. They were highest above the leach lines.

They were lowest under the leach lines at 4' to 10' at ranges from 59 ppm to 108 ppm. After 10' they increase from 86 ppm to 284 ppm at the 10'-12' range, then decrease at 13' to 17' feet from 261 ppm to 198 ppm.

Now let's take the fact that this house is now the perfect area in the entire town for the alluvium because of it's "relatively high permeability and porosity". In areas where great thickness of these units are present, rain and run-off can be expected to naturally recharge the groundwater table, and provide a relatively efficient storage and a "productive aquifer (2-7-4)".

So, what this means is that the nitrates are lowered under the leach lines because septics are not contributing to the higher nitrogen levels. This proves the exact opposite of Riverside's transport mechanism theory in the modeling chapters.

Since this is the most porous site (this house), and they chose to drill in a lawn area, anyone could conclude that the top foot at 1845 ppm would be constantly watered down through the soft soil to the 4 foot level where the nitrates would then increase because of the septic contribution and continue to transport down where the levels would eventually decrease towards the bottom at 17 feet.

It did not happen that way! All of the wacky theories that Riverside threw at us basically said that since we could not disprove their claims, that we would have to accept them because they were the experts.

Well, they were expert liars, that's all! This is not science. What this now proves is that even in completely porous soil (let alone compacted soils), nitrates are truly trapped by the natural filtration of soil. What is left out of this equation is that this house is across the street from the high nitrate Vasquez Rocks, contributing to the naturally high levels of nitrates. That is the true source! At 17 feet the drilling stopped at the house because they struck water.

Now let's look at the well tests there. Well 4-Y was at 33.7 ppm on 6/18/92, at 40.6 ppm on 8/31/92, at 51.2 ppm at 3/31/93, and finally at 90.7 ppm on 9/23/93. Now you tell me that when they soil drilled at 17 feet the nitrate levels were 198 ppm, but in their well the highest level it got to was 90.7 ppm. Please do not forget the fact that the home owner stated that the 50 year rain created a small lake of manure water in his yard at his well head. Not only did it smell bad, it contaminated his well! It jumped up to 90 ppm the next time they tested in September, after a very dry spring and summer.

He said for years his well tested in the 20's (ppm), before his neighbor penned a herd of cows up stream and never cleaned it up. It is now in the 90's. That is why we recommend manure clean up. It is a real nitrate source, and I still think it is cheaper to haul it away rather than pay for a sewer system. Just think, they might have you pay for a sewer system and still make you haul away the manure someday, just because you waited too long or you would not volunteer. I have included the letter from AV Rubbish stating a new discount for horse manure (Exhibit K) al. The deal was cut in March 1996 and with the discount I got for our town everyone should be thrilled to participate.

So now we are back to two of my mitigation recommendations: 1- Manure removal, and 2- Well testing quarterly for nitrates, with one test per year for human contribution chemicals. I have made a list of what we should test for: nitrates, arsenic, fluorides, boron, sodium, chlorides, and of course MBAS for surfactants (Exhibit L).

This is a fair and scientific group of tests that will really prove if individual wells have septic contamination. Nothing fancy, no bull, no isotopes, no "opinions" (For Sale!), just something we all can really agree on.

If, in the future, we start to get well readings that point out human factors (unless they are spiked wells), I will be the first to give my support for water and sewers. But, I am quite sure that my theories of nitrate contamination are the correct scientific interpretation of the data gathered by Riverside. I will bet the house on it! Let's see you Riverside folks do the same! What? No takers? I thought so!

Drill site #2 is the fire station. What is surprising is that the isotope tests there are between -1 and +2. The Riverside report finally states that the source is "Rock" nitrate (5-26-3). The Volcanic Basin starts only one mile south of the fire station, according to the William Muehlberger map, which now proves Alan Seward's contention that the underground volcanic basin extends even further than the above ground maps show.

I would conclude from actually looking at these hills that north of Sierra Highway the mountains are more the Granite Pelona Schist type. South at the fire station, the small hills are definitely volcanic types draining where the two types meet, into the low canyon in the fire station area. Of course, we also have an earthquake fault there and I hope no one falls in.

The Riverside report concludes (5-26-3) that the source is not from the volcanics, but they conclude that the nitrate levels reduce as the drilling gets deeper (proving nothing). I do not believe that 17 feet deep at the basement, 482 ppm is reduced and this fact should not be overlooked! Especially since the fire station is again upstream from the airport, in the blueline stream.

Drill site # 3 is near Anthony Road (5-26-5). First, I will go over their explanation of what occurred there. They discuss isotopic values in the shallow portion of the soil in the "soil organic range", similar to the "lawnsite" (at drill site # 1). They call it a very heavy animal source, because they chose a down stream site from the neighboring hillside, which they claim, was an "animal containment pen". Then they say (5-27-2) that "animal wastes do not appear to provide a large contribution to the nitrates deeper in the soil". "The nitrogen rich, shallow material appears to be utilized for growth of the overlying lawn grasses". (How about neither of the above?)

Not even close! First, the isotopic ranges are +3 to +5, which would be soil sources, not animal. Real levels start at +7 and go all the way up to +30. I drove there and I did not see any evidence of a lawn, so the theory of "shallow buildups for the purpose of growing a lawn" is not true. I will tell you why. First, there are probably only 20 yards with decent lawns in the whole town. We live in the desert! Why aren't they testing in my yard which consists only of foxtails, sage brush, mustard, and other assorted native plants (weeds). Also, if they love testing lawns, why didn't any of the isotope tests find ranges in the fertilizer level (-8 to +7)? That being said, look at the core drilling sample at site 3.0.

This is the most important fact in the entire Riverside report and they left it out of their conclusions! The nitrate level in the first foot is the highest ever recorded in this town at 8,415 ppm nitrates! In the second foot it is 1107 ppm, at the lowest level of 14 feet it is 45 ppm. What is going on in the first foot? They buried the 8,415 ppm (1870 as n) number on page B2-7 in the appendix. Then they came to the conclusion that somebody must be feeding a lawn. (There is not one there, look at the picture in the appendix). I do not think I could get 8000 parts per million if I was standing behind a cow with a measuring cup! Why didn't this ring all the alarm bells? I will tell you why, it would serve to disprove their conclusion that "Septics are the main cause of nitrate contamination, therefore mandating a sewer system."

It in fact proves that it's from an unknown source. The isotope test did not show it to be animal, fertilizer, rock or sewage. It only showed it to be from organic plant material breaking down into the soil. According to all my organic soil books, you would be lucky to get 75 ppm nitrates from composting plants. Where is 8,415 ppm coming from? There seems to be no natural process to create these levels. This level of nitrates has to be man made and dumped here. It cannot be from animals as they claimed.

At this level the nitrates would be toxic to anyone! Why did UCR ignore this clear and present danger? The HazMat teams should have been called and this area yellow taped! Instead they buried their findings in the appendix and tried to claim the high level of nitrates' source was decaying plants. Does anyone want to check this out? I should think that if they are so concerned with health and nitrate contamination, the houses south of this site should have been notified immediately and tested! At 8,415 ppm, people could die from drinking the water! Do they care? (NO!)

I hope this gets our town on the ball to test wells. We need over 200 wells tested four times a year! This really is a serious matter, not only to stop insane development, but also for health reasons.

At the end of chapter 5, they come to some new conclusions (5-28-2). Since chloride is found in some of these soil and well tests, they conclude it's from human septics and animals. Forget about the naturally occurring chloride from rocks and soils, it can only be from humans and animals. Forget about the entire chapter of isotope tests! It's from humans and animals. I am going to go sit in a corner and contemplate my navel and you will hear me repeating over and over again, it's from septics and animals..., that's basically what they did. Why there it is, the last page of chapter 5-30, the last sentence states, "Mixtures of contaminants from both manure and septic system sources will produce calculated contribution percentages intermediate between those shown". (Even though they are both in the same areas on the scale!) Sort of a Yin and Yang of poop.

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9. Love Letter from Lanny

Two new pages from our experts in Riverside! We received a letter from Lanny Lund on 4/17/96. He came to a brand new conclusion. Like I said to the professors on 5/8/96, at the town meeting, "Listen up boys, this ain't funny!" Well, here they go again. After being attacked with those damn isotope tests for all these months, we get a new disclaimer. Remember they kept saying that the isotopes prove the type of nitrates, and we civilians could not understand the algebra of modeling and the scientific "fingerprints" of isotope testing like they could. Well guess what! We did the math and the isotope chapter is just plain lies! I will tell you why. Ready? On page 2 of the letter, paragraph 1 states "Although chemistry and isotope data cannot directly differentiate between anthropogenic contributions from animal and human organic wastes, both of the preceding arguments indicate a higher likelihood of septic wastes impacting the groundwater".

What a crock! Or should I say crook? Everywhere in this report it sounds like the only reason they disclose these major contradictions is because they must have had a lot of experience in their field. I think it's because they have had a lot of experience in court! I showed a lawyer friend of mine parts of the Riverside report and he said it sounded like a bad used car dealer's contract. Way too many excuses. He said if their document went to court and this town really hired an expert who really knew how to decipher their paper, only their disclaimers would save them, not any of the scientific arguments.

By the way, the next town they decide to take this nonsense to, I think I will volunteer my services for free!

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10. Modeling (Just stand there and look cute, maybe they won't read our paper!)

This chapter was probably written by Cindy Crawford, Christie Brinkley, and Claudia Schiffer. That was my first impression when I read it. Strip away all the Greek and the algebra and it comes down to this: They claim that the only transport mechanism is septic output. They also state that rainwater will not reach groundwater levels. If this is truly the case, we should rename our town "Dry Gulch".

What they also want us to believe is that every other trace of chemical or human involvement disappears completely from every testing method, except nitrates! Chlorine is missing from 1/2 the well tests. They claim chlorine proves human and animal sources, though they do not explain why it disappeared in those areas.

Ammonium is missing from well tests. Phosphates and surfactants are also missing. Everything disappeared off the face of the earth from my septic tank, but those pesky nitrates, they just keep going and going and going, straight down into the groundwater.

The report says in twenty years all wells will be contaminated, and I say Bull Thistle! They have not proven anything supporting their position, they are not even close. This would mean that every well presently over twenty years old would have gone bad by now. Wrong!

Their theory states that the only areas of transport are under the leach lines from septic. Then they add their map (2-9, Fig. 2-2) (Exhibit M) showing alluvial areas in the basin and state that there are two types of alluvial ground in the basin. One is the "Older and Holocene Alluvium which has relatively high permeability and porosity (2-7-4)".

It continues to explain that "In areas where great thickness of these units are present, rain and runoff can be expected to naturally recharge the groundwater table, and provide a relatively efficient storage and productive aquifer".

The other type is the thin, dry alluvium where water does not penetrate down to the water table. They estimate that the basin consists of 400 acres in the center of town having the best storage capacity and the best transport ability because the alluvium is mostly made up of sand and gravel. The other parts of the basin, 10,600 acres, are made up of the 6,600 acres of "Nearly exposed hardrock basement and 4,000 acres of shallow or dry alluvial cover (2-10-3)".

Since this is a ratio of 26.5 to 1, it would be extremely easy to prove that after that 50 year rain the alluvial area in the downtown area would have spiked much higher than anywhere else and would have contained all of the human contamination elements immediately flushed into the groundwater.

It did not happen! If you refer to the well map (3-1, page 3-2), you would see that all of the wells over 90 mg/L in the Riverside report do not show anything resembling a plume, unless you compare it with the CH2M-Hill well chart. Then you discover that it is very similar, except the animal waste dumps have not been tested on the Riverside map, and with previous knowledge of CH2-M Hill one could leave out the evidence of the true contamination.

While we are on the subject of things left out, I found one important map left out of the final Riverside report that was previously in the draft report. This is chart 2-2 on page 2-5 of the draft showing, you guessed it, the drainage pattern of the Agua Dulce water shed, with the blueline stream (Exhibit N) going right through the pig farm dump and the airport property. (My dog ate it!)

After reading the entire draft, and comparing it with the final, it is very similar except the final report was fleshed out more to prove the contention of septic contamination only, while the first report basically said that there were many other factors contributing to the nitrate situation. They wrote the final report to ignore the unanswered questions in the draft, and came to the conclusion that only septics were the source of nitrates!

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11. Another Bad Area

The fourth area on the CH2M-Hill report is at the west end of Darling Road. We get 32.7 ppm, 35.2 ppm, 30.7 ppm, and 53.8 ppm. Also, the American Water Well Service (Exhibit O) shows one well tested in 1992 at 157 mg/L, a real hot spot! The North Country Trails section near there tested recently at 41 ppm. These wells feed approximately 50 homes. The CH2M-Hill report showed a plume near these wells, and lower wells north of those. This means it's a point source of contamination that should be looked into. We will ask the County to further examine that area. After Cal Mat is gone, we will all realize how special our little town is and how the real way to increase property values is to fight to keep our Community Standards District at 2.5 acres per home site.

Ten or so years from now we may be one of the few communities left in Southern California with large lots zoned for horses, etc. Now we will work to get a great high school built and we all will be sitting on a community that's a real gold mine!

So that sums it up! I win the bet. Here is the proof that the conclusions reached by UC Riverside were bogus. I am putting my name in for nomination to the Chamber of Commerce as "The Most Important Business In Agua Dulce". Without my Horticultural education and knowing my business of growing orchids, I could not have written this report and helped save our rural community! (Drop by and buy some!)

Please help us to truly solve these problems. Like Jack Petralia said to me personally, "You don't want to see any babies turn blue and die do you?".

No, I do not and I hope you will work as hard as I will to protect our groundwater and to keep that from ever happening.

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12. Water

The Sierra Pelona Water Basin holds approximately 5,000 acre feet of water, there are 345,000 gallons per acre foot. Multiplying that out comes to One Billion, Seven Hundred Twenty Five Million gallons of water (1,725,000,000) in the Sierra Pelona Basin. 5,000 acre feet is a conservative number, but this is what we will use for now.

In the basin there are approximately 1700 houses. The LA County Sanitation District states that the average house discharges 200 gallons a day. The Riverside report uses the number 300-350 gallons, according to a "Personal communication by W. Staats", who of course is not listed in the footnotes. This should be inserted just after R.F. Spaulding. They also left out Capt. Spalding, the African explorer, Hooray!

While the average home uses 1000 gallons a day, based on LA County District #37, only 200 gallons of it is discharged into the septic system. That would come close to the figure of 365,000 gallons a year or 1 acre foot per family. If there was no recharge, the 1700 acre foot usage per year would dry out the aquifer completely in 3 to 4 years!

This is based on the ridiculous Riverside notion that there is no transport mechanism other than septics. 800 gallons would disappear and not recharge the water table, ever. Assuming that there is an 80% loss, we still get a 20% return, so the town would not go dry in three years, but in four years.

Now let's take the Riverside figure of 300-350 and the town dries up in 6.5 years!

They also have an incorrect theory on transport modeling. On 6-4-3 they discuss that leach lines consist of two 3 foot X 100 foot strips located 4 feet apart, totaling an area of 600 square feet. This yields the typical loading of 350 gallons per day / 600 Sq. feet which equals .08 Ft./day or 713 cm/month over the leach field.

This is a vertical number only! The water does not go straight down. It also moves horizontally. That's why the mysterious "Modeling Algebra" is also not scientific. We will not totally pollute our wells in 20 years because water does not travel straight down. That's why the natural soil filters out septic output and they know it!

There has been a lot of discussion regarding Cal Mat's need for water for their proposed strip mine at Agua Dulce Canyon Road and Soledad Road. They need additional water and the only possible water sources are from a sewage treatment plant or an external source of water. Of course, they do not want to pay for it, they want our town to. That's why we feel the pressure from their representatives to make us get sewer and water systems.

Otherwise, we would show a completely united front against both the strip mine and sewers. Be aware who the players are on both sides. The community has been polled over the past ten years, and it is clear that they will not pay for this insanity. Riverside has been a contributor to the sewer issue and this UCR report shows the true bias and misinformation that they have been perpetrating with their unscientific conclusions that they have tried to sneak past the Water Quality Board. The taxpayers have been ripped off again. We have put a stop to this happening in the future.

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13. Animal Husbandry

Some people claim, to paraphrase Tom Leher, that they moved here to study animal husbandry, until they were caught at it.

You know why I moved here, to get back to the land and "Veg Out". For a real good time I'll kick back, do some reading in the shed with the crescent moon cutout in the door. I will open my "Encyclopedia of Organic Gardening" and look up the "Animal Excrement per 1000 lb. Live Weight" chart to see what is going on at the pig farm.

Did you know that between horses, cows, sheep, chickens, and pigs, 1000 lb. of pig will excrete the most per year. Chickens- 8500 lb, Sheep- 12,000 lb, Horses- 18,000 lb, Cows 27,000 lb, and Pigs- 30,000 lb. Wow! You do the math! If the farmer has 10 pigs there would be 300,000 lb per year, but if he had 100 pigs he would have 3,000,000 lb per year. Now, I do not want to hear from the so-called experts that there is hardly any manure at the pig farm site.

Lets see, if you have a 200 lb. pig on a train going 100 miles per hour and you have a 400 lb. pig on a plane landing at the Agua Dulce Airport and staying there over ten years, how "Pristine" can you get? Now class, I want you to answer the question in real math terms, not the existentialist New Riverside Math which would state that if you do not see any piggies, did they truly ever exist? Therefore, in an unfathomable universe, can the locals here really tell what kind of manure the professors are really shoveling? Good Question! You have 1 minute to figure it out.

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13. Beating a Dead Horse

This chapter raises only one question: "Where's the Beef?" I will hammer on one more item. This will now show how completely sloppy the UCR researchers have been. It has been scary even to write this report. I am not sure whether it's because UCR does not know much about what they are doing, or it's because they know exactly what they are doing! In other words, cooking the data - you tell me.

The item is potassium. They tested for it, and the most that they found was 5 ppm in the whole town. You would think that the lack of it would make them think twice about all their claims about fertilizer, but since they are not experts at fertilizer, I will clear it up for you.

If you go back to my 6-13-96 report entitled "Howard Carlip's Comments on the Riverside Report", you would read about "Fertilizers and Ammonium Sources", on page 7. The discussion concluded that if someone used 30-10-10 as directed, that there would be 1257 ppm of ammonium found.

Now, let's take that number and divide by three, because we used N-30, P-10, K-10. We would get 419 ppm potassium in the form of K20. To further reduce that number into elemental potassium, you simply multiply by 83% and you would get 348 ppm K.

What amazes me is that they did not find, in this entire town, any potassium over 5 ppm in the groundwater. You would certainly find high measurable levels of potassium, as well as phosphates, in the output from septic systems. See UCR chart B1-3 (Exhibit P). By now I have proven that the groundwater is not contaminated by septics in Agua Dulce.

It's very clear what has happened here. With regal authority UCR pronounced the condemnation of our town with phrases like "Fertilizer contamination" , and "Lawnsite fertilizer contributions".

They even had the nerve to stand in someone's yard, look over the fence and see too many animals in too small a space and write it up as "Downtown Business Center and the Densely Populated area of Town Contamination", instead of saying "There's cow flop in this guy's well".

They threw out, hid, or even lied about hard core data that went against their preconceived conclusion that "All contamination is from human sources".

This to me is criminal! They are dead wrong and they know it. They have got a lot of nerve pushing this garbage on our town

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Final Chapter

Going back to the geology discussion we find a large source of chlorides in the rocks and soils from sal ammoniac, which contains 66% chlorine. This was pointed out in the 1989 report by Allen Seward, but there was no chapter on rock and soil chemical analysis in the Riverside report.

Maybe it's because they were aware of the data documenting the explorations in the Agua Dulce area, around the turn of the century, to discover a new nitrate source when Chile stopped exporting.

It seems so unprofessional that there is no chemistry study! Also pointed out is the one Riverside rock and soil test on the "Vasquez Volcanics", showing 797 ppm nitrates buried in the appendix (B3-5), which only was given out to 2 people in the community. I finally got a copy at the beginning of May and the meeting with the State and Riverside TAC was on May 8.

My initial response was that "You must be kidding!" and so I wrote my speech parodying their presentation of their report which should have been titled "Disclaimers, Unanswered Questions, Doubts, Excuses, Contradictions, Hocus-Pocus-Dominocus, Covering-Our-Ass-From-Future-Liabilities, Oversights, Ignorance, Buried Truth, Outright Fudging, Nudge-Nudge-Wink-Wink, Say-No-More! All this was served up with a generous portion of Bull-Thistle!

Now that's not the cowboy way! We invited you folks into our homes after you promised us that you would do an honest paper and look what you gave us, Nitrate Nuggets! Then you send the bill to us taxpayers. We could have built that purdy museum with all of that darn tootin' wasted money. I know, we will call it the Vasquez Park-Riverside Gang Museum after the two biggest robberies in this town's history! You are lucky I moved here to become the Sheriff. I will not let this happen again! Our town's safe now, you town folk can now go back to beating each other up. Have a nice day Ma'am. I will be riding off into the sunset, drifting along with the tumbling tumbleweeds.

The conclusions that should have been reached are:

1. The pig farm dump, covering 10 acres to a depth of 38 feet, directly in the blueline stream, causes high levels of animal nitrate contamination of the main Agua Dulce water source.

2. Volcanic rock causes a significant level of natural nitrate contamination which is leached into all of the ground water.

3. These two sources of nitrate contamination are flushed into ground water during record rains, causing the abnormal spike reported in the UCR study.

4. Human septic sources are small and the chemicals integral with septic output were not detectable in any test in the URC report, even after record rains.

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The UCR report and its technical data fully proves these conclusions.

The modeling chapter, which was added after the UCR report was completed by the pro sewer TAC, has no relationship to any of the data in the report. Its modeling theories are unscientific and contrary to both the data and other published studies.

The final conclusion that humans are the primary source of nitrates in Agua Dulce is completely false and unsupported by any data in the UCR report.

I am Howard Carlip and I welcome your comments and I will meet anytime, anywhere, to debate with UCR and the State Water Quality Board about these issues.

Thank you. Howard Carlip

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