Cover letter from J. Polus, General Manager of Robson owned Lago del Oro Water Co. (click for larger view)

       Shortly after the citizen's flyer was distributed, Robson Communities, Inc. (RCI) requested that the Arizona Department of Environmental Quality (ADEQ) write a letter countering the information in the flyer. 

     ADEQ complied with the request and RCI distributed the ADEQ letter to every home in SaddleBrooke. 

       The cover letter to the SaddleBrooke residents, written by Jim Polus, General Manager of the RCI owned Lago del Oro water company, claims that the SaddleBrooke resident's flyer "was distributed in order to reverse a recent zoning change on the proposed Willow Springs development near Oracle." 

       Polus is apparently unaware of the fact that the referendum does not reverse the rezoning.  The referendum only allows citizens to act in place of the supervisors and decide the issue at the polls.

Letter written for RCI by ADEQ (click for larger view)

        In October of last year, ADEQ distributed an extremely misleading flyer to residents attending a meeting on water quality at SaddleBrooke. 

       Because of this, care must be taken when reading any material produced by ADEQ. 

       An analysis of the more interesting points in the ADEQ's most recent letter follows.

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       First of all, it is not a "clay cap," but a cap made of dirt and clay.  Instead of the pure clay cap in the original plan, the clay was mixed with dirt for cost reasons.  The mixture is 2 parts dirt and 1 part clay.

       According to a 1993 letter in the UA files, the ADEQ told the UA that, "ADEQ believes that the buried waste containers at the site will all ultimately collapse over time, regardless of the installation of a cap over the landfill." 

       ADEQ needs to explain the contradiction between their 1993 statement and their recent claim -- if the cap was insufficient in 1993, why did ADEQ approve it a few years later? 

       In April, Denise Ritche , executive assistant to Steve Robson of RCI, told me and others that she was present at a meeting between RCI and ADEQ held earlier that month  At the meeting RCI and ADEQ discussed the possibility of RCI adding a concrete cap over the existing cap at Page-Trowbridge.

       ADEQ is now saying the current dirt cap is safe -- why doesn't RCI believe them?

       Note the wording, "there is no evidence that chemicals from the landfill have leaked and have exceeded the Aquifer Quality Standards." 

       The finding of contaminants in groundwater beneath PTRL is evidence that PTRL has begun to leak into the aquifer -- it's just that so far, amount of the contaminants detected  have been below safe drinking water limit.

       In other words, ADEQ knows that contaminants have been detected in groundwater beneath PTRL, but instead of reporting that evidence, ADEQ carefully crafted the letter to make it appear as though PTRL isn't leaking. 

       According to Steve Holland, UA director of risk management, the detection of contaminants in groundwater beneath the landfill makes it reasonable to believe more contaminants will follow. 

       In November of last year tests confirmed, for the second time, that the federally regulated contaminant toluene was present in groundwater beneath PTRL. 

       In December, Holland told The Arizona Daily Star that because of the November finding, area residents have a "very reasonable concern" that higher levels of contamination would follow.

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       By saying "Groundwater and soils will continue to be monitored as required in the Post-Closure permit," ADEQ falsely implies that soil monitoring is an on-going process.

       As of this writing there have been two soil tests performed at Page-Trowbridge during its lifetime.  Both tests detected contaminants.

       In 1988 soil gas tests were performed.  The analysis reported "environmentally important compounds found at high concentrations throughout the study area." [click HERE for details]

       The second test was a test for radioactive material and was done in 1982/1983 by Joseph Salavetti for his masters thesis.  Salavetti detected the radioactive compound tritium in the soil.

       Note that ADEQ also says that monitoring will "serve as an early detection measure for future protection of the water supply." 

       Because ADEQ will not react unless contamination is found above the limit allowed for safe-drinking water, the question, "what will happen if and when contamination is found above the limit allowed for safe drinking water?" comes to mind.

       A situation in Tucson may provide insight to this question. 

       In 1990 ADEQ detected tetracloroethylene and tricloroethylene contamination in the aquifer beneath southeastern Tucson in amounts up to 2,200 times the safe drinking water limits. 

       No remedial steps were taken by ADEQ and by 1999, the contaminant plume had come within a mile of UA wells.

       In  July of 1999, the Arizona Daily Wildcat asked Holland what could be done about the contamination in the Tucson aquifer.  Holland answered by saying, "there's not a whole lot we can do to stop it. We're just monitoring it." 

       When the Wildcat asked how the UA would respond if the contamination reached the UA wells, Holland said that the UA would shut the wells down. 

       The UA has other sources of water to rely on. Oracle and SaddleBrooke do not.

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      By saying that the Closure Plan and the Post-Closure Permit (once it is implemented ) will "provide the necessary protection for the community now and in the future," ADEQ misleads readers to bleive they are guaranteeing the safety of the water supply in perpetuity.

       The Closure plan and Post-Closure Permit make no such guarantee.  These documents only authorize ADEQ to monitor the groundwater beneath the landfill and react when contamination levels exceed the federal limit for safe drinking water. 

        Keep in mind that ADEQ has thus far failed to act even when contamination levels have been measured in amounts up to 2,200 times the limit allowed for safe drinking water. 

       RCI asked ADEQ to help and ADEQ complied with the request by sending two ADEQ representatives to the meeting as well as distributing a flyer paid for by ADEQ.

      A scan of the flyer follows (click on either image for a larger view):
 

ADEQ flyer, page 1

ADEQ flyer, page 2

       The second page of the flyer is of particular interest.  Here we find ADEQ saying:

"The most recent sampling events for which ADEQ has received copies are the April 26, 2000 and May 17, 2000 ground water sampling events.  None of the results for the chemicals tested were above the detection limits used by the laboratory and none of the results for the chemicals tested were shown above the Aquifer Water Quality Standards [AWQS].

Detection Limits are set by the laboratory that tests the samples.  If  a contaminant is found below the detection limit, the lab does not report the amount detected.

       Now listen to this . . . 

"However, because the AWQS for methylene chloride is 5 ppb (ug/L) and the detection limit used by the lab was 10 ppb (ug/L), it cannot be determined from these results whether or not levels of methylene chloride between the AWQS and the detection limit were present."

1. The detection limit set by the laboratory for methylene chloride was 10 ppb, which is  twice the limit for safe drinking water as set by the Aquifer Water Quality Standards.
2. Because the laboratory does not report the amount of a contaminant in amounts less than the detection limit, and because the detection limit was twice the legal limit, methylene chloride could be present up to twice the limit for safe drinking water, yet have gone unreported.

Because the laboratory hired by the UA set the detection limit for methylene chloride at twice the federal limit allowed by federal law, and because the laboratory does not report the amount of a contaminant unless it exceeds the detection limit, ADEQ doesn't really know if methylene chloride is present in extremely harmful concentrations or not.

"However, because the AWQS for methylene chloride is 5 ppb  (ug/L) and the detection limit used by the lab was 10 ppb (ug/L), it cannot be determined from these results whether or not levels of methylene chloride between the AWQS and the detection limit were present."

       It was during the "April 26, 2000  ground water sampling event" mentioned in the ADEQ flyer, that the UA concealed a test confirming toluene, a federally regulated contaminant, was detected in groundwater samples taken from beneath the Page-Trowbridge radioactive/toxic waste dump.

       The evidence shows that the UA concealed a test result to allow them to falsely claim that this toluene finding could not be confirmed.

       ADEQ was presented with the evidence proving the UA concealed this test result on December 8, 2000.

       As of this writing, ADEQ has failed to act on this information.

       The laboratory that set the detection limit for methylene chloride at twice the legal limit is Turner Laboratories, Inc.

       Turner Labs threatened Cliff Russell, an Oracle resident, with legal action claiming that he used false pretenses to obtain test results showing that toluene had been confiremed in groundwater beneath Page-Trowbridge.  The test results contradicted the UA claim that the toluene finding was not confirmed.

Related stories and information:

• U of A Officials Cover Up Test Confirming Contaminants In Page-Trowbridge Aquifer 
• Oracle resident threatened with legal action over Page-Trowbridge water tests
• Oracle Resident Responds To Threat By Turner Laboratories
• Citizens Show ADEQ Evidence Of Cover-up; ADEQ Balks 
• Residents ask Attorney General to investigate cover-up 
• Letter To Arizona Attorney General Presenting Evidence of Cover-up & Requesting An Investigation