New Contaminant Found at Target Superfund Site

Target Cuts Deal with EPA to Proceed with Project on January 5, 2009

The Vanguard has learned that a group that monitors the Superfund site at the new Target location has discovered potentially a new source of contamination. This source was discovered at testing wells on the Target site.

According to the group, Frontier Fertilizer Superfund Oversight Group (FFSOG), EPA and Target have known that Trichloropropane (TCP) was detected in a sample taken just northeast of where the store would be. TCP is listed by the International Agency for Research on Cancer (part of the World Health Organization) as “probably carcinogenic to humans.” While TCP has been detected before at the Frontier Fertilizer site, this location is outside the current treatment area.

The level at which TCP was found was approximately 3000 times the level at which it would trigger action.

According to the group:

“The general movement of the groundwater is generally northeast from the detection site: toward existing homes. The EPA needs to determine whether this contamination is part of the current plume or a new source of contamination on the Target site. In order for that determination to be made, more sampling at different locations within the store footprint must be done, requiring a halt to construction until the testing is complete.”

Those who remember the Target campaign will recall of one of the concerns about the 2nd street location had to do with its proximity to the Target site. During the course of the campaign, controversy arose when the Yes on Measure K campaign purported that the EPA was in support of building a Target at this location.

According to FFSOG’s website:

From 1972 until 1983, Frontier Fertilizer personnel dumped residual pesticides from drums and tanker trucks onto the ground and into unlined pits on the property. These pesticides leaked into the groundwater and now form a contaminated plume lying between 30 and 130 feet below ground surface and reaching over 800 feet north of the original disposal basin. Soil on the site in the vicinity of the disposal basin is also highly contaminated.

The public became aware of the site in 1983 when a dog fell into a pit on the property and died from pesticide poisoning.

In 1994, the Federal Environmental Protection Agency (EPA) placed the Frontier Fertilizer site on the National Priorities List (NPL) and declared it a Federal Superfund Site. Since 1994, EPA has studied the site and repaired, upgraded and expanded an existing contaminant monitoring and removal system put in place by the State. EPA is currently in the process of developing and implementing a final remedy for treatment of the groundwater and soil contamination.

Target has to move several of EPA’s monitoring wells that are located under what will be the footprint for the store.

According to the President of FFSOG, Pam Nieberg:

“The wells that were to be replaced were important wells that were monitoring just beyond the eastern extent of the groundwater plume of contamination. They were there to tell us if the plume was still moving in that direction–not being adequately contained by the pump and treat system extraction system.”

There has been considerable discussion between members of FFSOG, the EPA, and Target as to whether Target needs to do more sampling to determine where the TCP is coming from.

Target is arguing that they need to stick to their schedule which has them pouring a slab for the store January 5. The TCP they believe is a fluke as it has not been detected in other samplings. They do not have the funding to do more sampling.

Other members of the group however argue that sampling is imperative and they do not buy that Target lacks funding for sampling.

According to Ms. Nieberg:

“One issue was that if it came from the source area and was part of the plume that EPA has been cleaning up, then it would be EPA’s job to investigate it and capture it in the P and T system. However, if it was not from the source area, it was a new contaminant site on Target’s property and Target would have to investigate it and clean it up. Also, if it was from the source area, which is southeast of the Target footprint, then that would indicate that there might be a plume or finger of contamination running under the Target footprint. “

The issue here was that if there was a plume of TCP under the footprint, because TCP is volatile, it could enter the building through the cement slab and pose a risk to workers in the store. Target proposed engineering controls. A layer of gravel covered by a membrane vapor barrier under the slab. Piping would run from the gravel layer up through the walls of the store and vent to the outside.

EPA management and attorneys met with Target representatives and reached an agreement to allow Target to move ahead but they would have to institute the engineering controls.

However, members of FFSOG strongly argued that sampling should be done prior to the pouring of the slab to determine the extent of the problem.

In a letter to EPA Project Manager Bonnie Arthur, Pam Nieberg wrote:

“I am concerned that Target is planning to move ahead with construction prior to further evaluation of the extent of the TCP contamination. I expressed these concerns to the FFSOG Board and community members in attendance and they believe that further sampling should occur to determine the extent and source of the TCP contamination prior to further construction at the Target site.”

She continued:

“You stated in your November 24th response that EPA can require Target to investigate the TCP contamination if you determine at a later date that the plume does not come from the Frontier site. However, once the foundation and parking lot are built, sampling will be much more difficult if not impossible in the case of the store concrete slab. Moreover, if the TCP originated from the source area, it changes the nature and scope of the Frontier site clean up and investigation. Specifically, this detection may indicate that the contamination has moved further that previously thought thus requiring reassessment of the pump and treat system and the extent of the groundwater contamination. Therefore, in addition to assessing the extent of the contamination, it is also essential to ascertain its source to the extent possible.”

She concludes:

“The issue is not just whether or not Target mitigates for possible TCP intrusion into the store as is currently planned. It is an issue of determining the extent and probable source of the TCP contamination, possible health impacts in the neighborhood and how to remediate if necessary. This is to request that the EPA take immediate action to further investigate the source, extent and movement of the TCP in the groundwater in the vicinity of the planned Target store and adjacent homes. Time of the essence as Target plans to move ahead very soon to build the store foundation.”

This is a very concerning situation as the EPA for whatever reason has decided to strike a deal with Target rather than require simple testing to determine the extent of the problem. The question arises, as Target proposes to build on a Superfund cleanup site, how much of a health threat if any, this poses to workers and customers of a new Target.

At this point, this is not a question of preventing Target from going into this location, it is now a question of mitigating whatever environmental and health impacts this choice of sites has. Target won ballot confirmation based on the notion that this would be a new and green Target. They pointed to the fact that this would be the first LEED-certified building. And yet, they seem wholly unconcerned about possible health and environmental impacts are now faced by the community based on decisions made by previous stewards of this property.

Some will argue that if the EPA has little problem with Target going forward neither should we. My concern is of course, the EPA under the Bush administration does not have a stellar record and has consistently sided with industry and commercial interests over environmental protection. As such, it would be interesting to see what a new EPA under an Obama administration would bring. It seems suspicious that the the date certain for beginning the project is January 5 just two weeks and a day before Obama officially and formally becomes President.

As the extent of this health problem is unknown at this time, Davis should demand answers BEFORE work goes forward. If there are no health threats, then Target can by all means, proceed as planned. Why not take the extra time to be sure? Unless of course they know something that we do not.

—David M. Greenwald reporting

Author

  • David Greenwald

    Greenwald is the founder, editor, and executive director of the Davis Vanguard. He founded the Vanguard in 2006. David Greenwald moved to Davis in 1996 to attend Graduate School at UC Davis in Political Science. He lives in South Davis with his wife Cecilia Escamilla Greenwald and three children.

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56 comments

  1. You might see this as an issue separate from Target being built, but it isn't. The same people who opposed Target being built are the same people behing the 'Oversight Group'. They are using this one test as ammunition to delay the store further. It's very transparent.

  2. …If Target didn't begin construction, we wouldn't know about this stuff….Yeah we would there have been superfund wells for over 20 years….You might see this as an issue separate from Target being built, but it isn't. The same people who opposed Target being built are the same people behing the 'Oversight Group'. They are using this one test as ammunition to delay the store further. It's very transparent….I see, so this concerns you none at all. Got it.

  3. I just wanted to comment here, this has the risk of being an issue that is obscured by the Target issue. For me, this is separate from the issue of whether or not Target should be built. For better or worse, that issue was decided over two years ago by the voters. That's fine.Oh, please. I'm not stupid. This garbage wasn't an issue when homes and a gas station were being built there. Now that Target wants there it is an issue. This is about stonewalling Target to do an end-run around Measure K because the anti-big box campaign failed….Yeah we would there have been superfund wells for over 20 years….my point exactly.

  4. I am not a fan of Target, but this whole issue is silly…If this were Trader Joes being built here instead of Target there would be people outside beating drums and chanting …we shall overcome… to stop the evil EPA people from keeping them from their cheap wine. This is just another one of those bogus pseudo-environmental matters that employ consultants who simply write endless reports and do nothing to really help the environment. Target does nothing to increase or decrease the underground plume issues of the actual contaminants.

  5. Rich:That's basically what I want to know–what is the chance that this is a health threat, if it is not a health threat, then build the building. If it is, what are we going to do to mitigate that health threat. It seems reasonable in making that determination that we determine the nature of the problem under the building before we pour concrete.I agree it is quishy, I want to un-quish it.

  6. I would just like to clear up a couple of points. This site has been a superfund site since the mid-80's when the State took it over from the county. In 1994, the site was placed on the National Priorities List and was declared a federal superfund site. USEPA has jurisdiction over the site now. The city is not responsible for this property or the contamination there. There are also no responsible parties. The people/companies responsible for illegally dumping the contaminants declared bankruptcy many years ago and are not involved. The superfund property, including the well field, are under the jurisdiction of the USEPA, and the clean-up is being funded by federal dollars. The property where the TCP was detected is owned by Target and is under their jurisdiction. The oversight group organized in 1994 and appied for and received grants from EPA to do the oversight work. With the funds, we hired a technical advisor-an expert in this field. Our primary concerns from the beginning have been that this site be cleaned up in a timely manner, as it poses a threat to the near-by communities and to our drinking water if contaminants in the ground water continue to move downward. As to this …garbage… not being an issue previously, in 1996, members of the FFSOG met with city staff to ask them not to permit the building of Mace Ranch 11, the housing development now immediately north of the superfund site, until EPA had finished with its field investigations. The FFSOG's technical advisor believed, based on his independent modeling of the site, that the plume was moving toward that area. The city checked with EPA, and since their contractor believed that the plume was being contained, EPA told the city it was okay to go ahead with construction. Now we have a community of dozens of homes sitting over a plume ground water contaminated with carcinogens and neural and reproductive toxins. Since 1994, the USEPA has done a great deal in the field to upgrade and expand the pump and treat system to fully capture the plume of contaminated ground water. As part of that system, there are a number of monitoring wells that help define the edge of the plume of contamination to ensure that the plume is being contained. The wells that Target had to …move… (actually replace), were a cluster of wells monitoring just outside the eastern-most extent of the plume. They were non-detects and demonstrated that the contamination in the groundwater was being contained in that area. Target had to destroy those wells as they were under the store footprint, and they were required by EPA to find suitable locations for replacement wells. During groundwater sampling to determine appropriate locations, the TCP was discovered just north- east of the Target footprint.Whether or not the TCP would have been found if Target were not planning to build is not the issue. TCP is a carcinogen, very mobile in ground water and volatile and it has been detected on Target's property. It's source, extent and movement must be determined and appropriate actions taken for the protection of near-by residents and under law. If a Trader Joes were being planned for the area, the same rules would apply. If the TCP can be shown to come from the superfund site contamination source area south west of the Target footprint, then USEPA is responsible for investigation and clean-up. If it is shown that the TCP is NOT from the superfund site, then, since Target owns the land where the detect was found, they are responsible for investigation and clean-up. This was known to them when they purchased the property.To determine the origin of the TCP, further groundwater sampling must be done, and some of that must be done in the area of the Target footprint. Once the slab is poured, that sampling will be difficult if not impossible. The FFSOG and the affected community believe that this sampling must take place prior to any further construction at the Target site.Pam Nieberg

  7. What are the odds this toxin could pose a serious threat to workers in the store?Even calling TCP a toxin is wrong in this particular case. There could be no threat to anyone's health from possible fumes. The EPA understands that.If a person is directly exposed to large amounts of Trichloropropane by drinking it or bathing in it, that would be hazardous. However, even doing a few times that would not cause cancer in a human.At low levels of direct contact, the worst pathologies are eye and throat irritation, nothing more. The irritation would go away very quickly. TCP breaks down immediately upon exposure to air. In water, TCP dissolves entirely.When we are talking about potential vapors, and no direct contact, there is nothing to fear. Seriously, you are far, far more likely to become sick from your coworkers' flatulence than you would from breathing air that contained TCP vapors.if it's 10 million to 1 that someone in the store could be harmed, that's not worth getting excited about.It's beyond 10,000,000:1 that TCP would harm anyone in that store. Target proposed engineering controls. A layer of gravel covered by a membrane vapor barrier under the slab.Because TCP vapors are harmless, there is no benefit to be derived from installing a vapor barrier. That would just be a waste of money.If you want to read more facts about Trichloropropane, go to this government site :http://www.atsdr.cdc.gov/tfacts57.html

  8. You did the same thing I did at first, googled it. Came up with the government site, all is well. As I read your post, I'm like, this all sounds very familiar and thought you had pulled the info off that site, and then you even cite the site at the end of your post. Nicely done.One interesting thing I noticed however: September 1995That's the date of that publication. Apparently there is more recent information including now the designation of TCP as a carginogen. What happens in these cases is that agents such as TCP as deemed not harmful unless clinical studies show them to be harmful. Problem is that you need good longitudinal studies to do.Don't try to pass yourself off as an expert based on googling a word and regurgitating it line by line.

  9. To: Pam Nieberg:I appreciate the detail.I still have a problem holding Target responsible for a civic issue that has not been dealt with sufficiently for fifteen years. Where have all these

  10. 4:47:I don't want to shatter your ego, but I think Pam did a good job of addressing key concerns on many people's minds and it was hardly a waste of time as many of us who were not you, enjoyed and found the additional information very helpful. You succeeded in making her case stronger, well done.

  11. I found more updated information re TCP in an EPA fact sheet dated April 2008. I ordered the complete order regarding TCP. The fact sheet had one or two interesting facts. …TCP is an emerging contaminant that is of interest to the government, private sector, and other parties. It is recognized by the state of Californi to cause cancer and is a known toxin…. It is also unlikely to sorb to soil and has low solubility in water. Check out EPA 505-F-07-008.

  12. …Yes, boo-hoo-hoo. You can't shop for your cheap crap. Who cares about the neighbors safety or heath, just as long as (sing along with me-me-me-me-me) I can shop for my cheap stuff!…Do you feel better after saying that? You clearly have no idea how difficult it is to make ends meet, pay a mortgage, and raise a family in this town on a modest income.

  13. Do you feel better after saying that? You clearly have no idea how difficult it is to make ends meet, pay a mortgage, and raise a family in this town on a modest income.Actually, yes I do know what it's like to pay a mortgage, raise a family and make ends meet. I choose to do it with a better moral conscience. Unlike many, I choose not to spend my money on expensive cell phone plans, cable TV or gym memberships which allows me and my family to shop locally, save the environment and support our smaller businesses. I don't buy from Target or Wal-Mart period because I don't approve in or support their business model. They don't provide a sustainable wage for workers, they sell cheap items that people fill up their garages with and don't really …need,… they don't contribute to a sustainable environment, they take away from the community by squeezing out smaller retailers, they create a co-dependent relationship with customers (YOU CAN'T LIVE WITHOUT THIS STUFF! Buy, buy, BUY!). It's unhealthy and (I don't care how many times they repeat this) NOT green.

  14. Oh and before you respond with a …Wow that must be so nice to be morally superior!… yes, you're right, it is nice to think in a forwardly fashion and not take the easy way out. It takes more effort but it's worth it to be more eco-minded and not wasteful.

  15. …Unlike many, I choose not to spend my money on expensive cell phone plans, cable TV or gym memberships…We don't do any of this stuff either. You must feel morally superior. Typical Davis elite.

  16. David,Off topic, but for your consideration:Some parents in recent months have had concerns about pesticides/herbicides used by the school district as well as the City of Davis.Sac News and Review ran a front page piece on the use of such chemicals in Sacrmaneto schools a couple of months ago.

  17. It's intererstingg that you are complaining about elitism, this is a common refrain:…You clearly have no idea how difficult it is to make ends meet, pay a mortgage, and raise a family in this town on a modest income….There is this kind of entitlement attitude that you are the only one who knows and understands what it's like to struggle to make ends meet and most importantly that there is only one way to do so–the way you have done.I struggled mightily this year financially, there were weeks I had to choose between food and gas to get to work. I often had to resort to eating plain rice since it was the only food I could afford.I don't see how having a Target is a big change for Davis. I've never seen that their prices are that much better.I also don't understand why people who struggle are somehow exempt from worrying about things like the environment and pollution.

  18. …Unlike many, I choose not to spend my money on expensive cell phone plans, cable TV…….Do us all a favor and give up your internet connection too! Holier than thou.

  19. …I often had to resort to eating plain rice since it was the only food I could afford. I don't see how having a Target is a big change for Davis. I've never seen that their prices are that much better….Price of plain rice comparison:Target 5 pounds = $1.14Nugget 5 pounds = $172.98According to Pam Nieberg, rice at Target is toxic, unfortunately. So you might want to cook it longer.

  20. …As to this …garbage… not being an issue previously, in 1996, members of the FFSOG met with city staff to ask them not to permit the building of Mace Ranch 11, the housing development now immediately north of the superfund site, until EPA had finished with its field investigations. The FFSOG's technical advisor believed, based on his independent modeling of the site, that the plume was moving toward that area. The city checked with EPA, and since their contractor believed that the plume was being contained, EPA told the city it was okay to go ahead with construction. Now we have a community of dozens of homes sitting over a plume ground water contaminated with carcinogens and neural and reproductive toxins….Mace Ranch II never should have been built until the site was cleaned up, period. Building Target over a contaminated site is just worsening the problem. And I say that having voted for Target!

  21. Thanks to Pam Neiberg and the others who are keeping an eye on the superfund site. Just think, if you did not do the very important work that you are doing then the BIG BOX advocates would cry conspiracy once it was discovered that the Target toxic site was contaminated and the Target store was already halfway complete. It's a no win situation. Basically, what you have shown us Pam (and others) is that nothing should have even been considered to be built at the Target location to begin with. The only reason Target was even marginally approved was because the pro-Target people …targeted… students who want to buy cheap stuff made in China (with lead poison unbeknown to them).

  22. Price of plain rice comparison:Target 5 pounds= $1.14(lead in the rice?)Nugget 5 pounds = $172.98Safeway $.77 / 5 pounds = $3.85Save Mart ?? probably less

  23. David,Why is it that the company that did the original contamination not get the bill for cleaning up the site? Who was it that did this dumping? I would be willing to be that it's that republican farmer that lives across the way. Ps. The perpetrators are still there. I've seen them go in and out frequently into this boarded up building on second street. Wether Target comes to Davis or not, the perpetrators who polluted out water and land must be held accountable.!!!

  24. I just wanted to comment here, this has the risk of being an issue that is obscured by the Target issue. For me, this is separate from the issue of whether or not Target should be built. For better or worse, that issue was decided over two years ago by the voters. That’s fine.However, if we are going to have a Target in Davis, it needs to be safe for the people and the neighbors. This issue must be dealt with and from what I have seen, they seem less than fully concerned and more concerned with cutting a deal.To the extent that a conversation occurs three days before Christmas, that would be on the lines I would like to see it. We can debate elsewhere whether Davis really needed a Target or not.

  25. Wait a minute! The toxic substances will be in Davis regardless of Target. If Target didn’t begin construction, we wouldn’t know about this stuff. The City should take over the remediation of the toxic substances and find-out who put them there. The financial responsibility is with 1. the land owner 2. person who put the toxic substances there 3. person who hauled them there 4. person who is operating on the land. Someone, the City, needs to find out who is financially responsible for this. The City needs to remediate the dangers so that no one is exposed.Target is not the issue

  26. I’m not sure it wasn’t an issue prior to Target wanting to build there. But you have missed an important fact–proximity. There was a good deal of distance between the site and the people who lived there. Now there will be people right on top of a toxic waste dump, with venting of carcinogenic fumes. You aren’t the least bit concerned that Target takes the time to find out what the heck they will be building over and exposing workers and customers to? That just seems irresponsible on your part.

  27. Mike:Let us assume for the sake of argument that there would be less complaint over Trader Joe’s in that location than Target. I’m not sure I agree with that point, given my stance on Trader Joe’s at University Mall.So bracket that point.Are you comfortable with the steps that have been taken by Target and the EPA to mitigate for potential harm to workers and the community? Do you think it is reasonable to have a better idea of what is down there before they pour a concrete slab over it? Do you believe we have adequate knowledge as to the level of toxicity?For me, regardless of what has been built up there or will be built up there, those are the key questions and I do not feel we have satisfactory answers.Most people who have posted thus far have been relatively unconcerned about these issues, none of them has explained why they are relatively unconcerned about those issues other than to argue that this is an issue because its Target. That’s an easy, shall I say …target…, but it doesn’t resolve this issue in an adequate way for me.

  28. If we are simply dealing with the issue of …a… business locating here and ignoring the issue that Target is a lousy choice, then lets go with the bracketing ;-)There is a HUGE difference between a deep plume (30-130 feet underground) and surface contamination. The only risk that workers and shoppers face is from second-rate goods.The issue that I believe is valid is that monitoring wells need to be relocated, but this is not remediation (not sure why) and it appears that this is being done. It is not Target’s issue, nor should it be, if there are newly found goodies in the plume.I am not clear on why a pump and dump remediation is not ongoing, but sometimes I forget that there is no relationship between EPA projects and doing anything for the environment… silly me.

  29. The issue here was that if there was a plume of TCP under the footprint, because TCP is volatile, it could enter the building through the cement slab and pose a risk to workers in the store.Could is a very squishy word in the above sentence. A reasonable question is: What are the odds this toxin could pose a serious threat to workers in the store?How do those odds compare with other threats which could arise? For example, if it’s 10 million to 1 that someone in the store could be harmed, that’s not worth getting excited about. It’s probably 1:1 that a worker or a customer will be seriously hurt in a parking lot accident in the next 5-10 years at Target; and no more than 2:1 that a forklift accident will hospitalize a customer in that same time frame. Life is full of dangers — the question is always how likely is the danger?Target proposed engineering controls. A layer of gravel covered by a membrane vapor barrier under the slab. Piping would run from the gravel layer up through the walls of the store and vent to the outside.The question to this …solution… is, How much less likely would this barrier make it so a Target worker would not ultimately get sick from the toxin? Again, if doing so makes working at Target far less hazardous than mowing a lawn — and that’s probably the case — then this is likely much ado about nothing.But if it is still quite likely, even after the barrier mitigation, that someone will develop cancer as a result of working there, then we ought to stop the development….As the extent of this health problem is unknown at this time, Davis should demand answers BEFORE work goes forward. If there are no health threats, then Target can by all means, proceed as planned….No health threats is the wrong standard. Reasonable threats — the millions to one variety — are part of everyday life and we should not paralyze society because life is not 100% without risks.

  30. The financial responsibility is with 1. the land owner I’m not sure who that is. But they knew what they were buying.2. person who put the toxic substances there 3. person who hauled them there Long, long gone.4. person who is operating on the land. That would be Target Corp.