The Case of the Missing Data
The EPA responds to environmental concerns in Palo Alto.

April 15, 2013

When I learned the scientific method in school, I was taught that one starts with a hypothesis, collects data, analyzes that data, and then proceeds to prove or disprove the hypothesis. The order of operations, needless to say, matters. In my last post, I posited a hypothesis: that there may be serious problems with water quality, and possibly even indoor air quality, in the southern part of Palo Alto.

Apparently, when you're in the government, the method is something more like this: conclusion.

I've now spoken with officials at the City of Palo Alto Utilities (CPAU), the California Water Resources Control Board (CWRCB), and the Environmental Protection Agency (EPA). I also attended a Palo Alto City Council meeting tonight. Everyone is singing a version of the same happy tune: everything is fine. Nothing is wrong. (In fact, City Council just spent two hours discussing how Palo Alto is Green and patting itself on the back accordingly.) The only problem is that no one has any data whatsoever to prove it.

To make a long story short, there are no monitoring wells in College Terrace or Barron Park, both of which are residential neighborhoods literally across two respective streets from what government officials nonchalantly refer to as "the COE plume." The monitoring wells in the COE plume, across the street, don't look as bad as they did in 1986 or 1995, but some of them sure don't look great. And that's just for TCE.

Much to my chagrin, the people in the adjacent neighborhoods mostly had no idea that such a plume existed until I informed them as a private citizen with no particular expertise on the matter. Not even the bank teller I talked to today at Wells Fargo, which sits directly on some of the most contaminated land at the site, knew that she was working near any hazardous chemicals. All she knew is that, "they've been working on the pipes since 2007." When I asked if her manager or anyone had informed her or anyone that her workplace was on an EPA Superfund site, her answer was no, and she asked if that meant the EPA was involved.

According to the EPA, it's one of the most aggressive cleanup operations they've ever mounted—which is of course why it's such a well-kept secret.

Meanwhile, there are no plans to test homes less than one thousand feet away because there's no clear indication that there's any reason to, says the government. And of course there's no clear indication because there are no monitoring wells, because the government decided not to put them there.

The EPA contends that there's no need because the houses are not down-gradient. Except that the CWRCB says that the EPA's assessment is wrong, and that the houses are actually cross-gradient. This would seem to make a difference.

You can listen to the occasionally interesting hour-long call with CWRCB and EPA for yourself. You can also read the e-mails I've sent to and from various officials (see below).

At this point, I have more questions than answers. Here's what I took away from the call:

  • If you smell cookie dough or cake batter where it doesn't belong, call the Palo Alto Fire Department immediately at +1 650 329 2413 (non-emergency number).
  • According to the EPA, the site likely will be contaminated for the rest of our lifetimes.
  • CA and EPA think our water and air are safe, but they don't have any data to prove it.
  • EPA for some reason uses community concern as a metric when evaluating how much to inform the community. (One would think that the only factor should be danger, not the community's prior knowledge or understanding of the danger.)
  • By law (apparently) landlords aren't required to inform their tenants of anything, but California law (it's not clear which one) requires notification upon change of real estate ownership.
  • There's no 2013 data about the site, or any data about College Terrace at all, and the various government agencies feel comfortable making sweeping assertions that affect our safety regardless.
  • Most residences on the plume tested did not have detectable levels of TCE in the air, but TCE was detected in the elevator shaft of one apartment building near Sheridan and the AOL building. Most commercial buildings except Wilson Sonsini haven't been tested yet, and neither the residential data nor the commercial data is available yet.
  • Maybe there will be one or two monitoring wells in College Terrace in the future, but not every block. Yet there are over 300 near Wilson Sonsini and Wells Fargo.
  • If you want to test your own water or air you'll have to pay for it yourself. Or you can just refuse to pay it as part of your water bill (for water testing) and see what happens. (Clue: a late fee!)
  • The last time residents were contacted about anything was apparently 2007 but the EPA is "on top of it" and "moving forward."

E-Mail Correspondence

Aaron Greenspan is the CEO of Think Computer Corporation and author of Authoritas: One Student's Harvard Admissions and the Founding of the Facebook Era. He is the creator of the FaceCash mobile payment system, ThinkLink business management system, and PlainSite legal transparency project.

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Brent Han (
December 4, 2016 at 3:24 AM ST

The Water Board began cleanup operations at the HP Superfund Site in 1981 and still hasn't acknowledged the full risk of vapor intrusion. The latest Five-Year Review from 2015 also states that a series of A1U wells (which measure 10-30 feet below ground) were to be redeveloped and sampled south-southeast of 395 PMR and on the east-side of Palo Alto square. However, these wells "could not be located, and had likely been destroyed." (p. 14) Apparently no further action was taken. Even if the area seemed clear in 2009 (p. 31), plumes change. Additional sources may be found. It really throws the Water Board's approach into question.

2015 Five-Year Review:$FILE/HP%205-Year%20Review_Final_09-2015.pdf

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