It would be an understatement to say that I am not the most athletic person in the world. Though I'm far from obese, I've never particularly enjoyed exercise. As a child, I found it to be a source of pain and little more. Yet when I moved from the Boston area to sunny Texas and then California, I realized that exercise at least did not have to be nearly as gloomy as I had once thought.

Once I got settled down in Palo Alto, in a house one block from Stanford University's southernmost edge in a quiet, suburban neighborhood called College Terrace, I got myself into a routine that involved running two or three times a week on a 2.25-mile-long circuit. If I was feeling especially ambitious, I could run up a large hill on Page Mill Road right past Hewlett-Packard's world headquarters and extend my loop to 3.5 miles—about as much as I could physically handle. The shorter route was just the right length for me to feel like I had actually exerted some energy without hurting myself, which was something that always concerned me because I was used to my body falling apart without notice. For years I had fought asthma whenever I ran; in high school my lung collapsed twice; and just after graduating from college, I learned that I had kidney stones, which (as many know) carry with them a lifetime threat of recurrence and possible kidney damage. Even though running had nothing to do with these more severe episodes, I still counted them against myself as reasons never to push too hard and to be extra careful about my health.

So it was that while running, but not so much as to force my body into open rebellion, I noticed something odd. When I was heading down the gently sloping hill on Peter Coutts Road towards Stanford Avenue, I turned right as usual to head back home, passed along the edge of a grassy area, and smelled...cookies. But not really cookies. Raw cookie dough. Outside.

It was enough to make me look around to make sure that there wasn't a large bakery or kitchen nearby that I had somehow missed. There wasn't: I was definitely outdoors, surrounded by grass, flowers, tall pine trees, and open road. Still, there were houses nearby, and one of them might have been baking cookies. Or all of them. For the smell of raw cookie dough to be that strong, it had to be lots of cookies. So I kept running and went home.

As a friend pointed out, a plausible explanation is that on that run, I had a stroke, though I'm still alive and well enough now to tell the tale. Ruling out that hypothesis, however, is the fact that on another subsequent run, I smelled it again. Raw cookie dough. At the intersection of Peter Coutts and Stanford. With nary a cookie in sight. The smell seemed to get stronger the closer I got to a small bridge and concrete structure over what looked like a ditch.

I looked it up on Google to make sure I wasn't missing anything obvious. My guess was that I was being tricked by some strange chemical, so I looked for "chemicals that smell like cookie dough." Nothing relevant showed up.

I probably went running on that same path twenty or thirty more times after that, and smelled cookie dough at the same place on half of those occasions or more. And then something truly weird happened.

"Hey," my roommate told me, just a few weeks ago. "Have you been over by Wells Fargo? It smells like cake batter." The local Wells Fargo bank branch is on the opposite end of the College Terrace rectangle. We were planning on grabbing a quick dinner along California Avenue anyhow, so we walked by.

"Right here," he said. And sure enough, along the sidewalk, just before reaching the ATMs, there was a clear smell—and one that I recognized. What my roommate called "cake batter," I called "cookie dough." The point was the same either way: the odor was completely out of place at both locations in the neighborhood, and we had each independently noticed it. The intersection of California Avenue and El Camino Real was about as reasonable a place to smell cake batter or cookie dough as Olympus Mons. But we were hungry, and it wasn't really clear who one would even tell about such a strange occurrence, so we went and got our dinner. On the way back when we passed the smell again, we at least confirmed to each other that we weren't crazy.

I had the unfortunate honor of celebrating my thirtieth birthday soon after, and I decided to mark the sad occasion by having dinner with some of my California friends at a restaurant in Mountain View. Afterward, I decided to risk sounding slightly paranoid by asking if others had noticed the phantom baking ingredients in our neighborhood, so I asked if two of my friends who live a few blocks away knew what I was talking about. They said no.

Then, a second later, "Wait a minute!"

"I know exactly what you're talking about! Yeah, it's right in front of Wells Fargo and it smells really sweet! What is that?"

•

I'm not completely naive; Silicon Valley is no stranger to toxic waste. When Fairchild Semiconductor, Intel, AMD, and other technology companies were starting out in the Santa Clara Valley, not too much was known about, well, anything. The clean room procedures and protective gear that we now take for granted didn't exist. Lots of chemicals, some of them very obviously dangerous, and others less-obviously dangerous, were needed if anything was going to work at the end of the day, especially in the industry's infancy. Today, it's quite clear that we are all glad things did work back then, even if things required arsenic and benzene and PCBs and lead, because the Valley helped the United States win the Cold War, beat the Japanese economy, and propel Gross Domestic Product to great heights, raising the standard of living for everyone. As with all things economic, though, the Valley contributed such great advances at a cost, and that cost usually involved those chemicals leaching into the ground and into the bodies of low-paid, immigrant workers for years, and years, and years, until somebody finally noticed. And then, if there were even relevant regulations in place at the time—which there often were not—someone called the EPA. Maybe.

When my company's office was located on Hillview Avenue in 2010, literally around the corner from Hewlett-Packard, I heard gossip about how the tech giant had polluted the area back in the day. Once a quick search confirmed that there was some truth to the rumor, it made me a bit nervous about drinking water straight from the tap at the office, so I bought a Brita filter, and didn't think much of it. Then California passed the Money Transmission Act, I had to close the office, and I began working from home, about a mile and a half away back in College Terrace, and sometimes at Stanford.

On February 21, 2013, news headlines sounded the alarm, and kept sounding it well into March, which is about when I saw it: Google had leased two buildings that were full of toxic fumes. Trichloroethylene, or TCE, was evaporating up from the soil. Searching for TCE on Google revealed that it was a carcinogen with a sweet smell. "Sweet like cookie dough?" I wondered. Pregnant women were exposed. The culprit in Google's case turned out to be an air conditioning setting that was also linked to building's underlying vapor extraction system, which had been inadvertently disabled when someone thought the air temperature was too cold.

Upon reading this, it triggered another memory. "I wonder what ever really happened to HP's toxic mess?" Very soon after, I wished the thought had never occurred to me, because it quickly became apparent that I had everything backwards. Hewlett-Packard's toxic mess wasn't really at its headquarters on Hanover Street, or even at its other building on the same block at 1501 Page Mill Road (the top of the hill). According to the EPA and the California Water Resources Control Board (CWRCB), the real mess, caused by Hewlett-Packard, Varian, and General Electric, was the Superfund site dating back to spills in or around 1981, located precisely 950 feet away from my front door.

•

This was a surprise. I knew what a Superfund site looked like. Chain-link fences. Dead plants. Rusting machinery. Peeling wood. Dripping liquids of unknown contents. Metal barrels with skulls and crossbones, callously discarded amidst giant heaps of glowing and growing sludge. Hospital wards full of young, bald children in chemotherapy.

Maybe that's what they looked like in New Jersey or Detroit or my home town, Cleveland. As usual, in Silicon Valley, we do things differently. Here, ground zero for toxic waste looks like Google Building QD6 or QD7. Or a lovely residential housing development on Whisman Road. Or in my neighborhood's case—perhaps the most spectacularly ironic Superfund site ever—a prestigious law firm's headquarters next to a soccer field teeming with happy kids. No, that's still not ironic enough.

Make that a prestigious law firm that's represented practically every Valley company that has ever dumped toxic waste into the soil. Make that the firm known most of all for its representation of Hewlett-Packard until HP's infamous spying scandal meant that one of the firm's named partners finally had to be fired as an advisor. Make that the law firm of Wilson Sonsini Goodrich & Rosati.

Photo: Michael O'Callahan / STUDIOS Architecture

To be fair, HP and Varian Medical Systems, the other major polluter at this particular Superfund site, have been paying for the EPA and the CWRCB to clean everything up, and so since 2006, that monitoring well, O67A2, has indicated that TCE levels have fallen precipitously, to almost zero. Unfortunately, that's just one well. For the entire zone of study, there are more than 340 others, and at some of them, the levels of contaminants have gone up. So it would be incorrect to think that a single well's measurements mean that WSGR's campus is now spotless. On March 5, 2012, monitoring well EW-7 in the small patch of grass on the law firm's front lawn registered at 600 µg/L. Data from 2013 doesn't seem to be available, despite the CWRCB informing me that the wells could be monitored "every second of every minute of every day." (Likely they were referring to the ability to view on-line data that had already been sporadically collected over the past decade or so.)

Two data points six years and a few feet apart don't really do justice to the scope of the problem, which at every Superfund site is complex across multiple dimensions. First, the word "contaminants" is important, because it's not just TCE that's a problem. According to the EPA, which releases update reports on Superfund sites every five years (the last of which for this site was in 2010), "The most frequently detected contaminants in soil included arsenic, gallium, trichloroethene (TCE), trichloroethane (TCA), 1,1-dichloroethene (DCE), tetrachloroethene (PCE), 1,2,4-trichlorobenzene, and phenol." Many, if not all, of these chemicals cause cancer.

The shape of the physical area being cleaned up is also not what you might expect. Generally called the "zone of study," it's extremely important because of its legal and regulatory significance. Sometimes, it's called the COE Study Area because its borders are California Avenue, just past Olive Avenue, and Emerson Street, all on the southern side of Palo Alto, centering around the intersection of Page Mill Road and El Camino Real. If something is in the zone, or the constituent sub-zones (with labels such as A1 and A2), it is worthy of study. If something is not in the zone, as far as the government is concerned, it does not exist.

Palo Alto's geography is such that there are two residential neighborhoods that are likely to be directly impacted by any contaminants in the soil of the Superfund site: Barron Park and College Terrace. Shockingly, neither neighborhood is in the zone of study. To the EPA and the CWRCB, they don't exist.

•

I may be many things, but a chemist is not one of them. I took AP Chemistry in high school as a double-period class that I didn't like much at all with a strange, portly teacher who spoke in a funny, high-pitched voice. Yet I remember learning about polar versus non-polar compounds and how well they tend to mix: with each other, not so well. When you have multiple polar or multiple non-polar compounds, they tend to mix among themselves just fine. As I recall, we were taught that soap works because its molecules are effectively hybrids: the polar end mixes with polar water, and the non-polar end mixes with non-polar oil.

Despite being the beneficiary of this very basic lesson, I admit to knowing nothing about the chemical properties of any of the contaminants listed by the EPA at the HP Superfund site. However, I'm pretty good at reading, and between the two government agencies coordinating the site's cleanup efforts, they've created quite a stack of paper over thirty-two years.

What the papers say is that there are two major types of risk to humans from contaminated soil: the contaminants getting into the air, and the contaminants getting into the water. Google provided us with a recent example of how the former might work. The latter requires only gravity for it to be a problem, and here on Earth, gravity is not in short supply. Depending on the highly variable underground topology of a specific region, chemicals might get into the water sooner or later.

The good news is that Palo Alto's water comes from the relatively pristine Hetch Hetchy reservoir. Local groundwater isn't used for drinking or bathing. (This is especially good because according to the EPA, showers are of particular concern. People tend to inhale water droplets in steam, increasing the potency of some contaminants in the body.)

Then there's the bad news. Based on my extremely rudimentary understanding of how water systems work, the EPA's stated analysis that, "At the Property and in the downgradient area, groundwater is not used as a source of potable water or for domestic purposes. Thus the only potentially complete pathway was the inhalation of VOCs migrating from the groundwater into indoor air (i.e, via vapor intrusion)," is alarmingly incomplete. The water gets to Palo Alto from Hetch Hetchy because it travels through a series of pressurized pipes. Those pipes in some places may be made of iron or steel, but in places like Palo Alto, at least some water mains (and especially the newer ones) are made of High-Density Polyethylene (HDPE) or Polyvinyl Chloride (PVC). In other words, the pipes are made out of plastic, which is another way of saying, oil. TCE is only one of many chemicals that penetrates (and in fact, according to some research, irreversibly turns to jelly) HDPE and PVC with what would seem to be incredible ease. So if HDPE or PVC pipes run through soil contaminated with just about anything, but especially TCE, it's possible that they'll pipe the contaminants right on up to the tap.

This would make one think that the EPA must compulsively and regularly test the water coming out of the tap in and around Superfund sites. In reality, the EPA does nothing of the sort. It instead chooses not to admit the existence of pipes that may carry water. It certainly does not admit that pipes carrying water inside the zone of study might continue to carry that same water outside of the zone. And so, in effect, the EPA does nothing at all, and declares the water safe.

Air quality is a different kind of problem because evaporation tends to mostly occur in the upward direction—though dissipation can still occur, at least there aren't pipes in the air—and our atmosphere is so enormous that the amount of air pollution outdoors from groundwater contamination would seem basically negligible. The question then becomes one of scope for indoor air quality: how big is the plume of contamination underground, and is there anything built on top of it. Since it's hard to see underground, to answer this question, the EPA turns to monitoring wells.

There are no monitoring wells in College Terrace or Barron Park, save for one, technically located in College Terrace because it is across California Avenue from the Wells Fargo branch. According to the EPA, there has never been any need for such analysis. Those neighborhoods—despite being directly adjacent to the plume as of the 1980s, and despite the tendency of liquids to spread out widely over time—are not in the zone. This is arguably the part of the saga that baffles me most.

There is something to be said, once again, for gravity. If the zone is on low ground and people live on high ground, water, however contaminated, will not flow up. In Palo Alto, it's not that simple. Silicon Valley is a valley, and El Camino Real is a vein running roughly down the middle, so the gradient around the zone is very shallow, almost flat. Where it isn't flat, water tends to run downhill toward Alma Street and the Oregon Expressway Underpass, which is equipped with a special pump system that also filters out volatile organic compounds, to the tune of several thousand pounds per year. (Why output is expressed in pounds by the government when the initial spill is described in terms of gallons is not clear to me.)

The CWRCB contends that College Terrace is simply the wrong direction in terms of land gradient for anything to matter, but this seems an overly simplistic and incredibly risky gamble, where the ones taking the risk are the residents who live there. By ending the zone at California Avenue, the Board and the EPA effectively argue that the contaminants will never cross the street, which is maybe twenty feet wide. That seems ridiculous, especially given that the one monitoring well located just on the other side of California, V-10, shows TCE levels consistently above zero but less than the 5 µg/L federal limit. In addition, just because land slopes one way on the surface doesn't mean that rocks and other subterranean formations have to look exactly the same underneath. Pipes aside, it's entirely possible that groundwater might shift in ways that we wouldn't necessarily expect based on what we can see above ground. The monitoring wells, which show levels of contaminants both rising and falling within a close area, confirm this. It's also notable that if the cookie dough smell is a sign of contaminants of any sort, they are flowing downstream through a creek that travels directly underneath our homes.

So, how safe is our water and our air? Well, as far as I can tell, we don't really know, and neither does the EPA or CWRCB. What really matters in the end is whether or not people who live in College Terrace can live long and productive lives, just as they would if nothing had ever spilled into the ground. I've never heard rumors of a cancer cluster in the area, or anything along those lines. On the other hand, it's not clear that anyone has ever bothered to look. If my next-door neighbors, who have lived in College Terrace since 1986, are any indication, almost no one even knows about the Superfund site to start with. The topic merited one article in the local Palo Alto newspaper when the EPA released its five-year report in 2010, and another in the Stanford Daily. On a daily basis, I read neither. There was no mention in either of the two leases I've signed for my house, nor in the two leases I've signed for nearby office space. Not to mention that plenty of students moved into the neighborhood in 2011 just after the last EPA report (and ensuing, limited discussion), and will likely be gone by the time the EPA issues its next one.

•

It's easy to get carried away worrying about environmental issues that could negatively impact one's life. Any Californian should be familiar with the ceaseless and somewhat absurd signs that warn of "chemicals known to the State of California to cause cancer" in every parking garage, laundry room, and apartment building in the state. Plastics and harmful chemicals are everywhere, from our pillows to our household cleaners. Yet despite the sea of toxins we live in, most of us still live far longer than our ancestors a century ago. So when trying to separate the signal from the noise, it helps to focus on facts, and not fears. Uncertainty surrounding any situation, whether environmental or otherwise, can be incredibly anxiety-inducing because there is never enough information to make an informed decision and move on. And that's why the situation with the HP Superfund site is so problematic.

I'll lay out the positive facts first. It's a fact that just by virtue of the site being designated for the EPA Superfund, this part of Palo Alto has been given federal attention for years that many other communities nationwide still long for today. It's a fact that serious money, in the millions of dollars, has been spent on the cleanup effort. It's a fact that monitoring wells have been installed and some data is available that suggests the cleanup efforts have generally moved in the right direction over time. It's a fact that the response of government officials in Palo Alto and California to my questions has been speedy (though hardly conclusive), which is uncharacteristic of most government agencies.

Still, despite the progress, other facts remain that point to uncertainty or negative developments. It's a fact that the HP Superfund site still exists right on the corner of El Camino Real and Page Mill Road, and stretches all the way past 395 Page Mill Road, otherwise known now as the AOL building—another HP dump site. The Stanford / Palo Alto soccer field complex upon which area children often play is a thin green veneer on top of highly contaminated groundwater and remediated soil that has apparently, since its remediation, been re-soaked by the contaminated groundwater. It's a fact that water tables rise and fall over time.

It's also a fact that the contaminants involved in the multiple spills are worth worrying about in high enough concentrations. TCE is worth worrying about, according to the federal government, when its concentration in ground water exceeds 5 µg/L. It's a fact that the average (mean) measurement of TCE at monitoring well F32A, at the intersection of Sheridan Avenue and Birch Street, is 81 µg/L, or over sixteen times the federally allowable limit, if you include the three readings available from 2007 (130), 2009 (33), and 2011 (80). It's a fact that the popular Italian restaurant Caffe Riace is a few feet away from this well, as is the parking space where I used to leave my car during the day when I worked. It's a fact that the abandoned lot where that space is located covers soil laced with TCE, TCA, and DCE, and that the lot is surrounded by houses, apartments, offices, and government buildings, which is typical of land all over the zone of study that is anything but abandoned.

It's a fact that Beckman Coulter's former building at 1050 Page Mill Road, later occupied by Facebook, Inc., is also surrounded by volatile organic compounds (VOCs), with a bonus of PCBs that leached out of two high-voltage electrical transformers that were located on concrete pads. It's a fact that the PCBs are detectable at levels far exceeding residential standards considered safe in the parking lot, and that the parking lot has a storm drain where PCBs are also detectable. It's a fact that the EPA does not appear to have paid attention to any of this because 1050 Page Mill Road isn't in the zone of study, even though it's closer to WSGR than the AOL building.

It's a fact that unsafe levels of tetrachloroethylene (also called perchloroethylene, or PCE), measured at 2.9 µg/m³, above the threshold of 2.1 µg/m³, were detected on the first floor of one of the Wilson Sonsini Goodrich & Rosati buildings in December, 2009. The other levels measured, of TCE, 1,1,1-TCA, and 1,1-DCE, were above zero but below the commercial threshold.

It's a fact that different studies about these various sites use different standards to evaluate whether a given level of contaminants is "safe" or not. First of all, it appears that safety standards have changed drastically over three decades for different chemicals in both directions, with some standards getting tighter and others looser. Secondly, there are standards for commercial use that are more tolerant than those for residential use. Many of the measurements deemed "safe" are safe for commercial contexts, even though there are thousands of residents literally on the other side of California Avenue, and even though one study states, "The [California Regional Water Quality] Control Board has required comparison to the residential ESL based on zoning of the property that allows unrestricted land use by the property owner (Stanford University)." (ESL is a term that means "Environmental Screening Level.")

It's a fact that although the City of Palo Alto has been responsive to my e-mails outlining these concerns, as has the CWRCB, neither party has been able to satisfactorily answer my questions, namely: are there contaminants in my air and/or water that I should know about?

It's a fact that I don't have any symptoms right now that could be directly attributable to the contaminants at the HP Superfund site. But it's also a fact that cancer takes a while to develop, and your local doctor's office isn't typically equipped to measure your blood for these contaminants. As Blake Ross points out, it's a fact that cancer rates near Mountain View's TCE plume have spiked.

And of course, it's a fact that although this saga has been playing out for thirty-two years, very few people in College Terrace seem to know anything about it. Even if everything is perfectly safe, the public has the right to know what its government is doing to protect citizens, and government has an obligation to inform the public in a more-than-perfunctory manner of these activities. Certainly local government, meaning the City of Palo Alto and the CWRCB, has utterly failed in that regard.

•

From my vantage point, this is a battle that cannot be won. I will likely move when my lease expires, if not sooner. I don't want to risk any extra potential kidney damage. The chemicals that are in the ground will be there for a long time, shifting from one place to another with no warning. But that's no excuse for the kind of inept oversight of the situation that seems to have been the norm for so long.

In the EPA and CWRCB's latest written status update from two years ago, there is a link to a web site for more information. The link wraps across two lines, making it hard to copy, but even when properly copied, it leads nowhere due to a technical error.

Stanford University, which owns the land that HP, Varian, General Electric and Beckman Coulter rented, plays an interesting role as well. Though hardly its main focus or source of income, Stanford profited from renting out its land as it was polluted, and may continue to profit from rent even after it is known that the land is polluted. Many Stanford faculty members, employees, graduate students and their families live in College Terrace since it is so close by. Stanford has extremely stringent policies for its own labs on campus about how chemical waste must be handled, but those policies clearly don't apply to Stanford tenants. By virtue of encouraging industrial use of its land right next to residences, Stanford now finds itself in a position where it may be putting its own affiliates at risk, myself included. (I am loosely affiliated by virtue of an unpaid fellowship at Stanford Law School.)

The City of Palo Alto, which should have been leading the charge for accountability on behalf of its residents, has apparently done nothing, or next to nothing. The involvement of larger government agencies has provided convenient cover for the City to defer any authority.

Politics notwithstanding, Palo Alto should centralize resources for concerned citizens on its web site and keep in direct touch with residents. All it has done so far is send out the City Arborist via the Fire Department to determine one thing for sure: whether the raw cookie dough smell that pervades the air in those two unlikely places, both along the path of a small creek likely laced with PCBs, comes from as-yet-undiscovered plant life. I do not anticipate that the search for the Cookie Dough Tree will be very fruitful. Then again, I guess you have to start somewhere.

It's not my goal to needlessly fearmonger. Nor do I mean to imply that Palo Alto is uniquely affected by pollution when there are thousands of similar or worse sites in the United States, and both China and Japan suffer from horrendous, ongoing environmental disasters.

Still, I live here, and I feel an obligation to ask about issues that directly affect my health and the health of others I care about. If some of these issues are already long-since resolved, then that's what I want to know. That's not what I'm hearing, however; I'm hearing that the existence of these issues is hardly even known. It seems clear that we need more information, which to me suggests that anyone within a one-mile radius of the zone of study who wants their home's air and/or water tested should be granted such a request immediately and at no cost to the resident. (This includes all of Stanford's graduate student population living in Escondido Village, which is next to College Terrace.)

Still, I hope we do find the Cookie Dough Tree, because that would allay a lot of my fears about the situation. If not, we should be prepared to at least discuss the state of affairs and demand accountability where appropriate. There are a lot of children in College Terrace—right next to what would appear to be the most beautiful, temperate and welcoming toxic waste dump in the world.

•

Below is a list of links that might be helpful in piecing together the puzzle.

United States Environmental Protection Agency

• EPA Superfund Site Web Site
• EPA Record of Decision - March 24, 1995
• EPA Five Year Review - September 14, 2000
• EPA Five Year Review - September 30, 2005
• EPA Five Year Review - September 30, 2010
  The EPA's official map of the zone of interest and its estimate of the underlying plume's scope is on pages 38-41 of the PDF.
• EPA Site Update - August 12, 2011

California Water Resources Control Board

• Interactive Google Map with Contaminant Data from Monitoring Wells
• Beckman Coulter Site File - 1050 Page Mill Road
• Beckman Coulter Site PCB Report - November, 2012

Contact

Roger W. Papler, P.G.
Engineering Geologist
San Francisco Bay Regional Water Quality Control Board
1515 Clay Street, Suite 1400
Oakland, CA 94612
roger.papler@waterboards.ca.gov

City of Palo Alto

Contact

Jason Nortz
Senior Planner
City of Palo Alto
+1 650 617 3137
jason.nortz@cityofpaloalto.org

WSGR Indoor Air Quality Tests

Note: WSGR's indoor air quality was also tested in the EPA's 2010 Five Year Review (above), where one sample was found to be over the commercially acceptable limit.

• January 12, 2011 - 640 [Now 650] Page Mill Road
• January 12, 2011 - 601 California Avenue

My Recent E-Mail Correspondence

• April 3, 2013 - Message to Government Officials Including Prior Threads

Other Links

• PlainSite Environmental Heat Map
• Latest (Color) Zone A1U TCE Map
• HDPE Pipe Chemical Resistance Information
• Palo Alto Public Works Department

Special thanks to S.C. and E.T. for their feedback.