Following are questions, answers and comments that were raised during a virtual public meeting on Oct. 26, 2020, to discuss environmental concerns raised by Prescott residents regarding the development of the Yavapai County Justice Center.

Questions & Answers:

Why are you bringing criminals from all over Yavapai County to our residential backyards that Commissioner Garrison says are too dangerous to take downtown?

Yavapai County Response: The Criminal Justice Center site is located adjacent to industrial uses such as garbage transfer station, a wastewater treatment plant, and the local animal shelter. The nearest residential area is over ¾ of a mile from the site. Currently inmates must leave the secure Gurley Street facility (located in Prescott’s downtown residential area) and be transported in large groups to court through the public park at Courthouse Plaza in the center of Prescott. The planned facility contains the detention facility and the courts within the same secure structure, allowing the safe and secure transport of inmates to court without the need to leave the secure facility.

How many of you who approved this jail would like to have it in your backyard?

Yavapai County Response: The Gurley Street detention facility in use today is in the center of Prescott’s downtown residential area. The new Criminal Justice Center site is located adjacent to industrial uses such as garbage transfer station, a wastewater treatment plant, and the local animal shelter. The nearest residential area is over ¾ of a mile from the site.

Who were the hazardous waste contractors who removed the UST excavations?

Yavapai County Response: The underground storage tanks (USTs) and associated material located on the property when obtained by the County were tested by Western Technologies, Inc. The tank and materials in that area were properly disposed of by Earth Resources under the guidance of Western Technologies, Inc. Environmental reports for the site are available at yavapaijustice.com/Documents.

You said the County issued a report on the soil stained excavations. Where is that report?

Yavapai County Response: Environmental reports for the site are available at yavapaijustice.com/Documents.

If there is an aquifer as you say, and it has directional flow north, what prevents those chemicals from going downhill through Granite Creek to Watson Lake, which are north and downhill?

ADEQ Response: Based on technical information contained in ADEQ's files, it appears that at least a portion of groundwater flow from beneath the closed Sundog Ranch Landfill and Yavapai County property will migrate "downhill" and discharge through Granite Creek which flows to Watson Lake. So no underground hydrologic features are believed to completely prevent groundwater movement in that direction. However, the results of landfill groundwater monitoring performed from approximately 1983 to 1998 (about 15 years), indicate that there were no chemicals detected above Arizona Aquifer Water Quality Standards (AWQS) except for nitrate. The nitrate was believed to have originated from historical unlined ponds at the City of Prescott Wastewater Treatment Plant.

Why didn't Jack Fields tell the citizens of all of the County soil and water investigations?

Yavapai County Response: Environmental reports for the site are available at yavapaijustice.com/Documents.

Does disturbing the earth stir up some of the chemicals in the soils?

ADEQ Response: The 2015 Phase II surface soil sampling was conducted at 16 visibly stained soil areas at the Yavapai County property. The analytical testing showed no exceedances to soil cleanup standards except for one soil sample. This sample was collected at a one square foot stained area where discarded hydraulic lines were on the ground. The 16 surface soil samples were analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and eight RCRA metals. The soil sample next to the hydraulic lines contained arsenic at 85 mg/kg (the cleanup standard is 10 mg/kg). An Earth Technology study for ADEQ in 1991 indicated background maximum concentrations of arsenic in Arizona soil of up to 97 mg/kg, with an average of samples at 9.8 mg/ kg. As this sample fell within the maximum background range, the stained soil was left in place. Based on this data ADEQ does not think there are chemicals in the soil that would be stirred up from earth moving activities.

Should the County cease work while VOC sampling goes forward?

ADEQ Response: ADEQ cannot require Yavapai County to cease its work. The available surface soil and soil boring sampling results indicate that there is no unacceptable risk to human health from soil disturbance at the property, unless excavation to a depth of 20 feet was to occur at the area of the former residential UST system. As a precautionary measure, Yavapai County may wish to utilize a portable calibrated photoionization detector (PID) to field-screen for potential VOCs in air during soil disturbance activities. If VOCs above ambient background levels were detected, typical environmental practice would be to cease soil disturbance to protect against worker exposure, and then evaluate soil conditions for possible staining or other evidence of environmental impact.

Was a closure certification issued by ADEQ?

ADEQ Response: ADEQ does not issue closure certifications for landfills. The rules for landfills are listed in 40 CFR§258, Subpart F – Closure and Post Closure Care. This section requires that landfills must prepare a written closure plan that describes the steps necessary to close. These include items such as the final cover design and installation, inventory of waste during the landfills active life, and a schedule for completing closure activities. The owner/ operator then must “certify” that the closure has been completed in accordance with the official closure plan. Once this has been completed the landfill then begins its post-closure care period and that period is for 30 years.

How many contaminant bore holes were made on the entire property to assess the toxics present?

ADEQ Response: There were a total of 11 borings drilled on the property. Bore holes “B-2” and “B-8” were the only holes that showed exceedances. That report is located yavapaijustice.com/Portals/0/WTI2016-06-02PrescottLakesPPBunkerPhase2.pdf.

What other sites have been considered for the jail?

Yavapai County Response: Renovation of the 40-year-old facility located on Gurley Street in downtown Prescott was considered for the County’s criminal justice facility needs.

What was specifically in the underground storage tanks? How did previous owners or operators of the property neutralize the remains left in the tanks?

ADEQ Response: The substance in the “tar tanks” was believed to be an asphalt-like substance. The material was not neutralized, it was removed along with the soil that was impacted and send to a Subtitle D landfill. Subtitle D is the designation given to non-hazardous waste landfills.

Who selected Speedy and Associates and have they been vetted as credible?

Yavapai County Response: Speedie and Associates were selected by the Board of Supervisors on recommendation of the Yavapai County Facilities Department through a competitive process. Speedie and Associates is fully licensed and has performed this kind of work for several counties and other government entities in Arizona. Speedie and Associates reports are available at yavapaijustice.com/Documents.

How will toxins from soil run off be prevented from running into the Watson Lake used for recharging the city of Prescott’s drinking water?

ADEQ Response: A comprehensive Storm Water Pollution Prevention Plan (SWPPP) was submitted by Yavapai County for ADEQ’s review and approval in accordance with requirements. The SWPPP includes best management practices (BMPs) to protect against releases of fuels and other construction related chemicals, substances, supplies, and solid wastes that could potentially be transported off the property via storm water runoff. It also specifies the locations and types of measures to control against erosion and sediment transport on and off the property, respectively. The project will complete installation of control measures before each phase of earth disturbance has begun when feasible as identified in the SWPPP implementation schedule. The SWPPP also provides details on conducting regular inspections and implementing corrective actions as necessary.

Why would the land that is recorded as having a shooting range on it many years ago be treated and remediated as such, rather than treating it as not based on a lack of records?

Yavapai County Response: Records indicate that an organization named the Prescott Sportsman Club owned the justice center site for about 3 years, from 1954 to 1957. There is no evidence that the site was used as a formal shooting range at that time or any other time. Tests conducted for lead on the site confirmed lead levels BELOW remediation levels. Environmental reports for the site are available at yavapaijustice.com/Documents.

Please check the mileage distance to surrounding residences. The numbers you indicated do not appear right to me.

ADEQ Response: In letters received by ADEQ there were two different developments mentioned, Cliff Rose and Prescott Lakes. Cliff Rose shows a distance from the site of 3.17 miles, calculated using distance.to/102W-E-Gurley-St,Prescott,AZ,86301,USA/1200-Prescott-Lakes-Pkwy,Prescott,AZ,86301,USA. For Prescott Lakes, we used the address of the Club at Prescott Lakes. This address shows a distance from the site of 1.27 miles, calculated using distance.to/311-E-Smoke-Tree-Ln,Prescott,AZ,86301,USA/1200-Prescott-Lakes-Pkwy,Prescott,AZ,86301,USA.

I’m confused about the timing of the County's responses to ADEQ's request for soil vapor testing and a methane gas survey. Initial excavation is already underway — and the County will only perform tests in FUTURE months? Why weren't tests required before beginning excavation?

Yavapai County Response: The County conducted all legally required tests, as well as many tests that were not legally required before the start of construction. In an abundance of caution, the County agreed to follow ADEQ’s recommendation to conduct the soil vapor test (to confirm prior tests showing no VOC and SVOC presence) and methane tests (to confirm prior tests showing methane was not migrating from the City of Prescott landfill on to the site). Environmental reports for the site are available at yavapaijustice.com/Documents.

Map of proposed sampling locations provided to ADEQ by the County | View Map >

Why would the Yavapai County Criminal justice Center (YCCJC) development trigger more concern about this site than did the Juvenile Justice Center, the expansion of the Prescott sewer plant or the development of Prescott Lakes Parkway linking Rt89 to Rt69?

Yavapai County Response: Any observation on the differences would be speculation.

When was this landfilled used?

ADEQ Response: The Sundog Ranch Landfill began operation in 1930 and was closed by the City of Prescott in 2002.

Does this site effect the water in Prescott lakes?

ADEQ Response: ADEQ does not believe that the land disturbance activities associated with developing the YCCJC will affect the surface water quality in Granite Creek or Watson lake as long as the procedures and measures of the SWPPP are adhered to, and that conditions of the ADEQ Storm Water Construction General Permit are followed.

What soil remediation was done because of the gun club waste? Who completed that, when was that completed and signed off as completed?

Yavapai County Response: Records indicate that an organization named the Prescott Sportsman Club owned the justice center site for about 3 years, from 1954 to 1957. There is no evidence that the site was used as a formal shooting range at that time or any other time. Tests conducted for lead on the site confirmed lead levels BELOW remediation levels. Environmental reports for the site are available at yavapaijustice.com/Documents.

Do you feel work should continue before the additional testing is conducted?

ADEQ Response: The available surface soil and soil boring sampling results indicate that there is no unacceptable risk to human health from soil disturbance at the property, unless excavation to a depth of 20 feet was to occur at the area of the former residential UST system. As a precautionary measure, Yavapai County may wish to utilize a portable calibrated PID to field-screen for potential VOCs in air during soil disturbance activities. If VOCs above ambient background levels were detected, typical environmental practice would be to cease soil disturbance to protect against worker exposure, and then evaluate soil conditions for possible staining or other evidence of environmental impact.

Comments:

1. Thank you ADEQ for sharing this information. I truly hope Yavapai County meets the commitments that they have made to complete additional testing.
2. Thank you ADEQ, quite informative and your involvement has helped the public feel protected.
3. Yavapai County is constructing a jail. Not a prison. 
4. Prescott Lakes is a city subdivision that is served by city water, not individual wells.
5. With the multi-layer number of employees on that site daily, I find it interesting that not one employee has raised their hand about headaches and challenges with air.