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LAWRENCE 'r,IVERMORE NATIONAL LABORATORY SITE 300 -2- 5 December 1988 Comments: LLNL should address the following deficiencies in a revised SWAT or SWAT addendum: 1. The report does not provide a complete sampling and analysis plan (SAP) including sampling and analysis specifications and quality assurance/quality control (QA/QC) procedu-res. However, on 19-21 July 1988, Regional Board staff conducted a Comprehensive Ground Water Monitoring Evaluation (CME) site inspection to evaluate the SAP during sampling of the MWs in the vicinities of two other landfills, Pits 1 and 7 . The 17 October 1938 CME report points out SAP deficiencies and recommends that LLNL »-rite a new stand-alone SAP document of sufficient detail and b--eadth to allow a sampling crew unfamiliar with past practices to correctly conduct the program. LLNL should use the new SAP, when available, in future Pit 6 monitoring, and should include it in the revised SWAT report or addendum. 2 . Although required by Article 4 , Section 13273 (b) (2) of the Water Code, the report does not characterize the soil-pore liquid in those areas likely to be affected if the landfi. 1 leaks. The report cannot conclude that the landfill does nct leak waste TCE at a hazardous concentration because LLNL did not sample the vadose zone in proximity to the Pit 6 bottom. LLNL should sample the soil-pore moisture directly beneath the landfill and should analyze these samples for the same suite of chemicals analyzed in the monitoring well samples. 3 . The report certification by the Registere41 Geologist (RG) is inadequate. In accordance with Section 13273 (b) of the Water Code, the RG should certify that the report contains the information specified in Sections 13273 (b) (1) and (2) (see attached certifica- tion language) . MLH:mlh