SITE INFORMATION AND CORRESPONDENCE

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. MEMORANDUM -CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - PALLYEREGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Wendy L. Cohen FROM: Michael Higgins Senior Engineer Project Engineer DATE: 19 January 1990 SIGNATURE: SUBJECT: MEETING SUMMARY AND DRAFT RCRA 3008 (h) ORDER, LAWRENCE LIVERMORE NATIONAL LABORATORY, SITE 300, SAN JOAQUIN COUNTY - CASE NO. 2677 On 9 January 1990, I attended a meeting convened by Lawrence Livermore National Laboratory Site 300 staff with agency staff listed on the attached sign-in sheet. The purpose of the meeting was for LLNL to get concrete statements from the agencies on future permitting requirements. For our part, I affirmed that the RWQCB will write waste discharge requirements (WDRs) on all wastewater discharges. The trichlorethylene (TCE) polluting much of the ground water at Site 300 may be a RCRA-waste, which would give EPA authority to write a RCRA permit. Since TCE is a hazardous waste, DHS has authority to write a treatment, storage, and disposal facility (TSDF) permit under Title 22. However, DHS agreed that a variance from Title 22 would be appropriate and EPA seemed to allow the same. EPA is still considering whether to include Site 300 on the National Priority List (NPL) . During the meeting, LLNL stated they are holding the draft Report of Waste Discharge (RWD) for off-site TCE contamination until they are sure the other agencies (mainly EPA) will not impose additional future requirements. I urged LLNL to submit the RWD right away to allow interim cleanup to begin as soon as possible. There has been substantial delay, as we sent the RWD forms to LLNL on 18 October 1989. They were supposed to apply for WDRs to begin interim extraction and treatment of the two VOC plumes that have escaped from the Site 300 General Services Area. The plumes, which are not yet completely defined, threaten drinking water supply wells on the Connolly Ranch and the California Department of Forestry property. The 3008(h) Order in preparation by FPA incorporates the time schedule from LLNL' s Octobl-r 1989 Wcrkplan. Mostafa Radmand of EPA g?vp me the preliminary draft -3008(h) order, which specifies i5 February 1990 as the deadline for LLNL to submit a report analogous to the RWD, characterizing the interim off-site ground water treatment and disposal option. This date may slip considerably because the 3008(h) order is a very preliminary draft and much is still handwritten. Also, the final draft will go to the facility for their comments, consuming more time. Recommendation The TCE plumes are continuing to move off-site. interim cleanup needs to begin as soon as possible. We should get the RWD from LLNL right away and urge them to start some interim cleanup to slow or halt the spread of the plume. MLH:gs