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OMEMORANDUMIS CALIFORNIA REGIONAL WATER QU %NTROL BOARD - CENTRAL VALLEY REGION uN 3443 Routier Road �' Phone: (916) 361-5600 Sacramento, CA 95827-3098 .a 4 ATSS Phone: 8-495-5600 TO: Wendy L. Cohen ` �P�GLS FROM: Michael Higgins Senior Engineer �N��J� Project Engineer %r, DATE: 21 September 1989 SIGNATURE: SUBJECT: SUBCHAPTER 15 COMPLIANCE REVIEW, CLOSURE AND POST-CLOSURE PLANS FOR PITS 1 AND 7, LAWRENCE LIVERMORE NATIONAL LABORATORY SITE 300, SAN JOAQUIN COUNTY - CASE #2667 In a 3 February 10,89 memorandum, !fre addressed the compliance of LLNL' s 9 May 1988 Resource Conservation and Recovery Act (RCRA) Closure and Post-Closure Plans for Landfill Pits No. 1 and 7 (CP) with the California Code of Regulations, Title 23, Chapter 3, Subchapter 15 (Subchapter 15). On 29 December 1988, the Department of Health Services (DHS) issued a notice of deficiency (NOD) based on both agencies' review of the CP for compliance with RCRA regulations. LLNL's 8 June 1989 response to the NOD (revised closure plan) does not adequately consider Subchapter 15 requirements. Following are the comments and recommendations resulting from my review for Subchapter 15 compliance of LLNL' s revised closure plan. Siting Criteria and Construction Standards. The siting criteria for Class I landfills specified in Subchapter 15, Article 3 require the facility to be underlain by a sufficient thickness of natural geologic materials which have a permeability not more than 10" cm/sec. The permeabilities in the Pit 7 vicinity are on the order of 10' cm/sec, far greater than the siting criterion. Section 2546 requires that the precipitation and drainage controls accommodate the maximum probable peak storm runoff. Sections 2542 and 2543 require Class I landfills to have a clay liner and a leachate collection and removal system, respectively, as feasible. To close the landfills as Class I waste management units (WMUs) , LLNL must either comply with applicable siting criteria and construction standards or propose an engineered alternative. In the revised closure plan, LLNL proposes closure as a Class I landfill , but does not propose to implement the Subchapter 15 prescriptive and construction standards. This is not acceptable. To comply with Subchapter 15 requirements, LLNL must either comply with C..\- i.. a- .}- ! .sr _ f...,,� a^.�.v r'� ��+nrna+ � h rh ?rL.iA\.0,C t�1P damp Jubchapte 15 5Landards or i ecl-j milYcnul an i::i�y in....� ..� E, �,., uu�i�i� which ache i--ve: performance goals. Engineered Alternative. Under Section 2510(b) , alternatives to construction standards may be considered when the discharger has demonstrated that the standard is not feasible and there is a specific engineered alternative that is (1) consistent with the performance goal addressed by -the particular standard, and (2) affords equivalent protection against water quality impairment. To show the standards' infeasibility, LLNL must demonstrate that compliance with the standard is (1) unreasonably and unnecessarily burdensome and will cost substantially more than alternatives complying with the standard, or (2) is impractical and will not promote attainment of the applicable performance standard.