SITE INFORMATION AND CORRESPONDENCE

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Mr. James T. Davis -2- 3. In the active landfills, i.e. , pits 1 & 7, wastes are not covered within 24 hours of the time such hazardous wastes are placed therein as required in Section II,8, (b) , 12 of the and IX,1, (c) ISD and 40 CFR 304(d) . Radioactive wastes can be spread by wind outside these pits. Wildlife are also subject to contamination due to this lack of daily cover. 4. The groundwater monitoring requirements for the active haz- ardous waste landfills and surface impoundments have not been complied with as outlined in Section VII of the ISD and 40 CFR 265.91 and .92. The facility is in the process of assessing groundwater monitoring needs and has installed 2-3 wells downgradient and 1 well upgradient of each disposal pit. Implementation of an appropriate system, is planned for commpletion in May of 1983. The facility must implement groundwater monitor- ing as required by the Interim Status Document by May 30, 1983. 5. There are no closure or post closure plans for the disposal pits as required in Section V & VIII, 5 of the ISD and 40 CFR 265.112, 113, 115. 6. There is no estimate of closure and post closure costs as required in Section VI of the ISD, Department of Health Services/Hazardous Waste Management Branch's letter dated August 1, 1982 and 40 CFR 265.112, 142 and .144. 7. The Waste Analysis Plan does not specify adequate test methods, acceptable parameters or sampling methods as required in Section III, 3 of the ISD and 40 CFR 265.13. There is a Waste Analysis Plan dated February 12, 1982 but it does not clearly spell out these requirements. 8. Facility transports hazardous wastes to and from Lawrence Livermore National Laboratory in facility owned vehicles but is not registered as a Hazardous Waste Hauler with the Department of Health Services as required in Section 66420(a) of the California Administrative Code. 9. There was no written facility inspection schedule or inspection log as required in Section III, 5 of the ISD and 40 CFR 265.15(a) , (b) and (d) . 10. Wastewater from high explosive processing is clarified by settling out particles first in a gravity type separator, then passed through a compartmented settling tank and finally disposed of in surface impoundments. Facility has not analyzed wastes in settling tanks for heavy metals and organic degradation products nor analyzed for these substances plus radioactive wastes in the surface impoundment sediments to determine whether or not these hazardous wastes are present, as required in Sections I,4, (c) , III, 3of the ISD, 40 CFR 265.13 and Section 25200.5,(b) ,(1) of the California Health and Safety Code.