Laserfiche WebLink
California l*ional Water Quality Cont Board a <br /> Central Valley Region Karl E.Longley,ScD,P.E.,Chair <br /> Arnold <br /> Linda S.Adams Sacramento Main Office Schwarzenegger <br /> Secretary for 11020 Sun Center Drive#200,Rancho Cordova;California 95670-6114 Governor <br /> Enviravnental Phone(916)464-3291 •FAX(916)464-4645 n 2 <br /> Protection http://www.waterboards.ca.gov/centTalvalley ''q Ir-'CENE <br /> DD <br /> JUN t 0 ,008 <br /> 17 June 2008 EIVVIR0/Vh1cN <br /> Ms. Claire Holtzapple <br /> PERIoIT/SERVNCEST H <br /> U.S. Department of Energy <br /> Livermore Site Office <br /> P.O. Box 808, L-293 <br /> Livermore, CA 94551-0808 <br /> DRAFT FINAL SITE WIDE RECORD OF DECISION, LAWRENCE LIVERMORE NATIONAL <br /> LABORATORY SITE 300, U.S. DEPARTMENT OF ENERGY, SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) has reviewed the May 2008 Draft Final Site-Wide Record of Decision (draft final <br /> SWROD), submitted on the behalf of the U.S. Department of Energy (DOE) by the Lawrence <br /> Livermore National Security, LLC. We have the following comments to be addressed in the <br /> Final SWROD: <br /> 1. Page 2-31, Section 2.8 Remedial Action Objectives. The first sentence of the first <br /> remedial action objective (RAO) under the heading "For Environmental Protection" states <br /> "Restore water quality to ground water cleanup standards within a reasonable timeframe <br /> and to prevent plume migration to the extent technically and economically practicable." <br /> State Water Resources Control Board Resolution No. 68-16 (Anti-degradation Policy) <br /> requires that the highest quality water be maintained to the maximum extent possible. The <br /> National Oil and Hazardous Substances Pollution Contingency Plan states that the <br /> technical impractibility waiver "is intended when compliance with an ARAR is not <br /> technically practicable from an engineering perspective. The criteria proposed for this <br /> waiver included engineering feasibility and reliability, with cost generally not a major factor <br /> unless compliance would be inordinately costly. Both standard and innovative <br /> technologies should be considered before invoking this waiver." Since DOE is not <br /> requesting an ARAR waiver, in order to comply with the State Anti-degradation Policy DOE <br /> must prevent plume migration to the extent technically feasible. Please remove the words <br /> "and economically" from the first sentence of the first RAO under the heading "For <br /> Environmental Protection". Also, for grammatical consistency, 'remove the word "to" before <br /> the phrase "prevent plume migration". <br /> 2. Page 2-36, Section 2.9.1.2. Risk and Hazard Management. DOE will continue to <br /> implement a risk and hazard assessment monitoring program which includes, in part, <br /> conducting wildlife surveys. DOE needs to explain in the final SWROD how these surveys <br /> are implemented. If there is a schedule and implementation plan for conducting the <br /> surveys, DOE needs to state where they are documented. If not, DOE needs to include the <br /> schedule and implementation plan in a revision of the September 2002 Compliance <br /> Monitoring Plan/Contingency Plan for Interim Remedies and report results in the semi- <br /> annual Compliance Monitoring Reports. <br /> California Environmental Protection Agency <br /> 'Fa Recycled Paper <br />