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California Regional Water Quality Control Board , <br /> \� Central Valley Region <br /> Karl E. Longley,ScD,P.E.,ChairmN:a~` <br /> Arnold <br /> Linda S.Adams 11020 Sun Center Drive 4200,Rancho Cordova,California 95670-6114I�4 1 Schwarzenegger <br /> Secrelaryfor Phone(916)464-3291 •FAX(916)464-4645 Governor <br /> Environmental http'//www.waterboards.ca.gov/centralvalley <br /> Protection RECEIVED <br /> 1 October 2009 <br /> ( 0 6 '009 <br /> C. Susi Jackson <br /> Environmental Protection Department ENVIRONMENTAL HEALTH <br /> P.O. Box 808, L-626 DEPARTMENT <br /> Livermore, CA 94551 <br /> WORK PLAN FOR THE EVALUATION OF POTENTIAL IMPACT TO GROUND WATER <br /> FROM PERCOLATION PITS AND SEPTIC SYSTEMS, WASTE DISCHARGE <br /> REQUIREMENTS ORDER NO. R5-2008-0148, LAWRENCE LIVERMORE NATIONAL <br /> LABORATORY SITE 300, LAWRENCE LIVERMORE NATIONAL SECURITY LLC AND U.S. <br /> DEPARTMENT OF ENERGY, SAN JOAQUIN COUNTY <br /> On 18 June 2009, California Regional Water Quality Control Board, Central Valley Region <br /> (Central Valley Water Board) staff received a letter responding to our 7 April 2009 comments <br /> on the March 2009 Work Plan for the Evaluation of Potential Impact to Ground Water from <br /> Percolation Pits and Septic Systems at Lawrence Livermore National Laboratory Site 300 <br /> (Work Plan). The Work Plan was required by Waste Discharge Requirements Order No. R5- <br /> 2008-0148 (Or%der). The Order states that the Work Plan "shall include a schedule for <br /> completing the work and submitting the final evaluation." The Order also states "If the <br /> Regiona; 'Water Board determines from review of the evaluation report that the effluent from <br /> septic systems poses a threat to groundwater, upon request of the Executive Officer the <br /> Discharger shall submit a work plan to the Regional Water Board for review and concurrence <br /> to install groundwater monitoring wells to determine if beneficial uses are being impacted." <br /> This letter contains additional comments on the Work Plan. Contingent on LLNL's addressing <br /> our additional comments in an addendum to the Work Plan, Central Valley Water Board staff <br /> concurs with the Work Plan. <br /> Monitoring and Reporting Program R5-2008-0148 (MRP) requires Lawrence Livermore <br /> National Laboratory Site 300 (LLNL) to evaluate groundwater up and dowgradient of Building <br /> 899, Building 850, Building 834 and Building 812 septic systems. LLNL should remove from <br /> the Work Plan specific references to monitoring and evaluation of wells up and down gradient <br /> of Building 899, Building 850, Building 834 and Building 812 septic systems for the following <br /> reasons: <br /> • The Work Plan proposes establishing groupings of septic systems based on similar <br /> geologic and hydrogeologic setting and use. After this is accomplished, LLNL will <br /> recommend representative septic systems to be evaluated in each grouping. <br /> • Monitoring of the septic systems at Building 899, Building 850, Building 834 and Building <br /> 812 conducted under Order No. R5-2008-0148 has shown that fecal and total coliform are <br /> not detected in groundwater downgradient of these septic systems. <br /> California Environmental Protection Agency <br /> C3 Recycled Paper <br />