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California Regional Water Quality Control Board k Central Valley Region Karl E. Longley, Sc D. P.E..Chair Arnold Linda S. Adams 1 1020 ti:n,! :n!cr I)ri:r-2n0 Rancho��.�rdo�a-(:!!i(on,i� W�670-61 LJ ti,.(ICUI-r1W �< Schwa,ee/)w ger I hnnr(1161 36-1- _JI • F�1\Ulhl-163-4h4: C;ore�n�n In/I hap �c�c�� alerbomds ca mrccntrilcallr� PWIL1n��? RECEIVED 30 April 2009 MAY 0 4 2009 Ms. Leslie Ferry Lawrence Livermore National Laboratory ENVIRONMENTAL HEALTH P.O. Box 808, L-544 DEPARTMENT Livermore, CA 94551 SUBSTANTIVE REQUIREMENTS OF CLEAN WATER ACT SECTIONS 401 AND 404, LAWRENCE LIVERMORE NATIONAL LABORATORY EXPERIMENTAL TEST SITE (SITE 300)-BUILDING 850 SOIL REMOVAL ACTION CERCLA PROJECT, U.S. DEPARMENT OF ENERGY, SAN JOAQUIN COUNTY California Regional Water Quality Control Board, Central Valley Region staff has reviewed the 12 March 2009 letter submitted by Lawrence Livermore National Security, LLC (LLNS) on behalf of the U.S. Department of Energy (DOE), requesting consultation regarding proposed construction activities at Site 300. The construction activities are necessary to implement an approved Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) removal action that includes the excavation, solidification, and consolidation of PCB-, dioxin-, and furan-contaminated soil. The DOE constructed the Building 850 facility in 1960 and subsequently conducted high explosive experiments at the Building 850 firing table. These experiments included the destruction of approximately 1 ,000 capacitors which resulted in contaminating the soil with PCBs, dioxins and furans. Most of the soil removal will occur in a geographic bowl above the drainage; however., some removal of contaminated sediment and soil will be necessary within and crossing an ephemeral tributary to Elk Ravine, which is an ephemeral tributary to Corral Hollow Creek. The contaminated sediment will be excavated to a depth of one-foot from a 70-foot long stretch of the ephemeral West Branch Elk Ravine Tributary, followed by installation of rip-rap on top of a layer of permeable geotextile within the excavated portion of the channel. The p:.Irpose of the rip-ran and gectextile is to prevent erosin^ ard. scouring of streambel sediment. The excavated soil will be solidified and consolidated in a Corrective Action Management Unit (CAMU). The CERCLA action is a non-time critical removal action. An Engineering Evaluation/Cost Analysis for the Building 850 Soil Removal was approved by the regulatory agencies in January 2008. On 17 September 2008, DOE issued the Action Memorandum documenting the approval of the removal action remedy. CERCLA activities are not subject to the administrative requirements of the Clean Water Act. i.e. obtaining permits, as long as the substantive requirements are met. During construction of the CAMU, removal of contaminated sediment from the West Branch Elk Ravine Tributary. and enhancement of upstream drainage elements at Building 850, DOE/LLNL must comply with the substantive requirements of the Clean Water Act, specifically sections 401 and 404. California Environmental Protection Agency