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f � Z Draft CMP/CP 2 22 June 2009 LLNL Site 300 San Joaquin County 4. Page 12, Section1.2.9.Building 812 (OU 9). In this section, DOE states that the Remedial Investigation/Feasibility Study (RI/FS) for the Building 812 OU is scheduled for completion in 2009. Since the completion date for the RI/FS has been extended due to the need to complete a soil washing pilot study prior to issuing the RI/FS, DOE needs to revise the expected completion date. 5. Page 14, Section 2.2. Remedial Action Objectives. DOE states in the second bullet "Prevent human ingestion of ground water containing contaminant concentrations (single carcinogen) above cleanup standards. Explain why DOE has "(single carcinogen)" after contaminant concentrations. 6. Page 46, Section 10.1.1.2. Increases in Contaminant Concentrations in Ground Water and Page 49, Section 10.1.2.2. Increases in VOC Concentrations in Soil Vapor. In both sections, DOE suggests increasing extraction treatment facility capacity as one of the responses to increasing contaminant concentrations. Explain how increasing facility capacity alone would mitigate increasing contaminant concentrations or explain that facility capacity would be increased in conjunction with increasing the wellfield extraction system by adding wells or increasing the pumping rate. 7. Page 46, Section 10.1.1.3. Impacts to Guard Wells. Please add a bullet to the possible actions that DOE may take in response to an impacted guard well stating that DOE would increase remedial efforts to stop further plume migration, such as "Expand remedial well field to stop plume migration." 8. Page 49, Section 10.1.2.2. Increases in VOC Concentrations in Soil Vapor. DOE states "If vapor zone contaminant concentrations increase in areas outside of active remediation, DOE will consider addition field investigations." Explain how DOE would know if increases outside the area of active remediation were occurring. DOE needs to explain if it has soil vapor monitoring points installed outside areas of active remediation and if so state the sampling frequency of these soil vapor monitoring points. 9. Appendix A, Ground Water Remediation Technical and Economic Feasibility Analysis Process Description. Include under technical feasibility analysis that DOE will analyze cost, effectiveness and time to cleanup to WQOs or background based on: • Optimization of the existing remedial system. • Installation of alternate remedial technologies such as in situ biological remediation and chemical reduction. 10.Table A-1. Please include the same footnotes to the MCL listed for chloroform on this table that DOE added to Table 2.11-1 in the 2008 Site-Wide Record of Decision for Site 300 (ROD). The footnotes states that the MCL is for trihalomethanes and that chloroform groundwater concentrations at Site 300 are well below the trihalomethane MCL of 80 micrograms per liter (ug/L) and are continuing to decline. The only change to the footnotes should be that the maximum concentration of chloroform in groundwater at Site 300 listed in the draft CMP is 3.2 ug/L, not 2.1 ug/L which was the maximum concentration at the time the ROD was issued.