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Final Release LLNL Site 300 (USD®E) <br /> level of remediation has been achieved, all further groundwater contamination on-site would be <br /> addressed by monitored natural attenuation (DOE 2003). It is important to understand that the <br /> EPA National Primary Drinking Water Standard of 5 ppb for TCE—the only contaminant ever <br /> detected off-site—will remain unchanged. <br /> Comment: <br /> The report assumes that the current cleanup activities will continue for the foreseeable future and <br /> at present levels. Every year the community is forced to lobby the DOE just to get the necessary <br /> funding to continue ongoing cleanup efforts. At the present time it seems unlikely that even the <br /> current cleanup activities will continue. <br /> Response: <br /> See the Response to the Comments under the Remedial Activities—Funding and Timeframe <br /> section of Appendix A. <br /> Comment: <br /> In recent years, the Site has not received much rainfall. There is agreement among the experts <br /> that in wet years the water table rises and the unlined waste pits become saturated. The <br /> contamination is then spread into the surrounding groundwater and soils. The last few relatively <br /> dry years have not allowed the plumes to migrate; therefore current data is skewed due to limited <br /> contaminant releases in the last several years. Rainfall totals have been recorded as high as 32 <br /> inches at Site 300 but the average rainfall for the last six years has been 10.4 inches. (Draft Site <br /> Wide Environmental Impact Statement,DOE 2004). <br /> Response: <br /> Pursuant to the requirements of the Comprehensive Environmental Response, Compensation, <br /> and Liability Act of 1980 (CERCLA), and under the oversight of the EPA, the California <br /> RWQCB, and the California Department of Toxic Substances Control, LLNL has conducted <br /> environmental sampling and investigations of chemical and radiological contamination both on <br /> and off-site areas of Site 300 since 1981. These data are extensive and span times of drought as <br /> well as times of heavy rainfall. The maximum annual rainfall at Site 300 was recorded in 1982- <br /> 83 when the site received 20.09 inches—the City of Livermore experienced 32.37 inches during <br /> this time period (LLNL 1994,DOE 2004). The average annual rainfall at Site 300 is 10.09 <br /> inches,based on data from 1965-1992 collected from the Site 300 weather station. Therefore, <br /> the average rainfall for the last 6 years, as reported in the Draft Site-Wide Environmental Impact <br /> Statement(DOE 2004), of 10.4 inches is only slightly (0.31 inches) above the historical average <br /> for Site 300. <br /> B-3 <br />