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STA743F CALIFORNIA Ask GEORGE DEUKMEJIAN,Governor a vrCALIFORNiA REGIONAL WATER UALITY C T L OARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD SACRAMENTO,CA 95827-3098 4 January 19&- J AN 0 5 141Pc' ENVIROMENTAL HEALTH FERiViIT/SERVICES Mr. Robert 0. Godwin, Associate Director University of California Lawrence Livermore NationalLaboratory P. 0. Box 808 Livermore, CA 94550 SOLID WASTE ASSESMENT TEST PROPOSAL AND WAIVER REQUEST, UNIVERSITY OF CALI- FORNIA, ,LAWRENCE LIVERMORE, NATIONAL LABORATORY SITE 300, SAN JOAQUIN COUNTY I have reviewed two documents, the Solid Waste Assessment Test (SWAT) Proposal and SWAT Waiver Request, both dated 1 July 1987 for UC Lawrence Livermore National Laboratory (LLNL) Site 300. Specific Waste Management Unit (WMUs) subject to the SWAT requirements include landfill Pits 1 through 9, the burn pit facility, the high explosives (HE) Class II surface impoundment, 11 unlined HE lagoons, 16 drywells, and two discharge areas at Buildings 819 and 879, for a total of 40 'WMUs. Your SWAT proposal covered landfill Pits 8 and 9 and the burn pit, while the waiver request covered landfill Pits 1 , 3, 4, 5, 6, and 7, the HE surface impoundment and 7 HE lagoons. The basis for the waiver request in almost all cases was that a SWAT was unnecessary because contamination had already been detected and investigations were underway and/or because ongoing ground water monitoring could readily detect any leakage from the WMUs. However, under the law, the Regional Board may grant a waiver only if available "information demonstrates that hazardous wastes are migrating into the water." To the best of my knowledge no hazardous waste has migrated to the ground water from the WMUs: Therefore, the waiver request is denied in all cases. Recently enacted legislation exempts WMUs with a capacity of less than 50,000 cubic yards of solid waste from the SWAT process. A questionnaire will be developed in the next year or two to implement this new exemption process and many of LLNL`s WMUs may qualify. WMUs with known contamination (such as Pits 3, 4, and 5) or a high likelihood of contamination (such as a few of the drywells and lagoons) probably will not be able to receive this exemption. However, to give LLNL a full opportunity to take advantage of the new law, I have requested that all WMUs except Pit 6 be moved from Rank 2 to Rank 5 (SWATS due 1 July 1991 ) . I anticipate the State Board will ratify this change the next time they consider ranking changes which will be in September 1988. Since the SWAT process for Rank 2 has progressed so far, however, at least one WMU must stay in