United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-92/081
August 1992
SEPA Superfund
Record of Decision:
Lawrence Livermore National
Lab (US DOE), CA
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NOTICE t
The appenflces listed In the index that are not found hi this document have been removed at the request of
me issuing agency. They contain material which supplement, but ad^ no further appNcable formation to
the content of the document All supplemental matarial is, however, contained in the administrative record
forthissite.
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50272-101
I REPORT DOCUMENTATION 1" REPORTNO. 1 ~ 3. Recipient. Acce88Ion No.
PAGE EPA/ROD/R09-92/081
. 4. TIlle and Subll1le S. Report D8I8
SUPERFUND RECORD OF DECISION 08/05/92
Lawrence Livermore National Lab (US DOE) , CA
First Remedial Action - Final 6.
7. Au1hor(8) a. Performing Organlzallon Rapt No.
t. PerfonnIng 0rg8InIza1ion Name and Addrea 10. Project/TaaklWork Unit No.
11. Con1racI(C) Of Gr8l'lt(G) No.
(C)
(G)
12. Sponaorlng Organlzallon Name and Addrea 13. Type o' Report . Period Cov8recf
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. $uppIeIt-'aI, NoI88 '
PB93-964504
16. AbeIr8ct (LImit: 200 -rda)
The BOO-acre Lawrence Livermore National Lab (LLNL) site is a multidisciplinary
research facility located in Livermore, California. The site is owned by the
Department of Energy (DOE) and operated by the Regents of the University of California.
Land use in the area is predominantly industrial with an urban area to the west and
agricultural lands to the east of the LLNL facility. Wetlands at the site consist of
three small areas associated with .culverts that channel runoff from the surrounding
area into Arroyo Las positas at the northern perimeter of the site. About
10,000 people use the ground water, which is blended from several downtown Livermore
municipal wells, as their primary drinking water supply. The LLNL site was converted
from agricultural and cattle ranch land by the Navy in 1942, who used the site until
1946 as a training facility and for aircraft assembly and maintenance. Solvents,
degreasers, and paints were routinely used. Between 1946 and 1950, the site was used
as a naval reserve command training center, and in 1951, the Atomic Energy Commission
(AEC) began using the property as a weapons design and physics research laboratory. In
1977, DOE took over responsibility of the site. Investigations for suspected ground
water contamination at LLNL were prompted by the state beginning in 1984, when
(See Attached Page)
17. Docu- AnaIy8I8 .. De8cript0r8 Livermore National Lab
Record of Decision - Lawrence (USDOE), CA
First Remedial Action - Final
Contaminated Media: Sediment, gw
Key Contaminants: VOCs (benzene, carbon tetrachloride, chloroform, PeE, TCE), metals
(chromium, lead), radioactive materials (tritium)
b. IdentIfter8fOpen-Ended Terma
Co COSAn FIeId/Group
1 a. A¥IIII8IIII1ty Sta-. 19. s-atty CIaa (ThI8 Report) 21. No. of PIgoa
None 70
20. s-rtt, CIaa (Thia P8ge) 22. PrIce
None
2n (4-77)
(See AHSI-Z3I.18)
5"!" In8tnM:11on. Oft R-
(~ HT1S-35)
~lolCommerce
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EPA/ROD/R09-92/081
Lawrence Livermore National Lab (USDOE), CA
First Remedial Action - Final
Abstract (Continued)
perchloroethylene was discovered in the domestic supply well of a nearby property. LLNL
began supplying bottled water to local residents whose domestic wells had been affected
by solvents migrating from the LLNL facility. Between 1985 and 1987, the LLNL continued
the ground water investigations, which revealed that releases of hazardous materials had
occurred at the ~LNL site during the 1940's. Also in the post-Navy era, localized
spills, leaking tanks, surface impoundments, and landfills contributed VOC, FHC, metal,
and tritium contamination to ground water and unsaturated sediments. Prior to 1985, LLNL
conducted two significant removal actions. From 1982 to 1983, four former pits in the
Taxi Strip Area in eastern LLNL were excavated and backfilled; in 1984, a former landfill
was also excavated and backfilled. This ROD addresses a final remedy for the .
contaminated sediment and ground water at the LLNL site. An additional potential source.
of hazardous materials, the Trailer 5475 East Taxi Strip Area, has been identified and is
being investigated. If additional public health or environmental risks from this or
other sources are identified, this ROD may be augmented to address any additional
necessary actions. The primary contaminants of concern affecting the sediment and
groundwater are VOCs, including benzene, PCE, TCE, chloroform, and carbon tetrachloride;
metals, including lead and chromium; and the radioactive material, tritium.
The selected remedial action for this site includes treating unsaturated sediment at LLNL
onsite using vacuum-induced venting to extract contaminants in vapor form from the
sediment and treating the vapors by catalytic oxidation and/or activated carbon; pumping
~ater at 24 initial locations to contain and remediate the ground water plume using both
existing and new extraction wells; constructing seven onsite facilities (A-G) to treat
the extracted ground water, and each treatment system will be designed to treat the
specific combinations of compounds, including using ultraviolet/oxidation at facilities
A, B, E, and F to treat VOCs; using air-stripping based technologies at facilities C, D,
and G to treat the chloroform and carbon tetrachloride; employing ion exchange at
facility D to remove chromium; and using granular activated carbon (GAC) at treatment
facility F to remove lead, if necessary; using GAC at all facilities to remove
contaminants from air streams generated during treatment; onsite recharging or reusing of
the treated water at the LLNL site; and monitoring ground water until EPA, DOE, and the
state regulatory agencies agree that cleanup is complete. The estimated present worth
cost for this remedial action is $104,100,000, which includes an annual O&M cost of
$21,585,000 for 50 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific sediment and ground water clean-up
goals are the more stringent SDWA MCLs and California State MCLs and include benzene
1 ug/l, PCE 5 ug/l, TCE 5 ug/l, lead 15 ug/l, total chromium 50 ug/l, tritium less than
20,000 picocuries per litre, chloroform 100 ug/l, total trihalomethanes 100 ug/l, and
carbon tetrachloride 0.5 ug/l. Sediment of the unsaturated zone will be rernediated only
if it is predicted that it would result in concentrations above an MCL if allowed to
migrate into the ground water. Unsaturated zone remediation will be complete when
modeling shows that contaminants will no longer migrate and cause ground water to exceed
MCL. The CWA (NPDES) discharge limits for these chemicals will also be met if effluent
waters from the remedial treatment are discharged to ditches or arroyos onsite.
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./
Lawrence Livermore National Laboratory III.
University of California Livermore, California 94551 ~
..
UCRL-AR.I09105
Record of Decision
for the Lawrence Livermore'
National Laboratory
Livermore Site
July 15, 1992
.
Environmental Protection Department
Environmental Restoration Division
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UCRL-AR-I09105
Record of Decision
for the Lawrence Livermore
National Laboratory
Livermore Site
July 15, 1992
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UCRL-AR -109105
1.
Record of Decision
July 15, 1992
Contents
The Declaration.............................. ...... """'''''''' .... ....,.. """ ........... ........ ............. ...................... """'"'''' 1
2.
1.1.
Site Name and Location ............ ....... ........... """'"'''''''''''''''''''''''''''''''''''' ......... ............. ......... .... I
1.2.
S'tatement of Basis and Purpose .."'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 1
Assessment of Site .................... ........... ............. ......... .... ..,.... ......... .......... ......... ............. ............. 1
1.3.
1.4.
Description of the Selected Remedy.. """'"'''''''''''''''''''''' .................,.............. ...,......... ............. I
Statutory DetelTTlinations .. ........ ........... .................. ...... ..... ............................. .......... ...... '"'''''''''' 2
1.5.
Decision Summary ......... [[[ ......... ....... """'''''''''''''''''''''''''''''''' ......... .... 3
Site Name, Location, and Description [[[ 3
2.1.
2.2.1.
Site History and Summary of Enforcement Activities [[[ '''' 3
2.2.
2.2.2.
2.3.
Site History ..... ........................ ................ ................. "[[[ 3
Summary of Enforcement Activities '''''''''' .................................................. ............. .... 6
Highlights of Community Panicipation ................... ......................................... ............. ......... '''' 6
2.3.1.
2.3.2.
Background.................. ............................... ......... ........... ..... ................ ................ .......... 6
Community Involvement.... ........... ...... '"'''''''''''''''''''''''''''''''''' ........... """'"'''' ............. 7
2.3.2.1. Commmunity Meetings ......................... """""""'''''''''''''''''' ....... ...... ......... .... 7
2.3.2.2. Ground Water Update and PRAP Fact Sheet .................................................. 8
2.3.2.3. Information Repositories .................,............... ............. ............................... .... 8
2.3.2.4. Support to Offsite Well Monitoring Program '''''''''''''''''''''''''''''''''''''''''''''''''' 8
2.3.2.5. Tours and General Information Requests [[[ 8
Contact with Technical Assistance Grant Advisors......................................... 8
2.3.2.6.
2.3.2.7.
Future Community Involvement [[[ ............. "" 8
2.4.
Scope and Role of Response Actions ..'"'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 9
Site Characteristics... .,.. ............. ............. ........... .:........... ..... ................. ......... '"'''' ...................... II
2.5.
2.5.1.
2.5.2.
2.5.3.
2.5.4.
VOCs .......... .... ......... ...... '"'''''''' .... ......... ........... ..,.......... ......... """'" .... ......... ................ 11
Fuel Hydrocarbons... .... ............. ....... ...... ............. ..... ...... ......... ............. ............... .......... 14
Metals..... .....,.. ..... ......... .................. ......................................... ......... ............................. 14
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UCRL-AR-109105
Record of Decision
July 15,1992
2.6.1.1. Contaminant Identification [[[ ............. ... .......18
2.6.1.1.1. Media of Concern [[[18
2.6.1.1.2. ContaminantS of Concern [[[18
2.6.1.1.3. Concentrations of Chemicals of Concern Used in the
Risk Assessment...... ............. ....... ........... .......".............................. .19
2.6.1.2. Exposure Assessment ... ......... ...... ......... .................. ....... ...... ........... ........... .....19
2.6.1.2.1. Exposure Pathways [[[ ..........19
2.6.1.2.2. Potentially Exposed Population [[[ .19
2.6.1.2.3. Exposure Point Concentration Estimates ........................................19
2.6.1.2.4. Exposure Frequency and Duration .................................................20
2.6.1.3. Toxicity Assessment..................... ........... .... ........... ....... ................. ......... .......20
2.6.1.3.1. Cancer Potency Factors ........,............... ............. ...................... ....... 20
2.6.1.3.2. Reference Doses for Noncarcinogens .............................................20
2.6.1.4. Risk Characterization..... .......... .................... ......... ...... ....... ..,.......... ................ 21
2.6.1.4.1. Carcinogenic Risks ............... .....................................,...... ..............21
2.6.1.4.2. Potential for Noncarcinogenic Effects ............................................21
2.6.1.4.3. Combined Carcinogenic Risks and Hazard Indices ........................22
2.6.1.4.4. Sources of Uncertainty [[[22
2.6.1.5. Environmental Risks.......... ......... ................. ........... ........... .............................23
2.6.1.6. Risk Assessment Conclusions [[[23
2.7.' . Description of Remedial Alternatives .... ............. .............,.. ............. ............... ...........................23
2.7.1. No-Action Alternative. ................ .... ......... ........... ................. ........... ...................... .......24
2.7.2. Ground Water Remedial Alternatives ............................................. .................... ......... 25
2.7.2.1. Ground Water Remedial Alternative NO.1 (The Selected
Alternative) .... ............. ..................................... ....... ........................... .............25
2.7.2.1.1. Ground Water Extraction Plan for Remedial
Alternative No. I-Complete Capture and Source
Area Extraction.......... ..........,................. .... '''''''''' .....,.... ................25
2.7.2.1.2. Treatment Options for Ground Water Remedial
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UCRL-AR-109lO5
Record of Decision
July 15,1992
2.7.2.3. Ground Water Remedial Alternative NO.3-Deferred Action ........................30
2.7.2.3.1. Treatment Options for Ground Water Remedial
Alternative No.3.................. ..... ................................................ .....32
2.7.2.4. Comparison of Ground Water Treatment Option Costs .................................32
2.7.3. Unsaturated Zone Alternatives ... ....... .... ..,...... ............. ..... ............. ............. ........ ..... .....32
2.7.3.1.
2.8.
Unsaturated Zone Remedial Alternative No. I-Vacuum-
Induced Venting (the Selected Alternative) [[[32
Unsaturated Zone Remedial Alternative NO.2-Deferred
Action............... [[[ 34
2.7.3.3. Comparison of Unsaturated Zone Treatment Option Costs ............................34
Summary of the Comparative Analysis of Alternatives [[[34
2.8.1. Ground Water ................. .."..... .... ......... ......... ............. .....,...... ........ ........" ................ .....39
2.7.3.2.
2.9.
2.8.2. Unsaturated Zone..... ........,.. ..... .......... .......................... ..." ............... ............... ............. .40
The Selected Remedies .................. .............................................."..................... ......... ...... ....... .41
2.9.1. Ground Water.. ................. .............. ................... ............... ........... ........... ...................... .41
2.9.2. Unsaturated Zone............................... .....,.............. ................... ......................... ...........42
2.10. Statutory Determinations [[[ ........................ .... .43
2.10.1. Protection of Human Health and the Environment[[[43
2.10.2. Compliance with ARARs [[[ ...... ..............4 3
2.10.3. Cost -Effecti veness... ................... ..................... ......... .................. ............. .....................4 3
2.10.4. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable [[[43
2.10.5. Preference for Treatment as a Principal Element [[[44
References........................................ ....... ........,.... ................... ......... ............... ........... ..... ............... ...... ........45
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UCRL-AR-109105
Figure l.
Figure 2.
Figure 3.
Figure 4.
Figure 5.
Figure 6.
Figure 7.
Figure 8.
Figure 9.
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Record of Decision
July 15,1992
List of Figures
Location of the LLNL Livennore site ....................."...................................... ................ ........ 4
The LLNL site and surrounding area [[[ 5
Isoconcentration contour map of total VOCs in ground water............................................... 12
Area where one or more VOCs in ground water equals or exceeds Federal or California
Maximum Contaminant Levels (MCLs) [[[ ..........13
Isoconcentration contour map of total fuel hydrocarbons (FHCs) in ground water.
Gasoline Spill Area, March 1989 ............................... ......... ........... ............... ......... ................ 15
A~as that exceed the Maximum Contaminant Level (MCL) for total chromium (50
ppb), lead (15 ppb). and tritium (20,000 picocuries per liter) ................................................16
Preliminary ground water extraction and treatment facility locations....................................27
Predicted ground water flow pathways for Extraction Alternative .
No. 1-Complete Capture and Source Remediation ..................................."...................... ...28
Predicted ground water flow pathways for Extraction Alternative
No. 2-Downgradient Control.......................................... ...,........................... ............. ......... 31
List of Tables
Remediation standards and State discharge limits for compounds of concern in ground
water at the LLNL site [[[10
Cancer potency values for carcinogenic chemicals of concern (Layton el ai.. 1990) ............20
Reference doses for noncarcinogenic chemicals of concern (Lay~on el ai., 1990) ................21
No-remediation-scenario cancer risk and hazard index (HI) values using the U.S. EPA
methodology (U .5. EP A, 1989a) [[[" ...22
Summary of costs for ground water remedial alternatives for the LLNL Livennore site ......26
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UCRL-AR-109105
. Record of Decision
July 15,1992
1. The Declaration
1.1. Site Name and Location
The Lawrence Livennore National Laboratory (LLNL) Livennore site, located at 7000 East
Avenue, Livennore, California, is a research and development facility owned by the U.S.
Department of Energy (DOE) and operated by the University of California. LLNL was placed
on the U.S. Environmental Protection Agency's (EPA) National Priorities List (NPL) in 1987.
Currently, about 10,000 people use ground water blended from several downtown Livermore
municipal supply wells as their primary drinking water supply. Contaminants from LLNL are
currently about 1.6 miles from these supply wells. U.S. EPA, in conjunction with the California
Department of Toxic Substances Control (DTSC) and the California Regional Water Quality
Control Board (RWQCB), oversees LLNL's investigations and cleanup activities in accordance
with Section l20 of the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended.
1.2. Statement of Basis and Purpose
This decision document presents the selected remedial actions for the LLNL Livennore site,
in Livermore, California, which were chosen in accordance witb CERCLA, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision
document is based on the administrative record for this site.
The U.S. EPA, the RWQCB, and the DTSC of the California Environmental Protection
Agency, fonnerly the California Depanment of Health Services (DHS), concur with the selected
remedies.
1.3. Assessment of Site
The identified compounds of concern, if not addressed by the selected remedies or other
considered measures, may present a potential risk to public health as discussed in the Proposed
Remedial Action Plan (PRAP) for the site.
1.4. Description of the Selected Remedy
The Feasibility Study (FS) evaluated many potential remedies for the LLNL site. Those
remedies were divided into two general groups, according to whether the chemical contaminants
are in ground water or in unsaturated sediment (Le., sediment above the water table where pore
spaces are only panially filled with water). Three alternatives were evaluated for the ground
water plume, and two remedies were evaluated for the unsaturated zone (Le., the interval above
the water table wher~ pore spaces are only panially filled with water).
The selected remedy for ground water is Remedial Alternative No.1 from the FS, which
includes:
.
Pumping water at 18 initial locations to contain and remediate the ground water plume.
Water will be pumped from one or more wells at each of these locations using existing
monitor and extraction wells, along with new extraction wells. The initial well locations
will be chosen to prevent any contaminants, primarily volatile organic compounds
(VOCs), from escaping from the current plume area in concentrations above their
Maximum Contaminant Levels (MCLs). To enable more rapid remediation, wells will
also be placed in all areas with" higher concentrations [i.e., greater than about 1 00 pam
per billion (ppb) VOCs or fuel hydrocarbons (FHCs)]. The initial 18 locations will be
augmented when field data indicate that new pumping locations will speed the cleanup.
1
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UCRL-AR-109105
Record of Decision
July 15,1992
Constructing about seven onsite facilities (A to G) to treat the extracted ground water.
Each treatment system would be designed to treat the specific combination of compounds
in the associated extraction wells.
. Using ultraviolet (UV)/oxidation-based remediation technology to treat VOCs at
Treatment Facilities A, B, and E, and FHCs and VOCs at Treatment Facility F.
Treatment Facilities C, D, and G would use air-stripping-based technology, which is
more effective on the higher concentrations of specific compounds in the area of those
facilities (chloroform, carbon tetrachloride, Freon 113, and I, I, I-trichloroethane).
Treatment Facility D will employ ion exchange to remove chromium, and Treatment
Facility F will use granular activated carbon (GAC) to remove lead, if necessary.
. .
The selected remedy fonreating the unsaturated zone is Remedial Alternative No. I from the
FS. This alternative includes using a process called vacuum-induced venting to extract the
contaminants in vapor form from the unsaturated sediments, and treating the vapors by catalytic
oxidation and activated carbon.
.
The selected remedies address the principal concerns at the LLNL site by removing
contaminants in ground water and soil vapor and treating them at the surface to levels protective
of human health and the environment.
This Record of Decision (ROD) applies to all known contaminants in ground water and
unsaturated sediment originating from activities at the LLNL site. An additional potential source
of hazardous materials (i.e., the Trailer 5475IEast Taxi Strip Area) was identified after
completion of the PRAP on the LLNL site. If future investigations identify additional public
health or environmental risks from this or other potential sources, this ROD may be augmented
through CERCLNSARA and the NCP to address any additional action.
1.5. Statutory Determinations
The selected remedies are protective of human health and the environment, comply with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and are cost-effective. The remedies utilize permanent solutions and alternative
treatment technology; to the maximum extent practicable, and satisfy the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element.
Because these remedies may result in hazardous materials remaining onsite above health-based
levels until cleanup is complete, a review will be conducted within 5 years after commencement
of remediation to assure that the remedies continue to provide adequate protection of human
health and the environment.
l£.MA<- eX /J7 L - k-
Da iel W. McGovern U
Regional Administrator, EPA: Region IX
0!.
,---," ~."
J~es T. Davis
~cting Manager, DOE San Francisco Field Office
f-S'"-'z..
Date
-~-:....,
?hJA~z-
~ Date
2
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UCRL-AR-109105
Record of Decision
July 15,1992
2. Decision Summary
2.1. Site Name, Location, and Description
LLNL is a multidisciplinary research facility owned by DOE and operated and managed by
the Regents of the University of California under contract with DOE. LLNL is located at 7000
East A venue in southeastern Alameda County, approximately 3 miles east of the downtown area
of Livermore, California (Fig. 1). The LLNL site, including the adjacent buffer zone, comprises
approximately 800 acres (Fig. 2). The site is heavily developed with large-scale experimental
research and support facilities. About 223 storage tanks exist onsite, 46 of which are
underground tanks that currently store hazardous materials. A stormwater drainage retention
basin roughly 800 feet by 300 feet in size is situated near the center of LLNL. This basin was
recently lined to prevent infiltration of ponded surface water.
The LLNL- site land surface slopes approximately 1 % to the nonhwest. Hills of the Diablo
Range flank the site to the south and east. The site is underlain by several hundred feet of
complexly interbedded alluvial and lacustrine sediments.
Ground water beneath the site is panly within the Spring and Mocho I hydrologic subbasins
(DWR, 1974). Depth to ground water at the site varies from about 120 feet in the southeast
corner to about 25 feet in the nonhwest comer. Ground water about 2 miles west of LLNL is
used for municipal supply in downtown Livermore. Ground water about 1,000 feet south of East
Avenue and about 1,000 feet west of Vasco Road and south of East Avenue is used for domestic
and agricultural irrigation. Two intermittent streams, the Arroyo Seco and the Arroyo Las
Positas, traverse the area (Fig. 2) and recharge the ground water system during wet periods.
Land immediately nonh of the LLNL site is zoned for industrial use. To the west, the land
use is zoned for high-density urban use. Sandia National Laboratories (SNL), Livermore are
located south of the site (Fig. 2) in an area zoned for industrial development. The area east of
LLNL is zoned for agriculture and is currently used as pasture land [LLNL Remedial
Investigation (RI), Thorpe er al., 1990].
As reponed in the Draft Environmental Impact Statement and Environmental Impact Repon
for LLNL and Sandia National Laboratories, Livermore (DOE and t,Jniversity of California,
1992), no threatened or endangered species are present at the LLNL Livermore site. Wetlands
are very limited at the Livermore site and consist of three small areas associated with culvens
that channel runoff from the surrounding area into Arroyo Las Positas at the nonhero perimeter
of the site (DOE and University of California, 1992). .
2.2. Site History and Summary of Enforcement Activities
2.2.1. Site History
The LLNL site was convened from agricultural and cattle ranch land by the U.S. Navy in
1942. The Navy used the site until 1946 as a flight training base and for aircraft assembly,
repair, and overhaul. Solvents, paints, and degreasers were routinely used during this period.
Between 1946 and 1950, the Navy housed the Reserve Training Command at the site. In 1950,
the Navy allowed occupation of the site by the Atomic Energy Commission (AEC), which
formally received transfer of the propeny in 1951. Under the AEC, the site became a weapons
design and basic physics research laboratory. In 1952, the site was established as a separate pan
of the University of California Radiation Laboratory. Responsibility for the site was transferred
from .\EC to the Energy, Research, and Development Administration in 1975. In 1977,
responsibility for LLNL was transferred to the DOE, which is currently responsible for the site.
In addition to weapons research, LLNL programs have been established in biomedicine, energy,
lasers, magnetic fusion energy, and environmental sciences. Details of the site history and the
3
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UCRL-AR-1091U5
Record of Decision
July 15,1992
Miles
o 5 10 15 20
C::::i:::::t:=t
ER[).LSR.gl.(1252
Figure 1. Location of the LLNL Livermore site.
4
-------
-...-...-
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FIgure 2. The LLNL sIte and surroundIng area.
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UCRL-AR-109105
Record of Decision
July 15,1992
use, storage and disposal of hazardous materials are presented in the Remedial Investigation (RI)
(Thorpe et aI., 1990).
2.2.2. Summary of Enforcement Activities
The LLNL site was in operation prior to the enactment of the Resource Conservation and
Recovery Act of 1976.
The first regulatory order for the LLNL ground water problem was a compliance order issued
in 1984 by. the California Department of Health Services (DHS) (now the Department of Toxic
Substances Control of the California Environmental Protection Agency). This order required
LLNL to investigate ground water quality and to supply bottled water to local residents whose
domestic wells had been affected by solvents migrating in ground water from LLNL. At the time
this order was issued, the ground water investigation was already underway, and bottled water
had been supplied to those local residents since December 1983. All private wells affected by
the solvents were permanently sealed by LLNL between 1985 and 1989. In 1985, the RWQCB
issued Waste bischarge Requirements to define the venical and lateral extent of ground water
contamination, and to allow discharge of ground water during the investigation. Between 1986
and 1991, the RWQCB issued four Waste Discharge Orders and tWo Site Cleanup Orders for the
LLNL site. Currently, two RWQCB Orders are in effect at LLNL. Order No. 88-075 allows
discharge of treated water from pilot Treatment Facility A to a recharge basin south of East
Avenue. Order No. 91-091 allows discharge of treated ground water from LLNL treatment
facilities to ditches and arroyos, and recharge of treated ground water via infiltration trenches and
recharge wells.
Between 1985 and 1987, the RWQCB was the lead regulatory agency for the LLNL ground
water investigation. In 1987, LLNL was added to the National Priorities List, as amended. In
November 1988, DOE, U.S. EPA, DTSC, and RWQCB signed a Federal Facility Agreement
(FFA), which named DOE as the overall lead agency and the U.S. EPA as the lead regulatory
agency.
LLNL conducted two significant removal actions prior to 1985. Four former pits in the Taxi
Strip Area in eastern LLNL were excavated and backfilled in the winter of 1982-83 under the
oversight of the RWQCB. In 1984, a former landfill was excavated and backfilled with
oversight by the DHS.
In May 1990, LLNL issued the CERCLA Remedial Investigations Report for the LLNL
Livermore Site (RI) (Thorpe et al., 1990). In December 1990, the CERCLA F easibiliry Study for
the LLNL Livermore Site (FS) (Isherwood et al., 1990) was issued, and, in October 1991, the
Proposed Remedial Action Plan for the LLNL Livermore Site (PRAP) (Dresen et aI., 1991) was
submitted. The Notices of Availability for the PRAP were published in three local newspapers
on October 18, 1991, and again on November 19 and 20, 1991, when the comment period on the
PRAP was extended. These documents, and all other documents that are the basis for selecting
the cleanup remedies for the LLNL site, are contained in the Administrative Record for LLNL,
which is located at the LLNL Visitors Center. The LLNL Visitors Center can be accessed from
the Greenville Road (east) entrance to LLNL.
2.3. Highlights of Community Participation
2.3.1. Background
The LLNL ground water problem was brought to the attention of the local community in
December 1983, when perchloroethylene (PCE) was first discovered in the domestic supply well
of a former rental property nonheast of the intersection of Vasco Road and East Avenue.
LLNL's immediate action was to sample private wells and deliver bottled water to nearby
residents whose wells had been affected. LLNL periodically surveyed these households, located
6
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UCRL-AR-109105
Record of Decision
July 15,1992
south, southwest and west of LLNL, to ensure that residents were receiving bottled water to meet
their water needs, and that the water was arriving in a timely manner. Subsequently, LLNL
provided free municipal (City of Livermore) water hookups to the affected households. LLNL
also began a regular private well sampling program. In all cases, testing results were (and
continue to be) shared with the residents either through telephone calls, personal visits, or follow-
up letters that include written sampling results.
In May 1988, LLNL and DOE held a general infonnation meeting for the community on the
ground wat~r investigation with key Ground Water Project staff. In addition, LLNL and DOE
have responded and continue to respond to requests from the public for information.
LLNL staff conducted interviews between April and July of 1988 with appro~imately 45
individuals, groups, and agencies to investigate their concerns and information needs regarding
the Livermore site cleanup. The results of these interviews formed the basis for the Community
Relations Plan that LLNL issued in May 1989. Copies of this plan were made available to the
public, and placed in the information repositories located at the Livermore Public Library and at
the LLNL Visitors Center.
The specific objectives of the LLNL Livermore Site Community Relations Program are to:
. Continue providing interested members of the community with timely information about
technical activities and findings.
. Provide ongoing opponunities for two-way communication between the LLNL Ground
Water Project and the community.
. Establish effective communication with local elected and administrative officials.
.. Remain alen to the community's needs and concerns about the Ground Water Project and
other LLNL activities.
2.3.2. Community Invoh'ement
Tqe LLNL Community Relations Program communicates with the public through six
primary methods:
1. Meetings with a Community Work Group (CWG).
2. Distribution of a quanerly newsletter called the Ground Water Project Update and fact
sheets.
3. Maintenance of the two infonnation repositories.
4. Suppon to those responsible for offsite water samples and water level surveys.
5. Setting up tours and responding to general infonnation requests.
6. Meeting with members of the public, including the Technical Advisors hired by a local
community group as pan of the EPA Technical Assistance Grant (TAG) Program.
Each of these activities is described below.
2.3.2.1. Community Meetings
LLNL established the CWG in 1988 to provide an ongoing forum to advance understanding
of technical issues and project decisions, community interests, and the Superfund process
throughout the course of the LLNL Ground Water Project. The group is composed of private
individuals, representatives of a local, community group, and representatives of U.S. EPA,
RWQCB, and DTSC. The CWG meets quanerly, and sometimes more often, depending on the
status of the technical and regulatory aspects of the Ground Water Project. LLNL has worked to
7
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UCRL-AR-109lO5
Record of Decision
July 15,1992
distribute and explain technical information to the CWG and identify key issues of concern.
LLNL has taken steps to respond to those concerns by providing additional information, making
changes to certain aspects of the project or, when changes are not possible, by providing the
reasons for not taking the proposed action. CWG meetings are open to the public.
A public meeting on the PRAP was held on November 6, 1991, as required by the CERCLA
process. About 80 people attended the meeting. The Notice of Availability for the PRAP was
published in three local newspapers on October 18, 1991. The public comment period on the
PRAP extended from October 18 to December 18, 1991. All comments on the PRAP are
addressed in Attachment A. the Responsiveness Summary, to this ROD.
2.3.2.2. Ground Water Updilte and PRAP Fact Sheet .
Distributed on a quarterly basis, the Ground Water Project Update reflects LLNL's desire to
regularly inform the community about the Ground Water Project. This multipage fact sheet is
distributed to more than 1,800 individuals and organizations. The first edition was published in
June 1989.
A fact sheet on the PRAP was disttibuted in October 1991 prior to the opening of the public
comment period on the PRAP. The fact sheet was written specifically to facilitate community
understanding of the PRAP.
2.3.2.3. Infonnation Repositories
LLNL established two information repositories in 1989 to provide locations for interested
members of the public to review project-related reports. One repository is located at the
Livermore Public Library, 1000 South Livermore Avenue, the other is at the LLNL Visitors
Center on Greenville Road. The Visitors Center also contains the Administrative Record, which
is comprised of all the documents that form the basis for LLNL's final cleanup plan.
2.3.2.4. Support to Offsite Well Monitoring Program
The Ground Water Project arranges sampling times and locations that are convenient to
those residents and businesses affected by the offsite well monitoring program. Followup
includes mailing a letter that explains the significance of the results.
2.3.2.5. Tours and Generallnfonnation Requests
Tours have been conducted on request for interested members of the public and for the
press. In 1991, tours were conducted of the pilot study treatment units for CWG members and
the press. On LLNL Family Day of 1990, special sitewide tours for a number of interested
groups were conducted. Requests for general information are handled by community relations
staff or appropriate LLNL staff.
2.3.2.6. Contact with Technical Assistance Grant Advisors
A local citizens group hired two technical advisors under a grant approved by U.S. EPA and
funded by the DOE as part of the TAG program. The technical advisors have attended CWG
meetings and have submitted comments to LLNL regarding project reports. LLNL provided
copies of project documents, conducted tours. responded to the advisors' queries, and held an a11-
day meeting with these advisors in July 1991. LLNL also provided one of the advisors with
work space and resources for a week to review project-related documents.
2.3.2.7. Future Community Involvement
DOE and LLNL are committed to maintaining community involvement throughout the
cleanup. If desired by the local community, DOEILLNL will continue to support a CWG. CWG
meetings may be used to brief TAG advisors, if desired. Progress of the cleanup will also be
8
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UCRL-AR-109105
Record of Decision
July 15,1992
reported to the regulatory agencies and the community in Monzhly Progress Reports. As
required by CERCLA, the Community Relations Plan will be updated after the ROD is signed.
2.4. Scope and Role of Response Actions
The remedial alternatives described in the FS (Isherwood et al., 1990) and the PRAP (Dresen
et aI., 1991) are summarized in this ROD and address VOCs, FHCs, chromium, and lead in
ground water, and FHCs and VOCs in sediment above the water table (the unsaturated zone). In
addition, tiitium has been detected locally in the soil and ground water, but as described in
Section 4.2.1 of the PRAP, tritium at LLNL is self-remediating via natural decay and does not
require cleanup. There is no significant way for people to be exposed to the contaminants in the
unsaturated zone at LLNL except by migration of the contaminants to the ground water.
This ROD addresses all known ground water and unsaturated zone contamination and any
resultant hum~ health and environmental risks, and incorporates the results of LLNL pilot
studies. Amendments to this ROD may be made in the future to address significant new or
additional contaminants and/or source areas or other unforseen conditions.
The cleanup objectives for all contaminants originating at LLNL are to:
I. Prevent future human exposure to contaminated ground water and soil.
2. Prevent further migration of contaminants in ground water.
3. Reduce contaminant concentrations in ground water to levels below MCLs, and reduce
the contaminant concentrations in treated ground water to levels below State discharge
limits (Table I).
4. Prevent migration in the unsaturated zone of those contaminants that would result in
concentrations in ground water above an MCL.
5. Meet all discharge standards of existing permits for treated water, and to treat vapor so
that there are no measurable atmospheric releases from treatment systems.
The selected remedial alternatives will achieve these cleanup objectives and address all of the
principal concerns at the site by removing the hazardous compounds from the ground water and
subsurface soil, when warranted, and treating them at the surface at about seven onsite facilities.
Ground water extraction will contain contaminant plumes, stop further migration of
contamir.ants in ground water, and prevent any human exposure to them via water wells. The
ground water treatment facilities will use different reP'lediation technologies appropriate for the
different influent contaminants and will be designed to reduce contaminant concentrations in the
treated ground water to levels below established State discharge standards.
Ground water extraction and treatment will continue until the Federal and State agencies
agree that the remediation standards have been m.et. The target objective is to reduce the
concentrations in the ground water after cleanup to levels below MCLs (Table 1).
The ground water remediation standards in Table 1 are the lower of the Federal or State
MCLs, and apply to the concentrations remaining in the ground water after remediation is
complete. Ground water cleanup is complete when samples taken anywhere in the plume
demonstrate that the remediation standards have been achieved. The discharge limits in Table 1
apply to the effluent water from treatment systems that may be discharged to ditches or arroyos.
Although some discharge limits are lower than MCLs, remediation will continue until the
remediation standards are met.
Volatile contaminants in the unsaturated zone will be removed by extracting them in vapor,
which will be treated on site. Atmospheric emissions from treatment systems will comply with
9
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UCRL-AR-I09105
Record of Decision
July 15,1992
Table l. Remediation standards and State discharge limits for compounds of concern in ground water at
the LLNL site.
Concentration limit for drinking water8
Pre-remediation
concentration
range at LLNL,
Federal California March 1990- Discharge limitb for
MCL MCL March 1991 treated water
Constituent (ppb) (ppb) (ppb) (ppb)
PCE 5 5 <0.1-1,OSO 4
TCE 5 5 <0.1-4,800 5
1,I-DCE 7 6 <0.5-370 5
cis-l,2.DCE 70 6 <0.5-24 5 (totall,2-DCE)
trans.l,2-DCE 100 10 <0.5-1 5
1,I-DCA 5 <0.5-60 5
1,2-DCA 5 0.5 <0.1-190 5
Carbon tetrachloride 5 0.5 <0.1-91 5
Total THMC 10()c 10()c <0.5-270 5
Benzene 5 1.0 <0.1-4,600 0.7
Ethyl benzene 700 680 <0.2-610 5
Toluene 1,000 <0.5-4,200 5
Xylenes (total) 10,000 1,75()d <0.5-3,700 5
Ethylene dibromide 0.05 0.02 <0.1-51 0.02
Total VOCs up to 5,808 5
Chromium+3 50 (total Cr)e 50 (total Cr) <5-150 (total Cr) 50 (total Cr)
Chromiupt+6 50 (total Cr)e 50 (total Cr) <10-140 11
Lead 15' SO d-l0 5.6
Tritiumg 20,000 pCilL 20,000 pCiIL <200-33,100 (h)
a Human receptor. The more stringent concentration limits on this part of the table are shown in a larger t~"peface to
illustrate that LL~L will comply with the most stringent requirements.
b From :'\ational Pollutant Discharge Elimination System (SPDES) Permit :'\0. CAOO29289 (revised 8/1190) and RWQCB
Order So. 91-091. Of the LL~L compounds of concern, VOC-specific State discharge limits exist In RWQCB Order
~o. 91-091 only for PCE (4 ppb), benzene (0.7 ppb), and ethylene dibromide (0.02 ppb). Other VOCs listed In this table
are included In the 5 ppb total VOC limit. Discharge limits for metals dltTer slightly according to discharge location.
C Total trihalomethanes (THMs); Includes chloroform, bromoform, chlorodibromomethane, and bromodichloromethane
(California Drinking Water Requirement).
d :\ICL is for either a single Isomer or the sum of the ortho, meta, and para isomers.
e Sational Interim Primary Drinking Water Regulation for total chromium is presently 50 ppb, but will increase to 100
ppb in July 1992. So :\ICLs exist for Cr+3 or Cr+6.
r Sational Primary Drinking Water Regulation Enforceable Action Lenl (Federal Register, volume 56, number 110,
June 7, 1991, p. 26460).
g The RI shows that ground water in the one well that currently exceeds the tritium :\ICL will be naturally" remediated
long before It migrates otTsite.
h There is currently no ~PDES discharge limit for tritium. LLSL will use the :\ICL for tritium as the discharge limit.
10
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UCRL-AR-I09I05
Record of Decision
July 15, /992
Bay Area Quality Management District (BAAQMD) standards. Contaminants in the unsaturated
zone will be remediated only if it is predicted that they would result in concentrations above an
MCL if allowed to migrate into the ground water. Unsaturated zone remediation will be
complete when modeling shows that contaminants will no longer migrate to ground water and
create concentrations in the ground water above an MCL.
As part of the additional source investigations that are in progress, evaluations of the
transpon of VOCs and non- VOCs from the unsaturated zone to the ground water will be
conducted. These investigations may identify areas where additional soil and ground water
remediation is necessary. Results of these investigations will be summarized in Monrhly
Progress Reports for review by the regulatory agencies and the public.
Treated ground water will be recharged via wells, the LLNL recharge basin, and local
arroyos, and/or used for LLNL landscape irrigation or in LLNL cooling towers, to conserve
water resources.
2.5. Site Characteristics
Initial releases of hazardous materials occurred at the LLNL site in the mid- to late 1940s
when the site was the Livermore Naval Air Station (Thorpe et al., 1990). There is also evidence
that localized spills, leaking tanks and impoundments, and landfills contributed VOCs, FHCs,
lead, chromium, and tritium to ground water and unsaturated sediment in the post-Navy era. A
screening of all environmental media showed that ground water and unsaturated sediment are the
only media that require remediation (Thorpe et al., 1990). The identified compounds that exist
in ground water at various locations beneath the site at concentrations above drinking water
standards are:
1. The VOCs trichloroethylene (TCE), perchloroethylene (PCE), 1,1-dichloroethylene (1,1-
DCE), 1,2-dichloroethylene (l,2-DCE), 1,1-dichloroethane (I,I-DCA), 1,2-
dichloroethane (l,2-DCA), carbon tetrachloride, and the trihalomethane (THM)
chloroform.
2. FHCs (leaded gasoline),
dibromide.
3. Chromium and lead.
4. Tritium.
The quality of data for these compounds was considered in the selection of the remedies for
the LLNL site in accordance with the LLNL Quality Assurance Project Plan (QAPP, Rice,
1988).
2.5.1. VOCs
including benzene, ethylbenzene, toluene and ethylene
The VOCs in ground water beneath LLNL occur in relatively low concentrations that underlie
about 85% of the LLNL site, over a total area of about 1.4 square miles (Fig. 3). The calculated
total volume of undiluted VOCs in ground water is less than 200 gallons. The vertical thickness of
the ground water VOC plumes varies from about 30 to 100 feet, and VOCs are seldom found
below a depth of about 200 feet. VOCs are relatively mobile in ground water and migrate at a rate
of about half the velocity of ground water. TCE and PCE are the predominant VOCs in the study
area, and are currently present locally in concentrations up to 4.8 and 1.1 pans per million (ppm)
respectively (1992 data). However, the higher concentrations are localized, and total VOC
concentrations exceed 1 ppm in ground water from only 10 out of a total of more than 300 wells.
The distribution of VOCs in ground water exceeding MCLs is shown in Figure 4. The VOCs and
chromium in ground water in the vicinity of the Patterson Pass-Vasco Road intersection appear to
originate on private property nonhwest of the LLNL site as discussed in Iovenitti et al. (1991) and
11
-------
Refer to Figure 1 for planned
ground water extraction locations -
Union Pacific
Legend /'/.;~.
, ~.
. Monllor/Prlvate/Zone1 /~yJI
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Figure 3. Isoconcentratlon contour map 01 total VOCs In ground water.
-------
Legend
General direction
o' ground water flow
Seale : Feet
I
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. H++-H.
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Figure 4. Area where one or more VOCs In ground water equals or exceeds Federal or California maximum contaminant levels (MCLs).
-------
UCRL-AR-109105
Record of Decision
July 15,1992
Hoffman (1991a). This offsite area will be investigated by the potentially responsible parties
under RWQCB order. If LLNL is found to be the source of chromium in this area, LLNL will
incorporate this area into the remedial design.
Chemical data from borenoles drilled at the locations of suspected VOC releases at LLNL
indicate that generally low residual VOC concentrations (less than 100 parts per billion [ppb])
are present in unsaturated sediments. The calculated total volume of undiluted VOCs in the
unsaturated zone is less than 100 gallons. Computer modeling indicates that downward
movement of VOCs above the water table is not likely to result in ground water VOC
concentrations exceeding MCLs for drinking water, except at the Building 518 Area in the
southeast corner of the site (Isherwood et al., 1990). The Trailer 5475 Area is also being
evaluated for possible cleanup.
In the Building 518 Area, VOCs (predominantly TCE) reach a maximum concentration of
about 6 ppm at a depth of 20 feet. These VOCs are believed to have originated from surface
spills or leaking drums in the post-Navy era. Recent investigation in the Trailer 5475 Area (also
called the East Taxi Strip Area) in eastern LLNL indicate that remediation may be necessary
pending additional subsurface investigations and modeling. Total VOC concentrations
(predominantly TCE) reach a maximum concentration in unsaturated soil of about 5 ppm in that
area. These VOCs originate from former landfills and surface impoundments.
2.5.2. Fuel Hydrocarbons
FH Cs occur almost exclusively where a leak of roughly 17,000 gallons of leaded gasoline
OCCUITed from a U.S. Navy-era underground fuel tank in the southern part of the site (Fig. 5).
Although some gasoline constituents are relatively mobile in ground water, FHCs in ground
water have not migrated more than about 500 feet from the leak point due to the very slow
ground water movement in the area (Thorpe et al., 1990). Within this area, total FHC
concentrations in ground water range from 0.001 to 16 ppm, and benzene concentrations range
from less than 0.0001 to about 4 ppm. Ethylene dibromide has been detected in nine Gasoline
Spill Area monitor wells above the MCL in concentrations from 0.0001 to 1.3 ppm. FHCs are
not present in ground water beneath a depth of about 150 feet.
Prior to withdrawal of fuel vapor by vacuum-induced venting as part of a Gasoline Spill Area
pilot study, up to 11,000 ppm total FHCs and 4,800 ppm aromatic hydrocarbons were detected in
the unsaturated sediments beneath the fonner fuel tank. Vinually all FHCs in the unsaturated
zone are about 50 feet radially from the leak point.
2.5.3. Metals
Metals above MCLs are present in only a few locations. Chromium in ground water exceeds
the MCL in 16 wells scattered in the nonhwest, central, and southwest parts of the study area and
near Arroyo Seco (Fig. 6). The maximum chromium concentration in ground water in the LLNL
study area is 160 ppb, in the nonhwestern corner of the site. Chromium in the LLNL area
sediments and ground water appears to have originated naturally and from some LLNL site
activities. At LLNL, chromate solutions were used in cooling towers as corrosion inhibitors
from approximately 1958 to 1970. Blowdown from the cooling towers was released to the storm
drain system, but neither the exact quantity of releases nor the chromium content of the water are
known. According to anecdotal information, storm runoff caused the blowdown to flow
nonherly before infiltrating into the ground near the West Traffic Circle. In addition, naturally
occurring chromium deposits have been mined in the hills southeast of LLNL. As described in
Section 2.5.1, chromium in ground water nonhwest of LLNL appears to orginate on private
propeny and will be investigated by others (i.e., the potentially responsible parties).
14
-------
......
V1
~
MW-358 @) Monitor well
GSB-374 . Soli boring
Total FHC lsoconcen.
""'0.1 -...J tratlon contour (ppm);
dashed where Inferred
Not detected
Not analyzed
Data not used In
contouring, due to free
product In GSW-403-6
and because GSW.12Is
completed beneath
the fuel plume.
Scale: Feet
~
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" RO.lSR-91.02S6
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. MW.441
@MW-~1 (NA)
Figure 5. Isoconcentratlon contour map of total fuel hydrocarbons (FHCs) In ground water, Gasoline Spill Area, March 1989. All areas
that exceed fuel hydrocarbon MCLs are encompassed by the O.1-ppm contour.
c:::
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In ground water.
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-------
UCRL-AR-J09J05
Record of Decision
July 15,1992
Recent analyses indicate lead is above the 15 ppb remediation standard in only two wells,
both in the Gasoline Spill Area, at a maximum concentration of 38 ppb. Lead has a low potential
for migration in bOth the saturated and unsaturated zones because it binds strongly to sediment.
This low migration rate and limited extent, indicate that lead at LLNL does not pose a health
threat. If, however, lead is found in ground water above the remediation standard, it will be
remediated .
2.5.4. Tritium
Tritium in ground water has historically exceeded its MCL (20,000 picocuries per liter
[pCi/L]) in only two wells, MW-206 and MW-363, both in the southeast part of the LLNL site.
Currently, water from only MW-206 exceeds the tritium MCL (Fig. 6). This tritium was
released to the subsurface in former, nearby evaporation ponds, is localized and well defined, and
the affected ground water is not used for drinking water. Although tritium migrates at the same
rate as ground water, ground water modeling indicates that by the time the affected ground water
moves offsite in the absence of active remediation, tritium concentrations would be reduced to
concentrations below drinking water standards by natural decay (tritium has a 12.3-year half-
life). Therefore, no pathway to humans exists for the observed tritium in ground water. The
tritium is effectively self-remediating via natural decay. Ground water will continue to be
monitored for tritium to track its distribution and concentrations over the duration of the cleanup.
Recent investigations have identified additional areas where tritium concentrations in
unsaturated sediments at LLNL are significantly elevated. These include the Building 514,
Eastern Landing Mat Storage, West Traffic Circle, Building 292, and Old Salvage Yard Areas.
However, the tritium activity in ground water in these areas is well below the 20,000 pCi/L
MCL. The only potentially significant transpon pathways to human populations for this tritium
are inhalation and skin absorption of tritiated water from direct soil evaporation or from water
taken up by plants and released to the air by transpiration from plant leaves. Most of the areas
where tritium has been detected are paved with asphalt, thereby limiting potential evaporation
from soil and further downward migration by infiltration of rainwater. Elevated tritium levels in
transpired water have been measured in isolated areas at LLNL. Screening-level calculations
have been performed by LLNL using the standard EPA model AIRDOS-EPA and very
conservative assumptions that maximize the calculated dose. These calculations indicate that
any potential dose from the measured tritium in soil would not exceed 0.01% of the
lO-millirem/year Federal dose standard (Macdonald er al., 1990). Additional information
regarding the distribution, concentration, toxicity, mobility, potential routes of migration, and
potential exposed populations of all LLNL compounds "f concern can be found in the RI, the
Baseline Public Health Assessment (BPHA) (Layton er af., 1990), and Sections 2.1 and 2.6 of
this ROD.
2.6. Summary of Unremediated Site Risks
As part of the RI repon (Thorpe er af., 1990), the BPHA (Layton er af., 1990) was conducted
to estimate the potential future health risks if contaminants in ground water and sediments
originating from LLNL were not remediated. Evaluation of a no-action scenario is a requirement
of the NCP, 40 CFR section 300.430(e)(6), to represent a baseline condition. In addition, a risk
assessment was conducted as part of the FS (Isherwood er af., 1990) to estimate the potential
public health risks if the concentrations of VOCs in ground water were reduced to their
respective MCLs. These and 9ther assessments of potential risks are summarized in the PRAP
(Dresen er al., 1991) and below. Details of the risk assessments are contained in the RI and FS.
2.6.1. Human Health Risks
The LLNL risk assessment consisted of several steps:
. Identifying the contaminants of concern (see Section 2.5 of this ROD).
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. Identifying the media through which exposure may occur.
. Assessing the exposure.
. Assessing the toxicity of each contaminant.
. Quantifying the risk.
Each of these is discussed below.
2.6.1.1. Contaminant Identification
2.6.1.1.1.' Media of Concern
The primary medium through which public exposure to LLNL contaminants may occur is
ground water. Air is also a medium of concern for contaminants that may volatilize from
contaminated soil or ground water. The public is not directly exposed to contaminated soils
because no offsite surficial soils contain significant concentrations of contaminants originating
from LLNL. Contaminated onsite surficial soils were evaluated as a potential medium of
concern. However, a screening analysis of the risks resulting from potential onsite exposure to
contaminated soils has shown these risks are insignificant (Layton et ai., 1990; Hoffman, 1991 b;
Macdonald et ai., 1991). Therefore, surficial soils are not a medium of concern for the LLNL
site.
2.6.1.1.2. Contaminants of Concern
A screening analysis was conducted to detennine which substances and exposure pathways
are potentially important from the perspective of potential adverse health effects. A statistical
analysis of thousands of water and soil samples estimated the relative abundance of particular
contaminants in the study area (Layton et ai., 1990). TCE, PCE, and chloroform account for an
estimated 91 % of the total amount of VOCs dissolved in the LLNL-area ground water. Of the
remaining VOCs, the most hazardous are carbon tetrachloride and I,I-DCE, which were used to
represent the potential adverse effects of the remaining 9% of the VOCs. Nearly 60% of the
mass of the remaining 9% of VOCs is 1,I-DCE. These compounds were used to estimate the
public health risks resulting from the offsite migration and domestic use of contaminated ground
water. According to the U.S. EPA, PCE, TCE, chloroform, and carbon tetrachloride are
classified as B2 carcinogens, which are described as "probable human carcinogens indicated by
sufficient evidence in animals and inadequate or no evidence in humans" (U.S. EPA, 1989a).
1,1-DCE is classified as a Class C carcinogen by the U.S. EPA (possible human carcinogen).
Other contaminants in soil and ground water include benzene at the Gasoline Spill Area,
tritium, and inorganic substances, such as chromium, lead, nitrate, sulfate, and manganese. A
screening analysis of the transpon and fate of benzene indicates that benzene or other gasoline-
related contaminants (toluene, xylene isomers, and ethylbenzene) are not likely to reach
detectable concentrations west of LLNL. Similarly, tritium continues to undergo radioactive
decay with a 12.3-year half-life such that by the time ground water containing elevated levels of
tritium would migrate to the western LLNL boundary in the absence of remediation,
concentrations would be within background levels. As stated in Section 2.5.4, LLNL plans to
monitor tritium in ground water over the life of the cleanup.
As discussed in a letter to the regulatory agencies (Hoffman, 1992), there is strong evidence
that the lead in LLNL ground water is naturally occurring. Funhermore, as described in Section
2.5.3, it appears that the migration potential for lead is very low, and its occurence above the
remediation standard is very limited. Several inorganic substances, including chromium, nitrate,
sulfate, and manganese, occur in ground water in concentrations exceeding regulatory limits in
various monitor wells, sporadically located onsite and offsite. Except perhaps for chromium,
which has been used in LLNL cooling towers, the observed concentrations appear to reflect
background levels of these constituents in ground waters in the Livermore Valley.
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2.6.1.1.3. Concentrations of Chemicals of Concern Used in the Risk Assessment
To assess the ground water exposure pathway, migration of the five VOCs of concern (PCE,
TCE, chloroform, carbon tetrachloride, and I,I-DCE) was simulated using the January-
September 1988 concentrations as initial conditions. These concentrations range from the
various detection limits up to a maximum of 6 ppm for TCE in the Building 518 Area.
2.6.1.2. Exposure Assessment
2.6.1.2.1. Exposure Pathways
The only potential exposure pathway for present and future offsite populations is use of
contaminated well waters. For domestic water uses, the potential exposure pathways are
ingestion of drinking water, inhalation of volatile substances, and entry through the skin. For
irrigation uses, the potential exposure pathways are inhalation of volatilized chemicals from
sprinklers, and ingestion of foods from crops or home gardens irrigated with water containing the
chemicals of concern. Exposure from contact with surface water runoff or sediment in local
arroyos that receive drainage waters from the LLNL site is not a pathway of concern, because no
chemicals of concern have been detected in downstream drainage channels near LLNL, and
ground water does not discharge to streams near LLNL. The most imponant offsite exposure
pathways with regard to health risk are those that result from domestic well water use from
offsite wells (Thorpe et at., 1990).
2.6.1.2.2. Potentially Exposed Population
As described in the BPHA and in Section 2.6.1.1.1 above, there are no significant onsi te
exposure pathways for LLNL site contaminants. Prior to any soil excavation at LLNL, the
existing soil cleanup data are reviewed and maps of known or suspected contamination are
consulted to determine whether additional sampling needs to be conducted prior to excavation.
If no samples have been previously collected in a given area, preconstruction sampling is
performed before excavation begins. If contamination is found, appropriate safety and disposal
practices are overseen by the LLNL Hazards Control Department.
The only potentially exposed offsite population consists of residents who use ground water
that has migrated from LLNL. In the assessments of risk for the LLNL site, a future residential-
use scenario was not considered because it is unlikely that transfer of ownership of the site from
DOE would occur in the foreseeable future. No change in ownership of the LLNL Main Site or
any ponion thereof, or notice pursuant to Section 120 of CERCLA, will relieve DOE of its
obligation to clean up contamination resulting from DOE activities, or any futu!"l" contamination
resulting from DOE activities at LLNL. In addition, no change of ownership of the site or any
ponion thereof will be consumated by DOE without provision for continued maintenance of any
containment system, treatment system, monitoring system, or other response action(s) installed
or implemented under terms of the LLNL FF A.
2.6.1.2.3. Exposure Point Concentration Estimates
To assess the potential future health risks of the known contaminants in ground water, the
movement of VOCs from their current distribution was simulated with a model. A
semianalytical model of contaminant transpon and fate in ground water was used that considers
advection, dispersion, retardation, and degradation. The BPHA contains details on the
assumptions and the parameters used in the model.
To address uncenainty inherent in all contaminant migration calculations, two scenarios were
investigated, one called "best-estimate" and the other "health-conservative." The health-
conservative scenario uses parameter v.alues and assumptions that yield exposures that are very
unlikely to be exceeded. U.S. EPA prefers using the most conservative of the health-
conservative scenarios (footnote "b," Table 4, Section 2.6.1.4.3) as their estimate of the potential
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health risk from the LLNL site. The best-estimate simulations use parameter values that are
considered to be the most likely or the most representative, based on existing knowledge of the
LLNL ground water system and contaminant propenies. Best-estimate simulation assumes no
human exposure to the ground water until it reaches the currently used municipal supply wells in
downtown Livermore because no private wells are currently contaminated and administrative
control limits the potential for domestic well installation into a contaminated zone. The
administrative control consists of notification by Zone 7, the local water agency, that a proposed
new well is in or near the contaminant plume.
2.6.1.2.4. Exposure Frequency and Duration
The exposure period for the offsite public for any exposure pathway of concern was assumed
to be a 70-year lifetime. For offsite exposures to contaminated ground water, the fate and
transpon model was used to calculate maximum 70-year average concentrations in ground water
at existing and potential offsite wells. It was assumed that the exposed population uses ground
water as its sole source of domestic water for this continuous 70-year period. These and other
assumptions were used to estimate the total daily uptake of each chemical of concern in
milligrams of chemical per kilogram body mass per day (mglkg-day).
2.6.1.3. Toxicity Assessment
2.6.1.3.1. Cancer Potency Factors
Cancer potency factors (CPFs) have been developed by U.S. EPA to estimate excess liferime
cancer risks associated with exposure to potentially carcinogenic chemicals. CPFs. expressed in
units of (mg/kg-day)-l, are multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes underestimation of the actual cancer
risks highly unlikely. CPFs are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and uncenainty factors have
been applied (e.g., to account for the use of animal data to predict the effects on humans).
CPFs for the LLNL chemicals of concern are listed in Table 2. In conformance with EPA
methodology, cancer.potencies are based on applied, rather than metabolized, doses.
Table 2. Cancer potency factors for carcinogenic chemicals of concern (Layton et aL, 1990).
Chemical
Carbon tetrachloride
Oral cancer potency (mglkg.d).l
0.13
0.0061
0.6
0.051
0.011
Inhalation cancer potency (mg/kg.d).l
0.13
0.0081
1.2
0.0033
0.017
Chloroform
1,I.DCE
PCE
TCE
2.6.1.3.2. Reference Doses for Noncarcinogens
Reference doses (RIDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RIDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be compared to the
RID RIDs are derived from human epidemiological studies or animal studies to which
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uncenainty factors have been applied (e.g., to account for the use of animal data to predict the
effects on humans). These uncenainty factors help ensure that the RIDs will not underestimate
the potential for adverse noncarcinogenic effects to occur.
Reference doses for the LLNL chemicals of concern are listed in Table 3.
Table 3. Reference doses for noncarcinogenic chemicals of concern (Layton el aL, 1990).
Chemical
Carbon tetrachloride
Reference dose (mg/kg-d)
0.0007
0.01
0.009
0.01
NA
Chloroform
l,t-DCE
PCE
TCE
SA= not available.
2.6.1.4. Risk ChDracterization
2.6.1.4.1. Carcinogenic Risks
The information from the preceeding steps was combined to determine if an excess health
risk would exist if the site were not remediated. Excess lifetime cancer risks are determined by
multiplying the intake level with the CPF. These risks are probabilities that are generally
expressed in scientific notation (e.g., 1 x 10-6 or 1E-6). An excess lifetime cancer risk of 1 x 10-6
indicates that, as a plausible upper bound, an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Tables A-I and A-2 in Appendix A summarize the estimated cancer risks for offsite exposure
to ground water for both the best-estimate and health-conservative exposure scenarios for PCE,
TCE, 1,1-DCE, chloroform, and carbon tetrachloride. Under the best-estimate exposure scenario
(Table A-I), the greatest incremental cancer risk is seven in ten million (7 x 10-7), which is
associated with a well 2 miles west of the LLNL site that is in the path of the plume containing
the highest concentrations of 1,1-DCE. Under the health-conservative exposure scenario (Table
A-2), the incremental cancer risks are on the order of one in one thousand (10-3) to one in one
million 00-6) for all wells. The highest predicted risk, two in one thousand (2 x 10-3), is for a
hypothetical well about 250 feet west of the LLNL ~te. However, no such wells have been
constructed to date or are planned for installation prior to cleanup. The most conservative of the
health-conservative scenarios (i.e., the one with the 2 x 10-3 incremental risk) is the scenario
prescribed by EP A for the LLNL site.
2.6.1.4.2. Potentialfor Noncarcinogenic Effects
Potential noncarcinogenic effects of a single contaminant in a single medium is expressed as
the hazard quotient (HQ) (or the ratio of the estimated intake derived from the contaminant
concentration in a given medium to the contaminant's reference dose). By adding the HQs for
all contaminants within a medium or across all media to which a given population may be
reasonably exposed, the hazard index (HI) can be estimated. If only one compound is involved,
then the HQ is equivalent to the HI. If the HI value is greater than 1.0, exposure could result in
adverse health effects. The HI provides a useful reference for gauging the potential significance
of multiple contaminant exposures within a single medium or across media.
Tables A-3 and A-4 in Appendix A summarize the estimated HQ's for offsite exposure to
ground water for both the best-estimate and health-conservative exposure scenarios for the
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chemicals of concern at LLNL. Under the best-estimate exposure scenario (Table A-3), the
greatest HQ is 1.4 x 10-3, which is for a hypothetical well 2 miles west of the LLNL site in the
path of the plume containing the highest concentrations of carbon tetrachloride. Under the
health-conservative exposure scenario (Table A-4), the HQ's are on the order of 10-2 to 10-1 for
all wells. The highest predicted HQ (0.8) is for a hypothetical well that is 250 feet west of the
LLNL site.
2.6.1.4.3. Combined Carcinogenic Risks and Hazard Indices
The maximum theoretical excess cancer risks for a hypothetical, no-remediation scenario,
based on the assumption that an individual will use well water for a 70-year (lifetime) period, are
presented in Table 4. The maximum additional cancer risk associated with the best-estimate
scenario in Table 4 means that the cancer risk from a lifetime exposure to VOCs (PCE, TCE,
chloroform, and carbon tetrachloride) in well water derived from a downtown Livermore
municipal supply well could be as high as 7 in 10 million (7 x 10-7), using EPA assessment
methods. This means that each individual that consumes 2 liters (about 2 quarts) of this water
each day for 70 years would increase his or her risk of developing cancer by 7 in 10 million
above the normal 1 in 4 cancer risk for Americans (U.S. EPA, 1989a). The HI associated with
the best-estimate scenario is far below 1.0, indicating exposure at the predicted concentrations
would not produce any adverse health effects from noncarcinogens (see the RI, Thorpe et aI.,
1990, for details).
Table 4. No-remediation-scenario cancer risk and hazard index (HI) values using the EPA methodologya
(U.S. [PA, 1989a).
No-remediation scenario
Best-estimate
Health-conservativeb
Health-conservativeC
Risk of cancer
7x 10-7
2x1o-3
lx10-3
HI
1.6x10-3
1
1
a See Isherwood et al. (1990) for an alternative method of computing the risk of cancer and HI.
b Based on potential monitor well drilled 250 feet west of LL:\'L.
c Based on receptor wells drilled in downtown Livermore.
Under the health-conservative no-remediation scenario, the maximum additional cancer risk
is two in one thousand (2 x 10-3) for a lifetime exposure to contaminants in water from a
potential monitor well drilled 250 feet west of LLNL. The HI calculated for this scenario is 1.
Because no drinking water wells are likely to be drilled in the area 250 feet west of LLNL, we
also calculated the risk based on a lifetime exposure to well water derived from downtown
Livennore using the health conservative assumptions. This unlikely scenario results in a
maximum additional cancer risk of one in one thousand (1 x 10-3) and an HI of 1. The HI of I
for the health-conservative scenario indicates that there is some potential for noncarcinogenic
health effects if the very conservative assumptions of the health conservative scenario were ever
realized, and if there was an additive effect of all the individual compounds. Both health-
conservative risks in Table 4 exceed EPA's one in ten thousand to one in ten million (1 x 10-4 to
1 x 10-7) acceptable risk range for Superfund sites.
2.6.1.4.4. Sources of Uncertainty
Uncenainties are associated with all estimates of cancer and noncancer health hazards. These
uncenainties result from incomplete knowledge of many physical and biological processes, such
as carcinogenesis. Where specific information is not available, it is necessary to make
assumptions and/or use predictive models to compensate for lack of information. The
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assumptions, models, and calculations are chosen such that the resulting risk and hazard
estimates are health-conservative. The specific sources of uncenainty in the risk and hazard
estimates presented here are funher discussed in the BPHA.
2.6.1.5. Environmental Risks
Currently, there is no potential risk of ecological impacts related to environmental exposure
to ground water because no ground water containing contaminants is present at the surface. either
onsite or offsite. No perennial streams exist at or near the site and no streams receive flow from
ground water. No critical habitats are affected by the ground water and soil contamination. No
endangered species or habitats of endangered species are affected by the site contaminants, as
described in the FS (Isherwood et al.. 1990).
2.6.1.6. Risk Assessment Conclusions
In summary, the identified compounds of concern, if not addressed by implementing the
response actions selected in this ROD, may present a potential risk to public health.
2.7. Description of Remedial Alternatives
In the FS, three remedial alternatives were assembled for ground water for the LLNL site:
1. Ground water extraction throughout the contaminated area, including source areas,
thereby preventing further contaminant migration and enabling the most rapid cleanup.
Ground water would be treated at the surface using UV/oxidation or air stripping-based
technology with GAC to prevent any measureable air emissions. The treated water would
be recharged or used at the LLNL site.
2. Ground water extraction at the downgradient edges of contamination to prevent further
contaminant migration. Ground water would be treated at the surface, as for Alternative
No.1, and recharged or used at the LLNL site.
3. Ground water monitoring and treatment at the point of use, if drinking water supply wells
should ever contain contaminants from LLNL in concentrations above drinking water
standards. Ground water would be treated at the surface as described in No.1 above.
The remedial alternatives for contaminants in the unsaturated sediment were:
1. Vacuum-induced venting with surface treatment of vapors using GAC, thermal oxidation,
or catalytic oxidation.
2. Deferring action to see if contaminants migrate to the grou:nd water, and, if they do,
extracting and treating the ground water as described for the ground water remedial
alternatives.
A third alternative. excavation and treatment and/or disposal, was also considered for
unsaturated sediment. However, this alternative would be applicable only if (1) contaminant
concentrations are found in the unsaturated zone that are high enough to cause concentrations
above MCLs in the ground water, and (2) they occur at relatively shallow, accessible depths.
Currently, no known locations meet these criteria, and this alternative was not considered funher.
However, excavation, treatment, and/or disposal could be employed in the future if high
concentrations of contaminants, treatable perhaps by bioremediation or aeration, are discovered
at excavatable depths.
The volume of ground water that contains contaminants above MCLs is much greater than
the volume of unsaturated sediment containing contaminants that may impact the ground water
in concentrations above MCLs.
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The ground water and unsaturated sediment alternatives were developed by considering the
nine evaluation criteria prescribed by EPA, as discussed in the FS. The FS discusses the various
technologies for treating extracted ground water and vapor and assembles them into treatment
options. The preferred treatment options vary from place to place because different parts of the
site contain somewhat different combinations of contaminants in ground water and unsaturated
sediment.
All the remedial alternatives considered for the LLNL site would include long-term ground
water monitoring and reponing, in compliance with CERCLA requirements, until demonstrated
achievement of the remedial action objectives. The costs of these activities, which are common
to all alternatives for their respective estimated times of operation, were not explicitly addressed
in the FS, but were presented in the PRAP to reflect the additional costs of maintaining a
remediation program into the distant future. Monitoring activities will be conducted and
reviewed periodically to gauge the effectiveness of the remedies. For all alternatives, the costs
and implemen.tation times were estimated using the assumptions discussed in the FS. The
program operations costs, which were not described in the FS, are summarized in Appendix A of
the PRAP (Dresen er aI., 1991).
All the treatment options for ground water will reduce the effluent concentration of VOCs,
FHCs, chromium, and lead below Applicable or Relevant and Appropriate Requirements
(ARARs) (Isherwood er al., 1990). Tables 3-1 and 3-2 in the FS, and Table 1 and Appendix B of
this ROD summarize the ARARs for the LLNL site.
As discussed in Section 2.8, Ground Water Alternative No.1 and Unsaturated Zone
Alternative No.1 meet all ARARs. Ground Water Alternatives 2 and 3 and Unsaturated Zone
Alternative 2 do not fully comply with the California non-degradation ARAR.
For treatment options that include disposal of treated ground water or air emissions, the
effluent concentrations will be in compliance with RWQCB Waste Discharge Requirements,
National Pollutant Discharge Elimination System (NPDES), and BAAQMD standards. Treated
ground water will be recharged at the LLNL recharge basin south of East Avenue, in local
drainage ditches and arroyos, or in infiltration trenches or recharge wells. Treated water will also
be used for on site landscape irrigation and in LLNL's cooling towers.
The approach for tritium is to keep it in the subsurface as much as possible where it will
decay naturally (i.e., self-remediate) and to minimize its migration. Extraction systems will be
designed and operated to prevent tritium from entering a treatment system in concentrations
above its MCL. This will be accomplished by monitoring the influent water to the treatment
system, both in pipelines and in the well(s). If water containing tritium above the MCL enters a
treatment system, the facility will be shut down, and the water containing tritium will be treated
by evaporation under existing National Environmental Standards for Hazardous Air Pollutants
requirements, or released within allowable limits under the existing permit to the sanitary sewer
system. No treated ground water will be recharged back to the subsurface if the tritium level
exceeds the MCL.
Treatment options utilizing air stripping will be designed with GAC on the effluent air
stream, so there are no measurable VOC air emissions. For those options employing GAC to
treat water or air streams, the GAC will be shipped offsite where it will be commercially
regenerated to destroy or recycle, if possible, the adsorbed contaminants. Options employing ion
exchange for treatment of metals will require offsite recycling or disposal of the ion-exchange
resin as a hazardous waste. The expected risk reduction after cleanup is complete is described in
Section 2.9.1 of this ROD.
2.7.1. No-Action Alternative
A No-Action Alternative was considered in the FS for the LLNL site to establish a baseline
for comparison. Under this alternative, LLNL would cease all characterization and remedial
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activities. Limited ground water monitoring would continue to track changes in ground water
chemistry. The No-Action Alternative is not the same as the Deferred-Action Alternatives
discussed in the FS and the PRAP, in that remedial actions may be taken in the future under the
Deferred-Action Alternatives. The No-Action Alternatives for ground water and unsaturated
sediment do not meet Federal and State standards to protect human health and were not
considered viable in the FS and the PRAP.
2.7.2. Ground Water Remedial Alternatives
Two ground water extraction plans that use different arrays of extraction wells form the basis
for immediate-action alternatives to remediate ground water. Each extraction plan is discussed
subsequently with its remedial alternative.
Costs for the ground water remedial alternatives are summarized in Table 5. In the FS, costs
were analyzed using a present wonh calculation procedure, as prescribed by EPA. This is the
standard procedure for comparing alternatives with costs and revenues beginning, ending, or
extending over-different periods of time.
2.7.2.1. Ground Water Remedial Alternative No.1 (The Selected Alternative)
2.7.2.1.1. Ground Water Extraction Plan/or Remeditll Alternative No. 1--Complete Capture
and Source Area Extraction
Under this plan, extraction wells would be strategically placed near contaminant margins to
intercept and hydraulically control all ground water originating from LLNL with VOC
concentrations exceeding MCLs. In addition, ground water would be extracted from source
areas (defined here as those areas with concentrations above about 100 ppb in ground water) to
expedite cleanup. This plan would utilize 18 initial' extraction locations and about 7 treatmem
facilities shown conceptually on Figure 7. A plot of the predicted ground water flow patterns
using these locations is shown in Figure 8. The flow lines (with arrows on Fig. 8) converge on
extraction locations and show the areas hydraulically captured by the extraction wells. The total
rate of ground water removal for this extraction plan is estimated to be about 350 gallons per
minute (gpm). Where VOCs and tritium occur together in ground water, the extraction systems
will be designed and monitored to minimize tritium migration and to prevent the water influem
to any treatment systems from containing tritium in concentrations above the MCL. Therefore,
no tritium will be released from treatment systems in concentrations above the MCL.
The 350-gpm sitewide extraction rate is a preliminary estimate used to estimate capture areas,
cleanup times and costs relative to other alternatives presented in the PRAP and ROD. This
extraction rate and the estimated treatment facility capacities will be analyzed and further refined
in the Remedial Design and as pan of ongoing work to decrease cleanup times and optimize
extraction and recharge rates.
It is estimated that it would take about 50 years to reduce contaminant concentrations to
MCLs if only the 18 initial extraction locations are employed. LLNL plans to implement the
selected cleanup plan in phases, and evaluate each phase with field data. Additional extraction
locations may be used to ensure full hydraulic capture of the plume, and/or to expedite cleanup.
If technologically feasible, and if funding permits, LLNL will attempt to achieve cleanup in less
than the predicted 50 years. It is estimated that all extraction and treatment facilities under
Alternative 1 would be operational in the 1993-94 timeframe, depending on congressional
funding. LLNL will make every effort to obtain sufficient funding to fully support the selected
cleanup plan. This alternative will comply with all ARARs.
,
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Table S. Summary or costs for ground water remedial alternatives for the LLNL Livermore site.
Present worth costs
(millions or 1990 dollars)8
Treatment Total
system present
Capital O&M Program worth of
Remedial alternative costs b costsC operationsd alternativee
Remedial Alternative No.1 9 21 73 103
50-year operation-UV/oxidation
primary treatment at Treatment
Facilities A, 8, E, and F; air stripping
primary treatment at Treatment
Facilities C, D, and G
Remedial Alternative No.2 6 14 79 99
90-year operation-UV/oxidation
primary treatment at Treatment
Facilities A, 8, and F; air stripping
primary treatment at Treatment Facility
C
Remedial Alternative No. 3ar 0.01 0.03 87 87
30-year operation beginning in 200
yearsi air stripping treatment at the
point of distribution in Livermore
Remedial Alternative No. 3bg
Monitoring 10 wells for 100 years 0.00 0.00 12 12
a Present worth calculated using a Serf: discount rate for Remedial Alternative ~o. lover SO years and
Remedial Alternative ~o. 2 over 90 years; and, for Remedial Alternative ~o. 3, a S% rate for a 30-Jear
operation and then at a 2%rate for 200 J'ears from possible commencement of treatment to 1990 for
operation and maintenance, and 230 years for program operations.
b Total capital costs of treatment systems, extraction wells, pipelines, water recharge and reuse facilities,
monitor wells, and piezometers.
C Present worth 01 annual operating and maintenance costs of treatment systems, extraction wells, pipelines,
water recharge and reuse facilities, monitor wells, and piezometers.
d Present worth of annual program operations; see Appendix A of PRAP (Dresen el lIL, 1991) for details.
e Sum of present worths of capital costs, treatment systems, operating and maintenance, and program
operations.
f Cost estimate for this alternative assumes that VOCs might migrate to Livermore municipal-supply wells in
200 years, If ever. Program operations costs are assumed to be $1.7S' million per year.
g Assumes lower program operations costs, $0.6 million per year, monitoring of 10 wells for 100 years, and no
treatment because computer modeling predicts that VOCs in ground water may never exceed :\fCLs in
Livermore municipal-supply wells.
,
26
-------
N
-J
8 . Extr8C~~g:~:catlon ~~t!?~"''''-''\, """"--,,.--~ /'/
~ Possible recharge well ,,~!~" ' ,jk--;~" ~ . ~x0'
D(50). Treatment 'acility and . ","""",-",,,,,,,,,, :1 ' ~-Io-"
estimated In'luent flow (gpm) , ' ,. "!' +H-H+..!..I+H'i..H+H-H-.;.+H-++t.~....
k''''''''''''' Direction 0' untreated water flOW',',',,,,,,,,:,..' '\:.A;"oyo Las P~sltas. ii*' -,-_.._,-,-,..fi'!1!~cm~U,B.O!9_n_'--'--"--"-:i
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.~ Direction 0' treated water flOW,J """',.""~",,f~,/. r "': .,""L.:1 ;""', ... -'-~1'
~. alternate route ,.11 ~ .:: : c:....,,;'!: l"'->."""'~""=""""','"",JL,."",,,,,,,,,,,,,,,', :; :I'~
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Figure 7. Preliminary ground water extraction and treatment 'acillty locations.
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-------
UCRL-AR -1 09105
Record of Decision
July 15, 1992
2.7.2.1.2. Treatment Options for Ground Water Remedial Alternative No.1
Ground Water Containing VOCs (Proposed Treatment Facilities A, B, C, E, and G) (Fig.7).
Treatment Facility E could potentially receive ground water containing nitium as well as VOCs.
Treatment Option 1. Granuwr-Activated Carbon. (GAC) Ground water pumped by
extraction wells would pass through beds of activated carbon where VOCs would be removed by
GAC. The operating costs of this treatment option are high.
Treatment Option 2. Air Stripping with GAC Treatment 01 the Vapor. Ground water
pumped by extraction wells would pass through an air snipper where VOCs would be removed
by transferring them from the water to the air. The vapors from the snipper would pass through
GAC to completely remove contaminants. This treatment option is the most economical for
ground water containing VOCs.
Treatment Option 3. UV/Oxidation Plus Air Stripping with GAC Filtering 01 the
Vapor. Extracted ground water would be blended with small amounts of hydrogen peroxide and
exposed to strong ultraviolet (UV) light, destroying most of the contaminants. LLNL pilot
studies have shown that some compounds require secondary treatment by air snipping, which
would be added to treat water after it passed through the UV /oxidation unit. The vapors from air
snipping would pass through GAC to remove contaminants. This option reduces the amount of
waste requiring funher treatment or disposal, especially where the majority of the contaminants
are readily oxidized by the UV/oxidation process. Costs for this option are moderately high.
Treatment Option 2 or 3 is preferred for Treatment Facilities A, B, C, E, and G, depending on
the concentrations and types of the compounds, and the flow rate influent to each treatment
facility.
Ground Water Containing VOCs and Chromium (Proposed Treatment Facility D) (Fig. 7)
Treatment Option 1. GAC Plus Ion Exchange. Ground water pu~ped by extraction
wells would pass through GAC beds, which would remove the VOCs. The VOC-free water
would then be fed through an ion-exchange resin to extract chromium. The operating costs of
this treatment option are high.
Treatment Option 2. Air Stripping with GAC Filtering 01 the Vapor Phase Plus Ion
Exclumge. Extracted ground water would pass through an air snipper to remove VOCs. The
vapors from the snipper would pass through GAC to remove VOCs from the air. The VOC-free
water would flow through an iO'1-exchange resin to extract chromium. This treatment option is
preferred because the higher concentrations of TCE, carbon tetrachloride, chloroform, and
Freon 113 make this treatment option more economical.
Treatment Option 3. UVIOxidation Plus Air Stripping and Ion Exchange with GAC
Treatment 01 the Vapor. Extracted ground water would be treated by UV/oxidation, destroying
most of the VOCs. Remaining VOCs would be removed from the water by air stripping. The
vapors from the air stripper would pass through GAC to completely remove VOCs. The VQC-
free water would then flow through an ion-exchange resin to extract chromium. The operating
costs of this treatment option are high.
Ground Water Containing FHCs, VOCs, and Lead (Proposed Treatment Facility F) (Fig. 7)
Treatment Option I. GAC Treatment. Ground water pumped by extraction wells would
pass through GAC beds, which remove the FHCs, VOCs, and lead. The operating costs of this
treatment option are high.
Treatment Option 2. Air Stripping with GAC Treatment 01 Both the Vapor and Liquid
Phases. Extracted ground water would pass through an air stripper to remove FHCs and YOCs.
The vapors from the snipper would pass through GAC to completely remove FHCs and VOCs.
29
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UCRL-AR -I 091 05
Record of Decision
July 15,1992
The water would then pass through GAC to extract lead and any remaining A-ICs or VOCs. This
treatment option is not preferred because the high concentration of A-ICs would require frequent
carbon regeneration that increases the operating costs of this treatment option substantially.
Treatment Option 3. UVIOxidation Plus GAC. Extracted ground water would be
treated by UV /oxidation, destroying most contaminants. The water would then pass through
GAC beds to remove lead and any remaining FHCs or VOCs. This treatment technology is
preferred because it can handle the high concentrations of A-ICs. It is also the most economical
of the treatment options.
Treatment Option 4. Subsurface Bioremediation. Biological treatment would utilize
the metabolic destruction of organic compounds by microbes that conven the organic
compounds in the ground water to less toxic compounds. Bioremediation of the A-ICs in the
Gasoline Spill Area is potentially viable. However, the relatively great depth ofFHCs at LLNL,
which makes providing the correct physical and chemic31 conditions for the microbes difficult,
and the sensitivity of microorganisms to subsurface conditions that are difficult to control, make
applicability of subsurface bioremediation at LLNL uncenain. In addition, bioremediation has
not yet been proven successful for chlorinated VOCs. Therefore, this treatment option was not
considered as an initi31 remedial action.
1.7.1.1. Ground Water Remedial Alternative No.2
2.7.2.2.1. Ground Water Extraction Plan for Remedial Alternative No. 2-Downgradient
Control
Under this plan, extraction wells would be placed along the western boundary of LLNL to
intercept and hydraulical1y control the offsite migration of those VOCs in concentrations
exceeding MCLs. In addition, extraction would also occur in the Gasoline Spill Area, where a
pilot remediation study is ongoing, and in the adjacent Building 518 Area to prevent migration of
FHCs and VOCs to the south of LLNL. This plan would use a total of 10 extraction locations, 1
through 7 and location 9 in and near the western boundary of LLNL and locations 17 and 18 in
the southeastern pan of LLNL (Fig. 7). Extracted water would be treated at Treatment Facilities
A, B, C, and F (Fig. 7). A plot of the predicted ground water flow patterns using the extraction
locations for this plan is shown in Figure 9. The rate of ground water extraction for this plan
isestimated to be about 200 gpm. This alternative would contain and remediate all known
contaminants. It is estimated that it would take more than 90 years to achieve MCLs under this
plan and that all extraction and treatment facilities would be operational in 1993.
2.7.1.2.1. Treatment Options for Ground Water Remedial Alternative No.2
This alternative differs from Alternative No.1 in that fewer initial extraction locations (10
compared to 18 for Alternative No.1) and treatment facilities (4 compared to 7 for Alternative
No.1) would be employed. The treatment options discussed in Section 2.7.2.1.2 for Treatment
Facilities A, B, C, and F would be identic31 for this alternative.
2.7.1.3. Ground Water Remedial Alternative No. 3-Defen'ed Action
For the Deferred-Action Remedial Alternative, ground water would not be treated until and
unless contaminants in concentrations greater than MCLs migrate to a drinking water supply
well, such as those operated by the California Water Service Company, located about 2 miles
west of LLNL. Under this alternative, treatment would take place at the point of distribution for
the affected water-supply system. If contaminants did reach supply wel1s, probably no sooner
than about 200 years, their concentrations would be substantially lower than those currently at
LLNL (Thorpe et aI., 1990). The ground water would be treated, at a minimum, to conform to
the MCLs for each contaminant before it is distributed for human consumption. Selection of an
appropriate treatment option would be made at the time that treatment may be necessary because
30
-------
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.
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Figure 9. Predicted ground water flow pathways for Extraction Alternative No. 2-Downgradlent Control.
c......
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10
N
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UCRL-AR-109105
. Record of Decision
July 15,1992
technology and economics may have changed considerably by then. Currently available options
are presented below for comparison.
2.7.2.3.1. Treatment Options for Ground Water Remedial Alternative No.3
Treatment Option 1. GAC Treatment. Ground water pumped by water-supply wells
would pass through GAC beds to remove contaminants.
Treatment Option 2. Air Stripping. Ground water pumped by water-supply wells would
pass through an air stripper. Because only very low concentrations of VOCs may ever occur in
water from supply wells (Thorpe et al., 1990), treatment of air emissions would most likely be
unnecessary. This treatment option is preferred because concentrations of compounds will be
very low and it is the most economical of the treatment options.
Treatment Option 3. UV/Oxidation. Ground water pumped by water-supply wells would
be treated by UV/oxidation. The concentrations of VOCs are expected to be reduced sufficiently
so that secondary treatment would be unnecessary.
2.7.2.4. Comparison of Ground Water Treatment Option Costs
For each extraction and treatment alternative described above, several treatment technology
options passed initial screening and were subjected to a detailed evaluation in Section 4 of the
FS. For purposes of comparing the treatment technologies in the FS, cost estimates were.
prepared (see Appendices D, E, and F of the FS) using U.S. EPA's suggested 30 years operating
and maintenance period (U.S. EPA, 1989b). A supplemental analysis was conducted for several
of the treatment facilities assuming 90 years of operation would be required for Alternative No- 2
to achieve ARARs. This detailed analysis indicates that, in general, for the same length of
operation (e.g., 30 years), (1) GAC is about 1.8 times more expensive in present worth for a
treatment facility than air stripping and (2) UV/oxidation treatment is 1.3 times as expensive in
present wonh as air stripping. Alternative No.3 has a very low present wonh, ranging from
$30,000 for air stripping to $280,000 for GAC, largely because the long timespan prior to
possible commencement of treatment reduces the total costs of this alternative in the discounting
procedure. This also. takes into account the different combinations of contaminants and treatment
options at each treatment facility.
In summary, GAC is generally the most costly treatment technology, followed by
UV loxidation, and then by air stripping. However, the costs in the FS do not include
the program operations costs in Appendix A of the PRAP. These costs do not significantly affect
the relative cost's of the treatment options, but they are significant in magnitude when comparing
remedial alternatives with different periods of operation.
2.7.3. Unsaturated Zone Alternatives
Costs of remedial alternatives for the unsaturated zone are summarized in. Table 6. The
remedial alternatives and treatment options are described below.
2.7.3.1. Unsaturated Zone Remedial Alternative No. I-Vacuum-lnduced Venting (the
Selected Alternative)
Current data indicate that only FHCs in the Gasoline Spill Area, VOCs in the Building 518
Area in the southeastern part of the LLNL site, and possibly VOCs in the vicinity of the Trailer
5475/East Taxi Strip Area in eastern LLNL will need unsaturated zone remediation (Isherwood
er al., 1990). FHCs and/or VOCs would be removed from the subsurface by vacuum-induced
32
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UCRL-AR -109105
Record of Decision.
July 15,1992
Table 6. Summary of costs for unsaturated zone remedial alternatives for the LLNL Livermore site.
Present worth costs
(thousands of 1990 dollars)-
Remedial alternative
Remedial Alternative No. I
Immediate action-IO-year operation;
vapor withdrawal and catalytic
oxidation treatment; vapor from
Building 518 piped to Treatment
Facinty Fe
Remedial Alternative No.2
Deferred action'-monitor and extract
and treat ground water, if necessary
Capital
costsb
Treatment
system
O&M
costsC
S29
585
Program
operationsd
o
Total
present
worth of
alternative
1,114
o
2S2g
600h
852
a Present worth calculated using a 5% discount rate for Remedial Alternative No.1 over 10 years;
and, for Remedial Alternative No.2, ,a 5% rate for 50 years from possible commencement of
treatment in 1990, and a 5% rate for 40 years of operation.
b Total capital costs of treatment systems, extraction wells, and monitor wells.
c Present worth of annual operating and maintenance costs of treatment systems, extraction wells,
and monitor wells.
d Included with ground water remediation only because the major remediation is associated with
ground water.
e The present worth of extracting and piping vapor from the Building 518 Area to Treatment
Facility F is $175,000 for 5 years of operation (including O&M) necessary to achien ARARs. The
present worth of installing a separate catalytic oxidation unit at the Building 518 Area and
operating it for 5 years is $1,100,000 (including O&M).
f Assumes a 50-to 60-year period before VOCs and/or FHCs migrate to ground water from the
unsaturated zone in concentrations above MCLs. Treatment by UV/oxidation at Treatment
. Facility F for 40 years beginning in 50 years (equivalent to the difference between Remedial
Alternatives No.1 and 2 at Treatment Facility F).
g Does not include costs of additional monitoring, extraction, or recharge wells or piezometers that
may be necessary.
h Ten percent of program operations costs charged to this alternative from years SI through 90
because tbey would not otherwise be necessary (4,000,000 x 0.1 x 1.5 discount factor present worth
of annual expenses from years SI to 90).
33
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UCRL-AR-I09105
Record of Decision
July 15, 1992
venting using extraction wells. Treatment options for the extracted vapor are described in the
following section. If vapor extraction were ever considered for any of the localized areas at
LLNL where elevated levels of tritium occur in the unsaturated zone, the water ponion of the
vapor could be (1) released to the atmosphere or (2) separated from the vapor by condensation.
For possible tritium air releases from treatment systems, the AIRDOS-EPA computer model
would be used to evaluate the potential annual dose to a hypothetical maximally exposed
individual. LLNL will shut down any treatment system that emits tritium to the atmosphere at a
rate predicted to contribute to an exposure of greater than 10 millirem/year (the Federal standard
for clean air).
We estimate that it would take about 10 years to remediate the unsaturated zone under this
alternative and that remediation would be underway by late 1992.
Treatment Options for Unsaturated Zone Remedial Alternative No.1
Treatment Option 1. GAC Treatment. Vapors from vent wells would pass through a
chamber containing GAC to remove VOCs or FHCs. The treated vapor would be discharged to
the atmosphere.
Treatment Option 2. Thermal Oxidation. Vapors from vent wells would pass through a
thermal oxidation chamber where the FHC and VOC vapors would be oxidized with. the
assistance of a heat source such as propane. The VOCs and FHCs would be destroyed and
treated air would be discharged to the atmosphere.
Treatment Option 3. Catalytic Oxidation. Vapors from vent wells would be heated and
passed through a catalyst, where organic compounds would be convened to harmless oxidation
products, such as carbon dioxide and water. The treated air would be discharged to the
atmosphere. A catalyst suitable for both VOCs and FHCs has recently been found. The rationale
for preferring catalytic oxidation over thermal oxidation for treatment of vapors is presented in
Appendix B of the PRAP. If use of catalytic oxidation results in emission of vapors with
compounds above regulatory standards, secondary treatment or alternative technologies, such as
GAC, will be evaluated and implemented to comply with regulatory standards.
2.7.3.2. Unsaturated Zone Remedial Alternative No. 2-Defe"ed Action
Unqer this alternative, all contaminants in the unsaturated zone would be left in place and
allowed to degrade, volatilize, or migrate to ground water under natural conditions. Ground
water would continue to be monitored according to the requirements of CERCLA. If any
contamination of ground water above MCLs occurs, it would either be remedi.:.ted by ongoing
ground water extraction and treatment, or by additional ground water extraction and treatment
systems, if necessary.
2.7.3.3. Comparison 01 Unsaturated Zone Treatment Option Costs
The relative present wonh costs for the three vadose zone treatment options are discussed in
Section 4 of the FS. In summary, the present value of GAC is about 50% greater than for
thermal oxidation, and catalytic oxidation is about 20% less than thermal oxidation.
2.8. Summary of the Comparative Analysis of Alternatives
The remedial alternatives and associated treatment options were evaluated against nine EPA
criteria in the FS and PRAP. The preferred remedial alternatives for ground water and
unsaturated sediment were analyzed in terms of these nine criteria and are summarized in
Tables 7 and 8.
34
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UCRL-AR -1 091 05
Record of Decision
July 15,1992
Table 7. Comparison of ground water remedial alternatives for the LLNL Livermore site. a
Remedial
alternativel treatment
technologies
Remedial
Altemative No.1 b
UV loxidation-based
systems for Treatment
Facilities A, B, E, and F.
Air stripping-based
systems for Treatment
Facilities C, D (plus ion
exchange), and G.
Remedial
Altemative No.2
UV loxidation- based
systems for Treatment
Facilities A, B, and F.
Air stripping-based
system for Treatment
Facility C.
Remedial
Altemative No.3
Deferred treatment-
Air stripping at
point of distribution, if
necessary.
Protective of
buman health and
tbe environment
Risk is reduced by design
criteria tbat are lower tban
ARARs. Reduces ground
water contaminant concen-
trations to MCLs; design
criteria for treated ground
water are lower tban dis-
cbarge limits.
Risk is reduced by design
criteria that are lower than
ARARs. Reduces ground
water contaminant concen-
trations to MCLs; design
criteria for treated ground
water are lower than dis-
charge limits.
Risk reduced by treatment
at point-of-distribution (if
necessary). Ground water
quality would be degraded
until treatment begins or
concentrations naturally fall
below MCLs.
Compliance
with ARARs
Meets all ARARs.
Long.term
effectiveness
Effective.
Does not fully sat-
isfy the State of
Califomia ARAR
concerning non-
degradation of
water resources.
Effective.
Does not fully sat.
isfy the State of
California ARAR
concerning non-
degradation of
water resources.
Effecthoe.
a lising the nine EPA criteria for detailed evaluation of alternatives (l:.S. EPA, 198&, pp. 6-1 to 6-31).
b The selected alternative.
c Present worth is calculated to renect the time value of money in excess of inflation, as described In Section 5.2
of the PRAP (Dresen d aL, 1991).
d If monitoring of ground water onl~o were to be conducted for 100 years, the present worth cost would be $12
million.
liV = l:Itraviolet light.
35
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UCRL-AR -J 091 05
Record of Decision
July 15,1992
Reduce toxicity, Implementability Present
mobility, and Short-term (technical and worth State Community
volume or mass effectiveness administrative) costC acceptance acceptance
Reduces mobilit}' by ~egligible Impacts Implementable. $103 Acceptable Tbe community
downgradient during InstaUatlon and million accepts tbe concept
hydraulic operation. About SO or tbe selected
containment and years required to alternative, but
source area achieve ~CLs In ground desires funding
extraction. water. commitments, a
Toxicity/mass detailed imple.
reduced by mentation schedule,
extraction apd continued
surface treatment. opportunity for
Involvement, and a
faster cleanup.
Reduces mobility ~egliglble impacts Implementable. $99 ~ot The community
through during installation and million acceptable accepts the concept
downgradient operation. ~inety or of a pump and treat
hydraulic more years required to alternative, but
containment; allows achie\'e ~CLs In ground prefers Alternative
migration of water. ~o. 1 because it is
contaminants across more expedient
LL~L site. and employs active
Toxicity/mass source remediation.
reduced by
extraction and
surface treatment.
Reduces volume by Remediation deferred Implementable. $87 ~ot :\ot
natural degradation until or unless VOCs Alternative ma;)' milliond acceptable acceptable
rather than by Impact In-use water not be acceptable to
treatment. Allows supplies. Segligible regulatory agencies
migration of con- Impacts during instal- because it delays
tamlnants beyond lation and operation. remediation an
present extent, and Estimated 360 years for estimated 200
Increase In the natural degradation to years.
volume of reduce contaminant
contaminated concentrations below
water. MCLs, and 30 years to
achieve MCLs after
treatment commences In
200 years, If necessary.
36,
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UCRL-AR -109105
Record of Decision
July IS. 1992
Table 8. Comparison of unsaturated zone remedial alternatives for the LLNL Livermore site.-
Remedial
alternative
Remedial Alternative No. Ie
Immediate Action
Vacuum extraction and
catalytic oxidation.
Remedial Alternath'e No.2
Deferred Action
Remove contaminants
that have migrated to
ground water by
extraction and
treatment at the
nearest treatment
facility.
Protective of
human health and
the environment
Risk reduced by actively
removing contaminants
from tbe unsaturated
zone.
Risk to humans not
actively reduced until
VOCs or FHCs migrate
to ground water.
Ground water quality
would be degraded until
treatment begins or
natural processes reduce
concentrations below
MCLs.
Comply
with ARARs
Meets all ARARs.
Does not fully satisfy
a State of California
ARAR concerning
non-degradation of
water resources
where migration to
ground water will
result in concentra-
tions greater than
MCLs.
Long.term
effectiveness
Effective.
Effective.
a t:sing the nine EPA criteria for detailed evaluation of alternatives «(;.5. [PA, 1988a, pp. 6-1 to 6-31).
b Present worth Is calculated to renect the time value of money In excess of Innation, as described In Section 5.2
of the PRAP (Dresen et cd., 1991).
c The selected alternative.
,
37
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UCRL-AR-109105
Record of Decision
July 15,1992
Reduce toxicity, Implementability
mobility, and Short-term (technical and PreseDt State Community
volume or mass effectiveness administrative) wortb costb acceptance acceptance
Reduces mobility Negligible Impacts Implementable. $1.1 mUlion Acceptable The communi!}'
by actlvel~' during Installation accepts the con-
remov.ing VOCs ud operation. cept of the se-
from the About 10 years lected alternative,
subsurface. required to but desires
Reduces achieve remedial funding com.
toxicity/mass by action objectives. mitments, a
extraction and detailed Imple.
treatment at the mentation
surface. schedule, con-
tinued opportu-
nity for in-
volvement, and a
faster cleanup.
Does not reduce Effective for both Implementable. $0.9 million ~ot The community
contaminant mobil- VOCs and FHCs; acceptable appears 10 accept
ity in the unsatu- as much as 90 the concept of this
rated zone. Volume years required to alternative,
reduced by natural achieve remedial but prefers
degradation rather action objectives. Altemati~'e
than by treatment No.1.
in an estimated 9()
years.
2.8.1. Ground Water
Overall Protection of Human Health and the Environment. All the ground water
remedial alternatives are equally protective of human health (if institutional controls are in effect
for Alternative 3 to prevent new or existing wells from being used) because each is designed to
meetthe same cleanup criteria. Consequently, the resulting health risks are identical among the
alternatives (Isherwood et al., 1990). Since Alternatives 2 and 3 would allow some continued
migration of VOCs in ground water, they also allow some degradation of the subsurface
environment.
Compliance with ARARs. Ground water Remedial Alternatives No.1 and No.2 are
designed to achieve all ARARs (Isherwood et al., 1990). However, Alternative No.2 would
allow higher-concentration VOCs in eastern LLNL to migrate across the site, and thus does not
fully satisfy the State of California ARAR regarding non-degradation of water resources.
Remedial Alternative No.3, treat at point-of-use, though estimated to be protective of human
health (Isherwood er aI., 1990), does not fully satisfy the California non-degradation ARAR.
38
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UCRL-AR-109105
Record of Decision
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Long- Term Effectiveness and Permanence. All three remedial alternatives are equally
effective in terms of permanence and stability of remediation and reduction in health risks by
removing and treating the contaminants.
Reduction in Toxicity, Mobility, and Volume. Remedial Alternatives No.1 and
No.2 reduce toxicity, mobility, and volume of the compounds. Alternative No.1 does not allow
additional contaminant migration beyond the current extent downgradient. Alternative No.2
allows VOCs in eastern LLNL to migrate across the site. Remedial Alternative No.3, deferred
action, allows more contaminant mobility than Alternative No.2 and does not reduce
contaminant mobility until and unless contaminants reach domestic or municipal wells in
concentrations above an MCL.
An advantage of the UV/oxidation remediation technology (preferred at Treatment Facilities
A, B, E, and F) is that TCE, PCE, 1,I-DCE, and FHCs are destroyed in one process,
thereby minimizing waste requiring further treatment or disposal. Use of GAC requires
regeneration of spent carbon to conven the captured compounds to harmless substances. Ion-
exchange resins for metals removal may require disposal as hazardous waste.
Short-Term Effectiveness. All the remedial alternatives would expose workers, the public,
and the environment to negligible impactS during installation and operation.
The selected remedial alternative is estimated to achieve the remediation goals in about 50
years compared to 90 years or more for Remedial Alternative No.2, which employs only four
treatment facilities and ten extraction locations. Alternative No.3 may take about 230 years to
achieve remediation goals, and remediation may not begin for 200 years. Each treatment option,
combined with the same remedial alternative, would require about the same length of time to
achieve the remediation goals. For Alternative No. I, it is estimated that plume containment and
overall hydraulic control will be achieved in 1995. This estimate will be funher refined in the
Remedial Design.
Implementability. Each of the remedial alternatives and technology options is technically
and administratively feasible and supponed by available services, materials, and skilled labor.
An advantage of the UV /oxidation technology over the GAC technology is that regeneration of
the spent carbon is unnecessary. The air-stripping-based and UV /oxidation-based technologies
generate substantially less spent carbon than the GAC system for water treatment. UV /oxidation
and GAC technologies also have minimal visual impact compared to air-stripping towers.
Cost. The present wonh of Ground Water Remedial Alternative No.1 (the selected
alternative) is estimated to be $103 million, assuming.50 years of operation. The present wonh
for 90 years of operation for Remedial Alternative No.2 is $99 million. The present wonh for
Remedial Alternative No.3 is $87 million, assuming air strippirig is the treatment option used. If
Remedial Alternative No.3 consisted only of monitoring ground water for 100 years, the present
wonh would be $12 million.
State Acceptance. The California RWQCB and DTSC accept the selected ground water
remedial alternative, Remedial Alternative No.1. The RWQCB does not accept Ground Water
Alternatives No.2 and No.3 since they do not fully satisfy the California non-degradation
ARAR.
Community Acceptance. The community accepts the general concept of the selected
alternative, but desires funding commitments, a detailed implementation schedule, continued
opponunity for involvement, and a faster cleanup. Implementation schedules will be included in
post-ROD documents called the Remedial Action Implementation Plan and the Remedial
DesignlRemedial Action reports. LLNL is continually exploring and implementing new
methods and techniques that will accomplish the fastest cleanup.
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Record of Decision
July IS, 1992
2.8.2. Unsaturated Zone
The remedial alternatives for the unsaturated zone are described below and compared in
Table 8 in tenns of the EPA evaluation criteria.
Overall Protection of Human Health and the Environment. Unsaturated Zone Remedial
Alternative No.1 is protective of human health and the environment and creates minimal health
risks. Remedial Alternative No.2 has some impact on the subsurface above the water table as
contamin,,"ts would be allowed to migrate naturally. Estimates indicate natural processes would
reduce the concentrations to below MCLs in 90 to 140 years (Isherwood el al., 1990, Appendix
G).
Compliance with ARARs. Remedial Alternative No.1 is designed to achieve ARARs.
Alternative No.2 may allow contaminants to reach the ground water in concentrations exceeding
MCLs in a few isolated places (i.e., the Gasoline Spill and Building 518 Areas, and perhaps the
East Taxi Strip Area), and therefore does not meet the California non-degradation ARAR.
Long- Term Effectiveness and Permanence. Both of the alternatives are effective in the
long run and reduce health risks permanently by removing and treating contaminants.
Reduction in Toxicity, Mobility, and Volume. Remedial Alternative No.1 results in the
immediate removal and complete breakdown of compounds to harmless substances, thereby
permanently reducing toxicity, mobility, and volume. Remedial Alternative No.2 (deferred
action) allows VOCs and FHCs to continue to migrate through the unsaturated zone to the
ground water. VOCs and FHCs would then be extracted and treated in the ground water at the
nearest treatment facility.
Short-Term Effectiveness. Both alternatives would expose workers, the public, and the
environment to negligible impacts during installation and operation. Achieving the remediation
objectives is estimated to require 10 years for the selected alternative, Alternative No. I, and 90
years for Alternative No.2.
Implementability. Both alternatives are technically and administratively feasible and
supponed by available services, materials, and skilled labor.
Cost. Present worth cost for 10 years of operation for the preferred alternative is
$1.1 million. The preferred alternative utilizes the most cost effective treatment option available
for both VOCs and FHCs. The present wonh of Alternative No.2 is $850,000.
State Acceptance. The California RWQCB and DTSC accept the selected unsaturated zone
alternative, Remedial Alternative No. 1. The RWQCB does not accept Unsaturated Zone
Alternative No.2 since it may allow ground water degradation.
Community Acceptance. The community accepts the general concept of the selected
unsaturated zone alternative, but desires funding commitments, Ii detailed implementation
schedule, continued opportunity for involvement, and a faster cleanup. Implementation
schedules will be included in post-ROD documents called the Remedial Action Implementation
Plan and the Remedial Design/Remedial Action repons. LLNL is continually exploring and
implementing new methods and techniques that will accomplish the fastest cleanup.
2.9. The Selected Remedies
Based on the requirements of CERCLA, the detailed analysis of the alternatives, and public
comments, DOE, LLNL, EPA, the DTSC of the California Environmental Protection Agency,
and the California RWQCB have determined that Alternative No.1 for ground water (pumping
and surface treatment by UV/oxidation and air stripping), and Alternative No.1 for the
40
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UCRL-AR-109105
Record of Decision
July 15,1992
unsaturated zone (vacuum-induced venting and surface treatment of vapors by catalytic
oxidation), are the most appropriate remedies for LLNL.
The selected remedies for this site protect human health and the environment, comply with
Federal, State, and local requirements (ARARs), are implementable, and permanently and
significantly reduce the toxicity, mobility, and volume of the contaminants.
The goal of this remedial action is to remediate ground water to the ARARs specified in the
PRAP anq this ROD. Based on information obtained during the RI and on a careful analysis of
all remedial alternatives, DOE, LLNL, EPA, DTSC, and the RWQCB believe that the selected
remedy will achieve this goal. The approach to be taken to the remediation will involve close
monitoring of ground water quality in monitor wells, extracted water quality in extraction wells,
and water level elevations near the extraction centers. The extraction well field will be operated
dynamically to optimize the cleanup. That is, based on the results from the monitoring plan,
individual wells may operate continuously, may be turned off, or may be pumped intermittently.
During the course of the remediation, new wells will be installed at appropriate locations and will
be operated in the same manner.
To ensure that cleanup levels continue to be maintained, the ground water will be monitored
until DOE and the regulatory agencies agree that cleanup is complete.
2.9.1. Ground Water
The primary purpose of the selected ground water remedy is to contain VOCs and prevent
funher downgradient and offsite migration in ground water, and to reduce the concentrations of
contaminants in ground water after cleanup to levels below MCLs, the designated cleanup levels.
Existing conditions at the site may pose an excess lifetime cancer risk of 2 x 10-3 from ingestion
of ground water contaminated with VOCs (primarily TCE) under health-conservative no
remediation assumptions. The selected alternative will address all ground water contaminated
with VOCs in excess of 5 ppb and will assure that ARARs for individual VOCs, FHCs, lead,
chromium, and ttitium will be achieved.
The selected ground water remedy involves immediately pumping water at approximately 18
initial locations within the ground water plume (Fig. 7). The total rate of ground water removal
for this extraction plan is estimated to be about 350 gpm. Water will be pumped from one or
more wells at each of these locations using existing monitor and extraction wells, along with new
extraction wells. The well locations will be chosen to prevent any VOCs from escaping from the
area in concentrat:ons above their MCLs. To enable more rapid remediation, wells will also be
placed in all areas where VOC or FHC concentrations in ground water exceed 100 ppb.
Additional extraction locations may be added to ensure complete hydraulic capture of the plume,
and/or to expedite cleanup, if field data indicate additional wells are necessary.
Seven onsite facilities (A to G) will be constructed initially to treat the extracted ground
water (Fig. 7). Each treatment facility will be designed to treat a somewhat different
combination of compounds. Treatment Facilities A, B, E, and F will use UV/oxidation as the
primary treatment technology. Treatment Facilities C, D, and G will use air-stripping as the
primary treatment technology. All facilities will use GAC to remove VOCs and FHCs from air
streams, and Treatment Facility F will use GAC to remove lead from ground water. Treatment
Facility D will use ion exchange to remove chromium from ground water.
The maximum additional cancer risk after remediation is complete is calculated at seven in
one hundred million (7 x 10.8) using the best estimate assumptions. This is over 100 times lower
than the one in ten thousand to one in ten million (1 x 10-4 to I x 10-7) acceptable level of risk
specified in the NCP (U.S. EPA, 1990). The HI for this scenario is far less than 1.0, indicating
that no adverse health effects from noncarcinogens would occur following the planned
remediation. Using health-conservative assumptions that EP A prescribes for assessing site risks,
41
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UCRL-AR-109105
Record of Decision
July 15,1992
the risk of cancer after remediation, based on a potential monitor well drilled 250 feet west of
LLNL, is 4 ;It 10-5, and 3 x 10-5 for potential receptor wells in downtown Livermore. Both of these
values are within the EPA acceptable risk range. The hazard indices for both health-conservative
scenarios are far less than 1 (2.7;1t 10-2 and 3.1 ;It 10-2. respectively), indicating no adverse health
affects from noncarinogens after the planned remediation.
2.9.2. Unsaturated Zone
The selected remedy for the unsaturated zone involves using vacuum-induced venting to
extract contaminant vapors from the unsaturated sediments and treating the vapors by catalytic
oxidation. Use of a catalytic oxidizer provides the flexibility to treat both FHCs and VOCs
together and substantially reduces the potential for producing dioxin. The purpose of this
response action is to prevent migration of VOCs and FHCs to ground water in concentrations
that would impact the ground water in concentrations above MCLs.
Current data indicate that only FHCs in the Gasoline Spill Area, VOCs in the Building 518
Area in the southeastern pan of the LLNL site, and possibly VOCs in the vicinity of the East
Taxi Strip in eastern LLNL will need unsaturated zone remediation (Isherwood et al., 1990).
FHCs and/or VOCs will be removed from the subsurface by vacuum-induced venting using
extraction wells.
The selected treatment option for the extracted vapors is catalytic oxidation. In this process,
vapors from vent wells will be heated and passed through a catalyst, where organic compounds
are convened to hannless oxidation products, including carbon dioxide and water. If use of
catalytic oxidation should result in emission of vapors with compounds above regulatory
standards, secondary treatment or alternative technologies, such as GAC, will be evaluated and
implemented to comply with regulatory standards.
The decision regarding whether an area requires vadose zone cleanup will be based on
unsaturated zone modeling and ground water monitoring. If modeling indicates that hazardous
materials will impact ground water in concentrations above an MCL, remediation will be
implemented. Remediation will continue until in situ concentrations, as verified by soil
sampling, are below those predicted to impact ground water above MCLs. In addition, the
ground water near the potential source will be monitored for impacts on ground water quality.
Details of the modeling and monitoring will be presented in the Remedial Design.
2.10. Statutory Determinations
Section 121 of CERCLA specifies that the selected remedial actions must comply with all
Federal and State ARARs, be cost-effective, be protective of human health and the environment,
and utilize pennanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. In addition, the selected remedies should
employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as their principal element. The selected remedies for ground water and the
unsaturated zone are the same as those described in the PRAP and meet these statutory
requirements as discussed below.
2.10.1. Protection of Human Health and the Environment
The selected remedy for ground water will provide adequate protection of human health and
the environment through extraction of contaminated ground water and treatment at the surface to
reduce in situ concentrations below MCLs. Discharges to the air will be designed for no
measurable contaminant emissions. In addition, further offsite migration of the contaminant
plume will be prevented. The selected remedy will reduce exposure to levels within or below
EPA's acceptable carcinogenic risk range of 10-4 to 10-7, and hazard indices will be far below
1.0 after cleanup.
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UCRL-AR -109105
Record of Decision
July 15, 1992
Vacuum-induced venting of the unsaturated zone will remove subsurface VOCs and FHCs
and prevent contaminant migration to ground water. Implementation of the selected remedies
will not pose unacceptable shon-term risks or impact the adjacent subsurface media, other than
some lowering of water levels due to ground water extraction. Lowering of the water table will
be mitigated by locally recharging the ground water with treated ground water.
2.10.2. Compliance with ARARs
The se~ected remedies will comply with all Federal and State ARARs, including the to be
considered (TBC) criteria in Appendix B. Table 1 and Table B-1 in Appendix B list and describe
the ARARs and TBCs that will be attained by each selected remedy.
2.10.3. Cost.Effectiveness
The selected remedies provide overall effectiveness proponionate to their costs. Present
wonh cost estimates for each alternative are presented in Tables 5 and 6. Although the selected
remedies cost somewhat more in terms of present wonh compared to the other alternatives, they
enable more rapid cleanup.
2.10.4. Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedies utilize permanent solutions and alternative treatment technologies to
the maximum extent practicable. The selecte9 alternatives permanently remove contaminants
from ground water and the unsaturated zone by extraction and treatment at the surface using
UV/oxidation, air stripping, GAC, and ion exchange for ground water and catalytic oxidation for
vapor. Both selected alternatives provide the best balance of tradeoffs among the alternatives,
and use treatment technologies that destroy most contaminants, convening them to hannless
compounds.
The selected alternatives will reduce contaminant mobility more than the other alternatives.
Although the. selected alternatives have a higher present wonh cost than the other alternatives,
the selected alternatives will accomplish the cleanup objectives in a shoner time period.
Therefore, reducing contaminant mobility and expediting cleanup time (shon-term effectiveness)
were the most imponant primary balancing criteria in selecting the remedies.
For both selected alternatives, overall protection of human health and the environment and
the compliance with ARARs were also decisive factors in remedy selection. Community
concerns were included in the decision-ma!-:ing process by addressing community input received
at CWG meetings and during the public comment period on the PRAP. The Responsiveness
Summary, attached to this ROD, addresses community comments on the remedial alternatives.
2.10.5. Preference for Treatment as a Principal Element
The selected remedial actions satisfy the statutory preference for selecting remedies in which
treatment that pennanently and significantly reduces the volume, toxicity or mobility of the
contaminants is a principal element. The selected remedial action for ground water uses
treatment to address the contaminated ground water, which is the principal medium of concern.
UV/oxidation-based technology destroys contaminants leaving residual harmless compounds
such as carbon dioxide and water. Both UV /oxidation and air stripping-based technologies will
achieve a permanent and significant reduction of the toxicity, mobility, or volume of the
contaminants. Similarly, for the unsaturated zone, vacuum-induced venting followed by catalytic
oxidation of the extracted vapor will destroy VOCs and FHCs after removal from contaminated
soil, thereby also meeting this statutory preference.
...
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UCRL-AR-109105
Record of Decision
July 15, 1992
References
California Department of Water Resources (DWR) 1974, Evaluation of Ground Water
Resources: Livermore and Sunol Valleys, Bulletin No. 118-2.
Dresen, M. D., W. F. Isherwood, and 1. P. Ziagos (1991), Proposed Remedial Action Plan for the
Lawrence Livermore National Laboratory Livermore Site, Livermore, California, Lawrence
Livennore National Laboratory, Livermore, Calif. (UCRL-AR-105577).
Federal Pacility Agreement under CERCLA Section 120 between the United States
Environmental Protection Agency, the United States Department of Energy, the California
Department of He,alth Services, and the California Regional Water Quality Control Board,
1988.
Fish, W. (1987), Subsurface Transport of Gasoline-Derived Lead at a Filling Station
Contamination Site in Yakima, Washington, Proceedings of the NWWA FOCUS Conference
on Nonhwestern Ground Water Issues, May 5-7, 1987, pp. 557 through 567.
Hoffman, F. (1991a), Possible Sources of Chromium in the Vasco Road - Patterson Pass Road
Area, Livermore, California, letter from Fred Hoffman, LLNL Environmental Restoration
Division Leader, to John Chesnutt, U.S. EPA Remedial Project Manager, dated August 16,
1991.
Hoffman, F. (1991b), Evaluation of Health Risk from Volatilization of Compounds from the
Vadose Zone, letter from Fred Hoffman, LLNL Environmental Restoration Division Leader,
to John Chesnutt, U.S. EPA Remedial Project Manager, dated August 16, 1991.
Hoffman, F. (1992), Results of Lead in Ground Water Analysis, letter from Fred Hoffman, LLJ\TL
Environmental Restoration Division Leader, to John Chesnutt, U.S. EPA Remedial Project
Manager, dated March 2, 1992.
International Agency for Research on Cancer (lARC) (1982), "Benzene," fARC Monographs on
the Evaluation of the Carcinogenic Risk of Chemicals to Humans, Suppl. 4 (World Health
Organization, IARC, Lyon, France), pp. 87-88.
Iovenitti,1. L., J. K." Macdonald, M. D. Dresen, W. F. Isherwood, and J. P. Ziagos (1991),
Possible Sources of VOCs in the Vasco Road-Patrerson Pass Road Area, Livermore,
California, Lawrence Livennore National Laboratory, Livermore, Calif. (UCRL-AR-
106898).
Isherwood, W. F., C. H. Hall, and M. D. Dresen (1990), CERCLA Feasibility Study for the
LLNL-Livermore Site, Lawrence Livermore National Laboratory, Livermore, Calif.
(UCRL-AR-I04040).
Layton, D. W., J. 1. Daniels, and W. F. Isherwood (1990), Baseline Public Health Assessmentfor
CERCLA fnvesrigarions at rhe LLNL Livermore Sire, Lawrence Livermore National
Laboratory, Livennore, Calif. (UCRL-53953).
Macdonald, J. K., M. D. Dresen, and W. F. Isherwood (Eds.) (1990), LLNL Ground Water
Projecr Monthly Progress Reporr, October 1990, Lawrence Livennore Nationaj Laboratory,
Livermore, Calif. (UCAR-lOl60-90-lO).
Rice, D.W., Jr. (1988), Quality Assurance Project Plan, UNL Ground Water Projecr, Lawrence
Livermore National Laboratory, Livermore, Calif. (UCAR-10219).
Sims, 1. M., K. A. Surano, K. C. Lamson, M. G. Brown, and G. M. Gallegos (Eds.) (1990),
Environmental Reporrfor 1989, Lawrence Livennore National Laboratory, Livennore, Calif.
(UCRL-50027 -89).
44
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UCRL-AR-/09J05
Record of Decision
July 15, /992
Thorpe, R. K., W. F. Isherwood, M. D. Dresen, and C. P. Webster-Scholten (Eds.) (1990),
CERCLA Remedial Investigations Reportfor the UNL Livermore Site, Lawrence Livermore
National Laboratory, Livermore, Calif. (UCAR-10299).
U.S. Department of Energy (DOE) and University of California (1992), Draft Environmental
Impact Statement and E'nvironmentallmpact Report for Continued Operation of Lawrence
Livermore National Laboratory and Sandia National Laboratories, LiverlMre, University of
California, Berkeley, Calif. (SCH-90030847).
U.S. Environmental Protection Agency (EPA) (1988a), Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA (Interim Draft), Office of Emergency
and Remedial Response, Washington, D.C. (OSWER Directive 9355.3-01) (October 1988).
U.S. Environmental Protection Agency (EPA) (1988b), CERCLA Compliance with Other Laws
Manual, Office of Emergency and Remedial Response, Washington, D.C. (OSWER
Directive 9234.1-01).
U.S. Environmental Protection Agency (EPA) (1989a), Risk Assessment Guidance for
Superfund, Human Health Evaluation Manual, Part A: Interim Final, EPN540/1-891002,
Washington, D.C.
U.S. Environmental Protection Agency (EPA) (l989b), Interim Final Guidance on Preparing
Superfund Decision Documents, Office of Emergency and Remedial Response, Washington,
D.C. (OSWER Directive 9234.1-01) (June 1989).
U.S. Environmental Protection Agency (EPA) (1990), "40 CFR, Pan 300, National Hazardous
Substances Pollution Contingency Plan, Final Rule," Federal Register, Vol. 55, No. 46,
March 8, 1990, p. 8716.
45
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Appendix A
Tables Summarizing
Predicted Cancer Risks and
Hazard Quotients for
Offsite Exposure
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UCRL-J09105 Record of Decision July 15,1992
Table A.I. Predicted cancer risks for the best-estimate exposure scenario based on EPA methodology.
Predicted Oral Oral Inhalation EPA
concentrationb intake cancer cancer total cancer
Receptor location8 Chemical (mglL) (mglkg-d) risk risk risk
Maximum chloroform.
concentration
Chloroform 1.5xl~ 4.3xl~ 3xl0-8 3xl0-7 4xl0-7
Maximum TCE
concentration TCE 1.0xl~ 2.9xl~ 3xl0-8 4xl~ 7xl~
1,I.DCE S.6xlO~ 1.6 X 10-7 lxlo-7 2xl0-7 3xl0-7
Carbon 4.4xl0~ 1.3 X 10-7 2xl0-8 2xl0-8 ~
tetrachloride Sum = 4xl0-7
Maximum l,l-DCE and
carbon tetrachloride
concentrations
TCE 8.0xlO-5 2.3xl~ 2xl0-8 3xl0-8 5xlO~
Chloroform 1.0xlO-5 2.9x10-7 2xlo-9 2xl0-8 2xl0-8
1,I.DCE 1.1xl0-5 3.lxlo-7 2xlo-7 4x 1 0-7 6xl0-7
Carbon 9.0xIO~ 2.6 X 10-7 3xl0-8 3xl0-8 ~
tetrachloride Sum = 7xl0-7
Maximum PCE
concentration
PCE
1.OxIO-5
2.9xIO-7
Ixl0-8
9xlO-lO
2x10~
8 All reteptor wells are 2 miles west or LL~L.
b Predicted maximum ground water concentrations have been reduced by a ractor or ten to account ror In-well dilution
that would occur because the municipal well would draw water rrom both contaminated and uncontaminated zones.
A-I
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UCRL-109105 Record of Decision July 15, 1992
Table A.2. Predicted cancer risks for the health.conservative exposure scenario based on EPA methodology.
Predicted Oral Oral Inhalation EPA
concentration intake cancer cancer total cancer
Receptor location Chemical (mg/L) (mglkg-d) risk risk risk
250 feet west of LLNL
Maximum chloroform
concentration
PCE 6.2xl0-3 l.8xl0-4 9xlo-' 6x 1 0-' lxl0-5
TCE 2.6xIO-1 7.4xI0-3 8xlO-5 Ix 1 0"""' 2x10-4
Chloroform S.Sxl0-2 1.6x10-3 Ixl0-5 Ix I 0"""' Ix 10-4
l,l-DCE 1.0xl0-2 2.9xl0-4 2x I ()-'4 3xl0"""' Sxl0-4
Carbon 7.9xl0-3 2.3 x 10-4 3xl0-5 3xlo-5 ~-s
tetrachloride Sum = 9x10-4
Maximum TCE, 1,1-
DCE, and carbon
tetrachloride
concentrations PCE S.2xI0-2 l.SxlO-3 8x10-5 Sxl0-6 8xlO-s
TCE 4.7xlO-1 1.3xIo-2 lxIO-4 2xt0-4 3xl0-4
Chloroform 2.0xlO-2 S.7xl0-4 3xlo-' 5x10-5 5xlO-s
t,I-DCE 2.4xlO-2 6.7xt0-4 4xI0-4 8x10-4 lxlO-3
Carbon 1.8xl0-2 5.3xI0-4 7xl0-5 7x10-5 QlQ-4
tetrachloride Sum= 2xt0-3
Maximum PCE
concentration PCE 2.7xI0-l 7.7xI0-3 4x10-4 3x10-5 4x10-4
TCE 6.2xI0-2 1.8x10-3 2x10-5 2x I 0-5 4x I 0-5
Chloroform 8.2xI0-3 2.3xI0-4 IxIO~ 2x10-5 2x10-5
l,l-DCE 1.4xlO-2 4.0xl0-4 2x10-4 5x10-4 7x10-4
Carbon l.lxlo-2 3.lxl0-4 4xlo-5 4x10-5 8,ill-5
tetrachloride Sum = lxlO-3
A-2
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UCRL-l 091 05 Record of Decision July 15, 1992
Table A-2. (Continued)
Predicted Oral Oral Inhalation EPA
concentration intake cancer cancer total cancer
Receptor location Chemical (mglL) (mglkg-d) risk risk risk
1 mile west of LLNL
Maximum chloroform
concentration
PCE S.9xlo-3 1.7xl()-4 9xl~ 6xlo-' 9xl~
TCE 2.4xlo-1 6.9xlo-J 8xlo-s 9xl0-5 2xl()-4
Chloroform 4.9xlo-2 1.4xlo-3 9n~ lxl()-4 lxl()-4
1,1-DCE 1.0xlo-2 2.9xl()-4 2xl()-4 3xl()-4 Sxl()-4
Carbon 7.9xl0-3 2.3xl()-4 3xlo-s 3xlo-s ~-s
tetrachloride Sum= 9xl0-4
Maximum TCE, 1,1-
DeE, and carbon
tetrachloride
concentrations PCE S.2x 1 0-2 l.Sxlo-3 8xlo-s Sxl~ 8xlo-s
TCE 3.8xlO-l l.lxlo-2 lxl()-4 lxl()-4 3xl0-4
Chloroform 1.7xlO-2 4.9xl()-4 3xlO...(i 4xl0-5 4xlO-s
l,l-DCE 2.2xlO-2 6.4xl()-4 4xl()-4 8xl()-4 lxlo-J
Carbon 1.8xlO-2 S.Oxl()-4 7xlO-s 7xlO-s ~-4
tetrachloride Sum= 2xl0-3
Maximum PCE
concentration PCE 2.lxlO-l 6.0xlo-3 3xl0-4 2xlO-s 3xl0-4
TCE S.8xlo-2 1.7xlo-3 2xlo-s 2xlO-s 4xlo-s
Chloroform 7.3xlO-J 2.1 xl()-4 lxl~ 2xlo-s 2xlO-s
l,l-DCE l.SxlO-2 4.2xl()-4 2xl0-4 SxlO-4 7xl0-4
Carbon 1.lxlO-J 3.3xl()-4 4xlo-s 4xlo-s ~-s
tetrachloride Sum = lxlO-3
"
A-3
-------
UCRL-1 091 05 Record of Decision July 15, 1992
Table A-2. (Continued)
Predicted Oral Oral InhalatioD EPA
concentration intake cancer cancer total cancer
Receptor location Chemical (mglL) (mglkg-d) risk risk risk
2 miles west of LLNL
Maximum chloroform
concentration
PCE 6.lx10-3 1.7xlo-" 9xlo-' 6xlo-' 9xl0-6
TCE 2.3xlo-l 6.6xlo-J 7xl0-5 9xlo-S 2x10""
Chloroform 4.5x I 0-2 1.3xlo-J 8xlo-' lxlo-" lxlo-"
l,t.DCE 1.0 X 10-2 2.9xlo-" 2xlo-" 3xlo-" Sxl0-4
Carbon 7.9xl0-3 2.3xlo-" 3xl0-5 3xl0-5 ~-s
tetrachloride Sum = 9xl0-4
Maximum TCE, 1,1-
DCE, and carbon
tetrachloride
concentrations PCE 4.9xlO-2 1.4xlo-3 7xlo-s Sxl0-6 8xl0-5
TCE 3.4xIO-1 9.7xlo-3 lxlo-" Ix 10"" 2x I 0""
Chloroform 1.6xIO-2 4.6xl0-4 3xl0~ 4x10-s 4x10-5
1,I.DCE 2.0xlo-2 S.6xlo-" 3xl0-4 7xlO"" lxl()-3
Carbon l.Sxlo-2 4.4xl0-4 6xlo-s 6xl0-s J.2$JJl-4
tetrachloride Sum = lxl ()-3
Maximum PCE .
concentration PCE 1.7xIO-1 4.9xlo-J 2x 10-4 2x10-5 3x I 0""
TCE S.6xlo-2 1.6xlo-J 2x 1 0-5 2xlo-S 4xl0-5
Chloroform 6.9xIO-J 2.0xl0-4 lxl0-6 2xlo-5 2xl0-5
1,I.DCE 1.3xlO-2 3.8xl0-4 2xl0-4 Sx 10-4 7xl0-4
Carbon l.lxlo-J 3.0xlo-" 4xlo-s 4xlo-s ~5
tetrachloride Sum = lxl0""'3
A-4
-------
UCRL-1 091 05
Record of Decision
July 15,1992
Table A-3. Calculation of the noncarcinogenic hazard index for the best-estimate exposure scenario.
Predicted Water EPA
concentrationb ingestion hazard index
Observation point' Chemical (mg/L) (mglkg-d) (exposurelRfd)
Maximum chloroform
concenlratwn Chloroform 1.Sxl0-4 4.3xl~ 4.3xl~
Maximum TCE
concenlratWn TCE 1.0 x 10-4 2.9xl~ NA
l,l-DCE S.6xl~ 1.6 X 10-7 l.8xlo-s
Carbon 4.4xl~ 1.3xl0-7 ~
tetrachloride Sum = 2.0xl~
Maximum carbon
tetrachloride and I,I-DeE
concentratWns
Chloroform
l,l-DCE
Carbon
tetrach loride
2.0xlO-s S.7xlO-7 S.7xlO-s .
4.SxlO-s l.3xlO~ 1.4xl~
3.SxlO-s 1.0 x 10-7 UtlQ-3
Sum = 1.6xlo-3
Maximum PCE
concentratWn
PCE
1.0xlO-s
2.9xlO-7
2.9xlO-S
~A = ~ot available.
a All receptor wells are 2 miles west of LL~L.
b Predicted maximum ground water concentrations have been reduced by a factor of ten to account for in.well dilution
that would occur because the municipal well would draw water from both contaminated and uncontaminated zones.
A-5
-------
UCRL-109105 Record of Decision July 15,1992
Table A-4. Calculation of the noncarcinogenic hazard index for the health-conservative exposure scenario.
Predicted Water EPA
concentration ingestion hazard index
Observation point Chemical (mg/L) (mg/kg-d) (exposureiRFD)
Well250 feet west of LLNL
Maximum chloroform
concentratwn PCE 6.2x10-3 1.8xl
-------
UCRL-109105 Record of Decision July 15, 1992
Table A-4. (Continued)
Predicted Water EPA
concentration ingestion hazard index
Observation point Chemical (mglL) (mglkg-d) (exposureiRFD)
Maximum TCE, l,l-DCE,
and carbon tetrachloride
concentrations PCE S.2x10-2 I.Sx10-3 lxlo-l
TCE 3.8xlo-l 1.lx10-2 NA
Chloroform 1.7xl0-2 4.9xl~ Sxl0-2
l,l-DCE 2.2x10-2 6.4xl~ 7xl0-2
Carbon 1.8xl0-2 S.Oxl~ ~l
tetrachloride Sum = IxlOo
Maximum PCE
concentration PCE 2.lxlo-l 6.0xlo-J 6xlo-l
TCE S.8x10-2 1.7x I 0-3 NA
Chloroform 7.3xIO-3 2.lxl~ 2xl0-2
l,l-DCE l.Sx10-2 4.2xI0-4 Sxl0-2
Carbon l.lxIO-2 3.3xl~ ~l
tetrachloride Sum= IxlOo
Well 2 miles west of LLNL
Maximum chloroform
concentrations PCE 6.lxI0-3 1.7xl~ 2xl0-2
TCE 2.3xI0-l 6.6xI0-3 NA
Chloroform 4.5xIO-2 1.3 x 10-3 lxlo-l
l,l-DCE 1.0x10-2 3.2xl~ 3xl0-2
Carbon 7.9x10-3 ' 1.9 x 10-4 J2il!rl
tetrachloride Sum = Sxlo-l
Maximum TCE, l,l-DCE,
and carbon tetrachloride
concentrations PCE 4.9xIO-2 1.4x I 0-3 Ix 10-1
TCE 3.4xlo-l 9.7x10-3 NA
Chloroform l.6xl0-2 4.6xl~ Sxl0-2
1,I-DCE 2.0xlo-2 5.6xl~ 6xlo-2
Carbon 1.5 xl 0-2 4.4xl~ ~l
tetrachloride Sum= 9xlo-l
Maximum TCE,I,J-DCE,
and carbon tetrachloride
concentrations PCE 1.7xlo-l 4.9x10-3 Sxlo-l
TCE S.6xtO-2 1.6xlo-J NA
Chloroform 6.9xIO-3 2.0xl~ 2xlo-2.
l,t-DCE 1.3 xl 0-2 3.8xl~ 4xl0-2
Carbon l.lx10-2 3.0xl~ ~l
tetrachloride Sum = txlOo
A-7
-------
Appendix B
LLNL ARARs
-------
UCRL-AR-l09J05
Record of Decision
July 15. 1992
Appendix B
LLNL ARARs
This Appendix discusses those standards, requirements, criteria, or limitations under
Federal environmental law, and any promulgated standards, requirements, criteria, or
limitations under State environmental or facility siting law that are more stringent than
those provided under Federal law, that the signatories to LLNL's Federal Facility
Agreement consider legally applicable or relevant and appropriate to the LLNL site. In
addition, nonpromulgated criteria advisories or guidance that do not meet the definition
of Applicable or Relevant and Appropriate Requirements (ARARs), but that may assist in
determining what is necessary to be protective, are listed as to be considered..(TBC).
Some of these apply to remediation activities, such as discharges from treatment
facilities, whereas others form the basis for determining when cleanup is complete. Table
B-1 is a summary of corresponding ARARs for ground water and the vadose zone. A
complete discussion of LLNL ARARs is presented in Section 3 of the Feasibility Study
(FS) (Isherwood et aI., 1990).
There are three general kinds of ARARs: chemical-specific, location-specific, and
action-specific. Chemical-specific ARARs usually result in health- or risk-based
concentration limits. The Comprehensive Environmental Re~ponse, Compensation, and
Liability Act (CERCLA) Compliance with Other Laws Manual (U.S. EPA, 1988b)
contains a nonexhaustive list of potential chemical-specific ARARs from which LLNL
has drawn to ensure that no ARAR is overlooked.
The chemical-specific concentrations proposed as remedial action objectives for
ground water remediation are given for the compounds of concern at LLNL in Table 1 of
this document. The standards in the columns of Federal and State drinking water
Maximum Contaminant Levels (MCLs) and Federal non-zero Maximum Containment
Levels Goals become remedial action objectives for ambient ground water (i.e., ground
water left in place after remediation), whereas the discharge limits given in the last
column apply to discharges of treated water under LLNL's National Pollution Discharge
Elimination System permit. The most stringent concentration limit is the governing
ARAR for each chemical of concern.
San Francisco Bay Area Regional Water Quality Control Board's Basin Plan ("Basin
Pian") taste and odor objectives are not considered an ARAR because acceptable
numerical expressions of these objectives are not available at the present time. There is
no methodology for enforcement of these objectives and consequently they have not been
enforced by the State. We, therefore, cannot use the Basin Plan's taste and odor
objectives to establish a cleanup level for compliance purposes. If in the future a method
is established for measurement and achievement of the Basin Plan's taste and odor
objectives and achievement of those objectives is determined to be applicable or relevant
and appropriate arid necessary to ensure that the remedy is protective of human health and
the environment, then LLNL will consider the objectives applicable to the cleanup.
If any additional hazardous substances are found in the ground water environment at
levels of concern in the future, standards for those will be requested and agreed upon with
the U.S. Environmental Protection Agency and the California Depanment of Toxic
Substances Control.
Resource Conservation Recovery Act (RCRA) Section 3020 bans hazardous disposal
by underground injection into or above a source of drinking water unless the reinjection
involves treated ground water from'a CERCLA response action. This section does not
apply if cenain conditions are met. At LLNL, proposed injection is a CERCLA response
B-1
-------
UCRL-AR-109105
Record of Decision
July 15, /992
action intended to clean up contamination; the contaminated ground water will be treated
to substantially reduce hazardous constituents prior to such injection; and the response
action will be sufficient to protect human health and the environment upon completion.
LLNL thus meets the conditions for exemption and is not subject to the ban.
Whereas specific ARARs do not appear to exist as cleanup standards for vadose zone
sediments, LLNL considers heal th protection (at a 10-6 risk) to be a remedial action
objective. Based on results of the Baseline Public Health Assessment (BPHA), ground
water constitutes the only significant pathway of exposure from vadose zone
contaminants. The BPHA demonstrates that, if ground water concentrations are at MCLs
or below, the health risk is well below l~.
Unsaturated sediment cleanup concentrations will be based on the mobility of. specific
contaminants in the sediment at the LLNL site. We have examined the potential for
hazardous substances in the sediments of the unsaturated zone to migrate to ground water
(Appendix G of the FS). The preliminary results of our investigation indicate that the
potential for affecting the ground water depends on the mass, concentration, and
distribution of contaminants in the vadose zone.
For the areas of greatest potential concern at LLNL, we conclude that the dominant
transpon mechanism for migration to the ground water is vapor diffusion. The model
illustrated in Appendix G of the FS provides a basis for deciding which, if any, areas at
LLNL may warrant vadose zone remediation. .
Based on the findings of the BPHA section of the Remedial Investigation (RI)
(Thorpe et ai., 1990) that no surficial soils at LLNL constitute a potential health threat,
we have no cleanup standards for surficial soils.
Location-specific ARARs are restrictions placed on the concentration of chemicals or
conduct of operations based on the location of a site. Potential location-specific ARARs
include the protection of:
. Wetlands.
. Floodplains.
. Historic landmarks.
. Coastal zones.
. Coastal barriers.
. Rare and endangered species.
. Cultural resources.
The LLNL site contains no floodplains, historic landmarks, coastal zones, or coastal
barriers. As stated in the Livermore Site Environmental Impact Repon (EIR) (DOE and
University of California, 1992), three small wetlands exist at the culvens that channel
runoff into Arroyo Las Positas at the nonhern perimeter of the site. A review of the
LLNL site for rare and endangered species was performed as pan of the site EIR, and
none have been found. No contemplated action will have an impact beyond those
discussed in Section 5 of the FS. LLNL does not believe that significant cultural
resources will be impacted, because (1) there is no source of water on the site to sustain
early cultures, and (2) vinually the entire site has been subject to intense development
over the last 50 years. No excavation is contemplated that would disturb sites to depths
greater than they may have already been disturbed.
California's Alquist-Priolo Special Studies Zones Act of 1972 (California Public
Resource Code, Section 2621, et seq.) provides constraints on the building of residences
B-2
-------
UCRL-AR-109105
Record of Decision
July 15.1992
within 50 feet of an active fault. RCRA 40 CFR Section 264.18(a) prohibits new
treatment, storage, or disposal facilities within 200 feet of a Holocene fault. There are no
active faults within 200 feet of LLNL, and construction of residences is not permitted
onsite; therefore, these two requirements are not ARARs. All treatment facilities will
comply with local construction codes as applied by LLNL's Plant Engineering
Department. .
Action-specific ARARs are usually technology- or activity-based limitations on
actions taken with respect to hazardous wastes. These requirements are triggered by the
panicular remedial activities that are selected to accomplish a.remedy. Since there are
usually several alternative actions for any remedial site, different requirements can be
triggered. Action-specific ARARs may indicate or influence how a selective alternative
is implemented.
The ARARs for the LLNL Livermore site are summarized in Table B-1.
B-3
-------
Table B- I. Federal and State and local ARARs for LLNL (mcldified from Chapter 3 of the LLNL FS).
c:::
Relevant and To be (")
:;.;,
Media to be Applicable. Appropriate considered t"'"
~
Comments remediateda (A) (RAR) (TIIC) :;.;,
o
Federal Chemico/-Speci.fu: .....
a
Requirements \()
.....
C:>
Safe Drinking Water Act This law establi'ihes treatment standards for current potential GW,VZ Xb Xb v,
(SDW A) drinking water sources by setting Maximum Contaminant
142 USCA 3001 Levels (MCLs) and non-zero Maximum Contaminant Level Xb
140 CFR 141.11-141.16; Goals (MCLGs), which are used 3.'i cleanup standards. Those
141.50-141.511 standards for the LLNL site are li'ited in Table 1 of the ROD.
Clean Air Act (CAA) National primary and secondary ambient air quality (;W,VZ XC :;.;,
142 USCA 7401-7642) standards (NAAQS) are defined under Section 109 of the CAA XC n,
<'>
C)
140 CFR S0-(i91 and are listed in 40 CFR 50. ~
Clean Air Act National Emission Standards for Hazardous Air Pollutants GW,VZ XC ~
142 USCA 7412) (NESHAPs) are specific to industrial emissions. 40 C.'R 61.92 XC ~
~
140 CFR 61.921 limits emissions of radionuclides to those amounts that would r:
td cause any member of the public to receive, in anyone year, a t;:,
I C;
.j::- ,maximum errective dose equivalent of 10 millirem per year. ;::,
.
Federal Action-Specific
Requirements
Action: Closure
Resource Conservation Requires that a facility be closed in a manner which minimizes GW,VZ Xb
Recovery Act (RCRA) the need for further maintenance and is protective of human Xb
42 USCA 6901 health and the environment. Applicable to hazardous waste
140 CFR 264.111) management facilities. <..
~
RCRA Requires removal of all hazardous waste and waste residues GW, VZ Xb ,~
140 CFR 264.178) from containment systems. Although the treatment facilities Xb ...
\..
-
and thermal system are not considered containment systems. ~
this closure requirement will be considered RAR. ~
I
-------
Table 11-1. (Continued)
c::
Relevant and 1'0 be Q
Media to be Applicable Appropriate considered r:--
Comments rt'mediateda (A) (RAR) (l'ne) :i..
~
,
Action: Pump and Treat .....
a
'C
RCRA Design and operating standards for tank systems. Tank GW,VZ Xb .....
a
140 CFR 264.19()-192) systems may be used for pump and treat alternatives. Xb VI
RCRA Design, monitoring, and performance standards for GW,VZ Xb
140 C"'R 264.601--(i021 miscellaneous treatment units. Xb
Land Disposal Restrictions Any waste placed in land-disposal units must comply with GW, VZ Xb
(LDRs) RCRA LDRs by either attaining specific pt'rformance or technolo~y. Xb
140 CFR 268) based standards. This is applicable to untreated soil or debris ~
"'
from the CERCLA cleanup. I")
<::>
Action: Thermal Treatment ~
RCRA These regulations apply to owners or operators of facilities VZ Xb ~
I;:)
140 CFR 265.373-3811 that thermally treat ha7..irdous waste in devices other than "'
I")
enclosed devices that use controlled name combustion. C:;:;.
td -.
I <::>
lI. Action: Transportation ;::s
Transportation of lIa7.ardous Transporters must be licensed ha1.ardous waste haulers. In GW,VZ Xb
Waste RCRA the event of a discharge during transportation, the transporter Xb
140 CI<'R 2631 must take immediate action to protect human health and the
environment (263.30) and clean up the discharge such that it
no longer presents a ha1.ard (263.31). Generated waste being
transported to an orrsite disposal facility would be subject to
this requirement. ?
Action: Reinjection 0/ ~
Treated Ground Water .....
V}
Xb .....
Safe Drinking Water Act These regulations consist of inventory and monitorin~ GW,VZ 'C
Underground Injection requirements for reinjection of treated ground water. Xb 'C
N
Control Program
140 CI<'R 144.26-271
140 C"'R 146.51-5211
-------
Table B-1. (Continued)
c-
Relevant and To be \
~
Media to be Applicable Appropriate considered ["-
Comments remediateda (A) (RAR) (TUC) :i
~
Action: Discharge of ..:..
c:
Treatment System Effluent \(
"-
Both onsite and offsite discharges from C..:RClA sites to Xd c:
Clean Water Act (CW A) GW, VZ '....
(33 USCA 1251-1376) surface waters are required to meet the substantive CW A Xd
National Pollutant Discharge limitations, monitoring requirements (40 CFRI22.41(i); 40
Elimination System (NPDES) CFR 136.1; 40 CFR 136.4), and best management practices
140 CFR 122-125) (40 CFR 125.100).
Action: Air Stripping ~
~
OSWER Directive 9355.0.28 Establishes guidance on the control of air emissions from air GW,VZ Xe (')
C)
strippers used at Superfund sites for ground water treatment. Xe ~
This is a nonpromulgated directive and is, therefore, TUC. ~
General Action-Specific ~
~
THCs. (')
t;;
DOE Order 5400.4 Prescribes conduct of operations on DOE facilities for GW,VZ Xd is
~ :::E
I compliance with CERCLA, and provides for the integration of Xd
cr-
NEPA and CERClA documentation for DOE. This is a
nonpromulgated regulation and is, therefore, TUC.
State and I.ocal Chemical-
Specific Requirements
Hazardous Waste Control HCW A controls hazardous wastes from their point of GW,VZ Xb
Act (HCW A) (Health and generation through accumulation, transportation, treatment, Xb "
$.::
Safety Code, Section 25100- storage, and ultimate disposal. All potentially hazardous .:::
25395), CCR, Title 22, ch. 30: materials are handled in accordance with standard chain-of- ......
v,
Minimum Standards for custody pr()(edures. ......
Management of Hazardous \()
and Extremely Hazardous ;S
Wastes
-------
Table 8.1. (Continued)
c:::
Relevant and To be ~
Media to be Applicable Appropriale considered ['"-0
~
Comments remediateda (A) (RAR) (THC) ~
I
Criteria for Identifying Tests for identifying hazardous characteristics are set forth in GW,VZ Xb ....
<:::>
Hazardous Wastes these regulations. If a chemical is either listed or tested and Xb '"
....
ITitle 22, (i(i(i9~(i77(i) found hazardous, then remedial actions must comply with ~
Title 22 requirements.
California Safe Drinking Regulations and standards for public water systems; MCLs GW,VZ Xb
Water Act, Health and Safety and secondary MCLs (SMCLs), which are enforceable in Xb
Code, Section 2549.5 California; requirements for water quality analyses and
laboratories. ~
Persistent and Total Threshold Limit Concentrations (TTLCs) and Soluble GW,VZ Xb (1:)
("')
Hioaccumulative Toxic Threshold Limit Concentrations (STLCs) have been Xb <:)
~
Substances established for selected toxics to be used in eswblishing ~
ITitle 22, 66(99) whether waste i.'i hal.ardous. If a chemical is either listed or tJ
tested and found hazardous, then remedial actions must C'\)
("')
comply with the hazardous waste requirements under Tille -.
....,
22. 5.
b:J ;::s
I Porter-Cologne Water Establishes authority for State and Regional Water Boards 10 GW,VZ xb
......
Quality Control Act determine site-specific discharge requirements and to regulate Xb
IWCJ3000-13806J, as di.'iposal of waste to land.
administered by the Swte
Water Resources Control
Board (SWRC8) and the
Regional Water Quality
Control Board (RWQCB) ~
under CCR Title 23, subch. Y.""
IS, 1050-2836. ......
Vi
State Water Resources The State 8oard's policy on maintaining the high quality of GW,VZ Xb ......
Control Board's Resolution California's waters implies that ground water cleanup should Xb '"
~
68-16 continue below MCLs if it can be shown that it is technically
feasible and cost effeclive to do so.
-------
Table II-I. (Continued)
c:::
Relevant and To be Q
Media to be Applicable. Appropriate considered ~
remediateda (A) (RAR) (TIIC) :i.
~
Xb '
GW,VZ ......
a
Xb \()
......
a
v,
GW,VZ xb
Xb
~
~
C")
()
...,
~
~
t1
~
C)
GW,VZ Xb t;j"
-.
()
Xb ;:,
Comments
29 USC 651 et seq.
Occupational Safety and
lIealth Act (OSHA)
OJ
I
00
29 CFR 1910 et seq.
Noise Control Act of 1972,
as amended by the Quiet
Communities Act of 1978
140 CI<'R 204, 205, 2111
Stat~and I.ocal Action-
Specific Requirements
Action: General Treatment of
Ha'lArdous Waste
lIa1.ardous Waste Control
Act, Health and Safety Code
(IICW A), Sections 25100-
25395
122 CCR 6710~71951
lIazardous Waste Control
Act Land-Disposal
Restrictions
122 CCR 669001
Hazardous Materials Release
Response Plans and
Inventory
III&SC, Div. 20, ch. 6.951
119 CCR, ch. 3, subch. 31
OSHA requirements under 29 CFR 1910.120 are applicable to
worker exposures during response actions at CERCLA sites;
. 29 CFR 1926 construction standards apply during
construction pha.'ie of treatment facilities.
Construction and transportation equipment noise levels (e.g.,
portable air compressors, and medium and heavy trucks),
process equipment noise levels, and noise levels at the
property boundaries of the project are regulated under this
Act. State or local agencies typically enforce these leveL 'i.
Requirements for general operations of interim status and
permitted facilities 167 100...{)7 108 I, including preparedness
and prevention 167 I 20...{)7126 I, contingency.plans and
emergency procedures 167140"'{)71451, and manifesting and
monitoring requirements 167180"'{)71951.
This law requires that certain hal.ardous wastes meet
minimum treatment standards prior to disposal at a landfill.
This law requires businesses handling hazardous materials to
plan for emergency response actions.
GW,VZ
Xb
Xb
......
Xb $::
~
Xb ......
Vt
......
\()
\()
N
GW,VZ
-------
Table 8-1. (Continued)
Comments
Media to be
remediateda
Applicable
(A)
Relevant and
Appropriate
(RAR)
To be
considered
(TnC)
Action: Closure
Hazardous Waste Control
Act Closure Requiremenl'i,
Sections 25100-25395
(22 CCR 67210-672201
Action: Tmnsportation
Hazardous Waste Control
Act Hauler Registration
Requirements (22 CCR
6642~6465Iand
Requirements for
Transporters of Hazardous
Waste (22 CCR 66530-665641
td
I
\0
Requirements for Generators
of Hazardous Waste
ITitie 22 66470-665151
Action: Discharge of
Treatment System Effluent
A facility shall be closed in a manner that minimizes the need
for future maintenance. 'If hazardous wastes are len in place,
postclosure care must continue for 30 years.
lIa7.ardous W3.'ites must be iransported by a hauler registered
with the State of California.
Owners or operators who ship hazardous waste from a
Transport, Storage, or Disposal (TSD) facility shall comply
with the generator standards in these regulations. These
standards include keeping of manifests (66481 I, submission of
. manifest to CDIIS within 30 days of shipment (66484(01,
preparation ora biennial report (66493(a)l, and a maximum
90-day accumulation time 166508(a)l. These regulations are
applicable to transportation and off.o;ite disposal of ha7.ardous
waste.
(iW, VZ
GW,VZ
GW,VZ
Xb
Xb
Xb
Xb
Xb
Xb
<:::
<:
~
r--
~
~
,
......
c:
\C
......
c:
'J,
~
n:.
r,
C)
..,
~
.Q.
t::;
n:.
r,
~.
~.
~
'-
$;::
-::
......
v,
......
\C
\C
tv
r
-------
Table B-1. (Continued)
Applicable.
(A)
Xb
xb
Relevant and
Appropriate
(RAR)
c:
(j
:::tJ
t--
~
~
I
.....
c:::.
\Q
.....
c:::.
v,
Action: Air Stripping
Air Resources Act
(liealih and Safety Code,
section 3900 et. seq.)
Bay Area Air Quality
Management District
I Regulation 8, Rule 47)
l-ocation-Specific There are no Federal or State location-specific requirements
Requirements for the LLNL site.
a GW -Pump and treat; complete hydraulic capture with source remediation.
VZ -Vacuum-induced venting with catalytic oxidations.
b All RARs are the same for all treatment options contemplated under this treatment alternative.
c CAA requirements only apply to treatment options with atmospheric discharges.
d Only orrsite CERCLA discharges to surface waters must be NPDES-permitted.
e Factors TBC are the same for all treatment options contemplated under this treatment alternative.
f Applies only to treatment options with surface discharges.
Porter-Cologne Water
Quality Control Act (WC
13000-13806), as
administered by the State
Water Resources Control
Board (SWRCB) and the
Regional Water Quality
Control Board (RWQCB)
under CCR Title 23, subch.
IS, 1050-2836
Fish and Game Regulations
on Pollution
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Comments
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GW,VZ
F..stablishes authority for State and Regional Water Boards to
determine site-specific discharge requirements and to regulate
disposal of waste to land.
Prohibits water pollution with any substance or material
deleterious to fish, plant, or bird life.
GW. VZ
Establishes allowable discharge standards for point sources
.within each I\ir pollution control district, and establishes
ambient air quality standards.
Requires permitting of VOC air discharges (e.g., from an air-
stripping unit).
(~W, VZ
(;W,VZ
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