2.2.1. Site History

2.2.2. Summary of Enforcement Activities

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 Discharge Requirements to define the vertical 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 Feasibility 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 al., 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.