Tri-Valley CAREs

Lawrence Livermore National Laboratory's Site 300

May 4, 2000 Public Hearing on Cleanup of Toxic and Radioactive Contamination

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A public hearing on the Proposed Plan for cleaning up Lawrence Livermore National Lab's (LLNL) site 300 will be held at 6:00 p.m. on May 4, 2000, at the Tracy Community Center, 300 E. 10th St., Tracy, CA. This will give the public the opportunity to directly comment on the proposed plan for the cleanup of major portions of site 300. Because the plan contains some controversial elements, we urge you to come to this hearing and tell the Department of Energy (DOE), Lab officials and the environmental regulators how you feel about this plan.

The Proposed Plan is a critical step in the cleanup process under the Superfund law, formally known as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). It is the document that selects the cleanup options.

This document, together with public and regulatory comments, serves as a basis for the legally-binding Record of Decision (ROD). The ROD presents the selected remedial action and responses to public comments. It specifies cleanup requirements, dates for complying with certain additional actions, and any special conditions that may be imposed on the cleanup. The U.S. Environmental Protection Agency (EPA) and other regulatory agencies with jurisdiction must approve the ROD.

Prior to the signing of the ROD, the Proposed Plan is evaluated by EPA according to nine criteria that are specified in the National Contingency Plan. These criteria include such things as "protection of public health" and "community acceptance." Therefore, the community's voice, advocating for adequate cleanup remedies, is particularly important at this time.

After the ROD is signed, no further public hearings or public comment are required under Superfund, unless there are substantial changes made to the cleanup plan. It is important to note that the ROD serves as the legal basis for cleanup actions and is crucial for the community and regulators to hold the Lab to its cleanup plan.

Site 300 was named in 1990 as a Superfund site, meaning it is listed by EPA as among the nation's most contaminated areas. Site 300 encompasses 11 square miles in the Altamont Hills between Livermore and Tracy. The site is surrounded by open space used primarily for ranching and recreation. With the rapid growth that is taking place all over the Bay Area, residential development is proposed for some property adjacent to site 300.

Since 1955, site 300 has been used by Livermore Lab to process and test high explosives materials, mainly used in nuclear weapons, and surrogate nuclear detonations. These activities have polluted the soil and groundwater at site 300 with a dangerous mixture of chemical and radioactive wastes including solvents, radioactive tritium, Uranium 238, explosives, and heavy metals.

Investigations and cleanup have taken place within the framework of the Superfund law, or CERCLA. In the early 1990's, to simplify the cleanup process, the Lab divided site 300 into eight operable units (OUs). Each OU was to undergo the comprehensive investigation and cleanup requirements set forth in the Superfund law and regulations. The investigation and study process is known as the Remedial Investigation/Feasibility Study process. Some OUs have already gone through the entire process (e.g., site 300's General Services Area).

Livermore Lab has designated the final OU as a "Site-Wide OU", which is supposed to wrap together all the other OUs, further investigations and potential emergency removal actions. It thus presents the best look at the overall cleanup plan for site 300. The ROD for the Site-Wide OU will be "interim"; and a final ROD is scheduled for 2007. The geology of site 300 is extremely complex. There are "synclines" and "anticlines", a number of faults, and many strata of different formations. This makes characterization of the contamination difficult, and modeling the movement of contaminants through these formations even more difficult.

Below, please find a brief description of the issues in the Proposed Plan about which Tri-Valley CAREs has major concerns.

1. The Proposed Plan and the interim ROD will not contain cleanup standards. Since the final ROD is not scheduled until 2007, we are concerned about ineffective performance during the interval between now and then. We recommend that interim cleanup goals be set at the most stringent levels. DOE will have an opportunity in 2007 to amend them, so long as it can prove why the more stringent goals cannot be met.
   
   
2. One of the major points that Tri-Valley CAREs is recommending is that a possible mission change or change in ownership of the site should be considered in remedy selection. If in the future DOE wants to dispose of the property, the remedy that is chosen today should not limit tomorrow's land-use decisions. DOE maintains that it will control the site indefinitely. Cleanup, however, should support multiple uses for the property.
   
   
3. Industrial standards are used for site 300 to set interim risk levels. Industrial standards allow more pollution than residential ones. While we recognize that residential standards may not be feasible in a few small places, on the whole, residential standards should be used. In the future, this would allow DOE to more easily dispose of the property and limit its liability. Also, as noted above, because the Bay Area is growing so rapidly, and residential growth is beginning to occur in Tracy and near site 300, it would be unfortunate if the cleanup levels decided in 1999 were to dictate how this 11 square mile site will be used in the future.
   
   
4. A Contingency Plan that addresses how cleanup will be modified in "the event of future changes in land use at site 300, or if a transfer of site ownership is anticipated" should be done in conjunction with this document, not in 2002 as is currently proposed.
   
   
5. At the site's High Explosives Process Area, much more detail needs to be provided about the cleanup remedies and contingency actions.
   
   
6. It is important to designate where excavated material from the site's Building 850 "sand pile" be deposited. This pile contains radioactive tritium, chemical explosives, Uranium 238, PCBs and dioxins.
   
   
7. In the Building 850 area, we would like more hydraulic control of the source areas so the groundwater plumes do not continue to migrate, thereby contaminating additional water resources.
   
   
8. All Uranium 238 contamination should be addressed in the contingency plan, particularly concerning changes in land use. There should be no action taken that would be irreversible, if the uranium needs to be removed at a later time.
   
   
9. At numerous meetings over the last several years with DOE, LLNL staff and regulators, Tri-Valley CAREs has strongly recommended that something be done to prevent the continuing release of radioactive tritium from the dump area "Pits 3 and 5" to the groundwater. With the rainy season just ending, no action was taken to mitigate this problem. While these particular dump sites have been separated from the Proposed Plan in order for LLNL to conduct further studies, we none-the-less must insist that an interim action be done now to protect the groundwater and soil near these pits.
   
   
10. The plan should contain milestones by which the success of the subsequent cleanup can be evaluated. The remedy and the accompanying plan should contain firm commitments. It is important that the plan contain a measurable schedule and performance standards which can be verified.
    
    
11. Risk assessment and modeling are imperfect sciences. We advocate using the Precautionary Principle (which states in part, that when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically).
    
    
12. We prefer cleanup remedies that actively destroy contaminants to ones that merely capture the pollutants by transferring them to another medium, e.g., from water to granular activated carbon.
    
    
13. Cleanup should be given priority over further weapons development. The budget for remediation of pollution at site 300 should be adequate, stable and assured over the many decades it will take to actually complete this momentous task. The DOE must not renege on its obligation to the community to clean up its mess. Currently, the money for cleanup of site 300 hovers at 1% of Livermore Lab's annual budget.

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