Lawrence Livermore National Laboratory Hazardous Pollution at Site 300
Key issues in the ongoing cleanup of leaking radioactive and toxic materials from nuclear weapons activities near Tracy, California
Overview
The Lawrence Livermore National Laboratory was founded in 1952 expressly to speed the development of new types of nuclear weapons. Livermore Lab is a National Nuclear Security Administration facility. NNSA is the semi-autonomous agency within the Department of Energy that is in charge of U.S. nuclear weapons development, testing and production.
The Livermore Lab has two physical locations, a Main Site in Livermore, California (in the San Francisco Bay Area) and the Site 300 high explosives testing range near Tracy, California (on the cusp of the Central Valley).
Site 300 was founded in 1955 to serve the Main Site’s nuclear weapons development activities. It encompasses 11 square miles along Corral Hollow Road. The Carnegie Recreational Vehicle State Park and Campground is across the Road from Site 300. Site 300’s eastern boundary is directly next to the new Tracy Hills housing development.
Site 300 has soil, groundwater and some surface waters that have been contaminated with toxic and radioactive materials. Releases to the environment have occurred from Site 300’s open-air detonations with high explosives and radioactive materials used in nuclear weapons, a variety of spills, leaking pipes, leaching from unlined landfills (dumpsites), disposal of waste fluids in lagoons and dry wells (sumps), and a recent overpressure accident that vented to the outside, among other hazardous activities.
Current operations at Site 300 include contained detonations with radioactive materials, open-air blasts with toxic substances, explosive and hazardous waste burning, and radioactive and hazardous waste storage. Prevailing winds blow contamination into the Central Valley, and, particularly, toward Tracy and surrounding communities.
In 1990, because of the magnitude of this contamination, Site 300 was added to the federal EPA’s Superfund list of most contaminated sites in the nation.
The Superfund law was passed in 1980 to address the nation’s most contaminated sites. An important aspect of the Superfund law is its public participation requirements.
Tri-Valley CAREs has utilized the law’s participation requirements since Site 300 was listed. Through regular community meetings and other public involvement activities – and including bilingual fact sheets, reports, and formal comment letters to the government – Tri-Valley CAREs has had a major impact on the Superfund cleanup of Site 300, both in stopping bad plans and in promoting better technologies that have then been adopted.
Major pollutants at Site 300
Site 300’s weapons activities have polluted soil, surface water, springs and regional groundwater aquifers with chemical and radioactive wastes including solvents, dioxins, furans, PCBs, perchlorate, high explosive compounds, toxic metals, and radionuclides (tritium, which is the radioactive hydrogen, and uranium-238 a heavy, radioactive metal). An off-site groundwater plume contaminated with solvents has migrated off-site from Site 300 and traveled under Corral Hollow Road and under the nearby Corral Hollow Creek.
At one time, the Superfund cleanup at Site 300 was projected to last 80 years, until the end of the 21st century, or more. At Tri-Valley CAREs most recent day-long meeting with Lab officials and the regulatory agencies, Lab technical staff told us that they do not have a firm estimated completion date – because there are too many unknowns.
Tri-Valley CAREs’ analysis of the Site 300 Superfund cleanup over many decades leads us to conclude that the severity and complexity of these contaminants, many commingled, requires research to develop more effective cleanup technologies. Further, we have concluded that there are areas at Site 300 that have yet to be fully characterized and therefore require ongoing investigation to ensure that the cleanup methods ultimately chosen will be effective and address the full range of contaminants present in the environment. These actions are necessary to address the “unknowns.”
Working hand-in-hand with our Tracy-area membership and with other community members, we are making progress. Below, you will read about several key issues that our technical staff and community outreach have identified as priorities for the coming year.
Superfund Cleanup: The Pit 7 Complex (Dumpsites)
The Pit 7 Complex is a series of large unlined dumpsites that were bulldozed into the ground and then filled with debris from the bomb blast firing tables as well as other radioactive and toxic wastes from other Livermore Lab activities.
After these unlined pits were completely filled, they were capped. During some heavy storm events, groundwater levels rose as much as 10 feet, inundating the pits and washing contaminants out. The pits have leaked uranium, tritium, perchlorate and other contaminants into the groundwater aquifer at high concentrations. The contamination in the groundwater then migrated outside the pits and it now forms a long plume.
In 2005, Livermore Lab constructed a series of drains upstream from the pits in order to divert rainwater runoff away from the pits – aka the Drainage Diversion System, or DDS. However, during years with heavier rainfall, the DDS did not keep all water out of the pits. In other words, their chosen remedy has failed.
In 2019, Livermore Lab outlined a workplan, in part to evaluate the performance of the DDS and the mechanisms for its failure as part of an engineering evaluation. Tri-Valley CAREs commented at the time that while this was a necessary start, the evaluation was insufficient under the Superfund law to address a remedy failure.
This summer, we analyzed the Lab’s Draft 2nd 5-Year Review, and we are encouraged that a full, more detailed, Focused Feasibility Study will now be undertaken to evaluate additional remedies to prevent groundwater from rising into the waste pits. The public comment letter on the Lab’s Review is available on our website.
Our letter’s first recommendation is for Livermore Lab to expand its public outreach and, at least, hold a public meeting in Tracy in 2026 when it completes the Focused Feasibility Study. We believe that public scrutiny is necessary to ensure that the additional cleanup methods that will be chosen meet your approval – early in the process before the Lab decides on its own to abandon some options that it may not favor, but that the community might want.
Our second recommendation involves the type of cleanup technologies that should be included in the Focused Feasibility Study. In our comment letter, we make note of the fact that the City of Tracy commented on the original cleanup plan and asked for excavation of the unlined pits and removal of the wastes.
Tri-Valley CAREs concurred with the City, and when the Lab said it couldn’t do that, we advocated that, at a bare minimum, the Lab could and should do “hot spot removal” of wastes from the pits so that there would be less contamination left in place. The Lab did neither and stated that its Drainage Diversion System would take care of it – which it did not.
Our third recommendation is to ensure that the additional cleanup technologies that you want (and that are chosen) become part of the legally-binding Superfund document call the Record of Decision. And, fourth, we lifted up some of the excellent state and federal regulatory agency comments that tell the Lab it must do more.
Superfund Cleanup: Outdoor Firing Tables
Open-air firing tables, where bomb blasts are detonated, cover a physically large space. For identification, you will see on the Site 300 contaminant map, included at the end of this report, that the Lab uses the building number for the nearby structure that houses the test’s diagnostic equipment to designate the firing table.
The Building 812 firing table: B-812 was one of the last open-air firing tables used to detonate nuclear weapons experiments outdoors with Uranium-238. The area of the firing table and associated buildings encompasses about 200 acres.
Four layers of groundwater exist in this area and three had detections of uranium isotopes exceeding the regulatory Maximum Contaminant Level, or MCL.
The hillsides, canyons and groundwater in this area are contaminated, as is a nearby surface spring. In addition to uranium-238 contamination, there are multiple chemical contaminants spread through this area.
The initial Superfund cleanup plan in this location proposed a technology that would have left high levels of radiation in place after so-called cleanup. Tri-Valley CAREs’ comments helped ensure that this was not allowed.
Therefore, at this contaminated area, the Lab has had to undertake a fresh Feasibility Study, this time because the first one was simply not acceptable to Tri-Valley CAREs, the community, or the regulatory agencies.
A new analysis and cleanup plan was supposed to be completed soon – but at our summer 2024 meeting with the Lab, we learned it is once again behind schedule. One of the main issues that the new feasibility must address is “How clean is clean,” meaning to what level must the uranium-238, in particular, be cleaned up.
In preparation, the Lab engaged in a lengthy analysis of Uranium-238 at various locations around Site 300 and then took samples from Mt. Diablo State Park, which has similar geology to Site 300.
To cut to the bottom line, there are higher concentrations at Site 300. Thus, when it comes time to determine “how clean is clean” we believe that Livermore Lab will be less able to argue for a more lenient cleanup standard.
Further, the cleanup of this firing table is one of the key elements in ensuring that the community gets a good cleanup that will be protective into the future. Public comment is likely to make a huge difference in what actually happens here.
Tri-Valley CAREs has already obtained an informal commitment from Livermore Lab to hold an early public meeting in Tracy when the feasibility study is done. The idea we had here, just like at the Pit 7 Complex, is to make sure the public can weigh in early – when all options are still on the table.
The Bldg. 851 firing table: This is the firing table for which new, bigger bomb blasts had been proposed. At least for the present, community opposition has caused Site 300 to shelve this plan.
In 2016, Tri-Valley CAREs obtained documents revealing that hunks of uranium-238 were unexpectedly found strewn around the ground at the Building 851 Firing Table. These are from old bomb blasts done there. The Lab found 27 separate chunks of uranium-238 measuring 3-inches in diameter or greater and weighing 80 pounds. There are also a lot of tiny, finely divided particles of uranium loose in the soils around that firing table.
The tiny particles that are part of the fallout from prior detonations pose the greatest risk of resuspension into the air due to the force of new bomb blasts or the heat of fires that periodically burn through the site.
Following the discovery of uranium splattered about, Livermore Lab undertook a gamma radiation survey of uranium- 238 in surface soils there. The survey disclosed highly elevated gamma radiation levels radiating outward from the table, like spokes on a wheel.
Additionally, the Superfund documents say that Site 300 personnel would not conduct active cleanup at this firing table as long as it is in use. Therefore, our advocacy regarding this firing table is to try to get it closed so that the Superfund cleanup process can go forward – and public health and the environment can be protected.
Conclusion:
Tri-Valley CAREs believes that we all have the right to clean air, land and water. We remain committed to ensuring that all of the hazardous and radioactive contaminants at Site 300 are cleaned up. Community participation in environmental decision-making at Site 300 is a human right – and a legal right under the Superfund law.
Further, it is pressure from the community that has – and will continue to have – a central role in determining “how clean is clean” as well as which cleanup methods should be employed at Site 300 and which ones pose an unacceptable risk of failure, insufficiency or further pollution.
You are invited to join our mailing list to receive monthly issue updates, including those pertaining to the Superfund cleanup activities at the Lawrence Livermore National Laboratory Main Site and its Site 300. You can sign up online at www.trivalleycares.org.
Or, for more information, you can contact our executive director at [email protected] or our senior advisor at [email protected]
On the front page at www.trivalleycares.org, you will also find the tab into our Spanish language website. Tri-Valley CAREs also circulates monthly issue updates in Spanish.
To receive our materials in Spanish, contact our bilingual community organizer at [email protected]g
Our website also features a “What’s new” section, an events calendar, a press room, a public reading room, and more in Spanish and English.
Tri-Valley CAREs has monthly virtual meetings and hosts virtual and in-person events, such as community meetings in Livermore and Tracy, where topics of greatest interest to the public are explored in detail. Join us!
The Superfund cleanup areas at Site 300 are called Operable Units. The Site 300 contaminant map follows with the Operable Units and the major associated hazardous pollutants listed.
Site 300 Contaminant Map
Photo credit: Lawrence Livermore National Laboratory. Pictured is the old Site 300 main entrance sign, located on Corral Hollow Road. Livermore Lab is a government-owned-contractor operated nuclear weapons site. The owner is the U.S. Department of Energy National Nuclear Security Administration. Since 2007, the contractor has been an LLC consisting of Bechtel National, University of California, BWX Technologies and Amentum. Prior to 2007, UC operated Livermore Lab.