Lawrence Livermore National Laboratory’s (LLNL) Site 300, the high-explosives testing range in the hills near Tracy, is once again at a crossroads, and your participation is needed!
California’s Department of Toxic Substances Control (DTSC) is proposing to renew two key hazardous waste permits for Site 300 in 2025: the Operating Hazardous Waste Facility Permit and the Post-Closure Permit. These dry bureaucratic terms hide very real stakes for our community’s health and environment. For nearly three decades, Tri-Valley CAREs (TVC) has served as a community watchdog over Site 300, and we’ve activated local residents at every permit milestone since the first was issued in 1996.
Now, DTSC is asking members of the public to chime in on how it should proceed with the public process on these permits. You can give your input on their website until November 19, 2025.
A Legacy of Watchdogging Site 300’s Hazardous Waste
TVC’s involvement with Site 300 goes back to the 1980s when the DTSC issued the first Hazardous Waste permit under the The Resource Conservation and Recovery Act (RCRA) Law. Then in 1996, when DTSC renewed Site 300’s hazardous waste permit, Tri-Valley CAREs further ensure the community’s voice was heard. That permit covered the Building 883 Container Storage Area (for routine lab hazardous wastes) and authorized a new Explosives Waste Storage Facility (EWSF) to hold bomb debris and other explosive wastes.
The very next year, in 1997, DTSC issued a permit for a new Explosives Waste Treatment Facility (EWTF). The EWTF was touted as a modern replacement for an old open burn pit (Building 829) where LLNL had openly burned high-explosive waste for decades. As that 1997 permit was finalized, the open burn facility was ordered to close, a victory attributable in part to public pressure.
TVC was there rallying residents, submitting comments, and even filing legal appeals when necessary to challenge weak permits. For example, when DTSC attempted a cursory permit renewal in 2016, Tri-Valley CAREs appealed it on numerous grounds as inadequate. Our consistent message: hazardous waste operations at Site 300 must not be rubber-stamped. They demand rigorous review and community oversight.
Why such persistence? Because hazardous waste permit decisions can literally shape the safety of our air, water, and soil for years to come. These permits govern how LLNL Site 300 stores, treats, and disposes of dangerous materials, including high-explosive residues and even “mixed” wastes that contain both hazardous chemicals and radioactive elements. Once granted, a DTSC hazardous waste permit remains in effect for up to ten years. That means the terms set now will control operations (and risks) until 2035.
Each renewal is a rare chance to scrutinize the Lab’s activities and demand improvements. As DTSC itself notes, permits are intended to ensure a facility operates in a manner that protects human health and the environment. In practice, a permit review allows the public to ask tough questions: Are open burn operations releasing toxic smoke unnecessarily? Could safer technologies or limits reduce pollution? Is groundwater monitoring sufficient around closed waste sites?
These are not abstract concerns. Site 300 is already a federal Superfund site due to extensive toxic and radioactive contamination in its soil and groundwater. Strong permits are one of the tools we have to prevent adding to that “poisonous legacy”.
Why These Permits Matter More Than Ever
The two permits up for renewal cover both active operations and a closed hazardous waste unit at Site 300. The Operating Hazardous Waste Facility Permit governs three active units:
- Building 883 Container Storage Area – where everyday lab hazardous wastes (solvents, acids, etc.) are stored.
- Explosives Waste Storage Facility (EWSF) – where high-explosive waste materials are safely stored prior to treatment.
- Explosives Waste Treatment Facility (EWTF) – where LLNL treats explosive wastes by open burning or detonation, since many explosives cannot be disposed of by other means
The Post-Closure Permit, on the other hand, covers the long-term care of the old Building 829 Open Burn Pit that operated from 1955 to 1996. That pit was closed and capped in 1997, but it left behind contamination. Hence, a post-closure permit is required to monitor groundwater and maintain the closed site.
Together, these permits encapsulate the past, present, and future environmental challenges at Site 300. They dictate everything from how much explosive material can be burned per day, to how leachate from the closed burn pit is managed. Importantly, renewal time lets us reassess risk. Are the current limits on open burning truly protective? (For instance, a 2008 draft permit reduced the allowable burn from 150 lbs to 100 lbs per day.) Are there cleaner alternatives to open-air burning that LLNL should adopt? These are the kinds of improvements a community can fight for when permits come due.
Flawed Public Outreach
You would expect that a permit renewal of this magnitude would come with robust public outreach, including clear information, easy access to documents, and genuine avenues for input. Unfortunately, DTSC’s recent actions have fallen short, and it’s frustrating community members across Tracy, Mountain House, Lathrop and beyond.
DTSC issued a public notice and “Community Survey” about the Site 300 permits, but it’s been riddled with issues. To start, the information that was mailed to residents wasn’t posted online. The official project documents are buried on DTSC’s “EnviroStor” database, where an interested resident has to search for the obscure EPA ID CA2890090002 to find anything. Even once found, the website and documents can be daunting to navigate. This is a far cry from the “easy to access” info that an average community member needs.
Worse, DTSC’s chosen method for gathering input – a SurveyMonkey online questionnaire – is a flawed tool for meaningful engagement. The survey (available at https://www.surveymonkey.com/r/B3LD7KC) is poorly designed. For example, several questions force you to pick just one option when you might reasonably want to select several concerns. By disallowing multiple selections, the survey all but guarantees a superficial “checkbox” result. It seems more intended to tick the box saying “we consulted the community” than to truly listen. Community members who attempted the survey have reported frustration that it doesn’t allow nuanced feedback, there’s no room to propose alternatives, only to choose pre-set options. This approach can actually misrepresent public sentiment, reducing our real concerns to a simplistic data point.
Tri-Valley CAREs is calling this out, loudly. We believe both LLNL and DTSC share responsibility for this deficient public engagement. The Lab, as the permit holder, should want an informed and involved public. Yet, they have been all too content to let this outreach fly under the radar. DTSC, as the regulator, has a duty under state law to facilitate meaningful public participation, especially for a project with Site 300’s history. On both counts, they’re falling short. This isn’t the first time, either.
Back in 2007, DTSC actually abandoned a draft Site 300 permit process after taking public comments it never responded to. And in a 2016 hearing in Tracy, community members’ pointed questions went largely unanswered by DTSC officials. These past missteps, combined with the current survey fiasco, paint a troubling picture: agencies appear more focused on the appearance of outreach than on the substance of community input. Tri-Valley CAREs refuses to let them get away with it. We will be preparing detailed comments of our own once the public comment period begins and will assist residents in navigating the system, with hybrid-community meetings in Tracy. The community’s health is too important to be sidelined by red tape or poor web design.
DTSC’s “Community Survey” flyer for Site 300 – a three-page public notice and questionnaire (November 2025). While it asks for community input on the hazardous waste permit renewals, the survey format and outreach have serious flaws that may limit meaningful participation.
The Power of Organized Community Action
If this all sounds a bit dispiriting, take heart: we have stopped dangerous proposals before, and we can do it again. Livermore Lab once planned to build a massive toxic and radioactive waste incinerator at Site 300. Tri-Valley CAREs and local allies launched a campaign that forced the Lab to cancel those plans. Not only that – we also won the shutdown of Site 300’s existing smaller incinerator, ending the routine burning of mixed radioactive wastes on-site. This victory didn’t happen overnight; it took years of community meetings, petition drives, technical reports, and yes, permit comment letters. But it shows that public pressure works. When agencies and labs are faced with organized opposition and well-founded arguments, they can and do change course.
We cite this example because the current permit renewal fight at Site 300 carries echoes of those past battles. The open burn/open detonation operations at the EWTF are essentially a form of incineration – detonating hazardous waste explosives in the open air, releasing contaminants into our environment. Safer alternatives do exist (for example, contained burn chambers or chemical neutralization methods), but the Lab won’t adopt them unless forced.
A strong outcry during the permit renewal, can push DTSC to require LLNL to study and implement safer technologies instead of rubber-stamping another decade of open burning. Likewise, community pressure can ensure the post-closure permit truly holds LLNL accountable for cleaning up the toxic residues of the past, rather than just monitoring them indefinitely.
Your Voice, Your Health: Take Action by Nov 19, 2025
Time is short, but we have an opportunity right now to demand better. Here’s how you can help protect yourself, your family, and your community from Site 300’s hazards:
- Submit your input to DTSC before November 19, 2025. We encourage you to use the DTSC survey – flawed as they are – so that your voice is on the record. You can fill out DTSC’s community survey (online at https://www.surveymonkey.com/r/B3LD7KC) or send your input directly via email or mail to DTSC’s Public Participation Specialist, Tammy Pickens ([email protected]). Make sure to state that you are providing input on the initial LLNL Site 300 Hazardous Waste Permit Renewal (Operating and Post-Closure) process. Tell them your concerns, be it the open burning or the lack of easy access to information..
- In your survey response, insist that DTSC hold a public meeting or hearing in the Tracy area with translation and evening hours so working families can actually participate. If enough of us request it, DTSC can be compelled to do more than just an online survey. Remember, they initially weren’t going to hold a hearing in 1996 and 1997 either, until public pressure forced the issue. We’ve done it before.
- Many neighbors don’t yet know about this permit process. Talk to your friends and family in Tracy, Mountain House, Lathrop, and other nearby communities. Share this information on social media or community groups. Tri-Valley CAREs has flyers and resources (in English and Spanish); reach out to us if you need materials to distribute. The more people know, the harder it is for DTSC and the Lab to ignore community voices.
- This isn’t just a one-time action. After this initial survey period, Tri-Valley CAREs will keep you updated once the full permit is released and the public comment period begins. We will be reviewing DTSC’s draft permit and decisions and releasing both detailed and suggested points of concern for others to comment on. If necessary, we will reserve the right to appeal any final permit that fails to protect our community as we have done in the past. Consider attending our monthly meetings to stay informed. We will also be working with regional and statewide partners to apply pressure on decision-makers.
Call to Action!
Site 300’s hazardous legacy will not fix itself. It will take engaged citizens to ensure that past contamination is cleaned up and new pollution is prevented. The current permit renewal is a critical juncture. It’s a chance to push LLNL toward safer practices. If we stay silent, we allow continued toxic status quo. Tri-Valley CAREs knows firsthand the power of community action. From stopping incinerators to reducing the size of bomb blasts, we have seen that determined people can make a difference, even against mighty institutions. Let’s do it again. Submit your survey input by November 19th. Urge your neighbors to do the same. Together, we can hold the Lab and DTSC accountable and move toward a healthier, safer environment for Tracy, Mountain House, Lathrop and all our communities.
Public Notice & Survey Links: For more information, read the DTSC public notice (English/Spanish) for the LLNL Site 300 permit renewal and complete the online community survey here: https://www.surveymonkey.com/r/B3LD7KC (submit responses by 11/19/2025). Your participation can influence the process. Let’s make our community’s demands impossible to ignore.
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