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Tri-Valley CAREs
Communities Against a Radioactive Environment

Livermore Lab's Site 300 Cleanup: Community Acceptance Criteria

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Dear environmental advocate:

Livermore Lab's site 300 is a high explosives testing range located between Livermore and Tracy. Site 300 is heavily polluted with toxic and radioactive waste, including chemical solvents, high explosive compounds, radioactive tritium and uranium. In 1990, the U.S. Environmental Protection Agency (EPA) put site 300 on its "Superfund" list of worst contaminated places in the country.

The cleanup of site 300 is at a crucial phase, one where the public can make a difference in determining whether the Lab chooses an appropriate set of remedies to clean up soil and groundwater at the site, and also whether it commits sufficient budget resources to do the job right.

The Lab has recently produced a draft "Site Wide Feasibility Study" (SWFS) to explain some of the options that could be used to clean up site 300. Following completion of a final SWFS, the Lab will then prepare a proposed Remedial Action Plan, which will form the legal basis for cleanup of the site, including such things as cleanup levels, how radioactive wastes should be controlled and the timing of cleanup activities. In order to be accepted by the EPA and other regulatory agencies, the final plan will be evaluated by nine criteria.

One of EPA's criteria for "signing off" on a cleanup plan is community acceptance. In the interest of achieving a real and lasting cleanup, Tri-Valley CAREs is proposing 12 Community Acceptance Criteria. We welcome your support. Please sign this form and return it to us. Also, we welcome any suggestions for additional criteria or other comments you may have.

Community Acceptance Criteria

#1. Complete the cleanup project in a timely manner. Set a schedule for cleanup activities and adhere to it. The goal should be to complete cleanup ten years after the DOE's last scheduled Record Of Decision, with up to 30 years thereafter for continued monitoring of residual contamination. As part of the plan, schedule milestones addressing total contaminant mass removal and trends toward achievement of cleanup goals should be established and committed to by the Dept. of Energy, which is the Lab's parent agency. Any areas at site 300 that will still be contaminated after ten years should be identified up front and the reasons stated.

#2. Cleanup levels should support multiple uses for the property. Those uses should be unrestricted by environmental contamination. The Lab's current assumptions about land-use need to be altered. As we can see, residential development is beginning to take place up to the site boundary. Therefore, assumptions should include the possibility of large residential communities relying on the regional aquifer for drinking water, thus speeding up groundwater movement. Second, we do not believe that site 300 will necessarily always remain in DOE's custody. The "need" for testing nuclear weapons and components (particularly of new and modified designs) is a political decision, not a technically necessary mandate, and, in our opinion this testing should cease. We recommend that site 300 future land use assumptions include mixed residential, recreational, ecological preserve and industrial activities. Without full cleanup to standards appropriate for all of the above-listed uses, substantial residual contamination may remain in soil and groundwater and restrict any non-military use of the property.

#3. Cleanup levels should be set to the strictest state and federal government levels. We believe that the strictest cleanup levels should be met in cleaning up the site. Federal and state Maximum Contaminant Levels (MCLs) for all groundwater (on-site and off-site) should be the "bottom line below which the cleanup will not fall." In many cases the technology exists (and/or can be developed) that will clean up contamination to "background" levels - that is to the level that existed in nature at the site before Livermore Lab took over in 1955 and began polluting it. In all cases where this can be achieved, it should be. In this regard, Tri-Valley CAREs concurs with a strict interpretation of the CA Regional Water Quality Control Board's non-degradation policy for groundwater. Migration of pollutants into pristine waters must be halted.

#4. Remedies that actively destroy contaminants are preferable. In order of preference, Tri-Valley CAREs recommends the following types of cleanup measures: a) remedies that destroy contaminants (i.e. by breaking them down into non hazardous constituents), such as ultra-violet light/hydrogen peroxide, permeable barriers, or biodegradation; b) active remedies that safely treat or remove contaminants from the contaminated media; c) monitored natural attenuation in so far as it relies on natural degradation (and not further dispersion of the pollution) within a reasonable time frame. What is called "risk and hazard management" (i.e., restrictions on land use, fencing, signs and institutional controls), while potentially useful for reducing short-term risks, is not a valid cleanup in our eyes and should only be used as an interim measure. In no case do we think that "point of use cleanup" (e.g., merely placing filters on off-site drinking water wells) is appropriate. When soil excavation takes place, it should be properly controlled to minimize releases of contaminated soil into the air, and onto adjacent properties.

#5. Radioactive wastes and the tritium-polluted underwater plume should be controlled immediately in order to prevent further releases to the environment. The tritium plume, nearly two miles long and growing, cannot be cleaned up in the traditional sense of the word, since it is not economically feasible to separate the radioactive hydrogen (tritium) from the water. Therefore, Tri-Valley CAREs recommends the following: a) isolation of the tritium contaminated wastes in the unlined dumps at site 300 to prevent further and continuing contamination of the groundwater; b) hydraulic control of the underground water plume to prevent further migration; c) aggressive monitoring to ensure no migration occurs over time while the tritium decays (tritium decays at a rate of 5.5% per year); and, d) a stringent contingency plan in case these methods fail. As it currently stands, groundwater rises into the unlined waste dumps during heavy rainfall and, once that water mixes with the radioactive wastes there, it picks up additional tritium contamination. Isolation of the wastes can be accomplished by means of drains, by capturing groundwater upstream from the dump sites before they are inundated, or by removing the tritium-contaminated solid debris from the dumps and storing it above ground in a monitored facility. This latter method has the highest likelihood of actually preventing further tritium contamination.

#6. Radioactive substances should be isolated from the environment. As is the case with tritium (discussed above), there are several underground plumes containing uranium 238. Technology exists to separate this contaminant from the groundwater. We recommend that this radioactive waste be stored in above ground monitored facilities after separation from groundwater.

#7. The ecosystem should be protected and balanced against the cleanup remedies. Site 300 sits on 11 square miles of land, including a series of steep hills and canyons, covered by grasslands. Seven major plant communities occur at site 300, including: coastal sage scrub, native grassland, introduced grassland, oak woodland and 3 types of wetland. Twenty species of reptiles and amphibians, 70 species of birds, and 25 species of mammals also live there. Special and rare and endangered species include the burrowing owl, San Joaquin Kit Fox and the Large-Flowered Fiddleneck. Ecological risks should be no greater than those for humans. The Lab should update its ecological assessment of 1994, as there are more complete data now. Moreover, cleanup activities should not inadvertently destroy unique habitat.

#8. Decisions should not rely on computer modeling. The draft SWFS points out just how complex the hydrogeology of the site is, and how little it is understood by the "experts". Given this, Tri-Valley CAREs believes that over-reliance on computer modeling to predict the fate and transport of pollution is not a good idea. Computer modeling should be used as a tool only, and continually updated by field testing.

#9. Additional site characterization is needed and therefore must be adequately included in budget planning. It is also apparent from the draft SWFS and other documents that additional characterization (e.g. of soil, groundwater, unlined waste dumps etc.) is necessary, and will have to be budgeted for many years to come.

#10. A contingency plan should be completed and subject to public review. We recommend that a site wide contingency plan be part of the SWFS, or part of the upcoming Remedial Action Plan. This is needed because cleanup of several areas at site 300 is not scheduled for some years to come and there are many uncertainties regarding the effectiveness of cleanup. For example, innovative technologies that have not been fully evaluated will be used (because exotic bomb testing activities created a "toxic stew" of contaminants).

#11. The public should be involved in cleanup decisions. As it now stands, public involvement takes place through Tri-Valley CAREs and at Lab-sponsored public meetings and hearings which could end altogether after "sign off" is obtained on the cleanup remedies. Instead, the Lab should commit to keeping the public informed and getting public feed-back on a regular basis.

#12. Cleanup should be given priority over further weapons development. Perhaps most important of all, Tri-Valley CAREs insists that cleanup of site 300 be given a priority over further bomb-creating enterprises, and that adequate, stable, long-term funding be assured in order that the cleanup may be done right. The current allocation of approximately 1% of Livermore Lab's annual budget to cleanup at site 300 (and only another 1% to cleanup at the Lab's main site) is insufficient. Moreover, ongoing and planned weapons activities must not be allowed to continue to pollute the site.

Please print out, sign and return to Tri-Valley CAREs, 2582 Old First Street, Livermore CA 94550. Fax: (925) 443-0177. Phone: (925) 443-7148.




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