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LLNL's Site 300: Burning Hazardous Waste in Our Backyard

Explosives testing facilities across the country accumulate millions of tons of hazardous waste and fail to ensure clean disposal of it. Disposal is currently handled by a process called open burning and open detonation (OB/OD). OB/OD of hazardous waste is a direct threat to human and environmental health and these facilities are doing it in our backyards and on the banks of our waterways.

Although the process was banned in 1984 by amendments that Congress made to RCRA (Resource Conservation and Recovery Act), an exemption was made by the EPA for “waste explosives” which are generated by the Military. The EPA justified that “waste explosives…cannot safely be disposed of through other modes of treatment” (See Regulatory Loophole” here). Thirty-two years have passed, however, since the exemption and science has found a range of alternatives to OB/OD. Ironically, some of the work on these alternatives was done at Lawrence Livermore National Lab (LLNL), however the facility has failed to adopt any of the practices that it itself developed. Lawmakers will continue being slow to ban OB/OD entirely unless communities begin to rally behind these alternatives.

Lawrence Livermore National Lab’s high explosives testing range, called Site 300, in Tracy, CA is one of these sites burning and detonating hazardous waste. OB/OD at Site 300 may give off carcinogens such as DNT, RDX, and TNT, the inorganic contaminants lead, arsenic, and mercury that inhibit fetus and infant development, and particulates linked to irregular heartbeat, asthma, and other respiratory issues (See more “Health Effects” here). The Hazardous Waste Permit Renewal that LLNL drafted for Site 300 this year permits their Explosive Waste Treatment Facility to burn 95 pounds of this waste per day and keep 15,836 pounds in storage (See Tri-Valley CAREs comments on the renewal here).

The Tracy Hills development that was recently approved for construction has made the situation in Tracy more urgent. More than 5000 homes are planned for this development and they are going to be within two miles of Site 300. Most alarming is that the aforementioned permit renewal “concludes that the treatment of explosive waste by controlled open burn or detonation will not expose sensitive receptors, (like children, seniors, pregnant women, endangered species, etc…) to substantial pollutant concentrations” (See Tri-Valley CAREs comments again here). This conclusion was based on data from a 2007 Health and Ecological Risk Assessment performed nine years before Tracy Hills was approved. Tri-Valley CAREs comments go on to urge LLNL to do a thorough Environmental Impact Report (EIR) of Site 300 activities on sensitive receptors.

Residents of Tracy, Livermore, and the entire Bay Area must organize in order to protect future Tracy Hills residents and in order to motivate LLNL to perform the EIR. The Wisconsin community group CSWAB (Citizens for Safe Water Around Badger) and allied groups spearheaded the CEASE FIRE campaign with a goal to “protect human health and the environment by calling for the immediate implementation of safer alternatives to open air burning, detonation and non-closed loop incineration/combustion of military munitions” and has been very successful (See CEASE FIRE campaign here). Much of the information in this post is thanks to information provided by CSWAB.

Site 300's Open Burn Cage used for burning hazardous explosives waste.

Site 300's Open Burn Pans used for burning hazardous explosives waste.