Communities Against a Radioactive Environment
Lawrence Livermore National Laboratory's Site 300
May 4, 2000 Public Hearing on Cleanup
of Toxic and Radioactive Contamination
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.
Livermore Laboratory's Site 300 Talking Points
- 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.
- 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
- 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.
- 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.
- At the site's High Explosives Process Area, much more detail needs
to be provided about the cleanup remedies and contingency actions.
- 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.
- 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.
- 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.
- 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
- 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.
- 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).
- 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.
- 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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