NID Action memo/Citizen's Watch

[Marylia Kelley <marylia@igc.org>]

Lab NIF Memo Incomplete
by Peter Strauss and Marylia Kelley
from Tri-Valley CAREs' December newsletter, Citizen's Watch

In September, as we reported, during the construction of the National
Ignition Facility (NIF), over 100 capacitors containing PCBs were uncovered
and removed. Treated as an "Emergency Removal Action" under the provisions
of the Superfund law, everything was quickly removed within days of the
discovery. But for DOE's desire to excavate before the winter rains, this
removal action could have been undertaken in a more deliberate manner, and
thus, could have included public participation. Instead, it was carried out
behind closed doors. By law, DOE was still required to prepare an "Action
Memorandum," subject to public comment. Overall the report is deficient and
incomplete, with many important data gaps. Below is a brief summary of
three key concerns:

** The cleanup level set is too lax. The Action Memo states that all soils
containing PCBs at or over 1,000 parts per billion (ppb) were removed from
the site. It is not clear why this level was set. At some other sites, the
levels decided upon have been six times more stringent, as low as 160 ppb.
One of the problems with PCBs is that they may contain dioxins and furans,
or similar molecules. Dioxins and furans are generally cleaned up to 1 ppb,
and may be toxic at 1 part per quadrillion.

** Monitoring is needed. The Lab dumped some "clean" soils (possibly
containing low-levels of PCBs) on the northern part of the site. There is a
potential that these soils will run-off into Arroyo Las Positas and the
industrial waste water system during heavy rains. We recommend that all
run-off be monitored for PCBs for at least one year, and detection limits
be set in the low parts per billion. We also recommend that run-off
controls be placed around the redeposited soil.

** Livermore Lab is a Superfund site. Groundwater below the NIF
construction site is significantly contaminated. Extraction locations for
pollutants are close to the NIF construction site. Tri-Valley CAREs is
concerned that the removal action and the surrounding excavation will
negatively affect the cleanup in this area. The Action Memorandum fails to
address this important issue altogether.