LLNL site 300 meeting/talking points

[marylia@earthlink.net (marylia)]

Hello. In addition to write ups in Citizen's Watch, here are some talking
points from Tri-Valley CAREs outlining key issues at stake in the Livermore
Lab's site 300 cleanup. We hope folks residing in the Bay Area and Central
Valley can come to this important public meeting. Read on...
Peace, Marylia

TALKING POINTS

ON SITE 300 DRAFT SITE WIDE FEASIBILITY STUDY
FOR PUBLIC MEETING 3/18/99,
6 PM TO 8 PM AT THE TRACY PUBLIC LIBRARY,
20 E. EATON AVENUE, TRACY
Library phone# (209) 831-4250 (for directions)

by Tri-Valley CAREs

1.                      This draft Site Wide Feasibility Study (SWFS) is,
in general, a very good effort to document the problem and what has been
done so far to clean it up. It conforms with Tri-Valley CAREs'
recommendations a few years back about the scope of the SWFS, and the Lab
and all involved should be congratulated.

2.                      However, the SWFS document is confusing about what
will be done to clean up site 300 in the future. And, because so many
different options are presented in the document, we recommend that there be
several iterations of this SWFS before a Remedial Action Plan (RAP) is
proposed. These could be revisions to this draft. At this stage we don't
want the agreed upon schedule with the regulators to be the driver (i.e., a
draft RAP is scheduled for September). Cleanup, ultimately, may be better
served if the Lab makes this a definitive document.

3.                      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 such cases where "background" cleanup levels that are more
protective of human health and the environment can be achieved, they should
be achieved. In this regard, Tri-Valley CAREs concurs with a strict
interpretation of the California Regional Water Quality Control Board's
non-degradation policy for groundwater.


4.                      Concurrent with a strict cleanup standard, as
outlined in #3 above, and as a priority to be completed as soon as
possible, all migration of contaminants into pristine waters should be
halted.  At a minimum, the standard of 1 in 1 million excess cancer deaths
should be adhered to, as well as meeting a hazard index of less than 1 (non
cancer health effects).

5.                      In order of preference, Tri-Valley CAREs recommends
the following types of cleanup measures: a) active remedies that destroy
contaminants (i.e. by breaking them down into non hazardous constituents),
such as ultra-violet light/hydrogen peroxide, solar detox, other oxidation
techniques, etc.; b) active remedies that safely treat or remove
contaminants; 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) is not a valid cleanup in our
eyes. Similarly, in no case do we think that "point of use cleanup"  (e.g.,
placing filters on off-site drinking water wells) is appropriate.  In all
cases, hydraulic control should be established (as outlined in #4 above) to
halt migration of contaminant plumes to pristine waters.

6.                      The solvent contamination (e.g. TCE) plumes are one
example where the pollutant can be cleaned up by breaking it down into non
hazardous constituents, and so that should be done as a preferred option,
as outlined in #5a above. (Immediate capture of the plume to halt further
migration should first occur to ensure that the entire plume gets cleaned
up.)

7.                      The tritium plume, nearly two miles long and
growing, cannot be cleaned up in the traditional sense of the word, since
it is not feasible to separate the radioactive hydrogen (tritium) component
from the water. Therefore, Tri-Valley CAREs recommends in conformity with
#5c above: a) hydraulic capture and control of the plume to prevent further
migration; b) aggressive monitoring to document capture over time and to
ensure no migration while the tritium decays (at a rate of 5.5% per year);
c) isolation of the tritium contaminated wastes in the unlined dumps to
prevent further and continuing contamination of the groundwater. As it
currently stands, groundwater rises into the waste dumps and "collects"
additional tritium contamination. This isolation of the wastes may be
accomplished by means of drains, but the most sure way would be to remove
the tritium-contaminated debris from the pits and store it above-ground in
a monitored storage facility; and, d) a stringent contingency plan in case
these methods fail (see also #11 below regarding the need for a site wide
contingency plan.)

8.                      The SWFS points out how complex the hydrogeology of
the site is. Given this, we feel that over reliance on modeling to predict
the fate and transport of contaminants is not a good idea. Computer
modeling should be used as a tool only, and continually updated by actual
field testing as that information becomes available. We believe that when
decisions rely on modeling (a bad idea to begin with), the absolute most
conservative assumptions should be used.

9.                      It is also apparent from this document that
additional characterization (e.g. of soil, groundwater, waste dumps etc.)
is necessary, and will have to be budgeted for many years to come.

10.                     Assumptions about land-use need to be altered. As
we can see,
residential development is beginning to take place up to the site boundary.
Any modeling assumptions should assume 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 stewardship. 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 land uses.

11.                     We recommend that a site wide contingency plan be
part of this document. This is so because the cleanup of a few sites are
put off until the future, and contingent actions should be part of the
cleanup plan and thus incorporated into the site wide Record of Decision
(ROD).

12.                     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 job 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.


We have many specific comments and questions about the document, but these
will be provided in written comments. However, we feel that a heavy
editorial pen should be taken to this document to make it much more
understandable to lay people. For example,  glossary of technical terms is
absolutely needed. (The Glossary published in the site 300 Site Wide
Remedial Investigation is an excellent starting place.)

For more information, contact Tri-Valley CAREs, 2582 Old First Street,
Livermore California 94550. Or call  (925) 443-7148

ends

++++ Please note that my email address has changed to
<marylia@earthlink.net> on 3/1/99 ++++

Marylia Kelley
Tri-Valley CAREs
(Communities Against a Radioactive Environment)
2582 Old First Street
Livermore, CA USA 94550

<http://www.igc.org/tvc/> - is our web site, please visit us there!
Our web site will remain at this location. Only my email address has
changed on 3/1/99.

(925) 443-7148 - is our phone
(925) 443-0177 - is our fax

Working for peace, justice and a healthy environment since 1983, Tri-Valley
CAREs has been a member of the nation-wide Alliance for Nuclear
Accountability in the U.S. since 1989, and is a co-founding member of the
international Abolition 2000 network for the elimination of nuclear
weapons.