Community Acceptance Criteria for cleanup

[marylia@earthlink.net (marylia)]

Dear friends and colleagues working on cleanup of nuclear and other
facilities: I am posting these Community Acceptance Criteria for 3 reasons.
(1) You are invited to please sign on at the end and return the message to
us; (2) You are invited to include comments, including other criteria, in
your return message; and (3) We at Tri-Valley CAREs want to encourage other
communities to develop "community acceptance criteria" at other sites. Our
criteria were development by our members in consultation with our Superfund
technical advisor Peter Strauss, We are interested in your feed-back. First
two quick notes -- sorry that the cool formatting gets lost here, and
please note that this is a fairly long file. There are 12 criteria and it
was 2 pages long in our newsletter. Read on...

Livermore Lab's Site 300 Cleanup: Community Acceptance Criteria

please read, sign and return

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 sign and return to Tri-Valley CAREs,
2582 Old First Street, Livermore CA 94550.
Fax: (925) 443-0177. Phone: (925) 443-7148.
E-mail: marylia@earthlink.net

Name:

Address:

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Additional comments:



++++ 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.