To the Mayor and City Council Members of Berkeley, February 28, 2003

Enclosed please find our comments addressed to the U S Environmental Protection Agency (US EPA), Region 9, regarding the Lawrence Berkeley National Laboratory’s (LBNL) Delisting Petition. We are requesting that US EPA deny the Delisting Petition for the many reasons stated in our letter.

We are respectfully asking for your support to assure that the Delisting Petition is denied. The Berkeley City Council voted unanimously on September 15, 1998 to request LBNL “to cease all oxidation/incineration/treatment of mixed waste and all radioactive releases”. (Resolution #59,695A-N.S.) This action was taken after an accident at the National Tritium Labeling Facility (NTLF), in July of 1998, when silica gel containing high activity tritium mixed waste was placed into a kiln at the NTLF which resulted in a fifty (50) Curie release into the environment.

This is not an isolated example, since monitoring after 1998, while the study was ongoing, showed that radioactivity continued to be released, and sample handling and other operations of the process could easily have contributed to a large portion of these releases.

During the past two decades radioactive Tritium has been released into the environment from the NTLF due to accidents and routine operations. Because of this long-term environmental pollution, the US EPA determined in July 1998 that LBNL qualified as a Superfund site, stating “ambient air samples collected on and off the LBL site have contained Tritium in concentrations that exceed the EPA’s Cancer Risk Screening Concentrations. Tritium has also migrated to groundwater, surface water, soil, and soil water, both within LBL boundaries and offsite.”

A large Tritium groundwater plume extends across the LBNL site, from north to south and had already exited the site boundary in 1997 (with concentrations of Tritium measuring as high 23,300 pCi/L, exceeding EPA’s drinking water standard). It should be noted that Lawrence Livermore National Laboratory’s (LLNL) Site 300 with its high explosives test site, eight landfills, several waste lagoons, etc received a Hazard Ranking Score (HRS) of 31.58. In comparison, LBNL’s HRS score is 50.35. (All sites with a score of 28.5 or above qualify as a Superfund site).

Furthermore, Tritium is continually measured in Chicken Creek, a tributary to Strawberry Creek, which flows “daylighted” through the UC Berkeley campus, city parks, back yards of private residences, and to the San Francisco Bay. It is our understanding that if US EPA approves LBNL’s Delisting Petition, the Lab will be able to continue the Catalytic Chemical Oxidation of Tritiated Mixed-waste at the site and thus continue this unnecessary degradation of the Berkeley environment.

Due to all of the above, we are asking you to support our city’s resolution requesting LBNL “to cease all oxidation/incineration/treatment of mixed waste and all radioactive releases and ask US EPA to deny LBNL’s Delisting Petition.

Sincerely,
Pamela Sihvola Co-chair Committee to Minimize Toxic Waste
L A Wood Berkeley Community Environmental Commission*
*For identification only