Public Comment Letter Regarding LLNL Site 300 Permit Renewal
Mr. Alejandro Galdamez
Program Manager
DTSC Office of Permitting
700 Heinz Avenue, Suite 300
Berkeley, CA 94710

Re: Comments on the Livermore Lab Site 300 Draft Permit Renewal and Draft Negative

Dear Mr. Galdamez:

I am writing to submit the following comments on the draft Hazardous Waste Facility Permit Renewal and draft Negative Declaration for the three hazardous and explosives waste facilities at Lawrence Livermore National Laboratory’s (LLNL) Site 300 near Tracy. The California Department of Toxic Substances Control (DTSC) did not conduct an Environmental Impact Report. Instead, DTSC based its tentative finding that no impact to the environment would result from Site 300’s hazardous waste operations on an inadequate California Environmental Quality Act (CEQA) document, the “Environmental Document Analysis/Checklist.” It is inadequate for the following reasons:

First, the CEQA document does not adequately take into consideration the fact the City of Tracy has given approval for the 5500 home Tracy Hills project located about one mile from the permitted areas at Site 300. This housing project is expected to be built out during the permit period, which will place significant numbers of “sensitive receptors” much closer to the site than previously anticipated. The CEQA document needs to take into consideration this new population in all aspects, especially in respect to air quality and noise.

Second, treatment of explosives waste via open burn/open detonation converts the waste to gases and ash and creates an impact on air quality. These treatment facilities meet the definition of a hazardous waste incinerator under California law and should be regulated as such. California law requires an Environmental Impact Report before hazardous waste incinerators can operate!

Third, the CEQA document acknowledges that Site 300 is a radioactive and/or mixed waste generator, then it makes the claim that Site 300 is not authorized to “manage” radioactive and/or mixed waste in permitted areas. However, when Site 300 generates mixed waste, from programmatic or cleanup activities, then that mixed waste must remain onsite at Site 300 being “managed” for some period in some waste accumulation area until it is shipped to LLNL Main Site for further storage and treatment. DTSC must regulate the management of mixed waste at Site 300.

Fourth, the seismic hazards in this area have been updated and an earthquake or strong seismic event is more likely than previously thought, and could seriously impact the permitted facilities. These potential seismic impacts need to be more thoroughly analyzed and based on updated seismic science in a full Environmental Impact Report.

Fifth, continued operation of the facilities may substantially degrade water quality. A mishap at the facilities—whether the result of accident, oversight, mechanical failure, or failure to comply with applicable regulations—may result in impacts to both ground and surface waters. Given Livermore Lab’s long and detailed history of such mishaps, an incident of this nature is to be expected.

Sixth, the permit will allow an increase in the liquid storage capacity at the Building B883 Container Storage Area from 3,300 to 5,500 gallons — a 67% increase — without any justification of need to support this increase. Site 300 is required to have a hazardous waste reduction plan in place, however this huge increase in allowable waste storage capacity does not encourage the site to reduce its hazardous waste generation or comport with the requirement that waste be reduced. In fact, it does just the opposite. Due to Site 300’s increased proximity to the public that is expected as the Tracy Hills development is built out over the next decade, I urge the DTSC to DECREASE the allowable liquid storage capacity at the Building B883 Container Storage area by 25% or more to protect public health and reduce the site’s hazardous waste generation.

Seventh, the CEQA analysis is also lacking as to whether project activities would create a significant hazard to the public or the environment through reasonably foreseeable intentional, naturally occurring or accidental release of hazardous materials into the environment from Site 300. While adherence to safety policies and design specifications are likely to minimize such risk, the hazard is nonetheless real and should be analyzed. The referenced hazards analysis predates the events of 9-11 and does not include the possibility of an intentional act resulting in release. As a result of an intentional act, equipment malfunction or other mishap, hazardous and explosives wastes and ash could easily be released into the environment. Moreover, Site 300 is subject to wildfires, which could also create a significant hazard to the public and the environment if a wildfire impacts the waste facilities. These environmental effects must be thoroughly analyzed in an Environmental Impact Report.

Finally, because the proposed project could have a significant effect on the environment, the issuance of the draft Negative Declaration was not warranted. On the contrary, the potential significant environmental impacts associated with the continued operation of the facilities necessitate the preparation of an Environmental Impact Report.

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