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STRAWBERRY CREEK WATERSHED COUNCIL August 2, 2011
Karen Toth, Supervising Hazardous Substances Engineer I
Re: Meeting Request Referral via DTSC to California Department of Public Health (DPH) and U.S. Environmental Protection Agency (EPA) regarding Radioactive Contamination, Emissions (neutron, gamma etc.), and Release of Nanoparticles, and Anthrax at the Lawrence Berkeley National Laboratory (LBNL) Dear Karen: Again, we appreciate our meeting with you on July 25, 2011. Per your request in writing and at the meeting, we are asking you to forward our urgent concerns regarding radioactive contamination, emissions, and release of nanoparticles at LBNL to be discussed with DPH and EPA. Background: LBNL, initially called the UC Radiation Laboratory, was originally located on the University of California Berkeley (UCB) central campus in Alameda County during 1932. By 1940, it was relocated to its present site on the steep hills of Strawberry and Blackberry Canyons east of the Hayward Fault and the central UCB campus. The first major facility, the 184-inch synchrocyclotron was built with funds from both private and university sources, and was used in the Manhattan Project in the development of the world's first nuclear bomb. Beginning in 1948 the U.S. Atomic Energy Commission and then its successor agency, theDepartment of Energy (DOE) funded the lab while it continued to expand its facilities in Strawberry and Blackberry Watersheds to this day. In 1991, DOE's Tiger Team found 678 violations of DOE regulations that cover management practices at LBNL. A key finding was that air, soil, and water in Berkeley and Oakland are contaminated with tritium and other radioactive substances (for instance uranium contamination left buried during the 184-inch Cyclotron decommissioning process) and toxic chemicals, as well as finding that LBNL was not in compliance with federal standards for radioactivity in air (the National Emissions Standards for Hazardous Air Pollutants, or NESHAPs, under the purview of US EPA/Region IX). Because of these findings DOE started funding a program intended to provide independent confirmation of LBNL's monitoring programs, i.e. the California Agreement in Principle (AIP) program to be conducted by California Department of Health Services(DHS, now DPH) which has jurisdiction over radioactivity in California. Outstanding Concerns: As we have discussed with DTSC, since this Spring 2011, our concerns are specific to the LBNL's ongoing work at the "Old Town" site, specifically the demolition of Buildings 25, 25A, and associated Workplans for contamination investigations in preparation for construction of the proposed General Purpose Laboratory (GPL) and the Solar Energy Research Center (SERC). The LBNL Old Town site was firstconstructed in the early 1940s, including Buildings 25, 25A, 25B, 44,44A, 44B, 40, 41, 52, 52A — all having been recently demolished or are in the process of being demolished. This is known to be a highly contaminated area. For instance, Building 25 housed a 150-ton synchrotron, a particle accelerator that operated through the 1950s. After the synchrotron was removed the site housed a linear accelerator with associated facilities. The two other demolition sites at LBNL: Bevatron and Building 51, constructed on the ravine of the North Fork of Strawberry Creek, as well as Building 71, site of radioactive curium release, warrant additional attention. Of particular note, the Old Town area still houses Building 4 (a former radioactive waste storage and staging area) and Building 5 (a former radioactive decontamination area and former outdoor radioactive waste storage area), as described in the AIP 1995 Annual Report. Since DTSC has no jurisdiction over radioactive issues, it is critical that the jurisdictional agencies, DPH and EPA be consulted now, as LBNL is proceeding with soil sampling plans that are completely inadequate to characterize the Old Town site, i.e. proposed 14 samples at 2 1/2 ft. depth with no individual isotopes to be analyzed, just summarily gross alphaand beta, etc. Our request for a meeting with DPH and EPA is urgent, in order to address the current practices at LBNL which have no independent agency oversight and review!
Sincerely,
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