Environmental Assessment (DEA) Demolition of the Bevatron
Building 51 and 51A. COMMENTS

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Mr. Carl Schwab U. S. Department of Energy
Berkeley Site Office, MS 90R1023 One Cyclotron Road, Berkeley, CA 94720

May 22, 2006

Subject: Comments on The Lawrence Berkeley National Laboratory’s (LBNL) Draft Environmental Assessment (DEA) for the Demolition of the Bevatron Particle Accelerator, Building 51 and 51A.

Dear Mr. Schwab,

PRESERVATION OF THE BEVATRON IS THE MOST PROTECTIVE ALTERNATIVE FOR BERKELEY NEIGHBORHOODS, OUR HISTORY, CULTURE, HEALTH AND THE ENVIRONMENT

• Preserve the Bevatron/Building 51 in commemoration of Nobel Laureate Owen Chamberlain (1920-2006) who was involved in the discovery of the antiproton at the Bevatron and worked on the Manhattan Project during the Second World War. Chamberlain was present in Los Alamos at the testing of the first atomic bomb. Shortly after, he became an outspoken activist for arms control and other issues of social concern. Owen Chamberlain recommended the conversion of the Bevatron facility to a historical and educational resource.

• Preserve the Bevatron/Building 51 in celebration of LBNL’s 75th anniversary in Berkeley scheduled for Founders Day, August 26, 2006.

• Preserve the Bevatron/Building 51 to provide the greatest protection for the health and safety of employees, nearby residents and wildlife (i.e. threatened Alameda Whipsnake) and those pedestrians exposed along routes for trucking out radioactive and hazardous waste which will result if the Bevatron is demolished.

In December of 1995, the California State Office of Historic Preservation, Department of Parks and Recreation listed the Bevatron, Building 51 and 51A as California Historic Resources with the following statement:

“Building 51 and 51A are eligible for inclusion on the National Register of Historic Places under Criterion Consideration G, as defined in 36 CF 60.4. The Building has strong associations with historic developments in the field of particle physics and was the site of a number of significant breakthroughs.

The Bevatron is also noted for its associations with three Nobel Prize-winning physicists (Louis Alvarez, Owen Chamberlain, and Emilio Segre). The breakthroughs developed by these three men were the result of the technology provided by the Bevatron, and its position as the premier facility of its type in the 1950s.” (Attachment 1.)

For the reasons noted in this statement, we consider it mandatory that LBNL and the Department of Energy (DOE) preserve the Bevatron , Building 51/51A Complex, as a living science history site, a museum and education center for the benefit of future generations interested in science, history, architecture and engineering.

Bevatron shielding blocksHowever, there are other reasons that preservation of the Bevatron must be the alternative chosen, and not the demolition of the building. These reasons have to do with the environmental impacts which will be miniscule with the Bevatron preserved in place, compared to the environmental impacts arising from the demolition of the facility. Preservation, therefore, provides the greater protection of the health and safety to employees, nearby residents and wildlife (i.e. threatened Alameda Whipsnake) and those exposed along routes for trucking out radioactive and hazardous waste. Some of the potential environmental impacts from the Bevatron demolition are as follows:

• radioactive, lead and asbestos dust permeating the atmosphere of the Berkeley Lab, surrounding neighborhoods, UC dormitories,

• radioactive and toxic dusts being washed down to further contaminate Berkeley’s groundwater which should be of potential beneficial use as drinking water in case of disasters or severe drought,

• exposure of pedestrians, shoppers, vehicle drivers and passengers to radioactivity as radioactive Bevatron concrete and metal debris is trucked on City of Berkeley streets (i.e. Hearst, Oxford, University Avenue, Shattuck Avenue, Adeline, and Ashby Avenue) to the freeway,

• severe and extended exposure would occur if any of the trucks hauling radioactive debris were involved in an accident. This is quite probable in view of the twelve accidents per year involving truck collisions along the project truck routes, that occurred between 2002-2004. (p. IVK-15 Table IVK-1 Draft EIR 10/21/05),

• exposing other communities to radioactive and hazardous waste by dumping it in nearby landfills, i.e. Altamont, Richmond, Nevada Test Site, Clive Utah, etc.

• continuing to speak of “low level” radioactive waste vs. “high level” radioactive waste as though the former were safe, despite the recent National Academy of Sciences Panel BEIR VII (Committee on Biological Effects of Ionizing Radiation) Report that there is no safe of dose of radioactivity (Attachment 2.),

• Department of Energy treating materials and waste with 2pCi/g of radioactivity and the Department of Transportation treating materials and waste with 270pCi/g of radioactivity as non-radioactive, which requires less safety precautions during transportation and allows the dumping of these materials in ordinary landfills and, therefore, their potential recycling/reuse in household goods and commercial medical equipment,

• a health disaster to project workers, lab employees, students and downwind neighbors should precautionary measures fail during the demolition of the transite exterior siding of Building 51, which contains 20% asbestos fibers.

The DEA is deficient in many respects. Because the Bevatron is eligible to be listed on the National Register of Historic Places, a thorough investigation of all the potential environmental and historic resource impacts of the demolition must be addressed in an Environmental Impact Statement (EIS), including the following:

Hydrology and Water Quality

The EA/EIS must provide: a geologic cross section of the three groundwater plumes which converge at the Bevatron site, i.e. Building 51/64 VOC plume, Building 7 Freon/VOC plume and the old town VOC/Building 7 Diesel plume, to show the depth and concentration of groundwater contamination in the four acre Bevatron site and vicinity.

In addition to the Bevatron core area, more monitoring wells should be located laterally along the Cyclotron Fault and New Fault because they could act as conduits for the contaminated groundwater.

Additional groundwater monitoring wells are needed (a) west of the northern lobe of the Building 51/64 plume as well as (b) west of the western lobe of Building 71 solvent plume to show whether the two plumes converge into a topographic swale and (c) west of the old town plume, specifically in the area between Buildings 46 and 51. All of these plumes are in the Blackberry Creek Watershed and drain west toward the city of Berkeley and San Francisco Bay. (Attachment 3.)

A sampling strategy must be developed and implemented prior to the circulation of the EA/EIS to characterize and provide comprehensive data on the extent of the potential groundwater contamination plume under the Building 5 1/Bevatron. Soil boring(s) and testing should be part of this investigation.

The EA/EIS should show a map of the groundwater plumes in 1995 and in 2005, as they expanded during the RCRA investigations under LBNL’s Environmental Restoration Program, so as to illustrate the direction and rate of their movement.

According to the Environmental Checklist’s Project Description: “Soil and groundwater contamination are known to be present in some areas beneath Building 51 /Bevatron.” The primary known chemicals of concern are chlorinated volatile organic compounds (VOCs) in soil and groundwater. In addition, PCBs have been detected in some groundwater samples. Contamination in soil, outside the plume source areas, has included primarily chlorinated VOCs, petroleum, aromatic hydrocarbons, polycyclic aromatic hydrocarbons, PCBs and Mercury.

It appears that the location of the groundwater monitoring wells in the general Bevatron site is insufficient to characterize the full extent of these plumes. Are the contamination plumes interrelated? It appears that there are no groundwater sampling wells located in the basement of the Bevatron core area.

If the Bevatron structure is removed, what are the potential effects of the increased rainfall on the now pervious site? What protections will be put in place in the future site design to protect further impact of rainwater on existing groundwater plumes? How will the increased groundwater influence slope stability?

Pulling the concrete plug: How will the removal of the Bevatron and its subterranean structures impact the movement and current hydraulic controls of these groundwater contamination plumes? This factor alone is reason for additional groundwater evaluation and monitoring wells. How is LBNL preparing to prevent any contamination from entering the creeks and ending up in downtown Berkeley where Strawberry Creek flows day-lighted through many public and private properties? For this reason, all site clean-up must be done to residential standards.

Biological Resources and Hazards and Hazardous Materials
The EA/EIS must answer the following questions and provide specified information as follows:
1. Tables showing the specific quantities of activated (containing induced radioactivity) material (e.g., electromagnets, scrap metal, steel, copper, lead, concrete blocks, etc.) and by which of the following radionuclide and by what amount of radioactivity (expressed in Curies) they are activated: Ar-42, Ba-133, Co-60, Cs-137, Eu-152, Eu-154, Fe-55, Ti-44, etc.

2. What is the level of “natural” and/or “background” radioactivity LBNL assigns to and/or deducts from each specific material before shipping?

3. What is the actual activation level of each material to be shipped, particularly for every material referred to as being “slightly radioactive” and “slightly activated”? (DOE 2pCi/g vs. DOT 270pCi/g?)

4. Swipe sampling protocols, e.g. the criteria for selecting items “thought to pose reasonably foreseeable risks” from surface contamination: the portion of the surface to be swiped.

5. The quantities of “non-activated” metals and concrete shielding blocks that are scheduled for shipment to government and private sector parties, with certification by non-DOE parties that the metal within the blocks would not be recycled.

6. The quantities of “non-activated” concrete blocks to be broken into rubble and released for construction projects and road building (again the metal contained within the blocks to be certified non-recyclable as above (see #5)

7. A description of the air monitoring system LBNL has in place to determine any changes in air quality during the deconstruction process, if it proceeds.

8. The capacity of first responders to deal with potential accidents or spills.

9. The detection limits of the surveying instrumentation.

10. Name and location of the specific municipal landfills to which “non-activated” materials will be sent where the landfill operator must certify that the metals will not be recycled.

11. Specifically what is to be shipped to the Nevada Test Site and Yucca Mountain, Nevada, Altamont landfill in Alameda County and Richmond landfills in Contra Costa County, CA, a private landfill in Clive, Utah, Hanford, WA, or other DOE facilities/sites?

12. The effects on the potential beneficial uses of Berkeley’s large aquifer, the Lennart Aquifer) i.e. availability in times of drought. Please describe LBNL’s request to the Office of the U. C. President to declare groundwater at LBNL non-potable, i.e. initiating the process of declaring LBNL site (Strawberry Creek watershed) as Brownfields
.
13. Potential effects upon the endangered Alameda Whip snake for which LBNL is critical habitat.

14. What are the cumulatively significant effects, on the human (and endangered
Alameda Whip snake) environment, of the Bevatron demolition concurrent with
the decommissioning and decontamination of the National Tritium Labeling
Facility and the construction and operation of the Molecular Foundry.

15. How radioactive and hazardous materials will be packaged for shipping. How will the trucks transporting hazardous site debris be externally identified as they move through our city and beyond Berkeley.

16. How will radioactive materials, those considered to be “non-radioactive”, be packaged for shipping. What are the various criteria used by LBNL to determine materials to be “non-radioactive”?

17. A consideration of alternatives to the demolition and shipping of unpackaged radioactive materials, which are considered non-radioactive, e.g. allowing radioactive materials to decay in place, without further demolition until fully decayed.

18. A comprehensive description of the various beam targets (including the magnet gap) and the beam dump areas during the Bevatron’s forty-year history, and a sampling strategy to determine where the highest concentrations and types of radioactivity are located. The U. S. Environmental Protection Agency’s (US EPA) current recommendation is to manage asbestos in place, i.e. leave it alone. For abatement, to encapsulate, enclose, encase asbestos at the Bevatron in areas where needed to prevent exposure to the public. Same abatement strategy should apply for lead.

Further, if the proposed Bevatron demolition proceeds, DOE must obtain COMMUNITY ACCEPTANCE from Clive, Utah residents and other communities who might be the recipients of LBNL’s hazardous and radioactive waste. (See Item 11 above.)

Air Quality and Transportation and Traffic
1. If LBNL ends up proceeding with the shipping of the Bevatron debris, all trucks involved must have hazardous materials warning placards in accord with the opinion of the National Transportation Safety Board and the Executive Director of the International Association of Fire Chiefs (West County Times, April 9, 2005). The hazardous materials signs on trucks help firefighters and health officials respond to accidents in the event that hazardous contents are exposed. If the trucks are not properly marked, community safety and emergency responders safety will decrease significantly. Note: In the past month, there were two deaths in Berkeley associated with construction trucks involved in traffic accidents, within blocks of the UC Berkeley campus. (See attachment 4.)

2. All debris trucks should be fully enclosed van-type vehicles.

3. The air quality along the truck route should be monitored from the Bevatron to 1-80 with a stationary air monitoring protocol.

4. DOE must allow the inclusion of the City of Berkeley Transportation Commission’s comments to the DEA/DEIS transportation, traffic and circulation issues as they will not be able to respond until they meet in June 2006.
Geology and Soils

The Bevatron is located on a four-acre site in the western portion of LBNL within the Blackberry Creek (a.k.a. the North Fork of Strawberry Creek) Watershed. The site is in the Hayward/East Canyon/Wildcat Canyon Earthquake Fault Zone, surrounded by two cross faults: the Cyclotron Fault to the south and the New Fault to the north.
The Final EA/EIS must include:

1. A most comprehensive earthquake fault map that would include all the faults in the entire Strawberry Creek Watershed, whether active or not, and an interpretation of the significance of the presences of these faults regarding the transport of surface and groundwater within the area of LBNL, where the Bevatron is located.

2. Watershed map for the LBNL hill site showing the various watershed and sub- watershed divides with a detail of the Blackberry Creek watershed and the four-acre Bevatron site.

3. A Seismic Hazard Zone Map which would show areas in the Strawberry and Blackberry Creek Watersheds where previous landslides had occurred, as well as all topographic, geological, geotechnical, and subsurface water conditions which indicate a potential for permanent ground displacement.

According to a 1949 geologist (C. Marliave) report on the bedrock conditions at the Bevatron site “...the area at the Bevatron is to be excavated and leveled off to elevation 710. The bedrock beneath this beveled surface will be comprised of poorly consolidated Orinda sediments... The Orinda formation absorbs water freely and the lava flows and breccia that are associated with it are also quite pervious so that the whole mass becomes readily saturated... There appears to have been considerable land sliding in the amphitheatre in which the Bevatron is to be located - and during periods of heavy rainfall, the underlying Orinda sediments become quite soft from absorbed water... seeps come out of the ground in many places.. .there are two known permanent springs in the area where tunnels have been driven into the hillside and pipes leading out from the caved entrances have been flowing water for many years.”

Even though landside deposits may have been modified or have fill placed over them, their subsurface characteristics/failure planes may exert controls on groundwater flow patterns and thus on the movement contaminant plumes at the hill site. Mapping of the historic landside distribution in the EA/EIS is extremely important for understanding/interpreting how the contaminant plumes may be distributed on the hill.

4. What is the current configuration and condition of the engineered drainage around the Bevatron site? How is groundwater from the seeps and springs intercepted and captured? Where are water sources diverted? Do creek beds of the historic creeks function as conduits for these waters? According to the 1875 F. Soule Map titled: Strawberry Valley and Vicinity showing the natural sources of the water supply of the University of California, at least two of the branches of the North Fork of Strawberry Creek were located directly under the Bevatron Complex. Please provide a historic map of the site showing these watercourses and their current state.
Cultural Resources

The EA/EIS must carefully consider alternatives to demolition and removal that would allow the Bevatron and its contamination to remain on site in relative containment. On site containment will allow the radioactivity to decay in place and not be hauled away to impact other communities. This would also preserve the historic aspects of the Bevatron as it is eligible for listing in the National Register of Historic Places for the research in particle physics that resulted in four Nobel prizes. In December 1995 the California State Office of Historic Preservation listed the Bevatron, Buildings 51 and 51A, as California Historic Resources, as stated earlier.

Bevatron complex, known as the Bevalac District is also eligible for the National Register of Historic Places at a national level of significance for the period 1949-1993. The EA/EIS must address the historic resource impacts of the proposed Bevatron demolition on the Bevalac Historic District. (See attachment 5.)

An application requesting Landmark status for the Bevatron is pending before the City of Berkeley Landmarks Preservation Commission, LPC (See attachment 6). The LPC opened the public hearing May 4, 2006 and continued the hearing to June 1st at the applicant’s request, to provide time to obtain document not yet released by the DOE, the Historic American Engineering Record (HAER) Addendum.
We therefore request that DOE complete the HAER Addendum, incorporate it into the EA/EIS, and extend the public comment period to receive public comment on the information in the HAER Addendum. This would allow greater understanding of what is actually proposed to be demolished.

There has been broad support to “Save the Bevatron and Building 51”. Over 100 individuals have signed petitions to preserve the Bevatron as a City of Berkeley and National Landmark. (See attachment 7.)

We believe that according to the National Historic Preservation Act, Section 106, the use of Federal funds is prohibited in the demolition of a site that is eligible for listing in the National Register of Historic Places, such as the Bevatron.
In addition, the Memorandum of Agreement (MOA) signed by DOE, California State Historic Preservation Officer and the Advisory Council on Historic Preservation regarding the demolition of the Bevatron building was ratified over eight years ago without any public notice or citizen participation and prior to the release of any environmental review documents for public inspection and comment. We ask that a new MOA be drafted with public participation prior to the completion of EA/EIS. (See attachment 8.)

The projected cost of 85 million dollars for the Bevatron demolition and removal is truly appalling taking into consideration the enormous initial cost of the construction of the facility in the early 1950s, which was approximately 10 million dollars. Therefore we propose that LBNL, in celebration of its 75th Anniversary in 2006, declare an International Architectural Competition for the design and restoration of the Bevatron, and designate it as a historic and educational resource/landmark, as proposed by Nobel Laureate Owen Chamberlain. (Attachment 9).

The shape of the Bevatron and its steel construction lends itself magnificently to the possibility of it being a center courtyard feature for future development at the site. This option would save taxpayers over 80 million dollars and save many communities from the serious potential pollution which the demolition, transportation, and waste dumping would bring about.

Please respond to the comments above in the final EA/EIS as well as to the enclosed letters of concern from Gene Bernardi, James Cunningham, Social Justice Committee of the Berkeley Fellowship of Unitarian Universalists, Public Citizen, Tri-Valley Cares, and BLUE. (See attachment 10.)

Pamela Sihvola, Co Chair CMTW...
L A Wood Berkeley Citizen


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