Dear Current or Former Girton Hall Parent:
We are responding to an August 18, 2000 letter from University of California's Child Care Services to Former Girton Hall Parents. The Committee to Minimize Toxic Waste (CMTW) is the "community activist group" to which the letter refers. We are sorry we are not more activist or we would have gotten this letter to you sooner. We have enclosed some comments on the University's letter and some facts about tritium that we have learned during the five years we have been investigating the radioactive releases contamination and waste from the Lawrence Berkeley National Laboratory (LBNL).
CMTW has never asserted that children are unsafe anywhere on or near the UC Berkeley campus, though it may be true. We do know that children and the unborn fetus are more vulnerable to radiation than adults, and that a Superfund re-evaluation revealed that radioactive tritium in air samples at the Melvin Calvin Lab on campus and the Lawrence Hall of Science exceeded the US Environmental Protections Agency's (EPA's) Cancer Risk Screening Concentration. Although we appreciate how hard it is to find day care, we suggest it might be advisable that parents with infants in Girton Hall find another place for their children until the contamination has been thoroughly investigated by an independent scientific group.
The Committee has focused mostly on radioactive tritium emissions from the Lawrence Berkeley National Laboratory's (LBNL's) National Tritium Labeling Facility (NTLF) only 110 meters from the Lawrence Hall of Science. We only recently became aware of the use of tritium at LBNL's Melvin Calvin Lab, located on the UC campus less than 90 meters from Girton Hall. LBNL's Donner Lab, north of Girton Hall, also uses radioactive substances in its research as does Etcheverry Hall, a UC facility on Hearst Avenue.
In 1998 the US Environmental Protection Agency (EPA) found that LBNL is eligible for the Superfund National Priorities List for cleanup because, as we indicated above, the amount of tritium found in air samples at the Lawrence Hall of Science and at the Melvin Calvin Lab exceeded EPA's Cancer Risk Screening Concentration. (see enclosed Superfund Re-evaluation of LBNL, 1998.) EPA looked at the most recent data available for Melvin Calvin Lab which was for 1995. Strangely, following that year LBNL no longer reported data from Melvin Calvin Lab's tritium monitor. Previously we thought the Melvin Calvin monitor measured tritium coming from the N'TLF. We just recently learned that Melvin Calvin is, itself, a source of tritium emissions.
Q: What is tritium?
Because the body cannot distinguish between tritiated water and ordinary water, tritiated water spreads throughout the body, radiating all body organs. This is not true of other radioactive substances, e.g. strontium 90 goes to the bones and teeth, and radioactive iodine goes to the thyroid gland.
Q: How radioactive is tritium?
In the first sentence of its document UC states that "tritium cannot penetrate the skin" and in the second sentence states, "any risk from tritium comes from ...absorbing it through the skin".
Tritium gas may not penetrate the skin (it is harmful if breathed), but tritiated water can be absorbed through the skin as well as breathed, and can be ingested when a child puts into his or her mouth leaves or soil containing tritiated water. Most serious of all is tritium organically bound in vegetation.
The Lab converts most of its tritium into tritiated water. Tritiated water is 25,000 times more harmful than tritium gas. The tritium which becomes organically bound in vegetation is 250,000 times more harmful than tritium gas. The readings for tritiated water contamination in soil and vegetation in the eucalyptus grove between the National Tritium Labeling Facility (NTLF) and the Lawrence Hall of Science (LHS) have been more than 12 times higher than the legal limit for drinking water. (See enclosed Fact Sheet on Tritium and the National Tritium Labeling Facility...) For this reason we strongly suggest that soil, vegetation and groundwater samples be taken, as well, around the Melvin Calvin Lab and Girton Hall, by an independent scientific group. Particular attention should be given to tree-ring studies for organically bound tritium since some of the highest tritium emissions at the Me1vin Calvin Lab were in the late 1970's.
Tore Straume, a scientific expert on tritium, was hired by the City of Berkeley to review LBNL's Environmental Health-Risk Assessment for Tritium Releases at the National Tritium Labeling Facility at Lawrence Berkeley National Laboratory (July 1998). In his report Straume indicated that LBNL downplayed the harmfulness of tritium when he stated "the low energy beta ray emitted by tritium is more effective in producing biological damage than the higher energy beta rays, X-rays, and gamma rays most commonly encountered".
Q: How is tritium used at LBNL and on the campus?
One third or less of the tritiations of compounds at the National Tritium Labeling Facility are associated with drug research. We are not sure what the other 70% of tritiations deal with except we know that some tritiations involve insect research, possibly on pesticides, and some are done to test the technique itself.
Q: How much of the tritium used at LBNL and the campus escapes into the environment?
About 200 curies of tritium gas is used in a tritiation. Less than one curie of that actually ends up in the tritiated compound. The rest, over 199 curies (which the NTLF converts to tritiated water) is released into the environment or stored as waste in Strawberry Canyon until it is released for shipment to other nuclear waste dumps e.g. Idaho National Engineering Lab, or Oakridge Tennessee.
It is interesting that UC chose to tell you about tritium releases in only one year, 1995. From 1982-1995 the average number of curies released was 215 curies per year. In the late 1980's some years had tritium releases of up to 500-560 curies. In 1996 the NTLF was closed for 6 months because of tritium waste handling violations. Since then the NTLF appears not to have yet resumed typical tritiation operations. However, it is expected that they will eventually return to business as usual.
Unfortunately, there are other activities that release tritium. On July 24, 1998 at least 35 curies of tritium were accidentally released during a Waste Treatability "Study" where combustion was used to attempt to remove solvents from tritiated mixed waste. In other words, over one third of what LBNL projects it will release in a year's time was released in one day. This accident is now under investigation by the California Dept. of Toxic Substances Control.
UC and LBNL attempt to convince the public that because the amount of tritium they use takes up little space, it is therefore not dangerous. Small does not equal safe. Did we see or can we see the bacteria and viruses that have killed or are killing thousands of people? (plague, polio, AIDS, etc.)
Exit signs do contain tritium gas, but tritiated water vapor, 25,000 times more harmful than tritium gas, should not be compared to the gas in Exit signs. (see enclosed Fact Sheet... for maximum levels of tritiated water found in soil, vegetation, rain water, etc. near LBNL and LHS)
Q: What are other natural sources of radiation exposure for the average person?
Since those people particularly susceptible to cancer can get cancer from "natural" radiation, in a democracy the populace should be able to declare "we want no more radiation than already exists". Actually, so-called background radiation is already elevated by bomb testing at the Nevada Test Site, by accidents such as Chernobyl and Three Mile Island, and, in this area, by the presence of accelerators and current and former reactor locations, e.g., Mare Island, UC's Etcheverry reactor, LBNL's Bevatron and Advanced Light Source, the Vallecitos reactor and radionuclide research at the Lawrence Livermore and Berkeley Labs.
As for consumer products, we can choose not to have chest X-rays or take airplane flights or use a smoke detector, but we cannot make a choice regarding exposure of ourselves or our children to radiation if we are not informed of its existence. We are very concerned that the San Francisco Bay Area does have extraordinarily high rates of breast and prostate cancer. However, we prefer the alternative of removing the sources of radiation, rather than leaving our homes.
Q: Are there any health risks to children, staff or visitors at the Girton Hall Day Care Center?
One of the scariest things about how this is all being handled is the fact that none of the agencies responsible for the health and safety of staff or children at the Day Care Center has expressed concern about the radioactive releases from LBNL's Labs on campus. In her cover letter to former Girton Hall parents, the director of child care services asks parents to be assured that students, faculty, staff and children who are or have attended Girton Hall are safe. You are asked to be assured while they "gather more facts". We believe this should made you uneasy, not assured. If you have dealt with LBNL and UC as much as we have, you would worry that they may only gather "facts" that are "reassuring".
The US EPA, as the agency responsible for determining whether tritium in air emissions exceeds the National Emissions Standards for Hazardous Air Pollutants (NESHAPs), is not anxious to reveal that it may not have done its job properly. The community brought to EPAs attention that erroneous parameters have been entered into the CAP 88 model used to determine whether the LBNL complies with NESHAPs. LBNL enters the actual NTLF stack height into the model as though the stack were towering over the Lawrence Hall of Science (LHS). The NTLF stack is on the downslope of the hill on which LHS sits. Thus the mouth of the stack is many meters below the LHS plaza which is often downwind of the stack. The meteorological data entered into the model originally came from the Oakland Airport, and then it came from the Blackberry Canyon although the NTLF and its stack are in Strawberry Canyon. A new meteorological station has been erected at a height such that it measures wind speed and direction, not at the level where the children are playing, but some distance above.
As for the California Dept. of Health Services (CDHS) we refer you to their Agreement in Principle Annual Report, 1995 which serves to alert readers that the magnitude of the tritium problem is greater than previously suspected. It also points to other areas containing legacy radioactive contamination.
The US Surgeon General has not analyzed data on tritium emissions at LBNL. Rather, they have written some letters related to the CDHS analysis of cancer statistics in some of the census tracts selected by our Committee because of their proximity to the LBNL or because of a known cancer cluster. In census tract 4001, which includes the top of Panoramic Hill, which lies in a southeasterly direction from LBNL, one of the predominant wind directions from the Lab, the observed number of breast cancers was found to be higher than the expected number at a statistically significant level. As you may know the actual, and thus expected, breast cancer rate in the S.F. Bay Area is one of the highest in the 'world. (April 1, 1999 letter to Gene Bernardi, CMTW, from Eva R. Glazer, M.D.. Cancer Surveillance Section, CDHS)