4.18 ENVIRONMENTAL COMPLIANCE AND INADVERTENT RELEASES
LLNL and SNL, Livermore must comply with all applicable federal, state, and local environmental regulations implemented by a variety of regulatory agencies including the Environmental Protection Agency, California Department of Toxic Substances Control (previously the California Department of Health Services), California Department of Fish and Game, regional water quality control districts, local air pollution control districts, county health departments, and the City of Livermore Water Reclamation Plant.
In 1989 the Secretary of Energy, James D. Watkins, established teams (Tiger Teams) to assess the ES&H programs and their management commitment to ES&H for all DOE facilities, and to determine if changes were needed to improve the protection of the environment, safety, and health. These Tiger Team Assessments of LLNL and SNL, Livermore, conducted from February to May 1990, identified a number of key findings in the area of quality assurance and quality control of environment, safety, and health programs. Both LLNL and SNL, Livermore have addressed and are continuing to take steps to address the deficiencies that were noted. (A more complete discussion of the Tiger Team Assessments can be found in Appendix C.)
The Environmental Protection Department of LLNL and the Environment, Safety and Health Department of SNL, Livermore conduct programs to assess compliance with applicable environmental regulations, and to estimate the impacts of operations on the environment, including the effectiveness of effluent control measures. The results of these internal monitoring programs are reported annually to DOE and to other appropriate federal, state, and local regulatory agencies. The results are published and available to the general public in the Laboratories' annual environmental reports.
Environmental analysts from the Laboratories assist in the day-to-day activities such as waste management, waste minimization, and pollution abatement control. Compliance status is maintained and verified by a staff who keep informed of all existing and planned activities, review construction documents, inspect facilities, and audit waste management procedures.
LLNL and SNL, Livermore conduct facility inspections to scrutinize proper handling and management of hazardous and radioactive wastes, as well as other critical aspects of waste generation and handling, in an effort to minimize environmental impacts. Trained personnel investigate, sample, and evaluate all potentially hazardous spills and leaks to the environment. After cleanup operations are conducted, the affected areas are sampled to verify that the cleanup has been successful. All spills, leaks, and releases that are required to be reported are reported to the appropriate regulatory agencies.
Tables 4.18-1 and 4.18-2, respectively, list the permits held by LLNL during 1990 and those held by SNL, Livermore during 1990.
Tables 4.18-3 and 4.18-4 summarize the regulatory agency inspections and audits conducted at the LLNL Livermore site and LLNL Site 300, respectively (LLNL, 1991f, 1992a). Table 4.18-5 summarizes the regulatory inspections and audits pertaining to SNL, Livermore during 1990 and 1991 (SNL, Livermore, 1991i, 1992b). Findings resulting from these activities are summarized below and are representative of the type of regulatory oversight that may be expected to continue into the future.
The more recent inspections have not identified new compliance concerns at either LLNL or SNL, Livermore.
LLNL Livermore Site—Regulatory Inspections and Audits
Air Inspections
The Bay Area Air Quality Management District conducted 20 days of inspections at the LLNL Livermore site during 1990. Inspections were conducted to review start-up of new equipment and operation of existing equipment with permits. As a result of these inspections, the Laboratory received three Notices of Violation. They were issued for operating a silk-screening unit without proper controls (the district interpreted this unit as regulated by rules pertaining to cold cleaners, rather than by the surface preparation rules LLNL thought applicable); operating two paint spray booths without permits; and using an improper mix of thinner in paint, resulting in too much volatile organic content. In response to these Notices of Violation the Laboratory took the following actions: the silk-screening unit was shut down until the rule applicability could be sorted out and compliance measures taken; the paint spray booths received permits to operate; and the paint shop corrected its mixing proportions of thinner to paint.
Hazardous Waste Inspections
The Department of Health Services inspected LLNL hazardous waste management units and generator operations on February 26 and 28, 1990. An inspection report was received in May. It cited the following: containers were improperly labeled (three containers were observed that either lacked labels or had labels that were only partially completed); one container located at a satellite work station was open; a fire extinguisher at one waste accumulation area (WAA) lacked a tag documenting maintenance activities; and one WAA lacked a readily accessible eyewash/safety shower. The Laboratory corrected the observed violations and responded to DHS with documentation of corrections in a letter dated June 26, 1990. DHS issued a Return to Compliance letter on September 3, 1990.
On September 21, 1990, the EPA visited the Livermore site as part of a nationwide information gathering effort to review training programs for incinerator operators. Although the LLNL incinerator has not operated since 1988, the inspector reviewed the historical training records on file. Staff who had operated the incinerator in the past also were interviewed. No report was sent to the Laboratory regarding the findings of this survey.
Tank Inspections
In January 1990, an inspector from the Alameda County Health Department inspected the floor of the Building 322 plating shop for approval of coating material and sampling procedures. Approvals were granted. The inspector returned on November 20 to inspect tank 298-R1U1 and analytical records for several other tanks.
Sewer Discharge Inspections
The Livermore Water Reclamation Plant spent 10 days onsite during Calendar Year (CY) 1990 inspecting and sampling discharges. Each of these inspections is summarized briefly below.
The Livermore Water Reclamation Plant inspector spent 2 separate days in February and March reviewing the Building 322 plating shop. This area was inspected first in February; during the March inspection, samples of the Building 322 plating shop wastewater discharge were collected. No formal reports were issued by the Livermore Water Reclamation Plant.
On April 30, specific areas of Buildings 196 (Sewer Monitoring Station), 197 (semiconductor and metal finishing process), 514 (Liquid Waste Treatment), 612 (Waste Storage), 131 (Microfab Processing Laboratory), and 253 (Hazards Control Bright-Dip Operation) were inspected by the Livermore Water Reclamation Plant. No violations were noted; however, the inspector arranged to return to participate in the quarterly pretreatment program. Split samples were collected on May 8, 9, and 18. The inspector observed a pH excursion. Corrective action was taken while sampling at Building 131.
On May 31, the inspector toured a construction site checking for potential sewer discharge concerns. None were noted.
Pretreatment processes were inspected and sampled at Buildings 131 and 253 on August 15. The inspector requested modifications at the Building 131 sampling location. These modifications subsequently were completed and reported to the Livermore Water Reclamation Plant.
On November 5, the Livermore Water Reclamation Plant inspected and sampled the Building 321 water jet, inspected various processes at Buildings 406 and 691, and toured the sewer diversion facility. No issues were noted by the inspector.
On December 10, samples were collected at Building 141, and the Building 251 facility was inspected. The Livermore Water Reclamation Plant inspector requested modifications to aid sample collection at Building 141 as well as construction of a berm around the Building 251 tank system. The modifications at Building 141 were completed and the design and construction of the berm were initiated as part of the retention tank upgrade project.
LLNL Site 300—Regulatory Inspections and Audits
Air Inspections
On June 12, 1990, the San Joaquin County Air Pollution Control District conducted an inspection of the vapor recovery system; no discrepancies were found.
Hazardous Waste Inspections
The EPA conducted an inspection of hazardous waste management activities on March 21, 1990 which resulted in a Warning Letter being issued to LLNL on June 28, 1990. This letter included the inspection report, which identified conditions at the facility at the time of the inspection, areas of noncompliance with RCRA regulations, and potential RCRA violations. Specific observations identified in the inspection report included the following:
- Hazardous wastewater was stored for more than 90 days in a portable tank, and records of weekly inspections for leaks or deterioration were not available;
- Accumulation start dates were not identified on labels for two waste containers held at a waste accumulation area;
- The emergency coordinator was not clearly defined in contingency plans;
- Training records lacked a description of the hazardous waste training requirements;
- Employees working alone did not have immediate access to external emergency assistance at one waste accumulation area;
- Three plans used at LLNL Site 300 to respond to various contingencies were incomplete and inconsistent;
- A written report of a leak from a retention tank containing oily wastewater was not filed with the EPA;
- An exception report was not filed for one manifest; the waste minimization plan was not submitted to regulatory agencies by December 27, 1989;
- Signs were needed to designate storage areas within the permitted storage area;
- A container of lead shot (D008) was observed in the permitted storage unit, although that waste stream is not identified in the permit;
- Land disposal restriction (LDR) notifications were not provided with three manifests;
- The appropriate treatment standard was not marked on one manifest;
- The proper EPA waste code was not shown on one waste container filled with Freon.
In response to these observations, LLNL made the necessary corrections and provided the EPA with documentation to support the corrections. The EPA sent LLNL a letter dated August 22, 1990, which stated that LLNL had addressed the violations and documented the facility's return to compliance with the regulations cited in the inspection report.
On August 8, DHS toured the two landfills being considered for closure pursuant to the Closure/Postclosure Plans originally submitted in 1988. This tour was an opportunity for DHS staff and management to become more familiar with the project and the proposed closure activities.
Staff from the EPA viewed the Environmental Restoration Division ground water investigation activities in the eastern General Services Area on November 14 as part of their general oversight of the CERCLA investigations.
Tank Inspections
On three occasions in 1990, San Joaquin County Public Health Services Staff visited LLNL Site 300 to witness soil sampling that was part of closure activities for three underground tank systems. On May 30, 1990, soil sampling was performed to complete closure of the already-removed underground diesel fuel tank system at Building 873. On June 27 soil sampling was performed coincident with the removal of the diesel fuel tank at Building 874, and on November 11 soil sampling was performed in conjunction with the removal of a small underground tank that received drainage from a drum storage area (since removed) at Building 875.
SNL, Livermore—Regulatory Inspections and Audits
Air Inspections
The Bay Area Air Quality Management District (BAAQMD) inspected SNL, Livermore air emissions sources on April 12, May 31, and August 31, 1990. A Notice of Violation (NOV) was issued to Sandia for three violations. These violations were administrative in nature (none involved exceeding allowable emissions) and included: failure to notify the Bay Area Air Quality Management District of an inactive landfill and onsite cooling towers, and operation of unpermitted sources. In response to the NOV, SNL, Livermore promptly notified the Bay Area Air Quality Management District of the inactive landfill and provided detailed information.
Since 1987 the landfill has been part of the California Solid Waste Water Quality Assessment Test (SWAT) Program. Because the site is being remediated through a California Regional Water Quality Control Board order, it was inadvertently unreported to the Bay Area Air Quality Management District. SNL responded promptly to the Bay Area Air Quality Management District on cooling towers in use and the treatment chemicals used onsite. In response to the issue of unpermitted sources, SNL initiated a sitewide air emissions inventory. This inventory evaluates and documents all equipment and materials usage to ensure compliance with air quality regulations. Applications and permit exemptions have been submitted.
Sewer Discharge Inspections
The Livermore Water Reclamation Plant inspected SNL, Livermore on three occasions in 1990. Livermore Water Reclamation Plant inspected the onsite sewer monitoring on July 16, 1990; the noncategorical waste process stream on July 17, 1990; and the onsite categorical sources (Electroplating Facility and Printed Wiring Facility) for compliance with federal pretreatment standards on February 26, 1990.
Hazardous Waste Inspections
The California Department of Health Services (now the Department of Toxic Substances Control) inspected the site on October 17, 1990. A Report of Violation alleging twelve violations of the Health and Safety Code was issued. The violations included inadequate labeling, improper signage, a missing contingency plan, lack of a permit for Bays 6 and 7 in Building 9622, storage of excess waste, failure to store waste in designated areas, aerosol cans without caps, and waste in open containers. SNL, Livermore has submitted a formal response to Department of Toxic Substances Control. DOE and SNL, Livermore are currently negotiating with Department of Toxic Substances Control to resolve these issues.
The Environmental Protection Agency (EPA) visited the site on March 8, 1990. They reviewed the waste analysis plan and the incinerator plan. The EPA issued a warning letter requiring revision and resubmission of the waste analysis plan and incinerator plan. SNL, Livermore revised and resubmitted these plans and has written subsequent plans since 1990.
On August 8, 1991, the California Department of Toxic Substances Control performed a waste management inspection at SNL, Livermore. A Report of Violation was issued. The violations included accumulation paperwork that was incorrect; two waste containers not closed; one waste container in poor condition; and silver recording paper improperly labelled. SNL, Livermore submitted a formal response in April 1992 to resolve these issues.
LLNL and SNL, Livermore—Summary of Inadvertent Releases
Table 4.18-6 summarizes inadvertent incidents that have occurred at LLNL from 1980 to April 1991; Table 4.18-7 summarizes inadvertent incidents that have occurred at SNL, Livermore from 1980 to July 1992. These tables represent a best effort to identify all incidents that may have had the potential to adversely affect the environment. The information in these tables has been obtained from the Unusual Occurrence Reports (LLNL, 1991t, 1992c; SNL, Livermore, 1991l, 1992c) that have been reported to DOE by LLNL and SNL, Livermore.
Table 4.18-1 Permits Held by LLNL Livermore Site and LLNL Site 300 During 1990
| Permits | Regulatory Agency |
| LLNL Livermore:
192 permits for air emissions and equipment operation |
BAAQMD |
| Waste Discharge Requirements Order No. 88-075 for discharge of treated ground water to ponds, and Permit No. 90-106 for discharge of treated ground water to storm drains | RWQCB |
| Hazardous Waste (Interim Status Document CA2890012584) | EPA, DTSC |
| Sewer Discharge Permit No. 1205A | LWRP, RWQCB |
| Permits for 65 storage tanks | ACHD |
| Federal Facility Agreement for Livermore ground water investigation/remediation | RWQCB, EPA, DTSC |
| LLNL Site 300:
Nine permits for air emissions and equipment operation |
SJCAPCD |
| Waste Discharge Requirements; Order No. 80-184 for Class II-1 solid waste landfills, Order 82-105 for cooling tower discharges, Order 85-188 for sanitary and industrial wastewater discharges to ponds and septic systems | RWQCB |
| Hazardous Waste, Part B Permit CA2890090002 for hazardous waste storage and Interim Status for open burning of high explosives | EPA, DTSC |
| Permits for 15 storage tanks | San Joaquin County |
ACHD = Alameda County Health Department.
BAAQMD = Bay Area Air Quality
Management District.
DTSC = Department of Toxic Substances Control.
EPA
= Environmental Protection Agency.
LWRP = Livermore Water Reclamation Plant.
SJCAPCD
= San Joaquin County Air Pollution Control District.
RWQCB = Regional Water
Quality Control Board.
Table 4.18-2 Permits Held by SNL, Livermore During 1990
| Permits | Regulatory Requirements and Implementing Agency | Category |
| BAAQMD permit for 16 air emission sources. Permits renewed annually. | BAAQMD | Air Q uality |
| EPA NESHAP permit for TRL low-level tritium evaporator. Trial run completed; permit approved. | 40 C.F.R. 61 (NESHAP), EPA | Air Quality |
| Permit for site sanitary and industrial wastewater discharge. Permit renewed annually. | City Ordinance, City of Livermore | Wastewater Discharge |
| 1983 RCRA Part B permit expired 12/88. Renewal filed 6/88, SNL is currently operating under interim status. | 40 C.F.R. 264 (RCRA), EPA
22 C.C.R. Chapter 30, DHS |
Waste Management |
| One underground storage tank registered; two underground storage tanks removed 12/20/89. | 23 C.C.R. 2611-2714 Cal. UST Reg., Alam. Co., DHS | Waste Management |
| Extremely Hazardous Waste Permits for
transporting hazardous waste offsite. Six were issued in 1990: 1/30/90—#2-12008,
2/15/90—#2-12076,
4/24/90—#2-12303, 4/24/90—#2-12304, 5/9/90—#2-12340, 7/23/90—#2-12580 |
22 C.C.R. 66570(b) DHS | Waste Management |
| Permit for Medical Waste | Alameda County Department of Environmental Health | |
| Incinerator Emergency Permit | EPA; Cal. EPA | Waste Management |
BAAQMD = Bay Area Air Quality Management District.
CFR = Code of Federal
Regulations.
DHS = California Department of Health Services.
EPA =
Environmental Protection Agency.
NESHAP = National Emission Standards for
Hazardous Air Pollutants.
TRL = Tritium Research Laboratory.
Table 4.18-3 Compliance Summary for 1990 and 1991-LLNL Livermore Site
| Audits/Inspections (date) | Regulatory Agency |
| Annual Inspection of permitted units (January 9, 11, 24, 1990) | BAAQMD |
| Inspection of B322* floor for approval of coating (January 1990) | ACHD |
| Waste Accumulation Area and Hazardous Waste Management inspection (February 26 and 28, 1990) | DHS |
| Inspect B322 plating shop (February 1990) | LWRP |
| Sampling of B322 plating shop discharge and total effluent at B196 (March 1990) | LWRP |
| Inspect specific discharges at B131, 196, 197, 253, 514, and 612 (April 30, 1990) | LWRP |
| Quarterly Pretreatment Sampling of Wastewater discharges (May 8, 9, and 18, 1990) | LWRP |
| Inspect newly permitted units (May 21, 1990) | BAAQMD |
| B321 asbestos removal (May 25, 1990) | BAAQMD |
| B391 LaNSA construction site (May 31, 1990) | LWRP |
| B272 refurbishment project, discussion of B196 and Facility A (June 14, 1990) | BAAQMD |
| B141 vapor degreasers, B166, T1786,* B383, and B391 cold cleaners (June 15, 1990) | BAAQMD |
| Permitted sources inspection of seven boilers, three vapor degreasers and one spray cleaner (June 28, 1990) | BAAQMD |
| Permitted sources inspection of two boilers, three cold cleaners and one solvent cleaner (June 29, 1990) | BAAQMD |
| B332 fuming box scrubber and B322 solvent cleaner (August 3, 1990) | BAAQMD |
| Permitted source inspection B224 milling machine, B175 solvent cleaner (August 9, 1990) | BAAQMD |
| Inspect and sample B131 and B253 for pretreatment program (August 15, 1990) | LWRP |
| Permitted sources, three solvent cleaners in B321 and various lathes (August 17, 1990) | BAAQMD |
| Review out-of-service sources (paperwork) and B511 degreasers (September 12, 1990) | BAAQMD |
| B418 paint spray booths, view Facility B for Permit to Operate (September 26, 1990) | BAAQMD |
| Inspect permitted air sources (October 3, 1990) | BAAQMD |
| Incinerator training records (October 4, 1990) | EPA |
| Inspect permitted air sources (October 10, 1990) | BAAQMD |
| Inspect Sources at B169B, 381, 611, and 691 (October 23, 1990) | BAAQMD |
| Inspect B418 paint shop sources and collect samples (November 5, 1990) | BAAQMD |
| Inspect and sample B321 water jet, inspect various processes at B406 and B691, tour sewer diversion facility (November 8, 1990) | LWRP |
| Inspect sources at B418, 432, 438, and 490 (November 16, 1990) | BAAQMD |
| Review underground tank records (November 20, 1990) | ACHD |
| Inspect B438 to verify compliance (November 30, 1990) | BAAQMD |
| Inspect B141 and B251 discharges (December 10, 1990) | LWRP |
| Compliance Evaluation Inspection of hazardous waste management facilities, selected generator operations, and temporary storage units (January 9-15, February 5, 1991) | DTSC |
| Inspect and sample processes at B197 and 511 (February 6, 1991) | LWRP |
| Inspect process and retention tank at B131 (March 1, 1991) | LWRP |
| Inspect and sample process and retention tank at B131 and 141 (April 25) | LWRP |
| B298 retention tank inspection (July 1991) | ACHD |
| Inspect B193, 196, 251, 253 (July 31, 1991) | LWRP |
| Inspect B321L, 322, and sampled process at B151 (September 10, 1991) | LWRP |
| Review of processes in B322, 253, 193, 196 (September 13, 1991) | LWRP, EPA, CWRB, SFRWQCB |
| Inspect and sample B321C and 251 (October 30, 1991) | LWRP |
| Inspect and sample B253 and 343 (November 18, 1991) | LWRP |
| Review start-up of new equipment; inspect operation of existing permitted equipment (20 days in 1991) | BAAQMD |
* B indicates building number, and T indicates trailer number.
ACHD = Alameda County Health Department.
BAAQMD = Bay Area Air Quality Management District.
CWRB = California Water Resources Board.
DHS = California Department of Health Services.
DTSC = California Department of Toxic Substances Control.
EPA = Environmental Protection Agency.
LWRP = Livermore Water Reclamation Plant.
SFRWQCB = San Francisco Regional Water Quality Control Board.
Table 4.18-4 Compliance Summary for 1990 and 1991-LLNL Site 300
| Audits/Inspections (date) | Regulatory Agency |
| S-300 RCRA inspection (March 21, 1990) | EPA |
| Annual Amsinckia grandiflora count (April 4, 1990) | USFW & CDFG |
| S-300 WDR 85-188 (April 5, 1990) | RWQCB-CV |
| Witness soil sampling at B874 former diesel tank location (May 30, 1990) | SJCPHS |
| Vapor recovery system (June 12, 1990) | SJCAPCD |
| Inspect tank closure at B874 (June 27, 1990) | SJCPHS |
| Familiarization tour for landfill closure at LLNL Site 300 (Aug 8, 1990) | DHS |
| View Pit 6 fault (End Sept., 1990) | California Mines & Geology |
| Water quality (Oct. 11, 1990) | RWQCB-CV |
| B875 tank closure (Nov. 5, 1990) | SJCPHS |
| View eastern GSA cleanup (Nov. 14, 1990) | EPA |
| Appraisal of overall tank program (Nov. 13-30, 1990) | DOE |
| Underground fuel tanks inspection (March 26 and April 11, 1991) | SJCPHS |
| Inspection of RCRA-regulated units (May 28, 1991) | EPA |
| Inspections of air sources (3 days in 1991) | SJCAPCD |
CDFG = California Department of Fish and Game.
DHS = California Department of Health Services.
EPA = Environmental Protection Agency.
RWQCB-CV = Regional Water Quality Control Board—Central Valley Region.
SJCAPCD = San Joaquin County Air Pollution Control District.
SJCPHS = San Joaquin County Public Health Services.
USFW = United States Fish and Wildlife Service.
Table 4.18-5 Compliance Summary for 1990 and 1991-SNL, Livermore
| Audits/Inspections (date) | Regulatory Agency |
| Federal wastewater pretreatment inspection (February 26, 1990) | LWRP |
| EPA inspection (March 8, 1990) | EPA |
| Permitted air discharge sources (April 12 and May 31, 1990) | BAAQMD |
| DHS inspection (June 20 and 22, 1990) | DHS |
| Process wastewater discharge inspection (July 16–17, 1990) | LWRP |
| Permitted air discharge sources (August 31, 1990) | BAAQMD |
| Process wastewater inspection (December 13, 1990) | LWRP |
| Process wastewater discharge inspection (January 30, 1991) | LWRP |
| Federal pretreatment compliance inspection (May 24, 1991) | LWRP |
| Air discharge sources (July 18, 1991) | BAAQMD |
| Process wastewater discharge inspection (September 4, 1991) | LWRP |
BAAQMD = Bay Area Air Quality Management District.
DHS = California
Department of Health Services.
EPA = Environmental Protection Agency.
LWRP
= Livermore Water Reclamation Plant.
Table 4.18-6 LLNL Inadvertent Events with the Potential for Environmental Impacts
| Date | Material Released | Description of Event | Consequences and/or Actions Taken* |
| 4/8/80 | Plutonium | Glovebox burst contaminating the laboratory and releasing 2.6×10-7 Ci of plutonium to the environment. | No worker exposures, no offsite consequences. |
| 4/16/80 | Plutonium | Fire-generated pressure caused leaky glovebox. Plutonium escaped into a room in Building 332. | No worker exposures, no offsite consequences. |
| Before 1982 | Actinium-227 and curium-244 | Actinium-227 and curium-244 leaked or were spilled onto asphalt. | The contaminated asphalt was removed and disposed of as radioactive waste. |
| Before 1982 | Tritium and organic solvents | Sampling in an area of a Taxi Strip Area, which was used between 1955 and 1976 as a disposal site, revealed soils contaminated with tritium, trichlorethylene, tetrachloroethylene, and chloroform. | The affected soils were removed in 1984 and disposed of as radioactive waste. |
| 1983 | Curium-244 | 0.002 Ci of curium-244 was accidentally spilled onto the soil. | The spill did not impact the environment. The material was completely recovered and was properly disposed of. |
| 6/8/84 | Tritium | Human error resulted in the release of 5000 Ci of tritium to the environment. | No offsite consequences, no action required. |
| Before 7/19/84 | Metals, PCBs, and radioactive materials | An abandoned landfill was discovered near the east LLNL Livermore site boundary. Soil sample analysis revealed contamination from lead, zinc, copper, cadmium, PCBs, and low-level radioactive contamination including cesium-137, radium-226, uranium-238, thorium-232, and americium-241. | The contaminated soils were excavated and disposed of at approved waste disposal sites. |
| 1985 | Petroleum products | During testing of 60 tank systems, leaks were discovered in the piping systems of 9 tanks. | The piping systems were either repaired and retested, or decommissioned. Contaminated material was removed and properly disposed of. |
| 1/25/85 | Tritium | Human error resulted in the release of 1000 Ci of tritium from Building 331. | No worker exposures, no offsite consequences. |
| 9/86 | Chromium and nickel | 50 lb of chromium and nickel were accidentally released to the sewer. | The wastewater was diverted into a Livermore Water Reclamation Plant holding pond which prevented it from contaminating the sewage treatment process. |
| 4/15/87 | Unknown milky-white substance | Inadvertent release into the storm drain lines. | Approximately 2000 gal of the material, which is believed to be paint residues from paint cleaning equipment, were collected and disposed of as hazardous waste. |
| 8/18/87 | Tritium | Human error during tritium unloading operation resulted in the release of 110 Ci of tritium into the laboratory and exhausted to the environment. | The worker received a radiation dose equivalent of 0.015 rem. A person at the site boundary would have received a radiation dose equivalent of 1×10-7 rem. |
| 10/7/87 | Mixed waste | A mixed waste spill occurred as a result of human error. | Approximately 100 gal of waste (pH 1.1), containing 250 ppm of depleted uranium and 1600 ppm of volatile halogenated solvents, spilled as a result of a partially open valve. The spill was remediated and the contaminated materials were shipped to a licensed disposal facility. |
| 10/19/87 | Hazardous waste | Less than 5 gal of hazardous wastewater containing chromium and other constituents were released to the storage drain when a tank overflowed during a steam-cleaning operation. | No sewer discharge limits were exceeded. |
| 4/25/88 | Acidic uranium solution | Approximately 500 mL of liquid (pH 2.0) containing 3.9×10-4 Ci/mL of uranium and nine other materials were spilled due to human error. | The spill was remediated. |
| 4/26/88 | Mixed acids | Roughly 0.5 gal of mixed acids were released due to an eruptive reaction that occurred during a Bulking Operation. | The spill was neutralized and recovered for proper disposal. Five workers were treated for minor injuries caused by exposure to the vapor plume. |
| 4/26/88 | Mixed acids | Roughly 1 to 3 gal of mixed acids were released due to an eruptive reaction that occurred during a bulking operation. | The spill was neutralized and recovered for proper disposal. As a result of exposure to the vapor plume, 41 workers received medical attention. |
| 5/10/88 | Plutonium | During a microscope disassembly operation a worker inhaled approximately 5×10-10 Ci of plutonium. The worker did not know that the microscope was contaminated. | The worker received an effective dose equivalent of 0.1 rem. The minor surface contamination resulting from the incident was cleaned up. |
| 6/13/88 | Waste oil mixture | Leaking 55-gal drum. | The spill was cleaned up and the recovered materials properly disposed of as hazardous waste. The spill did not impact the environment. |
| 7/1/88 | Dielectric fluids | Equipment failure resulted in a fire involving less than 2 gal of dielectric fluid (less than 1 ppm PCB), and approximately 105 gal of dielectric fluid. | The fire was extinguished and the area was properly cleaned up. The incident did not impact the environment. |
| 7/25/88 | Convoil-20 | Less than 5 gal of 100 percent Convoil-20 (petroleum distillate pump oil) leaked from a 55-gal drum. | The spill was cleaned up and the recovered materials properly disposed of as hazardous waste. |
| 8/24/88 | Reagent=grade phenol | Approximately 1.5 gal of 98 percent reagent-grade phenol leaked from a 55-gal drum as a result of human error. | The spill was cleaned up and the recovered materials properly disposed of as hazardous waste. Air monitoring indicated that air concentrations did not exceed the TLV level. |
| 8/26/88 | Methyl alcohol and tritium | Approximately 1 gal of 20 percent methyl alcohol and 8×10-9 Ci of tritium escaped from a leaking 55-gal drum. | All spilled materials were recovered. Swipe testing indicated that the area had been properly decontaminated. No soil or water was impacted. |
| 8/29/88 | Mixed waste | From 5 to 10 gal of liquid waste containing low levels of metals (Cr[III] 9.0 ppm, Be 45 ppm), and radioactivity (alpha 3.8×10-10 Ci/mL, beta 3.9×10-10 Ci/mL, tritium 1.3×10-7 Ci/mL) spilled from a leaking tank during a pipe transfer operation. | The material was cleaned up and disposed of as mixed waste. No soil or water was impacted. |
| 9/20/88 | Low-level radioactive waste | Approximately 30 gal of low-level, liquid radioactive waste escaped through a defective seal during a pipe transfer operation. | Approximately 10 gal of the spilled material was recovered; the remainder was lost through evaporation. Swipe testing indicated no residual traces of radioactive contamination. |
| 9/22/88 | Chemical carcinogen | Roughly 1 gal of 1 percent PCC-1 list waste (chemical carcinogens) in a saline solution leaked from a defective 55-gal drum. | The spill was cleaned up and the area decontaminated. The spill did not impact the environment. |
| 9/28/88 | Chromium and sodium dichromate | Approximately 20 gal of 50 percent Kodak sodium dichromate bleach solution containing 1.75 lb of chromium were spilled during a tank transfer operation. | The material was recovered. All contaminated soil was recovered, and removed, and the affected surfaces were decontaminated. |
| 10/15/88 | Metals and volatile halogenated solvents | As a result of human error, 1 gallon of a retention tank wastewater solution containing copper (72 ppm), chromium (600 ppm), nickel (160 ppm), zinc (12.4 ppm), beryllium (0.4 ppm), and 450 ppm of volatile halogenated solvents was spilled. | The material was recovered and disposed of as hazardous waste. |
| 10/21/88 | Chromium and sodium dichromate | Less than 1 pint of waste Kodak sodium dichromate bleach solution containing 8749 mg/L of chromium leaked from a drain seal. | The material, except for a small portion of the liquid that was lost by evaporation, was recovered and disposed of as hazardous material. The spill did not impact the environment. |
| 11/11/88 | Uranium | An unspecified amount of uranium oxide was released into a laboratory as a result of human error. | The material was trapped in filters and no radioactivity was released to the environment. Contaminated personnel were decontaminated and examined by the Medical Department. |
| 12/5/88 | Methanol | Less than 10 gal of methanol leaked from a defective 55-gal drum. | Most of the material was lost to the environment due to evaporation. The remainder was cleaned up and disposed of as hazardous waste. The spill did not impact the environment. |
| 2/23/89 | Machining coolant | 10 gal of wastewater containing a small fraction of machining coolant evaporated into the environment as a result of an exothermic reaction in a waste drum. | The drum was removed to a covered area to allow the reaction to go to completion. |
| 4/13/89 | Photographic waste material | Less than 1 pint of photographic waste material was spilled as a result of human error. | The contaminated cleanup materials, rocks, and soils were removed and treated as hazardous waste. Sampling was conducted to confirm that the cleanup was complete. Surface water and ground water were not impacted. |
| 4/18/89 | Diesel fuel | From 20 to 30 gal of diesel fuel were spilled as a result of human error. | All of the material was recovered. The contaminated cleanup materials and soil were disposed of as hazardous waste. The incident did not impact surface water or ground water. |
| 7/17/89 | Insulating oil and Freon 113 | Roughly 2000 gal of wastewater contaminated with insulating oil (2500 ppm) and Freon 113 were released to the surrounding gravel as a result of human error. | The incident was reported to the Regional Water Quality Control Board. |
| 7/28/89 | Sulfamic acid and potassium dichromate | Approximately 16 gal of microfilm bleach solution (a mixture of sulfamic acid and potassium dichromate in an aqueous solution) spilled onto a laboratory floor as a result of a pump failure. | The spilled material was recovered and placed in storage drums. No material was released to the environment. |
| 8/9/89 | Gasoline | Approximately 5 gal of gasoline spilled from a ruptured automobile gasoline tank. | Three gal of the material were recovered. Materials used in the cleanup were disposed of as hazardous waste. The spill did not contaminate the soil or ground water. |
| 8/25/89 | Tritium | Due to human error, 297 Ci of tritium was released to the environment. Based on stack monitoring information, this release consisted of 7 Ci of tritiated water vapor and 290 Ci of tritium gas. | The estimated radiation dose equivalent at the fenceline was conservatively estimated to be 0.0007 mrem. |
| 9/8/89 | Chromium and lead | As a result of human error, 75 to 100 gal of paint booth wastewater containing lead (40 ppm) and chromium (8 ppm) were spilled onto the floor. | Five gal of the material were lost to the sewer, 10 to 20 gal were recovered, and the balance evaporated into the environment. The contaminated soil was removed and disposed of as hazardous waste. Samples were taken to determine if further remedial action was required. |
| 11/15/89 | Chlorinated fluorocarbons | Approximately 3 gal of chlorinated fluorocarbons spilled from a leaky 55-gal drum. | The affected areas were cleaned up and the wastes from the cleaning operation were appropriately handled. A survey of the area indicated that no radioactive materials were involved in the spill. |
| 1/17/90 | Trimethylamine | Approximately 0.375 lb was spilled from a leaking cylinder. | No material was recovered. The cylinder was moved from its original location to a fume hood. |
| 1/18/90 | Methyl ethyl ketone | Approximately 50 lb were spilled due to a drum puncture at Building 612. | Approximately 1 gal of the estimated 6 gal was recovered by absorption into clay absorbents applied to the spill. Material not absorbed evaporated to the atmosphere. |
| 2/9/90 | High explosives and photo process rinsewater | Leak in liner of LLNL Site 300 surface impoundment pond. | 100 percent of the material that leaked through the primary liner was intercepted by the leachate collection system and returned to the overflow pond. |
| 3/2/90 | Various paint- related products and other containers | Suspect midnight dump or abandonment comprising of 55 containers. | All containers were intact and there was no evidence of leakage. There was no release to the environment (i.e., air, water, or land). |
| 8/23/90 | Battery acid (sulfuric acid) | 0.57 gal were spilled when two batteries were knocked off the top of a pallet onto the asphalt. | 100 percent of the material was recovered by using a baking soda and water mixture to neutralize the acid and an absorbent to collect the liquid. |
| 12/12/90 | Battery electrolyte solution containing lead | 3.9 gal were spilled onto other batteries, shelf, and floor of building due a puncture of one battery. | 100 percent of the material was recovered by using a neutralizing agent/absorbent onto the spilled electrolyte solution. |
| 12/26/90 | Washdown water containing oil (DTE) and Freon 113 | Approximately 25 gal were spilled when a copper pipe slipped out of a rubber gasket. | Visibly contaminated soil was excavated and soil samples will be taken to confirm cleanup. |
| 2/5/91 | High explosives process water | Approximately 500 gal were released due to a crack in the pump. | No materials were recovered. A valve was installed between the tank and the pump so that the tank can be isolated from the pump in the future. |
| 4/2/91 | Tritium | An estimated 144 Ci of tritium were released into the laboratory when a valve failed. | The worker received an effective dose equivalent of 1.1 rem. The potential radiation dose at the fenceline was estimated to be less than 1×10-5 rem. |
* Information excerpted from previous reports; no new analyses were prepared for this EIS/EIR.
Table 4.18-7 SNL, Livermore Inadvertent Events with the Potential for Environmental Impacts
| Datea | Material Released | Description of Event | Consequences and/or Actions Taken |
| 7/20/84 | Tritium | Certified, high-pressure gas, stainless-steel nipple failed as a result of a crack during a disassembly operation. This resulted in the release of 2.5 Ci of tritiated water into the laboratory. | One worker received a radiation dose equivalent to 1.65 rem, another received 0.145 rem, and five others received less than 0.045 rem. No offsite consequences. Facilities and procedures for an array of experiments were reviewed and upgraded. |
| 9/4/84 and 9/28/84 | Nickel sulfamate | Tank overflow resulted in the release of nickel sulfamate into the site sanitary sewer system. | The affected sewer was diverted into a holding pond, thus preventing upset of the sewage treatment plant. |
| 1/10/86 | Tritium | 40 ml of contaminated water containing 200 Ci of tritium were inadvertently released from a leak in a storage container caused by corrosion. | No worker exposure. No offsite consequences. Enclosure of regeneration water recovery operation in glovebox was performed. |
| 2/13/87 | Tritium | 3000-Ci glovebox release. | No worker exposure. No offsite consequences. Reviewed experimental design and changed procedure for packing disks for future experiments. No corrective action required. The tritium was removed by the gas purification system already in operation. |
| 8/18/87 | Tritium | 1110 Ci of tritium were inadvertently released as result of human error, during disassembly of a charging vessel. | The tritium was released to the environment. The worker received an effective dose equivalent to 0.015 rem. The potential effective dose equivalent at the site boundary was calculated to be 0.001 rem. Training and safety procedures were reviewed with staff. |
| 10/6/88 | Tritium | 124 Ci of tritium were inadvertently released to the environment due to an error in the drier regenerations program. | No worker exposure. No offsite consequences. Drier regeneration procedures and time between regeneration. |
| 2/6/89 | Tritium | Several hundred gal of wastewater, containing 18 Ci of tritium, were released as a result of an equipment failure. | The released wastewater was collected in a wastewater holding tank. No environmental release occurred. Equipment design was reevaluated to consider extreme weather conditions. |
| 3/6/89 | Tritium | 11.5 Ci of tritium were inadvertently released during maintenance activities. | No offsite consequences. Maintenance personnel are being trained on procedures for pump maintenance. |
| 4/15-21/91 | Cyanide | Sanitary sewer effluent exceeded allowable discharge for cyanide. Measured concentration 0.05 mg/L | LWRPb notified. Re-analysis of sample by contract laboratory was requested and done. No impact to employees, the public or operations at LWRP, or the environment. |
| 5/13-19/91 | Copper and zinc | Exceedence of wastewater discharge limit for copper and zinc: 4.5 mg/l (limit is 3.0 mg/l). Normal reading is <1.0 mg/l. | LWRP notified. Re-analysis requested and done. All sources of zinc checked. Bulletin to employees re-iterating wastewater discharge limits and policy. |
| 5/28/92 | Tritium | 4 Ci released by gasket leak in Tritium Research Laboratory. | Investigation being conducted. |
| 6/1/92 | Tritium | 36 Ci released through Tritium Research Laboratory stack failure after failure of a pressure regulator. | Investigation being conducted. |
a There were no inadvertent events
reported in 1982, 1983, 1985, and 1990
b LWRP = Livermore Water Reclamation
Plant
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