Committee to Minimize Toxic Waste

The National Tritium Labeling Facility (NTLF) was located on the eastern edge ofthe Lawrence Berkeley National Laboratory (LBNL) in Building 75. Just to thenorth of the NTLF is the Lawrence Hall of Science, a popular children's sciencemuseum that is visited by thousands of children every year (Figure 1). TheNTLF was established in 1982 as a National User Facility for the labeling ofcompounds used in pharmaceutical and biological research. The tritiation of these compounds involved an inefficient exchange process that required the useof large quantities of tritium (the radioactive form of hydrogen), i.e., 100+ curiesof tritium per tritiation and therefore thousands of curies per year. Commercialtritium facilities can not produce tritiated compounds in this way becauseFederal Regulations limit them to a total inventory of only 150 curies of tritium. Department of Energy Facilities, in contrast, can have much larger inventories. The NTLF's inventory limit, for example, was 15,000 curies.

The amount of tritium shipped out of the NTLF in tritiated compounds was avery small fraction of the total tritium used. The balance of the tritium went outeither as waste or was emitted via the facility's two stacks. Tritium emissionsfrom the NTLF's main stack were monitored on a weekly basis with a silica gelsampler and in real-time with an Overhoff system. The silica gel data were used The National Tritium Labeling Facility (NTLF) was located on the eastern edge ofthe Lawrence Berkeley National Laboratory (LBNL) in Building 75. Just to thenorth of the NTLF is the Lawrence Hall of Science, a popular children's sciencemuseum that is visited by thousands of children every year (Figure 1). TheNTLF was established in 1982 as a National User Facility for the labeling ofcompounds used in pharmaceutical and biological research. The tritiation of these compounds involved an inefficient exchange process that required the useof large quantities of tritium (the radioactive form of hydrogen), i.e., 100+ curiesof tritium per tritiation and therefore thousands of curies per year. Commercialtritium facilities can not produce tritiated compounds in this way becauseFederal Regulations limit them to a total inventory of only 150 curies of tritium. Department of Energy Facilities, in contrast, can have much larger inventories. The NTLF's inventory limit, for example, was 15,000 curies.

The amount of tritium shipped out of the NTLF in tritiated compounds was avery small fraction of the total tritium used. The balance of the tritium went outeither as waste or was emitted via the facility's two stacks. Tritium emissionsfrom the NTLF's main stack were monitored on a weekly basis with a silica gelsampler and in real-time with an Overhoff system. The silica gel data were used 2

to estimate the annual dose to the public to ensure compliance with NationalEmissions Standards for Hazardous Air Pollutants (NESHAPs) requirements. Dose estimates were modeled with CAP88, a computer program approved bythe US Environmental Protection Agency (US EPA).

The public first became aware that tritium was being released into theenvironment by the NTLF in the early 1990's. However, at that time very littlewas known about the nature of the problem. In 1996 community concernsregarding the NTLF began to escalate when Dr. Leticia Menchaca, an LBNLresearcher who had been investigating tritium in the area close to the NTLF,reported that the levels were higher than had been previously reported. Community concern was further increased when Susan Monheit, another LBNLemployee, produced a master's thesis which showed that the levels of tritium inplants, soils, and rain near the NTLF stack were unexpectedly high. She alsoreported above background tritium activity in rainfall samples collected 3.8kilometers from the stack. In the same year, some community membersindependently collected water samples from Eucalyptus trees between the NTLFstack and the Lawrence Hall of Science and also found that tritium activity levelswere unexpectedly high. In addition, Dr. Menchaca analyzed the organicallybound tritium activity in Eucalyptus leaves collected in the area around theNTLF stack and again found very high levels, especially in the area between thestack and the Lawrence Hall of Science. Shortly afterwards both Dr. Menchacaand Ms. Monheit were laid off at LBNL.

Another cause for community concern was the publication of a paper by Dr. ToreStraume (1995) in which he pointed out that there is an inverse relationshipbetween the energy level of radiation and its biological effectiveness. He alsostated that the biological effects of tritium beta rays were likely to besubstantially larger, i.e. 4 to 5 times larger, than previously thought.

In September of 2001 the National Institutes of Health announced that theywould discontinue funding the National Tritium Labeling Facility (NTLF). Shortly afterwards Lawrence Berkeley National Laboratory (LBNL) announcedthe Facility would be closed by the end of December 2001 and that the process ofdecommissioning and clean up would begin afterwards. However, the NTLFremained operational through mid-June 2002, while the oxidation of tritiatedmixed waste continued. The decision to close the NTLF at LBNL was welcomedby community members who had been concerned about tritium emissions sincethe early 1990’s. In fact in 1998 the US Environmental Protection Agency (USEPA) performed a Superfund reassessment of LBNL concluding that “Basedupon a preliminary Hazard Ranking System score, US EPA has determined thatLBNL is eligible for the National Superfund Priorities List” for cleanup, due totritium in air, soil, groundwater, and surface water.

In June of 2005 a National Academy of Sciences panel, formally known as theCommittee on Biological Effects of Ionizing Radiation (BEIR), concluded thatthere is no exposure level found below which dosage of radiation is harmless.The preponderance of scientific evidence shows that even very low doses ofradiation pose a risk of cancer or other health problems. The National Academyof Sciences panel is viewed as critical because it addresses radiation amountscommonly used in medical treatment and is likely to also influence the radiationlevels that the government will allow at abandoned and other nuclear sites.

Report Organization

The research effort reported on here has three primary objectives: 1) to monitortritium activity levels in rainfall near the Lawrence Hall of Science, and creeksdraining the watersheds close to the NTLF stack; 2) to date wood samples fromEucalyptus trees growing between the NTLF stack and the Lawrence Hall ofScience; and, 3) to determine the organically bound tritium content of the datedsamples as a means of reconstructing tritium emissions from the NTLF Stack. These three objectives are covered in Part A, Part B, and Part C of this report.

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