Los Alamos National Lab Hazardous Waste Permit
Exhibits of Interest: 2 versions of the geologic cross section under TA54
On the Last Leg Towards a New Haz Waste Permit at LANL
After numerous meetings with people and groups, including Nuclear Watch, who requested a public hearing on the original draft permit, the New Mexico Environment Department (NMED) has released a revised draft hazardous waste facility Permit for Los Alamos National Laboratory (LANL) that governs the lab’s operation and closure of 26 hazardous waste management units at the facility. This revised draft Permit is the result of nearly a year of addressing comments received on the original draft permit issued on August 27, 2007 and is open for public comment one last time.
The earlier 1989 Permit was due to expire in November 1999 but has been administratively extended until now. It is anticipated that the final Permit will be issued in 2010 and will govern hazardous waste operations at the permitted units until 2020.
Waste 101 - a quick primer on waste at the Lab
LANL generates hazardous and radioactive wastes from its general operations, nuclear weapons research and development activities, environmental restoration activities, and decontamination and decommissioning projects. Hazardous wastes that contain a radioactive component are referred to as “mixed waste.” The Permit ensures the current and future safe handling and treatment of newly generated hazardous and mixed wastes at the facility, because NMED only has authority these types of wastes. The March 1, 2005 Consent Order directs the ongoing environmental cleanup of legacy pollution sites, and the Permit governs required cleanup activities after the Order terminates in 2015. The U.S. Department of Energy, the owner of LANL, has authority over radioactive waste and continues its disposal in one of those unlined landfills, which is known as Area G.
The Permit is not for hazardous waste disposal – only for treatment and storage. The Permit requires that these wastes be removed from the facility within one year. (Certain wastes with no disposal path are allowed to stay longer.) However, hazardous and mixed wastes were disposed of in the past at Material Disposal Areas (MDAs) G, H, and L at TA-54. The draft Permit addresses the closure and potential post-closure care of these units.
Public Participation is a Winner in the Permit
The revised draft Permit requires LANL to issue e-mail notices to the public when the Lab submits specific documents to NMED. Interested persons will be able to add their e-mail address to a list maintained by LANL. This is a step forward with respect to transparency at the Lab and Nuke Watch appreciates the Lab’s interest in making this happen. The revised draft Permit requires LANL to establish a community relations plan, whose goal is to foster community understanding and involvement in its environmental programs. The revised draft Permit also requires LANL to establish an “information repository,” where Permit-related documents, including the Permit, may be viewed.
Seismic Issues are Addressed, but Only for 3 new facilities
Regulations prohibit location of a new hazardous waste facility closer than 200 feet to a fault that has had displacement in Holocene time (within the last 10,000 years). But the regulations apply only to a “new facility” and are not to currently permitted units. Based on a new LANL seismic report and an examination of the geologic strata at the sites that included a field visit, NMED determined that LANL has sufficiently demonstrated that earthquake hazards are not a significant threat at the three new permitted units. Unfortunately, the remaining 23 units are grandfathered in.
Financial Assurance for the Final Cleanup
There is an expectation that LANS will provide financial assurance for closure and post-closure, and cost estimates were prepared that totaled over $24 million for the permitted units. The regulations requiring financial assurance for closure and post-closure costs specifically exempt facilities owned and operated by State or Federal government agencies. However, since a private operator under contract with DOE operates LANL, it must comply with financial assurance requirements. This is important because DOE has not demonstrated a continuing commitment to its environmental cleanup obligations at LANL, and financial assurance is necessary to ensure compliance.
Nuclear Watch has Worked to Improve the LANL Permit, Now it’s Your Turn
NMED has issued a fact sheet to facilitate public review of that draft permit.
The department invites the public to submit written comments on the revised draft permit during a 60-day public comment period that ends at 5 p.m. MDT, September 4, 2009. After considering all written comments received from the public, and after a public hearing (if one is requested), the department will issue a final permit.Procedures for submitting written comments, requests for a public hearing, and a copy of the revised draft Permit are also available at the Department’s Web site under Revised Draft Permit (July 6, 2009).
Searchable, single pdf of the draft permit [33MB] - July 6, 2009
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