CCNS work to hold LANL accountable for reported detections (pdf) March 20, 2007

NMED 4.5.07 Orders to LANL April 7, 2007

CCNS Comments to the draft LANL SWEIS


National Academy of Sciences

Unbiased Report Necessary

The National Academies of Science (NAS) was requested by the Department of Energy (DOE) to perform a review of the groundwater protection program at LANL. Their statement of purpose is:

After an 18-month study, the NAS released a prepublication copy of the report titled the "Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory" on June 8, 2007, to which CCNS and Robert H. Gilkeson, Registered Geologist, have reviewed and provided extensive technical comments, which are available below.

We also found the review to be biased in favor of LANL. Throughout the report LANL was afforded undeserved praise in the language of the report. A clear cut example is the statement that the NAS committee was Ònot hesitant to take LANL's motto: 'The World's Best Science Protecting America' at face value." NAS prepublication copy, p. 3, 103. The purpose of this review is to determine the quality of the science LANL has employed in its ground water protection program, a task which cannot be accomplished if LANL's motto is accepted "at face value" by the committee. This statement was made in the context of requesting that LANL have its documents peer reviewed, a practice which is "the standard of science." p. 103. When our drinking water supplies are at stake, we are concerned about the committee's hesitance to question LANL on this basic scientific issue. We believe that the committee's action of taking LANL's motto on face value is indicative of a general bias in support of LANL and impacts the credibility of the review.

In addition, the review was riddled with errors, discrepancies and inconsistencies, despite the fact that it had been peer reviews by a board of scientists. The prepublication of the report is still a draft, and in need of significant edits. The issues with the report ranged from typos to contradictions between the overarching findings and the specific findings. As a symbolic example, when stating the committee's trust in LANL's science, the report misquotes LANL's motto, which is actually "The World's Greatest Science Protecting America."

In order to address and call the NAS attention to significant scientific issues with the report, CCNS and Gilkeson performed a public peer review of the prepublication copy. However, no official public comment period was provided for public input.

Click here for our cover letter to Kevin Crowley and John Wiley of the National Academy of Sciences. Attachments to the letter are available in pdf form below. Please see the side bar for additional materials.

Attachments
The following are provided to describe the variety of issues we found during the public peer review.

  • Attachment 1. Introduction Ð A Brief History.

  • Attachment 2. An Important Finding of the NAS Committee is that LANL/DOE have Failed to Install a Reliable Network of Monitoring Wells in the Regional Aquifer.

  • Attachment 3. The NAS Prepublication Copy Misrepresents Casing Advance Drilling.

  • Attachment 4.The NAS Committee Approval of the LANL Interim Groundwater Monitoring Plan is a Mistake that Must Be Corrected in the NAS Final Report.

  • Attachment 5. The NAS Committee Approval of the LANL Scheme for Monitoring and Data Quality is a Mistake that Must Be Corrected in the NAS final report.

  • Attachment 6. The Impracticable Rehabilitation of the LANL Characterization Wells.

  • Attachment 7. The NAS Prepublication Copy Misrepresents the LANL Knowledge of Background Groundwater Chemistry.

  • Attachment 8. The Misinformation about Regulatory Requirements in the NAS Report Prepublication Copy.

  • Attachment 9. The Presentation of Spurious Groundwater Contaminant Data in the NAS Report.

  • Attachment 10. Public Comment is Necessary for the LANL Plans and Reports and for the NAS Final Report.

  • Attachment 11. Other General and Specific Comments.

    July 12, 2007



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