Aanenson, J.W., H.J. Mohler, P.G. Voillequé, S.J. Maheras, A.S. Rood, H.A. Grogan, and J.E. Till. 2000.

Independent Technical Audit of Los Alamos National Laboratory for Compliance with the Clean Air Act, 40 CFR 61, Subpart H, in 1999.
RAC Report No.4-DOJ-LANL Audit-2000-FINAL.


This report documents results of the second independent audit of Los Alamos National Laboratory regarding compliance with the Clean Air Act, 40 CFR 61, Subpart H for the year 1999. It is concluded that Los Alamos National Laboratory was in compliance with 40 CFR 61, Subpart H for the year 1999. The offsite dose limit under the Clean Air Act regulation is 10 mrem per year, and Los Alamos National Laboratory reported a dose for 1999 of 0.32 mrem. This dose was confirmed by independent audit team calculations.

This audit was conducted by an audit team led by Dr. John E. Till and other members of the Risk Assessment Corporation research team as part of a settlement agreement and Consent Decree that resolved a lawsuit filed by Concerned Citizens for Nuclear Safety against the U.S. Department of Energy and Siegfried S. Hecker, a former Laboratory Director. A separate independent group, the Institute for Energy and Environmental Research, monitored the audit for completeness, quality, and thoroughness on behalf of Concerned Citizens for Nuclear Safety.

The audit team divided its work into four distinct areas that address the major elements of the compliance program. These areas were:

The radionuclide survey and associated emission data for unmonitored sources

  • The radionuclide survey and associated emission data for unmonitored sources

  • Effluent monitoring of major release points to air

  • Environmental compliance for non-point sources

  • Dose calculations

A number of general issues, in addition to specific regulatory requirements, were evaluated for each area, including traceability of data to their original source, documentation supporting compliance, technical competence, quality assurance, and overall confidence of the audit team in the compliance program. Thus the audit encompassed a scope much broader than a typical evaluation for regulatory compliance.

The audit team noted some aspects of the compliance program that could be improved and made a number of recommendations to this end. Examples include increasing automation for compilation of radionuclide usage and calculation of associated emission estimates, improving the quantitative criteria by which environmental samplers are located, revising the methodology by which some specific radionuclide usage and emission estimates are made, and producing a technical summary to accompany the dose assessment annual report.

The public's role in the audit process was critical. The positive interaction between the audit team, Los Alamos National Laboratory, the Institute for Energy and Environmental Research, Concerned Citizens for Nuclear Safety, and other participants confirmed that members of the public can and should play an important role where regulations related to public exposures are concerned.

The audit team commends the Laboratory for addressing the findings of the first audit and also for the concerted effort they have put forth during this audit to make it an open, thorough, and responsive process. Credit for this achievement is also due to Concerned Citizens for Nuclear Safety, who, as a citizens' organization, helped initiate the audit and design its format.

It is noteworthy that this audit was conducted under unusually difficult circumstances created by the Cerro Grande Fire that occurred in May of 2000 and critical issues with regard to security at the Los Alamos National Laboratory throughout this year. The audit's success is a direct reflection of the professionalism and dedication to this process by all involved parties.

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