Comments for LANL Hazardous Waste Permit due September 4
August 28, 2009
Public comments about the New Mexico Environment Department (NMED) revised draft hazardous waste permit for on-going operations at Los Alamos National Laboratory (LANL) are due by September 4, 2009. The revised draft of the 10-year permit may allow LANL to handle one-quarter million pounds of hazardous waste annually, including 12,500 pounds of high explosive waste to be burned in the open air. The original permit expired in 1999 and has been administratively extended every year for the past 10 years. Thus, it has been 20 years since there has been an opportunity to provide public comments about concerns for the generation, treatment and storage of hazardous waste at LANL. The revised draft permit can be viewed at the NMED website at www.nmenv.state.nm.us/HWB/lanlperm.html#LANLRevised7_6_2009.
Following the release of the draft permit in 2007, several non-governmental organizations, including CCNS and the Embudo Valley Environmental Monitoring Group, wrote extensive comments to NMED and requested a public hearing. The New Mexico Hazardous Waste Management Regulations allow for the parties to come together in an attempt to resolve their concerns, which resulted in 40 days of negotiations with NMED, LANL and the non-governmental organizations.
An on-going concern has been the lack of information about compliance with the 2005 Consent Order between NMED and LANL. The Consent Order requires the clean up of the "legacy," or buried, waste. There are 25 legacy dumps at LANL that contain dangerous mixtures of chemicals and radioactive waste. One example is "Area G." These areas also contain operations that will be part of the new permit. The importance of understanding the relationship between the permit and Consent Order is so that none of the waste slips through any regulatory loopholes.
One of the goals of the non-governmental organizations has been to ensure that public participation is an integral part of the regulatory processes. LANL has been lax in fulfilling public participation requirements for the Consent Order, such as providing documents in a timely manner and holding public meetings. The Environmental Protection Agency has specific public participation requirements for legacy dump cleanups where the contact must be early, often, meaningful and continuous. Contact about cleanup of these dumps will keep the public informed and encourage involvement.
Nevertheless, the permit allows for the burning of hazardous waste, which releases 100% of the poisons into the air we breathe. In 2004, NMED stopped the open burning of household trash because of toxic emissions. In 2006, LANL withdrew their applications for air quality permits allowing for open burning at one of the two sites under the draft permit. CCNS and the Embudo Valley Environmental Monitoring Group have opposed the open burning practices for years and with colleagues are circulating a petition calling for LANL to adopt alternatives to open burning.
Your participation will make a difference. Comments are due by September 4, 2009. For more information and a comment letter, please visit www.nuclearactive.org/RCRA_Permit/LANL_RCRApermitA2.html