Comments Needed for LANL Industrial Wastewater Discharge Permit
Why is Los Alamos National Laboratory (LANL) asking the Environmental Protection Agency (EPA) to renew a discharge permit for facilities that stopped discharging treated industrial wastewater to the environment years ago? Maybe because having as many as five facilities covered by a Clean Water Act permit provides an exemption from complying with the more protective hazardous waste laws. These facilities handle, treat and store hazardous waste and should be regulated by the Resource Conservation and Recovery Act, or the federal hazardous waste laws. Public comments are due to EPA on Monday, November 2nd. https://www.epa.gov/nm/lanl-industrial-wastewater-permit-draft-permit-no-nm0028355-0 A sample public comment to EPA that you can use to is available here – EPA comment for LANL industrial discharges 10-29-20 . 
Every five years or so, the EPA begins a process to renew the LANL permit to allow it to discharge industrial wastewater from pipes, or outfalls, into the environment from 11 facilities. The Clean Water Act jurisdiction covers the intentional discharge of pollutants from an outfall. It does not address accidental leaks of hazardous liquid wastewater or regulate the construction of treatment and storage facilities as required by the hazardous waste laws. Up to five facilities that handle hazardous waste remain on the permit even though they no longer have discharges.
One such facility is the Radioactive Liquid Waste Treatment Facility. This key facility, located across the street from the Plutonium Facility, treats liquid radioactive and hazardous waste contaminated by the fabrication of plutonium pits, or the triggers, for nuclear weapons. In 1963, discharges began through Outfall 051 into a tributary of Mortandad Canyon. In the late 1990’s LANL instituted a “zero liquid discharge” plan to eliminate the discharge. LANL RLWTF Zero Dischg Project 7-10-1998 LANL was aware it could lose the Clean Water Act exemption, which would put it under the more stringent hazardous waste laws.
“However, the potential for exposure to increased RCRA regulatory coverage with zero discharge underscores the need for better administration and documentation of compliance with Waste Acceptance Characterization] WAC requirements.” Elimination of Liquid Discharge to the Environment from the TA-50 Radioactive Liquid Waste Treatment Facility, LA-13452-MS, UC-902, June 1998, p 12.
Some examples of the safety requirements that would apply for all of the operations of the Radioactive Liquid Waste Treatment Facility include the operation and integrity of the tanks, tank systems, and pipes and pipe connections; characterization of hazardous waste; monitoring and inspections; and compliance with seismic standards.
The facility stopped discharging through Outfall 051 in November 2010 when the conversion to zero liquid discharge was complete. Nevertheless, EPA continues to recognize Outfall 051 as qualifying LANL for regulation under the Clean Water Act and thus exempts it from the more protective hazardous waste laws.
At least four outfalls remain on the permit even though they also have not discharged for years. These are the Strategic Computing Complex (no discharge between September 2016 and to at least May 2019); the Los Alamos Neutron Science Complex, or LANSCE, (facility cooling towers are no longer in use); the National High Magnetic Field Laboratory (treated water being “discharged” to the Sanitary Wastewater System (SWWS) Plant); and the High Explosive Wastewater Treatment Facility (since November 2007 an electric evaporator(s) has been in use).
- TONIGHT!!! Thursday, October 29th from 6 to 8 pm – Sandia National Laboratory (SNL)
and Kirtland Air Force Base (KAFB) Semi-Annual Public Meeting about their environmental programs and the proposed SNL Chemical Waste Landfill Post-Closure Care Permit Renewal. For more information, the meeting agendas and presentations:
SNL – https://www.sandia.gov/about/environment/environmental_management_system/public_meetings.html
KAFB – https://www.kirtland.af.mil/Home/Environment/
- Friday, October 30th – Cold War Patriots 12th National Day of Remembrance – Virtual Ceremony. Register at https://coldwarpatriots.org/
- Monday, November 2nd –
public comments due to EPA about two draft discharge permits for LANL under the Clean Water Act National Pollutant Discharge Elimination System (NPDES). Sample public comments you can use available at http://nuclearactive.org/.
- Tuesday, November 3rd – VOTE!
- Tuesday, November 3rd – Comments due to the Nuclear Regulatory Commission (NRC)
about the proposed consolidated interim storage facility at Waste Control Specialists/Interim Storage Partners (WCS/ISP) for high-level radioactive waste from nuclear power plants on the TX/NM border, five miles east of Eunice, NM. Information and sample public comments available here: http://nonuclearwasteaqui.org/ , http://www.beyondnuclear.org/radioactive-waste/ , https://www.sierraclub.org/texas/blog/2020/09/high-level-radioactive-waste-dump-could-come-texas , and https://www.nirs.org/campaigns/dont-waste-america/
- Thursday, November 5th from 5 to 7 pm –
Second Virtual Public Information Session on Proposed Tritium Venting at LANL – https://lanl.gov/environment/flanged-tritium-waste-containers.shtml or see attached NNSA announcement.
NNSA Tritium Venting Announcement 10-27-20
Tags: Clean Water Act, Environmental Protection Agency, EPA, exemption, hazardous waste, High Explosive Wastewater Treatment Facility, LANL, LANSCE, Los Alamos National Laboratory, Los Alamos Neutron Science Complex, National High Magnetic Field Laboratory, Outfall 051, Plutonium Facility, Radioactive Liquid Waste Treatment Facility, RCRA, Resource Conservation and Recovery Act, RLWTF, Sanitary Wastewater Facility, Strategic Computing Complex, zero liquid discharge
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