Public Comment Period for Ground Water Discharge Permit for the LANL Radioactive Liquid Waste Treatment Facility ends Thursday, December 12th

Here the sample TA-50 comment addressed to Ryan Flynn, Secretary-Designate of the New Mexico Environment Department:  f TA-50 sample comment 12-6-13


Runs 12/6/13 through 12/13/13

(THEME UP AND UNDER)  This is the CCNS News Update, an overview of the latest nuclear safety issues, brought to you every week by Concerned Citizens for Nuclear Safety.  Here is this week’s top headline:

  • Public Comment Period for Ground Water Discharge Permit for the LANL Radioactive Liquid Waste Treatment Facility ends Thursday, December 12th

The Ground Water Quality Bureau of the New Mexico Environment Department released a draft ground water discharge permit for the 50-year old Radioactive Liquid Waste Treatment Facility at Los Alamos National Laboratory (LANL) for public review and comment.  The Communities for Clean Water have prepared sample public comments for you to use, which are posted on the websites of CCNS and Amigos Bravos.  Public comments are due on or before Thursday, December 12th.

The Radioactive Liquid Waste Treatment Facility has been in operation since 1963 and treats liquid radioactive waste created at the plutonium and tritium facilities located across the LANL site.  The draft permit allows LANL to discharge up to 40,000 gallons a day of treated wastewater into the environment through one of three conveyances.  The first is through a discharge pipe into Mortandad Canyon.  The second is through an indoor Mechanical Evaporator System.  The third is to the outdoor, synthetically lined Solar Evaporation Tanks, consisting of two cells that each hold approximately 380,000 gallons, for evaporating tritium contaminated wastewater into the atmosphere.  Under a plan to eliminate the discharge to groundwater in Mortandad Canyon, LANL has almost stopped use of the pipe, but has increased use of the evaporative systems.

Part of the permit application process requires that LANL submit its plans for what will happen when it’s ready to close and decommission the liquid waste treatment facility.  Then both the application and the closure plans are subject to a public hearing.  In this case, however, the draft permit allows LANL to submit the closure plans six months following the issuance of the permit.  This results in another public comment period on just the closure plans and possibly another public hearing.  CCW objects to this provision and asks you to submit public comments on the issue.

The sample public comment is directed to Ryan Flynn, the Secretary Designate of the Environment Department.  It reads, “By separating the permit process from the closure process, there will have to be two permit proceedings which will cost your agency and the public time and money.  By including the closure and post-closure plans with the draft permit — as required — both public and Environment Department resources are appropriately conserved and a higher level of informed decision-making can be achieved.  That is a benefit to your agency and the public it serves.  Requiring the closure plans now — before permit issuance — will save federal taxpayer money as well because LANL will only have to undergo one groundwater permitting process on this facility.”

This has been the CCNS News Update.  To download the sample public comment and make a tax-deductible contribution, please visit our website at




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