BY MAIRE O’NEILL
maire@losalamosreporter.com
The New Mexico Environment Department’s Groundwater Quality Bureau has issued a list of revised acceptable corrective actions to the Department of Energy for treatment of the chromium plume below Los Alamos National Laboratory that includes resuming re-injection of treated water for a period of 12 months.
The new corrective action plan, called “Appendix A”, requires that during the one-year recommencement of injections, LANL will develop, install and operate an alternative disposal area for treated water that can handle the full amount of water intended to be extracted. The new plan was sent to the Department of Energy by NMED Water Protection Division Director John Rhoderick and Resource protection Division Director Rick Shean.
The disposal location has to be outside the plume and not hydrologically affect the plume. “Outside the plume will be 1200 feet from the router boundary of an area where the plume is well-defined as indicated by data,” the NMED directive states. It notes that the alternative disposal location can be used on an ongoing basis to inject treated water as an alternative to injecting into five of the existing injection wells
The corrective plan allows DOE to temporarily resume injection into two of the injection wells with the approval of the Pueblo of San Ildefonso and will require the installation and sampling of an additional well on the Pueblo’s land. If sampling at the new well (SIMR3) shows any evidence of chromium contamination above background, injections are to immediately cease. If there is no evidence of chromium contamination, DOE may continue to inject treated water into wells identified as CRINs 3 and 4 and may commence injection into CRIN 5.
No injections may recommence into the other two injection wells, CRINs 1 and 2 until another well, R-80 is installed, sampled and evaluated. NMED indicates that additional wells or analysis may also be required to determine the effects of CRINs 1 and 2 on nearby wells. If data shows that Screen 2 in well R-45 continues to be impacted the two injection wells will remain paused. If hard data shows that R-45 Screen 2 will not be impacted further by injections into CRIN-1 or CRIN-2, DOE may commence injection into one, the other, or both wells.
The NMED letter says that NMED seeks a path forward with DOE that will further the shared goal of protecting public health through collaborative decision-making while maintaining clear roles as permittee and regulator, respectively. NMED and DOE have been that path forward since December and appear to have reached an impasse.
“Recognizing the gravity of the situation, the risks to groundwater safety, and the urgent need to take immediate action, the GWQB is taking the extraordinary step, one that GWQB rarely takes, of identifying an acceptable corrective action path forward. NMED, including GWQB and HWB, feel this path is supported by the best available science and will allow us to take the action necessary to protect the regional aquifer,” the letter states.
NMED hopes LANL will now submit to them a revised Corrective Action Plan that includes the actions identified in Appendix A.
“This matter is of utmost urgency and your immediate response will reflect your understanding of the importance of submitting and implementing a revised CAP as soon as possible,” the letter states.
To continue to expedite corrective action, NMED would like LANL to identify and retain an independent mediator to facilitate such technical discussions as possible.
Retaining an independent mediator was recently recommended by the Government Accountability Office and discussed during the August 21 meeting in Los Alamos of the Radioactive and Hazardous Waste Interim Legislative Committee. See:
“We believe working together in conjunction with a third-party mediator will clarify the technical discussions and open both parties to new ideas to protect the environment and public health of this historic community, a goal we both share. We look forward to meeting within the next several weeks to collaboratively discuss the path forward for corrective action alternatives. Please contract with a third-party mediator and provide a copy of the contract prior to our meeting,” the letter states.
NMED also urged DOE in the letter to renegotiate “a functional and effective consent order” governing LANL cleanup.
”The fact that LANL has stated the 2016 consent order is an impediment to more aggressive clean-up is precisely why the U.S. DOE Environmental Management leadership in Washington, DC must renegotiate a new consent order,” the letter states.
DOE officials are evaluating the proposal, which was received Wednesday.