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Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory: Final Report 1 Introduction Operations at the Los Alamos site in northern New Mexico began in 1943 under the Manhattan Project. That project led to the world’s first nuclear bomb, which was successfully tested in 1945. In view of its continuing missions in national security and basic research, the original Los Alamos Laboratory became the Los Alamos Scientific Laboratory in 1947. Designated as Los Alamos National Laboratory (LANL) in 1981, the site is operated by Los Alamos National Security LLC1 under contract to the National Nuclear Security Administration (NNSA) of the U.S. Department of Energy (DOE). Like those at other sites in the nation’s nuclear weapons complex, LANL’s operations created a legacy of radioactive waste and environmental contamination, which is now being addressed by DOE (DOE, 1997). At LANL, liquid wastes were generally discharged into canyons, and solid wastes were buried in several locations, mostly in high mesas. Radionuclide and chemical contamination has been detected in some portions of the groundwater beneath the site. Under authority of the U.S. Environmental Protection Agency (EPA), the State of New Mexico regulates protection of its water resources through the New Mexico Environment Department (NMED). NMED has recently issued an Order on Consent for Los Alamos National Laboratory2 that establishes schedules for additional investigations that will lead to a corrective action decision under the Order. New Mexico citizens and citizens’ groups are also actively involved in environmental issues at LANL. The Pueblo de San Ildefonso,3 Los Alamos County, and the County and City of Santa Fe have water supply wells located in the projected pathway of groundwater leaving the LANL site, and, as a consequence, their citizens have a long-term interest in the quality of groundwater (see Figure 1.1). The committee’s study came at an important juncture in LANL’s groundwater protection program—beginning shortly after LANL completed an extensive program to characterize the site’s hydrogeology4 and continuing concurrently with LANL’s initial planning for sitewide groundwater monitoring. The study was funded by the DOE Office of Environmental Management. The Los Alamos site office of NNSA requested the study and served as the DOE liaison. NNSA also requested the committee to prepare an interim status report, which described the information-gathering phase of the study but contained no findings or recommendations. The interim report was issued in fall 2006.5 THE COMMITTEE’S TASK The statement of task for this study is shown in Sidebar 1.1. The first two subsets of tasks direct the committee to provide answers to questions regarding LANL’s knowledge of potential sources of groundwater contamination and aspects of its monitoring program. The last subset of the task statement asks for the committee’s recommendations. During the committee’s information gathering (see Appendix A), LANL representatives paraphrased portions of 1 Los Alamos National Security LLC is a consortium of Bechtel, the University of California, BWX Technologies, and Washington Group International. After competitive bidding, the Department of Energy selected this consortium to operate LANL in December 2005, and the transition was completed in June 2006. See http://lansllc.com/. 2 Usually referred to as the Consent Order. This legally binding agreement among NMED, DOE, and the University of California was signed on March 1, 2005. 3 The Pueblo de San Ildefonso is a federally recognized Native American tribal government—one of nineteen pueblos still in existence in New Mexico and one of five Tewa-speaking tribes. The Pueblo’s 30,271-acre reservation (i.e., Tribal Trust Lands) is located in north-central New Mexico adjacent to the LANL site (see Figure 1.1). 4 Los Alamos National Laboratory’s Hydrologeologic Studies of the Pajarito Plateau: A Synthesis of Hydrogeologic Workplan Activities (1998-2004), issued December 2005. 5 See http://books.nap.edu/catalog.php?record_id=11781.
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Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory: Final Report FIGURE 1.1 Location of Los Alamos National Laboratory in northern New Mexico. The site is traversed by numerous canyons, such as Mortandad Canyon, which has been studied extensively. Groundwater flow is generally from west to east toward Pueblo de San Ildefonso lands and the Rio Grande. SOURCE: Andrea Kron, LANL.
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Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory: Final Report SIDEBAR 1.1 Statement of Task This study will focus on specific scientific and technical issues related to groundwater monitoring and contamination migration at LANL as follows: General review of groundwater protection at LANL: What is the state of the laboratory’s understanding of the major sources of groundwater contamination originating from laboratory operations and have technically sound measures to control them been implemented? Have potential sources of non-laboratory groundwater contamination been identified? Have the potential impacts of this contamination on corrective-action decision making been assessed? Does the laboratory’s interim groundwater monitoring plan follow good scientific practices? Is it adequate to provide for the early identification and response to potential environmental impacts from the laboratory? Is the scope of groundwater monitoring at the laboratory sufficient to provide data needed for remediation decision making? If not, what data gaps remain, and how can they be filled? Specific data-quality issues: Is the laboratory following established scientific practices in assessing the quality of its groundwater monitoring data? Are the data (including qualifiers that describe data precision, accuracy, detection limits, and other items that aid correct interpretation and use of the data) being used appropriately in the laboratory’s remediation decision making? Recommendations to improve the future effectiveness of the laboratory’s groundwater protection program with respect to: Potential remedial actions for the groundwater contamination, especially for radionuclide contamination for which DOE is self-regulating; and Monitoring for long-term stewardship. the task statement to emphasize issues of greatest interest to the Laboratory and to DOE, as follows (Dewart, 2006): Do we [LANL] understand and have we controlled our sources of groundwater contamination? Are we adequately addressing issues of groundwater data quality? Is our groundwater monitoring approach effective in identifying contaminants that may migrate at unacceptable levels to public receptor locations? At the study’s beginning the committee recognized that water is a precious resource in northern New Mexico, and citizens of that state are very concerned that their water supplies be protected. The LANL site itself is located on lands historically occupied by Native Americans and immediately adjacent to several active pueblos. While confining its deliberations to technical issues, the committee included citizens’ concerns in its information gathering and kept their concerns in mind as it considered its task. The committee also recognized that LANL is legally bound to meet milestones specified in the Consent Order with NMED, which requires the Laboratory to evaluate and remediate, as necessary, contamination in the groundwater by about 2015. The task statement does not ask the committee to address or comment on the Consent Order, and it has not done so.6 However, meeting the Order’s provisions is strongly influencing LANL’s groundwater investigations, plans for monitoring, and future remediation decisions. The committee requested and received two presentations from NMED about the Order, which is described in Chapter 2. The committee considered its task to be a review of work in progress. Findings and recommendations are provided from this perspective. At the beginning of the committee’s first meeting, Mat Johansen, NNSA liaison to the committee, stated that LANL’s groundwater protection program is at about its temporal midpoint (see Figure 1.2). Significant source control measures began in the late 1990s and, under the Consent Order, the program is to be completed by about 2015—with continuing long-term monitoring and site stewardship. While observing that LANL has made great 6 The committee was also aware that radioactive materials at DOE sites, including LANL, are regulated by DOE, whereas the EPA has given the State of New Mexico authority to regulate toxic and chemically hazardous materials, as described in Chapter 2. In their meetings with the committee, DOE and LANL representatives did not raise this legal distinction as an issue for the committee’s delibrations.
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Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory: Final Report FIGURE 1.2 LANL groundwater protection activities over time. DOE and LANL are at about the halfway point in establishing the groundwater protection program. In preparing this report, the committee considered the program to be work in progress. The committee’s findings and recommendations are intended to assist DOE and LANL to complete the program by 2015 as required by the Consent Order. SOURCE: Johansen, 2006. progress, the committee also recognizes that considerable work remains. OVERVIEW OF THIS REPORT This report is organized according to the sequence of activities that one might consider in developing a groundwater protection program. Chapter 2 describes the technical, legal, and public issues that frame the program. Chapter 3 addresses sources of contamination and the degree to which they are accounted for and controlled. Chapter 4 describes hydrogeologic pathways along which contaminants might move from their sources eventually into a water supply and evaluates LANL’s Interim Plan to monitor those pathways. Chapter 5 addresses monitoring activities themselves—well drilling, sampling, sample analysis, and data quality. Each chapter addresses parts of the task statement and includes findings and recommendations. Chapter 6 summarizes all of the committee’s findings and recommendations. In the course of this study the committee developed some general observations that bear on the groundwater protection program. These observations are summarized below and presented in greater detail throughout this report. LANL learned a great deal during its Hydrogeologic Workplan, which was carried out from 1998 through 2004 to develop sufficient information to begin site monitoring (LANL, 1998a, 2005a). Work in geochemistry has not kept pace with this work in hydrogeology.7 Geochemical studies applied to LANL’s groundwater protection program would address how contaminants’ interactions with natural and anthropogenic materials affect their transport by groundwater—they may move freely with the groundwater or be retained to a greater or lesser extent by materials along the groundwater pathways. Geochemical interactions affect contaminant migration from sources (Chapter 3), along groundwater pathways (Chapter 4), and in monitoring wells (Chapter 5). A second observation is that LANL needs better ways to demonstrate its considerable knowledge of the groundwater system—ways that are both scientifically meaningful and reassuring to citizens. Introduced in Chapter 3, the use of mass balance and the careful representation of uncertainties are two recurring themes throughout this report. Mass balance analyses, with estimates of data uncertainties, can be used to account for contaminant sources, releases, radioactive decay, and migration through the hydrogeologic system. 7 Water is responsible for the migration of contaminants in the environment. Hydrogeology is the study of groundwater behavior in the subsurface. Geochemistry is the study of the chemical processes and reactions of materials of the Earth, and in this case would include how contaminants interact with these materials and groundwater.
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Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory: Final Report More generally, there are needs and opportunities for LANL to present more of its groundwater protection work in peer-reviewed literature. Peer-reviewed publication is the standard of science. LANL has produced massive amounts of report material, and the additional step of summarizing and publishing key portions, as it did with much information from the Hydrogeologic Workplan (VZJ, 2005), can help authenticate LANL’s groundwater protection program. LANL’s motto—“The World’s Greatest Science Protecting America”—is clearly applicable to groundwater protection.
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