A major issue developing among the regulators is interjection of surface water quality standards into the remedial action decision making. The New Mexico Surface Water Quality Board has expressed concern that non-point source runoff from the potential release sites at Los Alamos could lead to violations of surface water quality standards. These concerns may be leading toward more restrictive cleanup standards than would be expected under RCRA corrective action decision-making. The canyons into which runoff are ephemeral in all or part of their channel, flowing only during rainstorms or heavy snowmelt. Therefore, it is difficult to directly confirm or deny that surface water quality problems are occurring. Ongoing interactions with state regulators are geared toward resolving this issue.
Over the past year, there has been a major initiative to come to consensus among the regulators, DOE, the Laboratory, and Sandia National Laboratory on the processes and decision tools used in making corrective action decisions. This initiative has led to a document of understanding among the parties for the purpose of facilitating timely and cost-effective implementation of the environmental restoration programs (ER) at Los Alamos and Sandia. This will lead to a greater standardization in the planning and execution of ER at the two Laboratories.
The document of understanding contains a summary of the programmatic approach for accomplishing the ER project, base upon the Installation Work Plans for the Los Alamos and Sandia projects. The document lays a foundation for
Although the document is not legally binding, it provides a framework to define, clarify, and outline processes and procedures to implement the ER projects.