An Historic Perspective of NPDES Individual Permit for Storm Water Discharges from Solid Waste Management Units at Los Alamos National Laboratory - 18667
The Los Alamos National Laboratory (LANL) and the associated communities of Los Alamos and White Rock are located in Los Alamos County in north-central New Mexico approximately 60 mi north-northeast of Albuquerque and 25 mi northwest of Santa Fe. The 36-mi{sup 2} facility is situated on the Pajarito Plateau, which consists of a series of fingerlike mesas separated by deep east-to-west oriented canyons cut by predominately ephemeral and intermittent streams. The mesa tops range in elevation from approximately 7800 ft. on the flanks of the Jemez Mountains to about 6200 ft. at their eastern termination above the Rio Grande Canyon. The land surrounding the Laboratory is largely undeveloped. Public access to much of the facility is limited for safety and security reasons. Large tracts of surrounding land are held by the U.S. Forest Service (Santa Fe National Forest), the Bureau of Land Management (Bandelier National Monument), the General Services Administration and San Ildefonso Pueblo. Storm water discharges from Solid Waste Management Units (SWMUs) have been regulated at the LANL since the early 1990's and have evolved into an Individual Stormwater Permit (IP) that may be one of the most complex in the nation. Historically, storm water discharges from SWMUs at LANL were regulated under a nationwide general permit using a watershed based approach requiring a Storm Water Pollution Prevention Plan (SWPPP), monitoring at sub-watershed scale 'USGS like' gage stations, and inspection and maintenance of erosion controls. In 2001, the Cerro Grande Fire destroyed many Laboratory structures, residential homes and over 80,000 acres of forested lands in the upper watershed above Los Alamos that significantly changed the local hydrology. Several years later, a Federal Facilities Compliance Agreement (FFCA) was issued by U.S. Environmental Protection Agency (USEPA) that was followed by a Clean Water Act lawsuit filed by concerned citizens, the result of which required more focus on stormwater discharges from individual SWMUs and an IP covering over 400 Sites. The IP contains non-numeric technology-based effluent limitations, coupled with a comprehensive, coordinated inspection and monitoring program, to minimize pollutants in LANL's storm water discharges associated with historical industrial activities from specified Sites. Non-numeric technology-based effluent limitations include minimizing pollutants in discharges through erosion and sedimentation controls, management of run-on and runoff, employee training, inspection and maintenance of controls, annual reporting and public involvement. The IP establishes Target Action Levels (TALs) that are equivalent to New Mexico State water-quality criteria. These TALs are used as benchmarks to determine the effectiveness of control measures implemented under the IP. That is, storm water quality sample results from SWMU discharges are compared with applicable TALs. If one or more sample results exceed a TAL, LANL must take additional corrective action. The TAL results are also confounded by high levels of naturally occurring constituents such as aluminum and gross alpha, and urban constituents such as copper, zinc and PCBs which may not be a source from the regulated SWMU. Due to the remote rugged terrain, security access issues, number of monitoring locations, stringent TALs, reporting requirements and public involvement requirements, this permit is likely one of the most stringent and complex in the country. The Laboratory has implemented this permit in a compliant manner for the past seven years and is anticipating the issuance of a new permit in the next few months. This paper will cover permit requirements related to control measure installations, monitoring, reporting and public involvement as well as process improvements and remaining water quality initiatives such as developing studies to address issues such as discriminating between natural background levels and LANL-related contaminants during the execution of this unique permit. (author)