Given the recent data dumps by Los Alamos National Laboratory (LANL) about its proposed venting of large quantities of radioactive tritium from four Flanged Tritium Waste Containers, the New Mexico Environment Department (NMED) must reject LANL’s August 22^nd regulatory request for temporary authorization to vent.  This Update describes some of the obstacles LANL put in place to obstruct public participation and timely access to important documents.

Many people were unable to participate in the August 20^th in person and virtual LANL public meeting about the proposed venting because an artificial cap was set at 100 virtual participants.  Comments and questions submitted by zoom were reduced to a minimal number of words, resulting in incomplete responses.  The meeting ended promptly after two hours even though there were at least 11 people on line with their virtual hands raised.  https://nuclearactive.org/lanl-silences-public-and-tribal-voices-while-pushing-radioactive-tritium-venting/

Two days later, on Friday, August 22^nd LANL submitted a 79-page letter with enclosures to support its request for the Environment Department to grant temporary authorization by Friday, August 29^th to vent in the future.  Los Alamos National Laboratorys Flanged Tritium Waste Container Temporary Authorization Request and Mitigation Project is Compliant with Law and Protective of Worker Safety, Public Health, and the Environment, and Should be Approved by August 29, 2025

The public, however, received notice of the August 22^nd LANL letter only on August 27^th through the LANL Electronic Public Reading Room.  [To receive such notices, you can subscribe too at https://eprr.lanl.gov/ ]  During that day, LANL did a data dump of key and long-requested documents to its Flanged Tritium Waste Container webpage.  https://www.lanl.gov/engage/environment/ftwc

As a matter of respect as well as transparency, these documents should have been made publicly available for review at least prior to the August 20^th in person and virtual meeting.  They were not.

Documents posted on August 27^th included a two-page list of venting alternatives that many non-governmental organizations and individuals have requested multiple times over several years.  The alternatives list is brief in details and contains suboptions that are not explained.  FTWC Project Alternatives Summary LA-UR-25-28815

Other posted documents include LANL responses to two of the technical reports commissioned by Tewa Women United, based in Española, New Mexico.  The first report, Review of LANL Radiation Dose Assessment for the Venting of Flanged Tritium Waste Containers (FTWCs) at TA-54 of Los Alamos National Laboratory, authored by Bernd Franke, a Director of the Institute für Energie und Umweltforschung (IFEU), contains results from a model used to assess the possible range of radiation doses to the public across various weather scenarios.

Franke, an expert in radiation dose assessment, stated, “I utilized the same model as LANL and incorporated weather data from the station in Area G, while also considering adverse weather conditions, such as days with low humidity and increased wind frequency directed towards White Rock. Additionally, I compared these factors across various age groups of the public, in contrast to LANL, which solely includes adults in their compliance calculations. Using this analysis, I found that infants and small children have a potential radiation exposure three times that of adults.” https://tewawomenunited.org/2024/11/press-release-new-report-reveals-lanl-tritium-venting-could-have-triple-the-radiation-exposure-to-infants-compared-to-adults

The second report by Dr. Arjun Makhijani of the Institute for Energy and Environmental Research titled, “Out of Order:  An evaluation of the regulatory aspects of Los Alamos National Laboratory’s proposal to vent tritium from waste containers” assesses the compliance of LANL’s proposal with the applicable Clean Air Act radiation protection regulation set forth by the EPA in Title 40 CFR 61, Subpart H, as well as with Department of Energy (DOE) Order 458.1, which requires DOE facilities like LANL to keep public exposures and environmental contamination “as low as reasonably achievable.”

Out of Order indicates “using the very same assumptions about maximum possible releases at LANL, the proposed venting would not be in compliance with the Clean Air Act. The EPA was wrong to have approved the venting. That permit has expired. It should require that LANL completely re-do its application.”

Talavi Cook, former Environmental Justice Program Manager at Tewa Women United, said, “As important as they are, there are matters far beyond these technicalities.  Not only should the EPA radiation protection standards explicitly include children and infants in its definition of ‘any member of the public’, but Tewa Women United believes that radiation protection should extend to pregnant women due to fetuses comprising of 70% – 90% water; pregnant members of the public are not currently protected by the Clean Air Act or any other radiation protection regulation. It would be especially egregious if fetal health is compromised by LANL venting radioactive water vapor and making our rainwater and food radioactive. It is a matter of simple environmental justice for future generations.”  https://tewawomenunited.org/2024/11/press-release-new-report-reveals-lanl-tritium-venting-could-have-triple-the-radiation-exposure-to-infants-compared-to-adults

The LANL August 27^th responses to the two technical reports are similar to brief footnotes in a report, with no discussion and no cites to sources used to support the responses.  https://www.lanl.gov/engage/environment/ftwc

LANL also responded to Dr. Dylan Spaulding, a Senior Scientist at the Union of Concerned Scientists, who, on July 18^th wrote a letter to Environment Department Secretary Kenney about, among other things, the potential radiation doses to the most vulnerable members of the public from potential tritium venting releases.  https://www.lanl.gov/engage/environment/ftwc

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