Individual Permit: FAQs

The United States Environmental Protection Agency (EPA) Region 6 Office is the National Pollutant Discharge Elimination System (NPDES) permitting authority for the State of New Mexico.

The NPDES Individual Permit was issued to Los Alamos National Security, LLC, and the U.S. Department of Energy (DOE) by the U.S. EPA Region 6 Office located in Dallas, Texas. As of April 30, 2018 the work performed under the NPDES Permit is managed by N3B Los Alamos for the Department of Energy Office of Environmental Management.

Section A of the Permit requires the Permittees to install baseline control measures at all permitted Sites identified in Appendix A to the Permit as necessary to meet the non-numeric technology-based effluent limits intended to minimize pollutants in storm water discharges.

The Permittees must select, design, install and implement baseline control measures - including best management practices - in accordance with good engineering practices and manufacturer’s specifications.

The baseline control measures must address the following non-numeric technology-based effluent limitations as listed in Sections A.1 – 5 of the Permit.

• Erosion and sedimentation controls
• Management of Run-on and Runoff
• Employee Training
• Other controls, where applicable, such as:
  • controls to ensure that no waste, garbage, or floatable debris are discharged to receiving waters
  • minimization of dust generation and off-site vehicle tracking
  • minimization of the introduction of raw, final, or waste materials to exposed areas; and/or
  • placement of flow velocity dissipation devices if the flows would otherwise create erosive conditions

The Individual Permit designates 63 Sites as High Priority Sites for the purpose of completing the Corrective Action requirements described in Section E of the Permit. The list of 63 High Priority Sites is found in Section E.4 (a).

N3B must certify completion of corrective action at all High Priority Sites within three years of the effective date of the Permit.

The 63 High Priority Sites were identified based on previous detection of polychlorinated biphenyl compounds (PCBs) in storm  water runoff discharged from the Site(s). The 63 High Priority Sites are assigned to 33 Site Monitoring Areas.

Further information about the High Priority Sites can be found in each of the five volumes of the Site Discharge Pollution Prevention Plan on the Site Discharge Pollution Prevention Plan webpage.  The Storm Water Individual Permit Annual Report is available on the  Individual Permit for Stormwater reports webpage.

The Individual Permit establishes corrective action deadlines for Sites. However, N3B organizes the implementation of corrective action by SMA.

The schedule for corrective action work at any SMA that has both a High Priority and Moderate Priority Sites is based on the schedule for High Priority Sites; i.e., within three years of the effective date of the Permit.

There are three SMAs that contain both High Priority and Moderate Priority Sites:

• LA-SMA-6.5
• M-SMA-3.5
• PJ-SMA-18

Section D.2 of the Permit states that all samples taken for purposes of confirmation monitoring shall be taken at the Site Monitoring Areas (SMAs) specified in Appendix A to the Permit. Section D.2 further allows N3B to monitor two or more Sites in conjunction at an associated SMA instead of monitoring at each individual Site, when appropriate based on drainage patterns for the affected Sites.

SMA locations are based on reasonable site accessibility for sampling purposes and N3B’s best judgment to ensure that samples taken at a particular point will be representative of discharges from Sites in the drainage area.

For the purposes of monitoring, the 405 Sites are organized into 250 SMAs as listed in Appendix A to the Individual Permit.

The Site Discharge Pollution Prevention Plan (SDPPP) includes detailed information about the SMAs including:

• The location of each Site within the SMA drainage area
• The coordinates for the sampling location
• Estimates of the size of the drainage area for each of the Sites
• The total drainage area of the associated SMA

Appendix E to the Permit describes the purpose of erosion control measures as minimizing the potential for erosion occurring when storm water runoff flows across an area.

Baseline control measures used for erosion control at N3B include the following major categories:

• Capping
• Channel/swale
• Established vegetation
• Gabions
• Seed and mulch

Appendix E to the Permit describes the purpose of sediment control measures as retaining storm water-transported sediment onsite.

Baseline control measures used for sediment control at N3B include the following major categories:

• Berms
• Check dams
• Gabions
• Sediment traps
• Basins

Section F of the Permit requires N3B to prepare a storm water pollution prevention plan that is called the ‘Site Discharge Pollution Prevention Plan’ (SDPPP) in the Individual Permit. The Permit-required contents of the SDPPP and associated documentation are described in Section F.

The SDPPP must be updated annually to fully incorporate all changes made during the previous year and to reflect any changes projected for the following year.

The SDPPP is a document that has three primary objectives:

• Identify and summarize potential pollutant sources, including potential sediment-borne pollutants, that may affect the quality of storm water discharges associated with the IP Sites
• Identify and describe the control measures intended to reduce or eliminate pollutants in storm water discharges
• Document the procedures and schedules for sample collection and site inspection

Section I.7 (c) of the Permit requires that N3B send email notifications to members of the public who have subscribed on the public website to receive notifications about public meetings, which will be held approximately every 6 months.

N3B must email a draft agenda at least one week before the meeting and will consider suggestions from the public for changes or additions to the agenda.