Joint Comments from the Department of Energy, National Nuclear Security Administration (DOE NNSA) Los Alamos Field Office and Triad National Security, LLC on the U.S. Environmental Protection Agency’s New Mexico State-Wide Municipal Separate Storm Sewer System Strawman General Permit
In December 2020 and March 2021, EPA issued two MS4 strawman permit drafts specific to the Los Alamos area. EPA made text changes in the 2 nd strawman permit based on stakeholder comments related to the initial draft. During the public meeting on the Los Alamos area designation decision held on February 13, 2024, EPA staff stated that comments from the past strawman permits would be incorporated into the new MS4 permit to be issued state-wide. However, it does not appear that any of the text changes from the 2 nd Los Alamos area strawman permit were included in this state-wide general MS4 strawman permit. For reference, the 2 nd Los Alamos area revised strawman permit is included with these comments as Attachment 2. Many of the following comments refer to or state EPA’s updated text included in the 2 nd Los Alamos area strawman permit. The updated text from this 2 nd strawman permit that are referenced in the following comments should be applicable state-wide and it is suggested that this past work be reconsidered and incorporated.