Campaign to prevent radioactive tritium venting from Los Alamos National Laboratory
Updated Tritium Venting Summary:
LANL had four Flanged Tritium Waste Containers (FTWCs) filled with approximately 90,000 curies of radioactive tritium that they wanted to transport from Area G at LANL. They had been packaged at LANL’s Weapons Engineering Tritium Facility (WETF) in 2007 and sent to LANL’s Area G for permanent disposal. LANL reported that if they did not vent them into the air, there may have been a tritium explosion. CCW has worked diligently since 2020 to hold LANL accountable to the harm that the venting of the tritium waste containers could have on our communities.
Despite community concerns, and despite the fact that LANL found no measurable pressure on the vent rig gauges of the four FTWCs, the tritium venting took place between September 15 and September 29, 2025. LANL reports that the total radionuclide air emissions were 123 curies of tritium. During the course of the days of venting, it was raining off and on in the region. There was no public notice of pausing for rain during this time. The most reliable place that community members could find updated information about venting was the New Mexico Environment Department’s website. After venting had already begun, LANL began posting daily summaries on their website.
The FTWCs were moved back to WETF, where they were originally packaged, between October 5 and October 12, 2025. They were shipped from LANL to Waste Characterization Specialists in Andrews, Texas in late October - early November 2025.
Tritium Venting Timeline:
February 19, 2026: Volume 2 of the Flanged Tritium Waste Containers Report released
FTWC Radioactive Air Emissions Summary, Volume 2 Environmental Sampling & Expanded Plume Modeling
FTWC Radioactive Air Emissions Summary, Volume 1 Stack Emissions & Off-Site Dose Consequence
CCW Letter to NMED: February 2, 2026
Re: Follow-Up and Administrative Record Submission – Tritium Venting Public Meeting (December 9, 2025)
Dear Secretary Kenney and Mr. Wyka,
The Communities for Clean Water (CCW) Coalition submits this letter to formally document the questions, concerns, and deficiencies raised during the December 9, 2025 public meeting concerning tritium venting operations at Los Alamos National Laboratory (LANL), along with additional concerns arising from LANL’s statements during that meeting.
As highlighted in our letter dated October 17, 2025, CCW has consistently expressed concerns about the lack of transparency, the incomplete alternatives analysis, deficiencies in dose modeling, and non-compliance with ALARA requirements outlined in DOE Order 458.1. These concerns remain unresolved. This letter is intended to confirm that the record accurately reflects that substantial technical and regulatory issues are still unresolved. CCW requests written responses from NMED and NNSA LAFO within 60 days of the date of this letter.
I. Memorialization of Outstanding Technical Questions Raised at the Public Meeting
At the public meeting held on December 9, 2025, CCW and affiliated organizations presented a variety of inquiries, including but not limited to:
Explosion and Pressure Risk Claims
LANL’s final report indicates that there was no pressure in all four Flanged Tritium Waste Containers (FTWCs). What specific hazard(s) necessitated venting in the absence f pressure buildup?
Will LANL provide the original modeling that forecasted pressure increases of up to 5 psi per year?
What factors contributed to the significant overestimation of pressure in the modeling process?
What conclusions did LANL reach concerning explosion risk following headspace sampling?
Does the absence of pressure support previous community proposals that sampling should have occurred prior to making any venting decision?
ALARA Compliance
How could any release of tritium be aligned with ALARA when no pressure hazard existed?
Why was evacuation of headspace below atmospheric pressure necessary at all? What was the necessity of evacuating the headspace to below atmospheric pressure?
Alternatives Analysis
Where is the full alternatives analysis, including the 53 alternatives referenced to EPA?
Why was this analysis not provided to the public despite multiple requests?
Which safer alternatives were considered and why were they rejected?
Monitoring, Data Transparency, and Independent Review
LANL must provide the timeline for the release of all raw monitoring data from LANL, including stack logs, QA/QC records, calibration data, and comprehensive meteorological datasets.
What independent verification of results has been or is currently being conducted?
NMED, NMDOH, and EPA Region 6 must conduct an independent review and publicly present their findings.
Downwind and Community Exposure
What were tritium concentrations in rainfall during venting events?
What is the reason for the delay in the results of soil and ambient air monitoring until 2026?
When will the second report be released for public review and comment?
Have the analyses for infant, fetal, pregnancy, and cumulative exposure pathways been conducted? When can we expect the release of those findings?
Future Risk and Public Process
What measures will LANL implement to avoid unnecessary tritium releases as pit production increases?
DOE/NNSA must commit to engage with public processes prior to the occurrence of any future venting.
Future meetings must allow oral public comment. Given the number of technical issues experienced during the public meetings, transcripts must be provided to the public.
As there was limited time during the public meeting, CCW requests that each of these questions be formally addressed in writing within the next sixty (60) days and included in the final administrative record.
II. ALARA Violations and Improper Justification Based on Transportation Risk
During the December 9 meeting, LANL representatives stated that venting was essential to mitigate risks associated with transportation of the FTWCs. This explanation contains significant scientific and legal shortcomings and fails to meet ALARA requirements.
ALARA mandates that radioactive emissions be maintained at levels that are “as low as reasonably achievable,” considering technical feasibility and overall risk, rather than merely convenience or downstream logistical considerations. LANL has acknowledged that:
Headspace sampling could have occurred prior to venting.
Physical pressure testing could have been conducted without releasing tritium.
No pressure buildup or explosive gas mixtures were ultimately found.
Consequently, the purported transportation risk emerged solely after LANL selected venting as its operational approach. The risk does not provide a valid justification for the initial decision to release radioactive material, especially when there were viable alternatives available at the time.
LANL effectively utilized risks generated by its own selected approach to validate that same approach, which contradicts ALARA’s mandate to minimize releases from the outset. ALARA is not fulfilled by selecting the least risky option after opting for an unnecessary release pathway; it necessitates the selection of the least harmful option prior to making release decisions.
III. Failure to Demonstrate Necessity or Emergency
LANL has consistently stated that the venting process could have been postponed until at least 2028. No imminent threat existed. Despite this:
No prior headspace sampling was conducted.
No independent verification of modeling occurred prior to authorization.
The public and Tribal governments were denied meaningful opportunity to review alternatives.
This absence of urgency further weakens any assertion that tritium releases were inevitable or warranted.
IV. Administrative Record and Enforcement Implications
CCW submits this letter to ensure that the administrative record reflects:
That documented substantial unresolved safety and regulatory questions remain;
That LANL may have failed to demonstrate ALARA compliance;
That alternatives were neither fully analyzed nor disclosed; and
That transportation risk was improperly used to rationalize a release that could have been avoided altogether.
These identified failures pertain to NMED’s regulatory oversight responsibilities and will influence any forthcoming decisions regarding permits, enforcement, or corrective actions associated with waste handling at LANL.
V. Requests
CCW respectfully requests:
Written responses to all memorialized questions within 60 days of the date of this letter;
Public release of all raw monitoring, modeling, and alternatives data;
Independent technical review by non-DOE entities; and
Formal clarification from NMED regarding how ALARA compliance was evaluated prior to the issuance of the temporary authorization.
An independent determination by NMED as to whether LANL’s actions during the tritium venting operations complied with ALARA requirements, and, if not, what corrective or enforcement actions NMED will pursue.
It is essential that transparency, regulatory compliance, and community protection remain paramount, particularly in light of LANL’s expansion of tritium and plutonium operations.
Respectfully,
Kalyn Mae Finnell, Coordinator
Communities for Clean Water Coalition
December 9, 2025: LANL holds Tritium Venting Public Meeting
September 18, 2025
September 10, 2025
September 4, 2025
NMED APPROVAL WITH MODIFICATIONS OF LANL’S TEMPORARY AUTHORIZATION REQUEST TO VENT TRITIUM
August 29, 2025
CCW Sent letter to NMED Urging NMED to Deny LANL’s Request for Temporary Authorization to Vent Tritium for the following reasons:
The Public Meeting Failed to Meet NMED’s Standards
The Technical Review Was Not Independent
Alternatives Analysis Remains Incomplete and Obscured
Procedural and Community Justice Failures
There Is No Emergency
July 9, 2025
Our letter details requests on the following:
Scope of Public and Tribal Participation
Alternatives to Venting
Tribal Consultation and All Pueblo Council of Governors Engagement
Public Hearing and Pre-Hearing Comment Period
Use of Settlement Funds to Support Oversight
July 9, 2025
Note the following in the letter hyperlinked above:
"As a response to the letter requiring prerequisites to any NMED action on the temporary authorization request, NA-LA and Triad are exercising the option to request an opportunity to meet and confer to resolve disagreement associated with the June 9, 2025 letter."
"NMED exceeded its authority in functionally denying Temporary Authorization for Flanged Tritium Waste Container pressure mitigation activities over which NMED has no jurisdiction and which are necessary for the protection of worker safety, human health, and the environment."
June 13, 2025
Local Communities and NMED Halt Tritium Release from LANL for the Time Being
Los Alamos, NM - On June 9, 2025, the New Mexico Environment Department (NMED) denied the Department of Energy (DOE) and National Nuclear Security Administration (NNSA) Temporary Authorization Request for venting radioactive tritium into the air from four flanged tritium waste containers (FTWCs) at Los Alamos National Laboratory (LANL).
In the letter, NMED requests that DOE/NNSA meet the following criteria before submitting a “revised request for temporary authorization to NMED for consideration.”
Obtain an Independent Technical Review for alternative options for the depressurization of the FTWCs.
Hold a Public Meeting for interested stakeholders, which includes a review of the independent, third-party technical review for alternative options.
Conduct Tribal Consultation with interested tribal governments.
Conduct a Compliance Audit of hazardous waste and its operations, by an independent, third-party auditor.
The DOE/NNSA Notification of Planned Start of a Temporary Authorization Request Waste Management Activity to NMED was submitted on April 4, 2025 with an aim to begin venting on or after June 2, 2025. NMED’s decision to deny the request was in large part due to strong local advocacy, community and environmental health concerns, and lack of Tribal consultation. Local concern has continually grown with frequent rains across New Mexico in June thus far. Rain during venting would present a worst case scenario to public health and the environment, with adverse radiation impacts especially to pregnant women, infants and small children.
In response to the Temporary Authorization Request in April, Nuclear Watch New Mexico, Concerned Citizens for Nuclear Safety and Communities for Clean Water started a petition against the venting, which garnered more than 2,300 signatures online.
On May 14, 2025, CCW requested a 60-day public comment period to NMED, to ensure impacted members of the public are informed of the risks of LANL’s proposed tritium venting project -
Re: Requesting Public Comment Opportunity on LANL Temporary Authorization Request, Hazardous Waste Facility Permit, EPA ID No. NM0890010515
On May 30, 2025 CCW sent a letter to NMED requesting that NMED withhold its regulatory consent until LANL responds to the independent technical reports that CCW and Tewa Women United contracted, which revealed impacts on infants and fetuses, as well as potential harmful impacts on the Rio Grande, groundwater and food systems. Around this time, NMED also received a letter of concern from San Felipe Pueblo.
It is important that we as a community continue to ensure that LANL meets the requirements that NMED is requesting. CCW also continues to advocate for a 60-day public commenting period which includes public meetings.
As CCW we thank the public for your continued advocacy, including the dedicated work of our partners, Tewa Women United, Concerned Citizens for Nuclear Safety, Honor Our Pueblo Existence, the Institute for Energy and Environmental Research, the New Mexico Environmental Law Center, Nuclear Watch New Mexico, Breath of My Heart Birthplace, Amigos Bravos, the New Mexico Acequia Association, Partnership for Earth Spirituality, and Sovereign Energy.
Here are the facts
One teaspoon of tritiated (HTO) water will contaminate about 100 billion gallons of water.
When calculating the risk, LANL does so for adults - they are not required to do so for children, infants or pregnant women/fetuses. This does not properly represent the real impact on our communities. The author of one report, Bernd Franke, stated, “In the case of tritium, infants and small children get a radiation dose about three times greater than adults, with the same concentrations of tritium in air, water, and food.”
See the independent, technical reports about the impacts tritium venting could have on water at the bottom of this page.
See the independent, technical reports about tritium’s adverse impacts on infants, children and fetuses on Tewa Women United’s website.
CCW’s work to prevent tritium venting continues our collaboration with Tewa Women United (TWU) since 2020, when TWU released a petition that totaled more than 3,000 signatures. Since the petition, Tewa Women United has continued working to prevent the tritium venting, commissioning two reports to study impacts and finding: “LANL Omitted Dose Calculations to Infants & Children in Their Compliance Application.”
LANL showed a list of 53 alternatives for the tritium venting to the EPA Region 6, but this has not been released to the public, despite Freedom of Information Act (FOIA) requests by Tewa Women United. LANL has also failed to conduct independent studies on health and environmental impacts to waterways in the case of weather events. There has been no new public information about the venting given by LANL or DOE/NNSA since 2020.
In Tewa Women United’s November 2024 press release, Kathy Wan Povi Sanchez, member of San Ildefonso Pueblo and one of Tewa Women United’s co-founders, said, “Tritium makes water, our sacred source of life, radioactive. We were shocked to learn that LANL’s compliance calculations did not take infants and other children into account.”
In 2020 the All Pueblo Council of Governors distributed a press release titled “Pueblos Concerned about Los Alamos National Laboratories Planned Release of Radioactive Vapors.”
For more information, read Searchlight New Mexico’s June 2024 article about LANL tritium venting.
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Communities for Clean Water (CCW) contracted the German engineering firm Ingenieurbüro Rau to do Weather Modeling to see the impact that the Tritium Venting could have on rainwater, surface water and groundwater in the case of weather events (rain/wind) during venting.
Weather Modeling Report by Matthias Rau, Ingenieurbüro Rau
The present report “examines the dispersion and environmental impact of tritium released during the venting of Flanged Tritium Waste Containers (FTWCs) at Los Alamos National Laboratory (LANL).”
“The primary goal of the study is to assess how tritium disperses in the air and how it deposits through precipitation. This evaluation is critical for understanding the potential contamination risks at nearby locations, such as La Vista Church (2.2 km from the release site) and the Rio Grande River (5 km away).”
In Rau’s Conclusion, he states:
“The probability of high tritium deposition at the nearest receptor locations is relatively low, as rain events from the critical wind direction (west-northwest) are infrequent.
However, significant tritium release into the environment occurs during venting, with potential implications for local water bodies and ecosystems.
The report emphasizes the need for careful monitoring and potential mitigation measures to limit environmental exposure.”
That said, in a rain event, the amount of tritium released would contaminate local water bodies, including the Rio Grande, well above both the drinking water standard and the New Mexico surface water guideline. It would also contaminate groundwater and streams other than the Rio Grande in the area.
Read the report below:
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Dr. Arjun Makhijani with the Institute for Energy and Environmental Research (IEER) wrote a summary report of Matthias Rau's Weather Modeling document, in which he compares Rau's results to both national and New Mexico water standards and guidelines.
The main findings in Dr. Makhijani’s report are as follows:
“The U.S. Environmental Protection Agency (EPA) drinking water standard is a common reference value for understanding water contamination. For tritium, it is 20,000 picocuries per liter (pCi/L). In New Mexico, there is also the reporting guideline for surface water in the Rio Grande downstream of Los Alamos; it is 4,000 pCi/L. This short report interprets the Rau and Winkler (2025) modeling results in terms of these reference values.
Rainwater contamination on the venting day: The venting of the Flanged Tritium Waste Container (FTWCs) most loaded with tritium over one-day (24 hours) would, under specified adverse weather conditions, result in rainwater contamination at White Rock between 750 and 3,500 times the drinking water standard and between 3,750 and 17,500 times the New Mexico guideline. Venting of all four FTWCs under similar conditions would create proportionately similar contamination of rainwater to hundreds to thousands of times the two reference levels.
Annual average contamination: The drinking water standard and New Mexico guidelines would also be greatly exceeded even if the rainfall contamination were averaged over an entire year, assuming zero tritium releases on all days except those during which the ventings would be done.
Rio Grande contamination: Tens to hundreds of curies may be deposited in the Rio Grande River as a result of the ventings. A heuristic calculation of cumulative impact indicates that the Rio Grande may be seriously burdened with tritium as a result of the ventings.
Groundwater contamination: Tritium in rainwater would also contaminate groundwater as well as streams other than the Rio Grande in the area.
Los Alamos failure to evaluate groundwater impact: Los Alamos National Laboratory is required to assess groundwater impact under DOE Order 458.1. It has not done so.”
Read the report below: