Due to the myriad of technical flaws that occurred during the October 20^th virtual meeting on the proposed and controversial venting of 114,000 Curies of radioactive tritium from Los Alamos National Laboratory (LANL), the Department of Energy (DOE) committed to holding a second virtual meeting.  It may be held as early as next Tuesday, October 27^th.  CCNS will post alerts on our social media network once a date and time has been determined.

Over 150 people attended the virtual meeting.  Many people left early due to the uncontrollable feedback and a variety of problems with the powerpoint.  The session was recorded.  If requested, the session will be translated into Spanish.  The PowerPoint and other information are available at https://www.lanl.gov/environment/ , under “Resources.”

Pete Maggiore, a Senior Advisor and Acting DOE Assistant Manager at LANL, hosted the meeting.  The meeting was held only to receive public comments and questions.  DOE did not provide responses.  Maggiore hoped to respond to all comments in writing before the next virtual meeting.

Brian Watkins, a subject matter expert, presented a 14-slide PowerPoint.  https://www.lanl.gov/environment/flanged-tritium-waste-containers.php

He described the four Flanged Tritium Waste Containers, called FAT WACS, which are about 51-gallon stainless steel pressure vessels.  One FAT WAC can hold four to five smaller containers, called AL-M1s.  Watkins said only the gas in the larger container, or the headspace gas, would be vented.

After Watkins’ presentations, those who wanted to speak were given two minutes each.  Jay Coghlan, of Nuclear Watch New Mexico, observed that an analysis of alternatives to the venting has not been publicly released and that the New Mexico Environment Department has not seen it.  https://nukewatch.org/

Beata Tsosie, Coordinator of Tewa Women United’s Environmental Health and Justice Program, said she does not consent to the continuing desecration of her homelands and ancestral sites.  Because there is no safe level of exposure for tritium, Tsosie expressed her concern for pregnant women being exposed to the vented tritium.  She suggested that Indigenous and western technology and science come together to figure our how to cleanup LANL’s radioactive, toxic and hazardous waste mess.  https://tewawomenunited.org/

Cynthia Naha said that the federal government had not fulfilled its trust responsibilities to the Pueblos as evidenced by the fact that the downstream Pueblos of Cochiti, San Felipe, and Santa Ana had not heard anything about the proposed venting.

Dee Finney, a public health nurse living 20 miles downwind of LANL, expressed concern about emergency preparedness and notification procedures during the pandemic. She asked whether there is an evacuation plan.  She also asked to see the analysis of alternatives to venting.

Leona Morgan, a co-founder of the Albuquerque-based Nuclear Issues Study Group, said she does not consent to the venting, which she described as an example of environmental racism.  https://www.facebook.com/NuclearIssuesStudyGroup/

Carol Miller, a public health advocate, summarized the feelings of many of the commenters by saying, “We don’t want it.”

Cindy Weehler, a retired chemistry teacher, said that while LANL claims it is a “world class laboratory,” the virtual meeting was operated like the Keystone Cops.  She pointed to LANL’s failure in allowing the drums to become pressurized and said the penalty should belong to LANL.  She said, “This is your fault, not the public’s.  Someone at LANL made a poor decision,” and LANL needs to make decisions now that won’t harm the public.

Joni Arends, of CCNS, asked what plan LANL has for when the international Treaty on the Prohibition of Nuclear Weapons goes into effect. https://www.un.org/disarmament/wmd/nuclear/tpnw/

Forty-seven nation states or countries have signed and ratified the Treaty – only three more are needed for it to go into effect.  https://www.icanw.org/

The Treaty was modeled after the Convention on the Prohibition of the Use, Stockpiling, Production and Transfer of Anti-Personnel Mines and on Their Destruction (or Mine Ban Convention) https://www.un.org/disarmament/convarms/landmines/

and the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction https://www.un.org/disarmament/wmd/chemical/  , which challenged countries that still possessed those weapons.  Arends asked how LANL would address the economic harm that could occur to the workers, families and communities that have supported LANL once the Treaty goes into effect.  She asked again, “What’s the plan?”  http://nuclearactive.org/

To submit your comments electronically to LANL, email FTWC_publicinfo@lanl.gov.

Did You Know about These Opportunities to Get Involved?

1. Saturday, October 24^th – NM Environment Department’s Temporary Authorization (TA) for construction of the new Shaft and underground disposal rooms at the Waste Isolation Pilot Plant (WIPP) expires. Criteria for issuing TAs require that the project be completed within 180 days.

The Department of Energy and WIPP asked for the reissuance of the 180-day temporary authorization.  What will NMED do?  Violate the procedural due process rights of groups like CCNS who asked for a public hearing about the new shaft?  or proceed ahead with DOE/WIPP requests for reissuance of the temporary authorizations for another 180 days?  Comments to the NMED Hazardous Waste Bureau Chief Kevin Pierard – Kevin.Pierard@state.nm.us

2. Monday, October 26^th at 3 pm (virtual public meeting) and 6 pm (virtual public hearing) about the Environmental Protection Agency (EPA) draft permit for over 400 sites at LANL with the potential to discharge pollutants during stormwater events. To see the public notice, the draft permit, along with information about registering for the virtual meetings – https://www.epa.gov/nm/lanl-storm-water-individual-permit-draft-permit-no-nm0030759

            To register for the public meeting:  https://www.epa.gov/nm/forms/registration-form-virtual-public-meeting

            To register for the public hearing – which is required by Friday, October 23^rd if you want to submit an oral statement and data about the proposed permit: https://www.epa.gov/nm/forms/registration-form-virtual-public-hearing

Public comments due on Monday, November 2^nd – see No. 5 below.

3. Thursday, October 29^th from 6 to 8 pm – Sandia National Laboratory (SNL) and Kirtland Air Force Base (KAFB) Semi-Annual Public Meeting about their environmental programs and the proposed SNL Chemical Waste Landfill Post-Closure Care Permit Renewal. For more information, the meeting agendas and presentations:

SNL – https://www.sandia.gov/about/environment/environmental_management_system/public_meetings.html

KAFB – https://www.kirtland.af.mil/Home/Environment/

4. Friday, October 30^th – Cold War Patriots 12^th National Day of Remembrance – Virtual Ceremony. Register at https://coldwarpatriots.org/

5. Monday, November 2^nd – public comments due to EPA about two draft discharge permits for LANL under the Clean Water Act National Pollutant Discharge Elimination System (NPDES). Sample public comments you can use will be available at http://nuclearactive.org/ after the October 26^th EPA public meeting and hearing.

6. Tuesday, November 3^rd – VOTE!

7. Tuesday, November 3^rd – Comments due to the Nuclear Regulatory Commission (NRC) about the proposed consolidated interim storage facility at Waste Control Specialists/Interim Storage Partners (WCS/ISP) for high-level radioactive waste from nuclear power plants on the TX/NM border, five miles east of Eunice, NM.  Information and sample public comments available here:  http://nonuclearwasteaqui.org/ , http://www.beyondnuclear.org/radioactive-waste/ , https://www.sierraclub.org/texas/blog/2020/09/high-level-radioactive-waste-dump-could-come-texas , and https://www.nirs.org/campaigns/dont-waste-america/

During the devastating global pandemic government plans are proceeding to expose the public to more radiation generated by the nuclear industrial complex.  There are actions you can take to stop the two proposals.  The first is by Los Alamos National Laboratory (LANL) to vent 114,000 Curies of radioactive tritium into the air, and the other, is by the Nuclear Regulatory Commission (NRC) to reinterpret its own regulations that would allow “low-level” radioactive waste to be dumped in unlicensed and unregulated facilities.  Public comments are due to the NRC on Wednesday, October 21^st.  https://www.nrc.gov/waste/llw-disposal/transfer-vllw.html

On Tuesday, October 20^th at 5 pm Mountain Daylight Time, LANL is hosting a virtual public information session about its proposed venting of radioactive tritium.  To register for the phone-in and WebEx event, please email your name and organization to FTWC_publicinfo@lanl.gov. LANL Media Advisory FTWC 10-8-20

LANL announced its plans to vent in early March.  Extraordinary public opposition met those plans.  http://nuclearactive.org/take-action-lanl-plans-to-release-radioactive-tritium/ (9/10/20);  http://nuclearactive.org/lanl-plans-to-release-twice-the-amount-of-tritium-allowed/ (3/26/20); https://tewawomenunited.org/?s=tritium+venting

LANL withdrew its proposal.  http://nuclearactive.org/lanl-postpones-tritium-releases-due-to-global-pandemic/ (4/2/20)

LANL has asked the New Mexico Environment Department for a temporary authorization to conduct the venting.  CCNS objects to the issuance of a temporary authorization because it ignores the required public process.  Further, a temporary authorization is only good for 180 days.  There are several other, and larger, tritium-venting projects required by LANL contracts.  The current proposal is an attempt to piecemeal the venting work instead of revealing the scope of the entire project now.

On October 1^st, Senators Tom Udall and Martin Heinrich, and Representative Ben Ray Lujan wrote to LANL urging that a public information meeting be held for the local communities and Pueblos.  The letter recognizes the “difficulty accessing the Internet and lack of broadband in many communities in New Mexico,” which is another reason why the venting should not take place now. Letter LANL FTWC 10.01.2020

The NRC has been working for decades to allow for the disposal of “low-level” radioactive waste in unlicensed and unregulated facilities located across the country.  Previous proposals were named “Below Regulatory Concern.”  The latest proposal is named “Very Low-Level.”  This waste could include:  entire nuclear reactors and activated metal components and pipes from the reactor core. Other items could include radioactive gloves and booties contaminated with plutonium, cesium, strontium, and dozens of other biologically dangerous radioactive elements.

NRC’s proposal has the potential to let all of that waste be sent to general, or municipal, landfills, hazardous waste landfills, and incinerators.  However, contaminated metals may be recycled into consumer products.  https://www.nrc.gov/waste/llw-disposal/transfer-vllw.html

Colleagues at the Nuclear Information Resource Service, or NIRS, have prepared an electronic public comment that you can use to submit your comments.  https://www.nirs.org/radioactive-waste/llw/

1. Sat. Oct. 17^th – Women’s March https://womensmarch.com/

2. Tues. Oct. 20 at 5 pm – LANL Proposed Tritium Venting virtual public information session – see today’s Update.

3. Wed. Oct. 21^st at 10 am – NM Legislative Interim Radioactive and Hazardous Materials Committee virtual meeting. Topics include Carlsbad Brine Well, WIPP, Proposed Consolidated Interim Storage Facilities, and Sandia National Laboratories.  https://nmlegis.gov/Committee/Interim_Committee?CommitteeCode=RHMC

4. Wed. Oct. 21 – Comments due to NRC re: disposing of “Very Low-Level” waste in ordinary landfills, hazardous waste landfills, or in incinerators – see today’s Update.  Sample public comment available at https://www.nirs.org/radioactive-waste/llw/

5. Wed. October 21^st – Comments due to NNSA about the scope of the new Site-Wide Environmental Impact Statement (SWEIS) at Lawrence Livermore National Laboratory (located 50 miles east of San Francisco, CA).  For more information and a sample public comment letter, go to http://trivalleycares.org/

The Department of Energy (DOE) has approved its plans to increase plutonium pit production at Los Alamos National Laboratory (LANL) by 50 percent as a way to comply with what is described in the 2018 Nuclear Posture Review as a need for “an effective, responsive, and resilient nuclear weapons infrastructure” that can “adapt flexibly to shifting requirements.”

The Pentagon has stated it needs annual production of 80 plutonium pits, the triggers for nuclear weapons.  The DOE has approved its Supplement Analyses for four possible ways to execute this upgrade.  At LANL, DOE proposes upgrades to both LANL’s Plutonium Facility and the Radiological Laboratory Utility and Office Building which is part of the Chemistry and Metallurgy Research Replacement (CMRR) Project.

Despite a mission that has been re-directed and an expansion involving about $15 billion in upgrades for two major buildings and related infrastructure, DOE has decided not to undertake a new Site-Wide Environmental Impact Statement (SWEIS) for LANL.  https://www.energy.gov/nepa/downloads/doeeis-0380-sa-06-final-supplement-analysis and https://www.energy.gov/nepa/downloads/doeeis-0380-amended-record-decision  Neither our congressional delegation nor our Governor has voiced disapproval of bypassing the SWEIS.

On Wednesday afternoon, October 7th, a citizens’ hearing was held outside the New Mexico State Capitol Building. Testimony was taken about DOE’s dramatic expansion plans for LANL that involve an installation of the size and importance and with the attendant dangers of the closed nuclear weapons plant at Rocky Flats, Colorado. The event, which provided a place for dozens of citizens to express their opposition to DOE’s plans in Northern New Mexico, was sponsored by the Los Alamos Study Group.  http://www.lasg.org/

The DOE proposals are too broad and too expensive to go forward without an SWEIS with public review and comment opportunities.

Every day, new information is released about the increased hazards at LANL.  This week the Defense Nuclear Facilities Safety Board issued a new report about the inconsistent and inappropriate consideration of potential energetic chemical reactions, or explosions, involving transuranic waste stored at LANL.  The Board conducted an analysis of transuranic, or plutonium-contaminated, wastes stored at the Plutonium Facility, the old Chemistry and Metallurgy Research Facility, the Transuranic Waste Facility, and Area G and the potential for explosions.  It found that LANL has not fully analyzed for possible explosions involving transuranic waste stored at these facilities that would result in high exposures to workers and the public.  https://www.dnfsb.gov/documents/reports/technical-reports/potential-energetic-chemical-reaction-events-involving

The Board asked DOE to respond within 120 days.

1.  Two more Nuclear Regulatory Commission (NRC) teleconference public meetings about the Waste Control Specialists/Interim Storage Partners (WCS/ISP) proposal to bring 40,000 tons of high-level radioactive waste from nuclear power plants by rail to the west Texas/New Mexico border, five miles east of Eunice, New Mexico. For more information, fact sheets, transportation maps, and talking points:  http://nonuclearwasteaqui.org/ and http://www.beyondnuclear.org/centralized-storage/

At the two previous public comment sessions, people spoke in opposition to both WCS/ISP and Holtec.  Both NM and TX Governors have come out in opposition to both proposals.  https://www.currentargus.com/story/news/local/2020/10/06/texas-governor-greg-abbott-opposed-nuclear-waste-project-new-mexico/3628253001/

and  https://www.abqjournal.com/1480362/gov-argues-against-holtec-nuclear-storage-site.html

  a.  Th. October 8^th from 4 to 7 pm MST – call-in information available at:

            https://www.nrc.gov/pmns/mtg?do=details&Code=20201100

   b.  Th. October 15^th from 9 am to noon MST – call-in information available at:

https://www.nrc.gov/pmns/mtg?do=details&Code=20201101

Here are the call-in numbers: (888) 989-9268; Pass Code 5300047. Press *1 [star-one] as soon as you get through, or at any point, to get in line to submit verbal comments for 3-5 minutes. See NRC’s slideshow presentation here. See comprehensive action alert here. Help stop an environmentally unjust high-level nuke waste dump & thousands of Mobile Chernobyls nationwide!

2.  Celebrating Indigenous Peoples’ Day – Monday October 12^th events:

  a.  Sunday, Oct 11, 7 pm (Mountain Time)

Indigenous People’s Day LIVE: Wisdom, Art, & Activism

The International Indigenous Youth Council presents this virtual showcase filled with Indigenous artists, singers, dancers, activists & knowledge carriers from across Turtle Island.

   b.  Monday, Oct 12, 3:30 pm (Mountain Time)

Drive-In Event at The Downs in Santa Fe

Indigenous performers and artisans, vendors and food. Film “Neither Wolf Nor Dog” starts at 7:00 pm. Hosted by Motorama in partnership with the Santa Fe Indian Center.

3.  Wed. October 21^st – Comments due to NNSA about the scope of the new Site-Wide Environmental Impact Statement (SWEIS) at Lawrence Livermore National Laboratory (located 50 miles east of San Francisco, CA). For more information and a sample public comment letter, go to http://trivalleycares.org/

According to the Department of Energy (DOE), plans are under way to remove unused plutonium fuel from the Los Alamos National Laboratory (LANL). The uranium-plutonium fuel, containing around 26.4 kilograms (58.2 pounds) of weapon-grade plutonium, is called “mixed-oxide,” or MOX.  In a late-August document, DOE stated that the MOX fuel, produced in France for a program at the Savannah River Site (SRS), would be disposed of as transuranic waste and therefore go to the Waste Isolation Pilot Plant (WIPP).

At present the MOX fuel, in the form of pellets, is stored at LANL’s PF-4 plutonium facility.  DOE needs to empty PF-4 to have space for its planned annual production of up to eighty plutonium “pits”, or triggers, for nuclear weapons.

The DOE proposal to dispose of the useless MOX fuel pellets is unprecedented, but has been subjected to only a brief mention in an environmental analysis on pit production.  Tom Clements, director of SRS Watch, says, “The analysis conducted on the disposal of the plutonium fuel is totally inadequate and a full Environmental Impact Statement (EIS) must be conducted before any repackaging and shipment to WIPP. ”

One of Clements’ concerns about security of the disposal of MOX fuel pellets at WIPP is that safeguards on the material would be terminated and the weapon-grade plutonium would receive less monitoring.  Clements says, “As the MOX pellets contain enough purified plutonium for perhaps 10 nuclear weapons, steps must be taken to prevent access to the material during both repackaging and disposal.”

Clements believes the material must remain in secure storage at LANL’s PF-4 until a full EIS is prepared by DOE and the proposal is finalized.  Please see https://srswatch.org/wp-content/uploads/2020/09/SRS-Watch-news-on-MOX-LTAs-to-WIPP-September-23-2020.pdf for additional information and references. 

Clements also reports a second new development relating to plutonium. In a DOE fact sheet obtained on September 22, 2020, via the Freedom of Information Act, DOE revealed that 11.5 metric tons (25,353 pounds) of plutonium are stored at SRS.  DOE stated in a February 2020 letter to the SRS Citizens Advisory Board that the stored plutonium “is not posing any additional risks to communities surrounding the SRS.” Clements concurs with that assessment but says, “It appears DOE has plans to bring an additional 35 metric tons (77,162 pounds) of plutonium into South Carolina for processing, some of which could end up being stranded here as we saw with the failed MOX project.”

Clements observes that plutonium waste disposal activities are less safe than storage.  He says, “Those that claim imaginary risks of plutonium storage appear to be silent on the real long-term risks of nuclear processing and radioactive waste disposal activities at SRS.”  Please see https://srswatch.org/wp-content/uploads/2020/09/SRSW-news-on-SRS-plutonium-inventory-Sep-29-2020.pdf for additional information and references.   

1. Four Nuclear Regulatory Commission (NRC) teleconference public meetings about the Waste Control Specialists/Interim Storage Partners proposal to bring 40,000 tons of high-level radioactive waste from nuclear power plants by rail to the west Texas/New Mexico border, five miles east of Eunice, New Mexico. For more information, fact sheets, transportation maps, and talking points:  http://nonuclearwasteaqui.org/ 

   a. Th. October 1^st from 4 to 7 pm MDT –   https://www.nrc.gov/pmns/mtg?do=details&Code=20201097

      Teleconference: Bridge Number  (888) 989-9268  Pass Code 5300047

      Important:  Press *1 as soon as you get through, which allows you to talk when it’s your turn.

     Webinar: https://usnrc.webex.com/ 

Meeting number 199 125 5213

Password ISPDEIS

    b. Tues. October 6^th from noon to 3 pm MST   https://www.nrc.gov/pmns/mtg?do=details&Code=20201099

   c. Th. October 8^th from 4 to 7 pm MST    https://www.nrc.gov/pmns/mtg?do=details&Code=20201100

    d. Th. October 15^th from 9 am to noon MST   https://www.nrc.gov/pmns/mtg?do=details&Code=20201101

2. Fri. Oct. 2^nd – UN General Assembly will hold a High Level Meeting on the Total Elimination of Nuclear Weapons. Get Involved!  A sample letter you can send to your government encouraging them to participate in the October 2 meeting is available at https://www.unfoldzero.org/26-september-2020/#social   Names, emails, and twitter handles are also available.

On September 17th, the New Mexico Supreme Court issued a ruling on the legal challenge to temporarily authorize construction of a new shaft at the Waste Isolation Pilot Plant (WIPP).  The Supreme Court reversed a Court of Appeals decision that had thrown out the challenge.  Now, the Court of Appeals must proceed with considering the case.  But construction on the new shaft continues under the temporary authorization.  https://www.env.nm.gov/hazardous-waste/wipp/ scroll down to June 12, 2020 entries.   

The legal action was filed by Southwest Research and Information Center (SRIC) to overturn the authorization and stop the shaft construction.  http://www.sric.org/nuclear/wipp_litigation.php  On June 11th, the Court of Appeals dismissed the case.  The Appeals Court agreed with the New Mexico Environment Department and the Department of Energy (DOE) that the Court had no jurisdiction because the Environment Department had made no final decision to change the WIPP permit to allow the new shaft.  Now the Court of Appeals can take further action, which could include a ruling on a request to stop the construction, or the court could require additional briefs.

The fundamental question in the litigation is whether the Environment Department has illegally decided to issue a temporary authorization for the new shaft, since it has not held a required public hearing on a permit modification request for the new shaft.

SRIC, with support from hundreds of commenters on the draft permit, says that allowing the construction to begin has tainted the required public review, comment, and hearing process about whether the shaft should be permitted.  The Environment Department says that it  has not made a final decision to approve the new shaft and that the construction could be halted and reversed months after the construction began.  The new shaft is to be 30-feet in diameter and 2,200 feet deep.  Construction is expected to take 37 months.

On September 9th, before the Supreme Court’s order, DOE requested an additional 180-day temporary authorization to continue the new shaft construction. SRIC and others who have requested a hearing on the draft permit,  including CCNS, have strongly objected to the additional authorization and asked the Environment Department to stop the construction.

According to SRIC’s Don Hancock, “The new shaft would allow additional new underground rooms to physically expand WIPP for more waste than is legally allowed and for new types of waste.  The new shaft is one essential part of the DOE ‘Forever WIPP’ plan that many New Mexicans

oppose. ”

At nuclearactive.org, you can find a sample comment letter to tell the Environment Department that you object to a new authorization before the required public hearing process is completed.  WIPP New Shaft Comment Ltr 9-24-20

Did You Know Saturday, September 26^th is the International Day for the Total Elimination of Nuclear Weapons?   

A number of international organizations have joined together to establish #WeThePeoples2020, a platform for promotion of key UN and civil society events surrounding the 75^th anniversary of the United Nations, especially those between the International Day for Peace on September 21 (which is also the date of the UN 75^th Anniversary High Level Event) and the International Day of Nonviolence on October 2.

As part of its 11 Days of Global Unity, a number of international events and calls to action are taking place.  A calendar of events at https://www.unfoldzero.org/events/2020-09-21/   Here are a few:

Sat. Sept. 26^th – #WeThePeoples2020 and UNFOLD ZERO at https://mailchi.mp/unfoldzero/action-call-for-the-un-day-to-eliminate-nuclear-weapons?e=a35e310f72

There will be two Parts to accommodate different time zones. Part 1 is for folks in Asia/Pacific time zones.  Part 2 is for folks in Americas/Europe/Africa time zones, beginning at 11 am EDT, 9 am MDT.

Each Part will have three sessions.

Session 1: 10-12 presentations on nuclear disarmament issues
Session 2: Practical workshops on key approaches to nuclear disarmament, including using the arts, how to move the nuclear weapons budgets/investments to better things, and engaging key communities including youth, faith-based communities and policy makers.
Session 3: A panel discussion followed by Q&A on how to move the nuclear-armed states to relinquish nuclear deterrence and achieve a nuclear-weapon-free world.

For more information, go to:  https://mailchi.mp/unfoldzero/action-call-for-the-un-day-to-eliminate-nuclear-weapons?e=a35e310f72

Fri. Oct. 2^nd – UN General Assembly will hold a High Level Meeting on the Total Elimination of Nuclear Weapons.  A sample letter you can send to your government encouraging them to participate in the October 2 meeting is available at https://www.unfoldzero.org/26-september-2020/#social   Names, emails, and twitter handles are also available.

Tuesday, September 22nd is the last day to submit your comments to the Nuclear Regulatory Commission (NRC) about the Holtec International proposal to store all of the nation’s high-level radioactive spent fuel from commercial nuclear power plants in New Mexico.  The proposed Holtec site is located half way between Carlsbad and Hobbs, and 16 miles north of the Waste Isolation Pilot Plant.  Comments are needed about the draft environmental impact statement (DEIS).  https://www.nrc.gov/waste/spent-fuel-storage/cis/holtec-international.html, scroll down to Environmental Impact Statement.  A one-page sample comment letter you can use comes from Southwest Research and Information Center http://www.sric.org/ and is available at here in two formats: HOLTEC DEIS sample letter 9-17-20 WORD and HOLTEC DEIS sample letter 9-17-20 PDF

To learn more about the proposal, visit the Nuclear Issues Study Group’s Facebook page to view its “We Are Not a Wasteland” web series.  https://www.facebook.com/NuclearIssuesStudyGroup/videos  Episode One is about “Unpacking Holtec’s Proposal.”

https://www.facebook.com/537856386561307/videos/311435906545504

Among the major shortcoming of the proposal are that Holtec says that it wants to use the site for 120 years.  But the DEIS limits its analysis of environmental impacts to 40 years, which is clearly inadequate and not technically credible.  Since NRC has found that high-level radioactive waste can safely remain where it is for at least 120 years, that is a wiser choice for the next 40 years than packaging the waste and shipping it by rail through dozens of states – mostly in the eastern half of the nation – to New Mexico.  Since there is no permanent disposal site, it is likely that the waste at the Holtec site would never leave.

The DEIS omits discussion of Holtec’s plan to have the federal government own and pay for waste transportation which is not legal under current law.  Holtec has stated that it is lobbying Congress to change the law.  The NRC is not supposed to engage in lobbying, even though the federal agency does appear to support such a change in the law by encouraging the Holtec plan.

Because Holtec wanted NRC to hurry and issue a license to operate the facility, the NRC did not keep its promise to hold five in-person meetings in New Mexico.  Instead, it held inadequate and technologically challenged virtual meetings.

New Mexico Senators Tom Udall and Martin Heinrich wrote to NRC stating, “[t]here is no compelling public interest reason to justify this rush to replace meetings with virtual webinars, and this decision gives the Commission the appearance of valuing the preferences of a for-profit company looking to store highly dangerous nuclear waste over that of the public and their elected representatives.”

New Mexico Governor Michelle Lujan Grisham opposes the Holtec project because it “poses significant and unacceptable risks to New Mexicans, our environment and our economy.”  NM Governor Holtec Ltr 060719

1. TONIGHT Thursday, September 17, 2020 at 6 pm MDT – YOU’RE INVITED to an online ZOOM letter-writing party to HALT HOLTEC! Grab a drink and snacks and join us!  We’ll show you an easy way to take action. Together we can prevent environmental injustice and protect our health and safety!  And say hello to friends along the way. The link is https://tinyurl.com/NoNuclearWaste

Looking forward to seeing you!  Karen Hadden

SEED Coalition

karendhadden@gmail.com

For more information at www.nonuclearwaste.org

2. Tuesday, September 22nd – Public Comments are due to the Nuclear Regulatory Commission (NRC) about the proposed Holtec facility for ALL the nuclear plutonium fuel rods from nuclear power plants in the U.S. The proposed facility is located 16 miles north of the WIPP site, east of Carlsbad, NM.   Sample public comment letter at http://nuclearactive.org/  Email your comments to:   Holtec-CISFEIS@nrc.gov.

On Wednesday morning, the public was notified by Los Alamos National Laboratory (LANL) that releases of radioactive tritium could begin as early as Friday, September 11th.  LANL tried to launch this plan last March.  Communities organized against it and the project was halted. 

https://tewawomenunited.org/2020/09/action-alert-stop-radioactive-releases-at-los-alamos-national-laboratory , http://nuclearactive.org/lanl-plans-to-release-twice-the-amount-of-tritium-allowed/ , and http://nuclearactive.org/lanl-postpones-tritium-releases-due-to-global-pandemic/

If you were not signed up to receive emails from LANL’s Electronic Public Reading Room, you would not have received Wednesday morning’s notice.  https://eprr.lanl.gov/  [The subscribe button is on the lower left.]  The notice provided links to letters LANL submitted to the Environmental Protection Agency and the New Mexico Environment Department requesting permission to proceed with venting the four tritium containers.  The containers hold lead and an estimated 114,000 curies of radioactive tritium.

The tritium is in the form of tritiated water, which harms when it is inhaled or ingested.  https://ieer.org/article/energy-security/healthy-start-tritium-issue-38/

Now is the time of harvest.  People are outside and breathing deeply while they bring in the harvest.  The risk for breathing in particulates, pollutants, tritiated water, among other contaminants, has increased due to the COVID-19 global pandemic.  Smoke and ash from the Medio wildfire significantly contributed to poor air quality for weeks, which was finally knocked down on Tuesday night when the rain and snow arrived.  The link between increased COVID-19 death rates and air pollution are well known.

Even so, LANL, in its September 3rd, 2020 letter to the New Mexico Environment Department requesting a temporary authorization, states, “While these containers pose a minor, manageable hazard in their current configuration, they cannot be shipped without verifying headspace pressures have relieved, and pressure build up over time becomes increasingly more difficult to mitigate.”  LANL FTWC Venting to NMED HWB 9-3-20 

There is no emergency for LANL to get this work done.  Importantly, no alternatives to the venting have been proposed by LANL.  Yet the details of the activities have changed over the past six months.  The March 2020 reports said there was no place to dispose of the canisters off the LANL site.  Now the reports state there is.

On March 10th, 2020, LANL mailed an official public notice, which CCNS received.  Public Notice TA Resubmittal FTWCs 3-10-20  We have not received such a notice about the proposed venting to begin in September.

On April 1st, 2020, LANL sent an email to the Environment Department stating, “Venting of the [containers] is postponed indefinitely due to impacts of the COVID-19 pandemic.”  CCNS asks, “Why now?  The pandemic is not over.”  We question whether LANL’s April 1^st email was in reality an April 1^st joke.

CCNS has prepared a few short sample comments for you to use to take action.  It provides links for more information and contacts for regulatory officials, elected officials, and the media.  Please help spread the word and share this with your family and friends.   Sample Public Comments-LANL Tritium Venting 9-10-20

1. Friday, September 18^th – Public Comments are due to the
   

   (AP Photo/Albuquerque Journal)

   U.S. Environmental Protection Agency (EPA) about its LANL draft Clean Water Act’s National Pollutant Discharge Elimination System (NPDES) permit. CCNS will have sample public comments for you to use next week.

2. Tuesday, September 22nd – Public Comments are due to the Nuclear Regulatory Commission (NRC) about the proposed Holtec facility for ALL the nuclear plutonium fuel rods from nuclear power plants in the U.S. The proposed facility is located 16 miles north of the WIPP site, east of Carlsbad, NM.  http://www.beyondnuclear.org/centralized-storage/

Before the U.S. Army and the Manhattan Project exploded a one-hundred-ton pile of TNT on May 7, 1945 at the Trinity test site in south central New Mexico, the doctors were concerned about the impacts of radioactive fallout from the upcoming Trinity test that would occur on July 16^th. In order to investigate the anticipated fallout and its distribution, the one-hundred-ton pile was spiked with plutonium from the Hanford site as a tracer.  That fallout data is not publicly available.

The doctors created evacuation plans that were not used for the communities around the Trinity site.  They established arbitrary and ever-changing radiological exposure standards that would lead to evacuation.  The first standard would require evacuation at 50 times the official exposure limit.  Quickly that arbitrary standard was increased to more than 800 times higher than the official exposure limit established two decades later.

After the Trinity test, Dr. Louis Hempelmann, Director of the Health Group at the Los Alamos site of the Manhattan Project, said some people “were probably over-exposed [to the Trinity test], but they couldn’t prove it and we couldn’t prove it.  So we just assumed that we got away with it.”  Thus began the false narrative that no one was harmed from the overexposure to radiation from the Trinity test.

Nevertheless, this week, the National Cancer Institute continued the 75-year old false narrative with the release of a collection of six studies under the title, Study to Estimate Radiation Doses and Cancer Risks Resulting from Radioactive Fallout from the Trinity Nuclear Test.  https://dceg.cancer.gov/research/how-we-study/exposure-assessment/trinity  On the morning of Tuesday, September 1^st, the entire study was publicly released, with limited time to review it before the virtual briefing began.  While NCI said it would hold a second virtual briefing next week, many individuals and organizations plan to ask for more time to review the reports.

NCI claims that its study “provides the most comprehensive evaluation of the doses and risks from the Trinity detonation available today,” while acknowledging its significant limitations.  Those limitations impact data quality and the ability to assess cancer risk.  For instance, NCI reports that in 2017 it interviewed 210 New Mexicans over the age of 70 years about their diet, lifestyles, housing, sources of drinking water, and how much time they spent outside during the summer months.  That is an insignificant percentage of the estimated 580,000 people living in New Mexico in 1945.

Even so, NCI projected that between zero and 1,000 excess cancers would occur between 1945 and 2034.  NCI qualifies its projection by the statement, “Precise value[s] cannot be determined decades after exposure.”  https://www.youtube.com/watch?v=2AqzvIHJQzs&feature=youtu.be

1. Wed. Sept. 9^th beginning at 10 am, the NM Radioactive & Hazardous Materials Interim Committee meets via video conference to discuss LANL issues, receive an update about the KAFB Bulk Fuel Spill, and receive public comments around 3 pm. At 1:15 pm – Joni Arends, of CCNS will be on a panel with Beata Tsosie-Peña, of Tewa Women United; and Greg Mello, of the Los Alamos Study Group, about LANL Operations and Expansion Community Concerns.  To see the latest version of the agenda, instructions to participate via video conference, and the handouts, go to https://nmlegis.gov/Committee/Interim_Committee?CommitteeCode=RHMC

2. Th. Sept. 10^th at 6 pm, the Nuclear Issues Study Group will host a presentation about the Holtec proposal to bring all the high-level radioactive nuclear waste to NM. Comments are due Tues. Sept. 22^nd to the Nuclear Regulatory Commission.  This is your opportunity to learn more to Halt Holtec.  https://www.facebook.com/NuclearIssuesStudyGroup/

3. Check out Stephanie Hiller’s recent article U.S. Patriarchy and the Bomb
   

   stephanie

   at https://www.transcend.org/tms/2020/08/u-s-patriarchy-and-the-bomb/

A Tuesday, September 1^st virtual briefing by the National Cancer Institute about their Study to Estimate Radiation Doses and Cancer Risks Resulting from Radioactive Fallout from the Trinity Nuclear Test is set to re-traumatize the Trinity Downwinders and their families.

In 2013, when the National Cancer Institute (NCI) first met with members of the Tularosa Basin Downwinders Consortium to discuss their proposed study, the Downwinders were more than willing to help.  The Downwinders believed that the federal government had finally decided to return and document the harm done to the People of New Mexico by the first atomic bomb test on July 16, 1945 at the Trinity Test Site.  https://dceg.cancer.gov/research/how-we-study/exposure-assessment/trinity

Over a short amount of time, that trust evaporated.

Early on, NCI promised the Downwinders that they would be able to review the draft reports NCI would prepare for publication.  NCI paid the Downwinders and others to assist them in obtaining the crucial support of Tribal and Pueblo entities that would allow them to move forward.  However, once NCI had the Tribal and Pueblo resolutions, they limited communication with the Downwinders.

Nevertheless, the Downwinders offered a list of concerns about the study and requested that it include the Hispanic members of the communities living adjacent to the Trinity site.  They also queried whether the study could identify enough sources to adequately report about 1945 lifeways firsthand because the number of people still living who could share their memories was limited.

As the study proceeded, the Downwinders registered further concerns.  One question was how the NCI would address the re-suspension of particulate matter from the heavy windstorms that exist in New Mexico.  They also asked about an NCI questionnaire that was about 1945 food sources.  It was clear to the Downwinders that the research done by NCI had not utilized local experts to learn about the lifeways of Native People and Hispanics and how they accessed food in 1945.

In short, it was not clear that the NCI would be responsive to the Downwinders’ questions.

NCI will release six papers about their study on September 1^st at 8 am Mountain Daylight Time (MDT).  Those people who register for the virtual briefing will receive digital copies of the six papers by email immediately following publication.  A short summary of the six papers, in both English and Spanish, will also be emailed.

The September 1^st one-hour virtual briefing will begin at 2:30 Mountain Daylight Time (MDT).  After a welcome, opening prayer and introductory remarks, a pre-recorded presentation by the principal investigator Dr. Steve Simon will give an overview of the study results.  Finally, thirty minutes is scheduled for questions and discussion.  To register for the virtual briefing, go to https://www.surveymonkey.com/r/F5DCQSW.    

NCI is planning to host a second video conference the week of September 7^th.

Tina Cordova, co-founder of the Tularosa Basin Downwinders Consortium, said, “We’ve been waiting seven years for the NCI to complete and release this million dollar study.  We can only hope it tells the truth about what we all know to be true from our lived experiences and from what science now reflects and supports.”  https://www.trinitydownwinders.com/

The Nuclear Regulatory Commission (NRC) provided the wrong links in their HOLTEC webinar public notice about how the public could connect to yesterday’s (August 25, 2020) presentation– thus disenfranchising the public to participate in the webinar.  Below are the corrected links for today’s (August 26, 2020) webinar, and the Tuesday, September 2, 2020 webinar:

*****Note: Corrected hyperlinks to NRC’s WebEx site*****

SUBJECT: U.S. Nuclear Regulatory Commission to Conduct Public Online Webinars for the Draft Environmental Impact Statement for the proposed Holtec HI-STORE Consolidated Interim Storage Facility – August 26, and September 2, 2020

The U.S. Nuclear Regulatory Commission (NRC) will conduct additional public meetings via webinar soliciting comments on a draft Environmental Impact Statement (EIS) for Holtec International’s (Holtec) proposed Consolidated Interim Storage Facility (CISF) for spent nuclear fuel in Lea County, New Mexico.  The draft EIS evaluates potential environmental impacts of Holtec’s request to build and operate the proposed CISF.

The public meeting webinars will be accessible to the public by navigating, on the day and time of the meeting, to the internet link below and entering the event number and password associated with the date of the webinar when prompted.  Telephone access will be required for the audio portion of the meetings and is available by dialing the telephone number and entering the passcode provided below.  The NRC staff will present the results of the draft environmental impact analysis and receive the public’s comments on the draft report.  The NRC invites members of the public to attend the public meeting webinars and to present oral comments on the draft EIS.

Wednesday, August 26, 2020 – 4:00 pm MT (6:00 pm ET)

Webinar:

Event address: https://usnrc.webex.com/

Event number: 199 278 6216

Event password: HOLTEC

Telephone access:

Phone number: 888-566-6509

Passcode: 1904459

Wednesday, September 2, 2020 – 9:00 am MT (11:00 am ET)

Webinar:

Event address: https://usnrc.webex.com/

Event number: 199 183 5099

Event password: HOLTEC

Telephone access:

Phone number: 888-566-6509

Passcode: 1904459

The public may also submit written comments on the draft EIS before September 22, 2020.  Members of the public can provide comments by any of the following methods:

• • E-mail to  Holtec-CISFEIS@nrc.gov
  • Online at  https://www.regulations.gov/ (search for Docket ID NRC-2018-0052)
  • US Mail to the following address: Office of Administration, Mail Stop:  TWFN-7-A60M, ATTN:  Program Management, Announcements and Editing Staff, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001

The draft EIS can be found on the NRC public webpage for the Holtec CISF license application at https://www.nrc.gov/waste/spent-fuel-storage/cis/holtec-international.html.  If you do not have internet access, contact the NRC Public Document Room at 800-397-4209 for assistance.  Questions regarding the draft EIS should be directed to Jill Caverly at 301-415-7674 or at Jill.Caverly@nrc.gov.

The Nuclear Regulatory Commission (NRC) is processing the license application for Holtec’s proposed Consolidated Interim Storage Facility.  Holtec, a for-profit corporation, proposes building a facility for all of the nation’s commercial high-level irradiated nuclear fuel in Lea County 16 miles north of the Waste Isolation Pilot Plant.  Before the pandemic, the NRC had committed to receiving pubic comments on the draft Environmental Impact Statement for the facility at five in-person meetings held around the state.  Now, with the need for social distancing, the NRC plans to replace in-person meetings with four public online webinars, scheduled for August 20^th, NRC 8-20-20 Holtec Hrg, which is behind us, as well as on Tuesday and Wednesday, August 25^th NRC 8-25-20 HOLTEC HRG and 26^th NRC 8-26-20 HOLTEC HRG and Wednesday, September 2^nd NRC 9-2-20 HOLTEC HRG.  NRC also will not extend the comment period beyond the current date of Tuesday, September 22^nd.

Both the New Mexico Senators and the public have registered opposition to replacing in-person hearings with webinars.  A coalition of citizens’ groups urges individuals who make comments at the NRC webinars to say, “I’m making these comments under protest because the comment period should be extended until after the Public Health Emergency ends; the hearings must occur in-person at site locations in New Mexico; and the New Mexico’s Congressional Delegation or staff be included to verify the validity of the hearing format.”  Those who wish to protest might also say, “Every state in the nation has clearly said ‘no’ to hosting a storage site for this waste.  The People of New Mexico also say ‘no.’”

In a joint letter to the NRC dated August 18^th, Senators Tom Udall and Martin Heinrich, say, “The health and safety of New Mexicans as well as their ability to participate in a process that will ultimately impact them is much greater than the needs of any corporation seeking to have expeditious closure on its application.”  The Senators observe, “[T]here are no legal or statutory deadlines requiring the Commission to rush to complete this review by any certain time.”  UDALL & HEINRICH – NRC Virtual Meetings – (8-18-20)

The Senators go on to argue that, “[T]his decision gives the Commission the appearance of valuing the preferences of a for-profit company looking to store highly dangerous nuclear waste over that of the public and their elected representatives.”

Finally, the Senators ask the Commission to delay their decision on the license application, “[U]ntil such time as the pandemic is under control enough that the Commission is able to safely and effectively live up to its commitment of in-person meetings in New Mexico.”

1.  Fri. Aug. 21st through Th. Aug. 27th at 6 pm MDT – free screenings of the newly restored “Dark Circle,” created 40 years ago.   https://metrograph.com/

It is a “terrifying and moving documentary about the catastrophic power of nuclear energy” and the manufacture of nuclear weapons at the Rocky Flats Plant, west of Denver, Colorado.  Directed by Judy Irving, Chris Beaver and Ruth Landy.  Don’t miss this opportunity to view this important documentary.  Is this what LANL is, or could become with the proposed increase in plutonium pit production?

2.  Wed. August 26th – 100th anniversary of the ratification of the 19th Amendment that ensured the right to vote could not be denied based on gender.

To view the Proclamation in its entirety, click Proclamation Women’s Suffrage Month August 2020

To celebrate, check out the following events:

Sun. Aug. 23 at 2 pm sharp:  A Car Parade in Santa Fe – Meet in PERA parking lot across from Capitol. Proceed north on Santa Fe Trail toward Plaza. Take right on San Francisco, left on Cathedral Place, left on Palace, right on Lincoln past City Hall, left at Federal Court Building, left on Grant Avenue passing Santa Fe County Administrative Complex on the right and Nina Otero Warren’s House at 135 Grant. Honk twice and then return to the PERA parking lot.

Tues. Aug. 18 – Wed. Aug. 26:  100 Years Celebration – Centennial Online Event Honoring Women’s Right to Vote, a week-long virtual celebration.  The event, sponsored by the State of New Mexico, the City of Albuquerque, and the NM League of Women Voters, will feature a multitude of virtual activities and entertainment including poetry, music, photos, and history about women, by women.  The program will be broadcast on GOV-TV (Channel 16) and ABQ Special Events will broadcast the event on Facebook, Instagram, or Twitter. You’ll be introduced to a Suffragist daily throughout the celebrations and be able to play games while learning about the Women’s Suffrage Movement.

3.  Sun. Aug. 30th – deadline to submit your origami crane with a Message of Peace to the National Park Service. The cranes will be placed into a time capsule and opened in 2045 – the 100th year since the first atomic bombings.  https://www.nps.gov/mapr/learn/historyculture/messages-of-peace.htm