On Wednesday, protesters gathered at the St. Francis of Assisi statue at the Santa Fe City Hall to express opposition to any participation in Midtown Santa Fe by Los Alamos National Laboratory (LANL) as a master developer or as a tenant in any of the other six proposals.  Although the proposals have not been made public, it is understood that the National Nuclear Security Administration, Department of Energy (DOE), and LANL have submitted proposals to participate fully at the potentially expanding 66-acre site between Cerrillos Road, St. Michael’s Drive, Siringo Road, and Camino Carlos Rey.  While the City’s website states that the City will announce the finalists on January 15^th, as of this writing, the announcement has not been made.  https://www.santafenm.gov/media/rfps_docs/RFEI_20.05_.P__Real_Estate_Developers_and_or_Business_Entities_.pdf, p. 6.

Organized by the Los Alamos Study Group, nearly 50 people participated in the peaceful protest.  Greg Mello, Director of the Study Group, explained that because of safety lapses involving nuclear criticality, the City Council passed a resolution in 2018 opposing planned expanded production of the plutonium cores, or pits, for nuclear weapons at LANL.  https://www.lasg.org/  The plans of the Commander-in-Chief and DOE involve increased plutonium pit production from an authorized 20 per year to 30 per year – an increase of 50 percent.  In December, Congress approved $712 million in increased funding for this work.  https://www.heinrich.senate.gov/in-the-news/final-defense-budget-nearly-doubles-spending-on-pit-production

At the protest, Jim Eagle, a retired Navy officer who served on nuclear submarines, said, “If you’re against the nuclear mission, you’re against the training of the workforce and administrative support.”

There is little room in Los Alamos County for the needed housing and services for the projected 1,000 employees a year that LANL plans to hire over the next five years.  DOE wants to create a New Mexico Innovation Triangle with Midtown nearly halfway between LANL and Sandia National Laboratories in Albuquerque.  https://www.santafenewmexican.com/news/local_news/santa-fe-receives-proposals-to-redevelop-midtown-campus/article_ec2199c2-5228-5b83-a2c4-7c1241e704a9.html

Further, the Midtown Santa Fe is designated as an Opportunity Zone.  In 2017, Congress, under the Tax Cuts and Jobs Act, created these zones.  Under the law, governors are allowed to nominate certain census tracts as Opportunity Zones.  The New Mexico Economic Development Department describes the status this way:  “Designation as an Opportunity Zone allows for the creation of a new class of investment vehicle with tax advantages authorized to aggregate and deploy private investment located in Opportunity Zones.  The purpose of these tax advantages is to attract capital investment into economically distressed areas.”  https://gonm.biz/business-development/edd-programs-for-business/finance-development/opportunity-zones

The City announced that a new public input process would begin in February and continue into March and April.  https://www.santafenewmexican.com/news/local_news/city-closing-in-on-short-list-of-master-developers-for/article_44b98796-33e2-11ea-ac64-7b0e61acfffb.html

Joni Arends, of CCNS, said, “Regardless of whether LANL is a master developer finalist or a tenant in another finalist development, it is time to get involved in the Midtown process.”

1. Your financial support makes a difference!  Please help CCNS with an end-of-the-year tax-deductible contribution or a monthly sustaining donation.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We need your contribution to continue keeping you informed through our weekly broadcast and social media postings.  There’s a lot of work to be done in 2020 – and many proposals to expand operations (a new shaft at WIPP; expanded pit production at LANL; Radiation Exposure Compensation Act through House Memorial 5, etc.) are already on the table.  Stay informed with the CCNS Media Network!  Many thanks!

2. Thursday, January 16th – THIS MEETING WAS CANCELED DUE TO WEATHER.  EPA WILL RESCHEDULE IT.  The Environmental Protection Agency (EPA) will host a public meeting (beginning at 5 pm) and hearing (beginning at 7 pm) about the LANL Individual Stormwater Permit renewal at the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  This permit covers 405 site monitoring areas with the potential to discharge pollutants every time it rains or snows.  Come to the meeting to question why EPA has not required LANL to remove the pollutants from the ground.  https://www.epa.gov/nm/lanl-storm-water-individual-permit-draft-permit-no-nm0030759

3. Tuesday, January 21 at noon – The 2020 New Mexico Legislature begins its 30-day session.  To learn more, go to https://www.nmlegis.gov/

Training opportunities are available at the Center for Progress and Justice at  https://www.facebook.com/Center-For-Progress-and-Justice-194361180574806/

4. Thursday, January 23rd and January 30th – The Waste Isolation Pilot Plant (WIPP) will hold public meetings about its yet-to-be-submitted application for renewal of the ten-year hazardous waste permit to the New Mexico Environment Department (NMED).

IN SANTA FE:   January 23rd from 5 to 7 pm at the Santa Fe Hilton, 100 Sandoval Street, Santa Fe

IN CARLSBAD:  January 30th from 5 to 7 pm at the Skeen-Whitlock Building, 4021 National Park Highway, Carlsbad

For more information and to view the draft hazardous waste facility permit, go to https://wipp.energy.gov/rcra-proposed-mods.asp 

5. Friday, January 31st at noon -11^th Annual “Witness for the People” in the rotunda of State Capitol in Santa Fe.  This event is organized by Interfaith Worker Justice- NM as the People of Faith State of the State address.  Music will be provided by Paul and The Tone Daddies. Confirmed speakers include Archbishop John C. Wester; Lt. Governor Howie Morales;  Representative Angelica Rubio (sponsor of House Memorial 5, entitled “Individuals Exposed to Radiation Support,” which urges the New Mexico Congressional delegation to pass the proposed amendments to the federal Radiation Exposure Compensation Act (RECA)) ; Marian Naranjo, of Honor Our Pueblo Existence; Tina Cordova, of the Tularosa Basin Downwinders Consortium, also known as the Trinity Downwinders; and Ken Mayers with Veterans for Peace.  For more information, please contact The Reverend Holly Beaumont at hbeaumont@iwj.org  http://nuclearactive.org/trinity-hiroshima-nagasaki-commemoration-events-in-nm/

The City of Santa Fe released a request for expressions of interest for developing the old College of Santa Fe campus in what is now called “Midtown Santa Fe.”  The request directed to real estate developers and business entities is very detailed.  But the request does not require a detailed process for public review, comment, and participation of the proposals.  Many are questioning why.

An unqualified Los Alamos National Laboratory (LANL), along with the National Nuclear Security Administration and Department of Energy, has submitted more than one proposal to be the Master Developer or perhaps a tenant in other proposals.  The request asks for Developers with experience in higher education, civic use, residential and mixed use, creative arts and design, entrepreneurship and new business, and open space and recreation.  However, LANL does not have this experience.  They have been cited again and again for poor safety and management.  In fact, LANL-related messes remain in Santa Fe.  They include the Nuclear Laundry http://www.nuclearactive.org/docs/laundryinfo.html , the abandoned Eberline Instruments facility https://www.sfreporter.com/news/news-coverstories/2017/09/28/nuclear-neighborhood-2/ and https://www.sfreporter.com/news/2018/10/29/congressman-requests-records-on-airport-road-nuke-facility/ , and most recently, the LANL contractors who brought contaminated roofing materials to the Caja del Rio landfill https://www.santafenewmexican.com/news/local_news/lanl-faces-state-penalties-over-waste-violations/article_a18a4fef-8542-5e11-bf74-72839d3bd5c3.html .

Midtown Santa Fe, a 66-acre parcel, which may be expanded to 100 acres, is located between St. Michael’s Drive, Siringo Road, Camino Carlos Rey, and Cerrillos Road, thus the name, “Midtown.”  https://midtowndistrictsantafe.com/ and https://www.santafenm.gov/midtown_site

Proposals were due on October 31^st.  Since then, an Evaluation Committee led by the Midtown Project Director Daniel Hernandez and includes directors of key city departments, has been reviewing and evaluating the proposals behind closed door.  There have been a few leaks:  articles in the Santa Fe New Mexican https://www.santafenewmexican.com/news/local_news/city-mum-on-proposals-for-santa-fe-s-midtown-campus/article_f25cef7b-ceab-524a-80bc-29e5896c75d6.html ; https://www.santafenewmexican.com/news/local_news/santa-fe-receives-proposals-to-redevelop-midtown-campus/article_ec2199c2-5228-5b83-a2c4-7c1241e704a9.html ; and https://www.santafenewmexican.com/news/business/developer-proposals-hint-at-what-s-in-store-for-city/article_2ec04f5c-156f-53fe-b034-9939ea167b4a.html as well as discussions at Journey, a Sunday morning public interest group, at Collected Works Bookstore.  https://www.journeysantafe.com/  [The Mayor spoke on January 12, 2020.]  But there has been no formal public comment process.  There is no community member on the Evaluation Committee.

The City plans to notify the finalists on Wednesday, January 15^th.  The Los Alamos Study Group announced its plans to hold a press conference that day at noon at Santa Fe City Hall.  For more information, go to https://www.lasg.org/

Cynthia Weehler, a community activist, spoke at this week’s City Council meeting.  She pointed out that the Mayor said at Journey that the City Council will “use what they learned” about what the public wants in order to make a decision.  She said, “Mayor, … if we were given an opportunity to inform City Council of our wishes it was not something most of us were aware of.  And this is my point: because we, the people of Santa Fe, will have to live with the consequences of that decision, including urban sprawl, traffic, and changed cultural goals of the city, it should not be your decision alone.  We have not been invited to the table, as we should have been.  Do not make this decision without getting the public’s input.”

1.  Your financial support makes a difference!  Please help CCNS with an end-of-the-year tax-deductible contribution or a monthly sustaining donation.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We need your contribution to continue keeping you informed through our weekly broadcast and social media postings.  There’s a lot of work to be done in 2020 – and many proposals to expand operations are already on the table.  Stay informed with the CCNS Media Network!  Many thanks!

   2.     Wednesday, January 15th -The Environmental Protection Agency (EPA) will host a public meeting (beginning at 5 pm) and hearing (beginning at 7 pm) about the

   LANL Industrial Wastewater Discharge Permit renewal at the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  The permit includes Outfall 051 for the Radioactive Liquid Waste Treatment Facility, which has not discharged since November 2010.  Come to the meeting to question why Outfall 051 remains on the permit.    https://www.epa.gov/nm/lanl-industrial-wastewater-permit-draft-permit-no-nm0028355-0

   3.    Thursday, January 16th – The Environmental Protection Agency (EPA) will host a public meeting (beginning at 5 pm) and hearing (beginning at 7 pm) about the LANL Individual Stormwater Permit renewalat the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  This permit covers 405 site monitoring areas with the potential to discharge pollutants every time it rains or snows.  Come to the meeting to question why EPA has not required LANL to remove the pollutants from the ground.  https://www.epa.gov/nm/lanl-storm-water-individual-permit-draft-permit-no-nm0030759

   4.    Tuesday, January 21 at noon – The 2020 New Mexico Legislature begins its 30-day session.  To learn more, go to https://www.nmlegis.gov/ 

   5.    Thursday, January 23rd and January 30th – The Waste Isolation Pilot Plant (WIPP) will hold public meetings about its yet-to-be-submitted application for renewal of the ten-year hazardous waste permit to the New Mexico Environment Department (NMED).

   IN SANTA FE:   January 23rd from 5 to 7 pm at the Santa Fe Hilton, 100 Sandoval Street, Santa Fe
   
   IN CARLSBAD:  January 30th from 5 to 7 pm at the Skeen-Whitlock Building, 4021 National Park Highway, Carlsbad

   For more information and to view the draft hazardous waste facility permit, go to https://wipp.energy.gov/rcra-proposed-mods.asp

Planning is ongoing to commemorate the 75 years since the U.S. atomic bombings at the Trinity Site in July 1945, and over Hiroshima and Nagasaki in August 1945.  Educational events to challenge the false narratives about the bombings will take place around New Mexico, along with proposed memorials in the New Mexico State Legislature.  To see an event listing click here…f 2020 Events 1-1-20  CCNS will update the 2020 Event Listing at least once a month and provide it with the first Update of the month.     

The opening event is the 11^th Annual “Witness for the People” on Friday, January 31^st at noon in the rotunda of the State Capitol in Santa Fe.  Organizer, Interfaith Worker Justice – New Mexico, says the event is the People of Faith State of the State address.  http://www.iwj.org/locations/new-mexico  Confirmed speakers include Archbishop John C. Wester https://archdiosf.org/about-archbishop-wester ; Lieutenant Governor Howie Morales https://www.ltgov.state.nm.us/ ; Representative Angelica Rubio https://www.nmlegis.gov/Members/Legislator?SponCode=HRUBI ; Marian Naranjo, of Honor Our Pueblo Existence https://honorourpuebloexistence.com/ ; Tina Cordova, of the Tularosa Basin Downwinders Consortium, also known as the Trinity Downwinders https://www.trinitydownwinders.com/ ; and Ken Mayers of Veterans for Peace https://www.santafenewmexican.com/news/local_news/santa-fean-arrested-after-anti-war-protest-in-ireland-back/article_c3d72554-17ce-11ea-91db-cf4a2f755dfb.html .  Paul and The Tone Daddies will provide music.  http://paulpino.com/tone-daddies/  For more information, please contact The Reverend Holly Beaumont at hbeaumont@iwj.org.

Representative Rubio pre-filed House Memorial 5, entitled “Individuals Exposed to Radiation Support,” which urges the New Mexico congressional delegation to pass proposed amendments to the federal Radiation Exposure Compensation Act that would include the Trinity Downwinders and the Post’71 Uranium Workers.  After the Witness for the People event, participants will encourage their legislators to support House Memorial 5.  https://www.nmlegis.gov/Legislation/Legislation?Chamber=H&LegType=M&LegNo=5&year=20

In August, three national conferences focused on commemorating the U.S. bombings will take place in New Mexico.  The public is invited to attend one or more of the conferences.  Please be sure to register beforehand.

The Veterans for Peace National Conference runs from August 5^th through the 9^th in Albuquerque.  https://www.veteransforpeace.org/  The Upaya Zen Center begins its “Bearing Witness Memorial Sesshin:  Marking the 75^th Year Since the Nuclear Bombings” on August 5^th through the 10^th in Santa Fe.  https://www.upaya.org/program/bearing-witness-sesshin-the-75th-anniversary-of-hiroshima-and-nagasaki/?id=2209  The Campaign Nonviolence National Conference runs from August 6^th through the 9^th in Albuquerque.  https://paceebene.org/cnvconference2020  

The public is invited to join with the conference attendees at the commemoration events in Los Alamos.

On Thursday, August 6^th, the day the U.S. dropped an atomic bomb on Hiroshima, the public and conference participants will gather at Ashley Pond from 4 pm to 8 pm.  Beginning at 5 pm there will be a rally at the Main Stage with speakers, poets, and musicians.

On Sunday, August 9^th, the day the U.S. dropped an atomic bomb on Nagasaki, the public and conference participants will gather at Ashley Pond from 11 am to 3 pm.  From 1 to 3 pm there will be a rally at the Main Stage with speakers, poets, and musicians.

1. Your financial support makes a difference!  Please help CCNS with an end-of-the-year tax-deductible contribution or a monthly sustaining donation.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We need your contribution to continue keeping you informed through our weekly broadcast and social media network.  There’s a lot of work to be done in 2020 – and many proposals to expand operations are already on the table.  Stay informed with the CCNS Media Network!  Many thanks!

2. Thursday, January 9th – The New Mexico Environment Department (NMED) will host a public engagement meeting to discuss the 2016 Consent Order

for Los Alamos National Laboratory (LANL), which is between the Department of Energy and NMED.  The meeting will be from 5:30 to 7 pm at the University of NM – Los Alamos, 4000 University Drive, Bldg. 6, Room 631, Los Alamos, NM.  See the NMED news release in English and Spanish at  https://www.env.nm.gov/

If you need interpretation or assistance at the meeting, please contact Neelam Dhawan, of the NMED Hazardous Waste Bureau, at (505) 476-6042 or via email at Neelam.Dhawan@state.nm.us. 

3. Wednesday, January 15th -The Environmental Protection Agency (EPA) will host a public meeting (beginning at 5 pm) and hearing (beginning at 7 pm) about the

LANL Industrial Wastewater Discharge Permit renewal at the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  https://www.epa.gov/nm/lanl-industrial-wastewater-permit-draft-permit-no-nm0028355-0

4. Thursday, January 16th – The Environmental Protection Agency (EPA) will host a public meeting (beginning at 5 pm) and hearing (beginning at 7 pm) about the LANL Individual Stormwater Permit renewal at the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  https://www.epa.gov/nm/lanl-storm-water-individual-permit-draft-permit-no-nm0030759

5. Thursday, January 23rd and January 30th – The Waste Isolation Pilot Plant (WIPP) will hold public meetings about its yet-to-be-submitted application for renewal of the ten-year hazardous waste permit to the New Mexico Environment Department (NMED).

IN SANTA FE:   January 23rd from 5 to 7 pm at the Santa Fe Hilton, 100 Sandoval Street, Santa Fe

IN CARLSBAD:  January 30th from 5 to 7 pm at the Skeen-Whitlock Building, 4021 National Park Highway, Carlsbad

For more information and to view the draft hazardous waste facility permit, go to https://wipp.energy.gov/rcra-proposed-mods.asp

The Waste Isolation Pilot Plant (WIPP) will hold two public meetings about their draft hazardous waste permit application to renew the 10-year permit issued by the New Mexico Environment Department.  The Department of Energy and its contractor at WIPP, Nuclear Waste Partnership, LLC, are required to hold these meetings to inform the public about proposed changes to the hazardous waste management activities and to receive comments before they submit their application to the Environment Department.

This is the second renewal application WIPP will submit.  The first 10-year permit went into effect in December 1999.  It was renewed in December 2010.  The current permit expires on December 30, 2020.  The application is due 180 days before the permit expires, or on or before July 3^rd.

This draft application is 1,285 pages so it will take a while to review it before the public meetings occur in the second half of January.  https://wipp.energy.gov/Library/Information_Repository_A/DRAFT_2020_Renewal_Application.pdf

The first meeting will be held in Santa Fe on Thursday, January 23^rd from 5 to 7 pm at the Santa Fe Hilton, located at 100 Sandoval.  The second meeting will be held in Carlsbad on Thursday, January 30^th from 5 to 7 pm at the Skeen-Whitlock Building, located at 4021 National Parks Highway.  Public comments will be accepted through Monday, February 3^rd at infocntr@wipp.ws

Some of the proposed changes include moving provisions about dispute resolution; preparedness for emergencies and prevention of accidents; security; and characterization of the site from the main permit to the attachments.

WIPP is required to re-evaluate their 300-year Performance Demonstration by comparing the original application with subsequent applications.  The draft application states, “[T]he original analysis and the updated information reach the same conclusion that the only significant pathway for the release of hazardous waste or hazardous waste constituents from [WIPP] is the air pathway involving the release of volatile organic compounds from containers prior to final facility closure.”   

The New Mexico hazardous waste laws and regulations allow the Environment Department Secretary to request additional information to establish permit conditions that will protect human health and the environment.  For over a year, CCNS has been asking the Environment Department to require DOE to provide exposure information from WIPP operations, specifically the February 2014 release of radioactive and hazardous pollutants.  Apparently, the Secretary has not asked for such information because WIPP did not include it in their draft application.

Permit applications for both WIPP and Los Alamos National Laboratory (LANL) are due in mid-2020.  At a recent public meeting, LANL could not say when they will submit their application.  WIPP plans to submit theirs in March.

1. Your financial support makes a difference!  Please help CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We need your contribution to continue our weekly broadcast and social media work.  There’s a lot of work to be done in 2020 – stay informed with the CCNS Media Network!  Many thanks
2.  Friday, December 20th – The NM Environmental Improvement Board hearing on the proposed hazardous waste fee increases was completed.  The Board may render a decision at their next meeting on Friday, January 24, 2020.  The agenda has not been posted yet, but check back.    https://www.env.nm.gov/environmental-improvement/main-2/  Thank you to everyone who submitted comments.  They made a difference! 
3.  Thursday, January 9th – The New Mexico Environment Department (NMED) will host a public engagement meeting
   

    wjohnson@abqjournal.com

   to discuss the 2016 Consent Order for Los Alamos National Laboratory (LANL), which is between the Department of Energy and NMED.  The meeting will be from 5:30 to 7 pm at the University of NM – Los Alamos, 4000 University Drive, Bldg. 6, Room 631, Los Alamos, NM.   If you need interpretation or assistance at the meeting, please contact Neelam Dhawan, of the NMED Hazardous Waste Bureau, at (505) 476-6042 or via email at Neelam.Dhawan@state.nm.us.

4.   Wednesday, January 15th – The Environmental Protection Agency will host a public meeting (beginning at 5 pm)
   

    

   and hearing (beginning at 7 pm) about the LANL Industrial Wastewater Discharge Permit renewal at the Pojoaque Valley Sixth Grade Academy, 1574 State Road 502 West.  https://www.epa.gov/nm/lanl-industrial-wastewater-permit-draft-permit-no-nm0028355-0

On December 8^th, the New Mexico Environmental Law Center honored Joni Arends, Co-founder and Executive Director of CCNS, with the Griff Salisbury Environmental Protection Award at its annual Member Appreciation Party in Santa Fe.  The award recognizes an outstanding individual who has made significant contributions to the protection of New Mexico’s environment.  Since 1988, Joni Arends has been a leading voice against the nuclear weapons industry in New Mexico, including Los Alamos National Laboratory (LANL).  http://nuclearactive.org/   

The Law Center presented Joni with a handmade belt buckle engraved with the moon rising over the Ortiz Mountains, made by Reflective Jewelry.  https://www.reflectivejewelry.com/

The winner of the Law Center’s annual Toxic Turkey Award was LANL, for over seven decades of “polluting the human and natural environment and continuous violations of basic principles of environmental justice.”  The award is given to a person or group that has shown extraordinary disregard for New Mexico’s environment and the communities that live in it.

In announcing the award, staff attorney Jon Block pointed to the origins of LANL in the Manhattan Project to develop the first atomic weapons.  https://www.lanl.gov/  The federal government expropriated the sacred lands of the Peoples of the San Ildefonso and Santa Clara Pueblos as an isolated location for the secret laboratory.  LANL dumped hazardous chemical, metal and radioactive waste into the canyons running off the Pajarito Plateau and into hundreds of its dumps, all of which have since then contaminated the drinking water aquifer and the Rio Grande.

New Mexico’s Right to Know: The Potential for Groundwater Contaminants from Los Alamos National Laboratory to Reach the Rio Grande by George Rice 

Fact Sheet: New Mexico’s Right to Know: The Potential for Groundwater Contaminants from LANL to Reach the Rio Grande

The Law Center also gave awards to Tewa Women United and Norman Gaume.

Tewa Women United was awarded the Jeanne Gauna Community Environmental Advocacy Award for New Mexicans who have given significant time and effort toward grassroots advocacy for the welfare of our state’s communities, especially through the linkage of environmental health and community well being.  Kathy Wanpovi Sanchez, her husband J. Gilbert Sanchez, and their daughter Corrine Sanchez, were recognized for 30 years of representing a frontline community in the fight to protect sacred lands and the health of communities and the environment downstream and downwind from LANL.  http://tewawomenunited.org/

Norm Gaume, former director of the Interstate Stream Commission, received the Karl Souder Water Protection Award, which honors an outstanding individual who has made significant contributions to protection of New Mexico water.  Norm Gaume has been a leader in the efforts to prevent his former agency from moving forward with expensive and unrealistic plans to divert water from the Gila River.  Instead, he led the efforts to implement community-based plans intended to preserve the Gila.  https://www.krwg.org/post/gila-named-most-endangered-river

Douglas Meiklejohn, Executive Director of the Law Center, said, “The Law Center is proud to work with these organizations and individuals and to represent them in their efforts to force recalcitrant companies and agencies to be accountable to the people of New Mexico.”  https://nmelc.org/

1. Your financial support makes a difference!  Please help CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We need your contribution to continue our weekly broadcast and social media work.  There’s a lot of work to be done in 2020 – stay informed with the CCNS Media Network!  Many thanks!

   2.    Friday, December 20th, beginning at 9 am – the NM Env’l Improvement Board hearing on proposed Hazardous Waste fee increases in Room 309 at the Roundhouse.  See last week’s CCNS News Update for more info and a sample public comment letter in support of fee increases.  http://nuclearactive.org/nmed-proposes-to-increase-hazardous-waste-fees/

   Please get your letter in TODAY before the end of the hearing TOMORROW.  Industry is questioning the basis for the increases.  The Environment Improvement Board needs to know that the People support the fee increases.

   Happy Holidays to All!  Stay Safe!

For the first time in over 13 years, the New Mexico Environment Department is proposing to increase the fees for hazardous waste permits, review of cleanup documents, and hazardous waste business fees.  As a result, the New Mexico Environmental Improvement Board will hold a public hearing on Friday, December 20^th, beginning at 9 am, to hear from the public, the parties, and the Environment Department about the proposal.  The hearing will be held in Room 309 of the State Capitol Building, located at 490 Old Santa Fe Trail, in Santa Fe.  https://www.env.nm.gov/environmental-improvement/main-2/ and filings at https://www.env.nm.gov/environmental-improvement/eib-19-35-r/

CCNS has prepared a sample public comment letter you can use to support the proposed fee increases, which is available right here on our website.  Sample Public Comment HW Fees 12-12-19

The fee increases, if approved, will support the Department’s regulatory oversight of hazardous waste facilities that handle, treat, store, and dispose of hazardous waste.  The Department’s Hazardous Waste Bureau regulates 23 facilities, including Department of Defense (DOD) and Department of Energy sites.  Twelve are commercial and private facilities, including the oil refineries in Artesia, Bloomfield and Gallup.  https://www.env.nm.gov/hazardous-waste/permitted-facilities/

The proposal includes an annual inflation adjustment based on the Consumer Price Index (CPI) for All Urban Consumers.  If approved, the fees would keep up with inflation.  The current fees do not reflect the actual costs for the Hazardous Waste Bureau to do its regulatory business to protect human health and the environment.  Use of the CPI would provide consistent support for the Compliance and Technical Assistance Management Program of the Hazardous Waste Bureau.

The Bureau is funded by various sources, including grants from the Environmental Protection Agency, permit fees, and the General Fund.  Fees generate between $240,000 to $300,000 annually.  From Fiscal Years 2012 to 2019, the Martinez Administration did not fund the Bureau’s operating budget from the General Fund.  As a result, the operating budget exceeded revenues, resulting in the evisceration of the Bureau.  https://www.env.nm.gov/environmental-improvement/eib-19-35-r/, Pleading Log No. 1. 

Under the hazardous waste regulations, the fees are deposited into the state’s budget under the hazardous waste fund, which supports the hazardous waste program.

Since the beginning of the year, the Bureau held a number of teleconferences and meetings with the regulated community.  The DOD is a party to the hearing, representing its seven sites across New Mexico.  They are concerned about the increases in fees, which they calculate would be millions of dollars annually.  https://www.env.nm.gov/environmental-improvement/eib-19-35-r/, Pleading Log No. 6.

One solution would be for the sites to carefully review their documents before submittal to the Bureau.  In some cases, the number of hours dedicated by Bureau staff to the thorough review of the submittals resulted in an hourly cost of less than $4 an hour.  https://www.env.nm.gov/environmental-improvement/eib-19-35-r/, Pleading Log No. 1.

1. Thank you to everyone who contributed on Giving Tuesday to our CCNS Media Network, which includes the weekly CCNS News Update and this email.  If you missed Giving Tuesday, please support CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We really need your contribution to continue our weekly broadcast and social media work.  Many thanks!
2.  Monday, December 16th at 5 pm – New Mexico Environment Department and Department of Energy Annual Plan for Cleanup of Los Alamos National Laboratory Legacy Waste at the Los Alamos County Council Chambers, 1000 Central Avenue, Los Alamos.  This public meeting is required by the 2016 Consent Order.
   Here’s a link to a recent posting of the Updated Fiscal Year 2020 Appendices A, B, and C to the Consent Order – https://ext.em-la.doe.gov/eprr/repo-file.aspx?oid=0902e3a6800c30b4&n=EMID-700658_FY20_Consent_Order_Apps_A,B,C_110719.pdf
3.  Tuesday, December 17th from 5:30 to 7 pm – LANL hosted Individual Stormwater Permit public meeting (semi-annual meeting required by the permit) at LA Golf Course, 4244 Diamond Drive, Los Alamos.  Topics include:

• status of Individual Stormwater Permit (IP);
• 2019 stormwater/precipitation results; and
• overview of the IP website

4. Friday, December 20th, at 9 am NM Env’l Improvement Board hearing on proposed Hazardous Waste fee increases.  Room 309 at Roundhouse.  See this week’s CCNS News Update for more info and a sample public comment letter in support of fee increases.
5. Thursday, January 9th, NMED meeting re:  2016 LANL Consent Order.  Time and place:  TBD

This week the renewal of the New Mexico Environment Department hazardous waste permit for Los Alamos National Laboratory (LANL) began in a very controlled public meeting at the Cities of Gold in Pojoaque.  There was no presentation by the Department of Energy (DOE) or its contractor, Triad National Security, LLC, about their plans to renew the application.  If the public had questions, they were instructed to write them on a half-sheet comment and question card.  There was no explanation about if and how those comments and questions would be answered.

CCNS has prepared a pre-emptive sample public comment letter you can use to express what needs to be included in LANL’s permit application, including proposals to install confined burn and detonation facilities, and coming into compliance with the federal and state hazardous waste laws and regulations dealing with tank systems (that are used to treat liquid hazardous and radioactive waste) and seismic requirements.  The last surface rupture on the Pajarito Plateau fault system was 1,400 years ago – thus requiring additional LANL submittals and NMED review.  LANL_Permit_Renewal_App_public_comment_120519     The current ten-year LANL permit expires in late December 2020.  Under the regulations, the permit application is due to the Environment Department 180 days before the permit expires, or in late June 2020.  https://www.env.nm.gov/hazardous-waste/lanl-permit/  The hazardous waste permit renewal application for the Waste Isolation Pilot Plant (WIPP) is on the same timeline.  https://www.env.nm.gov/hazardous-waste/wipp-permit-page/  CCNS and others have made numerous requests to both LANL and WIPP management to submit their applications in the spring of 2020 to give additional opportunity for the public to review both.  At the meeting, CCNS asked when LANL would submit its application.  A LANL staff member said they could not disclose the date.

Large poster boards set on easels were lined up against the walls in the meeting room.  They provided limited information about the 27 sites that manage, handle, store, and treat hazardous waste that are regulated by the existing permit.  The 27 sites include LANL’s old Chemistry and Metallurgy Research Building at Technical Area 3, the Radioactive Liquid Waste Treatment Facility at Technical Area 50, the dumps at Technical Area 54, the storage units inside and outside of the Plutonium Facility at Technical Area 55, and the Transuranic Waste Facility at Technical Area 63.

As in 2010, LANL wants to add three open burning and open detonation sites to the permit, which have been operating for decades under interim regulatory status.  CCNS and others opposed it then and will now, as there is equipment capable of confining the burn and reducing the emissions by 99 percent.  https://www.eldoradoengineering.com/

Sitting next to the posters were LANL staff members, or subject matter experts, who were available to answer questions.  None of the officials and staff members, unfortunately, wore nametags, nor did they have business cards should a member of the public want to follow-up with them.  Further, contradictory information was sometimes provided to members of the public.  

Joni Arends, of CCNS, said, “If DOE and LANL continue to treat the public with disdain, it is going to be a long and difficult permitting process.  All in all, this first meeting was disappointing and unproductive.”

1. Thank you to everyone who contributed on Giving Tuesday to our CCNS Media Network, which includes the weekly CCNS News Update and this email.  If you missed Giving Tuesday, please support CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/ We really need your contribution.  Many thanks!
2. The Defense Nuclear Facilities Safety Board (DNFSB) released their important Technical Report 44 Los Alamos National Laboratory Plutonium Facility Leak Path Factor Methodology,
   

    

   dated November 12, 2019.  The report discusses weaknesses in the safety basis for the Plutonium Facility, as well as delays for installing safety control improvements – some due a decade or more ago.  https://www.dnfsb.gov/documents/letters/pf-4-safety-basis This report is referenced in the sample public comment letter found in today’s Update that you can use to put pressure on the NM Environment Department and LANL to require more regulation of LANL operations – not less. 

3.  Two Cold War Patriots Town Halls next week:  Tuesday, December 10th at Buffalo Thunder – Pueblo Ballroom and Wednesday, December 11th at Embassy Suites Albuquerque, at 1000 Woodward Place N.E., in Albuquerque.  For more information about the morning and afternoon programs, go to https://coldwarpatriots.org/events-news/ 
4. New Mexico Environment Department and Department of Energy Annual Plan for Cleanup of Los Alamos National Laboratory Legacy Waste on Monday, December 16th at 5 pm at the Los Alamos County Council Chambers, 1000 Central Avenue, Los Alamos.  This meeting is required by the 2016 Consent Order.

   Here’s a link to a recent posting of the Updated Fiscal Year 2020 Appendices A, B, and C to the Consent Order – https://ext.em-la.doe.gov/eprr/repo-file.aspx?oid=0902e3a6800c30b4&n=EMID-700658_FY20_Consent_Order_Apps_A,B,C_110719.pdf

   Please take care, All!

On Sunday, November 24^th, Pope Francis spoke in Nagasaki, the site of the second U.S. bombing of Japan on August 9, 1945.  We provide the full text of the Pope’s message.  He said,

“Dear Brothers and Sisters,

This place makes us deeply aware of the pain and horror that we human beings are capable of inflicting upon one another. The damaged cross and statue of Our Lady recently discovered in the Cathedral of Nagasaki remind us once more of the unspeakable horror suffered in the flesh by the victims of the bombing and their families.

One of the deepest longings of the human heart is for security, peace and stability. The possession of nuclear and other weapons of mass destruction is not the answer to this desire; indeed they seem always to thwart it. Our world is marked by a perverse dichotomy that tries to defend and ensure stability and peace through a false sense of security sustained by a mentality of fear and mistrust, one that ends up poisoning relationships between peoples and obstructing any form of dialogue.

Peace and international stability are incompatible with attempts to build upon the fear of mutual destruction or the threat of total annihilation. They can be achieved only on the basis of a global ethic of solidarity and cooperation in the service of a future shaped by interdependence and shared responsibility in the whole human family of today and tomorrow.

Here in this city which witnessed the catastrophic humanitarian and environmental consequences of a nuclear attack, our attempts to speak out against the arms race will never be enough. The arms race wastes precious resources that could be better used to benefit the integral development of peoples and to protect the natural environment. In a world where millions of children and families live in inhumane conditions, the money that is squandered and the fortunes made through the manufacture, upgrading, maintenance and sale of ever more destructive weapons, are an affront crying out to heaven.

A world of peace, free from nuclear weapons, is the aspiration of millions of men and women everywhere. To make this ideal a reality calls for involvement on the part of all: individuals, religious communities and civil society, countries that possess nuclear weapons and those that do not, the military and private sectors, and international organizations. Our response to the threat of nuclear weapons must be joint and concerted, inspired by the arduous yet constant effort to build mutual trust and thus surmount the current climate of distrust. In 1963, Saint John XXIII, writing in his Encyclical Letter Pacem in Terris, in addition to urging the prohibition of atomic weapons (cf. No. 112), stated that authentic and lasting international peace cannot rest on a balance of military power, but only upon mutual trust (cf. No. 113).

There is a need to break down the climate of distrust that risks leading to a dismantling of the international arms control framework. We are witnessing an erosion of multilateralism which is all the more serious in light of the growth of new forms of military technology. Such an approach seems highly incongruous in today’s context of interconnectedness; it represents a situation that urgently calls for the attention and commitment of all leaders.

For her part, the Catholic Church is irrevocably committed to promoting peace between peoples and nations. This is a duty to which the Church feels bound before God and every man and woman in our world. We must never grow weary of working to support the principal international legal instruments of nuclear disarmament and non-proliferation, including the Treaty on the prohibition of nuclear weapons. Last July, the bishops of Japan launched an appeal for the abolition of nuclear arms, and each August the Church in Japan holds a 10-day prayer meeting for peace. May prayer, tireless work in support of agreements and insistence on dialogue be the most powerful “weapons” in which we put our trust and the inspiration of our efforts to build a world of justice and solidarity that can offer an authentic assurance of peace.

Convinced as I am that a world without nuclear weapons is possible and necessary, I ask political leaders not to forget that these weapons cannot protect us from current threats to national and international security. We need to ponder the catastrophic impact of their deployment, especially from a humanitarian and environmental standpoint, and reject heightening a climate of fear, mistrust and hostility fomented by nuclear doctrines. The current state of our planet requires a serious reflection on how its resources can be employed in light of the complex and difficult implementation of the 2030 Agenda for Sustainable Development, in order to achieve the goal of an integrated human development. Saint Paul VI suggested as much in 1964, when he proposed the establishment of a Global Fund to assist those most impoverished peoples, drawn partially from military expenditures (cf. Declaration to Journalists, 4 December 1964; Populorum Progressio, 51).

All of this necessarily calls for the creation of tools for ensuring trust and reciprocal development, and counts on leaders capable of rising to these occasions. It is a task that concerns and challenges every one of us. No one can be indifferent to the pain of millions of men and women whose sufferings trouble our consciences today. No one can turn a deaf ear to the plea of our brothers and sisters in need. No one can turn a blind eye to the ruin caused by a culture incapable of dialogue.

I ask you to join in praying each day for the conversion of hearts and for the triumph of a culture of life, reconciliation and fraternity. A fraternity that can recognize and respect diversity in the quest for a common destiny.

I know that some here are not Catholics, but I am certain that we can all make our own the prayer for peace attributed to Saint Francis of Assisi:

Lord, make me an instrument of your peace:

where there is hatred, let me sow love;

where there is injury, pardon;

where there is doubt, faith;

where there is despair, hope;

where there is darkness, light;

where there is sadness, joy.

In this striking place of remembrance that stirs us from our indifference, it is all the more meaningful that we turn to God with trust, asking him to teach us to be effective instruments of peace and to make every effort not to repeat the mistakes of the past.

May you and your families, and this entire nation, know the blessings of prosperity and social harmony!” https://www.japantimes.co.jp/news/2019/11/24/national/full-text-of-pope-francis-nagasaki/#.Xd16I4VcPzB

The next day, the Chairman of the United States Conference of Catholic Bishops’ International Justice and Peace Committee, Bishop David Malloy, reaffirmed their commitment to global nuclear disarmament.  The statement said,

“For our part, the Catholic bishops of the United States remain firmly committed to global nuclear disarmament. We declared in 1993: ‘The eventual elimination of nuclear weapons is more than a moral ideal; it should be a policy goal.’”

“The United States and Russia have over 90% of the world’s nuclear weapons. This fact alone calls for our nation to exercise global leadership for mutual, verifiable nuclear disarmament. The extension of New START Treaty with Russia would be a prudent next step.”  https://www.vaticannews.va/en/church/news/2019-11/us-bishops-statement-nuclear-weapons.print.html

1.   GIVING TUESDAY New Mexico is Tuesday, December 3rd. Please support CCNS and the work we do to keep you informed weekly with the latest nuclear safety news, action alerts and sample public comments.  It costs money to produce the weekly CCNS News Update broadcast and social media outreach.  Consider a monthly contribution.  We are truly grateful for your support!    #GivingTuesdayNM

2.   Wednesday, December 4, 2019, from 5:30 to 7:30 pm, at Cities of Gold Hotel & Casino Conference Center in Pojoaque – LANL will hold a public meeting about the application they will be submitting to NMED for renewal of the Hazardous Waste Act permit.  The current permit expires in December 2020.  LANL wants NMED to continue regulating 27 hazardous waste units, as well as to add three interim status units.

CCNS will ask LANL to submit a permit application for the Radioactive Liquid Waste Treatment Facility, a hazardous waste facility, to the New Mexico Environment Department (NMED) as part of their permit renewal application.  Join us!

3.    Maybe – on Monday, December 16th – LANL will host a public meeting as required by the 2016 NMED Consent Order.  No public notice has been released.  Here’s a link to a recent posting of the Updated Fiscal Year 2020 Appendices A, B, and C to the Consent Order – https://ext.em-la.doe.gov/eprr/repo-file.aspx?oid=0902e3a6800c30b4&n=EMID-700658_FY20_Consent_Order_Apps_A,B,C_110719.pdf

Maybe – on Monday, December 16th – NMED will host a community meeting about the 2016 Consent Order.  No public notice has been released.

Maybe – in early January, the Environmental Protection Agency (EPA) will host public meetings and/or public hearings about LANL’s industrial waste water draft discharge permit and the individual stormwater permit.  No public notice has been released.

Please stay tuned.

4.   There are a number of BAD nuclear waste and consolidated interim storage facility bills moving through Congress that must be stopped.  PLEASE CONTACT YOUR CONGRESSPEOPLE TO OPPOSE THE BILLS.  These bills include:

This week, the U.S. House Energy & Commerce Committee passed House Bill H.R. 2699 – Nuclear Waste Policy Amendments Act of 2019, out of Committee.  It will go to the House floor soon.  The bill “would also authorize the U.S. Department of Energy to take ownership of commercial irradiated nuclear fuel at private, consolidated interim storage facilities (CISF).  This radical change to the Nuclear Waste Policy Act of 1982, as amended, would risk “interim” becoming de facto permanent surface storage, meaning loss of institutional control over time would guarantee large-scale releases of hazardous radioactivity directly into the environment.”

For more information, please check out Kevin Kamps’ Beyond Nuclear report at http://www.beyondnuclear.org/yucca-mountain/2019/10/10/radioactive-racism-is-not-progressive-urge-your-congress-mem.html

5.   If you appreciate our community leadership and work to keep you informed, please support CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/

The Department of Energy’s Idaho National Laboratory (INL) has always been the driver for the Waste Isolation Pilot Plant (WIPP).  That is evidenced again by the new agreement between the State of Idaho and DOE which requires “at least 55 percent of all transuranic waste shipments received at WIPP” be from Idaho each year and that, in addition, “DOE will give INL transuranic waste priority for shipments to WIPP,” if shipments from other sites are delayed for any reason.  Since its opening in 1999, slightly more than half of all shipments to WIPP have been from Idaho, but there remains enough waste in that state for several hundred more shipments.     

Idaho’s concern is based on previous promises and agreements not being kept.  The waste stored in Idaho was shipped from the Rocky Flats Plant, near Denver, where more than 70,000 plutonium pits, or the cores of nuclear weapons, were manufactured.

Almost 50 years ago, the federal government promised Idaho that the Rocky Flats waste would begin leaving by 1980.  That did not happen.  In 1981, DOE released its first record of decision stating that all Idaho waste would be at WIPP by 1990.  That did not happen.  Idaho reached a legally binding agreement with DOE in 1995 requiring that all waste would be at WIPP by 2018. That did not happen, so now another agreement.  https://gov.idaho.gov/pressrelease/little-and-wasden-announce-framework-for-u-s-department-of-energy-to-comply-with-1995-settlement-agreement-and-conduct-commercial-spent-fuel-research/

But, here’s the rub for New Mexico.

This summer, DOE released a draft five-year Strategic Plan for WIPP that would double the timeline for disposal operations from the scheduled closing date of 2024 to 2050.  Further, a new shaft would be needed, as well as new drifts for waste storage, which ultimately, would double the disposal area.  http://nuclearactive.org/public-should-comment-on-new-wipp-forever-strategic-plan/

On September 12th, DOE held a public meeting in Santa Fe about the strategic plan.  Santa Fe County Commissioner Anna Hansen attended to learn more about DOE’s plans for the 4,000 waste drums sitting in Area G fabric tents at Los Alamos National Laboratory (LANL).  https://www.santafecountynm.gov/county_commissioners/anna_hansen  She asked about the timing for shipping the waste to WIPP.   Representatives of DOE and WIPP responded, stating WIPP’s shipments cannot be reserved.

In contrast, DOE just pledged to reserve 55 percent of WIPP shipments for Idaho waste.

Again, DOE is asking New Mexicans to do more to support the clean up of other sites around the country ahead of LANL.

Commissioner Hansen questioned why.  She stated, “Our state agencies must ensure that WIPP reserve shipments for LANL plutonium contaminated waste.”  She continued, “Why doesn’t DOE ensure LANL has priority status for any unused shipments to WIPP?  DOE must make shipments of LANL transuranic waste a priority.”

1.    GIVING TUESDAY New Mexico is Tuesday, December 3rd.Please support CCNS and the work we do to keep you informed weekly with the latest nuclear safety news, action alerts and sample public comments.  It costs money to produce the weekly CCNS News Update broadcast and social media outreach.  We would be grateful for your support!    #GivingTuesdayNM

2.    There are a number of BAD nuclear waste and consolidated interim storage facility bills moving through Congress that must be stopped.  PLEASE CONTACT YOUR CONGRESSPEOPLE TO OPPOSE THE BILLS.  These bills include:

This week, the U.S. House Energy & Commerce Committee passed House Bill H.R. 2699 – Nuclear Waste Policy Amendments Act of 2019, out of Committee.  It will go to the House floor soon.  The bill “would also authorize the U.S. Department of Energy to take ownership of commercial irradiated nuclear fuel at private, consolidated interim storage facilities (CISF).  This radical change to the Nuclear Waste Policy Act of 1982, as amended, would risk “interim” becoming de facto permanent surface storage, meaning loss of institutional control over time would guarantee large-scale releases of hazardous radioactivity directly into the environment.”

For more information, please check out Kevin Kamps’ Beyond Nuclear report at http://www.beyondnuclear.org/yucca-mountain/2019/10/10/radioactive-racism-is-not-progressive-urge-your-congress-mem.html

3.    December 4, 2019, from 5:30 to 7:30 pm, at Cities of Gold Hotel & Casino Conference Center in Pojoaque – LANL will hold a public meeting about the application they will be submitting to NMED for renewal of the Hazardous Waste Act permit.  The current permit expires in December 2020.  LANL wants NMED to continue regulating 27 hazardous waste units, as well as to add three interim status units.

4.    *** We anticipate a LANL public meeting before the end of the year as required by the 2016 NMED Consent Order.  Here’s a link to a recent posting of the Updated Fiscal Year 2020 Appendices A, B, and C to the Consent Order – https://ext.em-la.doe.gov/eprr/repo-file.aspx?oid=0902e3a6800c30b4&n=EMID-700658_FY20_Consent_Order_Apps_A,B,C_110719.pdf

*** We anticipate a LANL public meeting about the Environmental Protection Act (EPA) Industrial Discharge Permit in January.  Please stay tuned.

5.    If you appreciate our community leadership and work to keep you informed, please support CCNS with an end-of-the-year tax-deductible contribution.  Mail your check to CCNS, P. O. Box 31147, Santa Fe, NM  87594-1147, or use our e-contribution form on the right side of our home page at http://nuclearactive.org/

Good morning,

Thursday’s public hearing about the draft groundwater discharge permit (DP-1132) for LANL’s Radioactive Liquid Waste Treatment Facility (RLWTF) has ended.  Upon motion by the “Citizen groups,” Tewa Women United, New Mexico Acequia Association, Honor Our Pueblo Existence, and CCNS, the Hearing Officer agreed to keep the record open until Monday, Nov. 18 at 5 pm for public comments.  Here is a sample public comment letter you can use.  DP-1132 public comment 11-16-19 Feel free to modify to express your concerns.  Please share with your networks, friends and family. 

We need public comments to let the Environment Department know that this 24-year odyssey must end with regulation of the RLWTF by federal Resource Conservation and Recovery Act (RCRA) as implemented by the NM Hazardous Waste Act.  The RLWTF handles, manages, treats, and stores hazardous and radioactive wastes.  Real regulation is required – not a figleaf/gimmick groundwater permit under the NM Water Quality Act.

Here are additional talking points you can use that focus on how the federal Resource Conservation and NM Hazardous Waste Act:

*    The RLWTF is a key facility for treating liquid radioactive and hazardous wastes from the production of plutonium pits (the triggers for nuclear weapons);

*    The NM Hazardous Waste Act is more protective of human health and the environment than the NM Water Quality Act;

*    Two RLWTF storage units, one inside and one outside, are covered by the NM Hazardous Waste Permit;

*    The RLWTF storage and treatment operations rely on tanks and ancillary equipment, such as sumps, pumps and pipes.  For new tank systems, the regulations require a Professional Engineer (P.E.) to review and certify that the tank system has sufficient structural integrity for storing and treating hazardous waste.  For example, the regulations require the P.E. assessment “must show that the foundation, structural support, seams, connections, and pressure controls are adequately designed and that the tank system has sufficient structural strength, compatibility with the waste(s) to be stored or treated, and corrosion protection to ensure that it will not collapse, rupture, or fall.”

These include a requirement that the design ensure that the tank system will not be dislodged if it is place in a seismic fault zone.  This is a factor in Los Alamos.  And the NM Water Quality Act does not have seismic requirements – unless the NMED Secretary requires additional information – which has not happened.  See below.

LANL-PAJARITO-FAULT-SYSTEM-FIGURES

*    The RLWTF is located within one block of the Plutonium Facility-4 and the Chemistry & Metallurgy Research Replacement (CMRR) Project, including the Radiological Laboratory Utility and Office Building (RLUOB).  In the mid-2000s, DOE proposed to build a Super Walmart sized Nuclear Facility, which was eventually canceled by the Obama Administration due to rising costs to address the increasing seismic threats on the Pajarito Plateau.  DOE initially said the Project would cost $600 million, which escalated to $6 billion.

Attached is a series of maps that Bob Gilkeson put together to show the Pajarito Fault System (PFS).  In Fig. 2, the RLWTF is located one block east of the CMRR and TA-55 Plutonium Facility.

*    On Fig. 4, Gilkeson wrote:  “An additional important factor is that the youthful PFS is currently at a growth stage where the interaction between the primary Pajarito Fault (PF or PAF) and the subsidiary Rendija Canyon Fault (RCF) and Guaje Mountain Fault (GMF) often results in multiple ground-breaking ruptures from two of the three faults (Lewis et al., 2009). The powerful multiple surface-rupturing earthquakes are described on page 3-25 in the DOE 2011 draft SEIS [Supplemental Environment Impact Statement] as follows:”

DOE’s assessment in 2011:  “New paleoseismic data argue for three Holocene (past 11,000 years) surface-rupturing earthquakes, including an earthquake on the Pajarito Fault, approximately 1,400 years ago; an earthquake on the Pajarito Fault approximately 5,000 to 6,000 years ago, which is consistent with an event during the same general time frame on the Guaje Mountain Fault; and a third earthquake on both the Pajarito and the Rendija Canyon Faults, approximately 9,000 years ago. This paleoseismic event chronology demonstrates that the Pajarito Fault often ruptures alone, but sometimes ruptures either with the Rendija Canyon Fault or Guaje Mountain Fault. When this occurs, the resultant seismic moment and, therefore, the earthquake magnitude are larger than when the main Pajarito Fault ruptures alone. Given the evidence for youthful movement on the Pajarito Fault system, future ruptures should be expected.  [Emphasis added.]” 

Additional seismic information is available at http://nuclearactive.org/gilkeson/

Thank you for taking the time to read this and create your own comments.  We learned on Thursday that DOE/NNSA and their contractor, Triad National Security, LLC, are saying that the LANL will have to close if they don’t get the groundwater discharge permit – the jobs v. protection of well-being, health, water, air, and soil argument.

Take a stand!  Get your comments in!  Please email us a copy so we can keep track of them to ensure they are placed in the hearing record.