Incomplete Draft Permit Supporting WIPP Expansion Subject to a Public Hearing
Activists, technical experts, and the public are asking why the Hazardous Waste Bureau (HWB) of the New Mexico Environment Department is processing an incomplete permit modification request for a proposed shaft and associated drifts at the Waste Isolation Pilot Plant (WIPP). Last year, the HWB issued a defective draft permit for public review and comment. Nearly 97 percent of the comments submitted opposed the proposed expansion and the new shaft. Nevertheless, that draft permit is the subject of a virtual public hearing scheduled to begin on Monday, May 17th. https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to March 10, 2021 posts.
The defects are numerous. The hazardous waste regulations require the Department of Energy (DOE) to explain why the shaft and drifts are needed. DOE is also required to notify the HWB of the plans to change the facility, such as the proposed waste disposal panels and rooms that would extend from the drifts. DOE has not explained the need or their planned changes.
The National Academy of Sciences Consensus Study Report [Review of the Department of Energy’s Plans for Disposal of Surplus Plutonium in the Waste Isolation Pilot Plant, 2020, https://www.nap.edu/catalog/25593/review-of-the-department-of-energys-plans-for-disposal-of-surplus-plutonium-in-the-waste-isolation-pilot-plant ] and the Government Accountability Office [Nuclear Waste Disposal: Better Planning Needed to Avoid Potential Disruption at WIPP, GAO-21-48, November 2020] gao-21-48 filled in some of those voids. Their recent reports describe future waste panels and DOE’s plan to dispose of 48 metric tons of surplus plutonium, currently stored at the Los Alamos National Laboratory, Pantex, and the Savannah River Site.
In its permit application, DOE did not provide even a glimmer of the future expansion plans and it opposes any discussion of the expansion at the public hearing. https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to June 12, 2020 post. The HWB did not alert the public to the planned expansion in the draft permit and similarly opposes any discussion of the expansion at the public hearing. https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to June 12, 2020 post.
Even so, this week DOE released a Supplement Analysis for the Waste Isolation Pilot Plant Site-Wide Operations, DOE/EIS-0026-SA-12, Rev. 0, Effective April 8, 2021 for two proposed “replacement” panels 11 and 12 located south of the proposed shaft No. 5. As you can see, more panels for more waste are proposed. But DOE has not been presented these evolving plans to the HWB as part of its permit modification request. These evolving proposed plans are not part of the draft permit and not subject to the public hearing. DOE_EIS-0026-SA-12_SA_for_WIPP_Site-Wide_Operations_Rev0_Final_Sig_on_File
Further, the proposed shaft is estimated to cost nearly $200 million and take 37 months to build, with completion in 2024. But the current permit, based on DOE’s previous agreements with the People of New Mexico, requires WIPP to end waste disposal in 2024 and begin a 10-year process to close the facility. https://www.env.nm.gov/hazardous-waste/wipp-permit-page/ , see Attachment G Closure Plan – August 2020, specifically, p. 10 of the pdf, p. 6 of the document, Permit Condition G-1d(2), which reads:
The Disposal Phase for the WIPP facility is expected to require a period of 25 years beginning with the first receipt of TRU waste at the WIPP facility [March 26, 1999] and followed by a period ranging from 7 to 10 years for decontamination, decommissioning, and final closure.
The draft permit has a limited scope that does not address portions of the permit that are logically related and necessary to the need and planned changes. For example, if DOE seeks a permit to construct the proposed shaft and related drifts, then it is logical to imagine that DOE wants to keep WIPP open beyond 2024. DOE’s actions imply that it wants to expand WIPP’s disposal capacity. Under the hazardous waste regulations, the related and necessary actions must be included in the DOE’s permit modification request and the draft permit. But they are not included.
In the end, the public is entitled to review DOE’s entire expansion plan as part of the permit modification process.
A virtual public hearing about a proposed new shaft and associated drifts, essential elements for the proposed WIPP expansion, begins on Monday, May 17th, 2021. New Mexicans can comment at that hearing where numerous groups, including CCNS, are opposing the shaft, drifts and expansion. https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to March 10, 2021 post.
We are Podcasting!
1. Thursday, April 15th at 6 pm – Virtual WIPP Town Hall about the environmental monitoring data from the January 31, 2021 four-hour test of the WIPP 700-C ventilation fan. The data has also been posted to the WIPP website here https://wipp.energy.gov/700c-restart.asp. To register for the virtual Town Hall meeting, go to: https://zoom.us/meeting/register/tJIkceiorDMjGtffC3a56Y9w7TuyGOSXoGWg. Stakeholders can also submit questions prior to the meeting by emailing the WIPP Information Center at email@example.com. Questions will be accepted through the end of the business day following the virtual Town Hall meeting. For more information: https://wipp.energy.gov/wipp_news_20210409.asp
2. Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself “permanently” in Santa Fe at the corner of Guadalupe and W. Alameda. JOIN US! We’ll have banners. Please bring a sign.
3. Fri. April 16th at 1:30 pm – Virtual meeting of the Regional Coalition of LANL Communities. Please express your concerns about the continuation of the ineffective RCLC. To view the agenda and zoom links: https://regionalcoalitionnm.org/
4. Th. April 22nd from 6 to 7:30 pm – Virtual open house for the Kirtland Air Force Base Bulk Fuels Facility. You will need to download Adobe Connect software to participate. See email below from KAFB:
“As we previously mentioned, the Air Force will be hosting a virtual open house for the Kirtland Air Force Base Bulk Fuels Facility project on Thursday, April 22, 2021 from 6:00 to 7:30 p.m. In light of Coronavirus concerns, this open house will be held virtually using a platform provided by the Air Force Institute of Technology (AFIT). Due to issues with previous software, there is a new update.
“Attendees will need to download the free Adobe Connect software to join the virtual meeting. It is suggested this be done in advance of the meeting date and time. The updated software can be downloaded at https://helpx.adobe.com/adobe-connect/connect-downloads-updates.html.
“Community members interested in joining the virtual open house can join using the following internet connection: https://ceschool.adobeconnect.com/afcec/
“An updated presentation will be provided that will include a project status update and a question and answer period. To submit questions, e-mail firstname.lastname@example.org.
“If you would like additional information, please contact Brannon Lamar at 377 Air Base Wing Public Affairs at (505) 639-8420 or by email, email@example.com.
“We ask that you share this notification with others in your community and hope you can join us at the upcoming event!
“Kirtland Air Force Base Public Affairs”
5. Saturday, April 24th from 8:30 am – 10:45 am on Zoom – Political Support for the Nuclear Ban Treaty, with Beatrice Fihn, Executive Director of the International Campaign to Abolish Nuclear Weapons, with ICAN campaigners around the world about how they have successfully used the ICAN Pledge to build support for nuclear abolition in other countries. Read the ICAN Parliamentary Pledge here: https://pledge.icanw.org/
To register, see the list of distinguished speakers and sponsoring organizations, including CCNS: http://bit.ly/political-tpnw
Tags: associated drifts, defective draft permit, Department of Energy, DOE, expansion, Government Accountability Office, HWB, Los Alamos National Laboratory, National Academy of Sciences, New Mexico Environment Department Hazardous Waste Bureau, Pantex, permit modification request, proposed new shaft, public hearing, Savannah River Site, STOP FOREVER WIPP, Waste Isolation Pilot Plant, WIPP