Current Activities

Public Comments at Safety Board Hearing Say It All

The public comment portion of the November 28th, Defense Nuclear Facilities Safety Board public hearing about restrictions the new Department of Energy Order 140.1 places upon the Board, was most informative.  Sure, the Department of Energy (DOE) Assistant Secretary for the Office of Environment Management, Anne Marie White, testified about implementation of Order 140.1, which unduly restricts the Board from doing its work.  She indicated that the Order had not changed the relationship between DOE and the Safety Board.  White left before the public comments began.  https://www.dnfsb.gov/public-hearings-meetings/november-28-2018-public-hearing

It was the son of former Board member, Navy Captain Jack Crawford, who served as a member of the Safety Board from 1989 to 1996, who laid it on the line.  https://www.dnfsb.gov/about/former-board-members?page=1   The Captain’s son, Jack Crawford, did not plan to testify, but he felt compelled to do so.  He was a coach and a teacher.  While he did not study nuclear safety, he knew from the discussion about the Order that things were serious.  He explained that the Board was modeled on the Navy; how the Navy has never had a nuclear accident, even though they lost two submarines.

Crawford compared how the DOE and the owners of the National Football League act.  When there is a need for a discussion between the NFL and the players, similar to the DOE and the public need to discuss issues, the owners and DOE leave.

Kathy Crandall Robinson, provided comments on behalf of Tri-Valley Communities Against a Radioactive Environment, based in Livermore, California  http://www.trivalleycares.org/ and the Alliance for Nuclear Accountability, a national network of more than 30 organizations located near DOE and National Nuclear Security Administration defense nuclear facilities.  http://www.ananuclear.org/   CCNS is a member organization of ANA.

Crandall Robinson spoke about the “particularly egregious problem with Order 140.1 [that] redefines and limits the role of [the Safety Board] in protecting worker safety and health.  Yet the Safety Board has been crucial to protecting workers.  To cite one example, the enormous importance of [the Safety Board’s] role in conveying information and carefully keeping records is highlighted in a recent Santa Fe New Mexican story entitled, ‘Exposed:  The life and death of Chad Walde.’  http://www.santafenewmexican.com/news/local_news/the-life-and-death-of-chad-walde/article_0fafac1a-d8c6-11e8-9b93-d3669f02cc94.html  The news article details Mr. Walde’s journey working in high radiation areas at Los Alamos National Laboratory, from the fall of 1999 to September 2014, and it cites [Safety Board] reports as evidence of exposures.”  https://www.dnfsb.gov/sites/default/files/document/16756/Tri-Valley%20CAREs%2C%20Alliance%20for%20Nuclear%20Accountability.pdf

The order, entitled, “Interface with the Defense Nuclear Facilities Safety Board,” was issued in May, without public notice and opportunity to comment.  https://www.directives.doe.gov/news/o140.1-interface-with-the-dnfsb-news

The Safety Board’s hearing record will remain open until December 28th, 2018.  The Safety Board will hold its third public hearing in Albuquerque in February.

 

Safety Board Holds Nov. 28 Live Streamed Public Hearing

On Wednesday, November 28th, the Defense Nuclear Facilities Safety Board will hold a public hearing about the Department of Energy Order 140.1, which restricts Board access to personal, facilities, and documents for some of the most dangerous DOE nuclear facilities across the country.  The restrictions are contrary to the congressional legislation that established the Safety Board in 1988.  Its statutory mission is to “provide independent analysis, advice, and recommendations to the Secretary of Energy … in providing adequate protection of public health and safety at defense nuclear facilities.”  The hearing will be held in Washington, DC from 10 am to 1:30 pm Eastern Time, or 8 am to 11:30 am Mountain Time.  https://www.dnfsb.gov/public-hearings-meetings/november-28-2018-public-hearing  It will be live streamed from the Board’s website at https://www.dnfsb.gov/ .

Wanting to hear from the public about the impact of the Order on the public’s confidence in both the Safety Board and DOE, the Board scheduled over 100 minutes for public comment.  If you would like to give public comments, please email hearing@dnfsb.gov by the close of business on Monday, November 26th.

The hearing record will remain open until December 28th, 2018.

This hearing is a follow-up to the initial hearing on August 28, 2018 where the Safety Board received testimony from the DOE and National Nuclear Security Administration officials, along with Safety Board technical personnel and the public.  The hearing was marked by DOE’s insistence that the Order meant little in the way of actual change, and the Safety Board’s growing skepticism.  https://www.dnfsb.gov/public-hearings-meetings/august-28-2018-public-hearing

The order, entitled, “Interface with the Defense Nuclear Facilities Safety Board,” was issued in May, without public notice and opportunity to comment.  https://www.directives.doe.gov/news/o140.1-interface-with-the-dnfsb-news

For the past 30 years, the Board has overseen and reported about both worker safety and public health and safety issues.  The new Order limits the Board’s oversight to public health and safety outside the boundary.  The new restrictions do not allow the Board to do its work efficiently and effectively.

The Safety Board conducts oversight and provides transparency at three DOE sites in New Mexico.  At Los Alamos National Laboratory, there are two on-site resident inspectors, who produce weekly reports that are posted on the Board’s website.  https://www.dnfsb.gov/documents/reports?f%5B0%5D=field_document_type%3A38  At Sandia National Laboratories and at the Waste Isolation Pilot Plant (WIPP), there are part-time resident inspectors.  They produce a monthly report about each site, also posted on the Board’s website.  https://www.dnfsb.gov/documents/reports?f%5B0%5D=field_document_type%3A39

In September, Senators Tom Udall and Martin Heinrich requested the Safety Board hold a hearing in New Mexico.  In October, the Safety Board announced it would hold a public hearing in Albuquerque in February 2019.  https://www.dnfsb.gov/documents/letters/letter-tom-udall-and-martin-heinrich-us-senate-re-dnfsb-hearings

 

Important New Mexico Legislative Committee Live Streams November 20th Meeting

In its final meeting of the year, the Radioactive and Hazardous Materials Interim Committee of the New Mexico Legislature has a full agenda.  On Tuesday, November 20th, beginning at 9 am and continuing until 5 pm, the Committee will hear about the Carlsbad Brine Well, the Radiation Exposure Compensation Act, the Gold King Mine Spill, the Waste Isolation Pilot Plant, and Los Alamos National Laboratory.  At 4:30 pm, the Committee will hear from the public.  https://www.nmlegis.gov/agendas/RHMCageNov20.18.pdf   The meeting will be held in Room 309 of the State Capitol and live streamed from https://www.nmlegis.gov/

Ken McQueen, Secretary of the Energy, Minerals and Natural Resources Department, will give an update about the remediation of the Carlsbad Brine Well.  It is located beneath the South Y highway junction of U.S. 285 and U.S. Highway 62/180.  In August, the Department began to fill the 400-foot deep cavern that is wide enough for the State Capitol to fit in it.  Some officials believe it could collapse at any time.  https://www.currentargus.com/story/news/local/2018/07/10/carlsbad-brine-well-could-collapse-during-construction-officials-say/772046002/

Tina Cordova and Mary Martinez White, of the Tularosa Basin Downwinders Consortium, will present about the harm done by the overexposure of radiation from July 16, 1945 Trinity atomic bomb test.  They will present about the proposed amendments to the federal Radiation Exposure Compensation Act that would expand coverage to the Trinity Downwinders and the Post ’71 Uranium Miners.  https://www.trinitydownwinders.com/

After lunch, Dennis McQuillan and Michaelene Kyrala, of the New Mexico Environment Department, will present the latest information about the Gold King Mine Spill and other Superfund cleanup issues.  https://www.env.nm.gov/river-water-safety/ and  https://www.env.nm.gov/gwqb/sos-nm-sites/

John Kieling, of the New Mexico Environment Department, will present about operations and management at the Waste Isolation Pilot Plant under the hazardous waste permit.  The Environment Department recently held a public hearing about a proposed permit modification to expand by 30 percent the volume of waste allowed for disposal.   The Martinez Administration wants to sign off on the proposal before it leaves office on December 31sthttps://www.env.nm.gov/hazardous-waste/wipp/

Dr. Thomas Mason will be wearing two hats when he presents about the management transition at Los Alamos National Laboratory (LANL).  He will be speaking as the LANL Director, and as President and Chief Executive Officer of the limited liability company, called Triad National Security.  Triad recently took over management and operation at LANL for the National Nuclear Security Administration, a stovepipe organization within the Department of Energy, for the research, design, and manufacturing of nuclear weapons.  Triad is composed of Battelle Memorial Institute, the Texas A&M University System, and the University of Californiahttps://www.triadns.org/

New Mexico Senator Jeff Steinborn, of Las Cruces, is the Chair of the Committee.  https://www.nmlegis.gov/Members/Legislator?SponCode=SSTEI

 

International Uranium Film Festival Returns to Southwest

The International Uranium Film Festival returns to the Diné Nation, with additional screenings throughout New Mexico and Arizona, from Thursday, November 29th through Wednesday, December 12th.  In an effort to keep people informed and aware, particularly during this critical time of escalating nuclear threats, the festival informs.

The Festival’s Director, Norbert G. Suchanek, said, “The issue of nuclear power is not only an issue of the Navajo Nation, who suffered for decades because of uranium mining. All people should be informed about the risks of uranium, nuclear weapons and the whole nuclear fuel chain.”

Films will be shown in Window Rock on November 29th and 30th and December 1st.  Awards will be presented for the best productions.

Screenings will also be held in Flagstaff on December 2nd at Northern Arizona University, in the Native American Cultural Center; in Albuquerque on December 6th at the Guild Cinema; in Grants on December 7th at the New Mexico State University Campus, in Martinez Hall; in Santa Fe on December 9th at the Jean Cocteau Cinema; and in Tucson on December 12th at the YWCA Tucson, in the Frances McClelland Community Center.  For more specifics, please go to http://uraniumfilmfestival.org/

Founded in 2011 in Rio de Janeiro, the festival aims to inform the public about nuclear power, uranium mining, nuclear weapons and the health effects of exposure to radioactivity. It seeks to educate and activate the public and inspires an informed discourse about the health and environmental risks of the nuclear cycle, from uranium mining to radioactive waste storage and disposal.

The Multicultural Alliance for a Safe Environment (MASE) is working to inform the public about the film festival.  MASE is composed of communities impacted by uranium who are working to restore and protect the natural and cultural environment through respectfully promoting intercultural engagement among communities and institutions for the benefit of all life and future generations.

Susan Gordon, MASE coordinator, said, “We are very excited to have expanded the Uranium Film Festival to six locations in New Mexico and Arizona. We have films from more than ten countries.

“We have a strong selection of films that examine the impacts from uranium mining including: “Half Life: The Story of America’s Last Uranium Mill,” https://vimeo.com/161080821;  “Dignity at a Monumental Scale,” https://vimeo.com/261408010;  and “NABIKEI (Footprints),” https://www.facebook.com/Shriprakash23 directed by Shri Prakash from India, who will be attending the Festival.

“We also have films that look at issues along the nuclear fuel chain, from nuclear weapons tests in the Marshall Islands, https://www.kathyjetnilkijiner.com; to nuclear waste storage proposed at Yucca Mountain in Nevada, https://www.therepositorymovie.com; to an amazing facility being built in Switzerland, https://vimeo.com/75918238 .”

 

CCW Rio Grande Sun Advertorial for DP-1793 (land application) Public Hearing

 

Sample DP-1793 (land application) public comment letters available here

Communities for Clean Water (CCW) has prepared four sample public comment letters – in word – you can use.  Please modify as needed to reflect your concerns.  They are:

Please include your email address so that you can be contacted.  Thank you.

 

Show Up for Water! Nov. 7th Public Hearing about LANL Waters

Beginning on Wednesday, November 7th, and continuing as needed, the New Mexico Environment Department will hold a public hearing about the polluted waters that originated in the three plumes in the deep regional drinking water aquifer below Los Alamos National Laboratory (LANL) that are treated and then applied to land.  The hearing is taking place because of the work of the Communities for Clean Water (CCW) coalition to address LANL water pollution.  http://nuclearactive.org/new-mexico-court-of-appeals-upholds-need-for-public-hearing-about-lanl-discharge-permit/

CCW encourages the public to attend the hearing and present their concerns.  Pre-hearing materials and sample public comments are available at http://tewawomenunited.org/action-toolkit-nov-7-public-hearing-in-los-alamos-on-the-toxic-chromium-plume/, http://ccwnewmexico.org/public-hearing-november-7th-9am/ , and http://nuclearactive.org/

Public comment will be heard following the introduction of the parties on the first day, at natural stopping points in the testimony, after lunch, and again at 4 pm.  DP-1793 H.O. Scheduling Order 10-31-18

The hearing will be held at the Los Alamos Magistrate Court, located at 2500 Trinity Drive, in downtown Los Alamos, beginning at 9 am and continuing until 5 pm.  No evening public comment period will be provided because the courthouse closes at 5:30 pm.  To view the Public Hearing Notices in English and Spanish, go to https://www.env.nm.gov/gwqb/public-notice/#Hearings

On July 27, 2015, the Environment Department issued a groundwater discharge permit, called DP-1793, to LANL, without holding a public hearing.  CCW had asked for a hearing three times during the comment period.  The Department refused.  Land application began.

CCW appealed the decision to the New Mexico Water Quality Control, which affirmed the Department’s decision.  CCW then appealed to the New Mexico Court of Appeals.  In late December, the Court held that the Environment Department “has limited discretion to grant or deny a public hearing,” citing the state Water Quality Act that allows for an “opportunity for a public hearing.”  http://nuclearactive.org/wp-content/uploads/2018/01/CCW-v.-WQCC-A-1-CA-35253-Opinion-12-27-17.pdf

Because a public hearing for the draft discharge permit for LANL’s Radioactive Liquid Waste Treatment Facility was already scheduled for April, the parties agreed to the November date.

Under DP-1793, polluted ground waters are brought to the surface and treated through ion exchange to remove perchlorate and chromium, and through granulated activated charcoal for the high explosive, Royal Demolition eXplosive, or RDX.  The treatment does not remove all of the pollution from the water.  http://nuclearactive.org/wp-content/uploads/2018/01/ATT00104.pdf

CCW continues to have concerns about the permit.  It allows the use of sprinklers on the back of tanker trucks or mobile units to land apply the treated waters, which spreads the waters into the air and back into the groundwater.  LANL has not explored the use of mycelium to capture the metals and remove them from the environment.       

LANL proposed to cleanup the waters to less than 90 percent of the standards.  For example, the New Mexico standard for cancer-causing chromium is 50 parts per billion per liter of water.  Ninety percent is 45 ppb.  LANL has not explained why they could not clean up the waters to 50 percent, or 25 percent, or to zero percent of the standard.  Each plume is moving to the Rio Grande.

The permit does not require LANL to establish a background, or baseline, concentration of the pollutant in the soils before land application began.  The Environment Department gave itself discretion whether to require soil monitoring at the end of the five-year permit.

These are just a few of the concerns the CCW has about the permit.

For more information and to download sample public comments supporting the use of mycelium, the precautionary principle, and more protective water quality standards, please see the post above this one or go to http://ccwnewmexico.org/public-hearing-november-7th-9am/.

 

Nov. 7 Hearing about LANL Land Application of Treated Plume Waters

There are three plumes in the deep regional drinking water aquifer below Los Alamos National Laboratory (LANL).  Although the plumes contain radioactive, toxic, and hazardous pollutants associated with operations at LANL, they are commonly known by the pollutant with the largest concentration.  They are the hexavalent chromium, or Chrome 6, plume; the perchlorate plume; and the high explosives, or Royal Demolition eXplosion, or RDX, plume.  Each plume is moving to the Rio Grande.

LANL is investigating the plumes by drilling extraction and injection wells in order to extract contaminated waters, treat them with either ion exchange or granulated activated charcoal, and return the water to the aquifer.  Some waters are too contaminated to be returned to the aquifer.

Under a ground water discharge permit issued by the New Mexico Environment Department on July 27, 2015 for a five year term, LANL received permission to land apply those waters to dirt roads, and to sprinkle the waters in the canyon bottoms.  The permit is called Discharge Permit 1793, or DP-1793.  http://nuclearactive.org/wp-content/uploads/2018/01/ATT00104.pdf

Such activities are the subject of an Environment Department public hearing scheduled to begin at 9 am on Wednesday, November 7th, and continuing on as needed, at the Los Alamos Magistrate Court, located at 2500 Trinity Drive, in Los Alamos.  The Hearing Officer will provide opportunities for public comments and non-technical testimony.  https://www.env.nm.gov/gwqb/public-notice/#Hearings

To help you prepare for the hearing, Tewa Women United, a member of Communities for Clean Water (CCW), and CCW are hosting a free workshop this Sunday, October 28th from 10 am to 3 pm at the Northern Rio Grande National Heritage Center, located at 848 State Road 68, in Alcalde.  http://tewawomenunited.org/oct-28-the-heart-of-the-community-speaks/

The training is called “The Heart of the Community Speaks.”  The workshop will provide an overview of policy-change basics, speaking points, and take action tools.  Lunch will be provided.  Please RSVP for the workshop at http://tewawomenunited.org/oct-28-the-heart-of-the-community-speaks/

The hearing is being held because the Communities for Clean Water coalition challenged the permit when it was first proposed in 2015.  CCNS is a founding member of CCW.  When a draft permit was released for public comments, CCW submitted three sets of detailed comments and requests for a public hearing.  http://nuclearactive.org/wp-content/uploads/2018/01/f-CCW-DP-1793-Comments-3-2-15.pdf, http://nuclearactive.org/wp-content/uploads/2018/01/f-CCW-DP-1793-Comments-4-29-15.pdf, and http://nuclearactive.org/wp-content/uploads/2018/01/f-CCW-DP-1793-Comments-6-15-15.pdf

Environment Department Secretary Ryan Flynn denied CCW’s request.  CCW appealed to the Water Quality Control Commission, which agreed with Flynn’s decision.  CCW then appealed to the New Mexico Court of Appeals, which agreed with CCW that a hearing must be held.  http://nuclearactive.org/new-mexico-court-of-appeals-upholds-need-for-public-hearing-about-lanl-discharge-permit/

Joni Arends, of CCNS, cordially invites you to attend the workshop and hearing.  She said, “Please show up for water.  Thank you.”

 

The INF Treaty in the News

THE INF TREATY IN THE NEWS

http://orepa.org/what-about-the-inf-treaty/ >

Why, suddenly, a shot-across-the-bow announcement from the President that the United States will withdraw from the Intermediate-Range Nuclear Forces Treaty? I say “suddenly” because the INF Treaty has been a bone of contention since at least 2012 when President Obama certified that Russia was in violation. Yet neither Obama nor Trump, until now, felt it required action.

I can think of two possible reasons—but first, a quick bit of background.

BACKGROUND

The INF Treaty was signed by the US and Soviet Union in 1987 and became effective in 1988. It eliminated all nuclear and conventional missiles and their launchers with ranges below 3,420 miles—sea-launched missiles were not included. British and French weapons were also not included.

The treaty grew out of the Soviet deployment, in 1977, of mobile-launched ballistic missiles with a range of just under the SALT II Treaty limit of 3,400 miles. Western European leaders raised concerns these weapons made them vulnerable to attack, and a strategy of negotiations backed up by the threat of deploying new NATO missile launchers across Europe was adopted.

Many proposals and even more rounds of negotiation ensued. Finally, in 1986, Soviet president Gorbachev proposed the total elimination of all nuclear weapons by the year 2000; the US countered with a phased reduction of INF missiles in Europe and Asia, to zero by 1989. It happened. The US and Soviet Union destroyed more than 2,500 weapons between them by June 1, 1991.

Ten years later, in 2001, President George W Bush announced the United States would unilaterally withdraw from a different treaty, the Anti Ballistic Missile Treaty, because the US wanted to deploy a missile defense system—a program already underway in the US.

Six years after that, President Putin declared the INF Treaty no longer served Russia’s interest, linking a decision to pull out to US action on the missile defense system.

In 2012, President Obama accused Russia of violating the INF Treaty when it tested a new cruise missile. Russia has argued that the US bases in Poland and Romania that can launch Tomahawk missiles is a violation of the Treaty; Russia also notes the US use of drones is a violation of the Treaty.

And it must be noted that the US has embarked on a $1.7 trillion dollar plan to modernize its nuclear weapons stockpile, production infrastructure, and delivery vehicles including low-yield weapons and new missiles systems which inject new concerns into the security plans of other countries. Modernization means weapons labs can hope for almost unlimited funding and free rein to design new nuclear threats.

WHY BRING IT UP NOW?

The likeliest answer is two words: John Bolton. Seven years ago, voices in conservative circles raised concerns about China’s intermediate-range nuclear forces which are not included in the bilateral INF Treaty between the US and Russia. President Trump has included this concern in his announcement. It is possible that his declaration is an attempt to get China to the arms control table.

The ascension of Bolton, a hard-right hawk who has never seemed to mind the idea of a nuclear arms race, opened the door for the advancement of this policy idea which had failed to get traction in the Obama years.

The flaw in this attempt is simple: China has no incentive to come to the table, and to do so now, when the US and Russia hold a massive advantage over China in total nuclear weapons (an estimated 1,500 each compared to China’s 300), would erase any leverage China might have to demand further US and Russian reductions.

The other possible explanation for the timing of Trump’s announcement reflects the ongoing strategy of the Administration to create and advance distractions at times of stress in order to control the media which, for the most part, is happy to play its part. Headlines about an arcane but important nuclear weapons treaty push the Mueller investigation off the “breaking news” newsfeed of TV cable media programs and play into the pre-election Republican strategy of stoking fears of all kinds in the electorate as voters head to the polls.

It seems to me that the answer to “Why now?” is likely a combination of the two options—a policy strategy the right-wing has loved for years is being pushed at a moment when a good distraction is helpful to the wider cause.

WHAT SHOULD WE SAY?

First, arms control treaties are, as a rule, good. It is difficult in the context of the existential threat of nuclear weapons—the arsenals of the US and Russia, if unleashed, would kill hundreds of millions of people in one afternoon and render the earth almost completely uninhabitable within a decade—to make a relative judgment about intermediate threats.

On the other hand, any instrument that constrains the nuclear powers is a good thing. Treaties such as the INF serve a purpose. In addition to getting rid of missiles and launchers back in 1991, the treaty also provided verification and inspection protocols which require communication and cooperation among the adversarial powers—this is a good thing.

At the very least, the INF Treaty serves a good purpose if only in the “things not getting worse” category.

In the decades since its passage, actions on both the US and Russian side have undermined confidence in the treaty—technological advances that were unforeseen thirty years ago challenge the security assurances the treaty was meant to provide.

One possible positive outcome of the Trump administration’s declaration could be a new round of negotiations about security that addresses the issues raised back in 1977 in today’s context. In the meantime, the positive elements of the INF should not be abandoned by either side.

China should be heard. Welcomed to the table if they decide to participate. Should they decline to join the conversation until the US and Russia reduce their stockpiles to relatively parity—around 500 warheads and delivery systems, Russia and the US should listen carefully. Many experts in both countries believe such nuclear force levels are achievable with no reduction in security.

Trump’s initiative, regardless of timing or intent, could have unintended, positive consequences. Republican presidents have been successful in the past in advancing arms control agendas, and nuclear abolitionists can support those efforts as steps on the way to zero.

SO — TALK ABOUT IT

The 1988 INF Treaty grew out of a concern raised 10 years earlier. Before it was finalized, it had sparked conversations between US and Soviet leaders that included proposals for complete nuclear disarmament with an actual target date!

Any effort to rework the INF Treaty should address security concerns of Russia and Europe and should consider radical but achievable proposals—like the closure of NATO nuclear-equipped bases in Germany, Turkey, Netherlands, Belgium and Italy matched by Russian actions to reduce the ten-minute threat posed by current Russian missile systems.

If, in the course of these discussions, other arms control or disarmament proposals arise, they should be considered in the context of the global desire to eliminate all nuclear threats reflected in the Treaty on the Prohibition of Nuclear Weapons approved by 122 countries at the United Nations in 2017. That Treaty is currently making its way through the ratification and accession processes in dozens of countries.

While the negotiations happen, stability is of critical importance—intemperate language or actions should be avoided on all sides. The issue of nuclear weapons and global security is too important to play politics with.

 

Ralph Hutchison

Coordinator, Oak Ridge Environmental Peace Alliance

23 October 2018

 

 

Hearing Begins Oct. 23rd on Proposed Major WIPP Expansion

On Tuesday, October 23rd and for additional days, there will be technical testimony and cross-examination of witnesses on the proposal to expand by about 30 percent the amount of radioactive and hazardous waste allowed at the Waste Isolation Pilot Plant (WIPP).  The hearing is being rushed.  Over objections of many groups to the schedule and to the limitation of oral public comment to one location, it appears the New Mexico Environment Department wants to approve the change before the current Secretary leaves office on December 31, 2018.  The only location for testimony and public comment is in Carlsbad.  https://www.env.nm.gov/wp-content/uploads/2016/05/FINAL-WIPP-Hearing-Notice-VOR-English.pdf and https://www.env.nm.gov/wp-content/uploads/2016/05/FINAL-Hearing-Notice-VOR-Spanish.pdf

The public comment period will last until the end of the hearing, which may be Thursday, October 25th.  Get your comments in NOW!  A sample public comment letter is available for you to use.  WIPP Amt of Waste public comment 8-8-18

The request by the Department of Energy (DOE) and its contractor, Nuclear Waste Partnership, would change the way the amount of waste has been measured for more than two decades. But DOE has not explained where the additional waste would be disposed since there is not space in the existing underground rooms, nor why the change is needed when WIPP is less than 55 percent filled.

Because the federal WIPP Land Withdrawal Act limits the amount of waste to 6.2 million cubic feet, how the waste is measured is important.  Waste emplaced at WIPP has always been measured based on the volume of the outer container.  That’s the way DOE has always reported to Congress how much waste is at WIPP, how DOE contractors have been paid and received performance bonuses, and the way that the WIPP Permit calculates the amount of waste.

The modification request would create an additional measurement, called the “Land Withdrawal Act TRU Waste Volume of Record [which] means the volume of TRU waste inside a disposal container.”

An unstated reason for the proposed measurement is that space for more than 1,000,000 cubic feet of waste has been forfeited or lost because of bad DOE management, poor contractor performance, and inefficiencies during the past 19 years of WIPP’s operations.  DOE has shipped and disposed of thousands of empty, or dunnage, containers and has intentionally not filled containers to capacity.

Technical witnesses at the hearing will be Ricardo Maestas for the Environment Department; Don Hancock and George Anastas for Southwest Research and Information Center, http://www.sric.org/;  Steve Zappe, who was the WIPP permit writer for more than 15 years, as an individual; and DOE contractors, Bob Kehrman and Mike Walentine, http://nwp-wipp.com/.  Those organizations and individual, Concerned Citizens for Nuclear Safety, http://nuclearactive.org/, and Nuclear Watch New Mexico, https://nukewatch.org/, can cross-examine witnesses.

Public comment will be held at 5 pm each day. The hearing begins at 9 am on Tuesday, October 23rd in Room 153 of the New Mexico State University Carlsbad Branch, 1500 University Drive, in Carlsbad.