Please Support CCNS and HOPE Request for Sanctions in the LANL DP-1132 Appeal before the New Mexico Water Quality Control Commission

CCNS and Honor Our Pueblo Existence (HOPE) request your support of our request for sanctions in the appeal of the groundwater discharge permit DP-1132, issued to Los Alamos National Laboratory for operation of the Radioactive Liquid Waste Treatment Facility.  The appeal is before the New Mexico Water Quality Control Commission, which has the authority to order sanctions.  We seek sanctions requiring the Permittees, the Department of Energy / National Nuclear Security Administration, to pay our expenses caused by DOE/NNSA’s unethical behavior.

This case involves small non-governmental organizations challenging large industrial sites to comply with environmental laws and regulations.  Since 2010, we have been challenging the improper regulation of the Radioactive Liquid Waste Treatment Facility.  Legally, the facility should be regulated by the New Mexico Hazardous Waste Act, not the New Mexico Water Quality Act.

During public hearings on DP-1132, the Permittees announced job openings, and two employees of the New Mexico Environment Department, who were decision makers concerning DP-1132, applied for and were hired by DOE / NNSA.  They had a clear conflict of interest.

The first time, in the summer of 2018, the hearing officer at a public hearing rejected the application of the Hazardous Waste Act, while she was actively pursuing employment with DOE / NNSA, which ultimately hired her.  http://nuclearactive.org/wp-content/uploads/2019/06/190606-CCW-Petition-for-Mandamus-2019-06-06.pdf

CCNS and HOPE incurred legal and other expenses during and after the permit hearing to right the wrong.

The second violation occurred this summer, during our DP-1132 appeal to the Water Quality Control Commission.  The Commission Chair pursued a job with DOE / NNSA, and at the same time allowed the unlawful permit DP-1132 to be effective indefinitely and postponed the appeal.  https://www.env.nm.gov/opf/water-quality-control-commission/, scroll down WQCC 22-21:  Concerned Citizens for Nuclear Safety and Honor Our Pueblo Existence’s Petition for Review of NMED Ground Water Discharge Permit DP-1132, click on link, go to November 4, 2022 Motion by Petitioners to Vacate Orders Issued Under Disqualification, November 17, 2022 Supplemental Memorandum on Motion by Petitioners to Vacate Orders Issued Under Disqualification, and subsequent filings.

It was another clear conflict of interest.  The Commission Chair is now working for NNSA.  http://nuclearactive.org/a-clear-case-of-disqualification-of-nmed-deputy-cabinet-secretary-stephanie-stringer/

During our years-long effort to right the wrongs, CCNS and HOPE incurred costs and legal expenses pursuing the appeal of DP-1132.

The Water Quality Control Commission meets virtually on Tuesday, January 10^th, 2023.  https://www.env.nm.gov/opf/water-quality-control-commission/  You can make public comments during that hearing, or submit a written comment on or before Friday, December 30^th, 2022.  https://nmed.commentinput.com/?id=ZCP4E or email them to Pamela.Jones@env.nm.gov    Here is a sample comment letter for your use:  f sample DP-1132 public comment ltr 12-22-22

Joni Arends, a CCNS co-founder and executive director, requests that you support our request for sanctions by submitting a written public comment or make a comment during the January 10^th Commission meeting.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D163442703

1. Friday, December 23^rd from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

2. Tuesday, December 20^th, 2022 – NMED released the public notice, revised fact sheet, and draft hazardous waste renewal permit for WIPP. It is available here https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.

3. Friday, December 23^rd, 2022 to Tuesday, January 3^rd, 2023 – CCNS will be generally closed for the holidays.

Tags: CCNS, Concerned Citizens for Nuclear Safety, conflict of interest, Department of Energy, DOE, DP-1132, Groundwater Discharge Permit DP-1132, Honor Our Pueblo Existence, HOPE, LANL, Los Alamos National Laboratory, National Nuclear Security Administration, New Mexico Environment Department, New Mexico Hazardous Waste Act, NMED, NNSA, Radioactive Liquid Waste Treatment Facility, right the wrongs, RLWTF, Water Quality Act, Water Quality Control Commission, WQCC