Within a year, under EPA's skeptical eye, DOE withdrew its plans to conduct a test phase, which would have allowed mixed waste at WIPP before EPA's official certification approval. DOE proposed, instead, to fast track its environmental compliance by emphasizing an administrative review of already completed scientific analysis. DOE's new plan is to begin disposal operations by November 1997.
The National Academy of Sciences Ideal Plan
WIPP is located in salt bed formations which have been undisturbed and therefore stable for over 225 million years. In 1956, the National Academy of Sciences (NAS) recommended salt formations as the most promising medium for permanent underground disposal of radioactive waste because salt tends to "creep." NAS proposed that salt would close in around disposed waste, creating a natural, sealed tomb which would prevent the waste from moving from its disposal location. The plan was economically attractive because it proposed that long-term waste monitoring would not be necessary. The earth's formations would create a natural, impermeable tomb for the waste.
WIPP Fails to Live Up to the Ideal Plan
Almost immediately scientists discovered that WIPP did not fulfill the ideal. Once excavation began, fractures began to appear, creating new pathways in the salt beds.
The waste containing plastic, organic materials, and sludge, is decomposing, emitting hydrogen gas which is flammable.
The salt, containing water droplets, was not dry. Exploratory drill holes uncovered a pressurized brine reservoir below the WIPP site. Water became a problem because it could advance the organic decay process increasing the speed of gas generation. In addition, scientists discovered that plutonium, which had been thought to adhere to soil, was soluble and would travel through water.
DOE is unable to produce dependable waste characterization data. Records amassed over fifty years without quality assurance procedures only approximately describe the volume of different waste components, or their chemical and radioactive content.
WIPP is located in an area rich with oil, gas and potash deposits. The possibility of human intrusion into the underground waste area after the facility is closed poses unresolved scenarios for allowing waste to escape.
How Dangerous is WIPP Waste?
The main radioactive element in WIPP waste is plutonium, a man-made isotope heavier than uranium (thus the term "Transuranic") which has a half-life of 24,000 years. In other words, the decay process which emits radioactive particles continues for 240,000 years. The alpha particles emitted cannot penetrate the skin or even a paper bag. However, if airborne from an explosion or caught by the wind and carried in dust form, they can be inhaled. If ingested through water, or food which has absorbed plutonium through the soil, the particles do internal damage. For example, plutonium lodged in the lungs or other organs emits alpha particles from within the body, causing lung cancer and genetic damage.
WIPP waste also contains lead, chromium, and carbon theatricalism. These are very long lasting toxic metals and chemicals which the Resource Conservation and Recovery Act (RCRA) has banned from land disposal. Industrial users must get special permission to bury this waste. In 1996, Congress, took away EPA's authority to regulate this waste at WIPP.
Is WIPP Waste Transportation Safe?
WIPP waste will travel through a minimum of 22 states and 14 Indian reservations. DOE projects transportation accidents which will be severe enough to release radioactivity. DOE has an elaborate satellite tracking system for WIPP waste trucks. However, DOE plans do not include a comprehensive, nation-wide program for emergency response information, training and equipment. Although NRC has certified the TRUPACT II waste container for contact-handled waste, no container has yet been approved for the more radioactive remote-handled waste scheduled for WIPP. DOE's current remote-handled waste study proposes that evaluations of contact-handled waste may be applied to remote-handled waste because, DOE asserts, only insignificant differences exist between the two. DOE has not offered proof for this assertion.
What are the economic costs of WIPP?
The perception of radioactive contamination can affect tourism, and create a negative market for any agricultural products that are perceived to be contaminated. There are already at least 2-3 trucks per day carrying radioactive materials through New Mexico to and from Los Alamos National Laboratory. Planned transportation of waste to WIPP (and the Yucca Mountain proposed high-level waste repository in Nevada) dramatically adds to the already dangerous transportation of radioactive materials through our state.
Today it is virtually impossible to obtain home-owners insurance for radioactive contamination. If your home, business or ranch were to be contaminated, either through normal WIPP operations or through an accident, the government would decide if clean-up of the contamination is economically feasible. Unless the accident is "extraordinary," declared you would have to prove government liability at your own expense and might never be compensated for contaminated products, crops or clean-up .
Already, real estate values along the WIPP route have been shown to have declined and nothing has even been transported to WIPP. Investor interest in our state may drop and bond ratings may fall when the contamination potential in New Mexico is known.
The public will have a chance to comment on WIPP 3 times before EPA's final certification decision.
1. Supplemental Environmental Impact Statement (SEIS) II
The SEIS II is a document which evaluates all alternatives to WIPP, including the no action alternative which would be to leave waste where it is and not proceed with WIPP. Congress's intent in requiring agencies to prepare an environmental impact statement is to force agencies to take a hard look at their proposed plans before irretrievably committing the nation's resources. However, the heart of the SEIS is that agencies must open their project evaluation to public scrutiny and public comment. Clearly Congress hoped that exposing agency proposals to public evaluation would curb costly projects committed to benefiting special interest groups.
The irony of conducting a SEIS hearing after WIPP has been built, after very significant resources have been committed, is apparent. However, DOE did conduct two environmental impact statements for WIPP before and during the construction of the facility, one in 1980 and one in 1990. The logic which forces another environmental impact statement before WIPP can open is a conservative one. WIPP currently costs $15 million per month. The cost undoubtedly will go up during WIPP's thirty to fifty years of operation. the current estimate for WIPP's lifetime cost is $9.2 billion. Therefore, DOE must do a final environmental impact statement to take a hard look at going ahead with this costly and irreversible project, and to consider whether the wastes can stay at their existing locations.
Many people nation-wide who testified at the two previous Environmental Impact Statement hearings may feel the absurdity of participating again. However, public participation makes an enormous difference. Although DOE proceeded with WIPP despite the testimony of many citizens around the country, the testimony did not fall on deaf ears. Because of public outcry congress put EPA in charge of DOE.
The SEIS II hearings may well be the last chance people have to voice their concern for transportation safety and question assumptions about the safety of geologic disposal. You might ask, who should testify? The answer is: everyone. Without large numbers of people, EPA could easily under pressure from Congress and DOE, could provide a perfunctory and meaningless review.
SEIS II 1996 hearings are tentatively scheduled for Washington, D.C., Colorado, Oregon, Tennessee, South Carolina and Idaho. In New Mexico hearings will be in Carlsbad, Albuquerque, and Santa Fe. However, WIPP waste will come from other DOE facilities. Because WIPP requirements will affect how these facilities analyze, package, ship and store the waste, the people who work at and live near those facilities must have an opportunity to comment on the WIPP SEIS II. Additional hearings should be scheduled in other states, such as Texas and California.
2. The New Mexico Environment Department will hold hearings on WIPP's hazardous waste permit. This permit imposes conditions that must be met during the WIPP operational phase. The permit may tighten requirements for waste characterization. This would be important because DOE's waste characterization procedures involve questionable accuracy and are scientifically controversial. No date yet for hearings.
3. The Environmental Protection Agency will hold hearings on the final criteria for evaluating DOE's compliance with the scientific standards imposed on WIPP. Since no exact science exists for proving compliance with the standards the decision to allow estimated data, expert judgment, quantitative credit for qualitative safeguards such as warning signs, will be decided by the compliance criteria. The public is eminently qualified to comment on these value laden judgments which affect the compliance decision. No date yet.
For information about the SEIS II and other hearings, call the CCNS RadioActive Hotline. In Santa Fe: 982-5611 Calling long distance: 1-800-456-8863.