OPPOSE
DOE'S PLAN TO EXPAND WIPP
WHAT:
The
Department of Energy (DOE) has asked the New Mexico Environment
Department (NMED) to change the operating permit for the Waste
Isolation Pilot Plant (WIPP) so that drums of waste would be opened
and examined at WIPP. DOE has stated for years that WIPP's mission
excluded opening any drums. Further, the change would allow waste
to be stored indefinitely on the surface at WIPP -- even wastes
that cannot be disposed underground.
WHAT'S
WRONG WITH THE CHANGE?
1.
It reverses the basic safety procedures at WIPP.
During the public hearing for the permit in 1999, the WIPP
official testified, under oath: "We never open waste containers
that are received from an offsite generator.... By not opening
the waste, we can eliminate the possibility of spreading contamination
throughout our facility. So not opening the containers, keeping
the containers sealed, is a major -- a major strategy in our protection
of human health and the environment." Opening drums dramatically
increases the likelihood of workers being contaminated with radioactive
and hazardous wastes. Opening drums dramatically increases the
likelihood of radioactive and hazardous wastes being released
into the environment.
2.
It gives WIPP a new, dangerous mission. WIPP has
been developed as the world's first underground repository for
some wastes resulting from nuclear weapons production. Wastes
would be shipped to WIPP for underground disposal (not surface
storage) from more than a dozen DOE sites after the wastes are
examined at those sites to insure that prohibited wastes are not
shipped to WIPP. Prohibited wastes include, among other things:
high-level radioactive wastes, explosives, liquids, ignitible,
corrosive, reactive or chemically incompatible wastes. If the
change is approved, prohibited wastes could be shipped to WIPP
based on the generator site's (often unreliable) records that
state that prohibited items are not present. Items prohibited
from underground disposal because they are too dangerous could
be stored indefinitely on the surface.
3.
It increases the likelihood that deadly high-level wastes
will come to WIPP. If DOE is allowed to change a fundamental
safety procedure and if prohibited wastes are allowed to be shipped
to WIPP, another likely change is to make WIPP the only site for
nuclear weapons wastes and also irradiated spent fuel from nuclear
power plants. This change in WIPP's mission is already being discussed
among various officials. Such an expansion would greatly increase
the hazards to workers at the site and to the public from waste
transportation.
WHAT YOU CAN DO (before September 26, 2000)
NOW:
Tell NMED
to deny the change in the WIPP permit and ask for a Class 3 Modification
process.
CALL:
NMED Secretary
Pete Maggiore (505) 827-2855
WRITE:
Mr. Steve Zappe
NM Environment Department
2044A Galisteo Street
Santa Fe, NM 87505
Email: steve_zappe@nmenv.state.nm.us
FOR MORE INFORMATION:
- Southwest Research and Information Center (SRIC),
PO Box 4524,
Albuquerque, NM 87106,
(505)262-1862
Email: sricdon@earthlink.net
website: www.sric.org
- Citizens for Alternatives to Radioactive Dumping,
144 Harvard Dr., S.E.,
Albuquerque, NM 87106,
(505) 266-2663
- Concerned Citizens for Nuclear Safety (CCNS),
107 Cienega,
Santa Fe, NM 87501,
(505) 986-1973,
website: www.nuclearactive.org
- Nuclear Watch of New Mexico,
551 W. Cordova Rd., #135,
Santa Fe, NM 87501,
(505) 989-7342
- Peace Action New Mexico
226 Fiesta Street,
Santa Fe, NM 87501,
(505) 989-4812
BACKGROUND INFORMATION:
On July 21, 2000, DOE submitted to NMED a request
for a Class 2 Modification to the WIPP operating permit to increase
above ground storage capacity, remove the time limit for storing
waste on the surface, and create new surface storage areas. The
change cannot be approved until after a 60-day public comment
period. NMED could deny or modify the request or it could require
a Class 3 Modification process which requires a public hearing,
including testimony and cross-examination of witnesses.
The reason
for the modification is to allow characterization (opening or
examining) of waste containers at WIPP. The WIPP permit, approved
by NMED on October 27, 1999, requires that such characterization
be done at the site where the waste is generated and stored and
prohibits such activities at WIPP. The purpose of the permit requirements
is to ensure that the sites actually examine waste containers
and not just depend on their written records (which are frequently
inaccurate) to determine what radioactive and hazardous wastes
are in each drum. Such characterization is to ensure that wastes
prohibited for disposal are not shipped to WIPP.
The prohibition
on opening drums at WIPP is also a fundamental safety procedure
for the facility. DOE and Westinghouse, the operating contractor,
have always said that WIPP would "start clean and stay clean."
Waste containers are shipped to WIPP, unloaded and examined to
ensure that the drums are not leaking, then taken by elevator
2,150 feet below the surface and stacked in rooms mined out of
the salt bed. The WIPP official who testified under oath at the
WIPP permit public hearing reaffirmed the long-standing safety
requirement:
"We never open waste containers that are received from
an offsite generator.... By not opening the waste, we can eliminate
the possibility of spreading contamination throughout our facility.
So not opening the containers, keeping the containers sealed,
is a major -- a major strategy in our protection of human health
and the environment."
Testimony of Robert F. Kehrman, February 22, 1999, pp. 83-84.
The proposed change includes:
* increasing the surface waste storage capacity in the Waste Handling
Building by 40 percent from 2,718 cubic feet (77 cubic meters) to
3,795 cubic feet (107.4 cubic meters);
* removing the 60-day limit for surface storage, so that wastes
can be stored indefinitely; and
* adding four new areas in the Waste Handling Building to allow
characterization and storage activities. Waste characterization
activities would include headspace gas analysis, radiography (X-raying
drums), and visual examination (opening drums and examining their
contents).
DOE has also
asked for an additional change to eliminate the audit and surveillance
program. Under that program, NMED observes DOE audits of waste
characterization activities at other sites to ensure that they
comply with the WIPP permit requirements and approves the site's
characterization program before the site can ship any wastes to
WIPP. Although DOE's public statements have implied that only
small sites would be using WIPP for characterization, in fact,
the way the modification is written, all sites would be using
WIPP for characterization. Since sites would no longer do the
waste characterization, there would be no audits or surveillance
by NMED at sites outside New Mexico.
DOE's Class
2 modification application may be found at: http://www.wipp.carlsbad.nm.us.
Additional information can be obtained at the DOE WIPP Information
Center, 1-800-336-9477, or NMED at (505) 827-2425.
Comments on WIPP Permit Modifications
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