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.


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


  • Southwest Research and Information Center (SRIC),
    PO Box 4524,
    Albuquerque, NM 87106,
    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


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