Mission

Concerned Citizens for Nuclear Safety

Our mission is to protect all living beings and the environment from the effects of radioactive and other hazardous materials now and in the future.

P.O. Box 31147
Santa Fe, New Mexico 87594

Telephone: (505) 986-1973
Fax: (505) 986-0997
Email: ccns@nuclearactive.org

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Our Work

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Help us help you. We gratefully accept donations to assist our organization in protecting all living beings and the environment from the effects of radioactive and other hazardous materials now and in the future.

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Current Activities

No DOE Employee Testifying at Permit Hearing about Proposed WIPP Expansion

No Department of Energy (DOE) employee will testify about the purpose and need for the construction of a fifth shaft into the underground mine at the Waste Isolation Pilot Plant (WIPP) during the May 17th public hearing.  This is important because over the decades DOE has signed multiple agreements that created a “social contract” with the People of New Mexico about WIPP operations.  These include agreements that WIPP would dispose of transuranic, or TRU, plutonium-contaminated waste from nuclear weapons manufacturing, in the deep geological repository over a 25-year disposal period, and then close down.  WIPP opened on March 25, 1999.  The current permit requires closure to begin in 2024.  Pleas see “Statement of Intent to Present Technical Testimony on Behalf of Southwest Research and Information Center,” dated May 3, 2021, Docket No. HWB 21-02.  Technical Testimony Intent DH Complete

But DOE and its contractor, Nuclear Waste Partners, LLC (NWP), have other plans.  Essential to those plans is digging a new $197 million shaft to the west of the existing disposal area and mining tunnels to connect the shaft to that area.  https://wipp.energy.gov/ and https://www.nwp-wipp.com/

DOE and NWP claim that the new shaft is needed to improve ventilation, but they misrepresent the truth.  Historically, the required airflow was provided by the four existing shafts.  New ventilation systems, not requiring the new shaft, were permitted in 2018 to increase ventilation capacity lost by the February 2014 fire and radiation release.

In truth, DOE has released a number of new reports that require WIPP’s operation for at least 60 more years, but about which they refuse to provide a witness during the upcoming hearing.  DOE, Carlsbad Field Office and Nuclear Waste Partnership, 2021, “Legislative Update Waste Isolation Pilot Plant,” February 9, 2021. https://wipp.energy.gov/Library/documents/2021/Final_2021_Legislative_Update_Presentation.   DOE, “Supplement Analysis for the Waste Isolation Pilot Plant Site-Wide Operations” (for excavation of two underground replacement panels), DOE/EIS-0026-SA, March 2021, effective April 8, 2021.  https://www.energy.gov/nepa/articles/doeeis-0026-sa-12-supplement-analysis-waste-isolation-pilot-plant-site-wide

Such expansion, in violation of the “social contract,” requires additional repositories and endangers public health and the environment in New Mexico and along transportation routes through many other states.

Ninety-seven percent of the hundreds of people who have provided public comments oppose expansion.

The proposed shaft and associated drifts are the subject of a five-day virtual New Mexico Environment Department public hearing, beginning on Monday, May 17th at noon.  https://www.env.nm.gov/hazardous-waste/wipp/, scroll down to March 10, 2021 post below “WIPP News 2021.”  DOE, NWP and the State Hazardous Waste Bureau support the new shaft and drifts.  However, the public should note that the Bureau added that it reserves “the right to modify its position [before the closing of the public hearing] based on any comment or testimony presented at the hearing or based on any written comments submitted.”

Public participation is thus invited.  People can make oral comments during the virtual hearing or submit written comments before or during the hearing. 

Some people are creating short videos about their concerns for putting more plutonium on the roads resulting in increased exposures to radiation to their neighborhood and communities.  Sample videos are available at the Stop Forever WIPP Facebook page, https://www.facebook.com/StopfvrWIPP/ and YouTube, https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA also; on YouTube you will find animations, “Broken Promises, Parts 1, 2, 3, 4,” as well as recent radio interviews on KUNM, and KSFR, KNIZ

Four short sample videos are available here:  “New Mexico is Not the Nation’s Nuclear Toilet;” https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA ; “This is My Neighborhood,” https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA ;  “These are Our Neighborhoods,” https://youtu.be/Iwm6o-XP58s ;  and “Why I’m Concerned for Our Neighborhoods,” https://youtu.be/KeotZ_dutqA.

Five Stop Forever WIPP Coalition newsletters and sample public comments you can use are available at CCNS’s website at http://nuclearactive.org/, and https://www.facebook.com/StopfvrWIPP/ .  Please share this Update with family, friends, and colleagues.


Did You Know?  We are Podcasting! 

 

1.  Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself “permanently” in Santa Fe at the corner of Guadalupe and W. Alameda.  JOIN Veterans for Peace, CCNS, Nuclear Watch NM, and others.  We’ll have banners.  Please bring a sign.

 

 

2.  Mon. May 17th – Fri. May 21 – Virtual Public Hearing about Proposed Shaft for the Waste Isolation Pilot Plant (WIPP). For more information:  NM Environment Department at https://www.env.nm.gov/hazardous-waste/wipp/ (scroll down to March 10, 2021 entry); Stop Forever WIPP Coalition at  https://www.facebook.com/StopfvrWIPP/ ; and CCNS at http://nuclearactive.org/

CALL TO ACTION! 

SUBMIT YOUR ORAL AND WRITTEN PUBLIC COMMENTS

ABOUT THE PROPOSED NEW SHAFT AND DRIFTS AT WIPP!

 

Please see the five-part Stop Forever WIPP Coalition newsletters about the proposed shaft, the public hearing, how you can participate, and sample comment letters you can use.  Newsletter No. 4 available in Spanish!

https://www.facebook.com/StopfvrWIPP/ ; and http://nuclearactive.org/

Create your own short video about your concerns for putting more plutonium on the roads resulting in increased exposures to radiation to their neighborhood and communities.  Sample videos are available at the Stop Forever WIPP Facebook page, https://www.facebook.com/StopfvrWIPP/ and YouTube, https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA also; on YouTube you will find animations, “Broken Promises, Parts 1, 2, 3, 4,” as well as recent radio interviews on KUNM, and KSFR, KNIZ.

Four short sample videos are available here:  “New Mexico is Not the Nation’s Nuclear Toilet;” https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA ; “This is My Neighborhood,” https://www.youtube.com/channel/UClofjc-x5YwtXHqg5hUh0AA ;  “These are Our Neighborhoods,” https://youtu.be/Iwm6o-XP58s ;  and “Why I’m Concerned for OUR Neighborhoods,” https://youtu.be/KeotZ_dutqA.

 

This is What Happens When DOE Gets in a Hurry

As has been clearly demonstrated by the Department of Energy (DOE) in recent years, when it gets in a hurry to ship plutonium-contaminated waste from Los Alamos National Laboratory (LANL) to the Waste Isolation Pilot Plant (WIPP), bad things happen. Both DOE sites are once again announcing efforts to get waste off the Hill at LANL for disposal at WIPP, but, in reality, shipments have been slowed by those efforts.

The latest event occurred in early March when LANL informed WIPP that it shipped two waste containers that held pyrophoric materials for disposal in the deep geologic salt mine.  Pyrophoric materials are those that ignite spontaneously when exposed to air, such as plutonium.  Upon notification of the potentially non-compliant explosive drums disposed in the underground, WIPP implemented the Contingency Plan, as provided for in the New Mexico Environment Department hazardous waste permit.  Below, please read the story at DNFSB Los Alamos Activities Reports for Week Ending March 5, 2021, March 12, 2021, March 19, 2021, March 26, 2021, and April 2, 2021.  See also DNFSB Waste Isolation Pilot Plant (WIPP) Report for February 2021 (See “Emergency Preparedness” paragraph:  “[Nuclear Waste Partnership] NWP identified opportunities to improve communication between the WIPP Emergency Operations Center and Joint Information Center.  In addition, NWP identified opportunities to improve the emergency response at the Central Monitoring Room.  The next annual emergency exercise is scheduled for October 2021.” and March 2021. 

Los Alamos Week Ending March 5 2021-1

Los Alamos Week Ending March 12 2021-1

Los Alamos Week Ending March 19 2021

Los Alamos Week Ending March 26 2021

Los Alamos Week Ending April 2 2021

WIPP Monthly Ending February 2021

WIPP Monthly Ending March 2021

The permit requires the hazardous waste emergency coordinator to determine whether there is a potential for a fire, explosion, or release of hazardous materials and to act immediately.  As a precautionary measure, WIPP implemented the Contingency Plan.  See Part 2, Section 2.12 “Contingency Plan” and Attachment D “RCRA Contingency Plan” at https://www.env.nm.gov/hazardous-waste/wipp-permit-page/

Invoking the plan involves identifying the drums were disposed of in Panel 7 and they were shipped from LANL to WIPP between July and September 2020.

Because WIPP was in a two-month maintenance outage, no waste was being disposed.  Nevertheless, workers were evacuated from the underground.

The Contingency Plan remained in place for two weeks as LANL and its contractor, Triad National Security, LLC, investigated the drum contents.  Triad determined the drums were compliant with the hazardous waste permit requirements.  DOE WIPP to NMED RCRA Contingency Plan 3-19-21

Concerns about these drums had began when, on Friday, February 26, 2021, LANL Plutonium Facility workers observed sparks in a drum while packaging waste air filters used in the gloveboxes where welding takes place.  That drum contained waste from the same source as the two drums disposed of at WIPP.

The Resident Inspectors of the Defense Nuclear Facilities Safety Board at LANL reported that Triad believed that “metallic welding condensates on the filters underwent a pyrophoric reaction when a different waste item was added to the drum and breached a bagged filter allowing the influx of oxygen.”

Unlike WIPP, Triad did not invoke the Contingency Plan as required by its hazardous waste permit.  HWB-LANL-Attachment-D_November-2020

These two incidents are just the latest in a number of similar events, including the Valentine’s Day 2014 explosion of one or more LANL drums in the WIPP underground, in which 22 workers and over 8,000 linear feet of the underground mine were contaminated. The 2014 explosion closed WIPP and stopped waste shipments for three years.  http://nuclearactive.org/safety-board-has-continuing-concerns-about-safety-at-wipp/


 

Did You Know?  We are Podcasting! 

 

1. Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself “permanently” in Santa Fe at the corner of Guadalupe and W. Alameda.  JOIN Veterans for Peace, CCNS, Nuclear Watch NM, and others.  We’ll have banners.  Please bring a sign.

 

 

2. TONIGHT: Thursday, April 29th at 5:30 – LANL Director, and President of Triad National Security, LLC, Thom Mason will host a community meeting.  You can ask questions about the proposed bridge across the Rio Grande, a proposed third powerline across the Rio Grande, expanded plutonium pit production, recent accidents in the Plutonium Facility, LANL’s budget, why LANL is invading Santa Fe with nearly 600 administrative workers, water use, protection of the Rio Grande, lack of cleanup, etc., etc., etc.  Online, visit https://www.lanl.gov/community/community-meeting.shtml for the Webex meeting link, password, and information about how to submit questions.

 

 

3. Th. May 6th at 11 am MDT, DOE Secretary Jennifer M. Granholm will testify before the U.S. House of Representatives Energy & Water Subcommittee about the Fiscal Year 2022 Budget Request for the DOE. Watch it at https://appropriations.house.gov/subcommittees/energy-and-water-development-and-related-agencies-117th-congress/congress_hearing      

  

 

4. Mon. May 17th – Fri. May 21 – Virtual Public Hearing about Proposed Shaft for the Waste Isolation Pilot Plant (WIPP). For more information:  NM Environment Department at https://www.env.nm.gov/hazardous-waste/wipp/ (scroll down to March 10, 2021 entry); Stop Forever WIPP Coalition at  https://www.facebook.com/StopfvrWIPP/ ; and CCNS at http://nuclearactive.org/ See the five-part Stop Forever WIPP Coalition series about the proposed shaft, the public hearing, how you can participate, and sample comment letters you can use.  Newletter No. 4 available in Spanish!

 

 

The New Shaft Permit Modification – Part 5 – When is a Shaft Not a Shaft but an Expansion?

The New Shaft Permit Modification

Part 5

A WIPP TALE:

When is a Shaft Not a Shaft but an Expansion?

(NO this is not a joke)

Proposed WIPP Shaft Opens the Door

for WIPP Expansion

 

During the week of May 17th the NM Environment Department (NMED) will hold a public hearing on the Department of Energy’s (DOE) proposed new Shaft at WIPP. DOE expects that this shaft will be finished in 2024, which is when DOE originally told NMED that WIPP would stop receiving waste under the existing state hazardous waste permit.

WIPP 2022 Concept showing the proposed new shaft and drifts. The proposed new shafts and drifts shown at K and N. The New Shaft (K) is labeled Material Hoist/Air Intake Shaft

 

The shaft is clearly an essential part of DOE’s long range plans, to expand WIPP—currently the only nuclear waste repository in the nation—and to operate it for decades.

While NMED and DOE are trying to limit the May 17th hearing to discussion only about the shaft as a ventilation shaft, New Mexicans are connecting the dots and won’t be fooled by a DOE process that is attempting to push their FOREVER WIPP agenda through piecemeal. This approach lacks appropriate study of the health and safety for communities near WIPP, environmental and economic effects from the modification, or adequate public education or involvement.

 

WIPP’s New Shaft Application Presents a Multitude Of Concerns for New Mexicans.

With so many concerns to be addressed,

Choose one of our 3 sample comment letters to send to NMED:

 

Broken Promises and Misrepresentations

Land Use and other Economic Considerations

Public Participation

 

Copy one letter, mix & match them or put one together yourself from the bulleted concerns below.

Click the email link  here to email your comments to NMED.

You may comment orally on May 17th even if you have already emailed your comments.

Find information here on how to comment orally at the public hearing.

 


 

 

Concerns for New Mexicans:

 

BROKEN PROMISES and MISREPRESENTATIONS

 

 
  • DOE has misrepresented the purpose of the New Shaft, as only a ventilation shaft, when in reality it is the first part of a planned expansion of WIPP. The General Accountability Office calls it a “utility shaft.”  WIPP’s 2022 conceptual draft calls it a “materials hoist” as well as an air intake shaft. A new filter building will provide more air than needed and is supposed to begin operations before the shaft is even completed.
  • DOE’s promises to the people of New Mexico include limiting the amount and types of waste disposal, and developing other repositories for the rest of the waste. The WIPP expansion will violate all these promises.
  • DOE’s current expansion plans for WIPP, as reflected in their permit renewal application, would eliminate any end date for WIPP. (Hence: STOP FOREVER WIPP!)
  • WIPP’s mission was to accept legacy/Cold War transuranic weapons waste, then decontaminate and close the dump, starting in 2024. DOE and the federal government always knew WIPP could not hold all the TRU waste and promised to build other repositories for the additional waste. WIPP was to be a “pilot project” for other repositories, but no other repositories have ever been built.
  • No State, including New Mexico, is willing to host the only repository. We are unwilling to become the nation’s de facto nuclear dumping ground.

 

WHAT’S DRIVING THE WIPP EXPANSION

 

  • One major driver is waste disposal from expanded production of plutonium bomb triggers (or “pits”) at Los Alamos and Savannah River, South Carolina over the next 60 years. These triggers are designed for new nuclear weapons — not to keep the current weapons stockpile reliable.
  • Another driver is disposal of 48 metric tons of “surplus” plutonium from Pantex and Savannah River and disposal of transuranic waste from a variety of DOE sites across the country. (Transuranic waste is waste contaminated with radioactive elements greater than [trans-] uranium [-uranic]. Most transuranic waste at WIPP is contaminated with plutonium and most also includes hazardous waste.)

 

LAND USE and OTHER ECONOMIC CONSIDERATIONS

 
  • Southeastern New Mexico has thriving agricultural and ranching industries (chile, pecans, and dairy to name a few) that could be at risk from any accident or release from the site or along the shipping routes.
  • Tourism is another major economic source for New Mexico. Becoming the nation’s nuclear sacrifice area could mean the loss of  tens of thousands of jobs in all the related hospitality industries.
  • Oil and Gas development — now one of the largest in the world — is also a major source of employment and state tax revenues. There are more than 500 oil and gas wells within 2.5 miles of the WIPP site.
  • Expanding WIPP will discourage other cleaner and healthier industries from creating jobs in the area.
  • Do we really want to transition southeastern New Mexico from the historical economies of agriculture, resource extraction and tourism to becoming the nation’s nuclear and hazardous garbage dump?

 

EXPANSION RISKS

 
  • Because of mismanagement, WIPP has already experienced an underground fire and a separate underground explosion that released radiation contaminating air and land offsite. Serious safety and management issues at the repository continue to this day, making another accident more likely.
  • Again, because of mismanagement, WIPP is planning on releasing contaminated exhaust air so they can increase the speed of waste operations.
  • Underground disposal of “produced water” and fracking from the massive oil and gas industry near WIPP is increasing the number and magnitude of earthquakes in the area. This could impact the integrity of the repository.
  • Expanded waste disposal means expanded waste shipments. This waste would be transported through New Mexico and many other states for disposal at WIPP, expanding waste transportation for decades and putting communities all along the routes at risk.

 

DEFICIENT PUBLIC PROCESS

  • DOE started constructing the shaft (with NMED’s approval) before the required public hearing, thereby showing that it did not care about its promises or public comment.
  • The WIPP Fact Sheet and Public Notices for the new shaft modification provide only a minimum of information about the new shaft, the WIPP facility, the waste, the contamination underground, and the hydrology & geology near the site.
  • The long term effects on communities near the site and along transportation routes have not been adequately studied. DOE hasn’t looked at potential exposures from WIPP since the 1990s. With no updated effects studies, impacts on the general public are mostly unknown, and possible disparate impacts on communities of color are completely unknown. Thus, NMED doesn’t have the data to be truly non-discriminatory and protective of human health and the environment.
  • NMED promised to translate all “vital” or important documents for Spanish speakers who are not fluent in English so they would have access to the same information that is easily available to English speakers. However, this has not been done.
  • Only public notices and the Fact Sheet have been translated. Even the draft permit itself has not been defined as “vital,” nor has it been summarized and translated. The Fact Sheet in no way summarizes the draft permit. This leaves those New Mexicans who aren’t fluent in English unable to inform themselves fully about this permit modification and unable to participate equally and meaningfully in the public process.

 

—————————————————————————–

References and links are at the end of this email

—————————————————————————–

 

How to Comment
Email written comments to:
Madai.Corral@state.nm.us
In the subject line include: HWB 21-02 WIPP Shaft
Mail written comments to:
Hearing Clerk, NMED, Room S-2100
PO Box 5469, Santa Fe, NM 87502-5469.
In your heading, include: HWB 21-02 WIPP Shaft
 
At the public hearing provide written or oral comments in your preferred language. If you will be commenting in a language other than English or Spanish, arrange for interpretation, ideally, 10 or more days ahead by contacting:
Ricardo Maestas
505-476-6000

 


 

Please share this newsletter with family, friends and colleagues

and
 

Please donate to the Stop FOREVER WIPP Coalition

through our GoFundMe Page.

 

 


 

Looking down into the partially excavated New Shaft (image: DOE)

 

References  & Links

How to comment at the hearing by Zoom or by phone
The Updated Fact Sheet
The Public Involvement Plan (PIP)
The Informal Resolution Agreement
Analysis of the PIP, Public Notice and Updated Fact Sheet

 

For More Information

Stop Forever WIPP 
Southwest Research and Information Center (SRIC)
Concerned Citizens for Nuclear Safety (CCNS)
Nuclear Watch New Mexico
Southwest Alliance 

 

 

Three Fabulous Free Virtual Public Education Events

As we celebrate Earth Day and commemorate the 35th anniversary of the Chernobyl nuclear disaster in 1986, three free virtual events are taking place between now and Friday, April 30th.  They are the Taos Environmental Film Festival and Conference; the Building Political Support for the Nuclear Ban Treaty webinar; and the Native American Forum on Nuclear Issues.

In honor of Earth Day, Thursday, April 22nd, two outstanding New Mexico Poets Laureate, Catherine Strisik of Taos, and Elizabeth Jacobson of Santa Fe, will read their poetry beginning at 7:30 pm.  For more information and zoom links, please visit https://taosenvironmentalfilmfestival.com/somos-information-1/

The free and virtual Taos Environmental Film Festival begins on Friday, April 23rd and continues through Sunday, April 25th.  For a listing of the films, please visit https://taosenvironmentalfilmfestival.com/

Along with the Film Festival, an Earth, Wind, Fire, Water and Spirit Conference, with a focus on the Environmental and Peace, will be held virtually.  Local, national and international leaders will speak about the two existential threats, nuclear weapons and climate change, as well as the military, forests, oceans, education, social justice, and peace. The free zoom conference takes place from Friday, April 23rd through Sunday, April 25th from 11 am to 1 pm Mountain Daylight Time.  There will be two one-hour sessions, one at 11 am and the other at noon.   For more information and registration, please visit https://taosenvironmentalfilmfestival.com/conference-information/

On Saturday, April 24th, the International Campaign to Abolish Nuclear Weapons, Massachusetts Peace Action, and Nuclear Ban US host a virtual webinar, Building Political Support for the Nuclear Ban Treaty.  Speakers include U.S. and international lawmakers.  The webinar will take place from 8:30 am to 10:45 am Mountain Daylight Time.  To register, please visit http://www.nuclearban.us/

On Monday, April 26th, the Native Community Action Council, in partnership with Native Americans for Restorative Stewardship, will present a virtual and free five-day speaker series.  A number of well-known speakers and artists concerned about the impacts of nuclear issues on Native American communities will present.  The event, named the 2021 Native American Forum on Nuclear Issues, will commence on Monday, April 26th and continue until Friday, April 30th, beginning each evening at 6 pm Mountain Daylight Time.

Speakers include Winona LaDuke, Tom Goldtooth, Carletta Tilousi, Steve Newcomb, Kandi White, Myron Dewey, Tommy Rock, Manny Pino, Joe Kennedy, and Ian Zabarte. Featured artists include Jack Malotte, Sorren Thunder Richards, Sarah Caligiuri, and Bryan Hudson, among others.  To register for your complimentary ticket, please visit https://tosavetheworld.ca/events/the-native-american-forum-on-nuclear-issues-nafni-2021/


Did You Know?  We are Podcasting!

 

1.  Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself “permanently” in Santa Fe at the corner of Guadalupe and W. Alameda.  JOIN Veterans for Peace, CCNS,  Nuclear Watch NM, and others.  We’ll have banners.  Please bring a sign.

 

 

2.  TONIGHT: Th. April 22nd from 6 to 7:30 pm – Virtual open house for the Kirtland Air Force Base Bulk Fuels Facility.  You will need to download Adobe Connect software to participate.  See excerpts below from a KAFB email:   

“Attendees will need to download the free Adobe Connect software to join the virtual meeting. It is suggested this be done in advance of the meeting date and time. The updated software can be downloaded at https://helpx.adobe.com/adobe-connect/connect-downloads-updates.html.

“Community members interested in joining the virtual open house can join using the following internet connection: https://ceschool.adobeconnect.com/afcec/

“An updated presentation will be provided that will include a project status update and a question and answer period. To submit questions, e-mail brannon.lamar@us.af.mil.

“If you would like additional information, please contact Brannon Lamar at 377 Air Base Wing Public Affairs at (505) 639-8420 or by email, brannon.lamar@us.af.mil.

 

 

3.  Wed. April 28thCommunities for Clean Water (CCW) will be a featured community organization, as part of the Peace Development Fund “Healing Our Communities and Our Land,” during its Grassroots Funding Week. CCNS is a founding member of CCW.  Please support our collective work to hold LANL accountable on surface and groundwater issues by making a donation.  Thank you!  https://www.mightycause.com/story/Supportcommunitiesforcleanwater

 

 

4.  Wed. April 28thSanta Fe City Council will vote up or down on resolution, introduced by Councilor Renée Villarreal, to leave the Regional Coalition of LANL Communities (RCLC). The agenda has yet to be posted.  Check here:  https://santafe.primegov.com/public/portal#   

Note:  The hearing may be delayed for two weeks due to illness.  Stay tuned.

 

 

5.  Mon. May 17th – Fri. May 21 – Virtual Public Hearing about Proposed Shaft for the Waste Isolation Pilot Plant (WIPP). For more information:  NM Environment Department at https://www.env.nm.gov/hazardous-waste/wipp/ (scroll down to March 10, 2021 entry); Stop Forever WIPP Coalition at  https://www.facebook.com/StopfvrWIPP/ ; and CCNS at http://nuclearactive.org/ See a five-part Stop Forever WIPP Coalition series about the proposed shaft, the public hearing, how you can participate, and sample comment letters you can use.

 

Incomplete Draft Permit Supporting WIPP Expansion Subject to a Public Hearing

Activists, technical experts, and the public are asking why the Hazardous Waste Bureau (HWB) of the New Mexico Environment Department is processing an incomplete permit modification request for a proposed shaft and associated drifts at the Waste Isolation Pilot Plant (WIPP).  Last year, the HWB issued a defective draft permit for public review and comment.  Nearly 97 percent of the comments submitted opposed the proposed expansion and the new shaft.  Nevertheless, that draft permit is the subject of a virtual public hearing scheduled to begin on Monday, May 17th.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to March 10, 2021 posts.

The defects are numerous.  The hazardous waste regulations require the Department of Energy (DOE) to explain why the shaft and drifts are needed.  DOE is also required to notify the HWB of the plans to change the facility, such as the proposed waste disposal panels and rooms that would extend from the drifts.  DOE has not explained the need or their planned changes.

The National Academy of Sciences Consensus Study Report [Review of the Department of Energy’s Plans for Disposal of Surplus Plutonium in the Waste Isolation Pilot Plant, 2020, https://www.nap.edu/catalog/25593/review-of-the-department-of-energys-plans-for-disposal-of-surplus-plutonium-in-the-waste-isolation-pilot-plant ] and the Government Accountability Office [Nuclear Waste Disposal:  Better Planning Needed to Avoid Potential Disruption at WIPP, GAO-21-48, November 2020] gao-21-48 filled in some of those voids.  Their recent reports describe future waste panels and DOE’s plan to dispose of 48 metric tons of surplus plutonium, currently stored at the Los Alamos National Laboratory, Pantex, and the Savannah River Site.

In its permit application, DOE did not provide even a glimmer of the future expansion plans and it opposes any discussion of the expansion at the public hearing.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to June 12, 2020 post. The HWB did not alert the public to the planned expansion in the draft permit and similarly opposes any discussion of the expansion at the public hearing.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to June 12, 2020 post.  

Even so, this week DOE released a Supplement Analysis for the Waste Isolation Pilot Plant Site-Wide Operations, DOE/EIS-0026-SA-12, Rev. 0, Effective April 8, 2021 for two proposed “replacement” panels 11 and 12 located south of the proposed shaft No. 5.  As you can see, more panels for more waste are proposed.  But DOE has not been presented these evolving plans to the HWB as part of its permit modification request.  These evolving proposed plans are not part of the draft permit and not subject to the public hearing. DOE_EIS-0026-SA-12_SA_for_WIPP_Site-Wide_Operations_Rev0_Final_Sig_on_File

Further, the proposed shaft is estimated to cost nearly $200 million and take 37 months to build, with completion in 2024.  But the current permit, based on DOE’s previous agreements with the People of New Mexico, requires WIPP to end waste disposal in 2024 and begin a 10-year process to close the facility.  https://www.env.nm.gov/hazardous-waste/wipp-permit-page/  , see Attachment G Closure Plan – August 2020, specifically, p. 10 of the pdf, p. 6 of the document, Permit Condition G-1d(2), which reads:

The Disposal Phase for the WIPP facility is expected to require a period of 25 years beginning with the first receipt of TRU waste at the WIPP facility [March 26, 1999] and followed by a period ranging from 7 to 10 years for decontamination, decommissioning, and final closure.

The draft permit has a limited scope that does not address portions of the permit that are logically related and necessary to the need and planned changes.  For example, if DOE seeks a permit to construct the proposed shaft and related drifts, then it is logical to imagine that DOE wants to keep WIPP open beyond 2024.  DOE’s actions imply that it wants to expand WIPP’s disposal capacity.  Under the hazardous waste regulations, the related and necessary actions must be included in the DOE’s permit modification request and the draft permit.  But they are not included.

In the end, the public is entitled to review DOE’s entire expansion plan as part of the permit modification process.

A virtual public hearing about a proposed new shaft and associated drifts, essential elements for the proposed WIPP expansion, begins on Monday, May 17th, 2021.  New Mexicans can comment at that hearing where numerous groups, including CCNS, are opposing the shaft, drifts and expansion.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to March 10, 2021 post.


We are Podcasting! 

 

1. Thursday, April 15th at 6 pm – Virtual WIPP Town Hall about the environmental monitoring data from the January 31, 2021 four-hour test of the WIPP 700-C ventilation fan.  The data has also been posted to the WIPP website here https://wipp.energy.gov/700c-restart.asp.  To register for the virtual Town Hall meeting, go to:  https://zoom.us/meeting/register/tJIkceiorDMjGtffC3a56Y9w7TuyGOSXoGWg. Stakeholders can also submit questions prior to the meeting by emailing the WIPP Information Center at infocntr@wipp.ws. Questions will be accepted through the end of the business day following the virtual Town Hall meeting.  For more information:  https://wipp.energy.gov/wipp_news_20210409.asp

 

 

2. Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself “permanently” in Santa Fe at the corner of Guadalupe and W. Alameda. JOIN US!  We’ll have banners.  Please bring a sign.

 

 

3. Fri. April 16th at 1:30 pm – Virtual meeting of the Regional Coalition of LANL Communities. Please express your concerns about the continuation of the ineffective RCLC.  To view the agenda and zoom links:  https://regionalcoalitionnm.org/

 

 

4. Th. April 22nd from 6 to 7:30 pm Virtual open house for the Kirtland Air Force Base Bulk Fuels Facility. You will need to download Adobe Connect software to participate.  See email below from KAFB:    

Dear Neighbor,

“As we previously mentioned, the Air Force will be hosting a virtual open house for the Kirtland Air Force Base Bulk Fuels Facility project on Thursday, April 22, 2021 from 6:00 to 7:30 p.m. In light of Coronavirus concerns, this open house will be held virtually using a platform provided by the Air Force Institute of Technology (AFIT). Due to issues with previous software, there is a new update.

“Attendees will need to download the free Adobe Connect software to join the virtual meeting. It is suggested this be done in advance of the meeting date and time. The updated software can be downloaded at https://helpx.adobe.com/adobe-connect/connect-downloads-updates.html.

“Community members interested in joining the virtual open house can join using the following internet connection: https://ceschool.adobeconnect.com/afcec/

“An updated presentation will be provided that will include a project status update and a question and answer period. To submit questions, e-mail brannon.lamar@us.af.mil.

“If you would like additional information, please contact Brannon Lamar at 377 Air Base Wing Public Affairs at (505) 639-8420 or by email, brannon.lamar@us.af.mil.

“We ask that you share this notification with others in your community and hope you can join us at the upcoming event!

“Regards,

“Kirtland Air Force Base Public Affairs”

 

 

5. Saturday, April 24th from 8:30 am – 10:45 am on Zoom – Political Support for the Nuclear Ban Treaty, with Beatrice Fihn, Executive Director of the International Campaign to Abolish Nuclear Weapons, with ICAN campaigners around the world about how they have successfully used the ICAN Pledge to build support for nuclear abolition in other countries. Read the ICAN Parliamentary Pledge here:  https://pledge.icanw.org/

To register, see the list of distinguished speakers and sponsoring organizations, including CCNS:   http://bit.ly/political-tpnw

 

The New Shaft Permit Modification – Part 4 – Public Participation Now and at the May 17th Public Hearing

The New Shaft Permit Modification
Part 4
Public Participation Now
and at
the May 17th Public Hearing

 

The WIPP underground showing the proposed new shaft and drifts (corridors)

 

The New Mexico Environment Department (NMED) regulates WIPP as a Hazardous Waste Facility for the storage and disposal of transuranic mixed waste. Transuranic waste is waste contaminated with radioactive elements greater than (trans-) uranium (uranic). Most transuranic waste is contaminated with plutonium and most also includes hazardous waste. NMED’s authority to regulate WIPP comes from the federal Resource Conservation and Recovery Act (RCRA) and the state Hazardous Waste Act. Within NMED, hazardous waste sites are regulated by the Hazardous Waste Bureau (HWB).

 

Public Participation

During the WIPP permitting process, public comment is required. RCRA requires meaningful public participation, including adequate information and notification. Public participation must also be equal and non-discriminatory. Because of previous and continuing problems with disparate treatment, in 2017 NMED signed an Informal Resolution Agreement with EPA to keep public participation fair and meaningful for all New Mexicans.

In 2019 and 2020, several hundred people commented on the WIPP shaft modification permit. 97% of comments each time have been against the new shaft and against WIPP expansion. These comments may have influenced NMED’s decision not to renew the Temporary Authorization given DOE to start excavating the new shaft before the required public hearing.
We are in a comment period now that will continue through the last day of the public hearing in mid May.

Read on for more details on the public process

or

skip to the end for information on
how to comment now and during the public hearing

 

Barriers to Public Participation

NMED has not made it easy for the public, and especially for the “Low English Proficiency” (LEP) public, to inform themselves and be able to participate in the permitting process in a meaningful way. Only the Public Notice, the updated Fact Sheet and the Index to the Administrative Record are in Spanish. The Draft Permit and the Public Involvement Plan (PIP) (which guides the public process) are not in Spanish. (Click here for an analysis of problems in the PIP, Public Notice and updated Fact Sheet. Links to these documents and to the WIPP Permit webpage are provided at the end of the newsletter.)

 

GAO’s map of the WIPP underground showing the proposed New Shaft (labeled “Utility Shaft”) and drifts but also showing the waste panels and waste rooms. The original footprint is in blue. The proposed, expanded footprint is in green. (image: GAO)

 

The Updated Fact Sheet is inadequate. The Fact Sheet states that the new shaft is only needed for better underground ventilation during the current operational period for WIPP. It denies that this “utility shaft” is to support DOE’s planned WIPP expansion. But that justification falls flat because it never explains why the taxpayers would spend almost $200 million on the new shaft if WIPP is going to stop waste disposal in 2024 and the new shaft won’t be finished until just a few months before that date. Importantly, the updated Fact Sheet does not mention that the Temporary Authorization allowed shaft construction to begin before the required public hearing, which many people view as a predisposition to approve the permit modification and prejudice the hearing process.

NMED has said that it wants to increase public involvement in their permitting and that they particularly want to make sure that LEP persons can participate equally and in a meaningful way. But because of the limited amount of information provided even for English speakers, commenting is very difficult. Additional discriminatory barriers to participation have been created for persons who are not fluent in English as they have access to even less information than English speakers have. For LEP persons it is almost impossible to be adequately informed and to be able to participate in a meaningful way in this hearing process.

Nevertheless, the public has been persistent in making their concerns known to NMED and this has led to positive change in the past. It is important that NMED hears about public needs and concerns and that the agency is called out for not providing equal participation for all New Mexicans. Our voices do make a difference.

 


 

How to Comment

Email written comments to:
Madai.Corral@state.nm.us
In the subject line include: HWB 21-02 WIPP Shaft

Mail written comments to:
Hearing Clerk, NMED, Room S-2100
PO Box 5469, Santa Fe, NM 87502-5469.
In your heading, include: HWB 21-02 WIPP Shaft

At the public hearing provide written or oral comments in your preferred language. If you will be commenting in a language other than English or Spanish, arrange for interpretation, ideally, 10 or more days ahead by contacting:

Ricardo Maestas
ricardo.maestas@state.nm.us
505-476-6000

 


 

How to Attend the Public Hearing

The hearing begins on Monday, May 17 at noon.
The virtual public hearing is on Zoom from Noon to 4 pm and 6 to 9 pm each day.
You may also join by phone

Join Zoom Meeting:
Phone one-tap: US: +16699006833,,91728945523#,,,,*050223# or +12532158782,,91728945523#,,,,*050223#
Meeting URL: https://zoom.us/j/91728945523?pwd=YitrSUtFYnZkcE5hVGFrb2Z1UDlUdz09

Meeting ID: 917 2894 5523
Passcode: 050223

Join by Telephone
For higher quality, dial a number based on your current location.
Dial: US: +1 669 900 6833 or +1 253 215 8782 or +1 346 248 7799 or +1 929 436 2866 or +1 301 715 8592 or +1 312 626 6799

Meeting ID: 917 2894 5523
Passcode: 050223

The hearing is in English, with simultaneous Spanish interpretation.
If you need an interpreter in a language other than Spanish, contact:

Ricardo Maestas
ricardo.maestas@state.nm.us
505-476-6000

 


Please share this newsletter with

family, friends and colleagues

and
 

Please donate to the Stop FOREVER WIPP coalition

through our GoFundMe Page.

 


 

Looking down into the partially excavated New Shaft (image: DOE)

 

References

The Hearing Public Notice is at:
https://www.env.nm.gov/hazardous-waste/wp-content/uploads/sites/12/2016/05/2021-03-18-HWB-Shaft-Hearing-Public-Notice-Final-Eng-Span.pdf

The Updated Fact Sheet is at:
https://www.env.nm.gov/hazardous-waste/wp-content/uploads/sites/12/2016/05/2021-03-18-HWB-Shaft-Hearing-Updated-Fact-Sheet-Final-Eng-Span.pdf

The Public Involvement Plan (PIP) is at:
https://hwbdocuments.env.nm.gov/Waste%20Isolation%20Pilot%20Plant/200611.pdf

The Informal Resolution Agreement is at:
http://nuclearactive.org/wp-content/uploads/2021/04/ResAgreement_1-19-2017.pdf

Analysis of the PIP, Public Notice and Updated Fact Sheet is at:
http://nuclearactive.org/wp-content/uploads/2021/04/Analysis-of-the-Permit-Modification-documents.pdf

The WIPP Permit Webpage is at:
https://www.env.nm.gov/hazardous-waste/wipp/

 


 

For More Information

Stop Forever WIPP
https://www.facebook.com/StopfvrWIPP/

Southwest Research and Information Center (SRIC)
http://www.sric.org/

Concerned Citizens for Nuclear Safety (CCNS)
http://nuclearactive.org/

Southwest Alliance
https://www.swalliance.org/

Stop FOREVER WIPPswalliance.orgnuclearactive.org

 

 

 

LANL Sparking Drum Causes Suspension of Radioactive Waste Shipments to WIPP

[There is a lot of information in this Update to help you understand the complexity of the LANL/WIPP/Expanded Plutonium Pit Production at LANL/Expansion Plans at WIPP issues.  Please read all the way to the end to learn about how to prepare for the May 17, 2021 public hearing about the proposed new shaft at WIPP.  There is an extensive list of links to reports about the sparking drum at LANL and WIPP.  Thank you for your interest in these issues!]

On February 26th, 2021, Los Alamos National Laboratory (LANL) workers saw sparks inside of a recently packaged 55-gallon drum of plutonium-contaminated transuranic (TRU) waste at the Plutonium Facility.  The workers followed procedures and pulled the fire alarm and evacuated the area.  LANL’s investigation then found that four other drums containing similar waste were still at LANL and that two such drums had been shipped to the Waste Isolation Pilot Plant (WIPP) and disposed in 2020.  In response to LANL’s findings, WIPP evacuated workers from the underground and suspended shipments from LANL.

This story is reminiscent of the February 14th, 2014 explosion of one or more drums in the WIPP underground.  These drums also had been packaged at LANL.  In that case, LANL scientists incorrectly used organic, rather than non-organic, kitty litter to sop up liquids in the drums.  The organic kitty litter created a chemical reaction and radiation release that contaminated 22 workers and over 8,000 linear feet of the underground mine; and vented contaminated air directly to the environment.

Both incidents show inadequacies in WIPP’s Central Characterization Project that operates at LANL and other sites and is supposed to ensure proper analysis of the waste.  Nevertheless, LANL again has shipped incompatible drums to WIPP.  Following the 2014 Valentine’s Day explosion, WIPP was closed for nearly three years at a $2 billion cost to taxpayers. Because of the underground contamination, WIPP continues to receive waste at a much lower rate than before the explosion.

The mission of WIPP is to dispose of “legacy” radioactive and hazardous waste created by the research, fabrication, and testing of nuclear weapons during the Cold War.  It appears that the sparking drum packaged in the Plutonium Facility and the other similar ones are “newly generated” waste from efforts to modernize nuclear weapons.

As LANL prepares to expand its fabrication of plutonium pits, the radioactive triggers for those nuclear weapons, the resulting TRU waste would exceed the capacity limits at WIPP, according to reports in 2020 from Government Accountability Office and National Academy of Sciences.  When establishing those limits in 1992, Congress tasked DOE to establish other waste repositories, but none are yet planned.

Instead DOE wants to expand the underground disposal area at WIPP for the additional waste, keep the site open until at least 2080, and develop no other repository.

A virtual public hearing about a proposed new shaft, an essential part of the WIPP expansion, begins on Monday, May 17th. New Mexicans can comment at that hearing where numerous groups are opposing the shaft.

 


QUESTIONS ABOUT HOW TO PREPARE FOR THE  May 17, 2021 PUBLIC HEARING?

 

Over the next five weeks, CCNS, working with the Stop FOREVER WIPP Coalition, will be providing information about the proposed new shaft, along with the connections between proposed expanded plutonium pit production at LANL and the lack of WIPP disposal space for such waste.  Check out the animations at https://www.facebook.com/StopfvrWIPP/

The Stop FOREVER WIPP Coalition has prepared three newsletters with more detailed information.  They are:

Part 1:  The New Shaft Permit Modification – Public Hearing Begins on Monday, May 17, 2021  http://nuclearactive.org/stop-forever-wipp-newsletter/

Part 2:  The New Shaft Permit Modification – WIPP’s Temporary Authorization http://nuclearactive.org/the-new-shaft-permit-modification/

Part 3:  The New Shaft Permit Modification – Your Comments and the May 17th Public Hearing.  Includes sample public comment letter you can use to submit.  http://nuclearactive.org/stop-forever-wipp-the-new-shaft-permit-modification-part-3/

For more information, check out these links:

Defense Nuclear Facilities Safety Board (DNFSB) Los Alamos Activity Report for Week Ending March 5, 2021.  https://www.dnfsb.gov/documents/reports/resident-inspector-weekly-reports/los-alamos-week-ending-march-5-2021   “We note that this energetic chemical reaction underscores the need for Triad to fully address the concerns outlined in DNFSB/TECH-46 Potential Energetic Chemical Reaction Events Involving Transuranic Waste at Los Alamos National Laboratory.”  https://www.dnfsb.gov/documents/letters/potential-energetic-chemical-reaction-events-involving-transuranic-waste-los  

DNFSB Los Alamos Activity Report for Week Ending March 12, 2021.  https://www.dnfsb.gov/documents/reports/resident-inspector-weekly-reports/los-alamos-week-ending-march-12-2021  “Triad personnel continued their efforts to identify waste containers with contents similar to those involved in the incident that occurred two weeks ago (see 3/5/2021 report.  They identified potential containers at the Plutonium Facility, Transuranic Waste Facility (TWF), and the Waste Isolation Pilot Plant.”   

March 12, 2021 NNSA letter to NMED about potential non-compliance under the Hazardous Waste Facility Permit.    

DNFSB Los Alamos Activity Report for Week Ending March 19, 2021.  https://www.dnfsb.gov/documents/reports/resident-inspector-weekly-reports/los-alamos-week-ending-march-19-2021  “On Monday, Triad personnel commenced an investigation for the event associated with the suspected titanium welding fume condensate that readily ignited into sparks during a waste drum-out (see 3/5/2021 report).”

March 19, 2021:  Report of Implementation of the Resource Conservation and Recovery Act Contingency Plan at the Waste Isolation Pilot Plant Facility on March 4, 2021, Hazardous Waste Facility Permit, Number NM4890139088-TSDF, Reinhard Knerr/CBFO and Sean Dunagan/NWP to Kevin Pierard, NMED HWB  https://wipp.energy.gov/2021-information-repository-documents.asp

Los Alamos Reporter:  March 24, 2021:  “WIPP Central Characterization Project is Lynchpin for Radioactive Waste Receive from LANL, Other DOE Sites”

[Reinhard Knerr, DOE’s field manager at WIPP] discussed the importance of the Central Characterization Project (CCP) which was established by DOE to standardize and provide efficiencies in the characterization and certification process at DOE waste generator sites such as LANL.

“The area I most worry about is the interface between the generator site and our program. We rely on Environmental Management at Los Alamos and their contractors to give us information. Sometimes they don’t have the information because it’s legacy waste and it really becomes a research project on both sides of the fence to make sure we understand what we’re taking,” he said. “Newly generated waste should be easier but sometimes the downside for newly generated waste is that people will make operational errors whenever you deal with it. There’s always room for mistakes so those are the types of things I’m a little more nervous about to tell you the truth because the legacy waste – it is what it is.”

Knerr said the legacy waste has been sitting for decades so “you feel pretty comfortable and if you don’t know what it is, you go ahead and you sample”. He said the CCP program is probably one of the most regulated programs anywhere in the world and that the people involved take a lot of pride in what they do especially when they are doing Acceptable Knowledge” research and chemical compatibility analyses to make sure they have multiple layers of control.

“I think we have learned a lesson that an error along that front has a lot of potential ramifications for us in the underground with regard to the operability of the repository. That program is a lynchpin of our characterization process but again we are dependent on the generator site,” Knerr said.

https://losalamosreporter.com/2021/03/24/wipp-central-characterization-project-is-lynchpin-for-radioactive-waste-received-from-lanl-other-doe-sites/

DNFSB 31st Annual Report to Congress, March 23, 2021.  See

  1. iii (Safety of Solid Nuclear Waste);
  2. 14 – 17 (Los Alamos National Laboratory);
  3. 22 – 24 (Safety of Solid Nuclear Waste);
  4. 29 – 30 (Los Alamos National Laboratory);
  5. 33 (Chemical Compatibility of Waste Mixtures with Nitric Acid and Nitrate Salts).

https://www.dnfsb.gov/documents/reports/reports-congress/31st-annual-report-congress

*** TODAY’S NEWS*** April 8, 2021:  “DOE prepared this supplement analysis (SA) to evaluate the Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement (DOE/EIS-0026-S2) in light of changes that could have bearing on the potential environmental impacts previously analyzed. Included with this SA is a proposed change pertaining to the excavation of two underground replacement panels for the disposal of transuranic (TRU) waste.”

https://www.energy.gov/nepa/articles/doeeis-0026-sa-12-supplement-analysis-waste-isolation-pilot-plant-site-wide


Did You Know?  We are Podcasting! 

1. Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself in Santa Fe at the corner of Guadalupe and W. Alameda. JOIN US!  We’ll have banners.  Please bring a sign.

 

 

2. Th. April 22nd from 6 to 7:30 pmVirtual open house for the Kirtland Air Force Base Bulk Fuels Facility. You will need to download Adobe Connect software to participate.  See email below from KAFB:    

Dear Neighbor,

“As we previously mentioned, the Air Force will be hosting a virtual open house for the Kirtland Air Force Base Bulk Fuels Facility project on Thursday, April 22, 2021 from 6:00 to 7:30 p.m. In light of Coronavirus concerns, this open house will be held virtually using a platform provided by the Air Force Institute of Technology (AFIT). Due to issues with previous software, there is a new update.

“Attendees will need to download the free Adobe Connect software to join the virtual meeting. It is suggested this be done in advance of the meeting date and time. The updated software can be downloaded at https://helpx.adobe.com/adobe-connect/connect-downloads-updates.html.

“Community members interested in joining the virtual open house can join using the following internet connection: https://ceschool.adobeconnect.com/afcec/

“An updated presentation will be provided that will include a project status update and a question and answer period. To submit questions, e-mail brannon.lamar@us.af.mil.

“If you would like additional information, please contact Brannon Lamar at 377 Air Base Wing Public Affairs at (505) 639-8420 or by email, brannon.lamar@us.af.mil.

“We ask that you share this notification with others in your community and hope you can join us at the upcoming event!

“Regards,

“Kirtland Air Force Base Public Affairs”

 

3. Submissions due Tuesday, June 1st: Calling all youth and community artists!

Communities for Clean Water (CCW) is working on a new ZINE and would love to feature your art, poetry, photography or writing. Open to all mediums and creative ideas.

Some questions to spark your reflection:

** Why is water sacred to you?
** What does it feel like in your body to live near LANL?
** How has your family and community been impacted by LANL?
** If water, land and air could speak, what would their message be?

Contact – ccwyouthreps@gmail.com – with submissions or questions! 

 

Stop FOREVER WIPP! The New Shaft Permit Modification – Part 3

The New Shaft Permit Modification
Part 3
Your Comments and the May 17th Public Hearing

 

As demanded by organizations and individuals, the New Mexico Environment Department (NMED) has scheduled a public hearing on adding a New Utility Shaft to the WIPP permit. The hearing will start at noon on Monday, May 17, 2021. Hundreds of people commented on the proposed new shaft in 2019 and 2020, and 97 percent of them objected to WIPP expansion and the new shaft.

NMED allowed the Department of Energy (DOE) to bypass the public process and start digging the new shaft with just a Temporary Authorization. But after receiving so many public comments in 2020 against the new shaft and against the Temporary Authorization, NMED stopped the construction of the shaft until after the public hearing. Public comments do make a difference!

A bucketload of excavated material is lifted from the utility shaft during the Temporary Authorization period. The Galloway work platform is at center. This multi-stage platform is suspended near the bottom of the shaft during shaft sinking. (image: DOE)

 

You can comment now on the proposed new WIPP shaft, which is part of DOE’s plan to expand WIPP and operate it forever, instead of developing new repositories. The plan violates existing limits set in federal law, state agreements, the WIPP Permit, and DOE’s decades-old social contract with New Mexicans.

Your comments and participation can help stop the new shaft and DOE’s WIPP expansion plan!

 

Read on to learn more

or

skip to the end to see a sample comment

 

The proposed expanded underground repository. Solid lines show current drifts (corridors), waste panels and waste rooms. Proposed drifts, panels and rooms are shown with dashed lines. The proposed new utility shaft is labeled in red “Shaft 5.” The four current Air Intake, Salt Handling, Waste and Exhaust Shafts are labeled in black. (image: Steve Zappe)

 

Hearing Officer Gregory Chakalian will preside over the public hearing, which will include testimony and cross-examination of several experts from DOE, NMED, and from the organizations and individuals that requested the hearing. There will also be oral comments from the public and the public can cross examine any of the witnesses.

Later in the summer, based on the regulations, the hearing record, evidence, testimony, and public comment, the Hearing Officer will issue a recommendation to approve or deny the shaft permit or to approve it with conditions. The NMED Secretary will then make the final decision, which can be appealed to the New Mexico Court of Appeals.

Details about how to watch and participate in the public hearing, either on Zoom or by phone, are provided in NMED’s Public Notice and Fact Sheet (both in English & Spanish). Simultaneous Spanish interpretation will be available on both Zoom and by phone, and interpretation into other languages may be available upon request. Future newsletters will provide more detailed information about the hearing.

Although oral public comments can only be provided during the hearing itself, anyone can submit additional written comments now and until the hearing is over.

 

Submit your own written comment, or copy and paste the following sample comment

Email comments to the NMED Hearing Clerk in Santa Fe

Madai.Corral@state.nm.us

 


 

 

SAMPLE COMMENT

 

Subject: HWB 21-02 WIPP SHAFT

I join with many other people to object to WIPP expansion and the new shaft. Please deny the new shaft draft permit.

The DOE expansion plan violates existing limits on WIPP set in federal law, state agreements, the WIPP Permit, and DOE’s decades-old social contract with New Mexicans.

DOE has not presented the entire WIPP expansion plan to the public and to New Mexico officials. Instead, DOE is providing only a single piece of the plan – the new shaft – saying that other pieces of the plan will be presented in the future. I object to DOE’s piecemeal and illegal approach. In order to provide informed public comments, the public must be able to review DOE’s entire plan.

I know that, after examining the expansion plan, the 2020 National Academy of Sciences report stated, “An incremental approach inhibits a comprehensive review by regulators and public of the full impact of the proposed … program on a future WIPP.”

I also know that, in 2020, it was the Government Accountability Office – not DOE – that provided the public with the design of DOE’s plan to more than double the number of underground waste disposal panels.

DOE’s claim that the new shaft is needed for underground ventilation is not true. WIPP has been operating all along with just the existing four shafts. When the New Filter Building is completed, it will provide more underground ventilation than WIPP has ever had before. Instead of being just a ventilation shaft, the New Utility Shaft is actually an integral part of DOE’s expansion plans. These expansion plans must be a part of the public hearing.

Again, please deny the draft permit.

(Your Name, Address and Date)

 

 


 

Please share this newsletter with

family, friends and colleagues

and
 

Please donate to the Stop FOREVER WIPP coalition

through our GoFundMe Page.

 

References
2020 NAS Reporthttps://www.nap.edu/25593
For More Information
Stop Forever WIPP
Southwest Research and Information Center (SRIC)
Concerned Citizens for Nuclear Safety (CCNS)
Southwest Alliance
 

New Mexico Files Suit to Halt Two Proposed High-Level Nuclear Waste Storage Facilities

(AP Photo/Susan Montoya Bryan, File)

On Monday, Attorney General Hector Balderas took a necessary step to protect the People, environment, and economy of New Mexico by filing a lawsuit against the United States Nuclear Regulatory Commission to stop its efforts to license two proposed facilities for high-risk, high-level radioactive waste from nuclear power plants.  Balderas alleges the proposals present a clear and present danger to New Mexico because of the risky and long-term burdens they impose on the State.  The suit was filed in the U.S. District Court for the District of New Mexico.  Attorney_General_Balderas_Announces_Lawsuit_to_Halt_Holtec_Nuclear_Storage_Facility

Holtec International is proposing to build and operate a consolidated storage facility, located halfway between Carlsbad and Hobbs, New Mexico, in the oil patch.  Holtec is seeking a license to store 8,680 metric tons of uranium vertically in 500 lead-lined canisters for 40 years, with future expansion to 10,000 canisters containing 100,000 metric tons of uranium for 120 years or longer.

Also, Interim Storage Partners is proposing to expand Waste Control Specialists low-level waste facility in Texas, located five miles east of Eunice, New Mexico.  Its application calls for storage of 40,000 metric tons of uranium for at least 40 years.

The license applications have a fatal flaw that NRC has ignored, while it continues to process the applications.  Challenges from local community members have been rejected, as well as the expert comments from New Mexico state agencies.  http://nuclearactive.org/officials-and-ngos-express-deep-concerns-about-holtec/ and http://nuclearactive.org/public-comments-needed-by-september-22nd-about-holtec-proposal/

The fatal flaw, you ask?  The applications of the limited liability corporations assume that the Department of Energy (DOE) will take title to the waste and pay the costs.  But the 1982 Nuclear Waste Policy Act prohibits DOE from taking title until a permanent federal repository is operating.  Yucca Mountain, the only proposed disposal facility, has been canceled for more than a decade.  Even so, the applications state that a permanent repository will be built by 2048.

This means that unacceptable burdens would fall on New Mexico should NRC illegally grant one or both licenses.  New Mexico would be responsible for emergency preparedness and response for transportation-related accidents along road and rail transportation routes that have yet to be disclosed.  Further, New Mexico would be responsible for the repair and maintenance for many years.  If the NRC grants one or more of the licenses, the ongoing daily threat from the transportation of the waste and operations at the facility(ies) would create an imminent and substantial endangerment to the diverse communities of New Mexico.

Attorney General Balderas explains why he took the legal action.  “I want to mitigate dangers to our environment and to other energy sectors.  It is fundamentally unfair for our residents to bear the risks of open ended uncertainty.”

In the lawsuit, New Mexico asks the Court for a preliminary injunction to suspend the licensing processes, as well as to declare the case in its favor.  https://www.nmag.gov/


1. Every Friday and Saturday from noon to 1 pm – Protest LANL signing a 10-year lease (for the former Descartes building) to establish itself in Santa Fe at the corner of Guadalupe and W. Alameda. JOIN US!  We’ll have banners.  Please bring a sign.

 

2. On Wednesday, March 31, 2021, the Santa Fe City Council voted 5 – 3, with Councilor Mike Garcia, the Council’s representative on the Regional Coalition of LANL Communities (RCLC), abstaining, to not approve the amended Joint Powers Agreement. https://www.santafenewmexican.com/news/local_news/santa-fe-city-council-rejects-lanl-coalition-agreement/article_570374dc-9234-11eb-9551-5be77d317e1f.html#tncms-source=login    Councilor Renee Villarreal will introduce a resolution for the City to withdraw its membership in the RCLC.  Stay tuned!  Raise your voice!

 

3. On Monday, March 29, 2021, CCNS, Honor Our Pueblo Existence (H.O.P.E.), and the New Mexico Acequia Association submitted supplementary comments to the Environmental Protection Agency (EPA) about its draft industrial wastewater discharge permit for 11 outfalls at Los Alamos National Laboratory (LANL). Our comments were filed in response to the Department of Energy and Triad’s request to EPA to reopen the comment period and its February 25, 2021 supplementary filings about the draft permit, challenge to the New Mexico Environment Department’s §401 certification of the draft permit, and planned changes to the Radioactive Liquid Waste Treatment Facility for Outfall 051.  https://www.epa.gov/nm/los-alamos-national-laboratory-lanl-limited-reopening-public-comment-period-npdes-permit-no  To review the filings, scroll down to the bottom of the page:  https://www.epa.gov/nm/los-alamos-national-laboratory-lanl-limited-reopening-public-comment-period-npdes-permit-no-0

 

The New Shaft Permit Modification

The New Shaft Permit Modification
Part 2
WIPP’s Temporary Authorization

 

The New Mexico Environment Department (NMED) must approve or deny the Department of Energy’s (DOE) New Shaft Permit Modification Request (PMR), based on regulations, evidence, and public comment. However, even before issuing the Draft Permit for public comment, NMED allowed DOE to start shaft construction under a Temporary Authorization (TA). The 180-day TA expired on October 24, 2020, and NMED denied the request to re-issue the TA. Under the TA, the new shaft was sunk to 116 feet deep – of a final proposed depth of 2,275 feet. The total estimated construction time is 37 months at an estimated cost of $197 million.

Looking down the New Shaft during the Temporary Authorization period.
An excavator and a personnel hoist are ready to be lifted out of the utility shaft
prior to another round of blasting. (image DOE)

 

In approving the TA, NMED stated: “This authorization is temporary and does not constitute a final agency action on the pending Class 3 PMR, nor does it prejudice or presuppose the outcome of the final action on the PMR. If NMED ultimately denies the PMR, the Permittees must reverse all construction activities associated with this Request at their expense and within the timeframes specified by the Department.”

 

Read on to learn more
or skip to the end
to see how you can help stop the WIPP expansion

 

Objecting to the TA

Various groups and individuals objected to the TA because it appeared to approve the new shaft before the required public comments and public hearing on the draft permit. It was also an “end run” around public involvement in deciding whether or not the New Shaft is even needed.

In 2019, 97 percent of the 295 organizations and individuals commenting on the New Shaft modification request opposed that request and also objected to the WIPP expansion.

On June 12, 2020, NMED issued the draft permit for 60 days of public comment. Again, 97 percent of the 360 organizations and individuals that commented opposed the New Shaft draft permit, including objecting to the WIPP expansion.

 

What isn’t said

The regulations require that the Permit Modification Request must state the need for the New Shaft and that the proposed change protects public health and the environment. The PMR and draft permit state that the need is for underground ventilation and do not mention that the New Shaft is an essential part of the WIPP expansion. (The shaft’s diameter is wide enough for a new waste hoist.) Nor do they describe the health and environmental impacts of “Forever WIPP.” (image DOE)

 

The public hearing

During the public hearing in May, Technical Testimony will be presented and witnesses cross-examined. The public can comment as well, both during the hearing itself and during the pre-hearing period we are in now. Public comment includes previous written comments, written comments submitted before the hearing begins, and written and oral comments made during the public hearing itself. All comments from the public must be considered along with technical testimony from expert witnesses when the the NMED Secretary makes his decision on the permit.

The hearing begins on Monday, May 17 at noon and will continue for a few days. People can participate on Zoom or by phone. There will be simultaneous English/Spanish interpretation.

More information about how to comment will be provided in the next Update. (image DOE)

 

How You Can Help Stop the New Shaft and the WIPP Expansion

People can help stop this New Utility Shaft by reading NMED’s Public Notice and Fact Sheet (both in English & Spanish), reading our analysis of these documents, and by participating in the permit modification hearing. Read our future newsletters to see our analysis, read a short timeline & history of WIPP, and to find out more on how you can participate and influence the hearing process.

 

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family, friends and colleagues

and

Please donate to the Stop FOREVER WIPP coalition

through our GoFundMe Page.

 

For More Information
Stop Forever WIPP
Southwest Research and Information Center (SRIC)
Concerned Citizens for Nuclear Safety (CCNS)
Southwest Alliance