TONIGHT at 5 pm MT and 8 pm MT: Two showings of Power Struggle, a 88-minute film by director Robbie Leppzer, POWER STRUGGLE (PowerStruggleMovie.com) that portrays Vermont’s heated political battle to shut down the Vermont Yankee nuclear power plant, located in southern Vermont on the banks of the Connecticut River. After the 5 pm MT showing, Arnie and Maggie Gunderson of Fairewinds Energy Education will examine the potential dangers of a nuclear disaster in Ukraine and discuss the ongoing efforts to track the migration of radioactive contamination worldwide. Screening tickets – $12 – https://kinema.com/events/power-struggle-zglpf2 After the 8 pm MT showing, Kevin Kamps of Beyond Nuclear will examine those potential dangers; the long-term threats to human health posed by high-level radioactive waste worldwide and the current battles in the U.S.A. over nuclear waste sites; and Holtec International’s safety violations in the construction of a high-level nuclear waste storage facility at the Chernobyl site. Screening tickets – $12 – https://kinema.com/events/power-struggle-4yqpng
March 10, 2022: The International Physicians for the Prevention of Nuclear War (IPPNW), the World Medical Association, the World Federation of Public Health Associations, and the International Federation of Medical Student Associations released their Global medical and public health organizations call for immediate end to war in Ukraine and critical need to prevent nuclear escalation. https://www.ippnw.org/wp-content/uploads/2022/03/Health-statement-Ukraine-March-2022.docx.pdf
Nuclear Issues Study Group, Manhattan Project for a Nuclear-Free World and Affected Communities & Allies Working Group present Nuclear is Not a Climate Solution on YouTube about nuclear testing in the Pacific, the nuclear disaster in Fukushima on March 11, 2011, and radioactive waste in the U.S. https://www.youtube.com/watch?v=lqQwRl5nqbQ
Friday, March 11 at 7 to 8 pm MT: Mothers for Peace presents Fukushima: 11 years after the triple meltdownwith Japanese journalist Hiroko Aihara who will be speaking on the current state of the Fukushima evacuees, the government’s plan to release irradiated water into the ocean, and what actions we can take. Please register in advance for this event: https://us02web.zoom.us/meeting/register/tZcudequqz0oGdNnRbckyKXrAM4muPQqioCt After registering, you will receive a confirmation email containing information about joining the meeting.
, March 12 at 11:30 am MT, Nuclear Watch South, Beyond Nuclear and Sierra Club presents Fukushima in the Foothills? about the Oconee Nuclear Station 50-mile Emergency Planning Zone involving three states (Georgia, North Carolina and South Carolina), 27 counties and 1,435,128 residents. No pre-registration required.
Last week, the New Mexico Water Quality Control Commission met to deliberate and make final decisions about the state’s Surface Water Quality Standards. In a Clean Water Act administrative process that occurs approximately every three years called the Triennial Review, conservation groups, including Amigos Bravos, Communities for Clean Water (CCW) and Gila Resources Information Project (GRIP), made proposals to the Commission to strengthen water quality standards and include important definitions that address the impacts of climate change on New Mexico’s waters. As temperatures increase across the Southwest the need to further protect New Mexico’s waters is paramount. https://www.env.nm.gov/opf/water-quality-control-commission/ and https://www.env.nm.gov/opf/docketed-matters/ WQCC 20-51 (R) In the Matter of Proposed Amendments to Standards for Interstate and Intrastate Waters, 20.6.4 NMAC.
The conservation groups successfully supported the state’s proposal to add climate change language to the objectives and definitions section of the standards. They also supported removing regulatory language that indicated a false equivalency between human sources of climate change and natural ones.
During the public hearing last summer, there was much argument about a proposed definition of “emerging contaminants,” such as PFAS, which was vigorously opposed by industry and Los Alamos National Laboratory (LANL). As a result of the Commission’s action last week, the New Mexico Environment Department now has the authority to require monitoring for emerging contaminants in federal water discharge permits.
LANL made many proposals to limit the Environment Department’s regulatory authority to protect water quality. One proposed analytical method would have limited the detection of PCBs in surface water. Another proposal was to eliminate sampling requirements for PFAS, the long-lasting “forever” chemicals, used as fire retardants in places such as at Cannon Air Force Base near Clovis. The Commission voted against LANL’s proposals.
Amigos Bravos was represented by the Tannis Fox of the Western Environmental Law Center. https://westernlaw.org/ CCW and GRIP were represented by Charlie deSaillan of the New Mexico Environmental Law Center. https://nmelc.org/
Amigos Bravos, based in Taos, works to hold polluters and government agencies accountable for water contamination and hazardous waste. https://www.amigosbravos.org/
CCW works to ensure that LANL-impacted community waters are kept safe for drinking, agriculture, sacred ceremonies, and a sustainable future.
GRIP, based in Silver City, works to safeguard natural resources and to facilitate informed public participation in resource use decisions. https://gilaresources.info/wp/
The Commissioners’ votes to strenghten the regulatory requirements that businesses, industries and municipalities must meet goes a long way to ensure protection of water quality.
With one click email your comments to NM Governor Michelle Lujan Grisham urging her to take action against the expansion of the Waste Isolation Pilot Plant (WIPP). https://stopforeverwipp.org/take-action-1
Cindy Weehler gave a powerful speech during the March 1, 2022 press conference at the New Mexico Capitol about why you should care about the expanding mission for the Waste Isolation Pilot Plant (WIPP). People are opposing the Department of Energy (DOE) WIPP expansion plans that violate the law. We provide Weehler’s speech below.
Weehler is Co-Chair of 285 ALL, a neighborhood issues awareness group based south of Interstate 25. Before the press conference, she presented over 1,100 petition signatures to the Governor’s Office. The petition reads:
Petition to Governor Michelle Lujan Grisham
New Mexicans call on Governor Michelle Lujan Grisham to stand up for public health and the environment by stopping the expansion of the nuclear waste facility called the Waste Isolation Pilot Plant (WIPP) in southeastern New Mexico.
New Mexicans oppose the nuclear waste expansion at WIPP because:
The federal government’ plans would transport more nuclear weapons waste to WIPP than is allowed.*
The plutonium nuclear waste in the WIPP expansion is still dangerous for hundreds of thousands of years and endangers the health of our families and future generations.
Unless New Mexico says ‘NO’ to WIPP expansion, other disposal locations will not be developed, and WIPP and NM will always be the only dump site, which is not fair. New Mexico never agreed to bear the burden of being the only nuclear waste dump site in the country.
The federal government has not been transparent about its WIPP expansion plans, and has repeatedly refused to discuss the plans publicly, including in hearings on the WIPP Permit. Many New Mexicans are not even aware of those plans. We deserve a transparent and fair process that includes the voices of all impacted communities.
We strongly support, and urge our Governor to take all necessary actions, including denying permits for the piecemeal expansion.
Press Conference Comments of Cynthia Weehler, Co-Chair of 285ALL
Rancher Ed Hughs
“Today, I’m not only speaking for the communities along Hwy 285, where I live; I’m speaking for all the communities along the radioactive waste route to and from LANL [Los Alamos National Laboratory]…those along NM 502, the farming pueblos, NM 599, those on the southern edge of town, and the ranchers along I-40. I’m also speaking for the communities in these 11 states that will now be included on the transport route, both coming and going. All of these communities will be at a higher level of risk because they’re on the radioactive transport route planned in the new Department of Energy [DOE] mission to expand WIPP. And none of them know about it.
“I’m calling out the DOE and WIPP today. They have covered up the new mission so that the public and our elected officials either don’t understand it or don’t even know about it. They refuse to meet with us. They distort the facts given to the media, even redefining words like transuranic so it now means “not that harmful,” when it means nothing of the sort. They try to break the expansion up into pieces so each one, separately, looks innocent. They act as if they can play [the] public; we disagree.
“So let me be clear, DOE is changing WIPP in every fundamental way, and it will have a huge effect on us:
The waste will be an unauthorized and much more dangerous form of plutonium,
When added to the huge new waste stream from new pit production, WIPP will need to hold 50% more waste than is allowed,
Instead of stopping shipments of waste to WIPP in 2024, it will continue taking more for most of the rest of the century,
The shipments past our communities will increase many times over, and
Much of that waste won’t be travelling in TRUPACT containers.
“This information comes from the Federal Register and the National Academies of Sciences.
“New Mexico agreed to host WIPP after carefully crafting agreements that limit what the federal government can do with it. It was afraid that this very thing would happen, and DOE didn’t disappoint. WIPP’s mission can only be changed if the DOE breaks every legal agreement that it made with NM in order to get it to host the WIPP site in the first place. These agreements are still in place, it is illegal to break them without changing the law or the permits, and New Mexico simply needs to insist they be honored, something the New Mexico Environment Department has refused to do.
“The DOE is right to withhold this information from New Mexicans; unethical and illegal, but it’s the right thing to do. Because when the public is told, it says, “no.” Over 1,000 New Mexicans from all the zip codes shown on this map signed this petition as soon as they saw it. This is the first any of them had heard about WIPP expanding; the first time the risks had been explained.
“Today, we delivered the petitions to the Governor. The signers ask for her protection from this federal overreach. We ask her because she has the tools, in the form of those agreements, to stop this. The petition says that her constituents support any actions she takes to protect them from this planned expansion and that it’s time for the DOE to find other sites for new waste. We have requested a response by March 15.
“New Mexico has done its part. Our agreements should be honored.
Commissioner Hansen speaking at the event
We made them in good faith, and the DOE should not be trying to pull a last-minute bait and switch by bringing waste to WIPP that wasn’t agreed to.
“Most importantly, the DOE doesn’t get to put us at risk quietly, in secret, and in an information blackout. If it wants to try to put us at risk, it had better do so openly and in the full light of day.”
Santa Fe County Commissioner Anna Hansen, Tewa Elder Kathy Wanpovi Sanchez, and Quay County ranchers Ed and Patty Hughs also provided comments.
1. CANCELLED: March 3rd at 5:30 pm – WIPP Virtual and In Person Community Forum with Reinhard Knerr, Manager of the DOE’s Carlsbad Field Office, and Sean Dunagan, President & Project Manager of Nuclear Waste Partnership, LLC. Forum will be rescheduled.
2. Sunday, March 6th at noon to 1 pm – International Day of Action for Peace in Ukraine, at the corners of West Alameda and Guadalupe in Santa Fe. What better place than where LANL has office space? Please note: LANL is the only Department of Energy (DOE) facility with the capabilities to fabricate plutonium pits, or triggers, for nuclear weapons. Join us for a peaceful demonstration. This Sunday, March 6th will be an international day of action for peace in Ukraine, a massive, unified response by peace-loving people around the world to say No to War in Ukraine; Yes to Negotiations and Peace. Find an event near you or sign up to organize one! We must make it clear that the war in Ukraine is a disaster for the people of Ukraine and a terrible threat to us all, including increasing the danger of nuclear war. There must be an immediate and unconditional ceasefire. You can downloaded posters for your rally here. National and local peace organizations are encouraged to join the coalition supporting the Global Day of Action. As UFPJ’s Statement on the Ukraine Crisis declares, it is “time to start stopping the wars: no war in Ukraine, then no war anywhere…. The peace movement must be a global people’s movement, aligned with the policies of no government.” Read the full statement.UFPJ has also created a Ukraine Crisis resource page, which is updated regularly. Please check it frequently for new analysis, commentary, and links to recent webinars.
3. Progressive Democrats of America Central NM Chapter Monthly Community Gathering Wednesday March 9 6:00 PM on ZOOM
Speakers:
Archbishop John C.Wester, Archbishop of Santa Fe
Jay Coghlan, of NukeWatch NM
“Abolishing Nuclear Weapons is a Moral Imperative”, Archbishop John C. Wester
PDACNM is honored to welcome Archbishop John C. Wester, Archbishop of Santa Fe to our monthly gathering. His courage in speaking out against the proliferation of nuclear weapons inspires us at PDACNM to follow his example and continue the fight against this peril, especially given the threat of a possible imminent war between two nuclear powers.
The following excerpt is from ICAN – International Campaign to Abolish Nuclear Weapons. Winner of the 2017 Nobel Peace Prize. You can read the rest of the article here.
On 11 January 2022, Archbishop John C. Wester of Santa Fe, New Mexico circulated a letter in support of nuclear weapons abolition and the Treaty on the Prohibition of Nuclear Weapons to all the parishes in his diocese.
In the letter, Wester outlines the risks and consequences of the new nuclear arms race and highlights the unique role of New Mexico in the U.S. nuclear weapons complex and of the Santa Fe diocese to support nuclear disarmament. He calls for an open dialogue on nuclear disarmament and redirecting resources from the nuclear arms race to peaceful objectives, like cleaning up nuclear contamination and addressing climate change.
New Mexico is at the heart of the U.S. nuclear weapons complex, with two major nuclear weapons laboratories – the Los Alamos and Sandia National Laboratories- located in the state and nearly 40% of the Department of Energy’s nuclear weapons budget allocated for work in New Mexico. It was also the site of the first nuclear test explosion in July 1945 and has the largest repository of nuclear weapons in the country.
The Archdiocese of Santa Fe has a “special responsibility” he states, to support the TPNW (Treaty on the Prohibition of Nuclear Arms) and to encourage its active implementation. “It is the duty of the Archdiocese of Santa Fe, the birthplace of nuclear weapons, to support that Treaty while working toward universal, verifiable nuclear disarmament,” Wester writes.
Why We Are in a New Nuclear Arms Race and What You Can Do to Stop It
Jay Coghlan, executive director of Nuclear Watch New Mexico, has worked successfully against radioactive incineration at the Los Alamos National Lab, and in Clean Air Act, Freedom of Information Act and National Environmental Policy Act lawsuits against the Department of Energy. He prompted a 2006 independent study that concluded plutonium pits last at least a century, refuting the NNSA’s assertion that we “need” new-design nuclear weapons and expanded plutonium pit production.
Jay will tell us how the new nuclear arms race is more dangerous than the first one. How it might lead to a nuclear hot war over Ukraine. And how devastating a nuclear war would be for everyone, including us.
You’ll learn about the nuclear weapons “modernization” program and the fancy new warheads being designed for it. You’ll be shocked to learn the amount of taxpayer money being wasted on this unnecessary program.
Jay will explain how the nuclear “modernization” program is dependent on new plutonium bomb cores (called “pits”) to be produced at the Los Alamos National Lab and the Savannah River Site in South Carolina. And why future plutonium pit production, in addition to its grotesque costs and environmental harms, could actually degrade national security.
Finally, we will engage with Jay in discussing how we can work together to slow the international arms race by hobbling the nuclear modernization program. Since the Pentagon has called expanded pit production the #1 modernization issue, then all we have to do is to stop future pit production, right?
How will we do this? Let’s talk about it on March 9th! Please join us!
If you are concerned about proposed expansion of beryllium machining operations at Los Alamos National Laboratory (LANL), now is the time to express your interest to the New Mexico Environment Department Air Quality Bureau. Public comments and expression of interest in the proposal to add two lathes for machining beryllium and a new sputtering coating operation are due by Saturday, February 26, 2022 at midnight Mountain Time by email to James.Nellessen@state.nm.us.
Expression of your interest will allow you to review the Bureau’s analysis of the permit modification request for 30 days following notification. It will also allow you to submit written public comments and request a public hearing. See Subsection B of 20.2.72.206 New Mexico Administrative Code – Public Notice and Participation. https://www.srca.nm.gov/parts/title20/20.002.0072.html
In late December, LANL submitted an application to the Bureau to modify its air quality permit to add two lathes for machining beryllium to the existing lathe at the Target Fabrication Facility at Technical Area 35, near the Plutonium Facility. https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to U.S. DOE/NNSA – LANL to Public Notice for Air Construction Permit (632M1) (posted 1/25/22).
LANL states that it will operate only two of the three lathes at a time. Even so, LANL is proposing to double these beryllium operations. See Id., Original Application, p. 29 – 30 of pdf.
The existing permit allows micro-scale precision machining to manufacture small laser targets for use at the Lawrence Livermore National Laboratory located in California, as part of the Department of Energy’s National Inertial Confinement Fusion program. https://www.eenews.net/articles/doe-lab-achieves-major-milestone-for-fusion-energy/
LANL also proposes to add a new coating process, called magnetron sputtering, that would take place in an unnamed room near the lathes. Each operation would result in beryllium air emissions through stacks on the roof of the building. See Original Application, p. 29 – 30 of pdf.
At atomic number 4, beryllium is a lightweight metal used in the nuclear weapons industry in fabricating plutonium pits, or the weapon’s trigger.
Exposure to beryllium-containing dust and vapors can cause acute and chronic lung disease, called berylliosis, for which there is no cure. Reports in the medical literature demonstrate that one to six percent of exposed employees are genetically sensitive to beryllium and are more susceptible to a form of berylliosis called chronic beryllium disease. https://rarediseases.org/rare-diseases/berylliosis/
In our review of the permit application, CCNS found that LANL asked for a waiver from monitoring beryllium emissions, which the Environment Department granted in late December 2021. See Original Application, p. 60 – 68 of pdf. This is surprising because there are extra requirements for protecting Class I areas, such as the ambient air quality at the nearby Bandelier Wilderness Area. See Original Application, p. 6 of pdf.
Please see: In response to Question 8, “Will the property on which the facility is proposed to be constructed or operated be closer than 50 km (31 miles) to other states, Bernalillo County, or a Class I area?” LANL answered “yes,” and provided the distance in kilometers: “Bandelier Wilderness Area (the wilderness portion of Bandelier National Monument) 0.0 km from the LANL boundary, 5.7 km from Building TA35-213.”
1. Saturday, February 26, 2022 – Public Comments due to NM Environment Department, Air Quality Bureau, about revision to LANL’s Air Quality Permit to add three lathes for micro-scale precious machining of beryllium metal.
For more information:https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Air Quality Bureau, for Public Notice for Air Construction Permit (632MI). Stay tuned. Sample public comments you can use are available above in the update.
2. THIS EVENING, February 24, 2022 at 6 pm MT – Dr. Frank von Hippel discusses the book Plutonium: How Nuclear Power’s Dream Fuel Became a Nightmare. ZOOM link is HERE.
Plutonium: How Nuclear Power’s Dream Fuel Became a Nightmare is a sweeping and intricate narrative of the worldwide impact of this manmade element over 80 years. The three authors – Dr. Frank von Hippel, Dr. Jungmin Kang and Masafumi Takubo – individually are renowned at home and abroad as experts who have shaped not just public debate but also government policies on the security and safety risks of plutonium. Together, they have crafted a powerful book that leads the reader deftly through technical, policy, social and economic arguments to arrive at their conclusion: the world will be safer if the separation of plutonium is banned. https://www.tandfonline.com/doi/full/10.1080/25751654.2020.1766165
3. On Wednesday, February 23, 2022,Ira Helfand, former president of the International Physicians for the Prevention of Nuclear War (IPPNW), delivered an extremely compelling warning about the risks of escalation to the use of nuclear weapons in the current conflict in Ukraine on Democracy Now! The segment is available at https://www.democracynow.org./ Click on the watch button for February 23, 2022. Ira’s segment begins at about 13 minutes in. Our colleague, Linda Pentz Gunter at Beyond Nuclear, who also delivered a powerful assessment of the risks associated with Ukraine’s 15 nuclear power reactors, including Chernobyl, joined Ira Helfand.
On February 10th, the International Campaign to Abolish Nuclear Weapons (ICAN) released a new report, “No place to hide: nuclear weapons and the collapse of health care systems.” a new ICAN report which examines the estimated impact of the detonation of one nuclear weapon over ten cities around the world (in all the nuclear-armed states + Germany as a nuclear host state).
4. Tuesday, March 1st at 11:30 am – Asking for Your Presence
Please join us for a press conference when we deliver over 1,100 petition signatures to Governor Michelle Lujan Grisham asking her to protect New Mexicans from the federal expansion of the Waste Isolation Pilot Plant (WIPP). This is your opportunity to let her know that vastly increased shipments of the most dangerous form of nuclear weapons’ waste, lasting the rest of the century as it is transported past your neighborhood,is not a risk you accept. She needs to know that many of her constituents will not support this federal overreach by the Department of Energy (DOE). Moreover, we do not accept this risk in secrecy and the information blackout that the DOE is forcing on us. If the DOE is trying to put us at risk, it must do so openly, in the full light of day.
When: March 1, 2022, 11:30 am
Where: Outside at the East side of the Statehouse
How: Outdoor event
Who:Joiningyou, the good people of New Mexico, will be County Commissioner Anna Hansen, Tewa Elder Kathy Sanchez, Quay County ranchers Ed & Patty Hughs, Co-Chair of 285ALL Cindy Weehler
5. Thursday, March 3rd at 5:30 pm – WIPP Virtual and In Person Community Forum with Reinhard Knerr, Manager of the DOE’s Carlsbad Field Office, and Sean Dunagan, President & Project Manager of Nuclear Waste Partnership, LLC. Online Registration Link. Questions will be taken in a written format.
Despite receiving comments from 19 non-governmental and business organizations representing tens of thousands of New Mexicans, the New Mexico Environment Department has permitted the use of the underground disposal Panel 8 at the Waste Isolation Pilot Plant (WIPP) with 16-foot high ceilings. The Panel 8 ceilings are three feet taller than those in the first seven disposal panels in the underground mine for plutonium-contaminated waste generated from manufacturing nuclear weapons.
The 19 groups requested that the Environment Department deny the permit modification request or elevate it as a class 3 modification, which would include a public hearing. WIPP Panel 8 Class 2 PMR Group letter 12-20-21 The Environment Department “determined, based on the public comments received, that ‘significant public concern’ over this [permit modification request] is not supported, which would warrant its elevation to a Class 3.” https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to the February 11, 2022 entry, Response to Comments [AR 220208], p. 5.
It is notable that for the recent renewal of a WIPP groundwater discharge permit, DP-831, the Environment Department found significant public interest when five groups requested a hearing. https://www.env.nm.gov/public-notices/ , scroll down to Eddy County and Waste Isolation Pilot Plant for Ground Water Discharge Permit (DP-831).
Mining of Panel 8 began in 2013 and was halted in 2014 when an underground fire and radiation release from one or more waste drums shutdown WIPP for nearly three years at a cost of $3 billion dollars.
The Permittees, U.S. Department of Energy (DOE) and its contractor, the Nuclear Waste Partnership LLC, claim the higher ceiling is necessary to reduce roof falls that could endanger workers. Increasing the Panel 8 ceiling height required re-calculation of the limits for emissions of volatile organic compounds (VOC) from the waste drums. But the Environment Department reports behavior that contradicts that position.
In its response to the public comments, the Environment Department reported that in 2021 the Permittees stated they “had not evaluated the need for VOC calculation changes nor run the model for the VOC calculations with the new room height” and “[o]nce the model was run the Permittees became aware of the need to submit a [request] to update the Permit based on the calculations for Panel 8.” https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to the February 11, 2022 entry, Response to Comments [AR 220208} , p. 9.
Joni Arends, a CCNS co-founder, responded, “How can the Permittees claim in 2021, four years after resumption of mining and increasing the ceiling height by three feet, that they didn’t recognize the need to recalculate the VOC emissions? The VOC emission limits are what protects workers from the hazards of breathing VOCs.”
Further, since 2013 the Permittees have been providing the Environment Department with verbal mining progress updates. https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to the February 11, 2022 entry, Response to Comments [AR 220208} , p. 8.
Arends stated, “It is unconscionable that the Environment Department did not require written progress reports.”
These are but two examples of what could have come to light in a public hearing.
Friday, February 25, 2022 – Public Comments due to NM Environment Department, Air Quality Bureau, about revision to LANL’s Air Quality Permit to add two lathes for machining beryllium metal.
For more information:https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Air Quality Bureau, for Public Notice for Air Construction Permit (632MI). Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
This week Concerned Citizens for Nuclear Safety (CCNS) asked the New Mexico Environment Department to withdraw its draft groundwater permit DP-1132 for the Radioactive Liquid Waste Treatment Facility at Los Alamos National Laboratory (LANL) because of the confusing, incomplete and defective documents released for public review and comment.
In preliminary comments, the non-governmental organization wrote that the sole subject of the Public Notice was the new financial assurance requirements for cleanup, closure of the site, and any post-closure environmental monitoring. The Facility opened in 1963. Operations include the storage, treatment and disposal of waters contaminated with plutonium and hazardous pollutants associated with the manufacture of nuclear weapons. These pollutants have been found in the regional drinking water aquifer.
However, the Draft Permit did not use the term “financial assurance,” but “financial responsibility.” It requires only that the Department of Energy (DOE) ask for annual congressional funding for cleanup. The conflicting and esoteric language makes it almost impossible to provide informed and cogent public comments.
Financial assurance is a pledge or guarantee so that the funds will be available when needed for cleanup. The funds could be in the form of letters of credit, insurance policies, bonds, or trust funds.
In contrast, financial responsibility is a duty or task that one is required or expected to do, such as asking annually for the funding.
CCNS suggested that the financial assurance requirements be a condition of the management and operating contract between DOE and the nuclear weapons contractor, Triad National Security, LLC. In this way the funding mechanisms would be in place now and be available until such time as the post-closure cleanup is completed.
Another confusion is that the Draft Permit pdf document available on the Environment Department webpage includes a lengthy revision to a LANL August 2016 Closure Plan. Changes were made on almost every page. But the Public Notice only invited comments about the Draft Permit, excluding the Closure Plan. This is a clear example of why the Environment Department must withdraw its Public Notice, make the necessary corrections and begin the process again.
Nevertheless, it appears that the Closure Plan may open the door for permitting a new low-level radioactive waste facility without a public hearing. Recall that the Public Notice limits comments to financial assurance in the Draft Permit, but not a new facility.
Comments are due to the Environment Department by 5 pm on Wednesday, February 16th. CCNS will post sample public comments you can use early next week.
For more information and to review the draft documents: https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Ground Water Quality Bureau for Discharge Permit DP-1132.
1. Saturday, February 12, 2022 – last day for NM Environment Department (NMED) Secretary to Decide Whether Significant Public Concerns about the Volatile Organic Compounds (VOCs) in WIPP’s newly mined Panel 8 Requires a Public Hearing as a Class 3 Permit Modification Request to the NMED Hazardous Waste Permit.
A BIG shout out to the individuals and 19 organizations that voiced strong opposition to the permit modification request and asked for a public hearing.
2. Wednesday, February 16 at 5 pm MT – Public comments due to the NM Environment Department about whether the proposed financial assurance requirements for the cleanup, closure and post-closure of the LANL Radioactive Liquid Waste Treatment Facility (RLWTF) at Technical Area 50 are adequate.
For more information: https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Ground Water Quality Bureau for Discharge Permit DP-1132. Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
4. Friday, February 25, 2022 – Public Comments due to NM Environment Department, Air Quality Bureau, about revision to LANL’s Air Quality Permit to add two lathes for machining beryllium metal.
For more information:https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Air Quality Bureau, for Public Notice for Air Construction Permit (632MI). Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
The New Mexico Environment Department is again trying to skirt proper regulation of the Radioactive Liquid Waste Treatment Facility at Los Alamos National Laboratory (LANL) as required by the New Mexico Hazardous Waste Act. At the direction of the Department’s Secretary, the Ground Water Quality Bureau released a draft discharge permit, called DP-1132, to address the sole issue of financial assurance requirements for cleanup of the Facility and the environment. The hazardous waste laws provide strong avenues for financial assurance, including a letter of credit, insurance policies and bonds, and trust funds. https://www.env.nm.gov/public-notices/, scroll down to Los Alamos County, use the dropdown menu to go to U.S. Department of Energy National Nuclear Security Administration – LANL, then to the Public Notice – Ground Water Quality Bureau for DP-1132. You will find blue green links to key required documents below.
The language in the draft discharge permit is weak. It requires LANL to ask only for annual cleanup funding for the nearly 60-year old facility that has discharged millions of gallons of “treated” radioactive and hazardous liquid wastes into Mortandad Canyon. It is anticipated a multi-year cleanup would be required. Contaminants have been found in the regional drinking water aquifer.
For over a decade, CCNS has argued that the proper, and more protective, regulatory structures are the federal Resource Conservation and Recovery Act and its implementing regulations and the New Mexico hazardous waste laws and regulations. https://nuclearactive.org/tag/radioactive-liquid-waste-treatment-facility/
Since 1963, the Facility has handled, managed, treated and stored hazardous and radioactive liquid waste that is piped underground from the Plutonium Facility and other nuclear weapons related facilities located across the LANL site.
Once those liquid wastes reach the Facility, they are transported through pipes from tank to tank for processing. The Ground Water regulations do not cover these operations. The hazardous waste laws and regulations do and are extensive to ensure the tank systems are operated correctly. The radioactive and hazardous sludge is shipped to the Waste Isolation Pilot Plant for disposal. The treated liquid waste can be discharged at a rate of 40,000 gallons a day to a discharge pipe in Mortandad Canyon or evaporated into the air.
Because federal and state governments are exempt from financial assurance, the draft permit language asks LANL to request annually for congressional funding, which can be uncertain. Under the hazardous waste laws, however, the Secretary can impose alternative requirements for financial assurance mechanisms, which would be used to invest in a cleanup that would protect the environment. If long-term monitoring were required, those financial mechanisms would be available to pay for those activities. 40 CFR § 264.140(c) and (d) Financial Requirements.
Public comments are due to the Ground Water Quality Bureau by 5 pm on Wednesday, February 16th. CCNS will be posting sample public comments you can use next week.
Saturday, February 12, 2022 – last day for NM Environment Department (NMED) Secretary to Decide Whether Significant Public Concerns about the Volatile Organic Compounds (VOCs) in WIPP’s newly mined Panel 8 Requires a Public Hearing as a Class 3 Permit Modification Request to the NMED Hazardous Waste Permit.
A BIG shout out to the individuals and 19 organizations that voiced strong opposition to the permit modification request and asked for a public hearing.
Wednesday, February 16 at 5 pm MT – Public comments due to the NM Environment Department about whether the proposed financial assurance requirements for the cleanup, closure and post-closure of the LANL Radioactive Liquid Waste Treatment Facility (RLWTF) at Technical Area 50 are adequate.
For more information: https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Ground Water Quality Bureau for Discharge Permit DP-1132. Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
Friday, February 25, 2022 – Public Comments due to NM Environment Department, Air Quality Bureau, about revision to LANL’s Air Quality Permit to add two lathes for machining beryllium metal.
The independent Defense Nuclear Facilities Safety Board recently reported that Triad National Security LLC, the nuclear weapons contractor at Los Alamos National Laboratory (LANL), wants the Department of Energy (DOE) to accept the risk of bringing large shipments of plutonium-238 in uncertified containers for repackaging in the Plutonium Facility. Triad wants DOE to approve an increase that would exceed the established quantity limits for the first floor of the Plutonium Facility and quantity limits for the gloveboxes that would be used in the repackaging operations.
A rem is a measure of radiation and being exposed to 25 rems can cause death or serious injury.
Dan Hirsch, a retired director of environment and nuclear policy programs at the University of California, Santa Cruz, said, “Just 25 rem is 12,500 X-rays and a very, very high cancer risk. That [the request is] so far over it is astonishing.” https://www.committeetobridgethegap.org/
Plutonium-238 is used as a heat source that can be converted to electricity for long-range space flights, rovers and satellites.
Over the decades, DOE has taken risks storing and transporting plutonium in uncertified containers. The Safety Board’s report does not provide information about the type of uncertified containers being used, nor where the large shipments would originate.
In 2002, Tri-Valley Communities Against a Radioactive Environment, or Tri-Valley CARES, filed a citizens’ suit against DOE for using the DT-22 canisters that failed the government’s “crush test.” Through the Freedom of Information Act, Tri-Valley CARES received reports about the safety of the canisters that revealed that DOE’s own engineers had concerns, citing several scenarios in which the canister could be crushed. As a result of the suit, DOE stopped the plutonium shipments from the Rocky Flats Plant, near Denver, Colorado, to the Lawrence Livermore National Laboratory, in Livermore, California. http://www.nuclearactive.org/news/052202.html and https://www.trivalleycares.org/
Hirsch commented, “They’ve identified another safety hazard at Los Alamos regarding containers that may not be able to keep the material from getting released, and they’re estimating doses that are astronomical.” Even so, Triad National Security, LLC, the nuclear weapons contractor at LANL, is asking for a pass.
1. Wednesday, February 2, 2022, 1 to 3 pm ET,or 11 am to 1 pm MT.Public Mtg. aboutS. Nuclear Regulatory Commission Regulatory Readiness for Oversight of Potential Large-Scale Commercial Transportation of Spent Nuclear Fuel. The notice with links is available at: https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22019A074
2. Saturday, February 12, 2022 – last day for NM Environment Department (NMED) Secretary to Decide Whether Significant Public Concerns about the Volatile Organic Compounds (VOCs) in WIPP’s newly mined Panel 8 Requires a Public Hearing as a Class 3 Permit Modification Request to the NMED Hazardous Waste Permit.
3. Wednesday, February 16 at 5 pm MT – Public comments due to the NM Environment Department about whether the proposed financial assurance requirements for the cleanup, closure and post-closure of the LANL Radioactive Liquid Waste Treatment Facility (RLWTF) at Technical Area 50 are adequate.
For more information: https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Ground Water Quality Bureau for Discharge Permit DP-1132. Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
4. Friday, February 25, 2022 – Public Comments due to NM Environment Department, Air Quality Bureau, about revision to LANL’s Air Quality Permit to add two lathes for machining beryllium metal.
For more information:https://www.env.nm.gov/public-notices/ , scroll down to Los Alamos County, then to the U.S. DOE NNSA-LANL heading and scroll down to Air Quality Bureau, for Public Notice for Air Construction Permit (632MI). Stay tuned. Sample public comments you can use will be available soon at CCNS’s website at http://nuclearactive.org/
Saturday, January 22, 2022, marks the first anniversary of the entry into force of the Treaty on the Prohibition of Nuclear Weapons. https://www.un.org/disarmament/wmd/nuclear/tpnw/ This landmark international treaty will be celebrated around the world, including in New Mexico. You are invited to the celebration of the Treaty and the January 15th birthday of Martin Luther King, Jr. on Saturday, January 22nd from 1 to 3 pm at the Shelter on the south side of Ashley Pond in Los Alamos. Bring signs and banners. Dress for inclement weather: wear layers, warm shoes and a hat, bring water and snacks. Veterans for Peace https://www.facebook.com/santafeveteransforpeace , Nuclear Watch New Mexico https://nukewatch.org/ and CCNS http://nuclearactive.org/ are hosting the event.
The Treaty is already having an impact and that impact is growing. Eight new countries have ratified the Treaty since its entry into force. A total of 59 state parties have ratified the Treaty. Eighty-six United Nations’ member states are signatories. Over 500 cities around the world have shown their support, including 19 with populations of over one million and nine capital cities. Over 2,000 parliamentarians and political leaders have signed a pledge to support the Treaty in their official capacity.
These accomplishments are significant and are the work of the International Campaign to Abolish Nuclear Weapons (ICAN), a coalition of non-government organizations promoting adherence to and implementation of the United Nations nuclear weapon ban treaty. https://www.icanw.org/ The work continues.
This week ICAN and PAX released a new report entitled, “Rejecting Risk: 101 policies against nuclear weapons,” in which they describe how the financial sector is helping to make everything associated with nuclear weapons unacceptable. Because of the Treaty, financial institutions around the world are now implementing policies to end investments in companies involved in the development, testing, production and manufacture of nuclear weapons. https://www.icanw.org/new_report_101_financial_institutions_have_restricted_investments_in_nuclear_weapons and https://paxforpeace.nl/
In order to help people learn more and get involved, organizations throughout the world are hosting informative virtual events.
On Friday, January 21st, the Campaign for Nuclear Disarmament will release a new report entitled, “Nuclear weapons are banned: What does this mean for Britain?” that was co-authored with the Acronym Institute for Disarmament Diplomacy. http://acronym.org.uk/ For more information, visit https://cnduk.org/
On Saturday, January 22nd at noon Mountain Time, Massachusetts Peace Action will present “Climate Change and Nuclear War: What We Can Do About the Twin Existential Threats.” The webinar is about how climate change increases the danger of nuclear war and how a nuclear war would cause further catastrophic climate disruption. For more information, visit http://masspeaceaction.org/
Did You Know about these opportunities to celebrate the TPNW’s first anniversary?
1. Friday, January 21st, the Campaign for Nuclear Disarmament will release a new report entitled, Nuclear weapons are banned: What does this mean for Britain” that was co-authored with the Acronym Institute for Disarmament Diplomacy. http://acronym.org.uk/ For more information, visit https://cnduk.org/
2. Saturday, January 22nd at noon Mountain Time,Massachusetts Peace Action will present Climate Change and Nuclear War: What We Can Do About the Twin Existential Threats. The webinar is about how climate change increases the danger of nuclear war and how a nuclear war would cause further catastrophic climate disruption. For more information, visit http://masspeaceaction.org/
3. Saturday, January 22, 2022 from 1 to 3 pm at Ashley Pond, 2200 Trinity Drive, Los Alamos, NM – Commemoration of Martin Luther King, Jr.’s Birthday and First Anniversary of the Treaty on the Prohibition of Nuclear Weapons Rally. Please join us with signs, flags and banners. Be prepared for inclement weather: wear layers, warm shoes and a hat. Bring water and snacks. https://www.icanw.org/cogreg/commemoration_of_mlk_jr_birthday_and_tpnw_anniversary
4. Tuesday, January 25 at 11 am MT,Nuclear Colonialism in the Age of the Ban Treaty: From New Mexico to the Marshall Islands. A free on-line seminar in which the Affected Communities Working Group of the Nuclear Ban Treaty Collaborative will discuss the first anniversary of the entry into force of the Treaty on the Prohibition of Nuclear Weapons (ban treaty). Register in advance for this meeting: https://us02web.zoom.us/…/tZIpfu2prz0vH9B3AXJ9wUg6l3j1B…
5. Thursday, January 27, 2022,National Downwinders Day.
6.Thursday, January 27, 2022 from 5:30 to 7:30 pm,N3B Environmental Management virtual Cleanup Forum for LANL. For login information, visit https://n3b-la.com/outreach/
7. Thursday, January 27, 2022 at 6 pm MT,Gordon Edwards speaks about Uranium – the Deadliest Shape Shifter. Virtual event hosted by Nuclear Energy Information Service. https://neis.org/ or neis@neis.org or 773-342-7650.
8. Just Announced!Wednesday, February 2, 2022, 1 to 3 pm ET, or 11 am to 1 pm MT.Public Mtg. aboutS. Nuclear Regulatory Commission Regulatory Readiness for Oversight of Potential
Large-Scale Commercial Transportation of Spent Nuclear Fuel. The notice with links is available at: https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22019A074