Current Activities

Santa Fe City Council Must Consider Impacts of Eberline Operations on the South Meadows Open Space

The Santa Fe City Council will hold a special meeting on Wednesday, February 1st at 7 pm to consider the proposed rezoning of the 22 acres of open space on South Meadows. City of Santa Fe Notice of Meeting 20230201 CCNS urges to you contact your city councilors and encourage them to vote no on the rezoning proposal.  https://santafenm.gov/elected-officials

There are too many unanswered questions about possible contamination of the open space remaining from decades of operations of the industrial Eberline / ThermoFisher radiation detection manufacturing facility to the south.  https://www.sfreporter.com/news/2020/01/08/less-radioactive/   The proposed rezoning would allow Homewise to build homes and condominiums on the site.  https://lospradosnm.com/

The open space is located near the intersection of Airport Road and South Meadows on the south side of Santa Fe.  The surrounding area has the highest population density, the fewest acres of open space, and the greatest number of children 14 and under.  There are several schools within blocks of the abandoned manufacturing facility and a 200-unit apartment building is going up diagonal to it. 

In 1953, Eberline began manufacturing radiation detectors.  In the early 1990s, the Environmental Protection Agency opened a Superfund investigation of the site.  In 2007, manufacturing ceased.  In that same year, 800 sealed radiation sources containing plutonium or cesium were removed from the site.  In 2009, EPA reopened the Superfund investigation.

We offer a precautionary tale that more environmental investigation is needed now.

Let’s look to the northwest to DP Road in Los Alamos.  DP Road runs parallel to the airport on the next mesa to the south.  On the south side of DP Road there was a Manhattan Project dump, called Material Disposal Area B.  It was excavated in the late 2000s with American Recovery and Reinvestment Act funding.  Because of the uncertainty of the dump’s contents, CCNS urged the Department of Energy to expand the proposed cleanup area.  That was not done.  http://www.nuclearactive.org/news/122906.htmlhttp://www.nuclearactive.org/news/010507.html ,   http://nuclearactive.org/wp-content/uploads/2020/11/HWB-RPD-PN-English-LANL-Nov-12-Meeting-1.pdf

Los Alamos County began construction of affordable housing projects on both sides of DP Road near the dump.   Sure enough, when contractors were digging a new sewer line, they dug up radioactive and hazardous waste.

Families have been living in the housing.  Investigations are on going.  Each investigation reveals more waste.  https://n3b-la.com/middle-dp-road/

What can we learn from the DP Road example?  A thorough investigation is needed about possible contamination of the 22-acres in Santa Fe.  The fact that EPA started two Superfund investigations reveals that unanswered questions remain.

Please contact your Santa Fe city councilors and urge them to vote no on the rezoning.  https://santafenm.gov/elected-officials


  1. Friday, January 27th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Monday, January 30th, 2023 from 5 to 8 pm Mountain – Online (ZoomGov) public hearing about the DOE/NNSA Surplus Plutonium Disposition Program. Each speaker will have three minutes to make comments.  The meeting URL will be posted on the NNSA’s NEPA Reading Room – https://www.energy.gov/nnsa/nnsa-nepa-reading-room

 

 

  1. Four-week online World BEYOND War book club with Vincent Intondi about his book, African Americans Against the Bomb, on Fridays, February 3, 10, 17, 24, 2023 at noon MT. Limited to 18 participants.  For more information and to register:  https://worldbeyondwar.org/events/

 

 

  1. March 9 and 10, 2023 – ICAN and ICAN Norway are hosting the ICAN Act on It Forum in Oslo, Norway. You are invited to join campaigners, youth, politicians, academics and others interested in nuclear disarmament to amplify voices demanding the end of unlawful and inhumane nuclear weapons.  March 2023 is the 10th anniversary of the first conference on the humanitarian consequences of nuclear weapons, hosted by Norway.  https://www.icannorway.no/

 

 

  1. If you missed Myrriah Gómez in Conversation with Alicia Inez Guzman about her new book, Nuclear Nuevo México: Colonialism and the Effects of the Nuclear Industrial Complex on Nuevomexicanos, at Collected Works on January 13, 2023, you can watch it at:  https://www.facebook.com/collectedworksbookstore

 

 

  1. “Risky Returns,” is a new PAX and ICAN report that answers the question: Will producing nuclear weapons be a safe investment opportunity in the long-term?  The companies still building nuclear weapons and their investors are getting called out.  https://www.icanw.org/fewer_long_term_investments_in_nuclear_weapons_producers_dont_bank_on_the_bomb?utm_campaign=2022_dbotb_launch&utm_medium=email&utm_source=ican   The report provides an overview of investments in 2022 of 24 companies heavily involved in the production of nuclear weapons for the arsenals of China, France, India, the Russian Federation, the United Kingdom, and the USA. #nuclearban #divestment #DontBankontheBomb #bizHumanRights
 

It’s Time to Speak Out at DOE’s Surplus Plutonium Hearings in Carlsbad and Los Alamos

 

 

“Buckle up.  This is going to be a contentious discussion.”  

On Tuesday, January 24th and Thursday, January 26th, the Department of Energy will hold in-person public hearings in Carlsbad and Los Alamos, respectively, about their plans to handle, treat and dispose of surplus plutonium in New Mexico.  On Monday, January 30th DOE will also hold a virtual public hearing about these plans to ship 34 metric tons of surplus plutonium in the form of plutonium pits, or the triggers, and non-pit plutonium for nuclear weapons to process at Los Alamos National Laboratory (LANL) and dispose at the Waste Isolation Pilot Plant (WIPP).

This is DOE’s sixth attempt to address how to handle surplus plutonium so that it could no longer be used in nuclear weapons.  DOE’s plan is found in the draft Surplus Plutonium Disposition Program environmental impact statement (EIS), which is open for public comment until February 14th.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

Previous DOE attempts did not include LANL and WIPP.  That has changed.  LANL and WIPP are now DOE’s targets.

Since 1994, DOE has spent billions of dollars and held dozens of public meetings and hearings about how to prevent access to surplus plutonium.  Immobilization is one method.  But in 2002, DOE canceled the immobilization program “due to budgetary constraints,” even though thousands of public comments supported immobilization of all the plutonium.

You can tell DOE three things at the hearings.

First, no additional plutonium should be brought to LANL.

Second, WIPP has a limited mission and does not have the capacity for all the surplus plutonium.

Lastly, DOE must immobilize and safely store the plutonium until technically sound, suitable disposition facilities are available.

The first public hearing is in Carlsbad on Tuesday, January 24th from 6 to 9 pm Mountain Time at the Carousel House at the Pecos River Village Conference Center, 711 Muscatel Avenue.

The second public hearing is in Los Alamos on Thursday, January 26th from 6 to 9 pm at Fuller Lodge, 2132 Central Avenue.

A virtual public hearing will take place on Monday, January 30th from 5 to 8 pm Mountain Time.  The direct link to the Online Zoom meeting is available here:   https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program  Scroll down to below the hearing location, date, time and details box.

Joni Arends, of CCNS, said, “If approved, DOE’s surplus plutonium plans will forever change New Mexico.  Current DOE plans would keep WIPP open until at least 2080 for the increased plutonium waste generated from expanded plutonium work at LANL.  It’s time to speak out about DOE’s plans.”  http://nuclearactive.org/does-dramatic-plan-to-move-tons-of-surplus-plutonium-for-processing-at-lanl-and-disposal-at-wipp/  , http://nuclearactive.org/stop-surplus-plutonium-waste-from-coming-to-wipp/ , http://nuclearactive.org/will-does-surplus-plutonium-end-up-in-new-mexico/

Even the Santa Fe New Mexican agrees.  On December 25, 2022, the 174-year old newspaper wrote in its “Our View,” entitled “Disposing of plutonium:  So many questions,” “Buckle up.  This is going to be a contentious discussion.” CCNS provides the “Our View” in its entirety below:

Our View – Santa Fe New Mexican

Getting rid of plutonium pits — so many questions

Dec 24, 2022  https://www.santafenewmexican.com/opinion/editorials/getting-rid-of-plutonium-pits-so-many-questions/article_4178b6d4-824e-11ed-aaa7-775a96e0dc9f.html

A Department of Energy proposal to dilute and dispose of plutonium waste at the Waste Isolation Pilot Plant in Carlsbad is ready for public comment — the draft environmental impact statement, all 412 pages of it, has been released.

The public can weigh in, whether in writing or by showing up for public hearings that will take place early next year.

Buckle up. This is going to be a contentious discussion.

The U.S. wants to be rid of 34 metric tons of plutonium bomb cores, or pits, stored at the Pantex Plant in Amarillo. The pits are Cold War legacies; because WIPP is restricted in the type of waste it can take, before disposing of it, the material must be diluted. Thus, the term, dilute and dispose. The Department of Energy’s decision about the waste was announced two years ago, but with no details.

At one point the Energy Department wanted to turn Cold War plutonium into a mixed oxide fuel for use in commercial nuclear plants. That would have happened at the Savannah River Site in South Carolina, but billions in cost overruns and delays hamstrung the effort, and the Trump administration killed the project in 2018.

It chose the dilute-and-disposal plan.

The draft statement fleshes out just what would happen to prepare the pits for disposal — in a facility, we might point out, that currently is seeking a renewal of its hazardous waste permit from the state of New Mexico. WIPP is open, but state Environment Department Secretary James Kenney and Gov. Michelle Lujan Grisham want more oversight of waste disposal at the plant.

That back and forth is separate from the Energy Department dilute-and-disposal proposal, but the permit discussion provides context for the coming fierce debate.

Here’s what community members already are questioning. The Energy Department plan includes considerable time on highways carrying radioactive material, including trucking the stuff at least twice through New Mexico. That would include trips on congested corridors inside the southern edge of Santa Fe. First, the material would be shipped to LANL, where workers would convert it to oxidized powder. From Los Alamos, the powder would be transported to Savannah River.

There, crews would add an adulterant to make the powder unusable in weapons. The dilution portion taken care of, the material would be taken to WIPP, the underground disposal site.

That’s a lot of time on the highway for radioactive material, especially considering conditions on Interstate 40. It seems an expensive and inefficient way of disposing of plutonium — a 3,300-mile trip, ending with the materials deep beneath the ground at WIPP.

That’s a site, by the way, that only was supposed to store low-level transuranic waste — the contaminated gloves, equipment, clothing, soil and other materials that need to be disposed of safely. The WIPP mission continues to be expanded, another reason the state must increase its oversight. We expect elected officials — whether the governor or members of New Mexico’s congressional delegation — to speak up further about possible plutonium pit disposal, too.

There are questions about whether the pits need to be removed from Pantex at all, or whether work to make them inoperable in weapons could take place where they currently are being held. That would mean improving storage facilities, but eliminate a lot of highway traffic. Barring keeping the pits in place, all waste roads lead to New Mexico, That why residents here have a huge stake in determining what happens to these pits.

Stay alert for notices of meetings and time for public comment. There’s no guarantee informed opposition will change plans by agencies intent on certain action, but speaking up beats staying quiet. Oh, and think about this: before rushing full speed ahead to produce even more plutonium pits, it’s time to at least try to find a way to dispose of the waste we’ve already created.

Maybe, just maybe, not all the waste has to be buried in New Mexico. Or driven across New Mexico highways. It’s a big country.


  1. Thank you to everyone who voted for Archbishop John Wester of Santa Fe as the 2022 Arms Control Association Person of the Year. The Archbishop is the runner-up!  The Energoatom staff at Ukraine’s Zaporizhzhia nuclear power plant (ZNPP) were selected as the 2022 Arms Control Persons of the Year through an online poll that drew more than 3,500 participants from nearly 80 countries.  https://www.armscontrol.org/pressroom/2023-01/zaporizhzhia-staff-2022-acpoy   

 

 

  1. Friday, January 20th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Saturday, January 21st from 2 pm to 3:30 pm – Build Windmills, Not Weapons free event at SOMOS (Society of the Muse of the Southwest), 108 Civic Plaza Drive, Taos, NM. Music, poetry and readings from the great Pacifists.  For more information, call 575-758-0081.

 

 

  1. Sunday, January 22nd The Second Anniversary of the Treaty on the Prohibition of Nuclear Weapons. https://www.nuclearbantreaty.org/

 

 

  1. Tuesday, January 24th, 2023 at 8 am Mountain Time – Bulletin of Atomic Scientists will make the 2023 Doomsday Clock announcement. https://thebulletin.org/doomsday-clock/

 

 

  1. Tuesday, January 24th, 2023 from 6 to 9 pm Mountain – Carlsbad, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Carousel House at Pecos River Village Conference Center, 711 Muscatel Avenue, Carlsbad, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Thursday, January 26th, 2023 from 6 to 9 pm Mountain – Los Alamos, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at *** New LOCATION *** at Fuller Lodge, 2132 Central Avenue, Los Alamos, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.      https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Monday, January 30th, 2023 from 5 to 8 pm Mountain – Online (ZoomGov) public hearing about the DOE/NNSA Surplus Plutonium Disposition Program. The meeting URL will be posted on the NNSA’s NEPA Reading Room – https://www.energy.gov/nnsa/nnsa-nepa-reading-room
 

DOE’s Dramatic Plan to Move Tons of Surplus Plutonium for Processing at LANL and Disposal at WIPP

Two in-person public hearings in New Mexico and one virtual public hearing will be held about the Department of Energy’s plan to ship more than 30 tons of surplus radioactive plutonium for processing at Los Alamos National Laboratory (LANL) and disposal at the Waste Isolation Pilot Plant (WIPP).  The plan is found in the draft Surplus Plutonium Disposition Program environmental impact statement, which is open for public comment until February 14th.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

The proposal by DOE’s semi-autonomous National Nuclear Security Administration (NNSA), if approved, would change New Mexico forever.  For example, see Santa Fe County Commission comment letter to DOE/NNSA, which was unanimously approved on January 10, 2023.     20230110 Santa Fe Co. Commision Comments on NNSA’s SPDP DEIS    &   https://www.santafenewmexican.com/news/local_news/santa-fe-county-commission-opposes-radioactive-material-being-sent-to-lanl/article_8b5847c8-9145-11ed-8ded-9b49183bb77a.html

Plutonium pits, or the triggers, for nuclear weapons would be trucked from the Pantex facility in Texas to LANL, where the pits would be pulverized into powdered plutonium.  From LANL, the powdered plutonium would be trucked to the Savannah River Site in South Carolina where an adulterant to inhibit recovery of the plutonium would be added.  The plan is to truck the waste from there to WIPP for disposal.  In total, the plutonium, in various forms, would travel over 3,300 miles.   http://nuclearactive.org/stop-surplus-plutonium-waste-from-coming-to-wipp/

The proposal places a tremendous emergency preparedness burden on states, regional governments and communities along the transportation routes.

CCNS urges you to learn more, get involved, and submit your comments to DOE/NNSA before the end of the comment period on February 14, 2023.  To download the draft plan, go to https://www.energy.gov/nnsa/nnsa-nepa-reading-room

The first public hearing is in Carlsbad on Tuesday, January 24th from 6 to 9 pm Mountain Time at the Carousel House at the Pecos River Village Conference Center, 711 Muscatel Avenue.

The second public hearing is in Los Alamos on Thursday, January 26th from 6 to 9 pm at Fuller Lodge, 2132 Central Avenue.

A virtual public hearing will take place on Monday, January 30th from 5 to 8 pm Mountain Time.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program  Click on this link for a direct connection to the Online Zoom meeting for the January 30, 2023 meeting.

NNSA states that the first 30 minutes of the in-person meetings will be a poster session where NNSA representatives will answer questions.  Spanish and English translators will be available.  NNSA will then make a presentation, followed by public comments.  Oral comments during the in-person and on-line public hearings will be limited to a maximum of three minutes.

Joni Arends, of CCNS, said, “NNSA’s plan is convoluted and complicated.  It has taken time to review it.  Next week CCNS will post on our website a letter requesting an extension of time to submit comments, talking points and public comments you can personalize for your use.”


  1. Without any formal or any informal public notice, email addresses for New Mexico Environment Department staffers have changed to @env.nm.gov. The change has impacted the public’s ability to submit timely public comments.  Generally when an email address is changed, one receives an email notice with a reminder to update one’s address book with the new address.  This has not been the case for NMED.  We don’t know if this is a statewide change.      

 

 

  1. Friday, January 13th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others. We will be planning for the second anniversary of the Treaty on the Prohibition of Nuclear Weapons on Sunday, January 22nd.

 

 

  1. Take action by Thursday, January 12th, 2023 – Who should be recognized as the 2022 Arms Control Association Person of the Year? The results will be announced on Friday, January 13th.  All nominees have, in their own way, provided important leadership that helped reduced weapons-related security dangers during the past year.  Vote here:  https://www.armscontrol.org/ACPOY/2022   

 

CCNS urges you to vote for Archbishop John Wester of Santa Fe, NM.  For more information about the Archbishop, check these links out:

https://archdiosf.org/documents/2022/1/220111_ABW_Pastoral_Letter_LivingintheLightofChristsPeace_Official_Reduced.pdf

https://www.armscontrol.org/act/2022-12/interviews/making-case-nuclear-weapons-immoral-interview-archbishop-john-c-wester

 

 

  1. Friday, January 13th at 6 pm – Santa Fe Conversation with Myrriah Gómez, Author of Nuclear Nuevo México at Collected Works Bookstore, 202 Galisteo Street, Santa Fe. Myrriah Gómez’s Nuclear Nuevo México demonstrates how earlier eras of settler colonialism laid the foundation for nuclear colonialism in New Mexico. Myrriah will be in conversation with writer Alicia Inez Guzmán.  https://uapress.arizona.edu/event/santa-fe-conversation-with-myrriah-gomez-author-of-nuclear-nuevo-mexico

 

 

  1. Friday, January 13th through Monday, January 16th in Albuquerque – The MLK 2023 Dream Weekend – Theme: Cultivating a Beloved Community mind to transform unjust systems.  For more information:  https://nmmlksc.org/event/mlk-2023-dream-weekend/

 

 

  1. Saturday, January 14th at 9:45 am – Martin Luther King, Jr. Commemoration March in Albuquerque – Join the Donald and Sally-Alice Thompson Chapter 63 of the Veterans for Peace at the corner of MLK, Jr. Avenue and University Blvd. NE on the UNM Campus. https://maps.apple.com/?address=Dr%20Martin%20Luther%20King%20Jr%20Ave,%20Albuquerque,%20NM%20%2087106,%20United%20States&ll=35.084921,-106.625647&q=Dr%20Martin%20Luther%20King%20Jr%20Ave  March proceeds to Civic Plaza downtown.  VFP needs help carrying banners.  Weather:  41 degrees at 10 am with a 4 mph very light breeze.    

 

 

  1. Tuesday, January 17th, 2023 at 9 am to 6 pm – virtual NM Air Quality Act permit public hearing about the LANL Beryllium Target Fabrication Facility. ABQ 22-41 (P).  DOE/NNSA applied for a permit modification for expanded beryllium operations, including two beryllium lathes and one sputtering machine.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D163077960

 

 

  1. Thursday, January 19th, 2023 from 6 to 9 pm Eastern – Augusta, South Carolina – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the North Augusta Municipal Building, 100 Georgia Avenue, North, Augusta, SC. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.    https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Tuesday, January 24th, 2023 at 8 am Mountain Time – Bulletin of Atomic Scientists will make the 2023 Doomsday Clock announcement. https://thebulletin.org/doomsday-clock/

 

 

  1. Tuesday, January 24th, 2023 from 6 to 9 pm Mountain – Carlsbad, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Carousel House at Pecos River Village Conference Center, 711 Muscatel Avenue, Carlsbad, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Thursday, January 26th, 2023 from 6 to 9 pm Mountain – Los Alamos, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at *** New LOCATION *** at Fuller Lodge, 2132 Central Avenue, Los Alamos, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.      https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Monday, January 30th, 2023 from 5 to 8 pm Mountain – Online (ZoomGov) public hearing about the DOE/NNSA Surplus Plutonium Disposition Program. The meeting URL will be posted on the NNSA’s NEPA Reading Room – https://www.energy.gov/nnsa/nnsa-nepa-reading-room
 

CCNS and HOPE Return to Water Quality Control Commission for Justice in the Discharge Permit DP-1132 Matter

On Tuesday, January 10th, CCNS and Honor Our Pueblo Existence (HOPE) will return to the New Mexico Water Quality Control Commission to ask it to vacate the decisions in which former Commission Chair Stephanie Stringer was involved.  https://shuffle.do/projects/honor-our-pueblo-existance-h-o-p-e  CCNS and HOPE have appealed the issuance of the groundwater discharge permit, DP-1132, for the Radioactive Liquid Waste Treatment Facility at Los Alamos National Laboratory (LANL) to the Commission.  https://www.env.nm.gov/opf/docketed-matters/, scroll down to WQCC 22-21 CCNS and HOPE’s Petition for Review of NMED Ground Water Discharge Permit DP-1132 and click on it for the drop down menu.

In the middle of the proceeding, Chair Stringer resigned and took a job with the Department of Energy / National Nuclear Security Administration (DOE/NNSA), which is a party to the appeal.  This is an ethical violation.  CCNS and HOPE are asking the Commission to vacate the decisions made while former Chair Stringer was actively pursuing a position with DOE/NNSA at LANL.

Recently, on December 9th, the New Mexico Ethics Commission filed a civil action seeking to enforce violations of the New Mexico Governmental Conduct Act by Chair Stringer.  The State Ethics Commission said that Stringer took “an official act while a public officer and employee that she should have had reason to believe would directly affect her financial interest.”  https://www.sec.state.nm.us/wp-content/uploads/2022/12/Resolution-2022-10-S.-Stringer.pdf

CCNS and HOPE will also ask the Water Quality Control Commission to order sanctions against DOE/NNSA.  This is the second time DOE/NNSA hired New Mexico Environment Department adjudicatory decision-makers while they were presiding in the DP-1132 matter.  http://nuclearactive.org/please-support-ccns-and-hope-request-for-sanctions-in-the-lanl-dp-1132-appeal-before-the-new-mexico-water-quality-control-commission/

CCNS and HOPE spent tens of thousands of dollars to enforce the Resource Conservation and Recovery Act (RCRA) and the New Mexico Hazardous Waste Act at the Radioactive Liquid Waste Treatment Facility.  LANL admits that the Facility handles, treats and stores hazardous waste, which requires RCRA regulation.  DOE/NNSA has struggled to resist and delay proper RCRA regulation.  Finally, DOE/NNSA resorted to hiring away Environment Department personnel that were conducting the permitting proceeding, nullifying the entire process.

CCNS and HOPE spent precious dollars to pay lawyers, staff and related expenses, including travel to courts in Washington, DC and Salt Lake City, Utah. https://nuclearactive.org/ccns-oral-argument-before-eab-to-terminate-lanl-outfall/ , https://nuclearactive.org/lanl-outfall-051-must-be-eliminated-from-clean-water-act-permit/ , http://nuclearactive.org/ccns-lawyers-take-lanls-clean-water-act-exemption-to-the-10th-circuit-court-of-appeals/  Due to DOE/NNSA’s ethical violations, the proceeding must be done over again, and these funds were wasted.  CCNS and HOPE seek to recover them from DOE/NNSA.

CCNS and HOPE encourage you to support our quest for justice.  You can make public comments in support of the CCNS and HOPE motion to vacate the unlawful proceeding and to award sanctions during the January 10th Commission meeting.  https://www.env.nm.gov/opf/wp-content/uploads/sites/13/2022/12/Notice-of-Public-Meeting_NM-Water-Quality-Commission.pdf

A sample public comment letter is available for you to modify at nuclearactive.org.  20230104 f sample DP-1132 sanctions public comment ltr

 


Did You Know about these important public comment opportunities about the DOE/NNSA expansion plans at LANL, WIPP, the Savannah River Site, the Pantex Site and the Oak Ridge National Laboratory?  Public hearings in New Mexico begin on Tuesday, January 24th.  Mark your calendar now!

 

  1. Friday, January 6th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Friday, December 16th, 2022 – DOE’s National Nuclear Security Administration (NNSA) released a draft environmental impact statement for its Surplus Plutonium Disposition Program. The proposed program involves shipping over 50 metric tons of plutonium pits in various forms from the Pantex Facility, north of Amarillo, TX, to LANL where the pits would be made into powder.  From LANL, the powdered plutonium would be shipped to the Savannah River Plant, in South Carolina, for “treatment,” and then to WIPP for disposal – a total distance of 3,300 miles.  The draft EIS is available to download from https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program  Comments are due on Tuesday, February 14, 2023.  Talking points and sample comments you can use to defend New Mexico from more nuclear waste generation and disposal should be available next week.

* * *

Four public hearings about the DOE/NNSA Surplus Plutonium

Disposition Program will be held in January 2023. 

They are listed below in chronological order.

* * *

 

  1. Tuesday, December 20th, 2022 – NMED released the public notice, revised fact sheet, and draft hazardous waste renewal permit for WIPP. It is available to download from  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.  Public comments are due on Saturday, February 18th, 2023 at 5 pm MT.  Stay tuned to CCNS and Stop Forever WIPP for talking points and sample comments you can use to defend New Mexico from more nuclear waste generation and disposal.  They should be available next week.

 

 

  1. Tuesday, January 10th, 2023 at 9 am – NM Water Quality Control Commission meeting at which the appeal of groundwater discharge permit DP-1132 for the DOE/NNSA’s Radioactive Liquid Waste Treatment Facility at LANL will be heard. At time of CCNS’s posting, the WQCC agenda has not yet been posted.  https://www.env.nm.gov/opf/wp-content/uploads/sites/13/2022/12/Notice-of-Public-Meeting_NM-Water-Quality-Commission.pdf

 

Please submit a letter in support of sanctions against DOE/NNSA for hiring adjudicatory decision makers, while they were in the decision making process, in the DP-1132 matter.  A sample public comment letter you can modify is here.  20230104 f sample DP-1132 sanctions public comment ltr

 

 

  1. Take action by Thursday, January 12th, 2023 – Who should be recognized as the 2022 Arms Control Association Person of the Year? The results will be announced on Friday, January 13th.  All nominees have, in their own way, provided important leadership that helped reduced weapons-related security dangers during the past year.  Vote here:  https://www.armscontrol.org/ACPOY/2022   

 

 

CCNS urges you to vote for Archbishop John Wester of Santa Fe, NM.  For more information about the Archbishop, check these links out:

https://archdiosf.org/documents/2022/1/220111_ABW_Pastoral_Letter_LivingintheLightofChristsPeace_Official_Reduced.pdf

https://www.armscontrol.org/act/2022-12/interviews/making-case-nuclear-weapons-immoral-interview-archbishop-john-c-wester

 

 

  1. Tuesday, January 17th, 2023 at 9 am to 6 pm – virtual NM Air Quality Act permit public hearing about the LANL Beryllium Target Fabrication Facility. ABQ 22-41 (P).  DOE/NNSA applied for a permit modification for expanded beryllium operations.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D163077960

 

 

  1. Thursday, January 19th, 2023 from 6 to 9 pm Eastern – Augusta, South Carolina – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the North Augusta Municipal Building, 100 Georgia Avenue, North, Augusta, SC. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.    https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Tuesday, January 24th, 2023 at Bulletin of Atomic Scientists Doomsday Clock release. More details will be available soon at  https://thebulletin.org/doomsday-clock/

 

 

  1. Tuesday, January 24th, 2023 from 6 to 9 pm Mountain – Carlsbad, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Carousel House at Pecos River Village Conference Center, 711 Muscatel Avenue, Carlsbad, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Thursday, January 26th, 2023 from 6 to 9 pm Mountain – Los Alamos, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Duane Smith Auditorium, Los Alamos High School, 1300 Diamond Drive, Los Alamos, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.      https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Monday, January 30th, 2023 from 5 to 8 pm Mountain – Online (ZoomGov) public hearing about the DOE/NNSA Surplus Plutonium Disposition Program. https://pnnl.zoomgov.com/j/1606354491?pwd=bnJrdUhNYUtMWk04ayt2NFdpRUJYZz09#success or

 

ZoomGov.com/join

Meeting ID: 160 635 4491

Passcode: 041993

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EPA’s Environmental Appeals Board Remands LANL’s Outfall 051 Permit Back to Region 6 for More Public Input and Action

In May 2022, CCNS, Honor Our Pueblo Existence (HOPE), and Veterans for Peace – Chapter 63 appealed the federal Clean Water Act discharge permit for Outfall 051, which is connected to the Radioactive Liquid Waste Treatment Facility at Los Alamos National Laboratory, to the EPA’s Environmental Appeals Board (EAB).   On December 28th, the three-judge panel in Washington, DC ruled unanimously to remand the federal permit, or send it back, to EPA’s Region 6 office in Dallas.  https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/Active+Dockets?OpenView and EAB DOE and Triad Remand Order 12-28-22

The non-governmental organizations argue that because hazardous waste is handled, treated and stored at the Facility, it is required to be regulated by the federal Resource Conservation and Recovery Act (RCRA) and the New Mexico Hazardous Waste Act.  http://nuclearactive.org/ , https://shuffle.do/projects/honor-our-pueblo-existance-h-o-p-e and  https://nmvetscaucus.org/nm-veterans-for-peace-chapter-63/

The remand demonstrates that the Permittees, the Department of Energy (DOE) and the National Nuclear Security Administration (NNSA), have been flip-flopping about whether they intend to discharge through Outfall 051.  In 1998, LANL determined that it would eliminate all discharges from Outfall 051.  From November 2010 to June 2019, no discharge was made.  The treated wastewater was evaporated into the air.

DOE/NNSA seek a Clean Water Act permit as part of the showing needed to get the Waste Water Treatment Unit exemption from RCRA and the Hazardous Waste Act.  In their 2019 permit application, they stated that Outfall 051 would only be used as a backup to the evaporation system.  Later, they stated the outfall would be an “integral component” of the Permittees’ operations “in the future.”

Immediately after the public comment period for the EPA permit ended, DOE/NNSA began discharging from Outfall 051.  This was an obvious attempt to prove that the Permittees should have a Clean Water Act permit for Outfall 051.

Does DOE/NNSA intend to continue discharging treated waste water from Outfall 051?  CCNS, HOPE and Veterans for Peace believe that the Permittees must clarify whether they intend to abandon all the investments that have been made in the mechanical and solar evaporation equipment in order to discharge all of the Radioactive Liquid Waste Treatment Facility output through Outfall 051.  Even if the Permittees plan to discharge some of the output through Outfall 051, they have no Waste Water Treatment Unit exemption from RCRA and the Hazardous Waste Act unless the entire output is discharged through Outfall 051, which has not been the case for decades.

Lindsay A. Lovejoy, Jr., attorney for CCNS, HOPE and Veterans for Peace, stated that, “DOE/NNSA must declare clearly their intentions with respect to discharges in the EPA remand proceedings.  Based on their declaration, the public should comment, EPA’s Response to Comments should be revised, and EPA should act again on DOE/NNSA’s application for a permit for Outfall 051.”  http://lindsaylovejoy.com/


  1. Friday, December 30th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Friday, December 16th, 2022 – DOE’s National Nuclear Security Administration (NNSA) released a draft environmental impact statement for its Surplus Plutonium Disposition Program. The proposed program involves shipping over 50 metric tons of plutonium pits in various forms from the Pantex Facility, north of Amarillo, TX, to LANL where the pits would be made into powder.  From LANL, the powdered plutonium would be shipped to the Savannah River Plant, in South Carolina, for “treatment,” and then to WIPP for disposal – a total distance of 3,300 miles.  The draft EIS is available to download from https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program  Comments are due on Tuesday, February 14, 2023.  Talking points and sample comments you can use to defend New Mexico from more nuclear waste generation and disposal should be available next week.

* * *

Four public hearings about the DOE/NNSA Surplus Plutonium

Disposition Program will be held in January 2023. 

They are listed below in chronological order.

* * *

 

 

  1. Tuesday, December 20th, 2022 – NMED released the public notice, revised fact sheet, and draft hazardous waste renewal permit for WIPP. It is available to download from  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.  Public comments are due on Saturday, February 18th, 2023 at 5 pm MT.  Stay tuned to CCNS and Stop Forever WIPP for talking points and sample comments you can use to defend New Mexico from more nuclear waste generation and disposal.  They should be available next week.

 

 

  1. Tuesday, January 10th, 2023 – time uncertain – NM Water Quality Control Commission meeting at which the appeal of groundwater discharge permit DP-1132 for the DOE/NNSA’s Radioactive Liquid Waste Treatment Facility at LANL will be heard. At time of posting, the WQCC agenda has not been posted. 

 

Please submit a letter in support of sanctions against DOE/NNSA for hiring adjudicatory decision makers, while they were in the decision making process, in the DP-1132 matter.  A link to a f sample DP-1132 public comment ltr 12-22-22 sample letter is available in the second to last paragraph here :  http://nuclearactive.org/please-support-ccns-and-hope-request-for-sanctions-in-the-lanl-dp-1132-appeal-before-the-new-mexico-water-quality-control-commission/

 

 

  1. By Thursday, January 12th, 2023 – Who should be recognized as the 2022 Arms Control Association Person of the Year? The results will be announced on Friday, January 13th.  All nominees have, in their own way, provided important leadership that helped reduced weapons-related security dangers during the past year.  Vote here:  https://www.armscontrol.org/ACPOY/2022   

 

CCNS urges you to vote for Archbishop John Wester of Santa Fe, NM.  For more information about the Archbishop, check these links out:

https://archdiosf.org/documents/2022/1/220111_ABW_Pastoral_Letter_LivingintheLightofChristsPeace_Official_Reduced.pdf

https://www.armscontrol.org/act/2022-12/interviews/making-case-nuclear-weapons-immoral-interview-archbishop-john-c-wester

 

 

  1. Thursday, January 12thChannel 27 (Albuquerque) – presentation by Stop FOREVER WIPP Coalition about the release of the draft hazardous waste permit for WIPP. More information available soon

 

 

  1. Tuesday, January 17th, 2023 at 9 am to 6 pm – virtual NM Air Quality Act permit public hearing about the LANL Beryllium Target Fabrication Facility. ABQ 22-41 (P).  DOE/NNSA applied for a permit modification for expanded beryllium operations.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D163077960

 

 

  1. Thursday, January 19th, 2023 from 6 to 9 pm Eastern – Augusta, South Carolina – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the North Augusta Municipal Building, 100 Georgia Avenue, North, Augusta, SC. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.    https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Thursday, January 24th, 2023 at Bulletin of Atomic Scientists Doomsday Clock release. More details will be available soon at  https://thebulletin.org/doomsday-clock/

 

 

  1. Tuesday, January 24th, 2023 from 6 to 9 pm Mountain – Carlsbad, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Carousel House at Pecos River Village Conference Center, 711 Muscatel Avenue, Carlsbad, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.  https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Thursday, January 26th, 2023 from 6 to 9 pm Mountain – Los Alamos, NM – in-person public hearing about the DOE/NNSA Surplus Plutonium Disposition Program at the Duane Smith Auditorium, Los Alamos High School, 1300 Diamond Drive, Los Alamos, NM. First 30 minutes are a poster session, followed by a NNSA presentation and then public comment session.      https://www.energy.gov/nepa/doeeis-0549-surplus-plutonium-disposition-program

 

 

  1. Monday, January 30th, 2023 from 5 to 8 pm Mountain – Online (ZoomGov) public hearing about the DOE/NNSA Surplus Plutonium Disposition Program. https://pnnl.zoomgov.com/j/1606354491?pwd=bnJrdUhNYUtMWk04ayt2NFdpRUJYZz09#success or

 

ZoomGov.com/join

Meeting ID: 160 635 4491

Passcode: 041993

Dial in only – 1-551-285-1373

 

Please Help Support Concerned Citizens for Nuclear Safety’s Work for 2023

Dear Supporters:

Concerned Citizens for Nuclear Safety wishes to thank you for your past support and to ask you for renewed contributions to allow us to carry on our work promoting the well-being and safety of human beings living in the shadow of the nuclear weapons industries.

It is easy to persuade politicians to spend money on weapons of war, but it is far harder to make them recognize the real costs involved.  Nuclear weapons production contaminates air and water, depletes the soil, and threatens the lives of those living and working nearby.  Economic necessity may force people to welcome the jobs these industries bring, but no one should be forced to suffer from the toxins they produce.  From those downwind from nuclear tests to those whose drinking water is polluted with toxic materials, the most affected individuals are often – although not exclusively – low-wealth and marginalized members of society.  The armed forces, the Department of Energy, National Nuclear Security Administration, and their civilian contractors have vast resources and every incentive to obscure and hide the damage done to people whose bodies and lands are daily exposed to radioactive contamination.

Since 1988, CCNS has worked tirelessly to spotlight these concerns by all available means:  distributing public knowledge through our website and social media; raising issues in public meetings; providing information to legislators, the media and others; meeting with officials of LANL, WIPP, NNSA, the New Mexico Environment Department and other agencies of the federal, state and local government and, when necessary, by filing lawsuits.  Below, please find a list of some of our activities from the past year, all directed toward the safety and well-being of our common communities.

CCNS’s job will never be finished, and it costs money.  Government officials and contractors need to be reminded – gently or forcefully, but in either case continually – to respect the lands where they work and the people who live on them.  Please help us to keep everyone, and especially residents of Northern New Mexico, safe from the pollution generated from one the most dangerous industries on the world.  Tax-deductible donations can be sent to CCNS, Post Office Box 31147, Santa Fe, NM  87594-1147, or they can be made at our website, http://nuclearactive.org/.

Thank you for your generous support!   Together we are making a difference!

Grant Franks                                                               Joni Arends, Co-founder and

Board Chairman                                                         Executive Director

 

The following is a partial list of the routine work and special projects that CCNS has engaged in during 2022.  (Items in bold face have required extraordinary expense for the retention of outside counsel.)

 

CCNS has:

 

  • Produced 52 weekly CCNS News Updates and Did You Know? to keep our subscribers and supporters up-to-date about new developments. CCNS is committed to the regular publication and dissemination of important events and challenges in the nuclear world and to producing fair, reasonable and even-handed reports. We consistently provide documentation, so that the reader can trust these materials and use the information themselves when contacting their representatives or other relevant officials.

 

  • Kept a close eye on the Cerro Pelado Fire, especially as it moved within five miles of LANL’s backgate. In response to concerns voiced by CCNS and others, LANL began fire prevention measures along State Road 4.

 

  • Worked to prevent the release of radioactive tritium from four flanged tritium waste containers stored at Area G, now slated for the spring of 2023.

 

  • Appealed the EPA’s issuance of a discharge permit for industrial sites that do not discharge, including the Radioactive Liquid Waste Treatment Facility (RLWTF) at LANL’s Technical Area 50. The Clean Water Act requires a discharge in order to issue a permit.  The EPA issued “zombie” discharge permits for facilities that don’t discharge, but handle, treat and store hazardous waste, thus requiring regulation under the Resource Conservation and Recovery Act (RCRA).  RCRA requires additional protections for the liquid waste treatment tank systems, additional seismic analyses, and additional monitoring.  LANL is resisting proper regulation.

 

  • Objected to the NMED’s issuance of discharge permit 1132 (DP-1132) for the RLWTF’s Outfall 051. It stopped discharging in November 2010, yet NMED issued the discharge permit.

 

  • Appealed the DP-1132 permit to the NM Water Quality Control Commission (WQCC) where once again, the adjudicatory decisionmaker applied for and gained employment with the National Nuclear Security Administration (NNSA) while making decisions in this matter, a clear conflict of interest. The next WQCC meeting is January 10, 2023.  CCNS encourages you to express your concerns.

 

  • Provided scoping comments about the proposed LANL Site-Wide Environmental Impact Statement (SWEIS). It should have been completed in 2018, but it was delayed for many reasons.  Since 2018. the American taxpayers have paid for new buildings, new personnel, and new bonuses for the weaponers.

 

  • Encourage the State of New Mexico to comply with its issued hazardous waste permit and close the Waste Isolation Pilot Plant (WIPP) in 2024.

 

  • Encouraged enactment of provisions of the WIPP Consultation and Cooperation Agreement to ensure DOE establishes criteria for a new repository in another state than New Mexico;

 

  • Attended WIPP public meetings, including the July 7th “fiasco” meeting in Santa Fe and the October 24th meeting at Buffalo Thunder.

 

  • Participated in in-person and virtual meetings of the NM Legislature Interim Radioactive and Hazardous Materials Committee in Clovis and Santa Fe.

 

  • Participated in the virtual meeting of NM Radioactive Task Force on December 16th.

 

  • Since October, CCNS has requested volumetric data for the LANL waste shipped to WIPP. Since January 2021, Environmental Management-Los Alamos (EM-LA) and NNSA have “shared” shipments to WIPP.  There were two kinds of waste:  pre-1999 legacy cleanup waste and the newly generated waste from plutonium pit production.  Based on unconfirmed data, it appears NNSA shipped more newly generated waste than EM-LA shipped legacy waste.  CCNS is requesting assistance from our congressional offices to confirm the data and cause the establishment of a transparent electronic database where the public can determine for themselves whether legacy cleanup waste is getting off the Hill.

 

  • Participated in the international working group seeking to implement Article 6 Victim Assistance and environmental remediation and Article 7 International cooperation and assistance of the Treaty on the Prohibition of Nuclear Weapons.

 

  • Held meetings with congressional staffers of Senators Heinrich and Lujan and Representative Leger Fernandez about LANL and WIPP issues.

 

  • Prepared for, attended and actively participated in the following weekly, monthly or quarterly meetings:

 

  • Buckman Direct Diversion Board meetings

 

  • Cease Fire Campaign

 

  • LANL Technical Working Group, with a focus on environmental issues

 

  • National Environmental Justice Advisory Committee (NEJAC)

 

  • Stop Forever WIPP Working Group

 

  • White House Environmental Justice Advisory Committee (WHEJAC)
 

Please Support CCNS and HOPE Request for Sanctions in the LANL DP-1132 Appeal before the New Mexico Water Quality Control Commission

CCNS and Honor Our Pueblo Existence (HOPE) request your support of our request for sanctions in the appeal of the groundwater discharge permit DP-1132, issued to Los Alamos National Laboratory for operation of the Radioactive Liquid Waste Treatment Facility.  The appeal is before the New Mexico Water Quality Control Commission, which has the authority to order sanctions.  We seek sanctions requiring the Permittees, the Department of Energy / National Nuclear Security Administration, to pay our expenses caused by DOE/NNSA’s unethical behavior.

This case involves small non-governmental organizations challenging large industrial sites to comply with environmental laws and regulations.  Since 2010, we have been challenging the improper regulation of the Radioactive Liquid Waste Treatment Facility.  Legally, the facility should be regulated by the New Mexico Hazardous Waste Act, not the New Mexico Water Quality Act.

During public hearings on DP-1132, the Permittees announced job openings, and two employees of the New Mexico Environment Department, who were decision makers concerning DP-1132, applied for and were hired by DOE / NNSA.  They had a clear conflict of interest.

The first time, in the summer of 2018, the hearing officer at a public hearing rejected the application of the Hazardous Waste Act, while she was actively pursuing employment with DOE / NNSA, which ultimately hired her.  http://nuclearactive.org/wp-content/uploads/2019/06/190606-CCW-Petition-for-Mandamus-2019-06-06.pdf

CCNS and HOPE incurred legal and other expenses during and after the permit hearing to right the wrong.

The second violation occurred this summer, during our DP-1132 appeal to the Water Quality Control Commission.  The Commission Chair pursued a job with DOE / NNSA, and at the same time allowed the unlawful permit DP-1132 to be effective indefinitely and postponed the appeal.  https://www.env.nm.gov/opf/water-quality-control-commission/, scroll down WQCC 22-21:  Concerned Citizens for Nuclear Safety and Honor Our Pueblo Existence’s Petition for Review of NMED Ground Water Discharge Permit DP-1132, click on link, go to November 4, 2022 Motion by Petitioners to Vacate Orders Issued Under Disqualification, November 17, 2022 Supplemental Memorandum on Motion by Petitioners to Vacate Orders Issued Under Disqualification, and subsequent filings.

It was another clear conflict of interest.  The Commission Chair is now working for NNSA.  http://nuclearactive.org/a-clear-case-of-disqualification-of-nmed-deputy-cabinet-secretary-stephanie-stringer/

During our years-long effort to right the wrongs, CCNS and HOPE incurred costs and legal expenses pursuing the appeal of DP-1132.

The Water Quality Control Commission meets virtually on Tuesday, January 10th, 2023.  https://www.env.nm.gov/opf/water-quality-control-commission/  You can make public comments during that hearing, or submit a written comment on or before Friday, December 30th, 2022.  https://nmed.commentinput.com/?id=ZCP4E or email them to Pamela.Jones@env.nm.gov    Here is a sample comment letter for your use:  f sample DP-1132 public comment ltr 12-22-22

Joni Arends, a CCNS co-founder and executive director, requests that you support our request for sanctions by submitting a written public comment or make a comment during the January 10th Commission meeting.  https://www.env.nm.gov/events-calendar/?trumbaEmbed=view%3Devent%26eventid%3D163442703


 

  1. Friday, December 23rd from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Tuesday, December 20th, 2022 – NMED released the public notice, revised fact sheet, and draft hazardous waste renewal permit for WIPP. It is available here https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.

 

 

  1. Friday, December 23rd, 2022 to Tuesday, January 3rd, 2023 – CCNS will be generally closed for the holidays.
 

Concerned Citizens for Nuclear Safety’s Work of 2022

Dear Supporters:

Concerned Citizens for Nuclear Safety wishes to thank you for your past support and to ask you for renewed contributions to allow us to carry on our work promoting the well-being and safety of human beings living in the shadow of the nuclear weapons industries.

It is easy to persuade politicians to spend money on weapons of war, but it is far harder to make them recognize the real costs involved.  Nuclear weapons production contaminates air and water, depletes the soil, and threatens the lives of those living and working nearby.  Economic necessity may force people to welcome the jobs these industries bring, but no one should be forced to suffer from the toxins they produce.  From those downwind from nuclear tests to those whose drinking water is polluted with toxic materials, the most affected individuals are often – although not exclusively – low-wealth and marginalized members of society.  The armed forces, the Department of Energy, National Nuclear Security Administration, and their civilian contractors have vast resources and every incentive to obscure and hide the damage done to people whose bodies and lands are daily exposed to radioactive contamination.

Since 1988, CCNS has worked tirelessly to spotlight these concerns by all available means:  distributing public knowledge through our website and social media; raising issues in public meetings; providing information to legislators, the media and others; meeting with officials of LANL, WIPP, NNSA, the New Mexico Environment Department and other agencies of the federal, state and local government and, when necessary, by filing lawsuits.  Below, please find a list of some of our activities from the past year, all directed toward the safety and well-being of our common communities.

CCNS’s job will never be finished, and it costs money.  Government officials and contractors need to be reminded – gently or forcefully, but in either case continually – to respect the lands where they work and the people who live on them.  Please help us to keep everyone, and especially residents of Northern New Mexico, safe from the pollution generated from one the most dangerous industries on the world.  Tax-deductible donations can be sent to CCNS, Post Office Box 31147, Santa Fe, NM  87594-1147, or they can be made at our website, http://nuclearactive.org/.

Thank you for your generous support!   Together we are making a difference!

Grant Franks                                                               Joni Arends, Co-founder and

Board Chairman                                                         Executive Director

 

The following is a partial list of the routine work and special projects that CCNS has engaged in during 2022.  (Items in bold face have required extraordinary expense for the retention of outside counsel.)

 

CCNS has:

 

  • Produced 52 weekly CCNS News Updates and Did You Know? to keep our subscribers and supporters up-to-date about new developments. CCNS is committed to the regular publication and dissemination of important events and challenges in the nuclear world and to producing fair, reasonable and even-handed reports. We consistently provide documentation, so that the reader can trust these materials and use the information themselves when contacting their representatives or other relevant officials.

 

  • Kept a close eye on the Cerro Pelado Fire, especially as it moved within five miles of LANL’s backgate. In response to concerns voiced by CCNS and others, LANL began fire prevention measures along State Road 4.

 

  • Worked to prevent the release of radioactive tritium from four flanged tritium waste containers stored at Area G, now slated for the spring of 2023.

 

  • Appealed the EPA’s issuance of a discharge permit for industrial sites that do not discharge, including the Radioactive Liquid Waste Treatment Facility (RLWTF) at LANL’s Technical Area 50. The Clean Water Act requires a discharge in order to issue a permit.  The EPA issued “zombie” discharge permits for facilities that don’t discharge, but handle, treat and store hazardous waste, thus requiring regulation under the Resource Conservation and Recovery Act (RCRA).  RCRA requires additional protections for the liquid waste treatment tank systems, additional seismic analyses, and additional monitoring.  LANL is resisting proper regulation.

 

  • Objected to the NMED’s issuance of discharge permit 1132 (DP-1132) for the RLWTF’s Outfall 051. It stopped discharging in November 2010, yet NMED issued the discharge permit.

 

  • Appealed the DP-1132 permit to the NM Water Quality Control Commission (WQCC) where once again, the adjudicatory decisionmaker applied for and gained employment with the National Nuclear Security Administration (NNSA) while making decisions in this matter, a clear conflict of interest. The next WQCC meeting is January 10, 2023.  CCNS encourages you to express your concerns.

 

  • Provided scoping comments about the proposed LANL Site-Wide Environmental Impact Statement (SWEIS). It should have been completed in 2018, but it was delayed for many reasons.  Since 2018. the American taxpayers have paid for new buildings, new personnel, and new bonuses for the weaponers.

 

  • Encourage the State of New Mexico to comply with its issued hazardous waste permit and close the Waste Isolation Pilot Plant (WIPP) in 2024.

 

  • Encouraged enactment of provisions of the WIPP Consultation and Cooperation Agreement to ensure DOE establishes criteria for a new repository in another state than New Mexico;

 

  • Attended WIPP public meetings, including the July 7th “fiasco” meeting in Santa Fe and the October 24th meeting at Buffalo Thunder.

 

  • Participated in in-person and virtual meetings of the NM Legislature Interim Radioactive and Hazardous Materials Committee in Clovis and Santa Fe.

 

  • Participated in the virtual meeting of NM Radioactive Task Force on December 16th.

 

  • Since October, CCNS has requested volumetric data for the LANL waste shipped to WIPP. Since January 2021, Environmental Management-Los Alamos (EM-LA) and NNSA have “shared” shipments to WIPP.  There were two kinds of waste:  pre-1999 legacy cleanup waste and the newly generated waste from plutonium pit production.  Based on unconfirmed data, it appears NNSA shipped more newly generated waste than EM-LA shipped legacy waste.  CCNS is requesting assistance from our congressional offices to confirm the data and cause the establishment of a transparent electronic database where the public can determine for themselves whether legacy cleanup waste is getting off the Hill.

 

  • Participated in the international working group seeking to implement Article 6 Victim Assistance and environmental remediation and Article 7 International cooperation and assistance of the Treaty on the Prohibition of Nuclear Weapons.

 

  • Held meetings with congressional staffers of Senators Heinrich and Lujan and Representative Leger Fernandez about LANL and WIPP issues.

 

  • Prepared for, attended and actively participated in the following weekly, monthly or quarterly meetings:

 

  • Buckman Direct Diversion Board meetings

 

  • Cease Fire Campaign

 

  • LANL Technical Working Group, with a focus on environmental issues

 

  • National Environmental Justice Advisory Committee (NEJAC)

 

  • Stop Forever WIPP Working Group

 

  • White House Environmental Justice Advisory Committee (WHEJAC)
 

NMED Releases WIPP Fact Sheet; draft Hazardous Waste Permit to be Released Tuesday, December 20th

On Thursday, December 8th, the New Mexico Environment Department released its fact sheet for the draft Waste Isolation Pilot Plant (WIPP) Hazardous Waste Permit.  The draft fact sheet is a way to let New Mexicans and the Department of Energy (DOE) know about the Environment Department plans for the ten-year renewal of the permit.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.   

WIPP is a deep geologic disposal site for plutonium-contaminated wastes generated from the production of pits, or the triggers, for nuclear weapons.  WIPP is located 26 miles east of Carlsbad, New Mexico.  It first opened in 1999 and is supposed to close in 2024.

The Environment Department summarized the new and more protective conditions it is considering.  These include prioritizing the disposal of waste generated prior to 1999, called legacy waste, from cleanup activities in New Mexico, such as at Los Alamos National Laboratory (LANL), which DOE owns.  LANL is located on the Pajarito Plateau above the Rio Grande.

The Environment Department says it will tie closing WIPP to the end of the ten-year permit term unless DOE provides an accurate inventory of all remaining wastes to be emplaced at WIPP.  DOE wants to keep the site open until at least 2080.  Thus, there could be a 50-year gap between what the Environment Department wants and what DOE wants.

The Environment Department will require DOE to submit an annual report describing its steps to site another geologic repository in a state other than New Mexico.  Laws passed by the U.S. Congress have always considered WIPP to be the first, but not only, repository.  Yet DOE has not begun finding another disposal site for nuclear weapons waste to fulfill promises to New Mexico and distribute the waste disposal responsibilities across the country.

The Environment Department Cabinet Secretary, James Kenney, stated, “The New Mexico Environment Department is taking a strong stance to protect the health, environment and interests of New Mexicans.  The proposed permit changes clearly prioritize DOE’s cleanup of legacy contamination in our state while holding the [DOE] accountable.”  https://www.env.nm.gov/home-news-releases/

The draft hazardous waste permit, about 1,200 pages in length, will be released next Tuesday, December 20th for public review and comment.  https://www.env.nm.gov/hazardous-waste/wipp/ , scroll down to WIPP News.

Joni Arends, of CCNS, encouraged you to get involved in this process.  Check out the CCNS website to explore public opposition to WIPP and to find fact sheets and sample public comments you can use and modify to submit your own comments.


  1. Friday, December 16th from 8 am to 9 am – STATE OF NEW MEXICO RADIOACTIVE WASTE CONSULTATION TASK FORCE NOTICE OF PUBLIC MEETING. This will be a virtual webex meeting.  Registration, public notice and agenda may be found at:  https://www.emnrd.nm.gov/wipp-transportation-safety-program/the-radioactive-waste-consultation-task-force/

 

 

  1. Friday, December 16th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Tuesday, December 20thPosting of the draft WIPP hazardous waste renewal permit and a revised fact sheet at https://www.env.nm.gov/hazardous-waste/wipp/ , under “WIPP News.” Get involved!  For more information:  http://nuclearactive.org/ and  https://stopforeverwipp.org/home
 

Diplomacy is the Path to Peace Events for the Week of December 19th

Under the banner of “Diplomacy is the Path to Peace,” non-governmental organizations, faith-based groups, individuals and others are gathering for nationwide activities the week of December 19th to end the war in Ukraine, not life on Earth.  https://defusenuclearwar.org/    

Defuse Nuclear War is promoting the nationwide action as one effort to reach the public and pressure key elected officials to use diplomacy as the path to peace.  They are encouraging people around the country to send photos of loved ones and others, whose futures are at stake, to the White House as well as to their senators and representatives.

Defuse Nuclear War.org will provide digital tools and links to facilitate the process to make it easy for people to send photos and accompanying messages to President Biden and members of Congress encouraging genuine diplomacy and measures to prevent nuclear war.

To learn more about Diplomacy is the Path to Peace, check out the November 30th live stream on the Defuse Nuclear War website.  Speakers included Ryan Black, Mandy Carter, Dennis Kucinich, Pastor Mike McBride, Khury Petersen-Smith, David Swanson, Marcy Winograd and Ann Wright.  https://defusenuclearwar.org/watch-videos/

In New Mexico, Veterans for Peace, CCNS, Nuclear Watch New Mexico, and other New Mexico non-government organizations will be joining together to organize events as we did for the Cuban Missile Crisis 60th anniversary on October 14th.  The groups met with staffers from Senator Martin Heinrich’s office about the need to defuse nuclear war.  They emphasized their demands to end the policy of “first use,” rejoin nuclear weapons treaties the U.S. pulled out of, take U.S. nuclear weapons off hair-trigger alert, get rid of the land-based ICBM nuclear missiles, support congressional action to avert nuclear war, and move the money to human needs, not war.   https://defusenuclearwar.org/learn/

Veterans for Peace member Bob Josephs recounted his experience during the Cuban Missile Crisis as a young Air Force officer near Izmir, Turkey; he was in charge of three nuclear-armed Jupiter missiles kept on hair-trigger alert.  Josephs explained, “I later learned that these missiles were the provocation for Khrushchev stationing Soviet missiles in Cuba.  Robert McNamara, Defense Secretary under Kennedy, said we avoided nuclear war only by luck.  A better plan than just plain dumb luck is to verifiably eliminate nuclear weapons as we pledged to do long ago in the 1970 Non-Proliferation Treaty.”   

To learn more, please join Veterans for Peace, CCNS, Nuclear Watch New Mexico, the Loretto Community, Pax Christi and others in Santa Fe at noon on Fridays for a one-hour peaceful protest at the corners of Alameda and Guadalupe.

In further support of the need to eliminate nuclear weapons, check out the two powerful, yet short podcasts https://defusenuclearwar.org/podcast/ and videos https://defusenuclearwar.org/watch-videos/ with Daniel Ellsberg.    Directed by Oscar-nominee Judith Ehrlich, the series explores the dangers of nuclear weapons and the politics that drive their existence.  Hear firsthand accounts from Ellsberg about his time as a nuclear war planner for the U.S. military and learn hidden truth about realities of nuclear weapons.

In episode 1, Daniel Ellsberg recounts the death toll and violent realities of nuclear war.

In episode 2, Daniel Ellsberg makes the case for the U.S. eliminating hair-trigger intercontinental ballistic missiles (ICBMs) that cannot be called back and are vulnerable to attack.

Defuse Nuclear War is a joint endeavor of RootsAction.org and the RootsAction Education Fund.


  1. Friday, December 9th from noon to 1 pm – Join the weekly peaceful protest for nuclear disarmament on the corners of Alameda and Guadalupe in downtown Santa Fe with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, Pax Christi and others.

 

 

  1. Friday, December 9th and 10thAnnual Congreso de las Acequias in Las Vegas, NM. For more information – https://lasacequias.org/congreso/

 

 

  1. Tuesday, December 13th at 5 pm MST – It’s a great time to start planning activities for the second anniversary of the Nuclear Ban Treaty. January 21st, 2023 will mark the second anniversary of the Treaty on the Prohibition of Nuclear Weapons (TPNW) entered into force.  https://www.nuclearbantreaty.org/upcoming-events-meetings/     Please share this email with friends, family, organizations, faith communities and others!

Register in advance for this meeting by clicking here: https://us02web.zoom.us/meeting/register/tZUrceyqqTIsHdK60QSqg7dzuHzS7nYpBKFj

 

 

  1. Friday, December 16th from 8 am to 9 am – STATE OF NEW MEXICO RADIOACTIVE WASTE CONSULTATION TASK FORCE NOTICE OF PUBLIC MEETING. This will be a virtual meeting. Register in advance here.   https://nmemnrd.webex.com/weblink/register/r6b896955a57fd36b3c9ff9ad435a6333           or HERE https://www.emnrd.nm.gov/wipp-transportation-safety-program/the-radioactive-waste-consultation-task-force/
    A preliminary agenda for this public meeting will be posted on the State of New Mexico’s Energy, Minerals & Natural Recourses Department web page https://www.emnrd.nm.gov/ no later 72 hours prior to the meeting and a final agenda posted on the same web page no later than 24 hours prior to the meeting.