With grave public health and environmental concerns about the potential reopening of the Waste Isolation Pilot Plant (WIPP) before the end of the year, on December 10, 2016 two non-profit organizations, Citizen Action New Mexico and CCNS, filed an expedited Freedom of Information Act (FOIA) request with the Department of Energy (DOE) for key documents, including the recently finalized 350-page Operational Readiness Review.  FOIA_WIPP_Emergency_Release_Dec10 DOE is required to respond within 10 days to an expedited FOIA request.  DOE denied the request because “no one will die tomorrow.”  DOE-Response-to-Expedited-FOIA-12-16-16

On December 21^st, at the invitation of the DOE FOIA Office, Dave McCoy of Citizen Action, Joni Arends of CCNS, and Don Hancock of Southwest Research and Information Center participated in a conference call about “narrowing” the information request.  They argued the FOIA should be expedited because of the existing imminent and substantial endangerment to workers, the public and the environment from hazardous conditions in the WIPP underground, citing the November 3^rd roof fall of a 200-foot long slab of salt in the panel where DOE plans to begin waste emplacement.  Workers were evacuated.

DOE responded that the groups could appeal the denial to the DOE Office of Hearings and Appeal.

Nevertheless, despite assurances that the operational readiness review would be publicly released on December 12^th, it was not.  On December 15^th, the DOE team leader provided a powerpoint summary of it at the WIPP Town Hall meeting.  http://www.wipp.energy.gov/wipprecovery/Presentations/Town_Hall_Slides_12_15_16.pdf  View the Town Hall at  https://livestream.com/rrv/wippdec

DOE describes readiness reviews for nuclear facilities as providing “an independent verification of readiness to start or restart operations.”  See DOE Order 425.1D.  The review team, composed of DOE officials from Hanford, Idaho, Oak Ridge, Savannah River, and DOE Headquarters, found 21 items that must be corrected prior to the proposed reopening and 15 items that may be corrected after reopening.  “Impact on safety” is the DOE’s criteria to determine what distinguishes prestart items from post-start items.

During the Town Hall, Don Hancock, of Southwest Research and Information Center, asked how ceiling collapses would be avoided when waste emplacement begins and continues for three years.  The question was not answered.  http://www.sric.org/

When asked whether Nuclear Waste Partnership, the management contractor and operator at WIPP, would receive a bonus if a container of waste was emplaced in the WIPP underground before the end of the year, Phil Breidenbach, President and Project Manager of Nuclear Waste Partnership, responded, “No.”  However, the Performance Evaluation and Measurement Plan (PEMP) clearly states that Nuclear Waste Partnership would receive a $2.1 million bonus.  See Metric/Milestone 1 on p. 12 of the FY 17 PEMP at http://www.wipp.energy.gov/NWPpayments/NWP/FY17_PEMP.pdf – correction made 12/28/16 from Metric/Milestone 1 on p. 13 at http://www.wipp.energy.gov/NWPpayments/NWP/FY16_PEMP_%20Rev_2.pdf

Quietly, on Friday, December 16th, the New Mexico Environment Department approved the “resumption of normal operating status at WIPP.”  https://www.env.nm.gov/wp-content/uploads/2016/01/161222PR-WIPPInspectionCompleted-1.pdf

CCNS and others argue that “normal operating status” no longer exists at WIPP because it is not the facility originally permitted by the Environment Department in 1999.  It is now a contaminated site with inadequate ventilation requiring workers to wear personnel protective equipment, including respirators.

Dave McCoy, of Citizen Action New Mexico, stated, “The Department of Energy is keeping critical safety documents secret that may challenge an overly hasty resumption of WIPP operations.  WIPP had a fire, an explosion with radiation exposure of 22 workers and the public, roof collapses, evacuations, and lacks medical and radiological response staffing.  Workers and the taxpayer deserve safety.”  http://www.radfreenm.org/

On December 22, 2016, Citizen Action and CCNS appealed the denial of the expedited FOIA request. CANM-CCNS-OHA-WIPP-Appeal-12-22-16

Despite promises made during their presidential campaigns, neither George W. Bush nor Barack Obama took U.S. land-based nuclear weapons off hair trigger alert.  With the possibility of a Trump presidency, there are two executive actions President Obama could take to reduce the risks of nuclear war.  Currently, U.S. nuclear weapons are on “hair trigger alert” and ready to launch 24/7.  President Obama could put them in maintenance mode that would provide additional time for information to be compiled before the president, as the sole decider, could launch nuclear weapons in retaliation to a nuclear attack.  He could also declare that the U.S. would never again be the first to use nuclear weapons, as the U.S. did in Hiroshima and Nagasaki near the end of World War II.

It is time for President Obama to fulfill his campaign promise and the promises he made in 2008 in Prague to reduce the nuclear danger.  He said then, “As the only nuclear power to have used a nuclear weapon, the United States has a moral responsibility to act.  We cannot succeed in this endeavor alone, but we can lead it, we can start it.  So today, I state clearly and with conviction America’s commitment to seek the peace and security of a world without nuclear weapons.”

There are approximately 16,000 nuclear weapons in the world and between the U.S. and Russia about 1,800 remain on hair trigger alert.  Currently, U.S. nuclear weapons may be launched through a “triad” of submarines, bombers, and land-based missiles, such as the Minuteman IIIs.

Joni Arends, of CCNS, said, “We will state the obvious – a President Trump with the nuclear codes scares the bejeebers out of us.  President Obama has the executive power to declare an official U.S. no-first-use policy and to remove 450 land-based nuclear weapons from hair trigger alert.”

She continued, “During this time of giving, please take a few minutes to urge President Obama to reduce the threat of nuclear war.  Two non-governmental organizations, the Union of Concerned Scientists and Physicians for Social Responsibility, have campaigns to assist you.  Children and future generations thank you for taking action today.”   

The Union of Concerned Scientists promotes “science for a healthy planet and safer world.”  It has extensive materials on its website about taking nuclear weapons off hair trigger alert, including a short animated video and an on-line letter.  http://www.ucsusa.org/nuclear-weapons#.WFNxGoVcNP4 and https://youtu.be/2x_57sE1_LQ

Founded in 1961, the Physicians for Social Responsibility documented radioactive strontium-90 from above-ground testing of nuclear weapons in baby teeth.  It has extensive materials on its website about no-first-use of nuclear weapons and the humanitarian consequences of nuclear war.  http://www.psr.org/nuclear-weapons/ and https://youtu.be/Pk5IT9ehh68

From December 2^nd to 4^th, more than 80 activists from around the country gathered in Chicago, Illinois to address the nation’s commercial high-level radioactive waste issues.  People attended from dozens of nuclear power reactor areas where highly radioactive waste is located now; as well as from New Mexico, Texas, and Nevada communities being targeted for new nuclear waste sites; and from along transport routes.  There were also participants from Canada where there are similar problems and from the Marshall Islands, where severe contamination and health problems persist from U.S. nuclear weapons testing.

The Summit included presentations from grassroots people and experts, as well as strategy sessions for activities in the upcoming year and beyond. There was agreement on the unsuitability of the proposed Yucca Mountain, Nevada site, and continuing strong opposition to any efforts by Congress or the new administration to proceed with that site. Representatives of the Western Shoshones also discussed how the site is totally contrary to their historic and treaty rights to the proposed site. That more than 40 states would be impacted by transporting waste to Yucca Mountain is another major concern.

Representatives from Texas and New Mexico provided information about their “non-consent” to, and the unsuitability of, the proposed consolidated storage sites at Waste Control Specialists, located on the Texas-New Mexico state line near Eunice, New Mexico, and the Holtec site near Hobbs, New Mexico. The Summit attendees agreed that people across the country would also oppose those sites and the transportation through many states that would be required.

Summit participants also agreed with people living near nuclear power plants that the irradiated fuel must be more safely stored. Pools where waste is too densely stored pose risks of major accidents that could affect millions of people. On-site storage in thin-walled casks that cannot be adequately inspected or repackaged when they leak also pose risks of significant releases. Such storage does not adequately protect from accidents, natural disasters, or terrorist attacks.

There was agreement that more robust on-site storage is needed now, including reducing the amount of waste in pools and using thick-walled containers to store waste in buildings that are protected, rather than the existing open air pads.

Rose Gardner, from Eunice, New Mexico, attended the Summit.  She said, “The country to ready to clean up the mess that’s been created. Since there is no permanent repository, and consolidated storage is not an acceptable option, we need to isolate radioactive waste more safely around reactor areas until there are safe disposal options. Further, environmental justice requires protection of people of color communities that must be addressed by the Nuclear Regulatory Commission and nuclear corporations.”

For more information about the Summit and to view the webinars about the issues, go to:  http://www.beyondnuclear.org/radioactive-waste-whatsnew/2016/12/2/national-grassroots-radioactive-waste-summit-december-2-to-4.html or go to http://www.beyondnuclear.org, go to Radioactive Waste on the left side of the home page, go to What’s New and learn more about the Summit.

On November 10, 2016, the Department of Energy (DOE) requested a temporary authorization from the New Mexico Environment Department to install eight closure bulkheads in the Waste Isolation Pilot Plant (WIPP) underground; discontinue inspections of existing closure apparatus and bulkheads; and terminate monitoring of hydrogen, methane and volatile organic compounds in the waste filled rooms.  http://www.wipp.energy.gov/rcradox/16-3326_Temporary_Authorization_Request.pdf  On the same day, DOE submitted a 757-page revised permit modification request to the Environment Department for the same changes.  http://www.wipp.energy.gov/library/Information_Repository_A/Class_3_Permit_Modifications/Response_TID_Revised_Class_3_PMR_WIPP_Panel_Closure_Plan.pdf

DOE believes it can install the proposed bulkheads under a 180-day temporary authorization before completion of the required public comment and public hearing on the modification request. Nevertheless, DOE acknowledges that it may need to request another 180-day extension of time.  http://www.wipp.energy.gov/rcradox/16-3326_Temporary_Authorization_Request.pdf

The Environment Department has said on previous occasions that a temporary authorization requires showing that the activities are “essential” and the need is “immediate.”  Otherwise, normal public comment procedures should be followed.

The Environment Department’s hazardous waste permit for WIPP requires that any request for a temporary authorization must be posted on the WIPP website, as well as mailing a notice that the document is posted to interested people.  But WIPP did not post their request as required.

On November 29^th, Don Hancock, with Southwest Research and Information Center, http://www.sric.org/, wrote to the Environment Department asking that it issue a notice of permit violation to WIPP and requesting a 30-day public comment period on the temporary authorization. sric-ta-letter-112916-1 The next day, Hancock received a response from the Environment Department, concurring with his assertion that WIPP had violated the permit. nmed-ta-southwest-research-response-letter11-30-16-doc The Environment Department contacted WIPP “to remind them of the permit provision and require that they immediately post the Temporary Authorization.”  WIPP then posted the request.  The Environment Department denied providing a 30-day public comment period.

In other WIPP news, the Environment Department recently extended the public comment period for the proposed 65,280 cubic foot waste container storage unit on the surface at WIPP until February 3^rd, 2017.  Sample public comments are available at http://nuclearactive.org/wp-content/uploads/2016/10/WIPP_Surface_Storage_Comment_102016.pdf

At the same time, while DOE is planning to close some of the contaminated underground and build above-ground storage, it is working to re-start waste emplacement following the February 2014 vehicle fire and explosion.

Hancock said, “WIPP officials knowingly violated permit requirements regarding posting the temporary authorization request.  WIPP has not adequately justified the temporary authorization, so the request should be denied.  WIPP needs to focus on protecting workers and the public from a contaminated mine that has inadequate ventilation and collapsing ceilings.  It should not continue to propose WIPP expansions and premature re-opening.”

#GivingTuesdayNM     –    Together we can do more

Dear Friends of CCNS,

Your support of CCNS will allow us to:

1. Bring light to the harm done to the Trinity Downwinders. Work with the Tularosa Basin Downwinders Consortium to finalize the Health Impact Assessment for the Downwinders of the first atomic bomb test at the Trinity Site in south central New Mexico on July 16, 1945; and

Push for congressional passage of amendments to the Radiation Exposure Compensation Act (RECA) that would include the Trinity Downwinders, as well as the Post-71 Uranium Miners;

2. Protect surface and ground water from LANL pollutants. Continue to take the lead with the Communities for Clean Water to challenge four ground water discharge permits for Los Alamos National Laboratory (LANL), issued by the New Mexico Environment Department and U.S. Environmental Protection Agency, that allow for the discharge of thousands of gallons per day into the canyons that flow to the Rio Grande and seep into the regional drinking water aquifer; and

3. Bring light to LANL nuclear weapons work. Work with the Interested Parties (Tewa Women United, Peace Action, Nuclear Watch New Mexico, and others) to push for reinstatement of the semi-annual public meetings for the Chemistry and Metallurgy Research Replacement (CMRR); and

Oppose expansion of the amount of plutonium allowed in the CMRR Radiological Laboratory Utility and Office Building (RLUOB) from 8.4 grams to over 450 grams.

We will continue to keep you informed through the CCNS Media Network with the CCNS News Update, which is posted on Fridays to our website at http://www.nuclearactive.org, Facebook and Twitter and emailed out to our extensive list – which we never share.

To make your donation, just click the DONATE button on the top right for a one-time donation, or the SUBSCRIBE button to make a recurring monthly donation.

Thank you for your support over the past 28 years!  Together we are making a difference!

CCNS Board and Staff

The Department of Energy (DOE) has been working to reopen the Waste Isolation Pilot Plant (WIPP) for the disposal of radioactive and hazardous waste without conducting the proper National Environmental Policy Act (NEPA) review.  In their recent eight-page letter to DOE Secretary Moniz, Southwest Research and Information Center (SRIC) and the Natural Resources Defense Council (NRDC) highlight the reasons why DOE must conduct the proper NEPA reviews, including supplementing the WIPP environmental impact statements, before reopening WIPP.  nrdc-sric-ltr-to-moniz-wipp-nepa-final112116

WIPP was to be a “start clean, stay clean” operation and was so analyzed in the 1980, 1990 and 1997 environmental impact statements.  The February 2014 fire and radiation release, which contaminated over 8,000 feet of the underground mine and 22 workers on the surface have created a contaminated facility that was not analyzed for in previous NEPA documents.  NRDC and SRIC state that DOE’s analysis “materially underestimated the probability and environmental consequences” of the low-probability, high consequence events.  Those events are now reasonably foreseeable, with significant adverse effects that require supplemental analysis under NEPA.

DOE’s plans to recover the mine, including the installation of a new exhaust shaft, a new permanent ventilation system, and disposing of waste in contaminated rooms, have not been analyzed, as required by NEPA.  The two non-governmental organizations argue that NEPA requires analysis of the proposed changes before WIPP could be reopened.  They have asked DOE to meet with them to discuss the “nature of the analyses to be undertaken.”

NEPA is a federal law, signed by President Nixon in 1970, to address major federal actions and their impacts on the environment.  It establishes “a national policy which [ ] will promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man.”  https://ceq.doe.gov/laws_and_executive_orders/the_nepa_statute.html 

SRIC and NRDC call for analysis of the 600 potentially explosive waste drums emplaced in the underground, as well as at Waste Control Specialists, located on the Texas-New Mexico border, and at Los Alamos National Laboratory (LANL), the source of the exploding drums.  The analysis must include review of DOE waste handling requirements and the inadequate line management oversight programs and processes at DOE Headquarters, WIPP, LANL and their respective contractors, including Energy Solutions, Inc.

The contaminated mine now requires the identification and analysis of new alternatives to reopening WIPP.  These could include not reopening WIPP, closing the contaminated areas and mining new rooms for waste emplacement.

Don Hancock, of Southwest Research and Information Center, commented, “NEPA requires that DOE’s plans and reasonable alternatives must be discussed with the public prior to deciding to reopen WIPP.  DOE must do so.”

In its effort to use contaminated portions of the Waste Isolation Pilot Plant (WIPP) for waste disposal, despite inadequate ventilation and on-going roof collapses, the Department of Energy (DOE) is ignoring the safer “clean salt” option.  WIPP’s stated mission has emphasized “start clean, stay clean” to not open waste containers to limit the likelihood of radioactive and toxic chemical emissions that endanger workers and the public.  The facility’s ventilation system was not designed for a radiation release, since such an event was never supposed to occur.

But on February 14^th, 2014, one or more drums released significant amounts of radioactivity that contaminated more than 8,000 feet of underground tunnels and the exhaust shaft that goes 2,150 feet to the surface. In addition, 22 workers on the surface were contaminated and radioactivity was released into the environment.

DOE intends, perhaps by the end of this year, to begin putting waste into a contaminated room underground.  Because of the contamination, such an activity will require workers to be in protective equipment with respirators.  DOE has not considered the safer option of closing up the contaminated Panel 7 and instead mining Panel 8 in the uncontaminated part of the mine or using areas of Panel 10 that were not contaminated.

This week DOE began its final operational readiness review, a necessary step to begin waste disposal.  Meanwhile incomplete air monitoring data indicate an increase in radiation levels in the underground mine, perhaps from recent falls of tons of contaminated salt rock from the ceiling.  See Carlsbad Environmental Monitoring and Research Center at http://www.cemrc.org/, specifically 2016 Station A and B Data at the bottom of the page at http://www.cemrc.org/2014-wipp-release/station-b-fas-data/ and the lack of New Mexico Environment Department, DOE Oversight Bureau at WIPP data at https://www.env.nm.gov/doeob/wos-data/

On November 10^th, DOE submitted a revised permit modification request to the New Mexico Environment Department for changing the closure plans.  DOE proposes to use barriers to close some of the contaminated area, while at the same time allowing waste to be emplaced.  http://www.wipp.energy.gov/library/Information_Repository_A/Class_3_Permit_Modifications/Response_TID_Revised_Class_3_PMR_WIPP_Panel_Closure_Plan.pdf

DOE also requested a temporary authorization so that it could do the closure before completion of the required public comment and hearing process.  Unfortunately, DOE has not posted the request for temporary authorization on the WIPP website.

The Environment Department is planning to conduct its annual WIPP inspection before the end of the year, as it must approve WIPP’s reopening.

Don Hancock, of Southwest Research and Information Center, urged caution.  “Rushing to put waste into contaminated areas increases the likelihood of another accident.  Moreover, the only obvious reason to rush re-opening of the facility is so that the DOE’s contractor, Nuclear Waste Partnership, will get $2.1 million in performance fees in addition to the $300 million increase in its contract since the radiation release.”

Recognizing the concerns raised by the community on the lack of adequate public notice about the renewal of the Triassic Park hazardous waste permit, the New Mexico Environment Department agreed to a 60-day extension of the public comment period from November 18^th to January 20^th, 2017 at 5 pm Mountain Standard Time.  The Environment Department will issue a third public notice, in both English and Spanish, to inform the public about the extension.

Triassic Park is a yet-to-be-built 35-acre commercial hazardous waste disposal facility located on 480 acres in rural Chaves County, about 35 miles east of Roswell.  It is near the small communities of Dexter, Hagerman, and Lake Arthur, where a large number of Spanish-speaking residents live and high levels of poverty exist.

The Environment Department also will ensure that the public notice and the permit fact sheet, both in English and Spanish, are physically posted at 27 locations in the area surrounding the landfill.  Those locations include six in Artesia, at the city council building, public library, the Cottonwood Rural Water Co-op, the Riverside Mutual Domestic Water Association, and the two post offices; one in Carlsbad, at the Otis Water Users Co-op; two in Dexter, at the town hall and post office; three in Hagerman, at the town hall, post office, and Fambrough Water Co-op; three in Lake Arthur, at the post office, town hall and Lake Arthur Water Co-op; nine in Roswell, at the public library, city hall, Roswell Adult Center, Berrendo Water Co-op, Cumberland Cooperative Water Users Association, and the four post offices; and three in Tatum, at the post office, town hall and community library.

The public notices will also be published in the Albuquerque Journal, the Roswell Daily Record, and the Carlsbad Current Argus in the classified section.  Public service announcements will air on KUNM-FM 89.9 in Albuquerque, KALN-FM 96.1 in Dexter, and KBIM-FM 94.9 in Roswell.

A printed copy of the draft permit is now available at the Environment Department’s District III office in Roswell, located at 1914 West Second; and in the Roswell Public Library, located at 301 North Pennsylvania.

For more information about Triassic Park, please visit sacredtrustnm.org.  The draft permit and many associated documents are also available at env.nm.gov/HWB/tpperm.html

The release of several documents over the last couple of weeks reveals that even though the 63-acre Area G dump at Los Alamos National Laboratory (LANL) was supposed to be “cleaned up” by December 31, 2015, the new projected cleanup date to begin work may not be until 2028, at the earliest, 13 years after it was supposed to be finished.  The December 2015 cleanup date was established by the 2005 Compliance Order on Consent, or Consent Order, agreed to by the New Mexico Environment Department and the Department of Energy (DOE) and its contractor, the University of California.  https://www.env.nm.gov/HWB/documents/LANL_10-29-2012_Consent_Order_-_MODIFIED_10-29-2012.pdf

On June 24, 2016, the Department and DOE agreed to a new Consent Order, but this time without the opportunity for the public to request a formal hearing.  https://www.env.nm.gov/HWB/lanlperm.html   In July, Nuclear Watch New Mexico sued the Department, DOE and its contractor over this and other issues.  http://www.nukewatch.org/cleanuplawsuit.html

Technical Area 54, where the dumps at Areas G, H and L are located, first started receiving hazardous, toxic and radioactive waste in the late 1950s, which were disposed of in unlined pits, trenches and shafts in the volcanic tuff.  Some of the trenches are 65 feet deep and the waste is buried in layers, like a cake.

Pollutants have been found in the ground water below Areas G and L, which threaten the drinking water for Los Alamos County and Santa Fe.  None of the recently released documents explain how the regional drinking water aquifer will be protected while there are more cleanup delays.

On October 12^th, the new DOE Environmental Management Field Office at LANL sent a letter notifying the Department of their withdrawal of the cleanup reports for Areas G, H, and L, which were submitted in 2011, stating that based on its life-cycle cost estimate and the need for the dumps to be available, it will submit new cleanup reports at some undetermined date.  doe-em-withdrawal-3-cleanup-plans-areas-g-h-l-10-12-16

Further, the new DOE Request for Proposal for cleanup of the LANL legacy waste reveals that preparing the cleanup documents will begin in 2026, with work possibly beginning in 2028.  https://www.emcbc.doe.gov/SEB/LLCC/rfppage.php, see September 21, 2016 cover letter, and at the bottom of the page, Amendment 001, Section L Red-line at p. 69.  It is anticipated that regardless of when the documents are released, the public will request a formal hearing.

Scott Kovac, of Nuclear Watch New Mexico, said, “It’s a disservice to make Northern New Mexico wait 13 more years for a “cleanup” that will probably want to leave most of the waste in the ground under a soil cap. The only way to completely protect the regional aquifer is to characterize the waste and remove the sources of the contamination. Then we’ll know what needs to be done. We expect more out of the world’s smartest scientists than a plan to cap the dumps.”

To learn about DOE’s cleanup plans for LANL legacy waste in the coming year, as well the completed and current work, please plan to attend the public meeting hosted by the New Mexico Environment Department and DOE’s Environmental Management at Los Alamos Field Office on Wednesday, November 16, 2016 from 5 pm at Fuller Lodge, in downtown Los Alamos.  https://www.env.nm.gov/wp-content/uploads/2016/01/161103PR-COAnnualPlanningPubMtg161116.pdf

Providing informed public comments about a proposed hazardous waste disposal site is a daunting task, especially if the supporting paper and electronic documents are in disarray.  This is the case for the draft permit for Triassic Park, a proposed landfill for hazardous waste located east of Roswell, New Mexico.  Supporting documents in the administrative record were unstapled to be scanned for internet posting, but were not re-stapled together and are sitting loose in boxes.  The on-line record has almost 200 out-of-order items, missing documents, and nothing has been updated in months.

Triassic Park is located in rural, southeastern New Mexico, near the small communities of Dexter, Lake Arthur and Hagerman, where there are high levels of poverty and a large number of Spanish-speaking residents.  To learn more about Triassic Park and the history of discrimination by the New Mexico Environment Department, please go to http://sacredtrustnm.org/nmed-the-triassic-park-permit-just-as-bad-as-the-first-time/

Gandy Marley, Inc., the owners of Triassic Park, applied for a hazardous waste disposal permit, and following a public hearing in 2002, the New Mexico Environment Department issued the permit.  Now Gandy Marley is asking the Department to renew the 10-year permit.  https://www.env.nm.gov/HWB/tpperm.html

During the first public hearing, issues of discrimination were raised because basic information about the site was not made available in Spanish for the communities surrounding Triassic Park and Spanish-speakers who tried to participate were sometimes insulted.

Those concerns remain as today’s permitting process is repeating some of the discriminatory practices that were complained about 15 years ago.  http://nuclearactive.org/card-civil-rights-complaint-to-epa-about-triassic-park-thirteen-years-and-no-resolution/  The Department had to be prodded into providing a fact sheet in Spanish and did not provide printed information near the site until the comment period was almost over. Even now those documents are in their Roswell office, which is only open during working hours.  Further, the Department insists that everyone can easily use the on-line record even when the communities are rural, poor and have large numbers of Spanish speakers.  Recent research about internet use reveals that these communities are more likely to have lower on-line access and fewer on-line research skills, thus increasing participation challenges.  For these reasons, the Department must provide a paper copy near the dump in a place with longer hours.

Communities for Environmental Justice and Citizens for Alternatives to Radioactive Dumping are committed to raising these issues.  The groups request that you to sign their Change.org petition asking the Department to extend the public comment period for 60 days after the administrative record is put back in order and a paper copy is accessible in a public building with evening and weekend hours near the dump.  Please sign the petition at https://www.change.org/p/nmed-provide-printed-information-for-those-affected-by-triassic-park-hazardous-waste-dump?recruiter=613284821&utm_source=share_petition&utm_medium=email&utm_campaign=share_email_responsive

Public comments are currently due to the Environment Department on Friday, November 18th.  All comments should be directed by mail or email to:
Dave Cobrain, Program Manager
Hazardous Waste Bureau – New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe NM 87505-6303
Email: dave.cobrain@state.nm.us

In your comment you must state that they are:
Triassic Park Draft Permit Public Comments

Sample public comments that you can use are available at http://sacredtrustnm.org/nmed-the-triassic-park-permit-just-as-bad-as-the-first-time/

Or use these talking points/requests to create your own:

• A paper copy of the entire Administrative Record, including the draft permit, English and Spanish Fact Sheets, the 2002 hearing record and the hearing transcript, and associated documents must be placed in a library near the site that is open evenings and weekends
• The online Administrative Record must be corrected, be made complete, be updated in a timely manner, and be made more user-friendly
• The comment period must be extended for an additional 60 days, beginning after these requests have been fulfilled