Late last week, the Environmental Protection Agency (EPA) quietly released draft guidance to be used following a radiation contamination incident that would allow radioactivity in drinking water at concentrations vastly greater than allowed under the Safe Drinking Water Act. https://www.regulations.gov/document?D=EPA-HQ-OAR-2007-0268-0210 Under the proposed Protective Action Guides (PAGs) for drinking water, no actions to protect the public would be taken even if the radioactivity in drinking water were dozens or thousands or millions of times higher than Safe Drinking Water Act levels. The PAGs would allow radiation exposures from drinking water that are equivalent to 250 chest x-rays a year, or five x-rays a week for 50 weeks a year for up to four years.

For example, the current limit for radioactive iodine-131 in drinking water is 3 picoCuries per liter of water. The proposed guidance allows 10,350 picoCuries per liter of water, which is 3,450 times higher. Further, the current drinking water limit for radioactive strontium-90, which causes leukemia, is 8 picoCuries per liter of water. The proposed guidance allows 7,400 picoCuries per liter of water, a 925-fold increase.

EPA explained in its federal register notice announcing the release of the draft guidance that “[t]he PAG levels are guidance for emergency situations; they do not supplant any standards or regulations, nor do they affect the stringency or enforcement of any standards or regulations. The PAG levels are intended to be used only in an emergency when radiation levels have already exceeded environmental standards. EPA expects that any drinking water system adversely impacted during a radiation incident will take action to return to compliance with Safe Drinking Water Act levels as soon as practicable.” https://www.regulations.gov/document?D=EPA-HQ-OAR-2007-0268-0210 at last paragraph of Section E.

In response, Diane D’Arrigo, the Radioactive Waste Project Director of the Nuclear Information and Resource Service, said, “Look no further than the current water crisis in Flint, Michigan to understand [the] concern that the EPA will not act to protect public health in an emergency. In this case, the EPA is attempting to ensure that it would not have to act decisively to protect public health!” http://www.nirs.org/home.htm

Catherine Thomasson, Executive Director of Physicians for Social Responsibility, added, “Clean water is essential for health. Just like lead, radiation when ingested in small amounts is very hazardous to our health. It is inconceivable that EPA could now quietly propose allowing enormous increases in radioactive contamination with no action to protect the public, even if concentrations are a thousand times higher than under the Safe Drinking Water Act.” http://www.psr.org/resources/letter-to-epa-pags-radionuclides.html

Public comments are due on Monday, July 25^th, 2016 and may be submitted by EPA’s preferred method electronically to regulations.gov and specifically to https://www.regulations.gov/#!submitComment;D=EPA-HQ-OAR-2007-0268-0210 or by mail to:

U.S. Environmental Protection Agency
EPA Docket Center
Docket ID No. EPA-HQ-OAR-2007-0268
Mail Code 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

For more information, please visit: https://www.epa.gov/dockets/where-send-comments-epa-dockets

In the early morning of July 16, 1945, the U.S. government detonated the first atomic bomb from a 100-foot metal structure in the south central desert of New Mexico.  In the massive explosion, the radiation and toxic materials rose an estimated 70,000 feet and began to fall back to earth in what many thought was snow.  The kids played in it, the cattle and vegetable gardens were covered in it.  Later that night when it rained, the water cisterns and acequias were contaminated with radioactive and toxic particles.

The innocent people of the Tularosa Basin were not informed beforehand and were not evacuated after the test, even though the exposures were at least 10,000 times higher than what is considered safe today.  Cancer rates in the Tularosa Basin are four to eight times higher than the national average.

For more information, please see Chapter 10, “The Trinity Test” of the 2010 Los Alamos Historical Document Retrieval and Assessment report at http://www.lahdra.org/pubs/Final%20LAHDRA%20Report%202010.pdf 

To memorialize those who have died and to honor those who are living with or who have survived cancer, the Tularosa Basin Downwinders Consortium, in cooperation with the Village of Tularosa, will host the Seventh Annual Candlelight Vigil on Saturday, July 16^th from 8 to 10 pm at the Tularosa Little League Field, on La Luz Avenue, west of the Tularosa High School.  Everyone is invited to attend.  Luminarias will be available for a small donation beginning at 7:30 pm.  July 16, 2016 event flyer

For more information, please contact Tina Cordova at 505 897-6787.

On July 16^th, 1979, an earthen uranium tailings dam at the United Nuclear Corporation Church Rock Uranium Mill failed, spilling 93 million gallons of liquid toxic waste into the Rio Puerco in New Mexico, which eventually flowed downstream into Arizona.  The spill contributed to the long-term contamination already present in the watershed from the release of untreated or poorly treated uranium mine water into the Rio Puerco.

The Red Water Pond Road Community Association and partners are very concerned about the uranium contamination legacy, which has poisoned our Mother Earth, and they are working to ensure clean-up at three Superfund sites.

On Saturday, July 16^th, the Red Water Pond Road Community Association will host 37^th commemoration of the North East Church Rock Uranium Tailings Spill from 7 am to 3 pm, located 12 miles north of Red Rock State Park on State Highway 566.  The public is cordially invited to attend.

The organizers invite you to “Please join the community on this journey to heal our Dine and Mother Earth and restore the Hozho’.  We believe we need to support one another and cherish all our families and communities, just as our elders have.  By working together, with our combined intelligence and wisdom we can and are addressing this legacy to provide a life of balance and harmony for our people now and for the future generations.  Thank you to the leaders who passed the Dine Natural Resources Act in 2005, and all who have been fighting for justice in the natural environment realm, especially the grass-roots organizations.

“This historic event is open to all ages and will share the struggles people face in their daily lives, the healing yet to come for our people and Mother Earth, and the awareness and education required in the local area, tribally, statewide and on the national level. We would like the younger generation to be present, advocate and carry on these traditions of caring for Mother Earth.

“It is said that The Four Sacred Mountains say to us,

‘My child I will feed you, give you good health, and I will give you strength and courage.  My child I will give you clean air and clean water to drink. I am your Life.  My child, get ready now and educate yourself.  Improve yourself and don’t forget who you are. My child what I am dressed with, is what you are dressed with.  I am your home and your mother and father.’

“Let us come together again and share these issues and concerns, collaborate and strategize, to push clean-up of these contaminated environments among our Dine people to restore, preserve and protect our Mother Earth.”

For more information, please contact Edith at 505-905-8051, Grace at 505-905-7010, Annie at 505-905-5721, or Terri/Peterson at 505-905-2731.  Please also visit http://swuraniumimpacts.org/

On May 27, 2016, President Barack Obama and Japanese Prime Minister Shinzo Abe laid wreaths at the Hiroshima Peace Memorial Park to mourn and honor those who died when, on August 6^th, 1945, the U.S. dropped the first atomic bomb used in war on the city.  In a moving speech, Obama asked, “Why do we come to this place, to Hiroshima?”  He answered, “We come to ponder a terrible force unleashed in a not-so-distant past.”  https://www.whitehouse.gov/the-press-office/2016/05/27/remarks-president-obama-and-prime-minister-abe-japan-hiroshima-peace

Obama then recognized those who perished that day – more than 100,000 Japanese men, women and children; a dozen American prisoners of war; and thousands of Koreans, many brought to Japan as forced laborers.

He explained that the voices of the survivors, the hibakusha, “will no longer be with us to bear witness.  But the memory of the morning of August 6, 1945, must never fade.  That memory allows us to fight complacency.  It fuels our moral imagination.  It allows us to change.”

As the first sitting U.S. President to visit Hiroshima, Obama challenged us to “change our mind-set about war itself” and to look to “a future in which Hiroshima and Nagasaki are known not as the dawn of the atomic warfare but as the start of our own moral awakening.”

We challenge the President, as part of his moral awakening, to accept the invitation of the Tularosa Basin Downwinders Consortium to attend the July 16, 2016 candlelight vigil in Tularosa, New Mexico.  The event commemorates those who died, or are suffering with cancer and other illnesses, as a result of the U.S. test of the first atomic bomb at the Trinity Test Site in south central New Mexico 71 years ago, on July 16, 1945.

Tina Cordova, co-founder of the Tularosa Basin Downwinders Consortium, said, “Listening to President Obama speak in Hiroshima was in some respects bittersweet for me.  Not because I am against him acknowledging the Japanese people and their suffering.  I believe they deserve it.  I simply regret that he nor any other U.S. President has made their way to New Mexico to do the same for the people here.”

She continued, “President Obama said ‘Imagine the moment the bomb fell.’  Yes, President Obama, imagine that moment in the desert of New Mexico that forever changed our lives.  We have suffered ever since and suffer still.  It is time the U.S. government makes their way back to where the first atomic bomb was detonated and takes responsibility for the U.S. citizens that were harmed in the process.  Anything less is immoral and contrary to the ‘moral revolution’ that President Obama referred to in his remarks in Japan.”

There is a broad spectrum of opinions about President Obama’s visit to Hiroshima.  Here is a sampling:

Funakoshi, Minami, Reuters.  “Obama mourns dead in Hiroshima, calls for world without nuclear arms,” at http://www.reuters.com/article/us-japan-obama-hiroshima-idUSKCN0YH2PQ

Funakoshi, Minami, Reuters.  “Hiroshima survivors:  Obama speech moving, ‘more than enough,’” at http://www.reuters.com/article/us-japan-obama-hiroshima-voices-factbox-idUSKCN0YI0GL

Germanos, Andrea, Common Dreams.  “Obama’s Historic Hiroshima Visit Underscores Nuclear Hypocrisy,” at http://www.commondreams.org/news/2016/05/26/obamas-historic-hiroshima-visit-underscores-nuclear-hypocrisy

Hutchinson, Ralph, Oak Ridge Environmental Peace Alliance.  “Did Hiroshima Awaken the President,” at http://orepa.org/did-hiroshima-awaken-the-president/

LaFleur, Jennifer, Center for Investigative Reporting. “America’s atomic vets:  We were used as guinea pigs – every one of us,” at https://www.revealnews.org/article/us-veterans-in-secretive-nuclear-tests-still-fighting-for-recognition/

McNeill, David, Irish Times.  “Barack Obama in Hiroshima:  long on words, short on action,” at http://www.irishtimes.com/news/world/asia-pacific/barack-obama-in-hiroshima-long-on-words-short-on-action-1.2663545

Morris-Suzuki, Tessa, Bulletin of the Atomic Scientists.  “Obama, Hiroshima, apologies, and the invisible victims of the atomic bombings,” at http://thebulletin.org/obama-hiroshima-apologies-and-invisible-victims-atomic-bombings9490

NPR Coverage, with links to listen to the speech:  http://www.npr.org/sections/thetwo-way/2016/05/27/479691439/president-obama-arrives-in-hiroshima-the-first-sitting-commander-in-chief-to-vis

New York Times.  “What Should Obama Say on His Visit to Hiroshima?” at http://www.nytimes.com/2016/05/25/world/asia/what-should-obama-say-on-his-visit-to-hiroshima.html?_r=0

White House coverage –

Video of speech – https://www.whitehouse.gov/the-press-office/2016/05/27/remarks-president-obama-and-prime-minister-abe-japan-hiroshima-peace

Text of speech – https://www.whitehouse.gov/the-press-office/2016/05/27/remarks-president-obama-and-prime-minister-abe-japan-hiroshima-peace

Widmer, Ted, Politico.  “History Department – How Obama Will Redefine Hiroshima, A president who’s never shied away from moral complexity steps onto his most challenging stage yet,” at http://www.politico.eu/article/how-barack-obama-will-redefine-hiroshima-japan-nuclear/

Hi,

CCNS and Nuclear Watch New Mexico teamed up to create these sample public comments that you can use to create your own comments to submit to the New Mexico Environment Department about their proposed 2016 Consent Order.  Sample public comments NMED d CO 5-27-16

We invite you to change up the comments, make additions, deletions and changes.  NMED likes to count comments that look the same as one comment regardless of how many people submitted them.

Please also email your comments to ccns@nuclearactive.org

Public comments about the New Mexico Environment Department’s draft 2016 Compliance Order on Consent, or the Cleanup Consent Order, for Los Alamos National Laboratory (LANL) are due to the Environment Department by 5 pm mountain daylight time on Tuesday, May 31^st, 2016.  4/1/16 Update (or see chart below)  CCNS and Nuclear Watch New Mexico have teamed up to provide sample public comments you can use.  They are available on the home pages of http://www.nuclearactive.org and http://www.nukewatch.org

Unfortunately, the draft Cleanup Consent Order creates more delays for cleaning up the legacy radioactive and hazardous waste dumped at LANL during the Cold War, which are above drinking water supplies for Pueblo de San Ildefonso and Los Alamos and Santa Fe Counties.  Over the past four and one-half years, the Environment Department granted LANL more than 150 extensions of time under the currently operating 2005 Consent Order.  Now the draft Order allows the Department of Energy (DOE), the owner of LANL, to opt out of cleanup because of “impracticability” or if it costs too much.  The Environment Department proposes to relinquish its regulatory power by allowing DOE to dictate the terms of cleanup, including the levels of pollutants allowed to remain in soil and water.

The draft order substantially changes the focus of cleanup from work at specific sites to a broad “campaign approach.”  NMED:DOE FrameworkAgreement for LANL Jan. 2011 and NMED Summary Framework Agreement 01-5-2012.  That approach failed when it was used to expedite shipping plutonium-contaminated waste from LANL to the Waste Isolation Pilot Plant (WIPP).  One or more of those drums exploded in the WIPP underground causing a more than two-year shutdown.  Over 600 potentially exploding drums are disposed of in the WIPP underground.

It also limits public participation in the review and comment about cleanup proposals and specifically removes all public participation in any modification of a finalized 2016 Cleanup Consent Order.

The draft Order does not include a final compliance date, which the 2005 Consent Order contains.  The legacy waste cleanup was supposed to be done by December 6, 2015 with the cleanup of the 63-acre Area G dump.  That did not happen.  For that reason and others, Nuclear Watch New Mexico filed a citizens’ suit under the hazardous waste laws against DOE and Los Alamos National Security, LLC (LANS), the management contractor, for missing the 2005 Consent Order cleanup deadlines.  Nuclear Watch is asking for a court order requiring DOE and LANS to come into compliance with the 2005 Consent Order “according to a reasonable but aggressive schedule.”  http://www.nukewatch.org/pressreleases/NW-PR-Lawsuit-5-17-16.pdf

Public comments are due to the Environment Department on Tuesday, May 31^th, 2016 by 5 pm mountain daylight time.  Please reference “Draft LANL Consent Order” and submit your comments to:

Kathryn Roberts, Director

Resource Protection Division

New Mexico Environment Department

P.O. Box 5469

Santa Fe, NM  87502-5469

By email to:  kathryn.roberts@state.nm.us

MAY 16, 2016 PRESS RELEASE:  FOR IMMEDIATE RELEASE

Contact: Rev. Holly Beaumont

505-660-5018

habeaumont@aol.com

RELIGIOUS LEADERS TELL OBAMA: KEEP YOUR PROMISE ON NUCLEAR DISARMAMENT

Over fifty religious leaders from across the United States including the three Roman Catholic Bishops in New Mexico, where at the Trinity Site in the Tularosa Basin the first denotation of an atomic bomb took place on July 16, 1945, have signed a letter to President Obama urging him to keep his promise to advance international nuclear disarmament before he leaves office.  a-Final-Letter-to-Obama-on-Disarmament-1

The letter comes as President Obama is preparing for a May 27 visit to Hiroshima in Japan, a city devastated by an atomic bomb on August 6, 1945. The letter reminds President Obama of the promise he made to the global community in his Prague speech in April of 2009 that one of his highest priorities would be to seek “the peace and security of a world without nuclear weapons.”

The urgency shared by these religious leaders is captured in a quote from the writer James Agee, who wrote in Time Magazine just days after the bombing of Hiroshima and Nagasaki, “…the demonstration of power against living creatures instead of dead matter created a bottomless wound in the living conscience of the race.”

The compelling words of Pope Francis are cited as well: “Nuclear deterrence and the threat of mutually assured destruction cannot be the basis for an ethics of fraternity and peaceful coexistence among peoples and states….Now is the time to counter the logic of fear with the ethic of responsibility, and so foster a climate of trust and sincere dialogue.”

The religious leaders who signed the letter call into question the movement underway to overhaul and modernize US nuclear forces at a cost of $1 trillion dollars over the next decade, asking how this plan can be squared with President Obama’s priority in his Prague speech to reduce the role of nuclear weapons in our national security strategy while urging other nations to do the same.

Signatories along with Catholic Bishops Most Reverend John C. Wester, Most Reverend Oscar Cantú, and Most Reverend James Wall include top leaders of the United Methodist Church, the Presbyterian Church (U.S.A.), the Christian Church (Disciples of Christ), the Church of the Brethren, the Central Conference of American Rabbis, Unitarian Universalists, the Alliance of Baptists, and the Presidents of Union Theological Seminary and Auburn Theological Seminary in New York and the President of the National Council of Churches.

Representing a wide spectrum of religious life in America, they are united in their commitment to prayer and study and specific actions that can treat “the bottomless wound” in the living conscience of the human race. One of the drafters of the letter, the Rev. James D. Brown of Santa Fe, NM, expresses his “gratitude for the remarkable support of the letter by diverse religious leaders at a time when American life is so often marred by divisiveness and sectarianism. This witness of solidarity is something we hope will inspire and encourage President Obama as he makes his way to Japan.”

###

To read the letter, a Final Letter to Obama on Disarmament-1

In a historic trip, President Obama will visit the Hiroshima Peace Memorial Park on Friday, May 27^th following the G-7 summit.  For the first visit by a U.S. siting president, Obama will visit the park located in the center of Hiroshima, which is dedicated to those harmed by the 1945 U.S. atomic bombing.  The President will  “offer a forward-looking vision focused on our shared future.”

Many non-governmental organizations, military and technical experts, and the public are urging Obama to announce his vision with four definitive steps towards “a world without nuclear weapons.”  They suggest Obama call for a United Nations resolution for a global moratorium on nuclear testing; reduce the U.S. nuclear arsenal from 1,550, as required by the New START Treaty with Russia, to about 1,000; and retire all 400 U.S. intercontinental ballistic missiles, or ICBMs.  Further, they suggest taking all ICBMs off alert status and cancelation of the $30 billion nuclear cruise missile and the $60 billion ICBM replacement.

Alliance for Nuclear Accountability 2016 “Trillion Dollar Trainwreck” report at http://static1.squarespace.com/static/52311edfe4b0830625de8366/t/570ff2bed210b8a7d566f530/1460662985134/trillion_trainwreck.pdf,

Beyond Nuclear at http://campaign.r20.constantcontact.com/render?m=1117799148730&ca=91cfd12f-97bc-4bd8-af56-4bc782e84258,

Democracy Now at http://www.democracynow.org/2016/5/11/obama_to_make_history_with_hiroshima,

Foreign Policy at http://foreignpolicy.com/2016/05/10/what-obama-really-needs-to-say-in-hiroshima/, and

Peace Action at https://peaceblog.wordpress.com/2016/05/10/peace-action-statement-obama-must-not-go-to-hiroshima-empty-handed/.

As Ben Rhodes, a deputy national security advisor, wrote, “The President and his team will make this visit knowing that the open recognition of history is essential to understanding our shared past, the forces that shape the world we live in today, and the future that we seek for our children and grandchildren.”  https://medium.com/@rhodes44/the-first-sitting-u-s-president-to-visit-hiroshima-1992461baf4c#.qk9bh42ua

“The open recognition of history is essential to understanding our shared past” is also one of the goals of the Tularosa Basin Downwinders Consortium.  For that reason and others, the Consortium invited President Obama to visit Tularosa, New Mexico and attend the Saturday, July 16^th commemoration events of the first atomic bomb explosion on July 16^th, 1945 at the Trinity Test Site.  July 16, 2016 event flyer and ACTION ALERT TBDC Jan 2016

The events include the Seventh Annual Candlelight Vigil that memorializes those who have lost their lives to cancer and honors those who are living with or who have survived cancer.  It will begin at 8 pm at the Tularosa Little League Field in West Tularosa.  Luminarias will be available beginning at 7 pm.

Tina Cordova, a co-founder of the Consortium, said, “By all means President Obama should visit Japan later this month and acknowledge the catastrophic results of the use of an atomic bomb.  However, he should also visit the American citizens who were the first victims of an atomic bomb as a result of the Trinity test.  We’ve been waiting 71 years for acknowledgement and help with the horrible health effects we’ve suffered ever since the bomb was tested at Trinity.  It’s high time for our government to right the wrong that was done to us.”

RELATED STORIES

1. Albuquerque Journal opinion editorial by Dr. Maureen Merritt, published Sun. 5/8/16 at http://www.abqjournal.com/770538/71-years-later-downwinders-are-still-ignored.html with seven comments

2. Al Jazeera 2/16/16 – “Inside America’s Atomic state: Residents of New Mexico reflect on the toxic legacy of life at the centre of the US nuclear complex at http://www.aljazeera.com/indepth/features/2016/01/america-atomic-state-160107102647937.html

3. Al Jazeera 7/15/15 – “The first victims of the bomb were American: The deadly legacy of nuclear tests in New Mexico continues to affect communities around the White Sands site,” at http://america.aljazeera.com/articles/2015/7/16/the-first-victims-of-the-bomb-were-american.html with 11 comments that include stories

4. Associated Press, “Residents Near Trinity Test Want Obama to Also Visit Village,” by Russell Contreras

a.      5/11/16 at http://www.kob.com/albuquerque-news/residents-near-trinity-test-want-obama-to-also-visit-village/4133898/#.Vz1GB9dcNP7

b.     5/11/16 at http://m.stamfordadvocate.com/news/article/Residents-near-Trinity-Test-want-Obama-to-also-7461279.php?cmpid=twitter-desktop#photo-10034528 with four photos

c.      5/11/16 at http://abcnews.go.com/Health/wireStory/residents-mexico-nuclear-test-site-seek-obama-visit-39043313

5. CCNS News Update – published on 5/6/16 at http://nuclearactive.org/%E2%80%A2dr-merritt-responds-to-los-alamos-historical-museum-trip-to-japan-to-obtain-perspective-about-1945-u-s-bombings/ and broadcast on KUNM-FM 89.9 on 5/7/16

6. Fox News Latino, aired on 5/12/16 at http://latino.foxnews.com/latino/health/2016/05/12/as-obama-plans-hiroshima-trip-nm-town-near-bomb-test-site-wants-visit-apology/?intcmp=bigtopteaser

7. KOB-TV Albuquerque, aired on 5/11/16 at http://www.kob.com/albuquerque-news/residents-near-trinity-test-want-obama-to-also-visit-village/4133898/#.Vz6WUNdcNP5

8. KRQE-TV Albuquerque, aired on 5/11/16 at http://krqe.com/2016/05/11/new-mexicans-call-on-president-to-recognize-how-atomic-bomb-test-hurt-community/

9. Las Cruces Sun News, published 5/14/16 at http://www.lcsun-news.com/story/opinion/2016/05/15/lab-team-visits-japan-ignores-bomb-victims/84290802/

10. New York Times, published on 5/11/16 at http://www.nytimes.com/aponline/2016/05/11/us/ap-us-obama-hiroshima-new-mexico.html?partner=IFTTT&_r=1

11. Ruidoso News – published on 5/12/16 at http://www.ruidosonews.com/story/opinion/editorials/2016/05/09/guest-editorial-downwinders—grievous-wrong-has-yet-righted/84145946/

12. Santa Fe New Mexican editorial “Our View” where the TBDC is mentioned – published 5/12/16 at http://www.santafenewmexican.com/opinion/editorials/our-view-at-hiroshima-time-to-reassess/article_ba06d63c-0f9a-57f1-8d82-ffe293cf0e5c.html#.VzXSZZpVi44.gmail
13. Socorro Chieftain – published on 5/12/16 at http://www.dchieftain.com/opinion/downwinders-still-ignored/article_d78fea30-17b5-11e6-bc34-ab05e28519fb.html

CCNS ACTION ALERT

At the request of CCNS and others, on Friday, May 13, 2016, the New Mexico Environment Department (NMED) granted an extension of time for the public to submit comments about the proposed draft Compliance Order on Consent (cleanup “Consent Order”) for Los Alamos National Laaboratory (LANL) to Tuesday, May 31, 2016 at 5 pm MDT.  Extension Public Notice No. 16-08 5-2016

Stay tuned here to download sample public comments you can use to compose your own comments on this important document.  Also, see the  CCNS News Update below about some of the concerns we have about the draft document.

Submit your comments to:

Kathryn Roberts, Director

Resource Protection Division

New Mexico Environment Department

P. O. Box 5469

Santa Fe, NM  87502-5469

OR at kathryn.roberts@state.nm.us and reference “draft LANL Consent Order”

The New Mexico Environment Department released a draft Compliance Order on Consent, or the Cleanup Consent Order, for Los Alamos National Laboratory (LANL) for a limited 45-day public review and comment period.  The hazardous waste regulations require at least a 60-day comment period for this type of document.

Currently, comments are due to the Environment Department by 5 pm mountain daylight time on Monday, May 16^th.  https://www.env.nm.gov/HWB/documents/PublicNotice__English.pdf and https://www.env.nm.gov/HWB/documents/Public_Notice_Spanish.pdf

Sample public comments that you can use are available at nuclearactive.org.

A few of the general purposes of the order are to “provide a framework for current and future actions to implement regulatory requirements;  … drive toward cost-effective work resulting in tangible, measurable environmental clean-up, … and provide for effective public participation.”  https://www.env.nm.gov/HWB/documents/ConsentOrder_Main_Document.pdf, see Sec. II.B, p. 4.  The Environment Department is failing at effective public participation by not providing at least a 60-day comment period.

The Environment Department states this draft will “supersede” the Consent Order signed on March 1, 2005 by representatives of the Department, the New Mexico Attorney General, the Department of Energy (DOE) and the LANL contractor, the Regents of the University of California.  https://www.env.nm.gov/HWB/documents/ConsentOrder_Main_Document.pdf, see Sec. II.A, p. 4.

This draft Consent Order is a complete replacement of the 2005 order, requiring additional time for public comments.

Back in the spring of 2002, when the first Consent Order was released for public comment, the Environment Department provided a 60-day public comment period, as required by regulations governing the handling and storage of hazardous waste.  But the Martinez Environment Department has cut that time to 45-days for a document that is over 200 pages long that essentially revokes the 2005 order.

The draft order substantially changes the focus of cleanup from individual work at specific sites to a broad “campaign approach” that was used to expedite shipping of plutonium-contaminated waste from LANL to the Waste Isolation Pilot Plant (WIPP).  One or more of those drums exploded in WIPP causing it to shutdown for over two years.  Over 600 potentially exploding drums are currently disposed of at WIPP.

On Wednesday, May 18^th, from 2 pm to 4 pm, Environment Department Secretary Ryan Flynn will discuss the public comments received at an afternoon meeting of the Northern New Mexico Citizens’ Advisory Board.  It will be held at the Cities of Gold Conference Center in Pojoaque.  http://energy.gov/em/nnmcab/downloads/nmed-revised-lanl-consent-order-draft-march-2016  It is unclear whether the Department will provide written responses to the public comments as has been done in the past with previous draft Consent Orders.

Your comments should be submitted to Kathryn Roberts, Director of the Resource Protection Division of the Environment Department at Kathryn.roberts@state.nm.us.

To view the proposed draft 2016 Consent Order with its appendices, go to:  https://www.env.nm.gov/HWB/documents/ConsentOrder_Main_Document.pdf

Appendix A – Solid Waste Management Unit/Area of Concern List – https://www.env.nm.gov/HWB/documents/APPENDIXA_SWMUAOCStatusList.pdf

Appendix B – Milestones and Targets – https://www.env.nm.gov/HWB/documents/APPENDIXA_SWMUAOCStatusList.pdf

Appendix C – Future Campaigns – https://www.env.nm.gov/HWB/documents/APPENDIXC_Campaigns.pdf

Appendix D – Document Review/Comment and Revision Schedule – https://www.env.nm.gov/HWB/documents/APPENDIXD-DocumentReview-CommentandRevisionsSchedule.pdf

Appendix E – Example Document Templates – https://www.env.nm.gov/HWB/documents/APPENDIXD-DocumentReview-CommentandRevisionsSchedule.pdf

Appendix F – Sampling/Analytical/Field Method Regulatory Guidance – https://www.env.nm.gov/HWB/documents/AppendixF-SamplingAnalyticalFieldMethodRegGuidance.pdf

After reading a series of blog posts by the three-member Los Alamos Historical Museum delegation about their recent trip to Japan to gain perspective about the August 1945 U.S. atomic bombings, Dr. Maureen Merritt wrote in an opinion editorial that her “first reaction was anger. “  She is angry that the Museum team could “spend tens of thousands of dollars to travel to Japan to find out how the Japanese feel about us bombing Hiroshima and Nagasaki 71 years ago, but can’t even mention the 1945 atomic blast at the Trinity site, or how our own New Mexico ‘downwinders’ feel about that fateful event.”

In the works for two years, the trip will result in an exhibit opening in December.  The National Trust for Historic Preservation gave the Museum a $10,000 grant.  The New Mexico Japanese Citizens League supports the project.  Judith Stauber, director of the Museum, said the exhibit would also explore the World War II internment camps established in New Mexico for Japanese Americans and German and Italian prisoners of war.

Nevertheless, the exhibit will not explore what happened to the victims of the first U.S. atomic bombing on July 16, 1945 at the Trinity Test Site in south central New Mexico.  The morbidity and mortality statistics for many of the counties surrounding Trinity are higher than those in the rest of the U.S.  Dr. Merritt writes that nuclear bomb survivors “living in and around the Tularosa basin feel much the same way the Japanese survivors do.”

Through Dr. Merritt’s editorial, the Tularosa Basin Downwinders Consortium invites the Los Alamos Historical Museum to learn about the first atomic blast by visiting with the Trinity downwinders, their children, grandchildren and great-grandchildren.  They will learn of the downwinders’ tremendous suffering from being bombed by their own country by an atomic weapon created at Los Alamos National Laboratory.

Merritt continues, “New Mexico‘s downwinders’ have been written out of the history books, including Los Alamos National Laboratory’s museums and carefully crafted stories of the Manhattan Project.  As a physician advocate and active member of Physicians for Social Responsibility [and a core member of the Tularosa Basin Downwinders Consortium], I am angry because a grievous wrong has yet to be righted.  The people of New Mexico, the United States, and indeed the world including Japan, deserve the full truth.  [The Tularosa Basin Downwinders Consortium] demand[s] equal time.  And that time is now.  71 years later.”

Museum registrar, Stephanie Yeamans, and Los Alamos High School student intern, Kallie Funk, joined Stauber on the trip. To read Dr. Merritt’s opinion editorial and to obtain the links to the Los Alamos Historical Museum blog posts, click here…Trinity op ed by Dr. Merritt TBDC 4.25.2016-2