WIPP Plutonium Disposition Scoping Comments

Hits: 1781

The NRC Required Canistered Spent Nuclear Fuel To Be Retrievable– But It Isn’t

Hits: 1872

Space Command

NEW MEXICO SPACE WARS

An ABQ Journal editorial (Nov. 28) describes the proposal to bring New Mexico the Space Command, Space Force project in glowing terms. There is no consideration of possible damage to public health and environmental consequences.  New Mexico’s politicians should not hand the military carte blanche trust for the startup of another project we know nothing about -- based alone on the promise of money and jobs.

The ABQ Journal editorial ignores the global threat from space conflicts and the record of environmental contamination and disease from military bases and two national laboratories.  While considering what New Mexico has to offer the Department of Defense, the Journal and politicians don’t consider what damage could come to New Mexico. Moreover, do New Mexicans want to be brought into the destructive aspects of military conflict in space like we were dragged into nuclear weapons development and tragic use?

The question is whether the Space Command project would be primarily administrative or would involve construction of missile and satellite technology and launches from New Mexico.  An Environmental Impact Statement should be first presented laying out potential adverse consequences of Space Command/Force plans for New Mexico. 

The Space Command/Force claims the right to dominance and assumes military conflict in space.  U.S. buildup of space weaponry and logistics accelerates the arms race and violates treaties for peaceful use of space. A violent conflict increasing the already enormous amount of space junk could irreparably damage modern communication systems. 

The setup of large aerospace corporations in New Mexico seeking a piece of the action could bring a lot of infrastructure challenges for our environment, housing, roads, schools, hospitals and scarce water supplies. The use of missile fuel may add to the perchlorate contamination of groundwater that is already wide spread at Air Force bases such as at Kirtland, Holloman, Cannon and White Sands.  Would there be production of space batteries using extremely toxic Plutonium 238?

The many spaceports around the country launching tens of thousands of mini-satellites for Elon Musk, Jeff Bezos and others will punch further holes in the ozone layer affecting atmospheric circulation in the Southern Hemisphere.

New Mexico is already damaged by failure to clean up radioactive and toxic laboratory and military waste.  Receiving more harmful impacts from Space Command/Force should be avoided.

The question remains -- is the public to be included in the decision to accept the project or are we to be bamboozled into believing this project will cause no harm but bring untold benefits?

 

Why are these military/industrial projects being proposed for New Mexico during the Coronavirus Pandemic:More nuclear weapons plutonium pit production? Storage of the entire nation’s nuclear reactor waste?  Doubling WIPP?  Space Command/Space Force?

The dropping of the first atomic bomb at Alamogordo with no warning to the public brought generational cancer and disease without compensation. 

Huge piles of uranium tailings and the 1100 ton Puerco River radioactive spill poisonsNative Americans, their children and animals. 

Kirtland AFB dumped an estimated 6 to24 million gallons of jet fuel and aviation gas into Albuquerque’s drinking water aquifer.  A toxic carcinogen, Ethylene Dibromide (EDB) is present in the aquifer. 

Holloman AFB contaminated groundwater with a fire fighting chemical (PFAHs) at levels 18,000 times higher than federal safety limits.  The NM Department of Health recommends not drinking, swimming in or even touching the foam from water in Lake Holloman. 

Cannon AFB sued againstNM Environment Department permit conditions to protect dairies and drinking water from high PFAH contamination. 

Los Alamos National Laboratory:

• Plans to produce more plutonium pits for nuclear weapons
• spread radioactive wasteand hexavalent chromium into the aquifer;
• has plans to release massive amounts of tritium into the neighboring tribal airspace;
• fifteen lab workers were recently exposed to plutonium;

The WIPP salt mine for the military’s transuranic radioactive waste:

• Had a $2,000,000,000shutdown from a fire and explosion
• released contamination to the surface and overexposed workers.
• The Department of Energy wants to double the size of WIPP despite promises to close in 2024.

 

The Nuclear Regulatory Commission wants to approve a plan for “interim”storage ofall the nation’s high level radioactive nuclear reactor waste at the Holtec site in southern New Mexico:

• Leakage to the aquifer,
• Interference with Permian Basin petroleum, potash and agricultural production.
• Because no repackaging facility nordeep geologic repository exists the waste would never leave.

 

Sandia National Laboratories has yet to excavate and remove the radioactive waste, toxic chemicals and heavy metals in its Mixed Waste Landfill:

• High level waste from the military, rocket fuel experiments and nuclear reactor meltdown experiments is mixed with metallic sodium that could potentially explode as happened at Beatty Nevada in 2015.
• Carcinogenic solvents are leaking from the unlined dump to Albuquerque’s drinking water aquifer.

 

 

Hits: 4590

Los Alamos National Laboratory Application for Venting of Flanged Tritium Waste Containers

 

October 20, 2020

By email:  This email address is being protected from spambots. You need JavaScript enabled to view it.

Mr. Kevin Pierard, Chief

Hazardous Waste Bureau

New Mexico Environment Department

2905 Rodeo Park Drive East, Building 1

Santa Fe, NM  87505

 

Subject:  Los Alamos National Laboratory Application for Venting of Flanged Tritium Waste Containers (FTWCs) at TA-54

Dear Mr. Pierard,

On March 31, Citizen Action NM and several other group and private persons made comments regarding the proposed Tritium release from Los Alamos National Laboratories.  Our concerns remain the same for this massive release of a radioactive release into the air space of surrounding communities. The comments of March 21, 2020 are herein incorporated by reference thereto.  (Attached below). 

In addition, we would submit that the planned release:

1.      Constitutes a public and private nuisance for members of the surrounding communities especially Pueblo and land-based Peoples who live downwind and downstream from Los Alamos National Laboratory (LANL).  A federal government action can be considered a public nuisance.  See,  Michigan v. Grand Traverse Band of Ottawa & Chippewa Indians (7th Cir. July 14, 2014),  The proposed action will expose persons, crops, animals, air, soil and water to a cancer causing, mutagenic radionuclide.  

2.      Deprives the surrounding communities of Equal Protection of the Constitution of the United States by imposing a radioactive hazard upon the foregoing communities that are minority people of color and of low economic status.

3.      Exceedance of the Clean Air standard of 10 mrem per year exposure.

 

The New Mexico Environment Department has the authority under the omnibus clause of the Resources Conservation and Recovery Act (as incorporated by NMAC 20.4.1.900 ADOPTION OF 40 CFR PART 270) to deny the permit for LANL’s release of tritium:

40 CFR § 270.32 Establishing permit conditions.

(b)

 (2) Each permit issued under section 3005 of this act shall contain terms and conditions as the Administrator or State Director determines necessary to protect human health and the environment.

74-4-4.2. Permits; issuance; denial; modification; suspension; revocation.

C.     The department shall provide timely review on all permit applications.  Upon a determination by the secretary that the applicant has met the requirements adopted pursuant to Section 74-4-4 NMSA 1978, the secretary may issue a permit or a permit subject to any conditions necessary to protect human health and the environment for the facility.  

NMED should exercise its authority to protect the people of New Mexico by denial of LANL’s Tritium release.  Alternatives are available to the release that will not not endanger an inestimable number of persons. 

Thank you for your consideration.

David McCoy, Executive Director

Citizen Action New Mexico

Albuquerque, NM

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

With Attachment

Attachment

Citizen Action New Mexico, Concerned Citizens for Nuclear Safety, and other NGOs and individuals

 

March 31, 2020

By email:  This email address is being protected from spambots. You need JavaScript enabled to view it.

Mr. Kevin Pierard, Chief

Hazardous Waste Bureau

New Mexico Environment Department

2905 Rodeo Park Drive East, Building 1

Santa Fe, NM  87505

 

Re:       Deny Withdrawal and Resubmittal of a Temporary Authorization Request for Waste Treatment, Storage, and Repackaging, Los Alamos National Laboratory Hazardous Waste Facility Permit, EPA ID No. NM0890010515

 

Dear Mr. Pierard:

 

The undersigned non-governmental organizations and individuals request a formal comment period and public hearing about the above-referenced March 9, 2020 “Request” application.  Use of the word “Request” is inappropriate for what actually minimally constitutes a Class 2 Permit Modification Request to the Los Alamos National Laboratory (LANL) Hazardous Waste Permit.  Several of the undersigned non-governmental organizations were parties to the public hearing process for the 2010 LANL Hazardous Waste Permit (HWP) renewal. 

 

INTRODUCTION

 

Given the growing public concern about the proposed venting of Tritium into the open air, a Class 3 Permit Modification Request would be more appropriate.  The purpose of various levels of modification requests is to “expand public notification and participation opportunities.” 53 Federal Register 37912 at 37913 (September 28, 1988).  That is why it should be considered as a permit modification requiring notice and opportunity for comment, which the Request does not mention.

 

Furthermore, the above Request proposes plans inconsistent with plans previously submitted to the Environmental Protection Agency (EPA) under the Clean Air Act (CAA) radioactive emissions standards.  This Request plans to vent the headspace gas of four containers, called Flanged Tritium Waste Containers (FTWCs), which are located at TA-54 Area G, Building 1028.  It is unclear whether treatment is allowed in Building 1028.

Further, the presence of “lead by-product from fired explosive actuators, or squibs,” which brings the proposed releases under the Hazardous Waste Permit, requires action by the Department.[1]  We question why fired explosive actuators were stored in these containers in the first place. 

The Request also does not specify or provide reference for the public as to what the expected release(s) from venting radioactive Tritium would be prior to the transport of the FWTCs to the Weapons Engineering Tritium Facility (WETF) at Technical Area 16 (TA-16). 

When LANL issues a notice that can have health consequences for the off-site public, it is reasonable to expect a description of the potential amount of radiation release and health consequences rather than wordsmithing a modification as a “Request.”  LANL’s CAA submittal estimates a maximum release of 20.2 millirem a year (mrem/yr.) – twice the 10-mrem/yr. CAA standard.[2]

Untimely Request.  Critically, this Request for massive venting of Tritium comes at a time of great concern for the pandemic spread of the Corona virus and springtime gathering and planting.  The Request does not describe a definitive amount of Tritium is anticipated being released from LANL.  The range is between 6 mrem/yr. to 20.2 mrem/yr. 

No Alternatives Discussed.  The Request barely touches upon continuing safe storage to allow Tritium to decay without potential health consequences for the public.  Further, safe storage is not described as an alternative that may be viable and more protective of public health and safety.  Potential health consequences for the public are not evaluated. 

Deny the Request.  We urge you to deny the Request and allow the Tritium to decay into harmless helium, which it does at a rate of six percent (6%) per year.  Given that the FTWCs were loaded in 2007 – thirteen years ago – it is estimated that 78 percent (13 years x 6%/yr. = 78%) of the Tritium has already disintegrated to helium – leaving an estimated 22% in the containers.  The Request does not address a safe storage alternative.

Unspecific and Delayed Monitoring Plan.  The monitoring of the Tritium release(s) would apparently take place after the release(s) and at other locations:

 

Note that due to the potential hazardous conditions of the work site, the venting and emissions monitoring systems will be designed using best practices, but commissioning tests on the system may be performed at a different LANL location or at Building 1028 after the FTWC mitigation is complete.[3]  [Emphasis added.]

 

Post-operational air monitoring is unacceptable.  The public needs to know the amount of the release(s) from each container in real-time.

 

The proposal as it stands could release an enormous amount of Tritium of 114,683 Curies into the public airspace allowing the maximum uncontrolled dose from this venting operation to be 20.2 mrem/yr. with no information as to the number of years.  Further, the amount of reduction that would occur by the use of a “getter bed” is not known.

 

Since a getter bed is not a recognized emissions control system in 40 CFR 61 Appendix D, no official "controlled" emissions estimate and dose calculation is presented here. The controlled emissions estimate will be the same as uncontrolled emissions estimate …[4]

 

In the May 17, 2019 submittal to EPA’s George Brozowski, Regional Health Physicists/Radon Coordinator, LANL stated they would remove “specific reference to a ‘getter bed’”

 

as an emission control system and an associated removal efficiency.  While the project will use an emissions control system, the exact equipment to be used is still being determined.  The project will use either a getter bed or molecular sieve system.[5]

 

Nevertheless, LANL stated they would use “either a getter bed or molecular sieve system.”  The two statements obviously conflict with one another.  It is unknown what the emission control system will be for the release(s) that has the potential to exceed the federal CAA standards.    

 

No formal Emissions Management Plan.  The granting of this Request would not have an emissions management plan and would apparently be followed by other venting operations at LANL reported after the fact:

 

Due to the very short-term nature of this project, a formal Emissions Management Plan will not be developed per usual LANL procedure. Rather, upon completion of the venting activities, RadNESHAP personnel will evaluate effects of the venting and off-site dose consequence on other LANL operations. We will communicate the results of the venting operations to you either as part of the Notice of Actual Startup or via telephone and email.[6]

 

Because there are no plans for a formal Emissions Management Plan, the public will not have real-time access to the amount of Tritium and other radionuclides released into the open air. 

 

Safe Storage Alternative.  Although “unsafe conditions” are cited for the continued storage of the FTWCs, ostensibly due to the presence of hydrogen gas, the expected time that the contents of the FTWCs could remain contained or be enclosed in some additional containment is not discussed.  The improvement of efficiency for a “getter bed” to prevent the release of Tritium to public air space and to achieve a calculated amount is not discussed. 

 

Public comment period and hearing.  A public comment period and public hearing should be provided on the Request.  The New Mexico Environment Department must deny the Request and require DOE/LANL to submit a Class 3 permit modification request to include Area G, Building 1028 and the proposed plan. 

 

CONCLUSION

 

For the reasons detailed above, we urge you to deny the Request.   Please provide an electronic response to all of the undersigned – all of which are opposed to LANL plans to begin venting on Friday, April 17, 2020. 

 

Respectfully, 

 

David McCoy, Executive Director

Citizen Action New Mexico

Albuquerque, NM

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Joni Arends, Co-founder and Executive Director

Concerned Citizens for Nuclear Safety

Santa Fe, NM

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Individuals:

Dr. Eric Nuttall, Ph.D., Emeritus, Chemical and Nuclear Engineering

Albuquerque, NM

This email address is being protected from spambots. You need JavaScript enabled to view it.  

 

Samuel Weisberg, CPO

Albuquerque, NM

This email address is being protected from spambots. You need JavaScript enabled to view it.  

 

cc:  Mr. George P. Brozowski at This email address is being protected from spambots. You need JavaScript enabled to view it.

 

 

 

 

[1]  LANL Letter and Request to Mr. Kevin Pierard, Chief, Hazardous Waste Bureau, New Mexico Environment Department, EPC-DO: 20-074, LA-UR-20-22103, March 09, 2020.  Request, p. 6. 

[2]  LANL Letter and Application to Mr. George P. Brozowski, Regional Health Physicist/Radon Coordinator, Multimedia Division, U.S. EPA, ESHID-603412, EPC-DO:  19-137, LA-UR-18-26283, May 17, 2019. Application, p. 9.  https://permalink.lanl.gov/object/tr?what=info:lanl-repo/eprr/ESHID-603412

[3]  Id., Application, p. 8.

[4] Id., Application, p. 10.

[5] Id., Letter, p. 2.

[6] Id.

 

 

Hits: 1816