Citizen Action Notice of IntentBEFORE THE ENVIRONMENT DEPARTMENT
CITIZEN ACTION Citizen Action New Mexico hereby gives notice that it intends to present technical testimony at the Public Hearing scheduled to begin on December 2, 2004, regarding the draft permit modification for the Mixed Waste Landfill, a radioactive and hazardous waste site at Sandia National Laboratories, New Mexico identified in New Mexico Environment Department (NMED) Public Notice No. 04-11 on August 11, 2004. Citizen Action will be represented by Sue Dayton, Director, Citizen Action, P.O. BOX 262, Sandia Park, New Mexico 87047 (505) 280-1844 or sdayton@swcp.com. Fax: (505) 281-7321. Citizen Action opposes the draft permit modification for the Mixed Waste Landfill as proposed by Sandia National Laboratories. Citizen Action supports a permit modification that requires complete excavation of the Mixed Waste Landfill with above ground storage of the waste at a properly engineered facility. Citizen Action New Mexico is a coalition of 12 distinct groups that include non-profit organizations, neighborhood associations, and other groups. The organization was formed in 1999 to advocate for excavation and clean up of the Mixed Waste Landfill. Citizen Action New Mexico intends to present three technical witnesses: Dr. Marvin Resnikoff, Radioactive Waste Management Associates; Erik Ringelberg, Upstream Technologies, Inc.; and W. Paul Robinson, Southwest Research and Information Center. Summaries of the testimonies to be presented by each of these witnesses with their respective resumes are attached to this Notice. Citizen Action New Mexico and its members also intend to present non-technical testimony including testimony from members of the public who live in the Albuquerque area adjacent to the Mixed Waste Landfill. Technical testimony: Marvin Resnikoff I. Party presenting technical testimony: Citizen Action and its members. II. Name and qualifications of the witness to be presented: Marvin Resnikoff, Ph.D. Dr. Resnikoff's qualifications are set forth in his attached resume. III. Summary of anticipated testimony: A) A closure plan, not a corrective measures study, should be required, since the mixed waste landfill is closed and will not be reopened. Other waste landfills at Sandia have had closure plans. B) The risk assessment in the CMS is inadequate. It fails to consider a sufficiently long-term scenario. It does not consider all hazardous and radioactive substances present at the landfill. It also does not consider all pathways through which contaminants might reach receptors. C) Groundwater has been found to be contaminated underneath the MWL. Further groundwater contamination is a strong possibility. Groundwater contamination has occurred at other places within Sandia as well as in other locations with similarly deep aquifers and dry climates. D) Complete waste characterization is absolutely necessary to complete an adequate, accurate risk assessment. The waste characterization presented by Sandia/DOE is incomplete and does not correspond to the measured gamma readings at the site as well as FOIA documents obtained by Citizen Action. E) The preferred corrective measure in the CMS, the Vegetation Layer, is an inappropriate corrective action for the MWL. It will allow migration of waste constituents and exposure of the local population. Risks from the Vegetation Layer will be much greater than was determined by the risk assessment in the CMS. The Vegetation Layer will require a much greater amount of maintenance than the cost assessment of the CMS includes. These problems would also exist with several other CMS alternatives. F) Risks to human health from the MWL can only be reduced to acceptable levels over the long term through immediate or eventual excavation of the most dangerous wastes. If the waste is to be excavated in the future, the landfill should be temporarily covered in a way that will not preclude excavation. The costs of future excavation will be significantly less than the CMS calculated. G) Implementation of the Vegetation Layer as recommended by the CMS will constitute a violation of federal regulations.
References/exhibits: Baskaran, M., "Mixed Waste Landfill Review", Department of Geology, Wayne State University, Detroit, MI 48202, July 5, 2000. Bunnenberg and Taeshner, 2000. "Soil Fauna Transport Versus Radionuclide Migration. " Radiation Protection Dosimetry. Vol. 92(1-3): pp. 35-38 City of Albuquerque Planning Department, "Albuquerque/Bernalillo County Comprehensive Plan", as amended January 2002, Figure 20. Committee to Bridge the Gap. "Contamination at the Beatty, Nevada, Radioactive Waste Disposal Facility." Los Angeles, CA, 1996, p.5 Connell, Sean D. "Geology, Groundwater, and Geologic Hazards in the Albuquerque Basin, New Mexico." American Geological Institute Publications. Accessed online at www.agiweb.org/environment/publications/ mapping/graphics/newmexico.pdf, February 2004. Dayton, Susan, for Citizen Action. "Comments: Interim WERC Independent Technical Peer Review of US/DOE SNL Draft Corrective Measures Study Nov. 2002" FOIA document #22, Feb. 20, 1997. Memo from Jerry Peace/MS-1148 to Mark Jackson, MS-0184 DOE/KAO and John Gould, MS-0184 DOE/KAO. Subject: MWL Classified Area Pit Contents. FOIA document # 112, Interview with Donna Hartzel to "G.L., 1989. As cited on Citizen Action website at http://www.radfreenm.org/pages/whatwhen.htm, accessed March 2004. FOIA document #114. Memo from M. Goodrich to A. Parsons, Sept 13, 1989. FOIA documents # 115 and #166. ER Program/Site Health and Safety Plan, 1992 Hakonson, Tom, Ph.D., Environmental Evaluation Services, LLC. "Review of Sandia National Laboratories/New Mexico Evapotranspiration Cap Closure Plans for the Mixed Waste Landfill." February, 2002. Irwin, Michael J., and Lee A. Brouillard, "Real-Time Monitoring for Performance Assessment, Corrective Action Management Unit Containment Cell, Sandia National Laboratories, New Mexico".
Kalb et al., "Accelerated Site Technology Deployment Cost and Performance Report: Comparability of ISOCS Instrument In Radionuclide Characterization at Brookhaven National Laboratory." March, 2001 New Mexico Environment Department, "Nuclear Fuel Assessment Project Summary, Sandia National Laboratories' Mixed Waste Landfill", August 2003 NMED, "Notice of Intent to Issue a Draft Order to Sandia National Laboratories, EPA 5890110518, 9/2/2002 NMED, "Response to Citizen Action's Comments on Sandia National Laboratories' Mixed Waste Landfill Corrective Measures Study Work Plan", EPA 5890000518-1, p. 21. Nuttall, Eric, Ph.D., "Sandia Mixed Waste Landfill/Nuclear Spent Fuel Disposal". 2003 Oztunali, OI and GW roles, "Update of Part 61, Impacts Analysis Methodology," NUREG/CR-4370, p. A-19. Resnikoff, Marvin. "Comments on the draft Corrective Measures Study Workplan for the Mixed Waste Landfill, December 19, 2001, prepared by Sandia National Laboratories." Radioactive Waste Management Associates, September 20, 2002. Robinson, Paul. "Review of 'Sandia National Laboratories, New Mexico Mixed Waste Landfill Corrective Measure Study Draft Work Plan of December 19, 2001" Submitted on behalf of Citizen Action. Robinson, Paul. Summary of Data Identifying Organic Compounds Detected in Groundwater Beneath the Mixed Waste Landfill, Sandia National Laboratories, Albuquerque, NM. January 2001. SNL/NM. "Final SNL/NM Site-Wide Environmental Impact Statement, Volume 1", October, 1999. DOE/EIS-0281. Sandia National Laboratories, "Report of the Mixed Waste Landfill Phase 2 RCRA Facility Investigation." September, 1996. Sandia National Laboratories, "Responses to New Mexico Environment Department Notice of Deficiency for the Mixed Waste Landfill: Corrective Measures Study Report, May 2003." EPA ID# 5890110518, HWB-SNL-01-025. Sandia National Laboratories, Environmental Restoration Project DOE/SNL/NM Responses to NMED October 30 1998, NOD for "Report of Mixed Waste Landfill Phase 2 RCRA Facility Investigation, Sandia National Laboratories, Albuquerque, NM, US Department of Energy, Attachment 9, June 10, 1999 (update), Sandia National Laboratories/New Mexico, U.S. Department of Energy. "Mixed Waste Landfill Corrective Measures Study Final Report." May 2003. US Environmental Protection Agency, "Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part A)," EPA/540/1-89/002, December 1989, Sect. 4.2. United States Geological Survey, United States Department of the Interior. "Land Subsidence in the United States". Circular number 1182. Devin Galloway et al., editors. 1999. United States Geological Survey, Probabilistic Hazard Lookup by Zip code, 1996. http://eqint.cr.usgs.gov/eq/cgi-bin/zipcode.cgi. Zip code 87101. accessed March 2004. USGS Earthquake Hazards Program, "Earthquake History of New Mexico", http://neic.usgs.gov/neis/states/new_mexico/new_mexico_history.html, accessed March 2004 WERC, "Final WERC Report Independent Technical Peer Review of the U.S. Department of Energy Sandia National Laboratories' "Working Draft" Corrective Measures Study", January 31, 2003 www.city-data.com, "Average weather in Albuquerque, New Mexico." Accessed March, 2004
V. List of exhibits to be used: Dr. Resnikoff may use documents from the Corrective Measures Study and earlier Sandia reports. He may also present relevant provisions of state and federal regulations as well as figures related to his review of the available related documents.
Resume of Marvin Resnikoff, Ph.D. Dr. Marvin Resnikoff is Senior Associate at Radioactive Waste Management Associates and is an international consultant on radioactive waste management issues. He is Principal Manager at Associates and is Project Director for dose reconstruction and risk assessment studies of radioactive waste facilities and transportation of radioactive materials. Dr. Resnikoff has concentrated exclusively on radioactive waste issues since 1974. He has conducted studies on the remediation and closure of the leaking Maxey Flats, Kentucky radioactive landfill for Maxey Flats Concerned Citizens, Inc. and of the leaking uranium basin on the NMI/Starmet site in Concord, Massachusetts under grants from the Environmental Protection Agency. He also conducted studies of the Wayne and Maywood, New Jersey thorium Superfund sites and proposed low-level radioactive waste facilities at Martinsville (Illinois), Boyd County (Nebraska), Wake County (North Carolina), Ward Valley (California) and Hudspeth County (Texas). He investigated phosphogypsum plants in Florida, Texas and Alberta, Canada, and served as an expert witness in a personal injury case involving a Texas phosphogypsum worker. He is also serving as an expert witness for CRPE, a public interest groups, regarding the proposed expansion of the Buttonwillow, California NORM landfill. He has conducted several studies of transportation accident risks and probabilities for the State of Nevada and several Nevada counties and dose reconstruction studies of oil pipe cleaners in Mississippi and Louisiana, residents of Canon City, Colorado near a former uranium mill, residents of West Chicago, Illinois near a former thorium processing plant, and residents and former workers at a thorium processing facility in Maywood, New Jersey. In West Chicago he calculated exposures and risks due to thorium contamination and served as an expert witness for plaintiffs A Muzzey, S Bryan, D Schroeder and assisted counsel for plaintiffs KL West and KA West. He is presently serving as an expert witness for plaintiffs in Karnes County, Texas, Milan, NM and Uravan, CO, who were exposed to radioactivity from uranium mining and milling activities and for former workers at the ITCO oil pipe cleaning yard in Louisiana. He also evaluated radiation exposures and risks in worker compensation cases involving G Boeni and M Talitsch, former workers at Maywood Chemical Works thorium processing plant. In June 2000, he was appointed to a Blue Ribbon Panel on Alternatives to Incineration by DOE Secretary Bill Richardson. In March 2004, Dr. Resnikoff was project director and co-author of a study of groundwater contamination at DOE facilities, Danger Lurks Below. In February 1976, assisted by four engineering students at State University of New York at Buffalo, Dr. Resnikoff authored a paper that, according to Science, changed the direction of power reactor decommissioning in the United States. His paper showed that power reactors could not be entombed for long enough periods to allow the radioactivity to decay to safe enough levels for unrestricted release. The presence of long-lived radionuclides meant that large volumes of decommissioning waste would still have to go to low-level or high-level waste disposal facilities. He assisted public interest groups on the decommissioning of the Yankee-Rowe, Diablo Canyon, Big Rock Point and Haddam Neck reactors. Under a contract with the State of Utah, Dr. Resnikoff is a technical consultant to DEQ on the proposed dry cask storage facility for high-level waste at Skull Valley, Utah and proposed storage/transportation casks. He is assisting the State on licensing proceedings before the Nuclear Regulatory Commission. In addition, at hearings before state commissions and in federal court, he has investigated proposed dry storage facilities at the Point Beach (WI), Prairie Island (MN), Palisades (MI) and Maine Yankee reactors. He has also prepared studies on transportation risks and consequences for the State of Nevada and Clark and White Pine Counties. In Canada, he conducted studies on behalf of the Coalition of Environmental Groups and Northwatch for hearings before the Ontario Environmental Assessment Board on issues involving radioactive waste in the nuclear fuel cycle and Elliot Lake tailings and the Interchurch Uranium Coalition in Environmental Impact Statement hearings before a Federal panel regarding the environmental impact of uranium mining in Northern Saskatchewan. He also worked on behalf of the Morningside Heights Consortium regarding radium-contaminated soil in Malvern and on behalf of Northwatch regarding decommissioning the Elliot Lake tailings area before a FEARO panel. He conducted a study for Concerned Citizens of Manitoba regarding transportation of irradiated fuel to a Canadian high-level waste repository. He was formerly Research Director of the Radioactive Waste Campaign, a public interest organization conducting research and public education on the radioactive waste issue. His duties with the Campaign included directing the research program on low-level commercial and military waste and irradiated nuclear fuel transportation, writing articles, fact sheets and reports, formulating policy and networking with numerous environmental and public interest organizations and the media. He is author of the Campaign's book on "low-level" waste, Living Without Landfills, and co-author of the Campaign's book, Deadly Defense, A Citizen Guide to Military Landfills. Between 1981 and 1983, Dr. Resnikoff was a Project Director at the Council on Economic Priorities, a New York-based non-profit research organization, where he authored the 390-page study, The Next Nuclear Gamble, Transportation and Storage of Nuclear Waste. The CEP study details the hazard of transporting irradiated nuclear fuel and outlines safer options. Dr. Resnikoff is an international expert in nuclear waste management, and has testified often before State Legislatures and the U.S. Congress. He has extensively investigated the safety of the West Valley, New York and Barnwell, South Carolina nuclear fuel reprocessing facilities. His paper on reprocessing economics (Environment, July/August, 1975) was the first to show the marginal economics of recycling plutonium. He completed a more detailed study on the same subject for the Environmental Protection Agency, "Cost/Benefits of U/Pu Recycle," in 1983. His paper on decommissioning nuclear reactors (Environment, December, 1976) was the first to show that reactors would remain radioactive for hundreds of thousands of years. In January 2004, a book on groundwater contamination at DOE facilities he investigated will be released by ANA, a consortium of public interest groups residing near DOE facilities. Dr. Resnikoff has prepared reports on incineration of radioactive materials, transportation of irradiated fuel and plutonium, reprocessing, and management of low-level radioactive waste. He has served as an expert witness in state and federal court cases and agency proceedings. He has served as a consultant to the State of Kansas on low-level waste management, to the Town of Wayne, New Jersey, in reviewing the cleanup of a local thorium waste dump, to WARD on disposal of radium wastes in Vernon, New Jersey, to the Southwest Research and Information Center and New Mexico Attorney General on shipments of plutonium-contaminated waste to the WIPP facility in New Mexico and the State of Utah on nuclear fuel transport. He has served as a consultant to the New York Attorney General on air shipments of plutonium through New York's Kennedy Airport, and transport of irradiated fuel through New York City, and to the Illinois Attorney General on the expansion of the spent fuel pools at the Morris Operation and the Zion reactor, to the Idaho Attorney General on the transportation of irradiated submarine fuel to the INEL facility in Idaho and to the Alaska Attorney General on shipments of plutonium through Alaska. He was an invited speaker at the 1976 Canadian meeting of the American Nuclear Society to discuss the risk of transporting plutonium by air. As part of an international team of experts for the State of Lower Saxony, the Gorleben International Review, he reviewed the plans of the nuclear industry to locate a reprocessing and waste disposal operation at Gorleben, West Germany. He presented evidence at the Sizewell B Inquiry on behalf of the Town and Country Planning Association (England) on transporting nuclear fuel through London. In July and August 1989, he was an invited guest of Japanese public interest groups, Fishermen's Cooperatives and the Japanese Congress Against A- and H- Bombs (Gensuikin). Between 1974 and 1981, he was a lecturer at Rachel Carson College, an undergraduate environmental studies division of the State University of New York at Buffalo, where he taught energy and environmental courses. The years 1975-1977 he also worked for the New York Public Interest Group (NYPIRG). In 1973, Dr. Resnikoff was a Fulbright lecturer in particle physics at the Universidad de Chile in Santiago, Chile. From 1967 to 1973, he was an Assistant Professor of Physics at the State University of New York at Buffalo. He has written numerous papers in particle physics, under grants from the National Science Foundation. He is a 1965 graduate of the University of Michigan with a Doctor of Philosophy in Theoretical Physics, specializing in group theory and particle physics. Dr. Marvin Resnikoff
Radioactive Waste Management Associates EXPERIENCE: April 1989 - present Senior Associate, Radioactive Waste Management Associates, management of consulting firm focused on radioactive waste issues, evaluation of nuclear transportation and military and commercial radioactive waste disposal facilities. 1978 - 1981; 1983 - April 1989 Research Director, Radioactive Waste Campaign, directed research program for Campaign, including research for all fact sheets and the two books, Living Without Landfills, and Deadly Defense. The fact sheets dealt with low-level radioactive waste landfills, incineration of radioactive waste, transportation of high-level waste and decommissioning of nuclear reactors. Responsible for fund-raising, budget preparation and project management. 1981 - 1983 Project Director, Council on Economic Priorities, directed project which produced the report The Next Nuclear Gamble, on transportation and storage of high-level waste. 1974 - 1981 Instructor, Rachel Carson College, State University of New York at Buffalo, taught classes on energy and the environment, and conducted research into the economics of recycling of plutonium from irradiated fuel under a grant from the Environmental Protection Agency. 1975 - 1976 Project Coordinator, SUNY at Buffalo, New York Public Interest Research Group, assisted students on research projects, including project on waste from decommissioning nuclear reactor. 1973 Fulbright Fellowship at the Universidad de Chile, conducting research in elementary particle physics. 1967 - 1972 Assistant Professor of Physics, SUNY at Buffalo, conducted research in elementary particle physics and taught range of graduate and undergraduate physics courses. 1965 - 1967 Research Associate, Department of Physics, University of Maryland, conducted research into elementary particle physics. EDUCATION
University of Michigan PhD in Physics, June 1965
Technical testimony: Erik Ringelberg I. Party presenting technical testimony: Citizen Action and its members. II. Name and qualifications of the witness to be presented: Erik Ringelberg. As is indicated in his attached resume, Mr. Ringelberg is an Environmental Scientist. He will testify on the basis of that experience and expertise about the field investigation, FOIA materials related to the landfill and its contents, and the remediation of similar sites. III. Summary of anticipated testimony:
1. The proposed waste disposal facility has had only a cursory Remedial Investigation and has failed to meet due diligence and ordinary scientific standards for the establishment of understanding regarding the nature and extent of the contamination. References: 1. http://hps.org/newsandevents/meetings/midyear/abstract217.html - Health Physics Remediation of a Classified Waste Landfill at Sandia National Laboratories, New Mexico. 2. http://www.sandia.gov/ltes/SiteSummarySheets/ERSiteNo_74.pdf - Sandia ER Project: ER Site 74 Chemical Waste Landfill. 3. http://www.sandia.gov/LabNews/LN05-07-99/landfill_story.htm - Sandia Lab News Sandia's Classified Waste Landfill project uncovers artifacts of Labs' early days. 4. http://www.sandia.gov/ltes/SiteSummarySheets/ERSiteNo_2.pdf - Sandia ER Project: ER Site 2Classified Waste Landfill, 2003 Exhibits: 1. Marssim, "Multi-Agency Radiation Survey and Site Investigation Manuel." 2. INEEL/USDOE. "Engineering Evaluation/Coast Analysis for the Retrieval of a Designated Portion of Pit 4. April, 2004. 3. "Idaho Completion Project." Pit 4 Removal. INEEL. 4. "Radioactive Waste Management Complex." INEEL. 5. "Lessons Learned from the Pit 9 Retrieval Demonstration Project." INEEL. June 10, 2003. 6. "ERD SOP 1.5 Well Development - Revision: 4. LLNL. 7. E-Z WELD Material Data Safety Sheet: 212 Purple/211/Clear Primer/213 Primer/Cleaner/228 Blue Primer. 8. E-Z WELD Material Data Safety Sheet: 207 CPVC Orange/907 Low VOC Orange/208 Multipurpose/908 Low VOC Multi all purpose CPVC/217 Gray/227 Flowguard. 9. Documents received under the Freedom of Information Act (FOIA): (*each document has corresponding FOIA number written at top right) SNL ER Program Information Sheet, 1987 (FOIA 90). SNL Working Draft, Sampling Plan 1992 (FOIA 92). SNL ER Program, 1993, Phase 2 RFI Work Plan (FOIA 101). Letter from Delacroix Davis, Jr. to James G. Steger, 1977, pg. 11 (FOIA 50). Memo from Jerry Peace/SNL to Mark Jackson, John Gould/DOE/KAO, 1997 (FOIA 22). Appendix D, SNL Site Health and Safety Plan Form, 1992 (FOIA 116). Remedial Action and D & D Scope Definition Worksheet, SNL, 1991 (FOIA 108). Interview with former SNL employee H. Abbott, 19...?...(FOIA 1). Interview with Donna Hartzel to G.L., 1989 (FOIA 112). Memo from Jerry Peace/SNL to Mark Jackson, John Gould/DOE/KAO, 1997 (FOIA 22). Memo from W.B. Cox, SNL to G.K. Laskar, DOE/KAO, 1997 (FOIA 21). Memo from W.B. Cox et al to G.K. Laskar, April 1, 1997 (FOIA 20). Excess Special Nuclear Materials (author's names deleted), p. 76, 1984 (FOIA 38). Interview with former SNL employee Bob Schwing, 1995 (FOIA 7). SNL ER Program, 1993, Phase 2 RFI Work Plan (FOIA 101). Interview with former SNL employee Max Moms regarding disposal of nuclear reactor materials in dump, 1998 (FOIA 12). Memo from Mike Goodrich to Alva Parsons dated 1989 (FOIA 114). Interview with former SNL employee Frank Statzula (FOIA 58). Interview with George Tucker, former SNL employee, 1995 (FOIA 3). "UNK UNK memo" from W.D. Burnett to R.R. Malone, Waste Management Fact Book, Memo (FOIA 34). Interview with Fernando Dominguez, recalling information given to him by Charlie Bergland, 1998 (FOIA 5). Memo to J.C. Vandermolen from G.J. Smith, SNL (FOIA 43). IV. Anticipated duration of direct testimony, excluding cross examination: 1 hour. V. Other exhibits to be used: Mr. Ringelberg may present studies, maps, and other figures (in Powerpoint format) from the Department of Energy and US Environmental Protection Agency and other organizations and their contractors.
AREAS OF EXPERTISE
Direction and Administration oOrganized and managed staff, field personnel, contractors, and volunteers. Coordinated with oversight agencies; developed threatened and endangered species management plans; and, developed memoranda of understanding/agreement, as well as informal partnerships with public agencies. Worked with complex organizational structures, such as Tribal Councils and diverse Board's of Directors. oDirected legal teams, formulated FOIA requests/appeals, managed successful litigation against state and federal agencies, and participated on Federal Advisory Committee Act committees. oExperienced in conference presentations, and organization of public hearings. Conducted public participation sessions on Forest Stewardship for USDA Forest Service Region 1.
Field Ecology oResearched the integration of riparian and wetland vegetation, habitat, and stream classifications. Created and tested new model for riparian ecosystem organization. Co-funded, developed, and managed the Missoula County riparian inventory. Experienced with ecological sampling methodologies and data analysis techniques. Developed and taught field and classroom environmental education curriculum. Familiar with all common data organization and spatial analysis software, in both Macintosh and Windows platforms. oInvestigated new models for ecosystem and watershed management. Experienced in large-scale watershed restoration and management, and in the development of relevant legal positions and administrative policies.
Remediation and Restoration oDirected or advised non-profit, tribal, and local government agencies on nuclear and hazardous waste, water quality policy, and technical restoration issues. Assessed related legislative policy impacts.
Community Collaboration RELATED EMPLOYMENT
Executive Director
Executive Director
Program Manager
Research Director
Consulting Scientist (concurrent, pro-bono)
Graduate Research Assistant
Director of Environmental Education
Environmental Scientist EDUCATION
ABD candidate Ph.D.
M.Sc. Environmental Education, 1991.
B.Sc. Microbiology, with a Business concentration, 1987. AWARDS Recipient of the George Bright Graduate Fellowship for academic achievement and exceptional service to the School of Forestry (1994-1995), and the Jesse M. Bierman Scholarship for academic achievement and potential in the life sciences (1994). CERTIFICATIONS
Water Rights in Nevada, Water Operator, 2004 GRANTS
Fish and Wildlife Service, TLIP (2005) ARTICLES, REPORTS, and PRESENTATIONS Invited Speaker at the 2004 Western Outdoor Writers Inaugural Conference, "Pyramid Lake, a success for Tribal fisheries management." Invited Speaker at the 2004 Western States Water Council Conference; Desert Terminal Lakes Conference, "Hatchery program for native fish species." Invited Speaker at the 2004 River Health and Barriers to Passage, Lake Tahoe to Pyramid Lake, "Tribal Fish Passage Management and River Health Concerns." Invited Speaker at the 2004 Lahontan Cutthroat Trout Interagency Meeting, "Changing directions in Tribal Fisheries." Invited publication: "Stakeholder Involvement in Department of Energy Decision Making, a Stakeholder's Perspective.", Spectrum, American Nuclear Society (2002). Invited speaker at the School of Forestry, The University of Montana (1999) on: "Riparian ecology and restoration." and "Riparian ecology, delineation, and streamside management zones." Invited speaker at International Exchange Conference (1998), Lewis-Clark State College: "Sustainable Development in Rural Communities." Invited speaker at Joint Meeting (1997) of Montana Regional Society of American Foresters and The Wildlife Society: "The Harlequin Duck, habitat use and behaviors along a Rocky Mountain stream." Research and educational work featured in: Birder's World article "The Harlequin Duck;" Wildbird article "Duck Tales;" and, the film "The Innu vs. Inco at Voisey's Bay."
Technical reports:
Unpublished Manuscripts: "Assessment of Rosgen and Strahler Stream Classifications, Examination of the relationships between geomorphology and riparian habitat." (1999). -with K. Cheek, University of Montana. "Rural community collaborations, a case study in western Montana." (1999).
Presentations: SEAB Blue Ribbon Panel and Jackson Wyoming community forum, social and technological issues surrounding the incineration of radioactive and hazardous waste (2000); Montana Wetlands Council, and Missoula County Commission (2000), "Inventory of Clark Fork watershed bank stabilization projects."; Developed, coordinated and reported conferences on "Stewardship Contracting I, and II, results-based land stewardship contracting" (1999), "Community Collaboration Forum" (1999), and, "Reinventing the Forest Service, Forest Options for the second century" (1998); Montana Watershed Council (1998), "Community collaboration in watershed planning."; National Society of Wetland Scientists Conference (1997): "The Riparian Mosaic and Continuum: Modeling riparian ecosystems."; and, Audubon Institute (1991), "Long-term storage implications at the Waste Isolation Pilot Plant." COMMITTEES and COMMUNITY SERVICE oCommissioner - Regional Water Planning Commission (2004); Reno, Nevada. o Member - Regional Stormwater Professional Advisory Group (2004); Reno, Nevada. oMember - US Fish and Wildlife Service, Truckee River Implementation Team (2003-4); Reno, Nevada. oObserver - US Fish and Wildlife Service, Management Oversight Group (2003-4); Reno, Nevada. oMember - Secretary of Energy Advisory Board, Alternatives to Incineration Committee; and, Steering committee for Stakeholder's Forum (2002); 2001 to conclusion in 2002; Washington, D.C. oParticipant - INEEL Long-Term Stewardship Research Program, St. Cloud State, 2001-2002. oChair - Missoula City/County Water Quality Advisory Council, 1993-1999. oCo-founder - Clark Fork Watershed Education Network, 1999-2001; Missoula, Montana. oScience Judge - Preliminary and Final, Montana State Science Fair, 1995-1999. oScience Judge - International Wildlife Film Festival, 1994-1997; Missoula, Montana. oMember - Montana Watershed Council, and Montana Wetlands Council, 1994-2000. o Ex-officio Board Member for the Swan Ecosystem Center, 1999-2000; and, Beaverhead, Bighole, and Mineral County (Montana) Advisory /Watershed Councils, 1998-2000.
Technical testimony: William Paul Robinson I. Party presenting technical testimony: Citizen Action and its members II. Name and qualifications of the witness to be presented: William Paul Robinson. Mr. Robinson has been employed as Research Director for Southwest Research and Information Center since 1976 and has worked as Research Director and as an environmental policy and technology assessment consultant for governmental, corporate, tribal and non-governmental organization clients since 1980. Mr. Robinson's education, professional experience and publications are set forth in his attached resume.
III. Summary of anticipated testimony:
The DPM recommended alternative therefore fails to provide a remedy that complies with the NMHWMR standard that requires a corrective measure and closure plan that:
IV. References:
6. "Is 'Trust Us, We're the Government' Really A Guarantee? A Review of Financial Assurance Options for Long-Term Stewardship at the Mixed Waste Landfill, Sandia National Laboratories" by Paul Robinson, 2002 at: http://www.radfreenm.org/pdf_docs/FinalFinancialAssuranceReport.pdf V. Anticipated duration of direct testimony, excluding cross-examination: 3 hours.
VI. List of exhibits to be used:
1. Resume of William Paul Robinson
WILLIAM PAUL ROBINSON
Master of Community and Regional Planning, University of New Mexico, 1992, "with distinction." Professional Project "Planning for Reclamation of Uranium Waste Sites in Germany." Course work included analysis of natural and modified water systems, including irrigation diversions, watershed analysis, urban flood reduction, environmental impact assessment methods, and geology. Graduate Study in Environmental Engineering, Johns Hopkins University, Baltimore, MD, 1974 5. Course work included water pollution chemistry and water resource engineering. Bachelor of Arts, Technology and Human Affairs Program, Washington University, St. Louis, MO, 1971 4. Course work included classes from anthropology, geology, engineering, and ecology programs. EMPLOYMENT RESEARCH DIRECTOR Southwest Research and Information Center, PO Box, 4524, Albuquerque, NM 87106-4524, USA. Coordinate and prepare environmental policy and technology research reports and technical analyses of mineral, water, waste management, and other natural resource development projects for non profit scientific and educational organization and contract clients. With Southwest Research continuously July 1976 present.
ADJUNCT PROFESSOR - 2004 - In the Fall 2004 Semester, was appointed at University of New Mexico to teach a senior seminar, "Sacred Sites and Environmental Protection," in the Native American Studies Program.
ENVIRONMENTAL POLICY AND TECHNOLOGY ASSESSMENT CONSULTANT Since 1980, government, corporate, tribal and non-governmental organization clients have included: PROJECT COORDINATOR CITIZENS' MINING INFORMATION NETWORK 1991 - 1996 - Southwest Research and Information Center. Project provides current technical and policy related information on mining to citizens and community organizations across the US. This Project funded by United States Environmental Protection Agency and private donors.
SELECTED PUBLICATIONS - "Mining and Mineral Development Management Policy in the Selenga River Watershed," with Galina Anosova, in proceedings of: Science for Watershed Conservation: Multidisciplinary Approaches for Natural Resource Management Conference, Convened by United States Geological Survey (USGS), Institute of General and Experimental Biology, Siberian Division -Russian Academy of Sciences, and Mongolian Academy of Sciences, September 1 - 8, 2004, Ulan-Ude, Russia and Ulanbaatar, Mongolia available at: http://www.sric.org/mining/docs/USGS-siberia.pdf
- "Evaluation of Application to Use the Sacaton Mine in Arizona to Meet Wisconsin Mining - "Uranium Mill Tailings Remediation Performed by US DOE: An Overview," report under a grant from Monitoring and Technical Assessment Fund, Washington, DC, May 18, 2004 available at: http://www.sric.org/U_Mill_Tailing_Remediation_05182004.pdf - "Environmental Remediation and Mine Waste Management at the Pecos, New Mexico USA Lead-Zinc Mill Tailings Site: A Case Study of a Durable Solution to an Inactive Mine Waste Pollution Problem," presented at "Environmental Remediation and Mine Waste Management: International Business and Technology Seminar," Bucharest, Romania convened by United States Agency for International Development (USAID), United States Department of Commerce (USDOC), Ministry of Economy and Commerce of Romania, Department of Mining, Romania, Institute for Studies and Power Engineering (ISPE), and Faculty of Land Reclamation and Environmental Engineering, , April 21-23, 2004 - "Analysis and Recommendations Regarding the Mixed Waste Landfill Corrective Measure Study Final Report prepared by Department of Energy and Sandia National Laboratories," Prepared under contract to Citizen Action, Sandia Park, NM, March 30, 2004 available at: http://www.radfreenm.org/pdf_docs/comments_mwl.pdf - "Statement of Intent to Present Technical Testimony in the Matter of the Petition for Alternative Abatement Standards for-L-Bar Uranium Mill, SOHIO Western Mining Company, WQCC-02-24(A), before the New Mexico Water Quality Control Commission, Santa Fe, NM, May 2003"
- "Comments on Interim Independent Technical Peer Review Panel Report of January 15, 2003 - "A Review of Financial Assurance Options for Long-Term Stewardship at the Mixed Waste Landfill, Sandia National Laboratories, " prepared under contract to Citizen Action, Sandia Park NM, through a grant from the Monitoring and Technical Assessment Fund (MTA), June, 2002, at: http://www.radfreenm.org/pages/robinson_full.htm - "Comments on "Environmental Assessment Screening Report: Possession and Management of Waste Nuclear Substances Situated at the Spanish American, Milliken, Lacnor, Nordic/Buckles, and Pronto Historical Properties in the Elliot Lake Area, Ontario: A Report of the Canadian Nuclear Safety Commission, May 2001," Prepared on behalf of Miningwatch, Ottawa, Ontario, Canada, February 14, 2002. - "Review of the Khiagda Uranium Mine Investment Rational and OVOS/Environmental Impact Assessment: Observations and Suggestions," Prepared on behalf of Buryat Regional Center on Baikal, Ulan-Ude, Buryat Republic, Russian Federation, January 28, 2002. - "Technical Testimony in the Matter of the Draft Final Permit for the Triassic Park Waste Disposal Facility, US EPA No. NM0001002484" before the New Mexico Environment Department, Case No.HRM 01-02(P), on behalf of Citizens United for a Rationale Environment, Roswell, New Mexico, October 11, 2001. - "Identification of Potential Water Quality Risks to Lake Baikal's Largest Tributary, the Selenga River, from Mining and other sources: A Preliminary Investigation," Prepared under contract to Baikalwatch, Earth Island Institute, San Francisco, CA, USA, September 20, 2001. - "Comments on Molycorp Work Plans - I and II, with attachments, prepared under contract to Center for Science in Public Participation, Bozeman MT on behalf of Amigos Bravos, NM, February 22, 2000 and March 29, 2000. - "L-Bar Uranium Mill Tailings Site Review: Analysis of Kennecott's Recent Activities and Current Proposals", prepared under contract to Cebolleta Land Grant Board, August, 1999. - "Evaluation of Environmental Technology Changes Proposed for La Oroya Smelter Complex in Central Peru: Final Report" February 1, 1999, on behalf of Sociedad Peruana de Derechos Ambientales (SPDA), Lima, Peru and Associación Interamericana para la Defensa del Medio Ambiente(AIDA), San Francisco CA, February 1999. - "Groundwater Restoration Long Beyond Closure at the Homestake-Milan and United Nuclear-Church Rock Uranium Mill Tailings Piles, New Mexico, USA: Full Scale Programs Requiring More Than 20 Years of Active Treatment", in Uranium Mining and Hydrogeology II, Freiberg Mining Academy, Freiberg Saxony, Germany, September 1998. Available at: http://www.sric.org/mining/docs/Umills.html - "In Situ Leach Uranium Mining without Aquifer Restoration?: Preliminary Comments on Heathgate Resources' Beverley Uranium Mine Environmental Impact Statement Main Report", prepared for Australian Conservation Foundation and Friends of the Earth (Fitzroy), July 1998. - "More Than Radon in the Uranium Dust:" Statement in Support of Testimony at US House of Representatives Judiciary Committee Subcommittee on Immigration and Claims Hearing on Uranium Workers Health Effects and Radiation Exposure Compensation Act Amendments, June 25, 1998, Washington, DC available at: http://www.sric.org/mining/docs/RECA.html
- "A Model Mine Shows its Cracks: An Independent Report on Environmental Problems at the Kubaka Gold Mine in the Russian Far East", by Julie Edlund, David Gordon and Wm. Paul Robinson, Pacific Environment, San Francisco, CA, April 1998. Available at: - "Comments on Air Quality Aspects of the Proposed Voisey's Bay Mine and Mill Project Environmental Impact Statement", prepared under contract to Center for Science in Public Participation on behalf of the Innu Nation, Labrador, Newfoundland, Canada, February 1998. - "Chino Mines Existing Mine Permit Application Documents: 1) An Annotated Chronology and 2) Matrix of Chino Existing and New Units", research memoranda prepared under contract to United Steelworkers of America Local 890 and Good Neighbor Project, February, 1998 - available from Southwest Research with permission of contractors. - "Environmental Issues and Concerns associated with the Proposed Dybycksa Gold Mine in the Alkhanai Area of Aginskoe Buryat Autonomous Region of the Russian Far East", prepared under contract to Pacific Environment and Resources Center, Sausalito, CA, December 1997. - "Report on Chino Mines' Proposed Santa Rita Pit Expansion in Relation to the Kneeling Nun Natural Landmark", prepared under contract to United Steelworkers of America Local 890 and Good Neighbor Project, October 1997 - available from Southwest Research with permission of contractors. - "Environmental Damage and Policy Issues in the Uranium and Gold Mining Districts of Chita Oblast in the Russian Far East: A Report on Existing Problems at Baley and Krasnokamensk and Policy Needs in the Region", prepared under contract to Baikalwatch/Earth Island Institute, November 1996. Available at: http://www.sric.org/mining/docs/Chitafin.html "Navajo Land Selection Project, Phase II Final Report", with Chris Shuey, under contract to Office of Navajo and Hopi Indian Relocation, US Department of Interior, July 1996. "Review of Recent Uranium Production and Market Trends" submitted to Canadian Joint Federal Provincial Panel on Uranium Mining in Northern Saskatchewan, on behalf of Saskatchewan Uranium Committee, June, 1996. "Review of Innovative Approaches to Environmental Remediation at Inactive Mining Sites with Multiple Implementation Barriers", Report to Western Governors' Association under contract to Mine Waste Working Group/ Advisory Committee to Develop On site Innovative Technologies, June 1996. - "Comments and Recommendations Submitted to Environmental Assessment Panel Reviewing Decommissioning Proposals for the Elliot Lake Uranium Mine Tailings Management Areas" before Canadian Environmental Assessment Agency Panel, Elliot Lake Ontario, Canada, on behalf of Northwatch, November 1995. Available at: http://www.sric.org/mining/docs/elliot95.html "Groundwater Contamination at Uranium Mill Tailings Sites in the United States Reclaimed by the DOE (Department of Energy) Uranium Mill Tailings Remedial Action Program (UMTRAP)" in Proceedings of Uranium Mining and Hydrogeology International Conference and Workshop, Freiberg, Saxony, Germany, October 1995. "Handling of radium and uranium contaminated waste piles and other wastes from phosphate ore processing Final Report, with Gerhard Schmidt and Christian Kueppers, Oeko Institut/Darmstadt, annex by Wm. Paul Robinson, European Commission Nuclear Science and Technology Report EUR 15448 EN (ISSN 1018 5593), Brussels, 1995. "Review of Tailings Management, Disposal and Reclamation Aspects of the Crown Jewel Mine Draft Environmental Impact Statement, submitted to Washington State Department of Ecology on behalf of Okanagon Highlands Alliance, August 1995. - "Innovative Administrative, Technical, and Public Involvement Approaches to Environmental Restoration at an Inactive Lead Zinc Mining and Milling Complex Near Pecos, New Mexico", in Proceedings of Waste Management '95 (proceedings available on CD ROM), University of Arizona, Tucson, Arizona, March 1995. Available at: http://www.sric.org/mining/docs/Pecos.html "Public Stakeholder Concerns and Recommendations related to Innovative Technology Development: Final Report", prepared under contract to Western Governors' Association for the Mixed Waste Working Group, Demonstration of On site Innovative Technologies (DOIT) Federal Advisory Committee, Denver, Colorado, September, 1994. "Final Subcontractor Report Navajo Land Selection Project: Evaluation of the Revenue Generating Potential of Certain Mineral Bearing Lands in the San Juan Basin of Northwestern New Mexico..." with Shuey, C. S., submitted to Office of Navajo and Hopi Indian Relocation, Flagstaff, AZ (ONHIR Contract 6198 930672), May, 1994 available from ONHIR. "Pollution Prevention Strategies: Policies, Opportunities and Examples for Mining Operations",in Proceedings of 1994 New Mexico Conference on the Environment, convened by New Mexico Environment Department, Albuquerque, NM, April, 1994. "Pollution Prevention, Mining and Mineral Processing, and Citizen Involvement: Policy Concepts and Potential Benefits", invited paper presented at International Conference on Pollution Prevention in Mining and Mineral Processing, convened by Colorado School of Mines, Snowmass, Colorado, August , 1993. "How Permanent is the Permanent Solution II: Supplemental Comments Regarding the El Molino [mill tailings from Pecos lead zinc mine and mill sites] Decision Document and Supporting Documents", submitted to New Mexico Environment Department, Santa Fe, NM, July, 1993, prepared on behalf of La Gente del Rio, Pecos, New Mexico. "How Permanent is the Permanent Solution: Review and Initial Comments on Pecos/El Molino Cleanup Project, San Miguel County, New Mexico", prepared on behalf of La Gente del Rio, Pecos, New Mexico, submitted to New Mexico Environmental Department, Santa Fe, NM, June 1993. "Windy Craggy [Proposed Copper/Gold Mine in British Columbia] Project Issue Overview", Prepared on Behalf of City of Yakutat, Alaska, September 1992. - "Mined Land Reclamation Requirements in Western States: Implications for a New Mexico Mining Law", with Janna Rolland, invited paper for 1992 New Mexico Environment Conference, New Mexico Environment Department, Santa Fe, NM, September 1992. "Experiences with the Reclamation of Uranium Mining Areas in the USA and Their Transfer to the Situation at Selected Sites in the South of the Former German Democratic Republic", with Gerhard Schmidt, Oeko Institut, Darmstadt, Germany, December 1991. "Mine Waste Problems Require Prompt Federal Legislative and Regulatory Action", Testimony before US House of Representatives, Subcommittee on Transportation and Hazardous Materials, Committee on Energy and Commerce, Washington, DC, September, 1991. "Design Criteria and Standards for Uranium Mill Waste Management in the United States of America", presented at Geology and Tectonics of the Gera Jachymov Fault Zone and Its Relationship to Regional Uranium Resources, Institute for Physics of the Earth, Gera, Germany, August, 1991. "An Introduction to the Giant Uranium Facilities of Eastern German: A Report of Observations of the Uranium Mines and Mills Operated by Wismut AG in Saxony and Thuringia in the Former German Democratic Republic", prepared for International Physicians for Prevention of Nuclear War/German Chapter, Heidesheim, Germany, June 1991. "Solid Waste, Waste Reduction, and Public Policy", New Mexico Law Review, University of New Mexico, Winter 1990. "Recommendations to the Albuquerque City Council/Albuquerque Mayor's Office of the City of Albuquerque Solid Waste Recycling Advisory Committee," Paul Robinson, Chair, et.al., Albuquerque, NM, December 1990. "Final Report Water Action Campaign: The Public Involvement Program of the Southwest Valley Service Option Evaluation", with Julie Stephens, Fred Griego, and Jaime Chavez, a Project funded by the New Mexico Legislature and Managed by the City of Albuquerque, Rio Grande Community Development Corporation, Albuquerque, NM, December 1991. "In the Hands of the People: Establishing Planning Power for a Community", with Kathy Newton and Julie Stephens, The Workbook, Southwest Research and Information Center, Albuquerque, NM, Vol. 15, No. 4, Winter, 1990. "Molybdenum Mining and the People of Northern New Mexico", The Workbook, Southwest Research and Information Center, Albuquerque, NM, Vol. 15, No. 2, Summer, 1990. "Deficiencies in the Molycorp Guadalupe Mountain Tailings Proposal", for Northern New Mexico Legal Services on behalf of Concerned Citizen del Norte, May 1, 1990. "Uranium Production and Its Effects on Navajo Communities Along the Rio Puerco in Western New Mexico", invited paper published in Proceedings of Conference on Race and the Incidence of Environmental Hazards, University of Michigan, Ann Arbor, Michigan, January, 1990. "Proposal for Long Term Isolation of the Uranium Mill Tailings at Ellweiler, Kreis Birkenfeld", prepared for Kries Birkenfeld (County Administrator) Landrat Dr. Ernst Theilen, Birkenfeld, Rheinland Pfalz, West Germany, November, 1989. "An Overview of Uranium Cleanup Standards and Experience in the USA", invited paper published in Proceedings of Conference on Neidrigdosisstrahlung und Gesundheit (Low Level Radiation and Health), in Birkenfeld, Rheinland Pfalz, West Germany, November, 1989. "The Interstate Waste Dilemma", invited statement before the New Mexico Legislative Interim Environment, Land Use and Solid Waste Committee, Lordsburg, NM, June 29, 1989. "Landfill Design and Operation Improvements for the Proposed Cerro Colorado Landfill", submitted to the Bernalillo County, NM, Planning Commission, Albuquerque, NM, May, 12, 1989. - "Statement for the Public Record on Proposed New Mexico Solid Waste Management Regulations", Santa Fe, NM, November 15 17, 1988, on behalf of Southwest Research and Information Center, New Mexico Public Interest Research Group and New Mexico Environmental Law Center, with Kevin Bean, Chris Shuey, Doug Meiklejohn and James Tarr. "Winslow, Arizona: An Environmental Evaluation with Emphasis on Water Resources", prepared under contract to United Transportation Union Local 1181, Gallup, NM, August, 1988 "Statement before the United States House of Representatives, Committee on Interior and Insular Affairs, Concerning Uranium Mill Tailings", Washington, DC, June, 28, 1988.
"Ground Water Problems in Albuquerque's South Valley: Identification, Clean Up and Alternative Water Supply Options," Statement Before U. S. House of Representative, Subcommittee on Natural Resources, Agricultural Research and Environment, Albuquerque, NM, November 1987. "Reclamation and Water Supply Issues Ten Years After the Passage of the Surface Mining Control and Reclamation Act of 1987", Statement Before the United States House of Representatives, Committee on Interior and Insular Affairs, Washington, DC, August 3, 1987. "Draft Environmental Assessment for Proposed Santa Ana Pueblo [NM] Sublease of a 50 Acre Site for use as a Wallboard Factory", prepared under contract to Centex American Gypsum Company, June, 1987. "Changing Forest Plans: A Way to Do It Outside the Courts", in The Workbook, January March 1987, Southwest Research and Information Center, reprinted as "Changing Forest Plans Outside the Courts" in Forest Watch, Eugene, Oregon, July 1987 and Technology Review, Cambridge, Massachusetts, November, 1987. "Report Evaluating Environmental Issues and Concerns Related to the Centex Wallboard Facility Proposed for Santa Ana Pueblo", prepared under contract to Centex American Gypsum Company, December, 1986. "Groundwater Monitoring Needs at the L Bar Tailings Site", prepared for the Cebolleta Land Grant Council, June, 1986. "Crow Butte Uranium In Situ Pilot Project Comments", prepared on behalf of Western Nebraska Resources Council, June, 1986. "Ground Water Contamination from Seepage of Wastewater from the Sohio (Kennecott Minerals) L Bar Uranium Mill Tailings Impoundment (II): April 1986 Updated Report", prepared for Cebolleta Land Grant Council, May, 1986. "Progress Report of the Puerco River Education Project", presented to the Policy Committee of the Puerco River Working Group (including New Mexico, Arizona and US Environmental Protection Agency), with Chris Shuey and Raymond Morgan, updated May, 1986. "Source Document for Information on Water Quality and Air Quality of the Navajo Reservation in New Mexico and Arizona", with Chris Shuey, for Navajo Tribe Division of Resources, January, 1986. "Comments on the Draft Environmental Impact Statement for Reclamation of the Jackpile Paguate Uranium Mine, Laguna Reservation, New Mexico, with Chris Shuey and Hollis Whitson, Esq., October, 1985. Better Ways to Use Water: A Handbook on Technologies to Improve Rural Water Use in Northern New Mexico, Northern New Mexico Water Project, Albuquerque, NM, October 1985. "South Valley Toxics Overview: Ground Water Contamination in a Poor and Minority Community: The South Valley of Albuquerque, New Mexico" under contract to Commission on Racial Justice, United Church of Christ, August, 1985. "Statement of Wm. Paul Robinson ... before a Joint Session of the [US] Senate Energy and Natural Resources Committee and House Interior and Insular Affairs Committee" regarding Uranium Mill Tailings Legislation, July, 1985. "Comments on Water and Reclamation Aspects of the Federal Coal Management Program Draft Environmental Impact Statement", March 1985. "Water Quality Effects of the Sohio Uranium Operations on the Cebolleta Land Grant Information to Document the Problem", under Contract to Simms and Garcia, attorneys for Cebolleta Land Grant, March, 1985, available from contractor or with contractor permission. "The Need for Non Coal Mine Reclamation Study in New Mexico: A Statement Concerning HB168", Testimony before New Mexico House of Representatives Committee on Energy and Natural Resources, Santa Fe, NM, February 11, 1985. "Summary of New Mexico Coal Transportation Study by Coal Transportation Task Force", January 1985. "Statement for the Public Record for the Ground Water Discharge Plan for Grain Power Tucumcari Ltd." with Chris Shuey, October 2, 1984. "Characterization of Ground Water Quality near a Uranium Mill Tailings Facility, and Comparison to Background Levels and New Mexico Standards", In Selected Papers on Water Quality and Pollution in New Mexico, New Mexico Bureau of Mines and Mineral Resources Hydrologic Publication 7, Socorro, New Mexico, 1984, presented April 12, 1984. "Environmental Cleanup: Employment Opportunities in New Mexico", with Chris Shuey, April, 1984. "Findings and Conclusions in the Matter of the Homestake Mining Company Uranium Mill at Milan, NM, Discharge Plan", March, 1984. "Water and Soil Issues...in the Santa Fe National Forest Plan Environmental Impact Statement (and Record of Decision)", for Save the Jemez, December, 1983. "Comments on Proposed Rules Regulating Drilled or Mined Shafts", with Don Hancock and Alice Hector, submitted to Texas Department of Water Resources for Serious Texans Against Nuclear Dumping (STAND), December, 1983. "Southwest Resource Council Comments on Phase II Report Environmental Assessment Arizona Strip District Uranium Development", with Chris Shuey, for Southwest Resource Council, October, 1983. "Comments on New Mexico Interim Hazardous Waste Regulation Program", with Michael Sousa, Testimony at EPA Hearing, August 24, 1984. "The State of the Environment: A New Mexico Perspective, A Southwest Research and Information Center Perspective", Testimony Before the US Senate Committee on Environment and Public Works, Albuquerque, July 6, 1983. "First, Second (and) Third Statement(s) and Findings of Fact and Conclusions for the Public Record in the Matter of the Radiation Protection Regulations Violation of United Nuclear Corporation", with Chris Shuey, February April, 1983, Several Statements for the record. "Comments on San Miguel Project Post Reclamation Annual Monitoring and Maintenance Program", For National Wildlife Federation, Boulder, Colorado, April 7, 1982. "Water Quality Training Program Final Report", for Five Sandoval Pueblos, Inc., Southwest Research and Information Center, March, 1982. "Statement for the Public Record of the New Mexico Water Quality Control Commission Regulation Hearing on March 3, 1982" concerning underground injection control regulation, March, 1982. "Geology and Water Supply of the Zuni Reservation", in Appeal of Finding of the Area Director that Opening the Zuni Reservation to Oil and Gas Exploration and/or Development will have No Significant Effect on the Human Environment....., Zuni Pueblo Legal Services, Zuni, New Mexico, January, 1982. "Statement for the Public Record of the Water Quality Control Commission Hearing on December 3, 1981" concerning water quality classification of the Rio San Jose in Cibola and Valencia Counties, New Mexico, Acoma Pueblo, Acomita, New Mexico, December, 1981. "Statement Before U.S. Senate Committee on Environment and Public Works Subcommittee on Nuclear Regulation Concerning the Implementation of the Uranium Mill Tailings Radiation Control Act, Public Law 95 604", Washington, DC, June 16, 1981. "Statement for the Public Record on the Proposed Amendments to the Radiation Protection Regulations, June 11, 1981 Before Environmental Improvement Board, George H. Hensley, Chairman", Albuquerque, New Mexico, June, 1981. "Impacts of Uranium Exploration and Methods for Regulation", Transcript of Testimony before Virginia Coal and Energy Commission, Richmond, Virginia, June 1, 1981. "Environmental Overview of the Four Corners Area", University of New Mexico Medical School Symposium on Reproductive Effects of Uranium Mining in the Four Corners Area, Albuquerque, NM, April, 1981. "Radon and Radon Daughters from Uranium Mines: Source, Impacts and Controls", Third Symposium on Uranium Mill Tailings Management, Colorado State University, Fort Collins, CO, November 24 25, 1980. "Statement on National Materials Policy before U.S. Senate Committee on Commerce, Science and Transportation Subcommittee on Science, Technology and Space", Washington, DC, Senate Hearing 96 112, July 1, 1980. "Responsible Uranium Mining and Milling: An Overview", Proceedings of First International Conference on Uranium Mine Waste Disposal, Vancouver, BC, Canada, May, 1980. "An Analysis of the Draft EPA Ore Mining and Dressing Best Available Technology Effluent Limitation Guideline Development Document", prepared under contract to Natural Resources Defense Council, Washington, DC, March, 1980. "Testimony before the House of Representatives Committee on Interior and Insular Affairs, Subcommittee and the Environment, Hearing on the Causes and Implications of the United Nuclear Churchrock Tailings Dam Failure", Washington, DC, October 22, 1979, "Comments on the Generic Environmental Statement on Uranium Milling, NUREG 0511", October, 1979.
"Testimony before the House of Representatives Committee on Interior and Insular Affairs, Subcommittee on Energy and the Environment, Hearings on the Nuclear Regulatory Commission's State Programs", Washington, DC, July, 19, 1979. "Comments on the Federal Coal Management Program Draft Environmental Statement", February, 1979. "Comments on the Star Lake Bisti Coal Region Draft Environmental Statement", November, 1978. "Bokum Uranium Mill License Application Comments", September, 1978. "Analysis of Mobil/TVA's Interim Mining and Reclamation Plan for Pilot In situ Leaching at Crownpoint, McKinley County, New Mexico, May 1978", June, 1978. "Temporal Change in the San Mateo Creek Drainage, Part of the Grants Mineral Belt, New Mexico", an Independent Research project at Technology Applications Center, University of New Mexico, May, 1978. "New Mexico Uranium Inventory, 1978", Southwest Research and Information Center, P. O. Box 4524, Albuquerque, NM, May, 1978. "Statement for the Public Record of the Radiation Protection Regulation Hearing of January 20, 1978", January, 1978. "New Mexico Uranium Slide Shows": 1 Overview of technology and environmental impacts, 1977; 2 Development on Indian Land aerial views, 1978; 3 Impacts of mines and mills aerial views, 1979; and 4 United Nuclear Churchrock tailings dam break, 1979. Slides and scripts by Wm. Paul Robinson. "Statement for the Public Record Regarding the Priority List for Wastewater Treatment Works Construction Grants", September 7, 1977. "Comments on Albuquerque Wastewater Treatment Facilities Draft Environmental Impact Statement", August, 1977. "Problems and Alternatives for the Navajo Indian Irrigation Project", Testimony before U.S. Senate Committee on Environment and Public Works, Subcommittee on Water Resources, Washington, DC, April, 1977. "Alternatives for Confined Livestock Operations in the South Valley Answers to a Community Problem", Southwest Research and Information Center, Albuquerque, NM, January, 1977. "Application of the Dynamic Method of Flood Plain Mapping to Selected Developing Nations", ECOsystems International, P.O. Box 225, Gambrills, MD, 21054, June, 1975. "User Requirements and User Acceptance of Current and Next Generation Satellite Mission and Sensor Component, Oriented toward the Monitoring of Water Resources", ECOsystems International, Gambrills, MD, June, 1975. "Impact of Remote Sensing upon the Planning, Management and Development of Water Resources," ECOsystems International, June, 1975. "Summary and Projection of Septic System Requirements and Problems for Anne Arundel County, MD", ECOsystems International, Gambrills, MD, March, 1975. "Technology Assessment of Large Scale Organic Farming in the U.S.," Technology and Human Affairs Program, Washington University, St. Louis, Missouri, May, 1974. SELECTED ORAL TESTIMONY OR PRESENTATIONS - "Testimony in the Matter of the Alternative Abatement Stand Petition of SOHIO for the L-Bar Uranium Mill Tailings Site before the New Mexico Water Quality Control Commission, " Santa Fe, NM, May 2003. - "Technical Testimony in the Matter of the Draft Final Permit for the Triassic Park Waste Disposal Facility, US EPA No. NM0001002484", before the New Mexico Environment Department, Roswell, NM, October 2001. - "Testimony in the Matter of the Rhino Environmental Services Application for a Solid Waste and Special Waste Landfill before the New Mexico Environment Department," Chaparral, NM September 2001. - "Testimony in the Matter of the Application of Molycorp, Inc for a Groundwater Discharge Permit for its Questa Molybdenum Mine (DP-1055)," before New Mexico Environment Department, Questa New Mexico, May - June 2000. - "Testimony in the Matter of the Application of Southwest Landfill, Inc. for a Solid Waste Facility Permit in Bernalillo County" before the New Mexico Environment Department Secretary, Albuquerque, NM, December 1996 and January 1997. -"Testimony in the Matter of the of the Application of Molycorp, Inc. for a Groundwater Discharge Permit for its Molybdenum Mill and Tailings Ponds" before the New Mexico Environment Department Secretary, Questa, NM, December 1996 - "Testimony in the Matter of Regulations Pursuant to the New Mexico Mining Act", Before New Mexico Mining Commission, Santa Fe, NM, May 1994 "Current Activities in Problem Scoping", in Proceedings of Inactive and Abandoned Mine Waste Cleanup: A Challenge for the 90s, convened by Colorado Center for Environmental Management, Salt Lake City, Utah, November, 1993. "Citizen Involvement and Pollution Prevention" in International Conference on Pollution Prevention in Mining and Mineral Processing", convened by Colorado School of Mines, Snowmass, Colorado, August, 1993. "Statement at the Public Hearing on the Resource Conservation and Recovery Act Permit proposed for Los Alamos National Laboratory", Before New Mexico Environmental Improvement Division and United States Environmental Protection Agency, Santa Fe, New Mexico, July 17, 18 and August 7, 1989. "Statement at the Public Hearing on the matter of the Municipal Solid Waste Incinerator proposed by Los Alamos, NM", before New Mexico Environmental Improvement Division, Santa Fe, NM, June, 1988. "Water Related Development Opportunities in the Eastern Navajo area", Workshop on Economic Development in Eastern Navajo Agency sponsored by New Mexico Office of Indian Affairs, June, 1985. "Toxic Contamination Sites in New Mexico", in the Conference on Water Contamination and Toxic Pollution in New Mexico, Albuquerque, NM, December, 1984 "In the Matter of the Groundwater Discharge Plan for Grain Power Tucumcari Ltd.", Tucumcari, NM, October, 1984. "In The Matter of the Permit for Underground Injection and Mineral Production Wells for Wyoming Fuels' Crow Butte Project", before the Nebraska Department of Environmental Quality, Crawford NB, July, 1984 "In The Matter of the Nuclear Regulatory Commission Environmental Impact Appraisal ... of the Source Material License for the Wyoming Fuels' Crow Butte ISL Project... Docket No. 40 8829", before the NRC Hearing Officer, Crawford, NB, July 1984. "In the Matter of the Discharge Plan for the Homestake Mining Company Uranium Mill at Milan, NM", Grants, NM, February, 1984. "Prioritizing Mineral Resources, Environmental and Conservation Needs", in Governmental Affairs Session, Society of Exploration Geophysicists Annual Meeting, Las Vegas, NV, September, 1983. "Mineral and Energy Development Projects on New Mexico's National Forests", at Citizen's Workshop on the Future of New Mexico's National Forests, Albuquerque, NM, September, 1983. "Concerns of the Environmental Community About Impacts from Uranium Operations on Federal and Indian Lands", at National Research Council/National Academy of Sciences Workshop on Research Needs for Optimizing Economic and Environmental Aspects of Uranium Production from Leased Federal and Indian Lands, Albuquerque, NM, December, 1982. "Summary of Recent Observations at Uranium Operations in the Northern Territory, Australia", Australian Institute of Aboriginal Studies, Canberra, ACT, July, 1982. Before South Dakota State Conservation Commission Concerning Exploration Permit Renewal for Silver King Mines, EX 5, Custer, South Dakota, February, 18, 1981. Before South Dakota State Conservation Commission Concerning Exploration Permit Renewal for Union Carbide Corporation, EX 31, Pierre, South Dakota, December 12, 1981. Before Colorado Water Quality Control Commission Concerning Reclamation Plan for Homestake Pitch Project, Saguache County, Colorado, Gunnison, Colorado, December 10, 1981. Before the New Mexico Radiation Technical Advisory Council regarding Amendments to the New Mexico Radiation Protection Regulations, Santa Fe, NM, May, 1981. Before the Virginia Coal and Energy Commission regarding Regulation of Uranium Exploration, Richmond, VA, June 1, 1981. Before Montana House and Senate Committees on Natural Resources regarding Uranium Mining and Milling Legislation, Helena, Montana, February and March, 1981. Before New Mexico House and Senate Committees on Natural Resources regarding Uranium Severance Taxes, Santa Fe, NM, February, 1981. "In the Matter of the Radioactive Materials License and Groundwater Discharge Plan for the Gulf Mount Taylor Uranium Complex", Santa Fe, New Mexico, January, 1981. In "State of Mexico vs. City of Albuquerque", in the Bernalillo County District Court, No. CU 80 04500, a nuisance complaint concerning odors from an Albuquerque sewage treatment plant, Albuquerque, NM, July, 1980. "In the Matter of the Groundwater Discharge Plan for the Ski and Tennis Ranch of Taos", Taos, NM, July, 1979. Resumed January, 1980. "In the Matter of the Groundwater Discharge Plan for the Bokum Marquez Uranium Mill (DP 100)", Santa Fe, NM, January, 1980. Before Minnesota House of Representatives Committee on Environment and Natural Resources Informational Briefing on Uranium Mining and Processing, St. Paul, MN, December, 1979. "In the Matter of National Pollutant Discharge Elimination System (NPDES) Permit for Bokum Resources Corporation, NPDES No. NM0028215", Santa Fe, NM, December, 1979. "In the Matter of NPDES Permit for Phillips Uranium Corporation, No.NM0028274", Santa Fe, NM, December, 1979. Before Royal Commission of Inquiry on Uranium Mining regarding Health and Environmental Protection, Vancouver, BC, Canada, December, 1979. Before New Mexico Water Quality Control Commission in Hearing regarding Selenium Standards, Part 3 103A, New Mexico Groundwater Regulations, Santa Fe, New Mexico, September 20, 1979. "In the Matter of Groundwater Discharge Plan for the Bokum Marquez Uranium Mill (DP 43)", Santa Fe, NM, May, 1979. "In the Matter of Amendments to New Mexico Radiation Protection Regulations", Santa Fe, NM, May, 1979. "In the Matter of NPDES Permit for Ranchers Exploration and Development Corporation, NPDES No. NM0026573", Santa Fe, NM, September, 1978. "In the Matter of NPDES Permit for Kerr McGee Nuclear Corporation, NPDES No. NM0020532", Santa Fe, NM, May, 1978.
|