OPPOSE DOE'S PLAN TO EXPAND WIPP

by, Don Hancock
Southwest Research and Information Center Administrator

WHAT:  The Department of Energy (DOE) has asked the New Mexico Environment Department (NMED) to change the operating permit for the Waste Isolation Pilot Plant (WIPP) so that drums of waste would be opened and examined at WIPP.  DOE has stated for years that WIPP's mission excluded opening any drums.  Further, the change would allow waste to be stored indefinitely on the surface at WIPP -- even wastes that cannot be disposed underground.

WHAT'S WRONG WITH THE CHANGE?
1.  It reverses the basic safety procedures at WIPP.  During the public hearing for the permit in 1999, the WIPP official testified, under oath:  "We never open waste containers that are received from an offsite generator....  By not opening the waste, we can eliminate the possibility of spreading contamination throughout our facility.  So not opening the containers, keeping the containers sealed, is a major -- a major strategy in our protection of human health and the environment."   Opening drums dramatically increases the likelihood of workers being contaminated with radioactive and hazardous wastes.  Opening drums dramatically increases the likelihood of radioactive and hazardous wastes being released into the environment.

2.  It gives WIPP a new, dangerous mission.  WIPP has been developed as the world's first underground repository for some wastes resulting from nuclear weapons production.  Wastes would be shipped to WIPP for underground disposal (not surface storage) from more than a dozen DOE sites after the waste was examined at those sites to insure that prohibited wastes were not shipped to WIPP.  Prohibited wastes include: high-level radioactive wastes; explosives; liquids; ignitable, corrosive, reactive or chemically incompatible wastes.  If the change is approved, prohibited wastes would be shipped to WIPP based on the generator site's (often unreliable) records that state that prohibited items are not present.  Items prohibited from underground disposal because they are too dangerous could be stored indefinitely on the surface.

3.  It increases the likelihood that deadly high-level wastes will come to WIPP.  If DOE is allowed to change a fundamental safety procedure and if prohibited wastes are allowed to be shipped to WIPP, the next likely change is to make WIPP the only site for nuclear weapons wastes and also irradiated spent fuel from nuclear power plants.  Such an expansion would greatly increase the hazards to workers at the site and to the public from waste transportation.

WHAT YOU CAN DO (before September 26, 2000):
Tell NMED to deny the change in the WIPP permit.

Write: Mr. Steve Zappe
NMED
2044A Galisteo Street
Santa Fe, NM 87505

or email: steve_zappe@nmenv.state.nm.us

For more information:  SRIC, PO Box 4524, Albuquerque, NM 87106. 
Phone: 505/262-1862. 
Email: sricdon@earthlink.net 
Website: www.sric.org

BACKGROUND INFORMATION
On July 21, 2000, DOE submitted to NMED a request for a Class 2 Modification to the WIPP operating permit to increase above ground storage capacity, remove the time limit for storing waste on the surface, and create new surface storage areas.  The change cannot be approved until after a 60-day public comment period.  NMED could deny or modify the request or it could require a public hearing, including testimony and cross-examination of witnesses.

The reason for the modification is to allow characterization (opening and examining) of waste containers at WIPP.  The WIPP permit, approved by NMED on October 27, 1999, requires that such characterization be done at the site where the waste is stored and prohibits such activities at WIPP.  The purpose of the permit requirements is to ensure that the sites actually examine waste containers and not just depend on their written records, which are frequently inaccurate, to determine what radioactive and hazardous wastes are in each drum.  Such characterization is to ensure that wastes prohibited for disposal are not shipped to WIPP. 

The prohibition on opening drums at WIPP is also a fundamental safety procedure for the facility.  DOE and Westinghouse, the operating contractor, have always said that WIPP would "start clean and stay clean."  Waste containers would be shipped to WIPP, unloaded and examined to ensure that the drums were not leaking, then taken by elevator 2,150 feet below the surface and emplaced in rooms mined out of the salt bed.   The WIPP official who testified under oath at the WIPP permit public hearing reaffirmed the long-standing safety requirement:

"We never open waste containers that are received from an offsite generator....  By not opening the waste, we can eliminate the possibility of spreading contamination throughout our facility.  So not opening the containers, keeping the containers sealed, is a major -- a major strategy in our protection of human health and the environment." 
Testimony of Robert F. Kehrman, February 22, 1999, pp. 83-84.

The proposed changes include: 

DOE has also asked for an additional change to eliminate the audit and surveillance program.  Under that program, NMED observes DOE audits of waste characterization activities at other sites to ensure that they comply with the WIPP permit requirements and approves the final audit report before the site can ship any wastes to WIPP.  Since sites would no longer do the waste characterization, there would be no such audits.

APPLICATION INFORMATION:
DOE's Class 2 modification application is on its website: <http://www.wipp.carlsbad.nm.us>.   Additional information can be obtained at the DOE WIPP Information Center, 1-800-336-9477 or NMED at 505-827-2425.