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QUOTE OF THE WEEK
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LANL’s Central Mission: Los Alamos Lab officials have recently claimed that LANL has moved away from primarily nuclear weapons to “national security”, but what truly remains as the Labs central mission? Here’s the answer from one of its own documents:
LANL’s “Central Mission”- Presented at: RPI Nuclear Data 2011 Symposium for Criticality Safety and Reactor Applications (PDF) 4/27/11
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Banner displaying “Nuclear Weapons Are Now Illegal” at the entrance in front of the Los Alamos National Lab to celebrate the Entry Into Force of the Nuclear Weapon Ban Treaty on January 22, 2021
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Follow the Money!
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Map of “Nuclear New Mexico”
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In 1985, US President Ronald Reagan and Russian President Mikhail Gorbachev declared that “a nuclear war cannot be won and must never be fought.”
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Waste Lands: America’s Forgotten Nuclear Legacy
The Wall St. Journal has compiled a searchable database of contaminated sites across the US. (view)
Related WSJ report: https://www.wsj.com
New & Updated
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High Detections of Plutonium in Los Alamos’ Acid Canyon
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NNSA life extension program and Pentagon tail fin kit create new military capabilities
The real action will begin soon. Note the press release’s phrase “With the incorporation of a new Air Force tail kit assembly…” In its last budget request NNSA marks the following milestone “In FY 2014, NNSA will integrate the nuclear bomb assembly components and the Air Force Tail Kit Assembly into functional Compatibility Test Units (CTUs) for integration testing with Air Force nuclear certified aircraft.” NNSA FY 2014 Congressional Budget Request, page WA-32.
This is a good example of how the NNSA’s ~$10 billion B61 Life Extension Program and the Air Force’s ~$3.2 billion Tail Kit Assembly program are co-joined. Together they will create the world’s first nuclear “smart” bomb for delivery by future super stealthy F-35s (with each bomb costing more than twice their weight in gold). This clearly creates new military capabilities for an existing nuclear weapon, contrary to official U.S. policy declared at the 2010 NonProliferation Treaty Review Conference and elsewhere.
National Nuclear Security Administration
U.S. Department of Energy
For Immediate Release
August 29, 2013
Contact: NNSA Public Affairs, (202) 586-7371
B61-12 Life Extension Program Radar Drop Tests Completed Successfully
WASHINGTON, D.C. – As part of the ongoing effort to refurbish the aging B61 nuclear bomb without resorting to underground nuclear testing, two successful B61-12 radar drop tests were successfully completed at the Tonopah Test Range in Nevada on Aug. 14 and 15, 2013, by engineers from Sandia National Laboratories.
Current B61s use decades-old vacuum tubes as part of their radar system. The new radar system, which had not been tested outside of a laboratory environment, was assembled in a gravity bomb configuration and successfully functioned as it was dropped from a helicopter.
“The B61 contains the oldest components in the U.S. arsenal,” said Don Cook, National Nuclear Security Administration Deputy Administrator for Defense Programs. “As long as the United States continues to have nuclear weapons, we must ensure that they remain safe, secure and effective without the use of underground testing. The B61 has been in service a decade longer than planned, and our refurbishment program is a scientific and engineering challenge. These successful tests have given us confidence in our ability to integrate the new radar design and move forward with our efforts to increase the safety and security of the bomb.”
The Nuclear Weapons Council, a joint Department of Defense and Department of Energy/NNSA organization established by Congress, moved the B61 Life Extension Program (LEP) from the planning stages to development engineering in February 2012. The scope of this LEP includes refurbishment of both nuclear and non-nuclear components to address aging, ensure extended service life, and improve safety, reliability and security of the bomb. With the incorporation of a new Air Force tail kit assembly, the design will also enable consolidation and replacement of the existing B61-3, -4, -7, and -10 bombs by the B61-12 bomb. The LEP will reuse or remanufacture existing components to the extent possible.
This radar drop test is one of several critical milestones for the B61-12 LEP this year. Radar testing will continue with integration of other B61-12 components, including the weapon and firing control units to demonstrate the arming, fuzing and firing subsystem. The B61-12 LEP is an essential element of the U.S. strategic nuclear deterrent and of the nation’s commitments to extended deterrence and it ensures the continued vitality of the air-delivered leg of the U.S. nuclear triad.
Established by Congress in 2000, NNSA is a semi-autonomous agency within the U.S. Department of Energy responsible for enhancing national security through the military application of nuclear science. NNSA maintains and enhances the safety, security, reliability and performance of the U.S. nuclear weapons stockpile without nuclear testing; works to reduce global danger from weapons of mass destruction; provides the U.S. Navy with safe and effective nuclear propulsion; and responds to nuclear and radiological emergencies in the U.S. and abroad. Visit www.nnsa.energy.gov for more information.
Excellence Unfulfilled at the LANL’s Plutonium Facility
A Los Alamos National Laboratory fact sheet touts the Lab as a plutonium “center of excellence”. However, the Laboratory Director paused operations in the Plutonium Facility on June 27, 2013. (The Plutonium Facility, called PF-4, is located at Technical Area 55 at Los Alamos National Laboratory (LANL). PF-4 is home for the Lab’s plutonium work, including nuclear weapons component production.) The pause was based on issues identified during safety reviews and findings from recent assessments. For one, the Defense Nuclear Facilities Safety Board (Board) performed a review of the Criticality Safety Program at Los Alamos National Laboratory (LANL) in May 2013. (The Board is an independent organization within the executive branch chartered with the responsibility of providing recommendations and advice to the President and the Secretary of Energy regarding public health and safety issues at Department of Energy (DOE) defense nuclear facilities.) This review identified significant non-compliances with DOE requirements and industry standards in the Lab’s Criticality Safety Program (CSP). In addition, this review identified criticality safety concerns around operations at the Plutonium Facility. The Board noted that some of these deficiencies are long standing and indicated flaws in federal oversight and contractor assurance. Much plutonium work, especially work with a high potential for criticality, will be stopped through the rest of 2013.
Nuclear criticality safety is defined as “protection against the consequences of an inadvertent nuclear chain reaction, preferably by prevention of the reaction.” The most potentially dangerous aspect of a criticality accident is the release of nuclear radiation if it maintains a self-sustaining nuclear chain reaction.
To date, the only thing self-sustaining is the Lab’s inability to address its criticality issues and yet still convince Congress to keep funding plutonium work there. To prevent bad things from happening, DOE’s regulations and directives require contractors to evaluate potential accident conditions and put in place appropriate controls and safety measures. History shows that the Los Alamos Laboratory just cannot do this, even though much of the work is performed on plutonium pits, the primaries of nuclear weapons. Even though actual need for this work has not been proven, the Lab has entrenched itself as the only place in the country where plutonium pits can be made, developed, and tested.
For fiscal year 2014, the budget request for nuclear ‘weapons activities’ at LANL was $1.4 billion. The exact amount that is spent on plutonium operations in PF-4 is unknown to us, but the budget request for 2014 for Directed Stockpile Work, which is where major parts of the plutonium operations are located, was $460 million. This is a 23% increase over last year’s budget. The funding pours into the Lab regardless of whether the Lab is actually doing any work, which is frequently stopped.
Here’s history of criticality problems and work stoppages at Los Alamos Laboratory:
In 2005, an assessment determined that LANL’s expert-based Criticality Safety Program (CSP) was not compliant with applicable DOE requirements and industry standards.
In 2006, LANS developed a Nuclear Criticality Safety Program Improvement Plan.
In 2007, in response to concerns raised by the Board’s staff, LANL determined that the authorized loading of vault storage rooms in PF-4 could lead to a critical configuration.
In 2008, the Government Accountability Office reported concerns about nuclear safety at LANL are long-standing. Problems included 19 occasions since 2003 where criticality safety requirements were violated, such as storing materials in quantities higher than safety limits allow, 17 of 19 of the site’s nuclear facilities operating without proper safety documentation, reported inadequacies in safety systems, radiological releases, and four enforcement actions for significant violations of nuclear safety rules.
Los Alamos Report for Week Ending April 3, 2009
LANL management placed the facility in stand-by mode until roughly 125 safety evaluations could be re-evaluated.
Los Alamos Report for Week Ending October 2, 2009
The Plutonium Facility was placed in standby mode because management declared the fire suppression system inoperable based on recent hydraulic calculations that concluded the system was not able to achieve the water coverage required. LANL had performed a system adequacy analysis in 2008. The hydraulic calculation completed for the system identified that 13 of approximately 100 hydraulic areas did not meet the requirement.
Los Alamos Report for Week Ending October 16, 2009
A general evacuation alarm was caused by a Criticality Alarm System signal because of a loss of all facility ventilation and failure of the Facility Control System at the Plutonium Facility. The facility was in standby mode during this event due to previously identified issues with the fire suppression system and, therefore, limited personnel were in the facility.
Los Alamos Report for Week Ending September 10, 2010
Operations in Plutonium Facility were suspended because potentially explosive ammonium nitrate was discovered in two filter ducts.
Los Alamos Report for Week Ending December 3, 2010
It was revealed that greater than 1000 items, or about 20%, of the total vault holdings are items packaged in potentially vulnerable containers with taped slip-top lids rather than in robust safety-significant containers that include a HEPA-filtered vent. The presence of these slip-top containers requires respirator use whenever operators access the vault. In FY10, LANL made meaningful progress in addressing these legacy materials.
In 2011, an event occurred at PF-4 in which fissile material handlers violated procedural requirements and criticality safety controls while moving and photographing plutonium rods.
Beginning in 2012, LANS experienced an 18-month exodus of criticality safety professionals from its criticality safety group. LANS currently employs 2 full-time and 2 part-time qualified criticality safety analysts, in addition to 3 part-time subcontractors—far fewer than the 17 criticality safety analysts it has determined to be necessary to support operations, meet mission goals, and maintain the CSP.
Los Alamos Report for Week Ending April 20, 2012
Plutonium Facility personnel use a software program called MAR Tracker to track plutonium that is used in the facility. A system engineer discovered an error in
MAR Tracker that caused only a small subset of applicable facility containers (roughly 1700 out of 13000 containers) to be checked during the required annual MAR surveillance. The Plutonium Facility was placed in Standby Mode.
Los Alamos Report for Week Ending June 15, 2012
LANL identified a number of fuel rods in TA-35 Building 27 that were not consistent with the criticality safety evaluation for the facility. Operations at this building had previously been suspended in late-May due to the discovery of three fuel rods that were not in the facility or institutional tracking systems.
Los Alamos Report for Week Ending December 14, 2012
LANL identified that the Criticality Safety Evaluations (CSEs) for two rooms did not adequately address the potential for interaction effects between storage locations. Plutonium Facility management suspended operations in these two vault rooms.
Los Alamos Report for Week Ending February 15, 2013
LANL began a focused training program (“boot camp”) to provide an intensive learning environment for new criticality safety staff. The program consisted of nine modules including: nuclear theory; criticality safety calculation methods; ANSI/ANS, DOE and LANL criticality safety standards and requirements; criticality safety evaluations; and criticality alarm and detection systems. This program along with on-the-job training and performance demonstrations was to provide a mechanism for achieving full qualification as a LANL criticality safety analyst. Conduct of the boot camp was part of the LANL corrective action plan for improving the nuclear criticality safety program.
Los Alamos Report for Week Ending May 3, 2013
The laboratory completed criticality safety assessments at LANL nuclear facilities. The review teams identified 3, 4, and 6 findings for TA-55, CMR, and Area G, respectively. In all cases, the assessments concluded adequate implementation of the Criticality Safety Program with the exception of identified findings. Notably, one of the findings at Area G identified that supervisors and operations center personnel did not have an adequate understanding of criticality safety requirements. Area G management paused operations based on this finding and conducted appropriate training to resolve this issue.
In May 2013, the staff of the Defense Nuclear Facilities Safety Board (Board) performed a review of the Criticality Safety Program at Los Alamos National Laboratory. This review identified significant non-compliances with applicable Department of Energy requirements and industry standards in the implementation of the Criticality Safety Program. The Board’s staff identified the following non-compliances during its review:
• Most criticality safety controls are not incorporated into operating procedures.
• Operators typically do not utilize written procedures when performing work.
• Fissile material labels do not list parameters relevant to criticality safety (e.g., mass).
• Some fissile material operations lack Criticality Safety Evaluations (CSEs).
• Some CSEs do not analyze all credible abnormal conditions.
Los Alamos Report for Week Ending June 28, 2013
The Laboratory Director paused programmatic activities at the Plutonium Facility. The pause was directed based on issues identified during procedural and criticality safety reviews and findings from recent assessments. Reviews at PF-4 have identified a number of procedural issues and the need for clarification and improvement of criticality safety controls.
Los Alamos Report for Week Ending July 26, 2013
Plutonium Facility personnel identified several criticality safety issues associated with recent construction activity. Even though plutonium work was paused, the Laboratory Director and the Facility Operations Director (FOD) approved construction activities that had the potential to affect nuclear materials.
For more information, please read the LAMonitor article By John Severance
Safety board visits LANL
Nuclear weapons are “the world’s most heinous weapons”
Secretary of State John Kerry correctly condemned the Syrian regime’s apparent use of chemical weapons, but he’s wrong calling them “the world’s most heinous weapons.” Instead that awful distinction belongs to nuclear weapons, a class of weapons far above any other. If ever used again nuclear weapons would indiscriminately kill far more people, including women, children and non-combatants, than chemical weapons ever could, and poison the planet with radioactive fallout. Nevertheless our country is planning repeating cycles of “Life Extension Programs” costing $100 billion or more, giving existing nuclear weapons new military capabilities. This is directly contrary to what Kerry’s predecessor ex-Secretary Hillary Clinton declared as official U.S. policy at the 2010 NonProliferation Treaty Review Conference.
The cost of the mismanaged Los Alamos and Sandia Labs’ Life Extension Program for the B61 nuclear bomb has more than doubled from $4 billion to $10 billion. A related $3.2 billion Pentagon program will produce a new tail fin guidance kit. Together these programs will create the world’s first nuclear “smart” bomb for delivery by future super stealthy aircraft, while each bomb will cost more than twice their weight in gold.
The U.S. should review its own moral authority while preparing for military action in Syria. In particular our New Mexican congressional delegation must stop automatically supporting expanded nuclear weapons programs without deeply questioning their own consciences. Our politicians’ justifications to date have been to protect a few hundred jobs at the Labs, which don’t really trickle down to average New Mexicans anyway.
As evidence of the lack of broad benefit to New Mexicans, according to the U.S. Census Bureau our state was 37th in per capita income in 1959. In 2010 we were 44th, despite the vaunted economic presence of the nuclear weapons industry in New Mexico, and in 2013 we were rated dead last for the well being of our children by the KIDS COUNT Data Center. Our politicians should be striving mightily that New Mexicans increasingly benefit from our vast renewable solar, wind, biomass and geothermal resources that would employ far more citizens, instead of pandering to nuclear weapons programs that produce a commodity that we can only hope will never be used.
On my soap box about Sandia Labs
John Fleck of the Albuquerque Journal had an article today entitled “Sandia Labs manager gets 6 more months,” describing Lockheed Martin’s half year contract extension. John knows all three nuclear weapons labs well, and I won’t be telling him things that he doesn’t already know. But I’ll use his article as an excuse to stand on my soap box about Sandia Labs.
To my taste, John’s article makes Sandia sound a little too benign with phrases like “the nuclear weapons research center” and “Sandia is one of the nation’s three nuclear weapons design and maintenance laboratories.” What is left unreported is that Sandia is a major production site that, for example, manufactured 850 neutron generators for nuclear weapons in 2010, and loads them with radioactive tritium. In addition to design responsibility for non-nuclear components, Sandia’s secondary mission has long been “weapons effects” research for making sure nuclear weapons continue to work in lethal radiation environments. This enables multi-strike nuclear warfighting rather than the simple deterrence sold as doctrine to the American public.
Further, instead of mere “maintenance,” all three nuclear weapons labs (Sandia, Los Alamos and Lawrence Livermore) are lobbying for a never-ending cycle of so-called Life Extension Programs that will intentionally introduce profound changes to existing nuclear weapons. Major changes are the last thing we should do to a stockpile that has been extensively tested and proven to be even more reliable than previously thought, when we can no longer full-scale test. All of this will be of enormous expense to the American taxpayer, where for example the currently proposed Life Extension Program for the B61 bomb has exploded in costs from $4 billion to more than $10 billion, resulting in each bomb costing twice its weight in gold. Added to this is a related $3.2 billion Pentagon program giving the B61 a new tail fin guidance kit, transforming it into the world’s first nuclear “smart” bomb for delivery by planned super stealthy aircraft.
In addition to prolonging their service lives for 30 years or more, these Life Extension Programs have and will create new military capabilities for existing nuclear weapons, despite denials at the highest levels of the U.S. government to the world at large (for example, at the United Nations’ 2010 NonProliferation Treaty Review Conference). The lab directors wear two hats, the first as directors who are required to annually certify to the president and Congress that the nuclear weapons stockpile is safe, secure and reliable. The second hat is that as presidents of the executive board of the for-profit corporations running the labs, which will directly benefit from never-ending Life Extension Programs that may actually undermine stockpile reliability. So far from mere “research” and “maintenance” we have a deep seated conflict-of-interest driven by profit that will stymie our global leadership toward getting rid of nuclear weapons while continuing to fleece the American taxpayer.
Foremost in this is the Sandia National Laboratories, which amongst the three labs now has the largest nuclear weapons budget. In the past, Sandia has been singled out as a model of lab mission diversification, with its total annual institutional budget falling below 50% nuclear weapons. That is no longer true given recent large increases to its nuclear weapons research and production programs, which now comprise ~55% of Sandia’s total budget.
Nuclear weapon research at the universities
A July 5th article in the Deseret News reported on an NNSA program that gives millions of dollars to universities for “predictive science”, which is defined as:
Predictive science is the application of verified and validated computational simulations to predict the behavior of complex systems where routine experiments are not feasible. The selected PSAAP II centers will focus on unclassified applications of interest to NNSA and its national laboratories — Lawrence Livermore National Laboratory, Los Alamos National Laboratory and Sandia National Laboratories.
Funny, nuclear weapons are not mentioned.
The good news, and few know this better than Utah, is that testing nuclear weapons no longer requires full-scale explosions. The bad news is that predictive science, to the NNSA, is the “science” of predicting whether nuclear warheads will work after they have been refurbished, modernized, and given new military characteristics. We know that the old versions work. Do the students know that they helping to prolong the nuclear menace by testing newly designed versions of the old weapons on their computers?
It should be called nuclear weapons perpetuating science 101.
New Mexico Members of Congress Vote for Exorbitant Nuclear Bomb While State Is Ranked as the Worst for Children
Yesterday all three House members of the New Mexican congressional delegation voted against an amendment that would cut money added to a wasteful nuclear weapons program. In April the Obama Administration asked for $537 million in fiscal year 2014 for a “Life Extension Program” for the B61 Cold War nuclear bomb, 45% above the 2013 level. The House Appropriations Committee added $23.7 million to that bloated request, which the amendment would have cut. Overall, the B61 Life Extension Program has exploded in estimated costs to where each warhead will cost twice their weight in gold just to “refurbish” (which does not include original production and ongoing maintenance costs).
The sponsor of the amendment, Rep. Mike Quigley, D-Ill., testified during floor debate:
At a time when we are slashing funds for disease research at the NIH [National Institute of Health], failing to fund our crumbling infrastructure, and underinvesting in our children¹s education, we are increasing funding to keep hundreds of nuclear bombs in operation that we will never use. The Cold War is over.
The Albuquerque Journal reported that Rep. Ben Ray Luján, D-N.M.,
…supported the full $551 million for the B61 Life Extension Program because it is a national security priority. “This funding is important for Los Alamos and Sandia labs’ effort to ensure the safety of the nuclear weapons stockpile, and cuts to that funding impact the ability to keep it secure,” Luján said.
Rather just ensuring safety and security the program will radically improve the bomb, giving it new military capabilities by turning it into a precisely targeted smart bomb and mating it to future bombers for supersonic stealthy delivery. Currently the main mission of B61 bombs is as tactical nuclear weapons in NATO countries, a relic of the Cold War. Improved B61’s fly in the face of Obama’s newly declared goal of reducing the presence of battlefield nuclear weapons in Europe, even as he proposes to negotiate with the Russians for further arms reductions. Moreover, if security is really the issue, the sure solution that saves taxpayers money and encourages nonproliferation is to withdraw the nuclear bombs from forward deployment in Europe, where a few years ago protesting peace activists were able to infiltrate within a few hundred yards of them.
Ironically, the B61 Life Extension Program may actually undermine our own national security by introducing major changes to existing bombs. Our stockpile has been extensively full-scale tested, and repeated studies have found our nuclear weapons to be even more reliable than previously believed. The Los Alamos and Sandia Labs propose to create a “frankenbomb” by mixing and matching four variants of the B61 bomb into a single new modification. Common sense dictates that the last thing we should do while seeking to maintain confidence in our reliable nuclear weapons stockpile is to introduce major changes that can’t be tested.
Our New Mexican congressional delegation represents a state that was just ranked as the worst of all fifty for the well-being of its children, where more than 25% live in poverty. In stark contrast, Los Alamos County, dominated by the lab, is the second richest county in the entire USA. Nuclear weapons programs are a poor producer of jobs, where for example according to the government’s own documents a new $6 billion plutonium facility was not going to produce a single new permanent job at Los Alamos Lab.
Contrary to the claimed economic benefits of the Los Alamos and Sandia Labs, New Mexico as a whole continues to fall from 37th in per capita personal income in 1959 to 44th in 2011. Nevertheless, the Labs have always had inordinate influence over New Mexican politicians. One extreme example is the recent starling revelation that in between unsuccessful Senate campaigns former Rep. Heather Wilson was paid more than $450,000 by the Los Alamos and Sandia Labs for “consulting” contracts that had no written work requirements.
The nuclear weapons labs have voracious appetites for federal funding, with their directors simultaneously acting as the presidents of the executive board of the for-profit limited liability corporations that run the labs (those private LLCs pay 2/3’s of the directors’ annual compensation of around one million dollars). Business will boom with never-ending Life Extension Programs, and Sandia and Los Alamos are not satisfied with just one Life Extension Program for the B61. They already plan yet another one 20 years from now that initial figures indicate would be even more expensive. In fact, the labs plan a never-ending cycle of Life Extension Programs that intentionally seek to implement major design changes for all existing types of nuclear weapons in our stockpile, costing at least $60 billion (while the doubling of costs has so far been the rule).
Jay Coghlan, director of Nuclear Watch New Mexico, commented, “Congressman Ben Ray Luján should ask himself the question what good does a Cold War nuclear bomb that the for-profit labs want to endlessly tinker with do for New Mexican children? Pork for the labs should not drive nuclear weapons policies, especially when it’s of little if any tangible benefit to average New Mexicans. Luján should, instead, dedicate himself to boosting funding for programs that would really help our children but are facing painful sequester cuts, such as education, medical care and food assistance. Those investments would really brighten their future, and help raise New Mexico from its shameful position as the worst state for kids.”
# # #
See House rejects effort to trim $23.7M in funding for B61, Michael Coleman, Albuquerque Journal, July 11, 2013.
For New Mexico’s ranking as the worst state for kids see Kids Count Data Center http://datacenter.kidscount.org/updates/show/20-2013-data-book-rankings
For the scope and schedule of perpetual Life Extension Programs for existing nuclear weapons see NNSA’s FY 2014 Stockpile Stewardship and Management Plan
https://nukewatch.org/importantdocs/resources/SSMP-FY2014.pdf
NM Environment Department Reclassifies WIPP Request!
Thanks to everyone’s work, the NM Environment Department has decided to get more information before allowing any leaky Hanford high-level tank waste to come to New Mexico!
NMED issued its determination to reclassify the DOE request as a class 3 – which requires a public hearing – “because there is significant public interest.”
Public comments made the difference!
There will be much more to do.
See https://nukewatch.org/watchblog/?p=1503 for background.
From the NMED release –
July 2, 2013
RE: ELEVATION OF CLASS 2 MODIFICATION TO REMOVE EXCLUDED WASTE PROHIBITION WASTE ISOLATION PILOT PLANT
…
The New Mexico Environment Department (Department) received a permit modification
request dated April 8,2013 from the U.S. Department of Energy Carlsbad Field Office and
Nuclear Waste Partnership, LLC (the Permittees) on April 9,2013. The Permittees seek to
modify the Waste Isolation Pilot Plant (WIPP) Hazardous Waste Facility Permit (Permit) and
request that the Department process the request as a Class 2 modification under the
regulations at 20.4.1.900 NMAC, incorporating 40 CFR § 270.42(b).
The request modifies the prohibition of excluded waste from the WIPP Permit.
…
Page 2
Under 40 CFR § 270.42(b)(6)(i)(C), the Secretary may determine that the modification
request must follow the procedures in § 270.42(c) for Class 3 modifications for the following
reasons: (1) There is significant public concern about the proposed modification; or (2) The
complex nature of the change requires the more extensive procedures of Class 3.
In this matter, I have determined that it is appropriate for the Department to process the
modification request as a Class 3 modification under 40 CFR § 270.42( c) because there is
significant public interest.
If you have questions regarding this matter please address them to Trais Kliphuis, of the
Hazardous Waste Bureau, at 476-6051 or [email protected].
Sincerely,
Ryan Flynn
Cabinet Secretary-Designate
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CRITICAL EVENTS
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New Nuclear Media: Art, Films, Books & More
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