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Community Comments

Posted July 12, 2017

Don Hancock
Southwest Research and Information Center
Albuquerque, NM

Southwest Research and Information Center (SRIC) provides the following comments on the proposed Updates for the Community Relations Plan.

1. SRIC does not understand the proposed changes to Section 2.1. Without explanation, the changes should not be approved.

The proposed deletion of "the facility" and replacement with "purposes" is unnecessary and could be confusing. It is unnecessary because "facility" better describes WIPP than does "purposes" (which are undefined) in the Plan and could be confusing. SRIC does not believe any changes are necessary in the existing language. But a better alternative would be:

"...for the WIPP facility to safely dispose of defense transuranic (TRU) waste."

The proposed additional sentence is not necessary and conveys the incorrect impression that there is no water in the formation, which is not true. There are interstitial drops of water in the formation.

2. SRIC does not understand the reason(s) to delete sentences in Section 2.2. Without explanation, the changes should not be approved. The two sentences are correct and provide information not otherwise contained in the Plan, so the effect of deleting the sentences is to provide less information to the public.

3. SRIC does not object to the other proposed changes.

SRIC also suggests that future updates provide some basis for additions and deletions to the Plan, as part of the effort to inform the public in a "transparent manner."

Thank you for your consideration.


Posted July 12, 2017

Permittees Response to Comments from
Don Hancock
Albuquerque, New Mexico

Dear Mr. Hancock,

Thank you for providing comments to the WIPP Hazardous Waste Facility Permit Community Relations Plan. The Permittees will respond to your comments in the order they were received.

Comment 1a:The proposed deletion of "the facility" and replacement with "purposes" is unnecessary and could be confusing.

Permittees response:
The reason that “the WIPP facility” was replaced with “purposes” is that “the WIPP facility” ended one sentence and the next sentence began with the same words. The author felt it was repetitive. Searching for an alternate phrase, the  author chose “purposes” which can be found in Public Law 102-579 Sec.3, a. (3) Land Withdrawal and Reservation For WIPP which states, “Such lands are reserved for . . . construction, experimentation, operation, repair and maintenance, disposal, shutdown, monitoring, decommissioning, and other authorized activities associated with the purposes of WIPP  as set forth in section 213 of the Department of Energy    National Security and Military Applications of Nuclear Energy Authorization Act of 1980.” 

The Permittees agree to change the sentence to read: “In 1992, Congress withdrew 16 sections of land from the public domain to be used by the DOE for the purposes of fulfilling the WIPP mission of safely disposing of defense TRU waste.”

Comment 1b: The proposed additional sentence is not necessary and conveys the incorrect impression that there is no water in the formation, which is not true. There   are interstitial drops of water in the formation.

Permittees response:
The Permittees suggest an alternate change: “The formation, which has existed for more than 250 million years, also demonstrates an absence of water as a viable pathway to the accessible environment, which ensures long-term isolation of TRU mixed waste constituents.”

The Permittees believe the added sentence better explains why the salt formation, in which the WIPP repository is located, will safely contain radionuclides for10,000 years and beyond.  

Comment 2: SRIC does not understand the reason(s) to delete sentences in Section 2.2. Without explanation, the changes should not be approved. The two sentences are correct and provide information not otherwise contained in the Plan, so the effect of deleting the sentences is to provide less information to the public.

Permittees Response:
The author’s intent was to provide a more concise and accurate definition of TRU mixed waste. The Permittees agree to leave the two existing sentences but propose a change to the second sentence: “The WIPP Permit is required to manage and dispose of these TRU and hazardous wastes as TRU mixed waste, which is waste that contains both radioactive and hazardous components.”  

Please let us know if our responses resolve your comments. We appreciate your perspective. Do we have your permission to post your comments and our responses to them?
Thank you.

 

Posted July 12, 2017

Don Hancock (Second Set of Comments)
Southwest Research and Information Center
Albuquerque, NM

Thanks for your responses. You certainly may post and make public our comments and your responses.

The proposed revision in response to comment 1.a. is acceptable.

The proposed revision in response to comment 1.b. is not acceptable and is more of an "advocacy" argument rather than a factual statement, especially the last phrase: "which ensures long-term isolation of TRU mixed waste constituents."

SRIC objects to that last phrase and requests that it not be used. Ensuring long-term isolation should include an explanation of the hundreds of oil and gas wells surrounding the site, and oil and gas resources below the WIPP repository horizon. 
The proposed revision to comment 2 is acceptable.


Posted July 12, 2017

Permittees Response to Second Set of Comments from
Don Hancock
Southwest Research and Information Center
Albuquerque, New Mexico

Comment 1b: The proposed revision in response to comment 1.b. is not acceptable and is more of an "advocacy" argument rather than a factual statement, especially the last phrase: "which ensures long-term isolation of TRU mixed waste constituents."

Permittees Response:

Mr. Hancock,

Thank you for your comments. The Permittees agree to delete the proposed sentence: "The formation, which has existed for more than 250 million years, also demonstrates the absence of water.”

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