Community Relations Plan

Community Relations Plan

In November 2010, the New Mexico Environment Department renewed the WIPP Hazardous Waste Facility Permit with the U.S. Department of Energy and Nuclear Waste Partnership, LLC, for a 10-year period.

We are committed to providing you background information about the Permit, offering you updated information related to Permit actions, and keeping you informed about opportunities to participate in the Permit process as a general member of the public.

The WIPP facility resumed normal operating status in January 2017, following two events that occurred underground at the WIPP facility in February 2014.

Our highest priority is to protect human health and the environment as we continue the WIPP’s important mission.

2018 Contractor Community Commitment Plan

Community Relations Photos

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External links:


Email: CommunityRelations@wipp.ws

Phone:
Community Relations Plan
1-866-271-9640 (toll-free)

Mail
Bobby St. John
Nuclear Waste Partnership LLC
P.O. Box 2078
Carlsbad, NM 88221

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."

Posted August 2, 2016

Donald Dayton
Carlsbad, New Mexico

Thank you for a copy of your Community Relations Plan. I am retired in Carlsbad after 30 years of federal employment in Environmental Management work with the U.S. Dept. of the Interior and the U.S. Department of Agriculture at various locations around the country. My last assignment was in Santa Fe, New Mexico.

After retirement, I volunteered to serve on the "Northern New Mexico Citizens" Advisory Board to "Advise the DOE through a federally chartered formal recommendation process on environmental restoration (cleanup) and waste management activities at Los Alamos National Laboratory (LANL) and the northern New Mexico communities impacted by LANL activities, (see attached). The Board was also provided with a trip to the WIPP site, a tour underground and discussion with the WIPP environmental management. I found my two year assignment on this Committee to be very successful in providing community input from the various communities impacted by LANL activities.

I urge that you set up a similar Citizen's Advisory Board with members representing local communities surrounding and impacted by WIPP. In the long run, it can prove to be very valuable and provide a positive impact on your community relations program.

I agree to having my comments and suggestions posted on the WIPP Community Relations Plan Web Page.

Attachment:

Posted August 2, 2016

Permittees Response to Comments from
Donald Dayton
Carlsbad, New Mexico

Dear Mr. Dayton,

Thank you for your interest in the Waste Isolation Pilot Plant (WIPP) and for providing comments to the WIPP Hazardous Waste Facility Permit Community Relations Plan. The purpose of the Community Relations Plan is to offer background information about the WIPP Permit, updates on Permit actions and opportunities for public participation in the Permit process.

With regard to your interest in establishing a WIPP Citizens Advisory Board (CAB), the Permittees will certainly consider how a CAB might add value to WIPP. Through the years the WIPP Project has developed valued relations with state and local stakeholders and actively supports public participation opportunities. In addition to regulators, the New Mexico Environment Department and the U.S. Environmental Protection Agency, there are numerous autonomous agencies and organizations that review WIPP operations for safety and compliance.

We welcome your participation in the WIPP Hazardous Waste Facility Permit process and encourage you to sign up for the WIPP facility mailing list to receive notifications of Permit actions and public meetings. You may also call the toll-free Community Relations number at 1-866-271-9640 for more information.

Thank you for taking the time to provide comments.

 

Posted May 24, 2015

Lisa Chappa

I saw in yesterday's paper that you are accepting ideas on how to improve the community relations for WIPP. I would suggest that it should be a goal for the NWP to have everyone in the community have a basic understanding of what WIPP is and how it works. This will avoid any spreading of rumors and reduce any fears.

Perhaps a WIPP month would work, or you could spread it out over the year. But concentrating efforts in one month would encourage families and friends to talk about it at dinner tables and around town. get WIPP people out into the community in a united effort in one month of the year.

For students I suggest a WIPP week. Similar to Engineer's week or Math awareness month, WIPP would visit local schools and offer a hands-on curriculum for students that week. Engineer's week also has a girl day which I think is a nice component. No need to rebuild the wheel, just use their model.

You could also work with local scout groups, after school science programs, and the Boys and Girls club to offer curriculum like games which relate to nuclear power and waste which could just be incorporated into their activities. Bring in people from the National Museum of Nuclear Science to do assemblies or run an evening family science night for the community. You could even sponsor or lead a summer camp!

Some possible curriculum is here:
Exothermic Reactions:
http://www.inquiryinaction.org/classroomactivities/activity.php?id=26
What to do with Waste:
http://www.kineticcity.com/controlcar/activity_print.php?activity=2&bid=51
Model a nuclear Plant:
http://www.charlesedisonfund.org/Experiments/Edison-pdf/edison_ch8.pdf

In this same month, also attend adult groups like Rotary, Lions, Christian Women's Club, and clubs at the college. Bring activities, show power points about how things work, and be available to answer questions. Maybe you could even host a movie at the end of the month. Perhaps this could be done in collaboration with the college or the Cave and Karst institute.

I believe that if you make educating the community a goal, you will find many opportunities to do that in a fun and positive manner. This will certainly improve the community relations and benefit the community in the process. Kids will be proud that their parents work at WIPP, young people will look for education that will allow them to find jobs there, and the community in general will be more likely to embrace WIPP, even in hard times.

Thank you for the opportunity to share my opinions, Lisa Chappa

-- "Be the change you want to see in the world." -Mahatma Gandhi

Posted September 17,2015

Permittees' Response to Comments from
Lisa Chappa
Carlsbad, NM

Ms. Chappa,

Thank you for taking the time to submit comments to the Waste Isolation Pilot Plant (WIPP) Hazardous Waste Facility Permit Community Relations Plan. Your positive comments and ideas for community outreach have been forwarded to the U.S. Department of Energy's Carlsbad Field Office Public Affairs representative and Nuclear Waste Partnership's Communications Department for outreach planning purposes.

The purpose of the WIPP Hazardous Waste Facility Permit Community Relations Plan is to make Permit-related information available to members of the public and to encourage public participation in the Permit process. The Plan (www.wipp.energy.gov/WIPPCommunityRelations/index.html) offers a number of opportunities for the public to become involved in the WIPP Hazardous Waste Facility Permit process.
  • You can request to be added to the WIPP Facility Mailing List [communityrelations@wipp.ws] to receive information about upcoming permit modification requests, as well as notifications about public meetings where permit modification requests will be discussed.

  • You can subscribe to the Stakeholder E-Mail Notification Service to receive specific types of WIPP Permit information while remaining anonymous. See the following link: www.wipp.energy.gov/Stakeholders/Notice.aspx

  • You can access and download Permit information from the WIPP Permit Information Repository (http://www.wipp.energy.gov/information-repository-index.asp) which includes:
    • The latest version of the WIPP Hazardous Waste Permit
    • Proposed permit modification requests
    • The State of New Mexico's response to that request
    • Permit compliance information
    • Other categories of information

  • The Plan provides a variety of e-mail and mailing addresses, a toll-free number and telephone numbers for contacts at both the New Mexico Hazardous Waste Bureau and the Waste Isolation Pilot Plant.
We encourage your participation in WIPP Hazardous Waste Facility Permit regulatory process.

Again, thank you for your comments and your interest in the Waste Isolation Pilot Plant.


Posted May 28, 2014

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1: Southwest Research and Information Center (SRIC) continues to support the Permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

2. SRIC appreciates that comments and responses are posted under the "Comments" tab.

3. SRIC is concerned that the August 9, 2012 Response to SRIC's comment about public involvement was not incorporated into the Plan.

The Response was: The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.

However, Plan section 3.7 does not have that language, nor any other discussion of the "meetings that are not required by the Permit." Nor does the Plan contain the link to drafts of Permit modifications.

SRIC supports including the additional language stated in the August 9, 2012 Response into the Plan. SRIC supports continuing the "meetings that are not required by the Permit" and the posting on the WIPP webpage of review drafts of Permit modifications.

4. SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only
with their consent, which could be given in a similar way to that done with individual comments.

5. SRIC agrees that these comments and the responses should be posted on the Community Relations Plan "Comments" tab.

6. I am glad to discuss any of these comments or other comments

Posted May 28, 2014

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

Mr. Hancock,

Thank you for taking the time to provide comments for improvement of the WIPP Hazardous Waste Facility Permit (HWFP) Community Relations Plan. The Permittees have addressed only comments that require a response. Responses for Comments 1, 3 and 4 are as follows:


Comment 1: Southwest Research and Information Center (SRIC) continues to support the Permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

Response 1: No comments were received objecting to Plan changes proposed by the Permittees. The following 2013 proposed changes by the Permittees will be incorporated into the on-line Community Relations Plan:

  • Co-Permittee name change from Washington TRU Solutions LLC to Nuclear Waste Partnership LLC, the current WIPP Project management and operating contractor
  • Clarification to Section 3.5 of Plan that describes how members of the public may be added to FacilityMailing List
  • Clarification to Section 3.7 to describe how public viewpoints can be documented for the record
  • Changes to standardize capitalization and hyphenation


Comment 3: SRIC is concerned that the August 9, 2012 Response to SRIC's comment about public involvement was not incorporated into the Plan.

The Response was: The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.

However, Plan section 3.7 does not have that language, nor any other discussion of the "meetings that are not required by the Permit." Nor does the Plan contain the link to drafts of Permit modifications.
SRIC supports including the additional language stated in the August 9, 2012 Response into the Plan. SRIC supports continuing the "meetings that are not required by the Permit" and the posting on the WIPP webpage of review drafts of Permit modifications.

Response 3: 40 CFR 270.42 requires that public meetings "must be held to the extent practicable in the vicinity of the permitted facility" for Class 2 and Class 3 Permit Modification Requests. The Permittees consistently meet this requirement by holding public meetings both in the vicinity of the facility and in either Albuquerque or Santa Fe. Section 3.3 of the Plan describes--and provides a hyperlink to--the Information Repository where Permit Modification Requests are posted upon submittal to the New Mexico Environment Department .Sections 3.4 to 3.6 of the Plan describe how members of the public are notified regarding Permit Modification Requests and how they can become involved in public meetings.

In the development of a Permit Modification Request, the Permittees may hold pre-submittal meetings, discussions and consultations with a variety of groups, consultants and experts. Such meetings are at the discretion of the Permittees and will not be included in the Plan.

SRIC notes in Comment 3 that the Plan does not contain http://www.wipp.energy.gov/rcradox/ProposedMods.htm, where interested members of the public can review drafts of Permit Modification Requests and check for public meeting dates as stated by the Permittees in the August 9, 2012 response to SRIC.

Thank you for bringing to the Permittees attention that the link identified in the August 9, 2012 response is not posted on the WIPP HWFP Community Relations Plan Web page. The Permittees agree to revise Section 3.7 of the Plan to include the link and the following language:

Interested members of the public can review Permit Modification Requests in draft stage and prior to being
submitted to the New Mexico Environment Department at http://www.wipp.energy.gov/rcradox/ProposedMods.htm, The link provides the opportunity to submit comments on draft Permit Modification Requests to the Permittees.

Comment 4: SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only
with their consent, which could be given in a similar way to that done with individual comments.

Response 4: There are a number of issues that preclude the creation of such a list of contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. Therelist.There may be Privacy Act considerations in certain instances. The Permittees are not familiar with the charters of these groups or the programs in which they are involved. Therefore, the Permittees would have to provide nonendorsement caveats that, in the long run, may inhibit public involvement. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

A list of involved groups is available on the External Links page on the NMED WIPP Home Page.

Please let us know if you have further comments related to the Permittees responses provided herein. If not, changes described above will be made to the Hazardous Waste Facility Permit Community Relations Plan. Do we have your permission to post your comments and the associated responses to the Community Relations Plan Comment page?

Again, thank you for providing input to the Plan and your interest in the WIPP Hazardous Waste Facility Permit


Posted July 19, 2012

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1. Southwest Research and Information Center (SRIC) continues to support the permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

2. SRIC appreciates that the addition suggested in our June 2, 2011 comments in Section 1.0 has been incorporated into the Community Relations Plan.

3. SRIC is concerned that the Plan posted (http://www.wipp.energy.gov/WIPPCommunityRelations/plan.html) does not include Sections 5.1 to 5.6 of the draft plan, including the changes that were agreed to. SRIC believes that the entire Plan must be posted.

4. SRIC continues to believe that the Plan should include the fact that public involvement is encouraged through a pre-submittal meeting on draft permit modification requests and that such requests are posted on the WIPP website link "Hazardous Waste Permit - Information on Proposed Modifications" to allow additional public involvement.

5. SRIC appreciates that the addition suggested in our June 2, 2011 comments for e-mail notification was incorporated into Section 5.3 of the Plan.

6. SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only with their consent, which could be given in a similar way to that done with individual comments.

7. I am glad to discuss any of these comments or other comments.

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

Posted August 9, 2012

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

Thank you for taking the time to provide SRIC's comments for improving the WIPP Hazardous Waste Facility Permit Community Relations Plan. Listed below are SRIC's comments followed by Permittee responses.

Comment 1: Southwest Research and Information Center (SRIC) continues to support the permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

Response: The Permittees' suggested changes to the Plan in 2012 have been incorporated. There were no comments objecting to the changes which include wording to clarify that public comments should be specific to the WIPP Hazardous Waste Facility Permit (the Permit) or the Hazardous Waste Facility Permit Community Relations Plan, consistency in capitalization and a contact name change at the New Mexico Environment Department Hazardous Waste Bureau.

Comment 2: SRIC appreciates that the addition suggested in our June 2, 2011 comments in Section 1.0 has been incorporated into the Community Relations Plan.

Response: Thank you for your input.

Comment 3: SRIC is concerned that the Plan posted (http://www.wipp.energy.gov/WIPPCommunityRelations/plan.html) does not include Sections 5.1 to 5.6 of the draft plan, including the changes that were agreed to. SRIC believes that the entire Plan must be posted.

Response: The Draft Plan provided Sections 5.1 through 5.6 to demonstrate how the Permittees proposed to accomplish each of the objectives listed below:

  • Establish working relationships with communities and interested members of the public
  • Establish productive government to government relations between the U.S. Department of Energy and affected tribes and pueblos
  • Inform communities and interested parties of permit activities
  • Minimize disputes and resolve differences with communities and interested members of the public Provide timely responses to individual requests for information
  • Establish mechanisms for communities and interested members of the public to provide feedback and input to the Permittees

Following public input to the draft Plan and incorporation of public comments and suggestions, the Plan was formalized and the table of contents reorganized. Sections 5.1 to 5.6 of the draft Plan correlate to Sections 3.2 to 3.9 of the formalized Plan that is currently online. The posted Plan, in fact, contains additional information that was not proposed in the draft Plan. Pleases see Sections 2.0, 2.1, 2.2, 2.3, 4.1, 5.0 and 6.0.

Comment 4: SRIC continues to believe that the Plan should include the fact that public involvement is encouraged through a pre-submittal meeting on draft permit modification requests and that such requests are posted on the WIPP website link "Hazardous Waste Permit - Information on Proposed Modifications" to allow additional public involvement.

Response: The Permittees agree to add the following statement in Section 3.7 Public meetings:

The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.

Comment 5: 5. SRIC appreciates that the addition suggested in our June 2, 2011 comments for e-mail notification was incorporated into Section 5.3 of the Plan.

Response: Your input is appreciated.

Comment 6: SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only with their consent, which could be given in a similar way to that done with individual comments.

Response: There are a number of issues that preclude the creation of such a list of contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. There may be Privacy Act considerations in certain instances. The Permittees are not familiar with the charters of these groups or the programs in which they are involved. Therefore, the Permittees would have to provide non-endorsement caveats that, in the long run, may inhibit public involvement. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 7: I am glad to discuss any of these comments or other comments.

Response: We would appreciate your feedback regarding this response. Thank you for your continued interest in the WIPP Hazardous Waste Facility Permit Community Relations Plan.


Posted May 29, 2012

Crystal Fletcher
Carlsbad, New Mexico

I am looking for any information available:

My name is Crystal Fletcher and I am an intern at Intrepid Potash in the Environmental Dept. I would like to get a recycling program initiated at the plant and would like any information on the Program that WIPP has in place for recycling in Carlsbad. I am in search of an established plan that can serve as a mentor for research.

Any information would be greatly appreciated.

Thank you,
Crystal Fletcher

Posted May 29, 2012

Permittees' Response to Comments from
Crystal Fletcher
Carlsbad, New Mexico

Crystal,

To get you started, please access the WIPP Community Relations Plan Web page and click on "Plan" from the menu at the top. Then scroll down to Section 3.3 and there is a link to the WIPP Information Repository. Click on the link and you will see the WIPP Annual Waste Minimization Report for 2011.

I will ask the WIPP program coordinator to give you a call tomorrow.

Best Regards


Posted June 2, 2011

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1. Southwest Research and Information Center (SRIC) supports the permit requirement for a Community Relations Plan and for the Plan to be developed with community input. There are many good elements included in the draft Plan. While a concise Community Relations Plan is appropriate, SRIC believes some essential information should be added to the Draft Plan.

2. Section 1.0. SRIC suggests that two important fundamental aspects of WIPP, which are included in Permit Attachment B, should be stated in this section. "During the Disposal Phase of the facility, which is expected to last 25 years, the total amount of waste received from off-site generators and any derived waste will be limited to 175,600 m3 of TRU waste of which up to 7,080 m3 may be remote-handled (RH) TRU mixed waste. For purposes of this application, all TRU waste is managed as though it were mixed."

3. Section 5.1. Over the past several years, an important aspect of public involvement in permit modifications has been the distribution of draft permit modifications and a pre-submittal meeting. That practice should be maintained and included in the Community Relations Plan.

4. Section 5.2. The fact that the Carlsbad Field Office provides financial assistance to some tribes should be included, and the tribes currently with such agreements should be listed.

5. The Community Relations Plan web page should include an e-mail notification system to provide those who sign up with notification when the information changes.

6. The Plan should include a list of involved community groups, including SRIC, and their contact information.

7. The Plan is generally written so that a glossary may not be needed. However, SRIC suggests that the Plan include either a link to Section 1.5 of the Permit for definitions or placing those definitions as a part of the Plan.

8. I am glad to discuss any of these comments or other comments.

Don Hancock

Permitees' Response to Comments from
Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

Mr. Hancock,

Thank you for taking the time to respond with comments to the Draft WIPP Hazardous Waste Facility Permit Community Relations Plan.

SRIC provided several suggestions, which are paraphrased below and followed by the Permittees' response.

Comment 2: SRIC suggests that a statement from Attachment B of the Permit, addressing authorized WIPP waste capacities, be included in the Plan's Section 1.0 Introduction and Background.

Response: The Permittees agree to include the Attachment B Permit language regarding authorized waste disposal capacities and transuranic waste management in Section 1 Introduction and Background of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 3: SRIC suggests that the Permittees continue to host pre-submittal meetings. Pre-submittal meetings are informal meetings that provide interested members of the public the opportunity to give input to preparation of proposed Class 2 and 3 permit modification requests prior to the Permittees submitting the request to the New Mexico Environment Department for consideration.

Response: Pre-submittal meetings are a best practice offered by the Permittees that have benefitted both the Permittees and stakeholders. These meetings are not intended to replace or substitute for public meetings required by federal regulation for Class 2 and Class 3 permit modification requests. The Permittees will continue to offer pre-submittal meetings, provided that such meetings continue to add value to the permit modification process. The Permittees will not institutionalize pre-submittal meetings in the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 4: SRIC suggests that a list of the tribal governments with whom the Department of Energy's Carlsbad Field Office has cooperative agreements should be included in the Plan.

Response: The DOE Carlsbad Field Office has established cooperative agreements with tribal governments in New Mexico and other states along WIPP transportation corridors to ensure the safe and uneventful shipment of transuranic wastes to WIPP. The draft WIPP Hazardous Waste Facility Permit Community Relation Plan is universal in its approach to New Mexico residents. The draft Plan offers a web page, toll-free telephone number, dedicated email address and other means for members of the public, communities, special interest groups, government entities and tribes to seek and to receive information about permit actions.

A list of tribal governments who have cooperative agreements with the Carlsbad Field Office is not a component of this WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 5: SRIC suggests that the Community Relations Plan web page should include an email notification system to alert subscribers when changes are made to the Plan.

Response: The Permittees agree to provide sign up capabilities and an email notification system to alert subscribers to changes on the WIPP Hazardous Waste Facility Permit Community Relations Plan web page.

Comment 6: SRIC suggests that the WIPP Hazardous Waste Facility Permit Community Relations Plan should include lists and contact information for involved community groups.

Response: There are a number of issues that preclude the creation of such a list or contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. There may be Privacy Act considerations in certain instances. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 7: SRIC suggests that the Plan include a link to Section 1.5 of the Permit that provides definitions of permit language.

Response: The Permittees agree to include a link to Section 1.5 of the Permit on the WIPP Hazardous Waste Facility Community Relations Plan home page.

The WIPP Hazardous Waste Facility Permit Community Relations Plan web page will be online June 28, 2011 at www.wipp.energy.gov. The web page will offer opportunities to be notified by email or mail about current permit actions. In the interim, if you wish to receive notifications about permit actions, you may do so at the following link: http://www.wipp.energy.gov/Stakeholders/Notice.aspx.

We would appreciate your feedback regarding this response. Again, thank you for your interest in the WIPP Hazardous Waste Facility Community Relations Plan.


Posted June 2, 2011

Cathrynn N. Brown
State Representative

I realize that the WIPP budget has financial constraints and that the community relations staff is overworked, but I believe that WIPP needs to reach out to state legislators. If you haven't already invited each representative and senator on a tour, please make it a point to do so. Keep after them until they "come and see." There is resistance to all things radioactive in the minds of some northern legislators, and we need to assuage their concerns.

I have spoken with the freshman class of legislators, and these individuals would like to go on a tour of the WIPP facility (and then visit LES) in the late summer or fall. Perhaps this tour could be conducted in conjunction with a meeting of the Radioactive and Hazardous Materials Committee. (I have already broached the idea with LES.)

Thank you for inviting comments from the community.

Cathrynn N. Brown
State Representative,
District 55 Carlsbad, Loving, Malaga & Otis

Permitees' Response to Comments from
New Mexico Representative
Cathrynn Brown, District 55
Carlsbad, New Mexico

Representative Brown,

Thank you for taking the time to respond with comments to the draft WIPP Hazardous Waste Facility Permit Community Relations Plan.

In response to your suggestion that WIPP should invite state legislators to tour the WIPP facility, the Department of Energy Carlsbad Field Office (CBFO) encourages the interest of every state legislator in the WIPP project. The CBFO offers a public outreach program with a full range of WIPP informational activities that includes WIPP tours.

The WIPP Hazardous Waste Facility Permit Community Relations Plan is specific in purpose: to offer interested New Mexico residents information about the WIPP Hazardous Waste Facility Permit and to inform members of the public about opportunities for involvement in the WIPP permit process.

The Plan will provide a web page, toll-free telephone number, dedicated email address and other means for members of the public, communities, special interest groups, government entities and tribes to seek and to receive information about permit actions.

The WIPP facility tour program is not specifically part of the permit and therefore it is not included in this plan.

The WIPP Hazardous Waste Facility Permit Community Relations Plan web page will be online June 28, 2011 at www.wipp.energy.gov. The web page will offer opportunities to be notified by email or mail about current permit actions. In the interim, if you wish to receive notifications about permit actions, you may do so at the following link: http://www.wipp.energy.gov/Stakeholders/Notice.aspx.

We would appreciate your feedback regarding this response. Again thank you for your interest in the WIPP Hazardous Waste Facility Permit Community Relations Plan.


Contact-handled Transuranic Mixed Waste

"Contact-handled transuranic mixed waste" means transuranic mixed waste with a surface dose rate not greater than 200 millirem per hour. [Pub. L. 102-579 (1992)]

Remote-handled Transuranic Mixed Waste

"Remote-handled transuranic mixed waste" means transuranic mixed waste with a surface dose rate of 200 millirem per hour or greater. For WIPP, the surface dose rate shall not exceed 1,000 rems per hour. [Pub. L. 102-579 (1992)]

Facility

"Facility" or "permitted facility" means the Waste Isolation Pilot Plant (WIPP) owned by the DOE and located approximately twenty six (26) miles east of Carlsbad, New Mexico, EPA I.D. Number NM4890139088. The WIPP facility comprises the entire complex within the WIPP Site Boundary as specified in the WIPP Land Withdrawal Act of 1992, Pub. L. 102-579 (1992), including all contiguous land, and structures, other appurtenances, and improvements on the Permittees' land, used for management, storage, or disposal of TRU mixed waste.

Permittees

"Permittees" means the United States Department of Energy (DOE), an agency of the Federal government, and the owner and co-operator of the WIPP facility; and Washington TRU Solutions LLC, Management and Operating Contractor (MOC), the co-operator of the WIPP facility. References to actions taken by "the Permittees" indicate actions that may be taken by either co-Permittee.

Secretary

"Secretary" means the Secretary of the New Mexico Environment Department (NMED), or designee.

TRU Waste

"TRU Waste" means waste containing more than 100 nanocuries of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for (A) high-level radioactive waste; (B) waste that the DOE Secretary has determined, with the concurrence of the EPA Administrator, does not need the degree of isolation required by the disposal regulations; or (C) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with part 61 of title 10, Code of Federal Regulations. [Pub. L. 102-579 (1992)]

TRU Mixed Waste

"TRU Mixed Waste" means TRU waste that is also a hazardous waste as defined by the HWA and 20.4.1.200 NMAC (incorporating 40 CFR §261.3).

Contact Handled Packages

"Contact Handled Packages" means TRUPACT-II, HalfPACT, and TRUPACT-III shipping containers and their contents.

Remote-Handled Package

"Remote-Handled Package" means RH-TRU 72-B shipping container and its contents.

Containment Pallet

"Containment pallet" means a device capable of holding a minimum of one 55-gallon drum, or 85-gallon drum, or 100-gallon drum or a standard waste box, or a ten-drum overpack and that has internal containment for up to ten percent of the volume of the containers on the containment pallet.

Waste Characterization

"Waste characterization" or "characterization" means the activities performed by or on behalf of the waste generator/storage sites (sites) to obtain information used by the Permittees to satisfy the general waste analysis requirements of 20.4.1.500 NMAC (incorporating 40 CFR §264.13(a)). Characterization occurs before waste containers have been certified for disposal at WIPP.

Waste Confirmation

"Waste confirmation" or "confirmation" means the activities performed by the Permittees or the co-Permittee DOE, pursuant to Permit Attachment C7 (TRU Waste Confirmation), to satisfy the requirements specified in Section 310 of Pub. L. 108-447. Confirmation occurs after waste containers have been certified for disposal at WIPP.

Substantial Barrier

"Substantial barrier" means salt or other non-combustible material installed between the waste face and the bulkhead to protect the waste from events such as ground movement or vehicle impacts. The substantial barrier incorporates the chain link and brattice cloth room closure specified in Permit Attachment A2.

Bulkhead

"Bulkhead" means a steel structure, with flexible flashing, that is used to block ventilation as specified in Permit Attachment A2 (Geologic Repository).

Explosion-Isolation Wall

"Explosion-isolation wall" means the 12-foot wall intended as an explosion isolation device that is part of the approved panel-closure system specified in Permit Attachment G1 (Detailed Design Report for an Operation Phase Panel Closure System).

Filled Panel

"Filled panel" means an Underground Hazardous Waste Disposal Unit specified in Permit Part 4 that will no longer receive waste for emplacement.

Internal Container

"Internal container" means a container inside the outermost container examined during radiography or visual examination (VE). Drum liners, liner bags, plastic bags used for contamination control, capillary-type labware, and debris not designed to hold liquid at the time of original waste packaging are not internal containers.

Observable Liquid

"Observable liquid" means liquid that is observable using radiography or VE as specified in Permit Attachment C (Waste Analysis Plan).


The WIPP Experience