June 19, 2026
Megan McLean, WIPP Program Manager
Hazardous Waste Bureau - New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87505-6303
Comments On The New Mexico Environment Department Agency-Initiated Draft
Haza...↓
Mexico
Dear Ms. McLean,
On April 23, the New Mexico Environment Department (NMED) issued a Draft Permit
proposing to require a minimum percentage of legacy shipments in the Waste Isolation Pilot
Plant (WIPP) Hazardous Waste Facility Permit (Permit). The percentage comes as an agency initiated
modification (AIM). New Mexico Hazardous Waste Regulations provide for NMED to
modify an existing permit for cause upon the receipt of information not available at the time of
permit issuance. NMED has determined there is sufficient basis for the development of this
agency-initiated modification that clarifies the priority to emplace legacy waste and reduces the
risk of Los Alamos National Laboratory (LANL) legacy waste during the current permit term.
These proposed changes that would require the Department of Energy (DOE) to ensure that
legacy transuranic waste shipments from Los Alamos are more than half (by volume) of the
annual total legacy waste shipments from all other DOE sites. I strongly support these proposed
changes.
DOE will likely claim that that they can not afford this, while spending $5B this year on nuclear
weapons pit production at LANL Cleanup is part of the job. DOE has not done the job back to
the beginning of the Cold War. Plus, DOE plans to leave 1 million cubic meters of
radioactive and hazardous waste buried in a seismic zone between a rift and a dormant
supervolcano.
I support the main proposed changes the of the Draft Permit:
From January 1, 2027 through December 31, 2031, at least 55% of the total volume of all
waste emplaced at WIPP from all generator/storage sites must be LANL legacy waste.
Beginning January 1, 2032, and until all LANL legacy waste has been emplaced at WIPP,
LANL legacy waste must be at least 75% of the total volume of waste emplaced from all
generator/storage sites.
Legacy waste currently stored above-ground at LANL Material Disposal Area-G shall be
shipped and emplaced at WIPP by July 1, 2028.
lf at any point any of those conditions are not met, all generator/storage site shipments
(with the exception of LANL) must cease until all deficiencies are cured.
An annual report, due by April 30 of each year, for each generator/storage site and for both
legacy and non-legacy waste, shall detail information needed to demonstrate prioritization of
LANL legacy waste and compliance with the requirements of this Permit section.
I believe it will be possible to get the above-ground waste out by July 1, 2028.
The AIM has no date for the buried waste to be gone. It just has requirements for the percentages
of LANL legacy waste to go to WIPP on an annual basis. A date to determine what buried legacy
waste that exists is needed. Nuclear Watch New Mexico/I suggest January 1, 2029 as the required
date to have completed this below-ground inventory.
WIPP is not a jobs program. It will be in operation long after its original completion date of 2024
as promised to the people of the State of New Mexico. It is DOE itself that has been delaying
work at WIPP by not funding WIPP adequately. DOE should be planning its next repository by
now.
Pit production is NNSA's most expensive program ever, with $5 billion to be spent over each of
the next six years and at least $60 billion over the next 20 years. There should be consideration
of how taxpayer resources would be better used to address urgent national security threats such
as cleanup, adverse climate change, and global pandemics.
The AIM reflects that the State is putting in some additional requirements because DOE didn't
do what it agreed to.
Sincerely,
(NOTE: Any Information here could become public)
P(Jam*+-
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Yes, i totally support NM DOE's conditions for disposal of transuranic waste from Los Alamos to WIPP. Thank you for standing strong on this.
Donna Detweiler
Albuquerque NM