ML20267A620
| ML20267A620 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/22/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20267A620 (12) | |
Text
From:
Deborah Reade <reade@nets.com>
Sent:
Tuesday, September 22, 2020 6:37 AM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Attachments:
DeborahReadeHoltecComments.pdf; 2020-SE-NMThreatsMap_11x17-v6.pdf To Whom It May Concern:
I am writing to submit a public comment in response to the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec Internationals application for a license to build and operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste (NUREG-2237).
My comments (DeborahReadeHoltecComments.pdf) and an accompanying map (2020-SE-NMThreatsMap_11x17-v6.pdf) are attached. They should both be included in the Record.
Thank you, Deborah Reade 117 Duran Street Santa Fe NM 87501-1817 Phone 505-986-9284 Reade@nets.com
Federal Register Notice:
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[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Sent Date:
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9/22/2020 6:39:00 AM From:
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U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 Submitted online at:
Holtec-CISFEIS@nrc.gov September 22, 2020 RE: Docket ID NRC-2018-0052; Holtec Internationals HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico Draft Environmental Impact Statement Comment To Whom it may concern:
I am writing to submit public comments in response to the Draft Environmental Impact Statement (DEIS) (Docket ID NRC-2018-0052) regarding Holtec Internationals application for a license to build and operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste (NUREG-2237). I am strongly opposed to the Holtec storage proposal.
The federal government, the NRC, the commercial power reactors and the American public all have the same problem. High-level waste (HLW) in the form of spent nuclear fuel (SNF) is building up in reactors around the country and around the world. The government promised the reactor companies that it would solve this problem by finding a safe place to dispose this waste. The deadline for this has long since passed. Everyone except the public sees consolidated interim storage (CIS) as a nice solution which would allow this problem to be put off on future generations. But moving ahead without a safe solution for this waste is how we got here in the first placerecklessly and irresponsibly. Unfortunately, CIS is not the answer; it would simply create an even more enormous problem, create unreasonable risks, and would waste both time and money that should be spent in making storage at or near reactors safe and secure now, while we actively pursue a true solution for our nuclear waste problem.
Unfortunately, as has been too often the case with the NRC, the entire licensing approach toward Holtec is flawed, reckless, and corrupt. There are too many unresolved problems, unsupported assumptions and too many promises that everything will be worked out in the future at every level of this project. It is impossible to believe that NRC is evaluating this project seriously when critical risk assessments of potential accidents at the site or during transportation are eliminated because accidental releases just "won't happen." Perhaps some one there might remember that DOE got rid of their safety oversight group with the same assumptionthere would never be an accident at WIPP. This was just a few years before a drum exploded underground at WIPP and released hazardous and radioactive materials more than 100 miles out into the environment.
All this was caused by multiple human errors and was just as obvious 15 years before it happened as the future dangers and risks are obvious now in the Holtec project. To claim there will never be any accidents resulting in a releaseespecially when NRC is also allowing thin and damaged containers to be usedis really quite incredible, in the literal sense of the word. People at NRC can't be that stupid, so I can only conclude that the people in control just don't care. Don't care about your fellow citizens along the routes or here in my state at the final destination. Allowing this shoddy plan and skimpy DEIS to go forward almost guarantees that an accident with a release will occur in at least one of the 20 cities along the transport routes. We don't need terrorists, our government happily puts us at high risk of nuclear explosion all on its own.
Both the applicant and NRC seem to thrive on magical thinking since there is no science-based or technically based proof that any of the many major problems can or will be solved anytime soon. The applicants seem focused on profits and NRC seems focused on sweeping an inconvenient problem under the rug and everyone is happy to ignore any inconvenient facts. "Don't worry; be happy" seems to be the name of the game. What is going on here is Nuclear Safety Lite.
PUBLIC PROCESS So far NRC has provided only a pitifully few in-person hearings/meetings in New Mexico and has provided a similarly pitiful range of materials in Spanish and Diné for Low English Proficiency (LEP) persons. The latest move to provide no in-person meetings but only 5 online meetings has discriminated against the very people most affected by the project in Lea and Eddy Counties, including the large numbers of minority and LEP persons in those counties.
It has been known for years that older, poorer, minority and rural people often have inadequate connections, less familiarity with online processes, and less access to computers and the internet. Poor people can't spend a lot of money on data even if they have online access through their phones. And in southeastern New Mexico connections can be poor. The New Mexico Environment Department has come to understand this and has been providing printed materials and in-person meetings for years in this area to make up for the difficulties with online access.
Clearly NRC has ignored this and cut out the very people who should, perhaps, have the most to say about the facility. Both New Mexico's senators have also questioned this practice of eliminating in-person meetings, wondering why the rush? Why can't we wait another year until it's safe to include all the affected communities in in-person meetings? It sure feels like dealing with public participation is just a bother to NRC and that you've already made up your minds about the project. we are just an inconvenient waste of your time.
The lack of translation of materials and the lack of in-person meetings also make it clear that again, NRC, really doesn't care about LEP persons or the minority people living near the site or along the routes. This is discriminatory.
TRANSPORTATION Continuing with transportation, NRC seems content to ignore facility transportationyet this is the phase of the project that affects most people as it will impact a majority of states and will probably go through at least 20 major cities. We have learned from WIPP studies that it is the transportation phase that creates most of the negative health effects of the entire project during normal operations. Though WIPP waste is transported by truck and Holtec transportation would primarily be by rail, studies to see what and where effects would occur along the routes are critical. Most WIPP effects occur at rest and truck stops where workers can, over time, receive many times the dose a nuclear worker is allowed. The same thing could occur at rail yards and stops. Risks from accidents would also follow along the routes thus putting many millions of Americans at risk. Discrimination in the pattern of these risks will be discussed later.
NRC has declined to provide meetings along the routes, or even to designate the routes properly, trying to limit discussion to the facility itself and to ignore facility transportation completely. This is
segmentationdividing one project into smaller parts and only looking at each part independently. This is not allowed by NEPA to which the Holtec project is subject. Though there is some minor discussion of transportation in the DEIS, it is inadequate. And claiming that there will never be an accidental release during transportation is so inadequate to be, again, stupid. And embarrassing. Perhaps such unbelievable claims are made because the transportation, as proposed, is so very dangerous and NRC wants to ignore anything that will make clear how reckless and irresponsible this entire project is.
NRC seems to be following several unsupported assumptions in its approach to the safety of facility transportation. First, it is assumed that there will be no through-wall cracks in the thin-walled canisters.
Second, it is assumed that there will be no transportation accidents with canister leaks.
Finally, it is assumed that the damage caused to the canisters each time the waste is transferred will be insignificanteven though the waste will be transferred at least 4 times to Holtec, 4 more if transported to Yucca Mountain and even more times if transferred to TADs. None of these is a conservative or prudent assumption, but these are relied on in the DEIS. (For instance, the TADs aren't even addressed in the Holtec ER or the NRC DEIS even though transferring to TADs would result in significant risks.)
Canisters: It is amazing that NRC even allows the use of thin-walled, welded canisters that can't be fully inspected or repaired. The rest of the world is using canisters more than 10 times as thick that are repairable. Evidence has already shown that through-wall cracks are possible in a very short time in the thin-walled canisters. With the huge radioactive load inside each one of these canisters, a breach during transportation could wipe out large parts of Chicago or Kansas City or Albuquerque or all of Hobbs or Roswell.
To assume there will never be a transportation accident with a breach is another example of magical thinking. With 10,000 canisters or more and forty or 150 years of shipping, that's not credible. The project could even extend to more than 300 years. Train accident statistics alone show that horrendously powerful accidents with fires can occur. Look at the picture above showing a real train accident on a trestle in southeastern New Mexicopossibly along the actual route. Do you really think the fragile, damaged canisters wouldn't fail during an accident like this? Do you really think this trestle could withstand the extreme weight of the nuclear railcars trip after trip after trip? With materials this
dangerous, a conservative approach is required, yet NRC is rushing forward in a reckless way, ignoring the science and following what they want things to bethe very definition of magical thinking.
And what is Holtec's plan if a canister does arrive measurably leaking? Besides claiming this will never happen, it is to send it back, even though this is actually not allowed. To send a leaking canister out on the road seems almost criminal and is certainly irresponsible so this is really not an answer. The DEIS doesn't include hot cells or Dry Transfer Systems at the facility and plans to destroy the reactor pools before waste has all been transferred offsite. This is totally shortsighted and a recipe for disasteror multiple disasters. The DEIS must plan for the high consequence/low probability event. Pools should remain if any waste remains on site. Hot cells should be constructed wherever there is dry storage and thicker casks that can be inspected and repaired should be substituted for the weak, thin-walled canisters.
Holtec must reconfigure any storage cells and retrain their people to eliminate damage to canisters when they are stored or transferred. Without these items, the transportation portion of the DEIS is inadequate.
A proper level of risk from human error must also be included in any risk assessment. Because Holtec has already been shown to have created and used a defective basket shim design without receiving approval for its use from the NRC, an especially high human error risk factor must be added to any risk assessment for their facilities and their canisters. Although this mistake was observed in four canisters, many other canisters are using the same design which could mean many other canisters could have been shipped while flawed. The assumption of perfect performance is already a false assumption.
Railway transportation: Holtec's boosters give many reasons why the huge weight of the canisters is not a problem for railway transportation. However, again, this is wishful thinking. May of our railbeds are in such poor condition already that trains must proceed extremely slowly. This problem of rail infrastructure has been known for years. Again, look at the picture and the trestle in SE New Mexico. A comprehensive study of the condition of the railbeds, trestles, bridges etc. must be done and must include a cost estimate of the price of repairing and reconstructing this infrastructure to make it able to support shipment of 10,000 casks. Who will pay for this upgrade must also be described. Will it be left to the railroads? To the states? Construction of the facility itself should not start until all the transportation infrastructure is in place. Though HLW transportation has occurred in the past, this will take place on a much larger and more frequent level. Will there need to be dedicated rail cars and other items as they become irradiated from multiple shipments? All this must be included.
Costs: And who will pay for the transportation? Holtec says DOE will pay for it but it is not allowed to pay for transportation to a CIS when there is no permanent disposal facility. Lack of real financial information here also makes the applicationand the DEISincomplete and inadequate.
STORAGE Site location: Really, Holtec couldn't have picked a worse place for this CIS. This is the most important oil and gas producing basin in the world. Until the pandemic, more drilling was going on in Southeast New Mexico than at any point in time and historically, oil and gas production has been a primary economic support of the state through taxes and royalties. Agriculture, ranching and tourism also bring in more than $605,000,000 in income. A HLW release into the air, water or soil could have catastrophic repercussions on these industries.
Besides the danger to oil and gas development, that development itself has also affected the geology of the area.
The land is heaving and sinking throughout the Permian Basin (where Holtec is located) with major sinkholes in several places including one nearby that threatens a road and structures. This is the result of older oil and gas development. Newer development adds fracking to brine injection and both are causing an increase in man-made seismic events. Because of the enormous number of wells in the area, this is an increasing problem. There need to be more studies of seismic events of different kinds and how they will affect un-cracked as well as partially and through-wall cracked canisters. How they will affect the complete Vertical Ventilated Modules (VVM) is also important to know. And an increase in frequency and strength of these events must be assumed as they are already following that pattern. Incorporating these geological events into a study of the suitability of the site and extrapolating into the future for increased fracking and seismic events must be modeled or the DEIS will continue to be inadequate.
In addition, this is one of the largest karst areas in the world which must also be thoroughly explored.
Years of exploratory drilling and study went into the WIPP site EISs and no less should be done here.
Karst areas and areas with high resource development like southeastern New Mexico are really totally unsuitable for a waste storage or disposal facility. This alone should make the site unacceptable. A CIS shouldn't be sited in such an unsuitable location simply because ELEA owns land there. If ELEA and Holtec want to continue, they must be able to show that the site actually is suitable both in hydrology and geology and that the extensive resource development in the area will not affect the site nor be affected by the facility. This has not been adequately done in the DEIS and is another reason why the DEIS is inadequate.
Canisters: Again, we come into the problem of the canistersthese thin-walled canisters, that can't be inspected or repaired. But now we are looking at them at the proposed facility, not during transportation.
Still, NRC obdurately claims that there will never be an accidental release.
Since these will be sitting in shallow storage for possibly 300 years (according to one of the applicants) and certainly for 40 or 100 years, whether there will be leaks and cracks during this time is of paramount importance. With possible through-wall cracks in as little as 16 years, the likelihood of at least one of the 10,000 canisters having a through-wall crack seems extremely high. But again, NRC is ignoring the prudent and conservative approach and is assuming that not a single one will ever crack nor will a single canister ever leak. Again, this is incredible. This doesn't help. This is not science-based thinking.
It is reckless to allow canisters to be used at all that can't be inspected and can't be repairedespecially when thick-walled, safer canisters that can be both fully inspected and repaired are already available. It
is reckless and irresponsible to have no plan for a hot cell at Holtecthe only way to repair canisters that can be fixed. This again assumes there will never be a problem with the canisters and there will never be even a single instance of serious human error.
Instead, what is more likely to be the case is something like what occurred at the WIPP project where for 15 years the HEPA filters sat in their HEPA filter banks where everyone had forgotten to fill in the spaces between each filter. When the explosion did occur, the release went out through the filters but it also went out straight into the environment through the un-filled spaces between the filters. This is human error.
Potash: Southeast New Mexico, in the area of the site, is one of the largest potash producing areas in the world. This salt can be highly corrosive and will be continuously working to corrode the containers and the steel and low-density concrete Cavity Enclosure Container (CEC) from the outside while the radiation from the SNF will be working away to deconstruct things from the inside. Most of the length of the CEC will be exposed to these salts. Holtec claims that no water will enter the vertical ventilated modules (VVM) but a major storm event combined with a tornado (common in the area) could change that. All of this needs to be evaluated in detail; This is inadequate in the DEIS Vents: Though evidently necessary, the vents in these modules not only can let water and debris in but can certainly let radiation out. If there is a leak or worse, a hydrogen explosion, there is an easy pathway to the environment just as with the WIPP HEPA filter banks. Every vent should be filtered in case of this eventuality. Of course, if unborated water were to enter a canister by a through-wall crack, a criticality event could occur. No filters will be able to stop that. Holtec claims there has never been a through-wall crack but this is just their assumption based, again, on wishful thinking. All their claims and assumptions must be backed up by scientific studies or they should be ignored.
Permanent repository: The DEIS assumes that Yucca Mountain will open as a HLW disposal repository. However, this is disingenuous. There is no certainty that Yucca Mountain will ever open or that the canisters will be in any shape to be transported to it if it does. After 40 or 100 or 300 years the canisters might be too delicate to move again, or because the risk of another 10,000 or more shipments across the country including 4 or more transfers, might by then be recognized as being extremely dangerous under any circumstances, there is a very real possibility that this hastily conceived and cheaply built "storage" facility might become a permanent repository. Then we will have a shallow, permanent HLW disposal facilityforeverin southeast New Mexico. Then these delicate canisters will need to remain "perfect" for hundreds of thousands of years as will the monitoring and maintenance of the VVMs. That Holtec or Holtec and WCS will become permanent repositories is a credible outcome and is inadequately addressed in the DEIS.
Another unsupported assumption is that NRC and Holtec can get Congress to change the law that now prohibits DOE transportation and a CIS storage facility at all until a permanent repository actually exists.
This is just so a "temporary" CIS does not become a permanent disposal facility and NRC is trying to find a way around this law. Again, why the rush? Why not follow proper procedure and either create a permanent repository first as the law requires, or change the law first and then start the licensing process for a CIS facility?
Another possibility is that even if Yucca Mountain does open, the canisters will be too delicate to be transported that far, but that they could still be transported just a few miles to WIPP. New Mexico was promised that WIPP would never take HLW but right now DOE is working to do just that. Holtec has
promoted WIPP (a "nearby facility") for HLW disposal in their presentations even though there are serious questions about the interaction of HLW with the WIPP salt and questions about whether adding the high level waste could create accelerated escape pathways for itself and for the transuranic waste that is already emplaced there. If the canisters start to crack and leak this will seem like a great alternative to everyone but the people in New Mexico who will have to make HLW a permanent part of their lives for generations to come. Again, this is a credible outcome and is inadequately addressed in the DEIS.
ENVIRONMENTAL JUSTICE Siting: The discrimination that is occurring in the public process has been discussed above. But it is just one example of the discriminatory nature of the entire project. Will NRC choose to allow siting of this very dangerous facility not only in a geologically unstable and high resource area, but also in an area that is already overburdened by other polluting and contaminating facilities and home to a large, low-income, minority population?
Background:
On top of high levels of naturally occurring arsenic in the soil, southeastern New Mexico has been subjected to pollution and contamination from the WIPP project, URENCO, Waste Control Specialists, the Gnome-Coach Experimental Test Site (all radioactive or mixed projects) and is in the middle of the permitting process for the Triassic Park Hazardous Waste Dump. VOCs from oil refineries are spread far and wide by the high winds. Much of the land has been contaminated by radioactive particulates from first the Trinity atomic bomb test and then the WIPP explosion and release in 2014.
Solid waste dumps, oilfield "landfarms,"
massive oil and gas development and the occasional superfund site further burden the area (see the updated Southeast New Mexico Threats Map, attached).
Disparate impact (siting): Large numbers of people of color and LEP people live both near the site and within 50 miles of the site. Large numbers of people of color live or work near the railroad lines where the waste will travel.
It is the poverty, discrimination, lack of access to health care and other social factors combined with the high burden of contamination and pollution from a multiplicity of hazardous, toxic and radioactive facilities already in the site area that has resulted in some of the highest cancer mortality in the state (see the updated Southeast New Mexico Threats Map, attached). This disparate impact has existed for at least 20 years. To add another potentially contaminating facility to the area without mitigating the problems that already exist would be highly discriminatory. It is not conservative to
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assume there will never be a release. At least one release must be assumed and its burden on the surrounding population must be modeled. Until this is properly done, the DEIS will remain inadequate.
Disparate impact (transportation): Both disparate impact studies of the facility and of facility transportation must be done. Transportation must be included for both accidents and impacts from normal operations. In addition to irradiation, diesel exhaust from the additional rail traffic can alone cause a disparate negative health impact on people living or working near the routes. Understanding the extent of this exposure and studying whether environmental justice communities along the route would be disparately impacted is critical. Also, the accident risk itself, both at the site and during transportation is possibly discriminatory as it is likely a high percentage of minority and low-income people live near railroad routes not only in New Mexico but also across the country. Whether the risk burden of an accident falls more heavily on these environmental justice communities must also be studied and understood.
Social concerns: In Colonias Development council v. Rhino Environmental Services the New Mexico state supreme court ruled that not only must disparate impacts be studied when appropriate, but that social concerns must always be considered. Social concerns that communities might have include the concept of disparate impacts but also include more. Even the perception that the area has become good only as a radioactive or hazardous cesspool can affect a culture or a community. This perception can destroy the dairy, agriculture and ranching that along with tourism and oil & gas development have historically supported the economy of the southeast and indeed, of all of New Mexico. Lack of access to medical care is another social concern. When poor and minority communities have social concerns that are ignored by the applicants or by the NRC, that is discrimination.
APPLICANT ETHICS Holtec CEO Krishna Singh has been caught trying to bribe whistleblowers to keep them from revealing widespread quality assurance violations in Holtec's containers. He was implicated in another bribe to a TVA official and got caught lying about it on an official form. Why would we want to license a facility with a company that is so corrupt it has been banned and barred from doing business with the TVA?
Why would NRC have any illusions that a company like that would follow the letter of the law or put safety first? Again, NRC doesn't seem to care at all about the health or safety of the citizens of this country or their environment.
ALTERNATIVES NRC must choose the no-action alternative for this project. It is a project that has been conceived in haste and is being continued as cheaply as possible in a reckless and irresponsible way. You can't do Nuclear Safety Lite. Real safety is not cheap. This "Safety is a Journey" approach was the attitude at Los Alamos National Laboratory (LANL) and WIPP that resulted in an explosion and release. The same reckless attitude with this project could kill and disable hundreds of thousands and render southeast New Mexico uninhabitable.
This project is based very little on scientific and technical knowledge and a lot on fantasy, magical thinking, and NRC's choice to ignore the many red flags that this project waves. This is a recipe for disaster. This approach, combined with NRC's refusal to include anyone but the most minimal number of communities in the public process shows that this is a political project that NRC is pursuing to show the reactor sites that the government is at long last meeting their commitments. Somehow the people of
this country have been forgotten, as risks to those living along the routes or near the CIS site are being completely ignored.
NRC must stop wasting time on Holtec (and WCS) and start switching immediately to thick-walled containers that can be fully inspected and repaired. It is true that there are some reactor sites that are not suitable for dry cask storage facilities for various reasons. But most of the sites are suitable. HLW should remain at the site or be moved to a dry cask storage site built as close as possible to the original site to minimize transportation risks as required by the NWPA. (And built in a suitable locationnot, for instance, at what is now or soon will be the high tide line, as they've chosen to do at San Onofre.)
Hotcells should be maintained safely and securely at sites where they currently exist or be built at the nearby new dry cask storage sites so that inspection, maintenance and repair can proceed normally and without transportation of leaking containers. Reactor Pools should remain viable as long as there is waste on site. Without these capabilities, no HLW storage or disposal facility is truly safe.
We must then as a nation work on a real solution to the, admittedly significant, problems of this waste.
Sincerely, Deborah Reade 117 Duran Street Samta Fe. New Mexico 87501 reade@nets.com
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Carlsbad Environmental Monitoring
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New Mexico Institute of Mining & Technology (testing)
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White Sands Missile Range (testing)
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> 140.2 - 154.0
> 154.0 - 158.4
> 158.4 - 191.4 Quay 181.0 De Baca 168.4 Guadalupe 191.0 Otero 161.4 Sierra 191.4 Luna 189.7 Lea 157.6 Eddy 158.4 Chavez 156.0 Torrance 157.4 Cibola 158.0 Hidalgo 154.7 4HEUSESOFWATER AIRANDLANDAREDIVERSEIN.EW-EXICOANDWILLCHANGEDRAMATICALLYWITHCLIMATECHANGE&ORCARETAKERSOFTHISSACREDTRUST THISMAPOFFERSABIRDSEYEVIEWOFTHEHEALTHOFOURENVIRONMENTINSOUTHEASTERNANDSOUTHCENTRAL.EW-EXICO)TDOCUMENTSPRIMARILYENERGY RELATEDSOURCESOFPOLLUTION THOUGHIN.EW-EXICOOTHERPOLLUTINGFACTORSAREALSOATWORK4HISMAPDOESNOTCOVERABATEMENTSITES MOSTSOLIDWASTEFACILITIESANDVOLUNTARYREMEDIATIONSITES AMONGOTHERTHINGS ANDSHOWSMAJORWATERBASINSONLY4HEREISACONCENTRATIONOFHIGHCANCERDEATHRATESANDLOWLIFEEXPECTANCIESINSOUTHEASTERNANDSOUTHCENTRAL.EW-EXICO$ESPITETHESEHEALTHPROBLEMS BOTHTHEFEDERALGOVERNMENTANDTHE.EW-EXICO%NVIRONMENT$EPARTMENT.-%$ CONTINUETOPROMOTENEWSITESANDEXPANDEXISTINGONES INCLUDINGTHEEXPANSIONOFTHE7ASTE)SOLATION0ILOT0ROJECT7)00 ANDTHEADDITIONOFTWO#ONSOLIDATEDh)NTERIMv3TORAGE&ACILITIES#)3& IN3%.EW-EXICO(OLTEC)NTERNATIONAL NEAR7)00 AND7ASTE#ONTROL3PECIALISTSn7#3#URRENTLY )NTERIM3TORAGE0ARTNERSn)30 JUSTOVERTHEBORDERIN4EXAS HAVEAPPLIEDFOR.2#LICENSESTOSTOREEVERYSPENTFUELRODFROMEVERYNUCLEARREACTORINTHE534HESEFACILITIESINCLUDETENSOFTHOUSANDSOFSHIPMENTSOFTRANSURANICANDHIGHLEVELNUCLEARWASTEWHICHWILLALSOALLENDUPIN3%.EW-EXICO4HE7)00TRANSPORTATIONPHASEALREADYACCOUNTSFORALMOSTALLOFTHENEGATIVEHEALTHEFFECTSOFTHATENTIREPROJECTDURINGNORMALOPERATIONS4HOUGH7)00TRANSPORTATIONISBYTRUCKAND#)3&TRANSPORTATIONBYRAIL THEREISNOREASONTOBELIEVETHE#)3RECORDWILLBEANYBETTER4HOUGHTHE3%AND3OUTH#ENTRALAREASHAVEMORETHANTHEIRFAIRSHAREOFPOLLUTION CONTAMINATION ANDHEALTHPROBLEMS OTHERAREASOFTHESTATELIKETHE.ORTHWESTCORNERWITHTHEMETHANESPOT THE5RANIUM-INING"ELTANDTHEAREAAROUND,OS!LAMOS.ATIONAL,ABORATORY,!., AREALSOHEAVILYPOLLUTEDANDCONTAMI-NATED!MORECOMPLETEPICTUREOFTHESEENVIRONMENTALTHREATSTHROUGHOUTTHESTATECANBESEENINTHEFULLSacred Trust/New Mexico Threats Map.
.OTETHATFALLOUTFROMTHE4RINITYTESTMAYVERYWELLEXTENDSOUTHANDWESTFROMTHEhOFFICIALvPLUMESHOWNONTHISMAP!DEQUATETESTINGHASNEVERBEENDONE BUTTHOUSANDSOFPEOPLEIN,INCOLN 3IERRA /TEROAND3OCORROCOUNTIESWEREEXPOSEDANDSUFFEREDILLEFFECTSFROMTHATEXPLOSION!FTERTHETEST 'ENERAL'ROVES MILITARYDIRECTOROFTHE-ANHATTAN0ROJECT STATEDTHATANYFUTURESITEFORFURTHERATOMICTESTINGSHOULDBEhPREFERABLYWITHARADIUSOFATLEASTMILESWITHOUTPOPULATIONv4HOUGHTHE.EVADA4EST3ITEORIGINALLYMETTHISREQUIREMENT EVENMORETHANMILESWASNOTENOUGH ASVIRTUALLYEVERYPARTOF.EW-EXICOHASBEENCOVEREDBYFALLOUTCLOUDSFROMTHENUMEROUSABOVEGROUNDNUCLEARDETONATIONSTHATTOOKPLACEIN.EVADA
Credits:7EAREGRATEFULFORPROJECTFUNDINGFROMTHE-ERCY3ISTERS .ORTHEAST#OMMUNITYANDFORADDITIONALPROJECTFUNDSFROMTHE.EW-EXICO#OMMUNITY&OUNDATIONIN-APSCREATEDBY$EBORAH2EADE $EBORAH2EADE$ESIGN2ESEARCHBY#ONCERNED#ITIZENSFOR.UCLEAR3AFETY $EBORAH2EADE$ESIGN -ULTICULTURAL!LLIANCEFORA3AFE%NVIRONMENT 0ARTNERSHIPFOR%ARTH3PIRITUALITY AND.EW-EXICO)NTERFAITH0OWERAND,IGHT2ESEARCHANDDATAINTERPRETATIONBY#ARLOS"USTOS 2ESOURCE#ONSULTANTAND')33PECIALIST&ORMOREINFORMATION REFERENCES ADDITIONALCREDITSANDACTIONYOUCANTAKETOPROTECTWATER AIRANDLAND PLEASEVISITwww.earthspirituality.org, www.swuraniumimpacts.org, and www.nuclearactive.org.
Areas with high concentrations of oil and gas wells (see inset for details)
Superfund sites (existing and proposed)
Brownfields Sites contaminated with depleted uranium Sites contaminated with nuclear materials Sites contaminated with PFAS
s Cities Towns Interstates WIPP (Waste Isolation Pilot Plant) routes Impaired rivers and streams (contaminated with pollutants at levels above legal limits)
Basins Tribal lands County borders Methane hot spot (inset map)
Trinity Test fallout plume (July 16, 1945)
Estimated WIPP release plume (Feb. 14, 2014)
Sites contaminated with hazardous materials Permitted active landfills Accidental releases from petroleum tanks (historic & current)
Uranium mines (not all are included)
Mine processing sites Nuclear reactor 0
10 20 30 40 50 miles WATER, AIR AND LAND: A SACRED TRUST