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SECTION VI -- RECOMMENDATIONS FOR ACTION

 

Actions which the public can take:

  1. The public should demand that DOE Environmental Management (DOE EM) go forward with the CRESP expert review. DOE EM promised that a panel of experts known as CRESP would review the report by Gilkeson and Citizen Action regarding defective groundwater at the MWL dump. DOE EM has since decided to delay the review. The report can be viewed at the Citizen Action website www.radfreenm.org under the section of groundwater monitoring.

     

  2. The Sandia RCRA Part B Hazardous Waste Permit requires consideration of the Long- Term Maintenance and Monitoring Plan for the Mixed Waste Landfill.

  • Demand a public hearing for the Long Term Maintenance and Monitoring Program for the MWL dump.Request that a public hearing be provided for the Permit and the Long Term

    Maintenance and Monitoring Plan.

  • Request that the Revised Draft Permit be publicly noticed for review by the public and opportunity for comment and review.

  • Advocate for complete excavation and clean up of the MWL with above-ground storage of the waste in an engineered facility on site.

     

    1. Demand a public hearing for the MWL dump as part of the Sandia hazardous waste permit process. Ask that the NMED proceed with the Sandia hazardous waste permit hearing process which has been stalled for several years.

     

    The following benefits can be had from cleanup:

  • Clean up GUARANTEES protection of Albuquerque's sole source aquifer from potential contamination from long-lived radioactive and hazardous waste buried at the dump.

  • Helps to develop new technologies that can be used to clean up hundreds of similar waste sites across the nation.

  • Sets a precedent for clean up of waste sites at Los Alamos National Laboratory that have released contaminants into the groundwater, surface waters and the Rio Grande.

  • Decreases the risks of cancer and other illnesses to surrounding communities over the long- term.

  • Releases future generations from the burdens of clean up of legacy waste from nuclear weapons production during the Cold War years.

  • Illustrates pure Sandia "can-do" engineering that's been conducted at other landfills at Sandia Nat Labs: characterize the site, dig it up, sort out, identify, characterize the waste, and recycle as much of the material as possible.

 

  1. Demand that Sandia produce the Five Year assessment report that the 2005 Final Order requires. The five year assessment has not been provided and NMED has not called for its presentation.

  2. An action for failure of NMED to comply with the RCRA program could be filed with Region 6 EPA.

  3. A lawsuit could be filed in state court for failure to comply with the Consent Order and the Final Order requirements.

  4. A lawsuit could be filed in federal district court for the failure of EPA Region 6 to maintain oversight for the RCRA program as managed by the NMED.

  5. A complaint could be filed with the DOE Office of Inspector General for the failure of Sandia Labs to protect the public from radiation by leaving Greater Than Class C Wastes in the MWL dump.

 

Past efforts with regulators have yielded few results. It is time for creative out-of-the-box strategizing to development new approaches to prevent the poisoning of Albuquerque's aquifer.

 

ACKNOWLEDGEMENT

 

Citizen Action is grateful to have been able to collaborate with Registered Geologist Robert Gilkeson. For many years Mr. Gilkeson has made a profound contribution to the review of administrative documents and writing technical documents related to the groundwater monitoring and regulation of Sandia National Laboratories' Mixed Waste Landfill, Chemical Waste Landfill and its other toxic dumps.