hwbdocuments.env.nm.gov isolation pilot plant/180404.1.pdfi \ -no to more waste at wippi i oppose...

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(Return Address) &J;,,,1 Pt Z:,.,,r /v '/1-( i 1 ''? '"" Mr. Ricardo Maestas New Mexico Environment Departm 2905 Rodeo Park Drive East, Building Santa Fe, NM 87505 180404.1 I\\\\\\\\\\\ \\Ill \\Ill\\\\\ \\Ill\\\\\\\\\\ II\\\\\\

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(Return Address)

&J;,,,1 Pt Z:,.,,r /v'/1-( i 1 ''?

'"" ~ Mr. Ricardo Maestas New Mexico Environment Departm 2905 Rodeo Park Drive East, Building Santa Fe, NM 87505

180404.1

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

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I ask N.fyf ED to deny that PMR. t'~ " IJ· ·'

If ttl!f R.fyi'R is not denied, it must be a €fass 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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Mr. Ricardo Maestas

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" ,.,

... ', f' . Permit Modification Request (PMR). . ~ '·

,.,,. I ask NMED to deny that PMR. ,.

'If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 25 percent. Any such change requires a public hearing.

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Mr. Ricardo Maestas <!"

New Mexico Environment Departme 2905 Rodeo Park Drive East, Building Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

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' . I as~ NMED to deny that PMR.

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If the PMR is not denied, it must be a Class 3 PMR because there is

·"' significant public concern. Further, (

it would increase the WIPP capacity by lllqre than 2 5 percent. Any such ch.•~g~ ~equires a public hearing.

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NO TO MORE WASTE AT WIPPI I oppose the "Volume reduction"

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·rask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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(Return Address)

Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI

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I oppose the "volume reduction" Permit Modification Request (PMR).

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I ask,NMED to deny that PMR.

If~he PMR is not denied, it must ,, be a Class 3 PMR because there is

significant public concern. Further, it would increase the WIPP capacity by more than 25 percent. Any such change requires a public nearing.

(name)

(address) -(city, state, zip)

(signature)

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lD M Ricardo Maestas "' r. . nme N Mexico Env1ro . ew kDnve 2905 Rodeo Par

NM 87505 Santa Fe,

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NO TO MORE WASTE AT WIPPI

. l oppose _the "volume reduction" · Permit Modification Request (PMR).

I ask NM,J~P to deny that PMR. ..... -·

If the: PMR is not denied, it must be a .. Class 3 PMR because there is silJD~flc:ant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public ·c.011.cern .. Further, it would increase th~ -WIPP capacity by more than 25 P.erceJ)t. Any such change requires a ·public hearing.

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-,~~d (~ Mr. Ricardo Maesras---New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it woulsl increase the WIPP capacity by more than 2,5 percent. Any such change .requires a public hearing .

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO -'··TO MORE •' . ~· . ~,.

··WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 25 percent. Any such change requires a public hearing.

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I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

,., .. I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WI PP capacity by more than 25 percent. Any such change requires a public hearing.

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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(Return Address)

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

(name)

(address)

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT . WIPPI

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I oppose the "volume reduction"'' Permit Modification Request (PMR).

· I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR beca1i~e there is

·'"' . significant public concern. Further, it would increase the WI.PP ccipacity by more than 2 5 perce~t)\ny such change requires a public hearing.

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• . Ms. Betty Richards 1010 Center Ave

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE ~AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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C' I IV Mr. Rica aestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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.NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 25 percent. Any such change requires a public hearing.

(Return Address)

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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f. 0. Po e -z._ 3=s._ (Return Address)

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Mr. Ricardo Maestas New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

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NO TO MORE WASTE AT WIPPI I oppose the "volume reduction" Permit Modification Request (PMR).

I ask NMED to deny that PMR.

If the PMR is not denied, it must be a Class 3 PMR because there is significant public concern. Further, it would increase the WIPP capacity by more than 2 5 percent. Any such change requires a public hearing.

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(name)

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(city, state, zip)

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.i EI~TERED From: To:

Maestas. Ricardo. NMENV BiswelL David, NMENV

Subject: FW: Deny 'Volume Reduction' Permit Modification Request Wednesday, April 04, 2018 8:37:43 AM Date:

From: Robb Chavez [mailto:[email protected]]

Sent: Tuesday, April 03, 2018 5:18 PM

To: Maestas, Ricardo, NMENV <[email protected] us>

Cc: Robb Chavez <[email protected]>'

Subject: Deny 'Volume Reduction' Permit Modification Request

I ask the New Mexico Environment Department to deny the 'volume reduction' permit

modification request .

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

Robb Chavez

515 12th St. SW

Albuquerque, New Mexico, 87102

180405

\ \\\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\ \\\\

From: To: Subject: Date:

Maestas. Ricardo, NMENV Biswell. David. NMENV FW: deny volume reduction permit request Wednesday, April 04, 2018 8:36:42 AM

From: Ernest Sturdevant [mailto:[email protected]]

Sent: Tuesday, April 03, 2018 6:59 PM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: deny volume reduction permit request

Ricardo,

I ask the New Mexico Environment Department to deny the 'volume reduction' permit

modification request .

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

Ernest W Sturdevant

3212 Georgia St NE

Albuquerque, NM 87110

505-321-8479

From: To: Cc: Subject: Date:

April 3, 2018

R Gardner Maestas. Ricardo. NMENV Don Hancock WIPP Volume Reduction PMR Tuesday, April 03, 2018 8:25:38 PM

Mr. Ricardo Maestas

New Mexico Environment Department

2905 Rodeo Park Drive East, Building 1

Santa Fe, NM 87505

[email protected]

RE: WIPP "Volume Reduction" PMR

Dear Mr. Maestas:

The undersigned groups, representing thousands of New Mexicans, strongly oppose the

"Volume Reduction" Permit Modification Request (PMR) that the Waste Isolation Pilot Plant

(WIPP) permittees submitted to the New Mexico Environment Department (NMED) on

January 31, 2018.

While there are many problems with the request, there are two overriding reasons that NMED

must either deny the request or determine to follow class 3 modification procedures, so that

additional public comment is allowed and a public hearing would be held on a draft permit.

First, the permittees - U.S. Department of Energy (DOE) and Nuclear Waste Partnership­

were told by numerous organizations before submitting the request, that the very substantial

changes in the WIPP Permit are strongly opposed and there is significant public concern. By

regulatory definition, such a request is a Class 3 modification. Nonetheless, the permittees

submitted the request as a Class 2 modification. State regulations 20.4.1.900 NMAC

(incorporating 40 CFR §270.42(b)(6)(i)(B) and (C)) provide that the NMED must deny the

request or determine that the procedures for Class 3 modifications apply. Thus, NMED must

take one of those two actions.

Second, the request seeks to very significantly change the way the volume of waste at WIPP is

measured in order to substantially increase the facility's capacity. Since before WIPP opened

in 1999, the waste volume is measured by the size of the outer container. That measurement

has always been included in the WIPP Permit, and it is that way that DOE has reported to

Congress how much waste is disposed at WIPP. The proposed new measurement of the

volume of waste inside a container results in "reducing" the amount of waste in WIPP by more

than 930,000 cubic feet. The effect would be to immediately increase WIPP's capacity by that

amount. Such an expansion of WIPP's capacity is a clear attempt to circumvent the WIPP Land

Withdrawal Act capacity limit of 6,200,000 cubic feet. Section 7(a)(3). Such a major change is

unacceptable, apparently contrary to law, and the PMR should be denied.

We ask you to deny the request or determine to consider it under Class 3 modification

procedures.

Sincerely,

Janet Greenwald Joni Arends

Citizens for Alternatives to Radioactive Dumping (CARD) Concerned Citizens for Nuclear

Safety (CCNS)

Albuquerque, NM Santa Fe, NM

[email protected] [email protected]

Scott Kovac Don Hancock

Nuclear Watch New Mexico Southwest Research and Information Center

Santa Fe, NM Albuquerque, NM

[email protected] [email protected]

Rose Gardner

Alliance for Environmental Strategies

Eunice NM

[email protected]

From: To:

Maestas. Ricardo. NMENV Biswell. David. NMENV

Subject: FW: Deny permit request please Wednesday, April 04, 2018 8:34:28 AM Date:

From: Justin Remer-Thamert [mailto:[email protected]]

Sent: Tuesday, April 03, 2018 8:35 PM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: Deny permit request please

I ask the New Mexico Environment Department to deny the 'volume reduction' permit modification request .

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

Justin Remer-thamert

From: To: Subject:

Maestas. Ricardo. NMENV Biswell. David. NMENV FW: Urgent, today

Date: Wednesday, April 04, 2018 8:33:07 AM

From: D&S Rodriguez [mailto:[email protected]]

Sent: Tuesday, April 03, 2018 9:02 PM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: Fwd: Urgent, today

Begin forwarded message:

From: Janet <[email protected]> Subject: Urgent, today Date: April 3, 2018at1:16:46 PM MDT To: Marla Painter <[email protected]>, Karen <[email protected]>, Eileen Shaughnessy <[email protected]>, Diane D'Arrigo <[email protected]>, Bob Aly <[email protected]>, Gary Oliver <[email protected]>, Jeff Radford <[email protected]>, "[email protected]" <[email protected]>, Sylviana Douville <[email protected]>, Noel Marquez <[email protected]>, Bruce Martin <[email protected]>, Randy Martin <[email protected]>, "[email protected]" <[email protected]>, Sofia Martinez <[email protected]>, Ross Lockridge <[email protected]>, Don Hancock <[email protected]>, card <[email protected]>, Abby Johnson <.s.ag_e.d [email protected]>, "Lon Burnam ([email protected])" <[email protected]>, Mary Olson <[email protected]>, Tim Judson <[email protected]>, Romilly Tsinhnahjinnie <[email protected]>, R Gardner <[email protected]>, Carol Merrill <[email protected]>, Mark Doppke <[email protected]>, Joni Arends <[email protected]>, Scott Kovac <[email protected]>, Sasha Pyle <[email protected]>, "[email protected]" <puhgepress@hotmfilLcom>, John Wright <[email protected]>, Mervyn Tilden <[email protected]>, Bill Addington <[email protected]>, Jade Cova <[email protected]>, Patricia Golden <[email protected]>, Patricia Golden <[email protected]>, David Kraft <[email protected]>, Cody Slama <[email protected]>, Susan Gordon <[email protected]>, June Lorenzo <[email protected]>, Mavis Belisle <[email protected]>, Dario Rodriguez <[email protected]>, Sara Keeney <[email protected]>, Edie Hood <[email protected]>, Myrriah Gomez <[email protected]>, "gailyrobin@comcastnfil" <[email protected]>, Maria Santelli <[email protected]>, "[email protected]" <donnagilmore@gms:u.L@m>, Abby Johnson

<[email protected]>, Patty Hughs <[email protected]>, Jeff Radford <[email protected]>, Mark Doppke <[email protected]>, Rose Gardner <[email protected]>, Noel Marquez <[email protected]>, "[email protected]" <[email protected]>, Bruce Martin <[email protected]>, "[email protected]" <[email protected]>, Romilly Tsinhnahjinnie <Tram [email protected] >, "[email protected]" <[email protected]>, Sylviana Douville <[email protected]>, Jade Cova <[email protected]>, Dario Rodriguez <[email protected]>, Don Hancock <[email protected]>, Eileen Shaughnessy <[email protected]>, Marla Painter <[email protected]>, "[email protected]" <[email protected]>, Cody Slama <[email protected]>, Scott Kovac <[email protected]>, Susan Gordon <[email protected]>, Karen <[email protected]>, Bill Addington <[email protected]>, "[email protected]" <[email protected]>, Graciela Robinson <[email protected]>, Carol Merrill <[email protected]>, Deborah Reade <[email protected]>, June Lorenzo <[email protected]>, Leona Morgan <[email protected]>, "[email protected]" <[email protected]>,Timothy Dominguez <[email protected]>, Bob Aly <[email protected]>, "flares [email protected]" <flares [email protected]>, Manuel Barragan <[email protected]>, Bob Villa <[email protected]>, "marvita [email protected]" <marvita [email protected]>, Kevin Kamps <[email protected]>, Randy Martin <[email protected]>, Diane D'Arrigo <[email protected]>, John Wright <[email protected]>, Tina Cordova <[email protected]>, Joni Arends <[email protected]>, Dave McCoy <[email protected]>, Myrriah Gomez <[email protected]>, ABQ Peace and Justice Center <[email protected]>

Please forward the following comment to [email protected] by midnight

tonight, including your address with your name under "Sincerely':

I ask the New Mexico Environment Department to deny the 'volume reduction' permit

modification request.

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

From: To: Subject: Date:

Maestas. Ricardo. NMENV Biswell. David. NMENV FW: WIPP Permit modification Wednesday, April 04, 2018 8:34:02 AM

From: Ji mi Gadzia [mailto:[email protected]]

Sent: Tuesday, April 03, 2018 9:52 PM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: WIPP Permit modification

Dear Mr. Maestas,

I ask the New Mexico Environment Department to .d_fil1¥ the 'volume reduction' permit modification request .

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing, ... at the very LEAST. I ask that you please deny this request.

Sincerely,

Jimi Gadzia PO Box 1622 Roswell, NM 88202-1622

From: To: Subject: Date:

Maestas Ricardo NMENV

Biswell David NMENV

FW: WIPP comment

Wednesday, April 04, 2018 8:34:17 AM

-----Original Message-----From: Joan Brown,osf[mailto:joa11kansaw1 s\\Cp.com] Sent: Tuesday, April 03, 2018 9:29 PM To: Maestas, Ricardo, NMENV <[email protected]> Subject: WIPP comment

I ask the New Mexico Environment Department to deny the 'volume reduction' permit modification request.

This permit modification would increase WIPP's capacity by 25%.

Such a significant change should at least require a public hearing for citizens to offer comments and express concerns and ask questions.

Sincerely,

Joan Brown, osf

Joan Brown,osf Executive Director New Mexico Interfaith Power and Light (NMIPL)

New Mexico Interfaith Power and Light PO Box 27162 Albuquerque, NM 87125 505-266-6966 www.nm-ipl.org [email protected]

1004 Major Ave. NW. Albuquerque, NM 87107 [email protected]

"There is no inner world without the outer world." Thomas Berry, Author of The Great Work

This email has been checked for viruses by A vast anti virus software. https· \\\\\\ a\ast com anl!\Jrus

From: To: Subject:

Date:

Maestas. Ricardo. NMENV Biswell. David. NMENV FW: Public Comments about Proposed WIPP Expansion - "Volume Reporting" Permit Modification Request -Changing the way waste is measured must be changed to Class 3 permit modification request Wednesday, April 04, 2018 12:02:32 PM

From: [email protected] [mailto:[email protected]]

Sent: Wednesday, April 04, 2018 10:40 AM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: Re: Public Comments about Proposed WIPP Expansion - "Volume Reporting" Permit

Modification Request - Changing the way waste is measured must be changed to Class 3 permit

modification request

April 2, 2018

Mr. Ricardo Maestas

New Mexico Environment Department

Hazardous Waste Bureau

2905 Rodeo Park Drive E, Building 1

Santa Fe, New Mexico 87505

Dear Mr. Maestas:

I am very concerned about the proposed expansion of the amount of waste in the Waste Isolation

Pilot Plant - a proposed 28% increase - all by changing the way waste is measured.

The proposed increase of 930,000 cubic feet requires the New Mexico Environment

Department to deny the request and require the Department of Energy and its contractor, Nuclear

Waste Partnership, to resubmit their request as a Class 3 permit modification request. This is a

significant volumetric change requiring more scrutiny by the public and

the Environment Department. Alternatively, the Environment Department must determine that the

request will follow Class 3 permit modification request procE!dures.

Over its 19 years of operations, DOE has shipped many empty (dunnage) drums, has not filled

containers to capacity, yet the contractors have been paid fully- and in some cases with bonuses.

To allow the proposed change, risks the health and environment for all New Mexicans.

Thank you for your careful consideration of my comments. Please use your regulatory power

to deny the request or require the Class 3 permit modification request procedures, which include an

opportunity for a public hearing as well as the opportunity to cross-examine sworn witnesses

Sincerely,

Margaret Forrest

www.margaretforrest.com 505.685.0780

From: To: Subject: Date:

Maestas. Ricardo. NMENV Biswell. David. NMENV FW: Permit modification request Wednesday, April 04, 2018 2:38:06 PM

From: Kelli Livermore [mailto:[email protected]]

Sent: Wednesday, April 04, 2018 2:27 PM

To: Maestas, Ricardo, NMENV <[email protected]>

Subject: Permit modification request

Dear Mr.Maestas,

I ask the New Mexico Environment Department to deny the 'volume reduction' permit modification

request.

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

Kelli Livermore

135 Rincon Loop

Tijeras, NM 87059

May you be at peace,

Kelli

From: To: Subject: Date:

Maestas. Ricardo. NMENV Biswell. David, NMENV FW: "volume reduction" Wednesday, April 04, 2018 2:48:35 PM

From: Sandi Kay [mailto:[email protected]]

Sent: Wednesday, April 04, 2018 2:47 PM

To: Maestas, Ricardo, NMENV <[email protected] us>

Subject: 'volume reduction'

I ask the New Mexico Environment Department to deny the 'volume reduction' permit modification request

This permit modification would increase WIPP's capacity by 25%.

This is a big change for WIPP and at the very least requires a public hearing.

Sincerely,

Sandi Shelby