Thornberg Companies has proposed an office complex that is expected to increase traffic along NM 599, the bypass route along which low-level nuclear waste is transported from Los Alamos National Laboratory to the Waste Isolation Pilot Plant.

September 16, 2003

Monica Montoya
Early Neighborhood Notification
City of Santa Fe
P. O. Box 909
Santa Fe, NM 87504

Re: Preliminary Approval (Traffic)-Thornberg Project/Santa Fe Estates

Dear Ms. Montoya,

Concerned Citizens for Nuclear Safety (CCNS) would like to express our concerns regarding the proposed Thornberg Companies office complex that would increase traffic along NM 599. As you may know, 599 is the route currently used to transport transuranic nuclear waste from Los Alamos National Laboratory (LANL) to the Waste Isolation Pilot Plant (WIPP).

The intent of the 599 bypass route was solely for the transportation of radioactive waste and not to facilitate commercial development in the area.

Furthermore, the Department of Energy (DOE) is not abiding by the mandate established between it and the City of Santa Fe that states that escorted WIPP trucks may only travel on 84/285 and 599 within the City limits between the hours of 2 and 6 a.m. CCNS has seen several WIPP trucks traveling from LANL unescorted into the 84/285 construction zone at or around 5 p.m.

The connection between 84/285, 599 and Ridgetop Road is already precarious; drivers have only 0.2 of a mile to merge from the south exit off of 84/285 onto Ridgetop Road. Even now, that distance provides inadequate time for a driver to react should a WIPP truck also be on the bypass. To increase traffic in this area would only increase the risk of this maneuver.

WIPP received its 2012th shipment of waste on Monday, September 15, 2003, including 67 shipments of waste from LANL. Waste shipments to WIPP have been steadily increasing since the facility began operation in 1999. A typical WIPP shipment consists of three TRUPACT II containers, which each holds up to 14 55-gallon drums of transuranic waste for a total of 42 drums. Transuranic waste is plutonium-contaminated waste that is created as a result of nuclear weapons production activities.

LANL is expected to produce 6,640 cubic meters of transuranic waste in 50 years of operation. This equates to nearly 598 shipments from LANL to WIPP along 599 remaining, assuming that LANL does not create any more transuranic waste than that estimated in its 1999 Site-Wide Environmental Impact Statement for Continued Operations of Los Alamos National Laboratory (DOE/EIS-0238).

Unfortunately, there are two facilities proposed for LANL that would dramatically increase the number of waste shipments along 599. The Modern Pit Facility (MPF), which is a facility that would create the "pit" or trigger of modern thermonuclear weapons, would create anywhere from 29,500 cubic meters to 56,500 cubic meters of transuranic waste over the next 50 years. This would create anywhere from 2,899 to 5,553 additional shipments of waste along 599. This is so much waste, in fact, that WIPP would not be able to hold it all. However, the DOE claims that once the current WIPP facility is full, a new WIPP facility will be sited and permitted.

Furthermore, the Chemistry and Metallurgy Research Building Replacement (CMRR), which performs advanced chemistry and research on radionuclides, would produce 2,332 cubic meters of transuranic waste. This would equate to 229 additional shipments of waste to WIPP along 599. All told, if these two facilities were to open and operate, we could anticipate a total 6,417 shipments of transuranic waste along 599 over the next 50 years.

The aforementioned MPF is also being considered to be located at WIPP. The MPF would also create large volumes of low-level waste, for which WIPP has no disposal capacity. In order to accommodate the 103,500 cubic meters to 251,500 cubic meters of low-level waste that would be generated, WIPP would have to send the waste either to Area G at LANL or to the Nevada Test Site (NTS). Currently, low-level waste can be shipped through Santa Fe along St. Francis Drive. However, at such large volumes, CCNS expects that the waste would begin to be diverted around Santa Fe and onto the 599 bypass route. Assuming that the waste was shipped in 55-gallon drums in the same configuration as the shipments to WIPP, this would constitute 24,717 shipments of low-level waste from WIPP to LANL or NTS.

In addition, there have been two major accidents involving WIPP trucks thus far. In September 2002, a drunk driver rear-ended a WIPP truck near the WIPP site. The shipment was eventually returned to its place of origin because one of the drums contained within the TRUPACT II was found to be leaking. The risk of such accidents occurring will only increase as the number of shipments increases and as the amount of traffic along 599 increases. Such accidents are particularly disconcerting because, according to a 1999 study by CCNS and the New Mexico Department of Health (NMDOH), in New Mexico, only 25% of trained Emergency Medical Service personnel and firefighters feel that they have adequate equipment to respond to a hazardous or radiological materials incident and only 28% feel that they are adequately trained to handle a radioactively contaminated patient. For more information, please see CCNS and NMDOH's survey of emergency responders along the WIPP route.

Considering the deadly cargo that 599 already supports and may support in the future, it is imperative that we deliberate carefully before making decisions affecting the route. CCNS hopes that you will take into consideration these facts before making a decision build a commercial facility, such as the Thornberg Project, with the potential to increase traffic on 599.

We would appreciate your passing this information along to the Santa Fe Planning Commission. If you or the Commission members have any questions or comments, please feel free to contact me.

Joni Arends
Executive Director