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March 7, 2008 John Kieling, Program Manager New Mexico Environment Department (NMED) Hazardous Waste Bureau 2905

Rodeo Park Drive East, Bldg. 1 Santa Fe, New Mexico 87505-6303 john.kieling@state.nm.us Before the New Mexico Environment Department March 14, 2008 Citizen Action Comments Re: Sandia National Laboratories (SNL), New Mexico March 2006 Request for Corrective Action Complete No Further Action (NFA) Status for 4 Solid Waste Management Units (SWMUs) and 1 Area of Concern (AOC) (Class III Permit Modification March 2006) General comment: DOE is proposing the following sites for No Further Action status. DOE is failing to address the problem of radionuclide contamination under DOE Orders. Request for public hearing is made for this Class III Permit Modification. The descriptions of the SWMUs/AOC are too vague for the public to determine whether the proposed NFAs are safe. Generally, the Fact Sheets fail to present information such as: exact types of Contaminants of Concern (COCs) and their volumes; the locations of drain fields on maps; the depth of septic tanks, seepage pits, piping, and drain systems; the positions of monitoring wells if they exist; drilling methods; type of well construction; depth to ground water; statistical water sampling data; direction of the flow of groundwater at the SWMU locations; volumes of waste water and the wastes discharged. Typical descriptions of the COCs gives no breakdown for the types of radionuclides that are at the various SWMUs. Apparently, Sandia has no intention of protecting the public from radionuclide contamination. DOE Order 450.1 is ignored. Often, the NFA status relies upon the collection of soil and septic samples at the current time from the SWMU sites that have no bearing on the hazardous wastes that were released over five decades of use and which may already have reached groundwater or have plumes on the way. The knowledge of groundwater contamination does not exist because the required well monitoring networks to detect contamination are not in place. NMED was cognizant in 1997 of the need for groundwater characterization: Over 20-30 year periods, the larger discharge rates reported for some of these smaller septic systems appear to be sufficient to drive contaminated liquids to the [ground]water. Additionally, a number of small septic systems are located in canyon or pediment areas where the unsaturated zone is made up chiefly of permeable gravel, sand, and potentially permeable fractured bedrock, and where

groundwater is relatively shallow. There is certainly potential in these cases that hazardous constituents such as VOCs and cyanide) can cause ground water to become contaminated to unacceptable levels. Therefore, HRMB will not approve NFA status for any septic system without ground-water characterization SWMU 8 and 58-Open Dump and Coyote Canyon Blast Area This is 288 acres that operated from the 1950 to the late 1960s. The Contaminants of Concern (COCs) include HE compounds, metals, VOCs, SVOCs, asbestos, petroleum fuels and radionuclides. The quantity of various COCs is not identified. The depth to groundwater in the area is unknown but is expected to be variable due to faulting in the area. Given the long history of use, the size of the unit and the COCs, the hydrologic setting must be investigated and monitoring wells put in place on a phased approach to begin with a minimum of 10 monitoring wells to investigate contamination at the groundwater as defined by the CO. This site is not suitable for release to NFA status. Residential land use status is unsafe. The clean up of the site to only an industrial standard allows water that will be used for residential purposes to be contaminated to an industrial level. No evidence of ecological risk studies with presentation of field data in the fact sheet provides the basis for any conclusion that the site has acceptable ecological risk. SWMU 28-2 Mineshaft This SWMU is in the Foothills Test Area in the US Forest Service withdrawn area near the southeast corner of Kirtland Air Force Base (KAFB). SWMU 28-2 is an abandoned mine shaft where mining took place in the early to mid-1900s. Based on interviews of SNL personnel the mineshaft was used for experimental testing and possible disposal activities. Depleted uranium was found at the entry to the mineshaft. COCs include HE compounds, metals, and radionuclides. Depth to groundwater is not known, therefore a minimum of two wells in a phased approach would be necessary to characterize and investigate groundwater contamination. The site is not suitable for release as an NFA, especially for residential use and given that it is on UF Forest Service land. The site requires further investigation. SWMU 105 Mercury Spill (Building 6536) The main part of bldg 6536 was built in 1967 and Rm. 113 where the Hg spill occurred was added in 1983. The Bldg. 6536 operated during the period that it would require a RCRA permit for operations as a regulated unit. The building was torn down. The quantity of the mercury spill is not described. The other chemicals and metals used for high heat experiments are not described. Nor is the method for disposal of the liquid waste stream from this building set forth. The building operated before there was sitewide collection of liquid wastes. The background value for Hg is 3000 times above background value for mercury. 1 cu yd of Hg contaminated soil was removed but that gives no indication of the amount of mercury released. No monitoring wells are present and a minimum of three downgradient and one upgradient monitoring wells are required. The clean up of the site to only an industrial standard allows water that will be used for residential purposes to be contaminated to an industrial level.

AOC 1101 Drain and Septic System Bldg. 885 Bldg. 885 operated beginning in 1953 to 1988. The site is a regulated unit that is required to close under a post-closure permit. The COCs include HE compounds, RCRA metals, cyanide, hexavalent chromium, VOCs, SVOCs, and radionuclides. Liquid waste volume is not set forth for operations. The septic system connected to two 25 ft deep, 5 ft in diameter seepage pits. The amounts of the COCs are not set forth. There are no monitoring wells. There is no evidence set forth to prove that the seepage pits or tanks were removed before the area was paved over. Where are the excavation records to make the conclusion? The site is insufficiently characterized or monitored to release it as an NFA. The risk assessment for residential use cannot be justified on the basis of the absence of data for this facility. ER Site 59 Pendulum Site Citizen Action does not oppose this NFA. Respectfully submitted, David B. McCoy, Executive Director Citizen Action New Mexico POB 4276 Albuquerque, NM 87196-4276 505 262-1862 dave@radfreenm.org Robert Gilkeson, Registered Geologist PO Box 670 Los Alamos, NM 87544 rhgilkeson@aol.com

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