Letters to the editor

Back to the salt mines
Corrections to inaccurate statements in Mr. Jensen's article on the Waste Isolation Pilot Plant (WIPP) in southeastern New Mexico ("Salted away," Sept. '99, p. 40):

1. WIPP is designated for disposal of transuranic waste, not low-level as the article states. People incorrectly assume these terms are interchangeable, but low-level waste is generally considered to be any radioactive waste other than uranium mill tailings, transuranic waste and high-level waste, including spent nuclear fuel.

2. It's not clear what is meant on page 40 when you state "The race is on to fill ... WIPP to the brim with transuranic waste." It is expected to take 30 to 35 years to complete the task. Shipments are currently averaging between zero to two shipments per week, and may ultimately ramp up to 17 per week.

3. I'm not sure how the statement asserting that the "first storage area is now a third full" was reached. As of Sept. 23, WIPP had received 31 total shipments since March 26, consisting of 95 standard waste boxes and 350 55-gallon drums. This amounts to 8,850 cubic feet, or roughly 10 percent the capacity of a single room. Furthermore, waste is not being stored, it is being disposed.

4. It is obvious from the last sentence on page 40 that no consideration was given in developing this article to how WIPP is regulated. Besides "proponents" and "opponents," the U.S. Environmental Protection Agency and the New Mexico Environment Department (NMED) are two regulatory agencies that also monitor shipments and disposal activities. The article gives the impression that the Department of Energy (DOE) is not subject to external regulation, which is incorrect.

5. Regarding the "crack in the ceiling," no one suggests that cracks resulting from separation of a slab from the back (roof) of a disposal room will somehow heal itself. The roof bolting system simply holds the dead weight of the salt slab, preventing its immediate collapse and only delaying the inevitable closure of the room. Furthermore, it's probably more correct to say that Westinghouse has collected "evidence" that a roof fall in a disposal room is unlikely.

6. The statement in the last column of page 41, "the WIPP site has been ready to receive waste since 1986," is only half true. Perhaps the construction was complete, but DOE had not demonstrated compliance with applicable regulations governing disposal of radioactive waste, nor had they received a permit for disposal of hazardous waste.

7. The "airtight" room is actually a building under negative pressure. Outside air enters the building, and passes through high efficiency particulate air (HEPA) filters before returning to the atmosphere.

8. The WIPP Land Withdrawal Act gave DOE title to 16 square miles, not eight as the article suggests. The surface facilities and underground repository are located within the central four square miles. Oil and gas exploratory wells encircle the Land Withdrawal boundary, and DOE is supposed to evaluate the potential impact on the repository of any drilling activity that may occur within one mile of this boundary.

Further information on the regulatory aspects of WIPP can be obtained from EPA's WIPP Program page at www.epa.gov/radiation/wipp, and NMED's WIPP Information page at http://nmenv.state.nm.us/wipp. DOE's WIPP page is at www.wipp.carlsbad.nm.us/wipp.htm.

Steve Zappe
Hazardous and Radioactive Materials Bureau
New Mexico Environment Department
Santa Fe, N.M.

A picture worth a thousand words
I have been an avid reader of your publication for several years and feel it is one of the better journals covering the water environment industry. The issues covered in each issue are timely and informative. The October cover story ("Biosolids: A growing understanding," p. 24) certainly meets these criteria.

However, there is something that bothers me about your recent article and many similar articles I have read over the years. Why do so many of these articles that are intended to allay public fears regarding land application of biosolids seem to include only photographs of surface application of the liquid sludge?

I realize that many facilities use surface application followed by incorporation as their disposal technique. When properly managed, this is an entirely acceptable procedure. However, to the general public, such photos may give the wrong impression.

Subsurface injection of liquid sludges is certainly an equally acceptable and safe disposal technique. I would argue that photos of this technique would help to convince the public that it has little to fear. Remember, a picture is worth a thousand words.

Keep up the good work!

Richard A. Schultz
Assistant Superintendant, Plant Operations
City of Kankakee Municipal Utility
Kankakee, Ill.

Editors' response:
Thank you for your insightful suggestion. While it is obviously easier and more dramatic to photographically illustrate surface disposal, we will strive to portray different biosolids disposal techniques in future articles.

One for the "Don't try this at home" file
I especially enjoyed the picture on page 44 ("The next big headache for UST owners: Y2K") of the October 1999 issue that showed a laborer in a tank pit working on an underground storage tank with a cigarette in his mouth. This must be from the "How not to" archives from the EPA.

Jim Trotter
Environmental Project Manager
Tosco Marketing Company
Tempe, Ariz.

Editors' response:
Thank you for your sharp-eyed observation. Although the image depicts an installation, not a removal, of a UST, we concur that it is surprising that EPA's archives contain a photo featuring a safety violation. We're going to save this photo for our "Don't try this at home" file.

No more bull
The Animal Residuals Management Conference needs to address not only solids residuals, but also vapor residuals ("Getting beyond the bull," Oct. '99, p. 8). The ammonia emitted by feedlots, poultry producers and agribusiness combines with ozone to form particulate nitrate in the range of PM-2.5 and below. This source of pollution needs to be addressed.

Bob Carter
Nelson-Dodd Co.
San Carlos, Calif.

Letters to the editor should be addressed to Environmental Protection Magazine Letters, 5151 Beltline Rd., 10th Floor, Dallas, TX 75240. Our fax number is (972) 687-6770. Send letters via e-mail to aneville@stevenspublishing.com. Correspondence should include the writer's full name, address and job title and may be edited for purposes of clarity or space.

This article originally appeared in the 12/01/1999 issue of Environmental Protection.