The Oak Ridge Environmental Peace Alliance joined people from around the country in declaring the National Nuclear Security Administration’s environmental analysis of earthquake risks at the Y-12 National Security Complex in Oak Ridge, Tennessee, “inadequate, in so many ways.”
OREPA’s comments can be found here.
NNSA prepared its Supplement Analysis, after being ordered by federal judge Pamela Reeves in September 2019 as a result of litigation brought by the Oak Ridge Environmental Peace Alliance, Nuclear Watch New Mexico, the Natural Resources Defense Council, and four individual plaintiffs. The judge also vacated two previous NNSA Supplement Analyses and one Amended Record of Decision.
After being ordered to “at a minimum” prepare a new Supplement Analysis of the 2011 Site-Wide Environmental Impact Statement, and being specifically ordered to include the 2014 US Geological Survey earthquake hazard data, NNSA released its latest review in April and gave the public 30 days to comment—later extended by 15 days in response to a request by OREPA.
“This SA is not likely to fare any better than the last two,” said Ralph Hutchison, coordinator of OREPA. “Instead of preparing a new Supplement Analysis of Y-12, as the judge ordered, NNSA chose to prepare an analysis of earthquake risks in three buildings at Y-12, ignoring the rest of the site. In the SA, NNSA admits it will not actually have the data it needs to estimate the performance of some its structures until the end of next year, 2021.”
At issue is the NNSA’s decision to continue dangerous Highly Enriched Uranium weapons operations in two aging facilities that were slated to be replaced. Instead, when cost and schedule problems forced NNSA to change its plans, it declared it will continue using Buildings 9215 and 9204-2E for thirty more years. It also acknowledges neither of the facilities meets modern safety standards and studies to determine if the buildings can be brought into compliance and made safe will not be finished until 2021.
OREPA filed a formal request with NNSA for a public hearing, NNSA denied the request. “Refusing a public hearing on the dangers and risks of design changes, using substandard buildings suggests that people in this area, my homeplace, are denied their rightful autonomy about their own area,” wrote OREPA Board president Kevin Collins, seventh generation East Tennessean, in his comments.
In lieu of bringing its enriched uranium buildings into compliance with modern safety standards, NNSA has declared a policy of Risk Acceptance. OREPA believes it is wrong to subject the public to risks without fully information them and getting their consent—hence, the call for a public hearing.
OREPA’s concerns about the seismic stability of the old facilities was underscored by Dr. David Jackson, Distinguished Professor Emeritus at UCLA. Dr. Jackson wrote: “NNSA’s review is defective in numerous regards. It falls far short of relevant professional and scientific standards, offers a simplistic analysis of risks that fails to disclose or properly analyze critical underlying data, fails to consider adequately some highly relevant new data from the USGS, fails to employ a modern set of tools for analyzing seismic risks, chooses an arbitrary measurement of risk, and fails to respond in any coherent manner to new information furnished by the USGS and the Defense Nuclear Facilities Safety Board.”
OREPA is calling for the NNSA to prepare a new Site-Wide Environmental Impact Statement, and to halt construction of the Uranium Processing Facility (UPF) until it has completed the legally required environmental studies.