2 May 2016
NNSA releases Environmental Review of UPF Bomb Plant Plans
OREPA replies: “Give ‘em hard hats,” does not constitute rigorous environmental analysis of seismic risk to workers or public.
The National Nuclear Security Administration today released the Supplement Analysis for the 2011 Site-Wide Environmental Impact Statement (SWEIS) for the Y-12 National Security Complex. The document, required whenever a federal agency significantly changes its plans, gives NNSA the green light to proceed with plans to construct a new nuclear weapons manufacturing complex that NNSA is still calling the Uranium Processing Facility, without further analysis of environmental impacts stemming from the new concept.
“The Supplement Analysis (SA) does exactly what we expected,” said Ralph Hutchison, coordinator of the Oak Ridge Environmental Peace Alliance which, along with Nuclear Watch New Mexico, filed a Freedom of Information Act request for the Supplement Analysis more than a year ago. “It attempts to shrug off radical changes as no big deal in order to move forward with the modernization of Y12.”
“An SA is supposed to take a look at the existing environmental analysis and decide if it still matches up with the new proposed action. In this case, even though the new action is profoundly different from the old proposal, the NNSA says no new analysis is required.”
In the 2011 Record of Decision published as result of the SWEIS, the NNSA announced its plan to build the Uranium Processing Facility, one building which would consolidate uranium operations that currently take place in several deteriorating buildings. But cost and other factors forced NNSA to step back from the “Big Box” UPF to propose a new scenario, postulating a very different Y-12, one in which aging facilities would be pressed into service for decades to come.
“The decision to continue to press old, unsafe buildings into service for another twenty-five years has profound environmental consequences,” Hutchison noted. “It also raises questions about worker and public safety as well as mission integrity. The SA declares, without analyzing the environmental impacts in any way, that under the new proposal, the upgrade of existing facilities which will be engaged in enriched uranium operations, will not meet current seismic standards.
With regard to seismic hazards, it would be prohibitively expensive to upgrade 50+ year old facilities to current seismic standards. As such, the plan is not to bring the long-range Y-12 EU facilities to current seismic standards, but to improve worker safety and reduce mission risk. (p. 30)
“ ‘Give ‘em hard hats and move some of the uranium out,’ does not constitute analysis of risks of sufficient rigor to meet the requirements of the National Environmental Policy Act,” said Hutchison. “The fact that NNSA plans to continue operations for at least twenty-five years in Building 9215 and Building 9202-2E while admitting the buildings are not seismically qualified is outrageous. The old SWEIS did not analyze the impacts from a collapse of one of those facilities because it assumed they would be phased out quickly and their operations moved into the UPF. Neither did the old SWEIS explain how the loss of those capabilities would affect Y-12s ability to meet mission requirements. Those kinds of analyses are not only required by law, they are questions any half-competent management team would want to know moving forward.”
“We’re not talking just about a new building, the UPF, anymore. We’re talking about the modernization of the entire Y-12 complex. Under the current proposal, the Y-12 of the future looks nothing like the Y-12 proposed in the 2011 SWEIS,” Hutchison said. “What NNSA should do is prepare a new Site-Wide Environmental Impact Statement that addresses the modernization of Y-12 in a comprehensive and coherent document, not a slap-dash addendum that attempts to force the new plan into the old SWEIS analysis. Department of Energy guidelines call for a review of Site-Wide EISes every five years to see if they are still applicable. The 2011 one clearly is not.”
The SA creatively attempts to define the UPF as “one facility with multiple buildings.” In reality, the UPF is no more. In its place are the MPB, the SAB, the MEB, the PSB, the CSB and the PSF, along with several other outbuildings. If the new facilities, the Main Process Building (MPB) will be built to maximum seismic and safety standards. Other non-radiological buildings, though still mission-critical, will be built to lesser standards.
“NNSA has abandoned the UPF in favor of a site-wide modernization of Y-12 that will include at least five new facilities and the continued use of two deteriorating facilities for critical uranium operations,” Hutchison said. “The SA is silent on how the decision to downgrade safety requirements for some of the uranium processing buildings will affect the ability of Y-12 to continue to meet mission requirements or how it will affect worker and public health. They are clearly interested in doing this job as quickly and as cheaply as possible. In this case, that means taxpayers will pay billions for Y-12 modernization and, as a bonus, end up with bomb facilities that are built to minimum safety standards. NNSA says this is good enough. We don’t agree.”
The SA brushes aside concerns about earthquakes and natural phenomena, saying “the potential impacts of operating the UPF would not be significantly different from those presented in the 2011 SWEIS.” The SA briefly acknowledges that new seismic data has been developed since 2011, including a new US Geological Survey hazard analysis that increased the risk of significant earthquakes in the East Tennessee Seismic Zone (second highest increase in the country) and says, “the new USGS seismic hazard map does not change the site-specific data at Y012 which is used to determine facility design and construction requirements.”
“It should,” said OREPA’s Hutchison, “when coupled with findings by researches at the University of Tennessee that this area has experienced earthquakes of a magnitude of 6.0 or greater, much higher than previously believed. It is not enough for an EIS to push aside rigorous analysis with an assurance that designers will take things into account in the future. The EIS has to analyze this now, in order to inform the design—which has been going on for two years, at a cost so far of more than $2 billion.”
OREPA one other area of deficiency in the SA. “Back in 2009, we told the NNSA that they should expect to encounter surprises as construction moved forward, and they should take steps to characterize the soil before hand in order to provide adequate protection for workers who would be the first to encounter such surprises, said Hutchison. “We weren’t being particularly imaginative. Our comments were informed by a simple understanding of past operations at Y-12, and we thought it likely that unexpected waste areas would be encountered—they might have radioactive wastes or other toxic or hazardous wastes. NNSA responded that they would develop and implement a plan to characterize areas that would be disturbed.
“If that was done, it was remarkably inept,” Hutchison noted. The construction of the haul road resulted in fifty ‘surprises’ according to media reports. Only a few were made public. The SA reports what was done with the wastes resulting from those discoveries, but offers no report on worker exposures or worker protections. “Now that we’re no longer talking hypothetical, we want an analysis, including worker exposure estimates, and a thorough and effective effort to characterize future areas of disturbance before workers stumble on to something lethal.”
You can find the SA here: final upf sa apr 20