Oak Ridge Environmental Peace Alliance comments on Environmental Assessment for Emergency Operations Center at Y12 in Oak Ridge.
Says EA relies on outdated data, should be integrated into Site-Wide Environmental Impact Statement.
for immediate release
29 July 2015
The Oak Ridge Environmental Peace Alliance today submitted comments on the National Nuclear Security Administration’s Environmental Assessment for a new Emergency Operations Center at the Y12 Nuclear Weapons Complex in Oak Ridge, Tennessee.
“Whether they are building bombs, taking them apart, or just storing weapons grade uranium and other hazardous materials, being equipped to handle emergencies is a critically important mission,” said OREPA coordinator Ralph Hutchison. “That means this facility has to be the last building standing in any kind of disaster—an accident, an earthquake or an attack.”
OREPA notes in its comments that the Environmental Assessment relies on outdated earthquake data, promises that critical environmental data will be compiled in the future rather than analyzed in the EA, and is not integrated into the site-wide plan for Y12.
“We are probably only months away from the announcement of the preparation of a Supplement to the now outdated 2011 Site-Wide Environmental Impact Statement,” Hutchison said. “The EOC should be included in that process, which will be more rigorous. The point of a Site-Wide environmental analysis is to integrate all significant projects in a single plan.”
The OREPA comments note the siting of the EOC as proposed exposes the facility to external assaults, placed above ground in a shallow valley between two accessible ridges. A “determined and knowledgeable adversary would want to minimize response capacity and create maximum chaos,” notes OREPA, making the EOC a prime target. “Locating it out in the open makes it a pretty soft target, too,” said Hutchison. “On the third anniversary of the Transform Now Plowshares action, one is left to wonder what lessons, exactly, NNSA learned from that incursion.”
The Environmental Assessment addresses seismic issues for the planned EOC, but relies on data and modeling from the 2011 SWEIS. OREPA notes that data from the US Geological Survey and University of Tennessee researchers have overwritten the 2011 SWEIS.
“The most stringent design requirements are for nuclear facilities,” said Hutchison. “The EOC is not a nuclear facility. But it’s mission requires it to survive even if—especially if—nuclear facilities are failing. Common sense requires a design that provides maximum survivability; the EA posits a ‘satisfactory and economical foundation’ for the EOC. That doesn’t sound like maximum survivability to me.”
OREPA also notes the EA does not analyze environmental impacts from construction of the EOC, noting that relevant data on contamination in soils has yet to be collected. “They really can’t issue a credible Finding of No Significant Impact if they haven’t analyzed soil data,” Hutchison said. “That’s the whole point of an EA, to deal with actual data. It should be a Finding, not a Guessing.”
In the end, OREPA calls for rolling the EA for the EOC into a Supplemental-SWEIS process. “This would not only save taxpayers money, it would accelerate DOE’s decision-making schedule,” OREPA says.
for more information: Ralph Hutchison, 865 776 5050, firstname.lastname@example.org
You can read the comments here: