It’s time to be heard. Since OREPA, Nuclear Watch New Mexico, Natural Resources Defense Council and four individuals sued the NNSA in July 2017, NNSA has been secretly preparing a second Supplement Analysis (SA) on the 2011 Site-Wide Environmental Impact Statement for the Y-12 Nuclear Weapons Complex.
On May 19, the SA was released. And, in an unprecedented move, NNSA offered a 30-day public comment period. That means you have until June 20 to submit comments.
The SA tries to cover ground that was not covered in previous environmental analyses. In particular, it looks at NNSA’s plan to continue to conduct Enriched Uranium operations in two aging facilities that do not comply with current environmental or seismic standards. These facilities, the 9215 Complex and Building 9204-2E, are at the center of OREPA’s legal challenge to the UPF bomb plant. NNSA fails to provide any solid information about the facilities in the SA. Instead, it says more study is needed and “NNSA believes the buildings can be operated safely.”
Below you will find information on where to send comments along with talking points that you can use to craft comments.
IT IS IMPORTANT THAT EVERYONE WHO READS THIS SUBMITS COMMENTS— This is our chance to hold NNSA accountable, and to show the court that will eventually decide our lawsuit that there is broad public concern about the UPF bomb plant.
Here are key talking points:
• Worker and public safety first. Any plan that relies on using the 9215 Complex and Building 9204-2E for decades to come must make worker and public safety the highest priority—not cost or schedule or “mission need.” If the buildings can not be brought into compliance they can not be used. If the work can not be done safely (not as safely as possible, but safe—period.), it can’t be done.
• Safety first means answer the safety questions before you start moving material from Building 9212 into the 9215 Complex. Safety first means answering fundamental questions about where work will be done before you commit irretrievable resources to a UPF design that relies on much of the enriched uranium work being done in out-of-compliance buildings.
• If it turns out that Complex 9215 and Building 9204-2E can not be brought into compliance and are deemed unsafe by the experts and computer models yet to be designed, and the UPF is already 1/3 built, there is no going back to redesign the UPF to accommodate the rest of EU operations.
• The NEPA process is a good one. It lays out a chronology for decision-making that requires horses to stay in front of carts, so that one decision follows from another in a rational sequence. To plunge forward with construction of the UPF before final decisions are made on EU operations is a direct contradiction to the requirements of NEPA. Decisions can not be segmented, neither can they leapfrog over NEPA requirements for the sake of convenience.
• The existence of a second SA, less than two years after the first SA, is clear evidence that the 2011 Y-12 Site-Wide EIS had gaps that require preparation of a full Supplemental-EIS. The plans for Enriched Uranium Operations have changed dramatically, in ways that change the fundamental assumptions about the environmental impacts of the EU program. And new information—the 2014 earthquake hazard map updates of the US Geological Survey and additional information about historical seismic activity in East Tennessee—must be included in the new EIS and incorporated into design decisions.
• It is never okay for a NEPA document to gloss over important environmental concerns with “we’re going to look at that soon, but for now we’re moving ahead with plans that can not be undone.” The point of NEPA is to force the analysis to be done before decisions are made.
• The current SA relies on vague generalities at points that require solid answers. “It may be possible to upgrade both facilities…(p.19); “a reduction in the Material at Risk limit has the potential to reduce the accident consequences… (p.20).” “NNSA believes that it can continue to operate…in a safe manner…(p.20).” “It appears that those risks and consequences are lower…(p. 18)”
• The Supplement Analysis also includes statements that are simply untrue. In discussing the challenges of cleaning up high-risk facilities in Oak Ridge, the SA says “EM [Environmental Management] schedules…are based upon priorities driven by potential for off-site environmental risks.” This flies in the face of the finding of the Department of Energy’s own Inspector General who placed Building 9201-5 (Alpha-5) at Y-12 at the very top of the Excess High-Risk Facilities top ten list. It is the worst facility in the country. It poses, in the words of the DOE Inspector General “an ever-increasing risk to workers and the public.” This is not speculative, it is not projecting into the future—it says there is a risk now, to workers and the public, and it is getting worse. But there is no funding to begin cleanup on Alpha-5 in the DOE’s more-than-$5 billion cleanup budget. Other, lower-risk, shovel-ready cleanup activities are being prioritized because they are easier and because DOE’s Environmental Management leadership wants to show some wins.
• Finally, far from documenting that sufficient environmental analysis has been done for Complex 9215 and Building 9204-2E, the 2018 Supplement Analysis does just the opposite—it states that safety and performance models have not yet been developed that allow us to understand fully the environmental impacts of a significant event. This confirms the OREPA/NWNM/NRDC lawsuit’s claim that a new EIS must be prepared for the entire EU program before the UPF can be built.
• The concern about the seismic performance of the aging facilities at Y-12 has been repeatedly confirmed by the Defense Nuclear Facilities Safety Board; among other things they found NNSA can not be certain that a design-basis accident in Complex 9215 and Building 9204-2E would not trigger a nuclear criticality event. NNSA’s response: “We will figure this out in the future,” is not acceptable; it kicks critical decisions down the road, placing workers, the public, and NNSA’s own mission capability at risk.
Your comments to the NNSA on the 2018 Supplement Analysis for the Site-Wide Environmental Impact Statement for the Y-12 National Security Complex (DOE/EIS-0387-SA-02) must be submitted by June 20, 2018. Comments sent after that date may be considered by NNSA, but it isn’t required to consider them.
Send comments to:
Jack Zanger, Attn: Y-12 SWEIS SA
P O Box 30030, Amarillo, TX 79120
You can also fax your comments to Mr. Zanger at 806 573 7108, or send them by email to email@example.com
If you want to read or download the SA, you can find it here: https://www.energy.gov/sites/prod/files/2018/05/f51/EIS-0387-SA02-2018.pdf.