The third time is proving far from charming for the government’s plan to continue making nuclear bomb parts in Oak Ridge. The National Nuclear Security Administration this week released its third Supplement Analysis [SA] for the Y-12 Nuclear Weapons Complex. Buried on page 31 of the report is the finding that the consequences of a worst-case scenario are ten times greater under the current plan than previously disclosed in the 2011 Site-Wide Environmental Impact Statement.
The 2020 SA follows on the heels of a 2016 SA and a 2018 SA, both of which were deemed insufficient by federal judge Pamela Reeves in a September 2019 ruling. The judge’s opinion, in a case brought by the Oak Ridge Environmental Peace Alliance, Nuclear Watch New Mexico, the Natural Resources Defense Council and four individual plaintiffs, vacated the 2016 and 2018 SAs and ordered the NNSA to perform a new analysis, using up-to-date information about seismic hazards.
The new SA examines a worst-case scenario for the current plan and finds the consequences would be “ten times greater” than the original UPF plan (p.31); the difference is in the continued use of out-of-compliance facilities. The scenario estimates 1.5 million people could be exposed to risk from an earthquake and subsequent fire and events triggered by an earthquake. The injury and death toll for workers is estimated to be “no more than 100.”
Ralph Hutchison, coordinator of the Oak Ridge Environmental Peace Alliance, said, “It is unconscionable that the Department of Energy should put the public at risk without any consultation at all”no public hearing, not even an information session. Instead, while the world is transfixed and the community is locked down by the threat of COVID-19, this document is quietly released and the public is given 30 days to comment.”
Hutchison also noted the document fails to meet the requirements of the National Environmental Policy Act which was the basis for the original legal challenge. “This Supplement Analysis falls short of the standards required by the National Environmental Policy Act,” said Hutchison. “NNSA is required to take a hard look at the environmental impacts that would occur if a design basis earthquake were to strike East Tennessee. But NNSA admits, in this document, that it does not yet know how the buildings will perform in such an earthquake. It says studies are underway that won’t be finished until the end of next year.”
“These are not just technical concerns,” Hutchison said. “They are real threats. They know that the use of these old buildings poses a significant risk to workers and the public. But they have never held a public meeting to discuss that with people in Oak Ridge or Knoxville. Instead, they have quietly adopted a policy of “˜risk acceptance,’ meaning they decided for us how much danger we will accept.
“This is not acceptable in a democracy. In a moment when we are all realizing that the unthinkable can happen, with catastrophic consequences, we want to be fully informed, and we want to be given a say in how much danger the government can put us in.
“NNSA should put its operations on hold until a public meeting can be held to present this information to the public and receive their comment,” Hutchison said.
STATEMENT OF THE OAK RIDGE ENVIRONMENTAL PEACE ALLIANCE
“The consequences of the worst-case design basis accidents are approximately ten times larger than the consequences for the [original} UPF”¦”
~ April 2020 Supplement Analysis
In a document* that states that seismic evaluations of deteriorating enriched uranium operations buildings at the Y-12 Nuclear Weapons Complex “are currently being performed” (p.11), and will be completed “by the end of 2021 (p.12),” the National Nuclear Security Administration nevertheless insists that it will push forward with its plan to continue enriched uranium operations in Building 9215 and Building 9204-2E for two decades or more.
The document is a Supplement Analysis [SA], a court-ordered look at the seismic qualifications of buildings that the NNSA used to produce nuclear weapons components in Oak Ridge, Tennessee. The SA acknowledges that portions of the buildings do not meet modern nuclear safety standards, and that evaluations to identify “remaining weaknesses and the potential for upgrades” are ongoing.
Even when that is completed, says NNSA, upgrades to bring the facilities into compliance with modern nuclear standards “may not be feasible or practical.” This despite the identification of both buildings as Category IV facilities”the highest risk category.
NNSA’s last look at the old buildings was in 2018, when they said making the buildings safe would be “cost prohibitive,” and they would continue to use them anyway. At that time they said they would reduce the risks by moving some dangerous material out of the buildings and by accepting a certain amount of risk on behalf of the workers and public.
The words “risk acceptance” do not appear in the new Supplement Analysis, but the SA’s analysis of worst-case accidents says the consequences would be ten times as great as the original UPF plan”because of the decision to continue to use the old buildings.
Despite the admission that critical information about how the old buildings will perform in an earthquake won’t be available for another 20 months, NNSA has determined that it is not required to prepare further environmental analysis of risks associated with using the old, out-of-compliance buildings for the indefinite future. This decision, if left in place, will lock in place an ever-growing threat to the people of Oak Ridge and Knoxville.
Since November 2019, East Tennessee has been the site of repeated seismic activity as recorded by the US Geological Survey. The East Tennessee Seismic Zone is the second highest activity zone in the United States. This means the risk of an earthquake is not hypothetical.
OREPA believes the public should be fully informed about the risk to which NNSA is subjecting it, and should have a chance to comment on the plans. We call for NNSA to schedule a public hearing as soon as conditions surrounding the COVID-19 threat have abated to allow for a safe gathering.
We also call on NNSA to suspend activities at Y-12 that are not in compliance with the order of the federal court in September 2019 and that also violate the subsequent COVID-19 safer-at-home order of Tennessee’s Governor Lee in March 2020.
All activities, except essential maintenance and safety tasks, that require workers to violate physical distancing recommendations of state and federal health officials should be suspended immediately at Y-12. This is important not only for the protection of the workers, several of whom have tested positive for COVID-19, but also for the community that is vulnerable to the spread of the virus.
* Draft Supplement Analysis for the Final Site-Wide Environmental Impact Statement for the Y-12 National Security Complex, Earthquake Accident Analysis (DOE/EIS-0387-SA-04, April 2020)