The Oak Ridge Environmental Peace Alliance, along with Nuclear Watch New Mexico, has challenged the National Nuclear Security Administration’s latest justification for the Uranium Processing Facility bomb plant under construction at the Y-12 National Security Complex in Oak Ridge, Tennessee. In a letter to the Secretary of Energy and the Administrator of the NNSA, OREPA and NWNM pointed out that the Final Supplement Analysis, released in July, falls far short of the “hard look” required by the National Environmental Policy Act.
The Final Supplement Analysis is NNSA’s attempt to comply with the order of the federal court in Knoxville, Tennessee. The court, in September of last year, ruled in favor of OREPA, NWNM, the Natural Resources Defense Council and four individual plaintiffs who argued that NNSA is in violation of NEPA, the law that requires federal agencies to consider the environmental impacts of their actions.
Among other deficiencies, Judge Pamela Reeve ordered NNSA to prepare “at a minimum” a new Supplement Analysis for the Y-12 Site-Wide Environmental Impact Statement that included consideration of the consequences of an earthquake in Bear Creek Valley, where the bomb plant in located and took into account the most recent hazard maps provided by the US Geological Survey.
NNSA’s Supplement Analysis fails to do what the judge said. Instead, the SA indicates that studies on the seismic performance of several buildings that are currently identified “not meeting current seismic standards” will not be completed until the end of 2021. NNSA declined to look at the consequences of an earthquake on the Y-12 site, choosing instead to limit its analysis to three facilities in the Enriched Uranium (weapons manufacturing) program.
Dr. David Jackson, Distinguished Professor Emeritus at UCLA, reviewed the Draft SA and the Final SA and concluded: “NNSA has failed to address serious environmental risk issues that I have identified twice in response to the Draft Supplement Analysis,” charging that NNSA has used “demonstrably false assumptions that large earthquakes can only occur on pre-recognized ‘capable faults.'”
Ralph Hutchison, OREPA coordinator, described the significance of the failure by NNSA. “A large earthquake in Oak Ridge would have catastrophic effects. NNSA says a design-basis earthquake could result in a nuclear criticality as well as numerous fires and the release of a plume of highly enriched uranium.
“The problem NNSA has,” Hutchison continued, “is that they have put production goals before public and worker safety. They are spending billions of dollars on a new bomb plant which is part of a commitment to the Enriched Uranium program that will depend for at least 20 more years on facilities that NNSA admits does not meet modern safety standards. This is a problem they have created for themselves, and they are trying to avoid the consequences by refusing to comply with environmental laws.”
In the Final Supplement Analysis, NNSA indicates it will publish an Amended Record of Decision that declares no further environmental analysis is required.
“We have sent our comments to reiterate the shortcomings of the Final SA,” said Hutchison, “so they have a chance to reconsider before they dig themselves deeper into the hole they are in.
OREPA’s comments can be found here.