Two nuclear watchdog organizations are urging Energy Secretary Ernest Moniz to order a new site-wide environmental impact statement for the Y-12 National Security Complex due to changes in a major construction project at the Tennessee nuclear weapons facility.
The updated EIS is necessary after the department amended its 2011 record of decision for the new Uranium Processing Facility, canceling plans for a single “Capability-sized UPF” building and advancing construction of multiple structures while sustaining operations at the decades-old Buildings 9202-2E and 9215, according to an Oct. 27 letter to Moniz from the Oak Ridge, Tenn., Environmental Peace Alliance and Nuclear Watch New Mexico.
“The Amended Record of Decision for the Uranium Processing Facility (UPF) is a significant change from the National Nuclear Security Administration’s July 2011 Record of Decision for the Final Site-Wide Environmental Impact Statement for the Y-12 National Security Complex in Oak Ridge, Tennessee,” the letter says. “As an agency within the Department of Energy, NNSA is required under the National Environmental Policy Act (NEPA) to prepare a Supplemental Environmental Impact Statement if ‘there are substantial changes to the proposal or significant new circumstances or information relevant to environmental concerns.’ (10 CFR § 1021.314(a); 40 CFR § 1502.9(c)).”
The organizations have requested a response within 30 days.
In response to questions on the matter, NNSA spokeswoman Francie Israeli said the agency has received the letter and is considering its response.
The UPF is intended to provide all enriched uranium processing capabilities at Y-12 for the U.S. nuclear arsenal, enabling the NNSA to retire its 71-year-old Building 9212. Under congressional mandate the new complex should be finished by 2025 at a cost of no more than $6.5 billion.
In the face of concerns over increasing costs and a lengthening completion timeline for UPF, the NNSA signed off on the 2014 Red Team recommendation to build multiple, smaller structures rather than one massive building.
The semiautonomous DOE agency in 2011 released its final site-wide environmental impact statement (SWEIS) for Y-12, followed by a supplement analysis in April of this year. Both documents addressed measures needed to sustain Y-12’s uranium processing activities “in a safe and secure environment,” including those covered by the 2016 amended record of decision, obviating the need for further environmental analysis, the agency said in the ROD.
“Based on the analysis in the SA, NNSA’s revised strategy is not a substantial change to the proposals covered by the Y-12 SWEIS, nor does it represent significant new circumstances or information relevant to environmental concerns,” the NNSA document says.
The watchdogs begged to differ on the question of new circumstances. The NNSA’s amended record of decision and earlier environmental documents indicate that existing production facilities at Y-12 would not be upgraded to cover modern environmental and seismic standards, even given U.S. Geological Survey findings published in August 2014 showing a spike in the earthquake danger for the seismic zone that covers Y-12, according to the letter. The organizations were not convinced by the NNSA supplement analysis’s finding that the updated USGS data was “not relevant.”
The February 2014 finding of a previously unidentified radioactive debris field during UPF site preparation is another new data point of worry, the letter says. Contaminated debris, some of it radioactive, has been found no fewer than 50 times, according to media reports cited by Nuclear Watch New Mexico and the Oak Ridge Environmental Peace Alliance. The NNSA must scrutinize the situation before moving ahead with the project, or face the potential for significant exposures to personnel working on the UPF, they said.
The new plan also means maintaining the “old, contaminated” Buildings 9215 and 9202-2E, rather than eliminating them as previously planned, Nuclear Watch New Mexico Executive Director Jay Coghlan said in a telephone interview.
Coghlan said he doubted DOE would respond affirmatively to the watchdog’s request. Should that prove to be the case, “We’ll be examining our options and NNSA should look upon that statement as they wish,” he said.
