Staff Reports
NS&D Monitor
07/31/15
As the July 30 deadline neared for public comment on the National Nuclear Security Administration’s draft environmental assessment for a new emergency operations center at the Y-12 National Security Complex, an activist group urged the agency to release more information and to merge the EA process with a supplement to a site-wide environmental impact statement (SWEIS) that was prepared in 2011 but might need to be updated due to changing plans for the Uranium Processing Facility and other projects at the Oak Ridge site.
The Oak Ridge Environmental Peace Alliance, a longtime critic of Y-12 operations, is strongly against construction of the multibillion-dollar UPF, but the group’s leader – coordinator Ralph Hutchison – said on Wednesday the EOC is an important facility and should be built. However, he added, it should be planned with updated seismic data, based on new reports by the U.S. Geological Survey and others, and not rely on some of the old information in the 2011 SWEIS.
The NNSA has not confirmed that it will revise the SWEIS, but spokesman Steven Wyatt earlier this year acknowledged that it was a possibility.
“We are probably only months away from the announcement of the preparation of a supplement to the now-outdated 2011 (SWEIS),” Hutchison said in a prepared statement. “The EOC should be included in that process, which will be more rigorous (than an environmental assessment). The point of a site-wide environmental analysis is to integrate all significant projects in a single plan.”
Hutchison said the proposed EOC is not a nuclear facility and thus might not be subject to some of the stringent design standards. “But,” he argued, “ its mission requires it to survive even if – especially if – nuclear facilities are failing. Common sense requires that 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.”
The NNSA plans to construct the new emergency operations center on the east side of the sprawling Oak Ridge plant.
The peace alliance said the draft EA does not analyze all the environmental impacts associated with the new emergency center and said soil samples evaluating possible contamination have not yet been taken.
“They really can’t issue a credible ‘finding of no significant impact’ if they haven’t analyzed soil data,” Hutchison said.
OREPA’s comments note that combining the environmental assessment for a new EOC with the overall impact statement on the entire Y-12 site would save taxpayers money and accelerate the Department of Energy’s decision-making schedule regarding multiple projects associated with Y-12 modernization.
Hutchison said the DOE, including the NNSA, have become “increasingly opaque” in recent years, refusing to release information to the public and “erecting barriers” to limit access to public information.
“This does not inspire confidence from the public,” the group said in comments submitted to the NNSA’s James Donnelly, the NEPA compliance officer for the environmental assessment. “Quite the contrary, it inspires curiosity and suspicion – what does our government have to hide from us?”
The group added: “Despite NNSA’s refusal to formally publish plans for its multibillion-dollar modernization effort at Y-12, the public is aware that the current roadmap calls for construction of several new facilities designed to varying levels of seismic response, and to continue the use of aging facilities which do not meet current earthquake design standards for 20 years or more.”
In the summary of its comments, OREPA said combining the environmental reviews makes common sense.
“Analysis of the environmental impacts associated with construction of the EOC, or any other facility, should be made in the context of plans for ongoing operations at Y-12 for the life of the proposed facility itself and the operational facilities at Y-12.”
