Criticism of the National Nuclear Security Administration

May, 25,2020

Ms. Terri Slack
P.O. Box2050
Oak Ridge, TN

Dear Ms. Slack,

We, The Western North Carolina Chapter, Physicians for Social Responsibility express our concern over the inadequacies of the National Nuclear Security Administration (NNSA) draft supplement analysis (SA) for the Y-12 complex in Oak Ridge Tennessee.

We add our voices to the criticism made by the Defense Nuclear Facilities Safety Board who in July, 2019 concluded that the Y-12 criticality safety program is dealing with systemic, and long-standing problems; among them is the failure to properly address risks associated with earthquake hazard in the region. The seismic hazard analysis needs to be reviewed using the USGA maps updated in 2014.

We are concerned to learn that the Supplemental Analysis limits the analysis to only some parts of the Y-12 complex. Earthquakes are regional in nature, and a major seismic event would affect more than just the UPF and the two ELP facilities. Indeed, it would affect not just the whole of Y-12, but also the entire area. 

The public has a right to data that will help us understand the risks that NNSA proposes to  undertake in our name. PSR/WNC is concerned not just with radiological threats, but also the potential release of other toxins or hazardous materials.

NNSA must not proceed without a more inclusive, and carefully thought out SA or EIS. We need a new EIS, or SA for all of Y-12. We need to understand the risks to the entire facility, as well as the greater Oak Ridge community.

When a revised EIS or SA is produced, NNSA needs to schedule an extended period for public review or comment, and arrange for well publicized public hearings.

Thank you.

Sincerely,

Terrence P. Clark, MD
Chairman
Western North Carolina Chapter
Physicians for Social Responsibility