Arial photo of Y-12 Plant, Oak Ridge, Tennessee, Photograph Attribution:

https://en.wikipedia.org/wiki/Y-12_National_Security_Complex#/media/File:Y-12_Aerial.jpg

Background

The U.S. Department of Energy (DOE) National Nuclear Security Administration (NNSA) released an environmental assessment draft for the proposed movement of the Lithium Processing Facility (DOE/EA-2145) to the unused Biology Complex at the Y-12 National Security Complex. The Y-12 Security Complex is a multi-use facility that "maintains the safety, security, and effectiveness of the U.S. nuclear weapons stockpile."

Link to DOE/EA-2145

Link to Environmental Assessment

Comments Delivered to This email address is being protected from spambots. You need JavaScript enabled to view it.

U.S. Department of Energy, National Nuclear Security Administration

NNSA NEPA Document Manager, Attn: LPF Draft EA

P.O. Box 2050, Oak Ridge, TN 37831

Re: DOE/EA-2145: Lithium Processing Facility at the Y-12 National Security Complex; Oak Ridge, Tennessee, Public Comments, Due January 22, 2021

To Whom It May Concern:

Environmental Review, Inc. has reviewed the draft Environmental Assessment for the Oak Ridge Y-12 project and has the following comments:

1. Page ES-1 – this document appears to use the Executive Summary for a high-level explanation of environmental impacts. This approach appears to sidestep meaningful evaluation in the body of the report, and the report does not include a conclusions and recommendations section. Paragraph 1 states that the report assesses the impacts of facility construction but fails to appropriately consider the impacts from implementation (demolition, remediation, construction...).

2. Page 2-6 Utility lines and a water line are discussed, are those areas impacted by contaminants? If so, this section should describe the impacts. Addressing environmental impacts including subsurface contaminants in soil and groundwater should be evaluated and emphasized by adding new sections to the report. Those topics are likely to be significant given the industrial usage of the site and those topics are ostensibly absent from this document. Where applicable, add contaminant plume maps, data tables, and geologic cross sections. Why have these topics been given short shrift?

3. Page 3-1 section 3.1, paragraph 2 cites 40CFR Parts 1502.1 and 1502.2 and recommends a “sliding scale approach” for selecting which activities are significant. Clarification is needed on how this approach is implemented in this document and where the activities fall on a continuum with respect to the environmental impacts.

4. Page 3-1 section 3.1 paragraph 3 - This discussion narrows the scope of the environmental impacts to consider by separating the impacts from phasing out operations in building 9204-2 which was discussed in a different section (section 3.15) and demolition (section 3.16). Review of sections 3.15 and 3.16 indicates that significant work including environmental cleanup will likely occur during the demolition phase. Those activities are major activities so they should be included as environmental impacts (during the construction phase). That approach appears to sidestep the necessity of evaluating environmental impacts. That appears to be wholly inappropriate, so clarification is needed in this regard.

5. Figure 3-2 on page shows the age of mission-critical facilities at Y-12. It does not, however, specify the expected lifespan of the new project. What measures can be implemented to ensure building lifespans reach and exceed expectations? Given the project involves relocation of the lithium processing facility to an existing structure, will this renovation consider the completed project site as a new or existing building?

6. Section 3.6.2 on page 3-21 states that “small quantities of process water generated during lithium processing would be characterized and properly disposed.” What is the approximate amount of wastewater produced on an annual basis? To where will lithium contaminated water be removed? If this contaminated water is being removed off-site, what protocols are in place to prevent spills in the transportation process?

7. Section 3.12 in the document mentions construction and operation waste, including special waste, will be transported to nearby waste facilities. Is there any protocol to ensure materials in transit to the waste storage facility do not escape and contaminate areas along roadways? If there is a spill, how will it be handled to ensure local roadways and ecosystems are properly protected?

8. This document should have sections added, including for the environmental impacts during implementation or construction, soil and groundwater contamination from historical industrial operations, conclusions, and recommendations sections. Those sections should discuss the contents of the necessary evaluations, not just mention it in passing as a done deal in the Executive Summary section.

Please direct all responses to these comments to the following email addresses: This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it., and This email address is being protected from spambots. You need JavaScript enabled to view it..

Sincerely,

Wesley Hoffer (Associate in Virginia)

Environmental Reviewer

Environmental Review, Inc.

1792 Rogers Avenue

San Jose, California 95112

Stefano Favuzzi (Associate in Illinois)

Environmental Reviewer

Environmental Review, Inc.

1792 Rogers Avenue

San Jose, California 95112

Scott Leroy (Associate in Maryland)

Senior Environmental Reviewer

Environmental Review, Inc.

1792 Rogers Avenue

San Jose, California 95112

Environmental Review Workshop - 501(c)(3) Nonprofit Public Benefit Corporation (Environmental Review, Inc.)