OREPA Accuses NNSA of Mendacity on Nuclear Criticality Safety

OREPA | orepa.org

A letter dated April 6, 2020 from Lisa Gordon-Hagerty, Administrator of the National Nuclear Security Administration, to Consolidated Nuclear Services, operating contractor of the Pantex and Y-12 nuclear weapons facilities, highlights ongoing criticality safety deficiencies at the Y-12 National Security Complex in Oak Ridge, Tennessee.

The letter, a Preliminary Notice of Violation, characterizes the nuclear criticality safety deficiencies as “of high safety significance.” In the letter, NNSA reveals that CNS has failed to implement the criticality safety plan that was in place when it took over operations at the facility in 2014.

During that same period—and even before, stretching back to at least 2010, NNSA has failed to hold its contractors accountable. Instead, NNSA and its contractors have issued assurances that safety is their paramount concern at Y-12. In a February 2018 meeting in Oak Ridge, Y-12 site manager Geoffery Beausoleil declared that he simply would not allow a worker to be put in an unsafe workplace.

            “There is no polite way to put this,” said Ralph Hutchison, coordinator of the Oak Ridge Environmental Peace Alliance, “and it’s important that we are crystal clear because of what is at stake. They are lying about safety at Y-12.

“This Preliminary Notice of Violation is only the tip of the iceberg,” said Hutchison. “It appears to be NNSA’s effort to pass the buck to its contractor, blaming them for not acting on this since they took over in 2014. Where has NNSA been all this time? Do they think throwing CNS under the bus absolves them of their failure to provide oversight?”

CNS and NNSA have long been aware that highly enriched uranium is present in processing equipment and lines in quantities that were likely to exceed criticality safety limits. The issue had been raised as early as 2007 by the Defense Nuclear Facilities Safety Board—the DNFSB sent a letter to NNSA in July 2019 highlighting its concerns; that letter declared a systemic breakdown in criticality safety programs at Y-12 and charged NNSA with failing to act in a timely manner to address concerns that were formally raised in February 2019.

The problems continue. Criticality safety problems are identified on an almost weekly basis by the Safety Board’s resident inspectors. They include discovery of accumulations of fissile material in processing lines, filters, and equipment; storage of fissile materials in unapproved areas and containers; lack of institutional knowledge; interruptions in processing operations because of failing equipment; and failure to follow prescribed procedures when problems are discovered.

The attention to criticality safety reveals duplicity on the part of NNSA and its contractor, Hutchison says. “A key element in NNSA’s effort to reduce risks to workers and the public while they continue to work in unsafe, deteriorating buildings has been a program to remove excess ‘Material-at-Risk’. It is an attempt to limit highly enriched uranium in Buildings 9212, 9215, and 9204-2E, all of which fail to meet current environmental and seismic safety standards—two of them lack modern criticality safety alarm systems.

“But the Safety Board’s most recent weekly report, April 10, 2020, notes the presence of dollies loaded with uranium chip cylinders that appear to be leaking. The report notes that ‘chip dollies in Buildings 9212 and 9215…have been stored for significantly longer than prior practice.’”

The backlog is due to an interruption in processing equipment in November of 2018.

“Why is this material-at-risk still in these buildings?” Hutchison asked. “We’ve been told they have a program—they told a federal judge—and as recently as this month in an environmental analysis they described their ‘ongoing program’ to minimize vulnerabilities by removing all material-at-risk. And now we find there are chip cylinder dollies, several of them leaking, that have been sitting there since 2018 with no removal in sight?”

NNSA notes that CNS is in violation of federal law and says fines in excess of $1.2 million could be levied. But they won’t, NNSA says, because CNS was already penalized $800,000 in its 2018 performance review.

CNS has thirty days to respond to the Preliminary Notice of Violation.


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