ML19343B214

Comment (31) E-mail Regarding WEC - CFFF Draft EA

ML19343B214
Person / Time
Site:	Westinghouse
Issue date:	12/09/2019
From:	Public Commenter Public Commenter
To:	Office of Nuclear Material Safety and Safeguards
NRC/NMSS
References
84FR57777
Download: ML19343B214 (11)

Text

From:

pamela Glaw <greenlawpk@gmail.com>

Sent:

Monday, December 9, 2019 9:02 AM To:

Quintero, Jessie

Subject:

[External_Sender] Re: Re: Posting of comments submitted on the EA for the WEC-CFFF Attachments:

NRC Draft EA JBG Comments 26 Nov 2019 352 PM for XCOM FINAL to be emailed to NRC.docx

Dear Jessie,

Please let me know when you get the email attachment. Thanks!

Pamela On Mon, Dec 9, 2019 at 6:22 AM Quintero, Jessie <Jessie.Quintero@nrc.gov> wrote:

Ms. Greenlaw, I checked the email account again and did not see any emails from you. You are welcome to send the comments to me at this email address. I will get them docketed as soon as you send them along.

Thanks, Jessie PS - I copied the WEC email address to double check emails are still going through.

From: pamela Glaw <greenlawpk@gmail.com>

Sent: Sunday, December 08, 2019 10:56 PM To: Quintero, Jessie <Jessie.Quintero@nrc.gov>

Subject:

[External_Sender] Re: Posting of comments submitted on the EA for the WEC-CFFF

Jessie, Thank you for your response.

The comments I prepared and delivered at the NRC meeting about WEC-CFFF were as an individual. I had not yet had approval from the executive Committee of the John Bachman Group of Sierra CLub to comment on behalf of our Group. The comments submitted in writing are those comments made by me for or on behalf of the John Bachman Group of Sierra Club (in the Midlands.)

The email I copied from communications from NRC and to which I sent these written comments from the John Bachman Group of Sierra Club is

WEC-CFFF-EA@nrc.gov.

WEC-CFFF-EA@nrc.gov Because I did not receive any notification that my email had not gone through, I was anxious. If you can find the comments of Nov. 27 at this email address, I would like to know, as I actually did make the deadline. The alternate way to submit comments was to a webpage.

What is the correct one to which I should resend comments to?

Pamela Greenlaw Chair, John Bachman Group, Sierra CLub On Fri, Dec 6, 2019 at 12:07 PM Quintero, Jessie <Jessie.Quintero@nrc.gov> wrote:

Hi Ms. Greenlaw, Thanks for checking in. How did you submit your comments? I checked all of the comments we received through regulations.gov and our email and I dont see one from you. We of course have the comments you submitted during the public meeting. Can you email me your comments now, well accept them!

If you are doing a docket number search in ADAMS, there are two sets of comments. The comments that came in through Regulations.gov start at #4 because comments submitted previously on the June 2018 email were counted as 1-3. Those comments actually include the letter you sent back in 2018 saying an EIS should be completed. The comments through regulations.gov show up in ADAMS as Comment (##) of NAME on Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility.

For those submitted via email, they appear in ADAMS as 2019/11/xx - Comment (##) E-mail regarding WEC-CFFF Draft EA.

Let me know if you have any other questions, Jessie Quintero From: pamela Glaw <greenlawpk@gmail.com>

Sent: Friday, December 06, 2019 11:21 AM To: Quintero, Jessie <Jessie.Quintero@nrc.gov>

Subject:

[External_Sender] Posting of comments submitted on the EA for the WEC-CFFF

Dear Ms. Quintero,

A couple of days ago I spoke with you on the phone about the publishing of comments by the public. Today, I noticed that the comments listed began with #4.

Please fill me in on what the plan is to post comments #1, #2, #3, as well as the comments delivered orally at the public hearing in November.

I am particularly concerned about whether or not you actually received the comments from me on behalf of the John Bachman Group, Sierra Club. Please confirm for me that you received them.

Thank you for your attention to this matter.

Sincerely, Pamela Greenlaw Chair, John Bachman Group, Sierra Club 803-736-29

Federal Register Notice:

84FR57777 Comment Number:

31 Mail Envelope Properties (CADVZvGrUOyf9bu44QYSL9WN86bDcB0yM5Suui2-VMXgvE7ENdg)

Subject:

[External_Sender] Re: Re: Posting of comments submitted on the EA for the WEC-CFFF Sent Date:

12/9/2019 9:01:35 AM Received Date:

12/9/2019 9:02:13 AM From:

pamela Glaw Created By:

greenlawpk@gmail.com Recipients:

Post Office:

mail.gmail.com Files Size Date & Time MESSAGE 4209 12/9/2019 9:02:13 AM NRC Draft EA JBG Comments 26 Nov 2019 352 PM for XCOM FINAL to be emailed to NRC.docx 26947 Options Priority:

Standard Return Notification:

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Recipients Received:

Comments, Requests, and Information Concerning the Draft Environmental Assessment for the Westinghouse Columbia Fuel Fabrication Facility November 26, 2019 John Bachman Group, Sierra Club

Dear Madam or Sir:

This letter is a set of comments from the John Bachman Group of Sierra Club, a part of the oldest and largest, grassroots environmental organization in the United States, the National Sierra Club. Our John Bachman Group covers an area of 7 counties in the Midlands, including Calhoun and Richland Counties. It boasts a membership of roughly 900 people. As many of our members reside, worship work, recreate, and own property in the Lower Richland County vicinity of the Westinghouse Fuel Fabrication Facility, WEC-CFFF, we are very disturbed by a large number of problems with the Environmental Assessment. Wrong and omitted information, impractical timelines, and the refusal to use best practices when working with environmental justice communities throughout the entire process need to be addressed. We are stakeholders whom your decisions will affect into and beyond the foreseeable future.

We believe you at the NRC must recognize how Westinghouse has not been forthright with all in the Lower Richland Community and how it must broaden its scope to include the communities of Gadsden and Eastover in addition to the Hopkins community.

Westinghouse has had recent serious problems even through today with its safety culture and with its inability to capture and control pollution on site and drifting slowly toward off site areas. Indeed, the first EA produced in 2018 was withdrawn on account of serious events. The current EA is facing the same difficulties, as a slue of additional, serious events have been occurring, even through this week.

Using a brief outline and then a discussed number of concerns, we ask you to read all comments and grant the requests below.

Brief overview of INCIDENTS at Westinghouse (WEC-CFFF)

. The State newspaper reported the following events, some in which some workers were exposed to radiation or injured.

Since 2016, the facility has run afoul of federal regulators for different events

• uranium which built up in an air pollution control device,

• uranium leaking through a hole in the plant floor into the soil below the plant,

• failure by Westinghouse to notify authorities of historic leaks on the property,

• water had dripped a rusty shipping container leaked water onto a barrel of nuclear waste and into the ground,

• groundwater beneath the site is polluted with an array of toxins, including nitrate, solvents and nuclear materials, dating as far back as the 1980s,

• uranium and technetium-99 under the building in the groundwater will not be removed until the facility closes down and is decommissioned,

• a worker had to be hospitalized after he got uranium on his hand which could not be removed at Westinghouse, a small fire this summer erupted in a container that held nuclear material.

DEMANDS/REQUESTS-- what the community and other stakeholders need Both the NRC and Westinghouse restricted the geographical area considered to an average 5-mile radius, whereas it must consider communities in the area within a 20-mile or greater radius, especially should a disaster occur as a result of events at WEC-CFFF. Omitting stakeholders leaves a great gap in proof of the NRCs doing its due diligence. The NRC and Westinghouse must include communities throughout a 20 mile radius of WEC-CFFF. The wind blows and water flows much farther than 5-miles in every direction. In case of a disaster, preparations such as safety warning and evacuation plans must be required and implemented.

These are the things we and our families believe you, the NRC, are obligated to to do to begin to address the problems with the inadequate, present draft Environmental Assessment and its illogical, hasty FONSI statement.

The following requests/ demands should be granted:

1. Extend the public comment period beyond the current Nov. 27 by 6 additional weeks. The NRC is hastily rushing to approve a license at the same time WEC continues to commit safety violations. Reports of events by the NRC on ADAMS are posted months after violations are discovered. The latest safety violation occurred on Sept. 5 and Sept. 10, 2019 and was published on Nov. 22, 2019. This was a severe level IV safety lapse, endangering many people and their environment. Publication of this event appeared on ADAMS 5 days before the deadline to comment on the draft EA.

2. The NRC must adopt practices of effective communications with the Environmental Justice community and go the second mile beyond lock-step, traditional ways of engaging on these environmental justice issues. Publishing the EA and instructions for comments in the Federal Register indicates the NRC has done its job but not its duty. The 30 days given to read, discuss, understand, and comment on this draft Environmental Assessment (EA) are not enough. Many people in the community are not internet connected, do not have computers in their homes, and did not receive any announcements of the EA in the manner they communicate. This has been a constant theme of the community, that they do not have access to information from the NRC.

3. Abandon this draft EA and replace it with a new draft EA. The present draft EA is premature, and there are a great many errors in and omissions from this draft EA as was the 2018 draft EA. A new draft EA must be prepared and submitted for public review and

comment and it must include the must include the following: a. the safety review which the NRC promised to share by Nov. 23 and was preplanned by NRC to occur four days before the draft EA comment deadline, b. an aggressive and broad inspection schedule; The current inspection timeline and scope are too limited to gather sufficient data to plot and analyze for indications of trend of improvement or worsening of Westinghouses performance in safety culture and in managing physical pollution problems; c. the details of the quantities of each of the toxins, solvents, and nuclear materials released into the environment and recovered; d. the list of incidents and events since the last renewal license was issued in 2007; e. details of what and how proper mitigation is to occur and be evaluated to demonstrate success or failure of Westinghouses policies and procedures, especially given that both NRC and Westinghouse stated that delineating and mitigating leaks under the building would not happen until the WEC-CFFF is decommissioned; f. an analysis of the potential loss of property values by the land-owners within a 20 mile radius in cases of different scenarios from any and all emergencies or disasters resulting in contamination emanating from the WEC-CFFF into the community. In the EA section of Historical and Cultural Resources the NRC misses the mark by discussing only historical buildings, grave sites, and memorials. Culture of the deep land ethic, land ownership has been omitted and must be included. Land is the wealth of the community, the uniter, the high value in Lower Richland. Furthermore, the NRC must require Westinghouse establish a bond or insurance instrument to compensate land owners in the future should these land owners for loss of the value of their property and for relocation should a real a disaster occurring at the WEC-CFFF which affects their land, water, and air, require evacuation. An evacuation plan must be included in the EA.

4. The FONSI in the draft EA must be withdrawn and replaced with a finding of highly probable significant environmental impact over forty years. The FONSI in the EA before us on which we are commenting is a non-scientific, illogical, and unjust conclusion.

The final EA must reject a FONSI and state a finding of highly probable environmental impact over forty years based upon an examination of science of moving plumes of contaminants in groundwater, transportation of toxic materials in and out or the facility, Westinghouses (poor) track record on reduction of violations and incidents, and likelihood of having difficulty changing its safety culture over time. Assumptions, predictions, lists of plans, and wisbful thinking are NOT findings.

5. After the replacement EA draft comment period of six weeks is complete, its final EA is prepared, and the finding of probable environmental impact is determined, an Environmental Impact Statement (EIS) process must be done.

6. After the EIS process is completed, Westinghouse must demonstrate for a one-year period that their plans for dealing with problems of leaked materials and safety culture are effective. Westinghouse has to prove it is able to operate problem-free for that year before a renewed license is even considered.

7. Only a ten-year license should be considered after the EIS process is finished, given all the problems Westinghouse has had and continues to have. A forty-year license would prevent stakeholders from being able to hold Westinghouse accountable for 5 generations. For an Environmental Justice community, indeed for any community, a forty-

year license for a facility handling and processing toxic and radioactive waste, would be both cruel and unjust.

Please find below discussion of specific evidence and needs for further analyses and changes in the EA. The poor track record of WEC-CFFF is contained in lists with references to NRC documentation. You will also find comments on specific portions of the EA pertaining to o our points in the letter body above..

Westinghouse has had a history of withholding valuable information about incidents, beginning with groundwater.

In EA section 3.4, lines 27-34 on page 3-15 recognizes that there are pathways between the shallow and deeper aquifer systems such that the groundwater can move through the confining layer or potentially, through open-hole groundwater wells penetrating the confining layer. Presently, groundwater in the shallow aquifer is contaminated by organic and inorganic chemicals as well as radioactive materials from WEC-CFFF operations. Well samples obtained from the three on-site wells penetrating the confining layer suggest that groundwater in the deeper aquifer is not contaminated as a result of the WEC-CFF plant operations (WEC 2019c.)

Deeper investigation must occur to determine the source of the presence of this contamination of the shallow aquifer and to test water in the deeper aquifer from an angle other than punching through a top confining layer near the contamination of the upper, shallow aquifer. Unless it is tested, there can be no certainty that the deeper aquifer is not contaminated.

Underground piping leak at Westinghouse Columbia nuclear fuel plant (2011)

NRC didn't know about 2011 underground piping leak at Westinghouse Columbia nuclear fuel plant for six years: The U.S. Nuclear Regulatory Commission says its safety inspectors did not know for six years that uranium had leaked from an atomic fuel factory on Bluff Road, a sprawling industrial plant under scrutiny for past operating practices.

The leaking uranium, discovered by plant owner Westinghouse in 2011, was unknown to NRC inspectors until the fall of 2017, when they ran across information about the accident while preparing a special environmental study on the plant, the agency told The State newspaper. (The State Aug. 29, 2018)

Underground piping leak detected at Westinghouse Columbia nuclear fuel plant in 2011 will not be cleaned up before 2058: Seven years before a uranium leak was discovered at a Westinghouse nuclear fuel factory this summer, the toxic radioactive material trickled out of a pipe buried below the plant on Bluff Road. That 2011 leak, unknown to many Lower Richland residents, sent uranium levels soaring to amounts not typically found in the area's soggy soil, in one spot exceeding safe drinking water standards.

But Westinghouse hasn't cleaned up the polluted site - and it doesn't plan to for at least 40 years -

despite evidence the contamination will spread into creeks, ponds and groundwater, according to a June report by the US Nuclear Regulatory Commission.

If Westinghouse obtains a new 40-year operating license this year from the NRC, the cleanup would occur no sooner than 2058, when its Bluff Road plant would be shut down, federal records show. The NRC's June environmental assessment says the contaminated soil is below a uranium recovery and recycling building on the Westinghouse site.

"Because the contaminated material is located beneath the... building, the soil will not be remediated until decommissioning," the NRC report said. "Therefore, the contaminated material will likely be a source of future ground-water and/or surface water contamination if the material leaches into the shallow water-table aquifer." Westinghouse does not know how long the uranium leak - discovered in 2011 - occurred or how much pollution escaped into the ground, the NRC report said. (The State Aug.

16, 2018)

> Download: Final Environmental Assessment for the Renewal of SNM-1107, Columbia Fuel Fabrication Facility, June 2018 (12.5MB PDF)

> See also: Westinghouse requests 40-year license renewal for Columbia nuclear fuel plant Underground piping leak detected at Westinghouse Columbia nuclear fuel plant in 2011 requires soil excavation: A leak of an underground contaminated waste water line was detected under the concrete floor slab of the Solvent Extraction Area at Westinghouse Electric Co's Columbia nuclear fuel fabrication facility in 2011. Westinghouse now presented a supplement to its 2014 Environmental Report specifying how the resulting soil contamination shall be dealt with once the plant will be decommissioned. Westinghouse expects that an amount of 81,610 cubic feet [2,311 m3] of soil will have to removed.

> Download: SNM-1107 Environmental Report Supplement, March 6, 2018 (13MB PDF)

In Dec. 2018 both uranium and technetium-99 were found in groundwater on site above drinking water standards.

In July of 2019, a mere 3 1/2 months ago, uranium leaked through a 3-inch hole in the cement floor of the spiking station. During a public meeting and subsequently, no one from Westinghouse or the NRC shared how much liquid containing the uranium was lost or how long that leak had been ongoing.

According to the NRC Event Notification Report from July 23, 2019,...it was not conclusively determined that the contamination migrated into groundwater. Further, the report stated, several soil samples taken from the immediate area on July 11, 2019, were analyzed at the Columbia Chemical Laboratory. The highest measurements reported from the sample are 4,000ppm Uranium and 24ppm Fluoride with a pH of 2.4. The uranium results were 1,000 times the EPA limit for drinking water.

Although the soil under the hole where the leak occurred was removed and monitoring of the soil and water will continue, it is important to note that just because there were no immediate negative effects on people, the soil and the groundwater does not mean that no such effect will show up later, particularly if there are interactions and synergistic relations among different contaminants. WEC-CFF and NRC agreed the clean up of more soil than what was collected might break through a confining layer of clay.

Section 4.4.2.2.Radiological Contaminants states in lines 22-23, Operations have resulted in abnormal leaks and spills that allowed the release of uranuim and T-99t o the environment.

HUMAN ENVIRONMENT and SAFETY CULTURE:

WESTINGHOUSE is not forthcoming and has exhibited a pattern of failure to report.

Under the EA there should be evidence of improvement in the safety culture described in the EA, yet, Section 4.13 Public and Occupational Health, lines 13 - 16 state that renewal of the WEC-CFFF license does not involve changes in current operating practices; therefore, changes in public and occupational health are not expected. The EA should examine evidence of improvement in the safety culture related to operating practices. The result of lax following of safety practices of the recent past belie the overt statement that current operating practices do not need improvement because changes in public and occupational health are not expected for the future. These statements seem to discount the workers over the years who have been hospitalized after having been contaminated with toxic and/or radiological material. Though no immediate deaths were reported, safety culture improvements would do much to prevent worker accidents and regulation violations.

On Apr. 25, 2018, NRC issued a Notice of Violation to WEC, because "the licensee failed to assure that under normal and credible abnormal conditions, all nuclear processes were subcritical. Specifically, the licensee failed to assure that, under the credible abnormal condition of a fissile-bearing solution leak from process vessels or piping in the solvent extraction or cylinder wash areas, movement and replacement activities for 55-gallon drums used for processing in the uranium recycle and recovery services (URRS) area would remain subcritical. This resulted in a failure to include a credible accident sequence in the licensee's integrated safety analysis."

> Download: Inspection Report and Notice of Violation, Apr. 25, 2018 (PDF)

NRC issues Notice of Violation to Westinghouse for non-compliance to safety rules at Columbia nuclear fuel plant that lead to hydrofluoric acid spill

"[...] the licensee failed to establish adequate management measures to ensure that two engineered controls identified as IROFS [items relied on for safety] were designed and implemented such that they were available and reliable to perform their function. Specifically, for a minimum of three years prior to June 16, 2018, established management measures failed to ensure IROFS ADUHFS-502 and ADUHFS-902 were available and reliable to perform their intended function when needed in order to comply with the performance requirements of 10 CFR 70.61. As a result, on June 16, 2018, hydrofluoric acid (HF) solution was spilled from HF Spiking Station #2 and spilled from the diked area. [...]" (enphasis added)

(NRC Inspection Report and Notice of Violation, Oct. 5, 2018)

Violation of criticality rules at WEC-CFFF Columbia nuclear fuel plant "As part of a review to revalidate the design of passive safety controls, on October 16, 2019 an engineering calculation was completed which demonstrates that one of two independent and redundant passive overflow devices used in the Solvent Extraction (SOLX) process was undersized for its

credited safety function. This passive overflow device is an Item Relied On For Safety (IROFS),

designated as SOLX-115. The IROFS prevents the potential backflow of uranium bearing solution from the SOLX process into the commercially-provided, chemical supply drums. These drums are non-favorable geometry (NFG) containers used to add chemicals to the batch process.[...]"

> View: NRC Event Notification Report for October 17, 2019, Event No. 54335

> Download: Follow-up report, Nov. 15, 2019 (PDF)

Workers at Westinghouse Electric Co. Columbia nuclear fuel plant still receive individual radiation doses twice average According to NRC's report on occupational radiation exposure at NRC-licensed facilities in 2017, the workers receiving the highest individual doses in the U.S. nuclear fuel industry are those employed at Westinghouse Electric Co.'s Columbia nuclear fuel plant. In 2017, the individual TEDE (total effective dose equivalent) annual dose of workers with measurable dose was 1.74 mSv at this plant, while the average for all five fuel facilities covered was 0.088 mSv.

> Download: Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2017, Fiftieth Annual Report, NUREG-0713 Vol. 39, U.S. NRC, March 2019.

Although these doses are within the regulations, the report is of the average dose for workers. The range of exposures among the workers and the highest doses for particular individuals are not delineated. This means that for a number of workers, the exposure levels to chemical and radiological materials may be higher than average. This is a crucial factor requiring investigation rather than a glossing over in the EA.

INSPECTIONS AND EVALUATIONS:

Finally, the EA Environmental Sampling program described in Table 2-3 sets out a once-per-year sampling for vegetation soil, fish, and sediment. This will not provide valid scientific information measured over time which can be plotted and analyzed. A schedule of sampling must not be less than once per quarter for everything to be tested, as all could have an impact on human health.

Sincerely and eagerly awaiting your agreement with our requests and the granting thereof, Pamela Greenlaw Chair, John Bachman Group, Sierra Club 803-736-2977