ML20244A380
| ML20244A380 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/30/2020 |
| From: | Public Commenter Public Commenter |
| To: | Office of Nuclear Material Safety and Safeguards |
| NRC/NMSS | |
| References | |
| 85FR46193 | |
| Download: ML20244A380 (7) | |
Text
From: John Grego <friendsofcongareeswamp@gmail.com>
Sent: Sunday, August 30, 2020 5:56 PM To: WEC_CFFF_EIS Resource
Subject:
[External_Sender] Re: Westinghouse Environmental Impact Statement Scoping Process Federal Register Notice Attachments: Westinghouse 2020 EIS Scoping Public Comments.docx NRC--Friends of Congaree Swamp has attached comments on scoping of an EIS for Westinghouse Electric Company LLC related to Dockets No. 70-1151 and NRC-2015-0039.
Prof. Grego On Fri, Jul 31, 2020 at 11:25 AM WEC_CFFF_EIS Resource <WEC_CFFF_EIS@nrc.gov>
wrote:
Good morning On July 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff announced, in the Federal Register, its intent to prepare an environmental impact statement (EIS) for Westinghouse Electric Company, LLCs (Westinghouses) request to renew its operating license for its Columbia Fuel Fabrication Facility in Hopkins, South Carolina, and the beginning of the scoping process. See 85 FR 46193.
The NRC staff is inviting the public, local, State, Tribal, and Federal government agencies to participate in the environmental scoping process by submitting written comments during the scoping comment period, which ends on August 31, 2020, via:
o Federal Rulemaking Web Site: Go to https://www.regulations.gov and search for Docket ID NRC-2015-0039, o E-mail comments to: WEC_CFFF_EIS.resource@nrc.gov, o Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001.
The NRC is conducting the EIS scoping process in accordance with section 51.29 of Title 10 of the Code of Federal Regulations (10 CFR). The purpose of the scoping process is to determine the appropriate scope of the EIS, including significant environmental issues to be analyzed in depth, as well as those that should be eliminated from detailed study because they are peripheral or are not significant. After the close of the scoping comment period, the NRC staff will prepare a concise summary of its scoping process in accordance with 10 CFR 51.29(b). The scoping summary report will be sent to each participant in the scoping process for whom the staff has a physical or e-mail address.
Once the draft EIS has been prepared, the NRC staff will publish it for public review and comment in accordance with 10 CFR 51.73.
Federal Register Notice: 85FR46193 Comment Number: 20 Mail Envelope Properties (CAK8bcS3+iausk1q169CiXH=R34mx+fM+v6nq9wfetE-ewMJfXQ)
Subject:
[External_Sender] Re: Westinghouse Environmental Impact Statement Scoping Process Federal Register Notice Sent Date: 8/30/2020 5:55:30 PM Received Date: 8/30/2020 5:55:50 PM From: John Grego Created By: friendsofcongareeswamp@gmail.com Recipients:
Post Office: mail.gmail.com Files Size Date & Time MESSAGE 2243 8/30/2020 5:55:50 PM Westinghouse 2020 EIS Scoping Public Comments.docx 224656 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
PO Box 7746 Columbia, SC 29202-7746 August 25, 2020 Office of Administration Mail Stop: TWFN-7-160M US Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff RE: Dockets No. 70-1151, NRC-2015-0039
Dear Nuclear Regulatory Commission,
Friends of Congaree Swamp would like to offer the following comments on the scoping process for an Environmental Impact Statement for Westinghouse Electric Company LLC/Columbia Fuel Fabrication Facility (WEC). We will note WECs poor record of notification and compliance and do not feel that their actions under the previous permit warrant a 40-year extension.
Recent Reporting Incidents. The Draft Environmental Assessment released during the November 2019 public comment period rightly noted the history of recent incidents at WEC, but de-emphasized the troublesome handling of these incidents. First, there is the context of the re-opened Environmental Assessment. Less than a month after issuing the draft Environmental Assessment and FONSI in June 2018, a leak at Hydrofluoric Acid Spiking Station #2 released uranyl nitrate and hydrofluoric acid into the soil, an incident that further raised concerns about WECs environmental and safety record. WECs initial response to the report of this incident also raised alarms; they planned to monitor any COPC (Constituents of Potential Concern) migration using an existing monitoring well 190 feet away from the site; at typical rates of groundwater flow, contamination would not be detected for over a year. Fortunately, SCDHEC requested a more aggressive sampling plan.
Leaks including radionuclides from a contaminated wastewater line in 2008 and 2011 were not reported at the time they occurred, and only came to light in 2019. The 2011 incident is particularly concerning because WEC at that time was petitioning SCDHEC to decommission air sparging and soil vapor extraction onsite and was granted relief.
Another incident from 2019 raised management questions as well. During a May 2019 inspection, SCDHEC found numerous intermodal containers containing storage barrels that had not been previously reported. Some of these intermodal containers and the barrels stored therein were not well maintained, and contamination was found on-site.
Further, these containers, designed only for temporary storage, had been used for storage for up to 14 years. Though this incident appeared in the Environmental Assessment, WECs failure to disclose the site and existing contamination showed lack of attention to proper site management and disclosure. Further, the Environmental Assessment made no mention of the accidental nature of the discovery of this problem.
Intermodal containers. The damaged and leaking trailers and their contents are currently being remediated under the Southern Storage Area Operable Unit Intermodal Container Work Plan, details of which appear in the Final Interim Remedial Investigation Summary Report developed as part of Westinghouses February 2019 Consent Agreement with SCDHEC. Under the negotiated work plan, Westinghouse has been required to test soil underneath the containers for radionuclides, empty the containers of their barrels, properly dispose of the barrels and their contents, and ship the containers off-site (some as low-level radioactive waste). Contaminated soil beneath the containers was removed and subsequent tests found no further evidence of contamination. Though this situation has been resolving itself well, it is symptomatic of issues with the safety culture at the plant.
Reporting. Unfortunately, the Communications Protocol prepared as part of the Consent Agreement leaves too many reporting decisions to WECs discretion. Given WECs history, we are not confident that future incidents will be disclosed in a timely manner.
We request that the Communications Protocol be revisited as part of the Environmental Impact Statement.
Wildlife impacts. The discussion of possible impacts on wildlife in the Environmental Assessment was insufficient. The site straddles the ecotone between the Congaree River floodplain and bluff ecosystems and lies along obvious migration/transit corridors for a large variety of wildlife. Impacts on wildlife need to be more carefully explored; we would request surveys to assess wildlife onsite (e.g., field transect surveys for birds and camera traps for fauna), as well as studies to inventory and assess aquatic life in Mill Creek. Though Wood Stork and Rafinesques Big-eared Bat were listed in the Environmental Assessment as species of concern in the area, the environmental impact statement should more specifically discuss impacts on these species.
Cultural impacts. The Westinghouse site lies along the bluff edge at a prominent bend in Mill Creek and is a likely site of Native American activity, if not settlement. We would request a thorough archaeological survey on site to identify and protect sites of interest.
Further, Prof. Mark Groover studied the nearby Thomas Howell site (38RD397). Plats and maps dating to the mid-1700s identify a road from Howells Ferry passing by the Thomas Howell site and through lands now occupied by the Westinghouse facility. An effort should be made to identify the footprint of this historic road.
Wards Mill in the 1825 Robert Mills map appears at the current site, and is identified by Harry Hampton in Woods and Waters and Some Asides as the former site of Sunset club pond). A USDA Drainage Investigations map from 1908 identifies the current site of Upper and Lower Sunset lakes as Rawls Mill (adjacent to a plat owned by Belton Rawls). Annotation on the map indicates that the stage of historic floods in 1903 and 1888 were recorded on site, so there is evidence of consistent (and possibly continuous) use of the mill dating through the early 19th century, and possibly earlier. The archaeological survey should require a thorough investigation of the history of these impoundments and identify opportunities to protect and interpret the site. In addition, we would request localized archaeological surveys prior to the siting of any monitoring wells or additional site infrastructure.
Sediment sampling and the Sediment Transect Sampling Work Plan. Detection of uranium in sediment/sludge samples from stormwater ditches, wastewater treatment plant lagoons, and both Sunset lakes precipitated further study. Sediment sampling included the East lagoon and sanitary lagoon as well as waterbodies in the floodplain. Sediment sampling in Upper and Lower Sunset Lake and the channel of Mill Creek was required under the Consent Agreement, and results from the sampling are troubling. Fluoride and Nitrate were detected in many of the samples, and Uranium was detected in the wastewater treatment lagoon and four samples from the Sunset lakes. As SCDHEC noted in its comments on the Draft Interim Remedial Investigation report, the presence of uranium in the Sunset lakes was unexplained. Westinghouse speculated the uranium may have resulted from a 1971 spill of 1 to 1.5 million gallons of wastewater, while SCDHEC noted that information from the spill had not been shared in Westinghouses reporting since 1977. We request that additional investigation of the 1971 incident be required, and that a source study for uranium in the Sunset lakes be conducted rather than accepting Westinghouses explanation at face value.
Fish tissue study. As part of the Consent Agreement, Westinghouse tested for uranium and fluoride near its outflow on the Congaree River, as well as two locations far downstream (centered at US 601) and far upstream (centered at the Thomas Newman boat landing) from the out-take. Westinghouse has a permit for the outflow to discharge process wastewater, contaminated wastewater, and sanitary wastewater; the first two may include uranium. Results from the study indicated that fish at the discharge were in slightly poorer condition and had higher concentrations of fluoride than fish from the control sites, though no differences in uranium concentration was found. Westinghouse tried to argue away the results for fluoride by citing possible alternative explanations for the fluoride results, none of which were explicitly tested. To be clear, the test was designed to identify differences in CPOCs in fish tissues between the out-take and control sites, and differences were in fact detected. We would like additional testing to take place, including freshwater mussels.
Surface water sampling had been intermittent in the past, but sampling conducted as part of the Remedial Investigation found Fluoride in all samples, nitrate in several, and CVOCs in two. Sampling included drainage ditches, Gator Pond and Upper and Lower Sunset Lakes. Uranium was detected in all samples, though an order of magnitude below
the MCL (Maximum contaminant level); no Technetium-99 was discovered in the water samples. Given the prevalence of CPOCs in surface waters near the facility, we recommend sampling of fish species in the Sunset lakes and Mill Creek to test for CPOCs.
Technetium Source Investigation Work Plan Technetium-99 (Tc-99), a man-made radionuclide, had been detected in groundwater and the East Lagoon, a wastewater storage site with an aging, 1980s era liner. The East Lagoon was initially believed to be the source of Technetium-99 contamination, but a work plan was set up to identify alternative sources, as well as the extent of Tc-99 contamination. Tc-99 was tested at a variety of potential sources in two different phases, and neither phase has conclusively established a source. The Phase I study identified Tc-99 in the sediments of the East Lagoon and Alligator Pond and in groundwater, but not in soil or surface water samples, and could not identify a source for the contamination.
Additional process sites were sampled in Phase II to understand the extent of contamination and identify its source. Results in the Final Interim Remedial Investigation Summary Report were inconclusive, though contour plots of Tc-99 concentration strongly suggest the East Lagoon as a source. We were troubled by Westinghouses contour plot of Tc-99 contamination, as it explicitly excluded contour lines at 10 pCi/L, though Westinghouse indicated in the report narrative that they had done so . With the source yet unidentified, it is absolutely critical that the Tc-99 source investigation continue. Westinghouse tried to argue in the Final Interim Remedial Investigation Summary Report that they should not report lower levels of Tc-99, as per SCDHECs request, but we agree with SCDHEC that more sensitive testing take place.
Groundwater sampling. The groundwater sampling system now comprises over 90 wells, with 29 added as part of the consent agreement, including several placed in the floodplain for the first time. Alarmingly, some of the floodplain wells detected CVOCs including a couple that were placed on the opposite side of Mill Creek and the Sunset Lakes from the plant. Westinghouse argued that there was evidence that floodplain soils were degrading the CVOCs, but SCDHEC was particularly troubled by the presence of any CVOCs at all at wells downgradient of Mill Creek and the Sunset lakes, since there was no obvious explanation of how a contaminant plume could pass under the lakes. Though groundwater models have been refined at part of a conceptual site plan, we agree with SCDHEC that there is more that needs to be learned about the surficial aquifers at the site.
Groundwater contamination by fluoride, nitrates, Chlorinated Volatile Organic Compounds (CVOCs), and radionuclides has been well-documented for years. Three different contaminant plumes have been identified for CVOCs: a western groundwater area of concern, a main contaminant plume (check location), and an eastern plume.
Most of the nitrate and fluoride contamination is downgradient of wastewater treatment lagoons, but we recommend further investigation to definitely identify a source for all three groundwater plumes. Further, we request that air sparging and soil vapor extraction remediation used until 2011 be studied for renewal.
Sincerely, John M. Grego, President