ML20247J533
| ML20247J533 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/31/2020 |
| From: | Public Commenter Public Commenter |
| To: | Office of Nuclear Material Safety and Safeguards |
| NRC/NMSS | |
| References | |
| 85FR46193 | |
| Download: ML20247J533 (5) | |
Text
From: Congaree Riverkeeper <CRK@congareeriverkeeper.org>
Sent: Monday, August 31, 2020 4:58 PM To: WEC_CFFF_EIS Resource
Subject:
[External_Sender] Westinghouse EIS Scoping Comments (Docket ID NRC-2015- 0039)
Attachments: CRK Westinghouse EIS Scoping Comments (Docket ID NRC-2015-0039).pdf To Whom It May Concern:
Please find attached Congaree Riverkeeper's scoping comments for the Westinghouse Columbia Fuel Fabrication Facility EIS (Docket ID NRC-2015- 0039).
Thank you and please let me know if you have any questions.
Bill Stangler Congaree Riverkeeper 803-760-3357
Federal Register Notice: 85FR46193 Comment Number: 33 Mail Envelope Properties (CAJCpkTEXhdU2rWpvp0P8Zpx1=y1XTpLcsF_CNt8k76pHx30CAQ)
Subject:
[External_Sender] Westinghouse EIS Scoping Comments (Docket ID NRC-2015- 0039)
Sent Date: 8/31/2020 4:58:25 PM Received Date: 8/31/2020 4:58:48 PM From: Congaree Riverkeeper Created By: CRK@congareeriverkeeper.org Recipients:
Post Office: mail.gmail.com Files Size Date & Time MESSAGE 340 8/31/2020 4:58:48 PM CRK Westinghouse EIS Scoping Comments (Docket ID NRC-2015- 0039).pdf 781058 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
August 31, 2020 U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: Scoping Comments for Westinghouse EIS (Docket ID NRC-2015- 0039)
To Whom It May Concern:
I am writing on behalf of Congaree Riverkeeper to submit the following comments as part of the scoping process for the preparation of an environmental impact statement (EIS) related to Westinghouse Electric Companys request to renew the operating license for its Columbia Fuel Fabrication Facility (CFFF) in Richland County, South Carolina.
The U.S. Nuclear Regulatory Commission (NRC) announced in the federal register on July 31st, 2020 their intent to prepare an Environmental Impact Statement for this project1. This EIS is being prepared because the Environmental Assessment published in October 2019 failed to account for and analyze the impacts from both recent and historical release of contaminants from the facility. This EIS should include a full accounting of all past releases from the facility to appropriately determine the environmental impacts of renewing the operating license for the facility.
This facility has had past releases or potential releases from several sources, including leaks from unlined lagoons, spills in the process area, and poor management of materials in storage areas.
The EIS should identify all possible sources of releases of contaminants and evaluate the likelihood and potential impacts of future releases.
The EIS should include an examination of both exiting and ongoing, as well as any anticipated or possible impacts to both groundwater and surface water resources. The EIS should also examine the movement of existing contamination off site, as well as the movement of existing contamination towards Waters of the State/Waters of the US.
1 https://www.govinfo.gov/content/pkg/FR-2020-07-31/pdf/2020-16150.pdf Post Office Box 5294
- Columbia, South Carolina 29250 1 (803) 760-3357
- www.congareeriverkeeper.org
The EIS should examine existing and potential impacts to flora and fauna. This should include, but not be limited to, species protected under the Endangered Species Act and included in SCDNRs State Priority Species List2 In addition to examining potential impacts to aquatic species, as mentioned above, the EIS should also examine potential impacts of fish consumption on human health.
At least twice in the past (a spill from West Lagoon 1 in 19713 and the overflow of two lagoons in October 2015) lagoon failures have caused a release of contaminants into the environment.
This facility has six operating waste lagoons, including one without a liner. The EIS should evaluate the status of each of these lagoons and examine their potential environmental impacts.
Additionally, the EIS should examine potential impacts of flooding, both to the lagoons and the rest of the facility. Flooding risks should also be analyzed under various climate change scenarios.
The EIS should include a robust examination of cumulative impacts.
The EIS should examine the environmental impacts for alternatives that include not renewing the license, as well as various alternative license lengths (i.e. 10 years, 15 years, 20 years, etc).
It has been previously stated that Westinghouse will not undertake significant efforts to remediate existing contamination until the facility is decommissioned at the end of the license period. 4 The EIS should examine the potential impacts on the extent and movement of contamination, and the cost of remediation of waiting to address legacy contamination.
The EIS should examine the potential for current or future groundwater or surface water contamination from this facility to impact residential wells in the area.
The EIS should also examine any impacts from the continued operation of this facility to impacts resources at Congaree National Park, approximately 5 miles away.
2 https://www.dnr.sc.gov/swap/index.html 3
Little is still know about this 1971 lagoon spill, and the EIS should also examine the impacts of that event.
4 https://apnews.com/2ad315feb6e645449953edc0feaa6d93/No-clean-up-of-nuclear-leak-in-South-Carolina-for-years Post Office Box 5294
- Columbia, South Carolina 29250 2 (803) 760-3357
- www.congareeriverkeeper.org
We appreciate the opportunity to provide these comments and will continue to engage on this important decision.
Sincerely, Bill Stangler Congaree Riverkeeper Post Office Box 5294
- Columbia, South Carolina 29250 3 (803) 760-3357
- www.congareeriverkeeper.org