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Category:Response to Request for Additional Information (RAI)
MONTHYEARML22080A2822022-03-21021 March 2022 Westinghouse, Response to NRC Request for Additional Information Associated with the SNM-1107 License Renewal Environmental Impact Statement ML22052A0122022-02-21021 February 2022 Response to NRC Request for Additional Information Associated with the SNM-1107 License Renewal Environmental Impact Statement ML21102A0692021-04-0606 April 2021 Westinghouse Columbia Fuel Fabrication Facility License Renewal Environmental Commitments ML21141A1522021-03-24024 March 2021 RAI-31 - Actual CO2e Emissions Calculations ML21141A1512021-03-24024 March 2021 Clarification Needs-Westinghouse Lr EIS-WEC Response ML20353A2912020-12-18018 December 2020 Enclosure 14 - Response to Request for Additional Information - Monthly Discharge Monitoring Reports ML20353A3342020-12-18018 December 2020 Enclosure 27 - Response to Request for Additional Information, Westinghouse Nuclear Fuel Columbia Site Evaluation Report, March 1975 Section 2 ML20353A3282020-12-18018 December 2020 Enclosure 25 - Response to Request for Additional Information, Boring Logs ML20353A3272020-12-18018 December 2020 Enclosure 24 - Site CSM Cross Sections, 2.5X Vertical Exaggeration and 15X Vertical Exaggeration, Conceptual Site Model Rev. 1a ML20353A3242020-12-18018 December 2020 Enclosure 21 - Response to Request for Additional Information, Westinghouse Nuclear Fuel Columbia Site Evaluation Report, March 1975 Appendix 2.E ML20353A2972020-12-18018 December 2020 Enclosre 20 - Response to Request for Additional Information - May 2019 Air Permit Renewal Application Table 4 - Emission Calculations for Scrubber ML20353A2932020-12-18018 December 2020 Enclosure 16 - Response to Request for Additional Information - Soil & Materials Engineers, Inc., 1982, Ground-Water Hydrology of the Westinghouse Electric Corporation Plant, Richland County, South Carolina: Report No. H-8119, March 1, 1982 ML20353A2922020-12-18018 December 2020 Enclosure 15 - Response to Request for Additional Information LTR-RAC-18-81 Hf Spiking Station 2 Summary Westinghouse Nuclear Fuel Facility Hopkins, Sc ML20353A2842020-12-18018 December 2020 Enclosure 8 - Response to Request for Additional Information - Table 2 - Emission Calculations for Industrial Incinerator ML20353A2902020-12-18018 December 2020 Enclosure 13 - Response to Request for Additional Information - LTR-RAC-19-64, Manifests for Hfss 2 Soil Remediation ML20353A2892020-12-18018 December 2020 Enclosure 12 - Response to Request for Additional Information - DHEC Response to Hf Spiking Station 2 Assessment Report ML20353A2872020-12-18018 December 2020 Enclosure 10 - Response to Request for Additional Information - Sum of Fractions of Isotopic Uranium in Soil Beneath Sea-Land Containers Figures ML20353A2862020-12-18018 December 2020 Enclosure 9 - Response to Request for Additional Information - Table 6 - Industrial Incinerator; Emission Calculations for Metals, Acid Gases, and Dioxin/Furans ML20353A3352020-12-18018 December 2020 Enclosure 28 - Response to Request for Additional Information, Westinghouse Nuclear Fuel Columbia Site Evaluation Report, March 1975 Section 6 ML20353A2802020-12-18018 December 2020 Enclosure 4 - Response to Request for Additional Information - Phase II Remedial Investigation Work Plan ML20353A2962020-12-18018 December 2020 Enclosure 19 - Response to Request for Additional Information - Preliminary Human Health Risk Assessment Westinghouse Columbia Fuel Fabrication Facility 5801 Bluff Road Hopkins South Carolina ML20353A2792020-12-18018 December 2020 Enclosure 3 - Response to Request for Additional Information - Cww Well Permit and Approval ML20353A2782020-12-18018 December 2020 Enclosure 2 - Response to Request for Additional Information - March 2019 Environmental Report Updates ML20353A2772020-12-18018 December 2020 Enclosure 1 - Response to Request for Additional Information Re Environmental Review for the Proposed Renewal of the Westinghouse Columbia Fuel Fabrication Facility License ML20353A2942020-12-18018 December 2020 Enclosure 17 - Response to Request for Additional Information - 2018/2019 Annual Groundwater Report ML20353A2832020-12-18018 December 2020 Enclosure 7 - Response to Request for Additional Information - Facility Wide Criteria and Tap Model ML20353A2882020-12-18018 December 2020 Enclosure 11 - Response to Request for Additional Information - RA-433, Environmental Remediation ML20353A2812020-12-18018 December 2020 Enclosure 5 - Response to Request for Additional Information - RAF-104-5, Environmental Protection Guidelines and Checklist ML20353A2822020-12-18018 December 2020 Enclosure 6 - Response to Request for Additional Information - TAF-500-11, 10 CFR 70.72 Engineering Pre-screening Checklist ML20353A3292020-12-18018 December 2020 Enclosure 26 - Response to Request for Additional Information, Westinghouse Nuclear Fuel Columbia Site Evaluation Report, March 1975 Section 5 ML20317A1912020-11-12012 November 2020 Westinghouse Response to Request for Additional Information Schedule- Environmental Review for the Proposed Renewal of the Westinghouse Columbia Fuel Fabrication Facility License (Enterprise Project Identifier L-201-RNW-0016) ML20287A5462020-10-12012 October 2020 Westinghouse - Response to Request for Additional Information Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Facility Waste ML20266G5522020-09-22022 September 2020 Attachment 1 - Response to Request for Additional Information Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Facility Waste ML20266G5512020-09-22022 September 2020 Westinghouse Electric Company, LLC - Response to Request for Additional Information - Alternate Disposal Approval and Exemptions for Specific Columbia Fuel Fabrication Facility Waste ML20063P3272020-02-29029 February 2020 Interim Remedial Investigation Data Summary Report Westinghouse Columbia Fuel Fabrication Facility ML18257A0622018-09-13013 September 2018 Response to Request for Additional Information Westinghouse Electric Company WCAP-16260-P/WCAP-16260-NP, Revision 2, the Spatially Corrected Inverse Count Rate (Scicr) Method for Subcritical Reactivity Measurement. ML18144A9942018-05-24024 May 2018 Westinghouse Electric Company, LLC - Response to Request for Additional Information Regarding Application for NRC Consent to License Transfer (EPID L-2018-LLM-0001) ML18005A5362018-01-0505 January 2018 Westinghouse - Response to Request for Additional Information (TAC # L33317)re License Renewal Application for Columbia Fuel Fabrication Facility 2022-03-21
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WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 Enclosure 1 Response to Request for Additional Information Request for Alternate Disposal Approval and Exemption for Specific Columbia Fuel Fabrication Facility Waste 1 of 3
WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 On May 8, 2020, Westinghouse submitted a request for alternate disposal approval and exemption for specific Columbia Fuel Fabrication waste containing byproduct and special nuclear material. Specifically, the request was for an exemption to the requirements in 10 CFR 70.3 License Requirements to allow Westinghouse to transfer the specific waste for disposal at the US Ecology Idaho, INC disposal facility.
The staff needs additional information in order to potentially grant an exemption to 10 CFR 70.3 as per the regulatory requirement in 10 CFR 70.17(a). Westinghouse should provide information that justifies:
- a. The exemption is authorized by law
- b. The exemption will not endanger life or property or the common defense and security
- c. The exemption is otherwise in the public interest.
WESTINGHOUSE RESPONSE The NRC issued license SNM-1107 to Westinghouse Columbia Fuel Fabrication Facility (CFFF) and CFFF is required to comply with the regulations as provided in 10 CFR 70, Domestic Licensing of Special Nuclear Material. Specific exemptions to 10 CFR 70 may be granted under 10 CFR 70.17 if the applicant can demonstrate that the exemption is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.
By Westinghouse letter (A. Spalding) to the NRC Document Control Desk, Request for Alternate Disposal Approval and Exemptions for Specific Columbia Fuel Fabrication Facility Waste, LTR-RAC-20-45 (ML20129J935), Westinghouse submitted a request for an exemption for the specific material provide therein and provided information to support the NRC Staff review. Below is a summary of how the proposed exemption request meets the requirements of 10 CFR 70.17(a).
Authorized by Law In LTR-RAC-20-45, Enclosure 1, Columbia Fuel Fabrication Facility Evaluation in Support of 10 CFR 20.2002 Request for Alternate Waste Disposal, the removal of the East Lagoon will be completed in accordance with NPDES permit #SC0001848 issued by South Carolina Department of Health and Environmental Control as well as Richland County requirements. In addition, the material will be transported in compliance with US Department of Transportation (DOT) regulations to US Ecology Idaho, Inc. (USEI). USEI is a Subtitle C Resource Conservation and Recovery Act (RCRA) hazardous waste disposal facility permitted by the State of Idaho to receive radioactive waste that is not licensed or exempted from licensing by the NRC. As such, the material will be removed per state and local regulations, will be shipped per existing federal regulations to a location approved by the state of Idaho to receive the material. The proposed exemption is not otherwise inconsistent with NRC regulations or other applicable laws.
Therefore, the request is authorized by law pending NRC approval of the exemption.
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WESTINGHOUSE NON-PROPRIETARY CLASS 3 to LTR-RAC-20-80 Date: October 12, 2020 Not endanger Life, Property, or the Common Defense and Security In LTR-RAC-20-45, Enclosure 1, Section 5.0, Radiological Assessment, describes exposure scenarios for the Maximally Exposed Individual, describes how the material will meet DOT regulations for transport and confirms that a persons annual dose will not exceed 15 mrem for 1,000 years after closure of the USEI facility.
In LTR-RAC-20-45, Enclosure 1, Section 6.0, Criticality Safety, identifies that the USEI Waste Acceptance Criteria would not be exceeded before the safety limit of 0.1 gram of U-235 per liter of media would be reached.
Finally, CFFF maintains an NRC approved Physical Security Plan (ML19295F234). As such, shipments of the waste material for disposal at USEI will be conducted in accordance with applicable regulations that provide reasonable assurance the requested exemption will not endanger life, property or the common defense and security.
In the Public Interest This exemption request supports the Westinghouse capital improvement project to close the East Lagoon in 2021. This project is part of CFFFs ongoing efforts to remediate legacy environmental concerns at the site. Closing a lagoon with an aging liner, as described in LTR-RAC-20-45, Enclosure 1, Section 3.1, East Lagoon, is protective of the environment and in the interest of public health and safety.
Summary Westinghouse has provided the aforementioned information to support, in accordance with 10 CFR 70.17(a), an NRC determination that the request for disposal of specific materials from the CFFF site at the USEI site is in accordance with applicable laws and regulations, will not endanger life or property or the common defense and security, and is in the interest of the public.
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