ML20302A441

Comment (11) of Deborah Matherly on Scoping Related to Preparation of an Environmental Lmpact Statement on the Westinghouse Fuel Plant in Richland County, South Carolina

ML20302A441
Person / Time
Site:	Westinghouse
Issue date:	08/30/2020
From:	Matherly D - No Known Affiliation
To:	Office of Administration
References
85FR46193 00011, NRC-2015- 0039
Download: ML20302A441 (2)

Text

August 30,2O2O To: Office of Administration SUNI Review Complete MailStop: TWFN-7-A60M Template=ADM-013 U.S. Nuclear Regulatory Commission E-RIDS=ADM-03 ADD: Jessie Quintero, Sarah Achten, Diana Toro Washington, DC 20555-0001 Diaz, Mary Neely WEC_CFFF_E 15. resou rce@ nrc.gov Comment (11)

Publication Date: 7/31/2020 From: Deborah Matherly CITATION 85 FR 46193 105 Serendipity Way, Unit 398 Lexington, SC29072 Comments on the U.S. Nuclear Regulatory Commission's Scoping Related to Preparation of an Environmental lmpact Statement on the Westinghouse Fuel Plant in Richland County, South Carolina - Docket Docket lD NRC-2015- 0039 I

Dear NRC,

Sirs and Madams:

Please include this entire letter in the official record of the draft Environmental lmpact Statement, ElS.

I have read the Savannah River Site Watch (SRS Watch) comments that were submitted to your office on August 20,2020.1 am concerned about many aspects of the concerns and findings documented in those comments, based on official reports to and by the Nuclear Regulatory Commission and other sources. I look forward to the NRC addressing those comments fully in the scoping for the El$ including but not limited to the following key points:

1. ln fairness, please extend the official scoping cornment period by 90 days, as requested by the Sierra Club and SRS Watch on August 10,2O2O' Westinghouse Fuel Fabrication Facility (WEC) has too many serious and complex problems to not allow the public enough time to respond.

2. The current operating license is effective through 2O27.This EIS does not need to be rushed- it should be complete and comprehensive, especially in light of serious issues that are still in the process of discovery. For example, the WEC is in the process of addressing and responding to a Consent Agreement with the South Carolina Department of Health and Environmental Control (DHEC) "to assess and address releases of pollutants into the environment at the Site." (As noted in items 2, 3 and 4 of the SRS Watch letter, the reports behind the Consent Agreement identify very serious discharges into the air, ground, and water that must be addressed.)There are ongoing findings of rnuch higher than average worker exposure to radiation, compared to other nuclear plants. The Nuclear Regulatory Commission is the midst of a Safety Evaluation Report related to serious findings of radioactive materials at higher than allowable levels being found in air scrubbers on multiple occasions. Finally, Westinghouse is in bankruptcy and the plant is now under new ownership.

ln light of this history of problems and current uncertainty as to the priorities and expectations of the new owners, I request the following four actions:

1)The scoping deadline should extended by 90 days.

2) The proposed schedule for the EIS should be explicitly extended to allow for the inclusion of studies that are now underway or that will be required due to current actions and agreements. These studies include a) the NRC Safety Evaluation Report which should be in the public record - preferably prior to issuing the ElS, but definitely within six months of completion of the EIS-, and b) the substantial fulfillment of the South Carolina DHEC Consent Agreement, including legally binding commitments to meaningful public engagement in the lower Richland community; greatly improved worker safety and monitoring; and air, land and water remediation and mitigation.

3) The EIS itself should include the reports and requirements identified in the 14 items in the SRS Watch comments, including accommodation for climate change.

4l The Proposed Action of renewing the license for WEC should be reduced from 40 years to a maximum of a twenty year operating period, with public review required at ten years. Forty years without opportunity for public review and oversight is clearly unwarranted for a plant that has displayed long-term patterns of violations of requirements.

Thank you for accepting all my comments and for placing this letter in its entirety into the official record.

105 Serendipity Way, Unit 398 Lexington, SC 29072