ML21288A279

Comment (15) E-mail Regarding WEC Cfff Draft EIS

ML21288A279
Person / Time
Site:	Westinghouse
Issue date:	09/20/2021
From:	Stangler B Congaree Riverkeeper
To:	Office of Nuclear Material Safety and Safeguards
References
86FR43277, NRC-2015-0039
Download: ML21288A279 (3)

Text

WEC_CFFF_EIS Resource From: Congaree Riverkeeper <CRK@congareeriverkeeper.org>

Sent: Monday, September 20, 2021 4:29 PM To: WEC_CFFF_EIS Resource

Subject:

[External_Sender] CRK Westinghouse Draft EIS Comments (NUREG-2248)

Attachments: CRK Westinghouse Draft EIS Comments.pdf Follow Up Flag: Follow up Flag Status: Completed Please find attached Congaree Riverkeeper's comments on the Westinghouse draft EIS (docket id NRC20150039, NUREG2248).

Thank you.

Bill Stangler Congaree Riverkeeper 803-760-3357 1

September 20, 2021 U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: Comments on Westinghouse Draft EIS (Docket ID NRC-2015- 0039, NUREG-2248)

To Whom It May Concern:

I am writing on behalf of Congaree Riverkeeper, a grassroots non-profit organization that works to protect the Broad, Lower Saluda and Congaree Rivers, to submit the following comments on the draft 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.

First and foremost, after reviewing the draft EIS and the NRCs public presentations, we contend that the NRC staffs preliminary recommendation to renew the facilitys operating license for an additional 40 years is a significant error, is not supported by the findings of the EIS, and is widely opposed by the community.

The EIS evaluated the proposed 40-year license renewal, as well as two alternatives: no action, and a 20-year license renewal. While the EIS states that the impacts from the proposed action (the 40-year license) and the alternative 20-year license are similar, the actual discussion suggests otherwise.

The following are excerpts from the draft EIS (emphasis added):

The nature/type of potential environmental impacts from continued licensed operations for an additional 20 years would be similar to those from the proposed action (i.e., proposed 40 years of continued operation). However, the extent of the impacts would differ in light of the amount of time the CFFF would operate and uncertainties associated with the outcome of the ongoing remedial investigations per the CA process. (Page 2-26)

With consideration of the history of the site, remaining uncertainties about past leaks, and the potential for the risk of leaks to increase with the age of plant components, the NRC staff concludes that future inadvertent releases of contaminants to the subsurface are reasonably foreseeable. (Page 3-43)

Post Office Box 5294

• Columbia, South Carolina 29250 1 (803) 760-3357

• www.congareeriverkeeper.org

These statements indicate that a shorter license term would in fact reduce the potential for the inadvertent release of contaminants, and reduce the potential environmental impacts associated with continued operations. As such, the 20-year license alternative should be seen as having less potential environmental impact than the proposed 40-year license.

The EIS also discusses the costs and benefits of the proposed action and alternatives and concludes that the 20-year alternative also would result in a positive economic benefit-cost ratio similar to the proposed action, suggesting that, based on the public health and safety factors that should guide the NRCs final decision, the shorter license term should be the preferred option.

Additionally, numerous elected officials, citizens, and organizations have expressed concerns about the proposed 40-year license, and have advocated for a shorter license term. We urge the NRC to listen to this feedback from the community.

We recommend that the NRC renew the operating license for a period of 20 years. This will allow the NRC and others to learn more from the ongoing remedial investigations being conducted and evaluate the effectiveness of the actions that are being, and will be taken as part of the DHEC consent agreement. This would also be consistent with the previous license renewal for this facility, which was renewed in 2007 for a 20-year term.

We appreciate the opportunity to provide these comments.

Sincerely, Bill Stangler Congaree Riverkeeper Post Office Box 5294

• Columbia, South Carolina 29250 2 (803) 760-3357

• www.congareeriverkeeper.org