ML21327A152

Comment (4) of L. Riggin on Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility

ML21327A152
Person / Time
Site:	Westinghouse
Issue date:	11/19/2021
From:	Riggin L State of SC, Dept of Natural Resources
To:	Office of Administration
References
86FR53694 00004, NRC-2015-0039
Download: ML21327A152 (9)

Text

11/23/21, 10:37 AM blob:https://www.fdms.gov/5f30c426-ef5d-4632-a66e-86804db61576 SUNI Review Complete As of: 11/23/21 10:37 AM Template=ADM-013 Received: November 19, 2021 PUBLIC SUBMISSION E-RIDS=ADM-03 Status: Pending_Post ADD: Jean Trefethen, Tracking No. kw6-q274-w1tk Antoinette Walker-Smith, Mary Neely Comments Due: November 19, 2021 Comment (4) Submission Type: Web Publication Date:

9/28/2021 Citation: 86 FR 53694 Docket: NRC-2015-0039 Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility Comment On: NRC-2015-0039-0088 Westinghouse Electric Company, LLC, Columbia Fuel Fabrication Facility Document: NRC-2015-0039-DRAFT-0090 Comment on FR Doc # 2021-21053 Submitter Information Email: RigginL@dnr.sc.gov Government Agency Type: State Government Agency: South Carolina Department of Natural Resources General Comment South Carolina Department of Natural Resources Comments Attachments 2021113 NRC License Westinghouse Electric Company DEIS_SCDNR Comments blob:https://www.fdms.gov/5f30c426-ef5d-4632-a66e-86804db61576 1/1

South Carolina Department of Natural Resources 1000 Assembly Street Suite 336 Robert H. Boyles PO Box 167 Columbia, SC 29202 Director Lorianne Riggin November 13, 2021 Director, Office of Environmental Programs Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 electronic submission RE: Westinghouse Electric Company, LLC Draft Environmental Impact Statement; Columbia Fuel Fabrication Facility; Nuclear Regulatory Commission; Docket ID: NRC-2015-0039 To Whom It May Concern, The South Carolina Department of Natural Resources (SCDNR) is the state agency charged by state law with the management, protection, and enhancement of wildlife, fisheries, and marine resources in South Carolina. SCDNR is responsible for formulating comprehensive policies for water resources through a State Water Plan to address issues affecting water supply, water quality, navigation, hydroelectric power, outdoor recreation, fish and wildlife needs, and other water resource interests. SCDNR is also charged with the statewide responsibilities for regulating watercraft operation and associated recreation on state waters, conducting geological surveys and mapping, promoting soil and water conservation, management of invasive aquatic plants, flood mitigation, drought response planning and coordination, and the state scenic rivers program. SCDNRs mission is to serve as the principal advocate for and steward of South Carolinas natural resources. (SCDNR authorities and responsibilities are described in Titles 48, 49 and 50, South Carolina Code of Laws (1976), as amended).

Due to the SCDNRs responsibilities as a steward for the states natural resources, we have enclosed comments for the purpose to aid the development of the Final Environmental Impact Statement to assess the relicensing of this facility.

Thank you for the opportunity to participate in the review of this project and provide comments.

Sincerely, Office of Environmental Programs Director South Carolina Department of Natural Resources cc: DHEC

Page 2 SCDNR Comments NRC-2015-0039 Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility Draft Environmental Impact Statement Nuclear Regulatory Commission NRC-2015-0039 Project Summary Westinghouse Electric Company, LLC (WEC) requested a license renewal for its Columbia Fuel Fabrication Facility (CFFF) in December 2014 for a period of 40-years to continue fabricating low-enriched uranium fuel assemblies for commercial nuclear power reactors from the U.S. Nuclear Regulatory Commission (NRC). In June 2018, the NRC published a finding of no significant impact (FONSI) concerning the license. However, in July 2018, a leak at the CFFF facility caused uranium to enter the subsurface beneath the building. Additionally, another leak of uranium into the subsurface of the main building occurred in 2011 resulting from a buried pipe. Due to these incidents, the NRC decided to re-open its environmental review, withdrawing the previously published FONSI and reinitiating the National Environmental Policy Act review process. As such, the SCDNR provides the following information to assist in the development of the Final Environmental Impact Statement.

SCDNR Comments The following comments are in reference to the Draft Environmental Impact Statement (DEIS)

(ML21209A213) published originally on August 6, 2021 and reopened for comment again on September 28, 2021.

2.2.2.1.2 Environmental Monitoring Program

• SCDNR finds the sample size of one fish per year to be a poor indicator of uranium and Tc-99 levels. Appropriate sample sizes should include at least 3-5 individuals and samples should be collected at multiple locations to allow for statistical comparison. Suggested locations for additional fish sampling would include a site on Mill Creek above possible contamination and other sites within Sunset Lake and Gator Pond.

3.1.1 Site Vicinity

• Please note that the Mill Creek Mitigation Bank (SAC-2014-00222), an approved stream and wetland mitigation bank under the Compensatory Mitigation Framework authorized by the U.S.

Army Corps of Engineers, is within 5 miles of the project area located on a 1,769-acre parcel at Latitude 33.823886°N and Longitude -80 .884224°W. Please include this property when describing the site vicinity.

3.3 Surface Water Resources The SCDNR recommends that further consideration be given to what impacts may exist to the facility and associated resources if a drought occurs. How would operations affect water quality if minimum flows continued to an extended drought? Could a drought result in a higher concentration of contaminants in the Congaree River?

Additionally, does the facility follow the City of Columbias Drought Management Plan and Drought Ordinance? If so, include this information in the Final EIS and how that would affect their water use and Columbias overall water supply.

3.5 Ecological Resource Sections 3.5.1 and 3.5.2 overlook analysis for the potential impacts to herpetofauna that may inhabit wetlands within the floodplain associated with Sunset Lake, Gator Pond, Mill Creek or the Congaree River. Additionally, while contamination levels in surface waters are within health standards for maximum contaminant levels, the standard and threshold for tolerance to contamination for other organisms, especially those species, such as frogs that exhibit cutaneous respiration, cannot be assumed to 2

Page 3 SCDNR Comments NRC-2015-0039 be the same. The impacts of organisms that depend on those isolated wetlands and the impacts to those species should also be considered in development of a Final EIS. Also, because the emphasis for impacts to aquatic resources has been evaluated solely based on the direct discharges to the Congaree River or surface overland flow and the distance before any contaminants would reach the Congaree River, the SCDNR requests more consideration be given in a Final EIS for mitigating measures to prevent impacts to herpetofauna, such as mechanisms in place to deter entry into the projects lagoons with the use of sediment fencing and a mortality monitoring protocol. Additionally, open surface water lagoons within the project footprint should also be covered to prevent use by a variety of water bird species. Similarly, since the drainage ditch between the main facility building and Sunset Lake had high levels of TCE, the SCDNR recommends a prevention plan for entry by herpetofauna.

Also, please note that according to the SCDNR Heritage Trust Database, a repository for all rare and both federally and state threatened species data, there are several species that could potentially inhabit the site.

Please see the attached table (Attachment A) of known occurrences of species within five miles of the site and a known element of occurrence from the SCDNR Heritage Trust Database of white catfish on the property and Mill Creek is likely to contain Flat Bullhead, Banded Killifish and Cedar Creek Crayfish.

All these species are of moderate conservation priority under the South Carolina State Wildlife Action Plan 1.

For regulated species the following were missing from the appropriate tables.

• Table 3-3 should include the following state listed species: Spotted Turtle (threatened), Carolina Gopher Frog (endangered), Carolina Pygmy Sunfish (threatened), Southern Hognose Snake (threatened), and Wood Stork.

• Table 3-4 is missing the federally protected species Canbys Cowbane Tiedemannia canbyi.

• Table 3-5 is missing the following migratory bird species that could be within or in the vicinity of the project footprint: Anhinga, Great Egret, Great Blue Heron, Red-shouldered Hawk, Yellow-billed Cuckoo, Pileated Woodpecker, Snowy Egret, Acadian Flycatcher, Yellow-breasted Chat, Baltimore Oriole, Black-and-white Warbler, Blue Grosbeak, Scarlet Tanager, Summer Tanager, Carolina Chickadee, Black-throated Blue Warbler, Prairie Warbler, Yellow-throated Warbler, Chestnut-sided Warbler, Pine Warbler, Carolina Wren, Brown Thrasher, Barn Owl, Blue-winged Warbler, Yellow-throated Vireo and White-eyed Vireo.

Additional information regarding these species that are protected under federal or state statutes can be found at: https://www.dnr.sc.gov/species/index.html and https://www.fws.gov/southeast/pdf/fact-sheet/south-carolina-species-list-by-county.pdf.

Regarding the ecological resources, the SCDNR finds that impacts to these resources needs to be assessed with additional information, such as monitoring the use of the project site by wildlife and how they are affected, to determine if the impacts are indeed small.

3.7 Climatology, Meteorology, and Air Quality In accordance with the South Carolina State Climatology Office, the following clarifications are needed for the Final EIS.

• In Section 3.7.1.3 Winds, page 3-64 line 4 and 5 should be corrected to state and higher average winds occur from November to April.

• In Section 3.7.1.4 Severe Weather, page 3-64 line 17-19 should have an additional sentence to state These events were likely all that were in the database, but lightning and lightning damage are far more common than what is reported.

1 SCDNR State Wildlife Action Plan www.dnr.sc.gov/swap 3

Page 4 SCDNR Comments NRC-2015-0039

• In Section 3.7.1.4 Severe Weather, page 3-65 line 22-25 mentions Hurricane Floyd and SCDNR Climatologist find that this is not applicable to the project site as there was no significant effect on Richland County from that storm. However, more data regarding Hurricane Hugo should be included as this storm moved inland and had a recorded 8-hour period of winds gusting past 40 mph and a peak gust of 64 mph at the Columbia Metropolitan Airport. Additionally, further down in line 25-27, Richland County has been impacted by more than three tropical systems and two hurricanes since 1930. More data regarding hurricanes and tropical storms that have impacted the state can be found here: https://www.dnr.sc.gov/climate/sco/hurricanes/.

• Please note the discussion regarding sea level rise in Section 3.7.1.6 is not relevant to the project location. However, there are other components of the 2018 Fourth National Climate Assessment that could be included specifically impacts of temperature changes within the Southeast Chapter of the Assessment: https://nca2018.globalchange.gov/chapter/19/.

4

Attachment A: SCDNR Heritage Trust Database Element of Occurrence Data within 5 miles of the project site.

Federal Protection State Protection State Wildlife Last Observation Species Full Name G Rank S Rank Status Status Action Plan Priority Date PLANTS Bog St. John's-wort, Creeping St. John's-G3 S2 Not Applicable Not Applicable High 6/1/1974 wort - Hypericum adpressum Carolina Birds-in-a-nest, Carolina ARS: At-Risk Macbridea G2G3 S3 Not Applicable High 8/8/1967 Species

- Macbridea caroliniana Green Fringed Orchid, Ragged Fringed Orchid, G5 S2 Not Applicable Not Applicable Not Applicable 6/5/2006 Ragged Orchid

- Platanthera lacera Winter Grapefern

- Botrychium G4? S1 Not Applicable Not Applicable Moderate 11/28/1997 lunarioides FISHES Banded Killifish G5 S1 Not Applicable Not Applicable Moderate 7/13/1949

- Fundulus diaphanus Banded Sunfish

- Enneacanthus G5 S3S4 Not Applicable Not Applicable Moderate 10/20/2000 obesus Blackbanded Sunfish

- Enneacanthus G3G4 S2S3 Not Applicable Not Applicable High No Data chaetodon Carolina Lance G4 S3 Not Applicable Not Applicable Moderate 8/14/2002

- Elliptio angustata Carolina Pygmy ST: State Sunfish - Elassoma G2 S1 Not Applicable Highest 2/1/2013 Threatened boehlkei

Page 6 SCDNR Comments NRC-2015-0039 Federal Protection State Protection State Wildlife Last Observation Species Full Name G Rank S Rank Status Status Action Plan Priority Date Cedar Creek Crayfish

- Procambarus G4 S4 Not Applicable Not Applicable Moderate No Data chacei Cedar Creek Crayfish

- Procambarus G4 S4 Not Applicable Not Applicable Moderate 4/18/1955 chacei Cedar Creek Crayfish

- Procambarus G4 S4 Not Applicable Not Applicable Moderate 10/25/2007 chacei Coastal Plain Crayfish G4G5 S4S5 Not Applicable Not Applicable Moderate No Data

- Procambarus ancylus Eastern Pondhorn

- Uniomerus G4 S3 Not Applicable Not Applicable Not Applicable 5/16/2006 carolinianus Eastern Pondhorn

- Uniomerus G4 S3 Not Applicable Not Applicable Not Applicable 9/13/1995 carolinianus Eastern Pondhorn

- Uniomerus G4 S3 Not Applicable Not Applicable Not Applicable 5/19/1998 carolinianus Eastern Pondhorn

- Uniomerus G4 S3 Not Applicable Not Applicable Not Applicable 10/8/2002 carolinianus Flat Bullhead

- Ameiurus G4 S4 Not Applicable Not Applicable Moderate 5/26/2009 platycephalus Northern Lance G4 SNR Not Applicable Not Applicable Not Applicable 6/20/2006

- Elliptio fisheriana Northern Lance G4 SNR Not Applicable Not Applicable Not Applicable 7/24/1996

- Elliptio fisheriana Northern Lance G4 SNR Not Applicable Not Applicable Not Applicable 9/13/1995

- Elliptio fisheriana 6

Page 7 SCDNR Comments NRC-2015-0039 Federal Protection State Protection State Wildlife Last Observation Species Full Name G Rank S Rank Status Status Action Plan Priority Date Northern Lance G4 SNR Not Applicable Not Applicable Not Applicable 5/19/1998

- Elliptio fisheriana Roanoke Slabshell G3 S2 Not Applicable Not Applicable High 8/14/2002

- Elliptio roanokensis Santee Crayfish

- Procambarus G4 S4 Not Applicable Not Applicable Moderate No Data blandingii Sawcheek Darter G5 S4 Not Applicable Not Applicable Moderate No Data

- Etheostoma serrifer Sawcheek Darter G5 S4 Not Applicable Not Applicable Moderate 8/3/2010

- Etheostoma serrifer Shortnose Sturgeon LE: Federally SE: State

- Acipenser G3 S3 Highest 1/1/2019 Endangered Endangered brevirostrum Snail Bullhead G4 S3S4 Not Applicable Not Applicable Moderate No Data

- Ameiurus brunneus White Catfish G5 SU Not Applicable Not Applicable Moderate No Data

- Ameiurus catus White Catfish G5 SU Not Applicable Not Applicable Moderate 7/15/1977

- Ameiurus catus BIRDS Barn Owl - Tyto alba G5 S4 Not Applicable Not Applicable Moderate 1985 Great Blue Heron G5 S5 Not Applicable Not Applicable Moderate 2014

- Ardea herodias MAMMALS Eastern Fox Squirrel G5 S3S4 Not Applicable Not Applicable Moderate 5/1/1980

- Sciurus niger Rafinesque's Big-eared Bat SE: State G3G4 S2 Not Applicable Highest 7/25/2002

- Corynorhinus Endangered rafinesquii 7

Page 8 SCDNR Comments NRC-2015-0039 Federal Protection State Protection State Wildlife Last Observation Species Full Name G Rank S Rank Status Status Action Plan Priority Date Swamp Rabbit

- Sylvilagus G5 S2? Not Applicable Not Applicable High 1989-01 aquaticus 8