ML21327A156
| ML21327A156 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/19/2021 |
| From: | Malek E Westinghouse |
| To: | Office of Administration |
| References | |
| 86FR53694 00005, NRC-2015-0039 | |
| Download: ML21327A156 (62) | |
Text
11/23/21, 10:42 AM blob:https://www.fdms.gov/5cbf8464-cf59-4025-bcfb-560a89b7fde5
SUNI Review Complete As of: 11/23/21 10:42 AM Template=ADM-013Received: November 19, 2021 E-RIDS=ADM-03 Status: Pending_Post PUBLIC SUBMISSION ADD: Jean Trefethen, Tracking No. kw6-w7hp-dyks Antoinette Walker-Comments Due: November 19, 2021 Smith, Mary Neely Comment (5) Submission Type: Web Publication Date:
9/28/2021 Docket: NRC-2015-0039 Citation: 86 FR 53694 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-0091 Comment on FR Doc # 2021-21053
Submitter Information
Email: malekem@westinghouse.com Organization: Westinghouse Electric Company LLC
General Comment
See attached file
Attachments
LTR RAC 21 77
blob:https://www.fdms.gov/5cbf8464-cf59-4025-bcfb-560a89b7fde5 1/1 WESTINGHOUSE NON-PROPRIETARY CLASS 3
Westinghouse Electric Company LLC Columbia Fuel Site 5801 Bluff Road Hopkins, South Carolina 29061-9121 USA
Office of Administration Direct tel: 803-647-2046 Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission, e-mail: malekem@westinghouse.com Washington, DC 20555-0001, ATTN: Program Management, Announcements Your ref:
and Editing Staff Our ref: LTR-RAC-21-77
November 19, 2021
SUBJECT:
Transmittal of Westinghouse Electric Company Comment on the Environmental Impact Statement for the License Renewal of Columbia Fuel Fabrication Facility Draft Report for Comment [Docket ID NRC-2015-0039]
REFERENCE:
(1) NUREG-2248, Environmental Impact Statement for the License Renewal of the Columbia Fuel Fabrication Facility in Rich land County, South Carolina, Draft Report for Comment (July 2021) (ML21209A213)
(2) LTR-RAC-21-57, Westinghouse Revised SNM-1107 License Renewal Application, (September 2021) (ML21263A217)
Westinghouse Electric Company LLC (Westinghouse) appreciates the opportunity to comment on Reference (1), the Nuclear Regulatory Commissions (NRC) draft Environmental Impact Statement (EIS) for the License Renewal of the Columbia Fuel Fabrication Facility (CFFF) in Richland County, South Carolina. Westinghouse supports the preliminary r ecommendation that the CFFF license be renewed for an additional 40 years. The enclosures provide co mments on the draft EIS for your consideration.
In addition to the detailed comments in Enclosure 1 through 4, Westinghouse has installed programmatic controls at the site to further assure that future operations are safe and protective of employees, the public and the environment. These include an extensive envi ronmental monitoring network with established action levels well below regulatory limits, a Conceptual Site Model that is kept current, and implementation of a risk-based remediation procedure that assures a pr edictable response to any issues in the future.
Westinghouse has previously submitted a proposed licen se renewal commitment to complete the Consent Agreement (CA) with South Carolina Department of Health and Environmental Control (DHEC) and has proposed two additional license renewal commitments to the NRC as part of the license renewal application.
The two new license renewal commitments would address the potential need for adjustments to Westinghouses extensive environmental monitoring program over the renewed license term. Westinghouse has proposed to (1) submit its environmental monitori ng program to the NRC for review and approval upon DHEC approval of the Remediation Investigation (RI) re port or within five years of the license renewal, whichever comes first; and (2) submit its environmental monitoring program to the NRC for review and approval when Westinghouse submits the final CA re port to DHEC. These proposed commitments provide NRC with two additional opportunities to require adju stments to the environmental monitoring program based on the data acquired during execution of the CA. Thus, under Westinghouses proposed
© 2021 Westinghouse Electric Company LLC All Rights Reserved WESTINGHOUSE NON-PROPRIETARY CLASS 3
Page 2 of 61 Our ref: LTR-RAC-21-77 November 19, 2021
commitments, the license renewal would represent an approval of the environmental monitoring program for an initial period of five years or less.
In addition to the many new environm ental media sampling requirements in the license renewal application, Westinghouse is required to submit copies of groundwa ter reports to both DHEC and NRC and notify NRC of any National Pollutant Discharge Elimina tion System (NPDES) Notice of Violations.
Westinghouse has completed the remedial investigation fieldwork to fully characterize the site. This has significantly reduced uncertainties regarding the imp act of existing contaminates. Westinghouse has been given authorization from DHEC to begin writing the Re medial Investigation report. Fieldwork data was submitted to DHEC through monthly progress reports, and the current data is publicly available on Westinghouse and DHEC websites.
Westinghouse has made improvements to site operations to further assure that future operations are safe and protective of employees, the public and the environment.
For example, over the past several years, Westinghouse has:
completed extensive fieldwork under a Remedial Investigation Work Plan to characterize the source, nature, and extent of impact in groundwat er, surface water, soil, and sediment. This work included the addition of 57 new groundwater monitoring wells; eliminated a nickel-plating operation; eliminated the use of tetrachloroethylene (P CE) and replaced it with a non-hazardous material; completed a Technetium-99 (Tc-99) source investiga tion which determined current site operations do not have the potential to introduce concentrati ons of Tc-99 above the Environmental Protection Agencys drinking water standard into the environment; removed legacy UF6 cylinders for off-site disposal; re-designed the Hydrofluoric Acid (HF) Spiking Stations; installed a sentinel groundwater monitoring well network around the Chemical Area manufacturing building; removed all intermodal storage containers with radiological materials from the Southern Storage Area and implemented procedural requirements to forbid this method of storage; removed out-of-service equipment and disposed of uranium contaminated equipment on the manufacturing building roof; removed the East Lagoon from service, remediated, di sposed of waste materials, and restored the former lagoon footprint to a grassy field; established a Community Engagement Board; completed fieldwork for a cultural resource survey in accordance with a plan approved by the South Carolina Historic Preservation Office; and initiated sanitary lagoon sludge characterization activities and process replacement design in preparation for lagoon closure.
Additionally, Westinghouse continues to invest in infr astructure in preparation for an additional 40 years of operation. To ensure infrastructure longevity Wes tinghouse has replaced or refurbished key systems such as boilers, cooling towers, fire system, and undergr ound piping, and executes a process to continually assess infrastructure and capital assets for future replacement and refurbishment.