ML23114A361

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Enclosures 2 & 3 - SCDHEC Approval Letter of Westinghouse Ri Report, Dated March 23, 2023 and Environmental Sampling and Monitoring Program Section of SNM-1107 License Application
ML23114A361
Person / Time
Site: Westinghouse
Issue date: 03/23/2023
From: Kuhn K
State of SC, Bureau of Land and Waste Management
To: Joyner D
Office of Nuclear Material Safety and Safeguards, Westinghouse
Shared Package
ML23114A358 List:
References
LTR-RAC-23-31
Download: ML23114A361 (1)


Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3

LTR-RAC-23-31 Enclosure 2

Enclosure 2

SCDHEC Approval Letter of Westinghouse RI Report, dated March 23, 2023

(Non-Proprietary)

March 23, 2023

Ms. Diana P. Joyner Principal Environmental Engineer Westinghouse Electric Company LLC Nuclear Fuel Columbia Fuel Fabrication Facility 5801 Bluff Road Hopkins, SC 29061

Re: Westinghouse Electric/Columbia Plant Final Remedial Investigation Report dated February 28, 2023 Richland County Consent Agreement CA-19-02-HW File # 51377

Dear Ms. Joyner:

The South Carolina Department of Health and Environmental Control (Department) has reviewed and approves Remedial Investigation report. The Department is requesting a Feasibility Study work plan to address the future steps for this site. Please submit the Feasibility Study work plan, to my attention, on or before July 15, 2023. If you have any questions, please contact me at kuhnkm@dhec.sc.gov or (803) 898-0722.

Sincerely,

Kimberly M. Kuhn, Project Manager State Voluntary Cleanup Section Division of Site Assessment, Remediation and Revitalization Bureau of Land and Waste Management

Cc: Lucas Berresford, BLWM Veronica Barringer, Midlands EA Office Chuck Suddeth, P.G., AECOM, 101 Research Drive, Columbia, SC 29203 Jeremy Grant, AECOM, 101 Research Drive, Columbia, SC 29203 File # 51377 WESTINGHOUSE NON-PROPRIETARY CLASS 3

LTR-RAC-23-31 Enclosure 3

Enclosure 3

Environmental Sampling and Monitoring Program Section of SNM-1107 License Application

(Non-Proprietary)

Non-Proprietary Class 3

10.1.3 Solid Waste Disposal

Solid waste disposal preparation facilities, with sufficient capacity and capability to enable processing, packaging, and transfer of solid wastes to licensed treatment or disposal sites, in accordance with applicable regulations, are provided and maintained in proper operating condition.

10.1.4 Environmental Sampling and Monitoring

The CFFF environmental sampling and monitoring program includes the sampling criteria presented in Table 10.1. Samples are either an alyzed by the sites Chemical Laboratory or sent off-site to a certified laboratory. Sampling methods are in accordance with approved Environmental Protection Agency (EPA)/Department of Energy (DOE) methods. (Note:

For wells found not to contain water at the time of sampling, an evaluation is performed by the Environmental Protection Function to determine if alternate well data can be used to represent the dry well; or, if a new well must be installed.)

Table 10.2 presents the well monitoring network and Table 10.3 presents the associated typical program analytical sensitivities. The groundwater monitoring network is comprised of four types of wells:

(a) Perimeter wells to detect a potential release before it could migrate off-site.

(b) Sentinel wells to detect a potential source or contaminant migration in an operable unit.

(c) NPDES permit required wells to detect a leak in and a potential contaminant migration from the site wastewater treatment system.

(d) Area of impact wells to monitor known areas impacted by uranium and Tc-99.

At a minimum, three wells are designated to monitor for each area impacted by uranium and Tc-99. One well is located to detect maximum concentration and two are located downgradient of the impacted area.

Locations of the four air, vegetation and soil monitoring stations are presented in Figure 10.1. A fifth soil sample is taken in the stormwater ditch on the southeast corner of West 2 Lagoon. Figure 10.2 presents the locations of surface water sampling locations.

Surface water sampling locations:

1. Entrance - Sample obtained from entrance side of flood gate valve from Mill Creek Swamp into Upper Sunset Lake. GPS Coordinates: N-335259.72 W-805556.32
2. Exit - Sample obtained from exit side of flood gate valve from Sunset Lake Swamp into the canal. GPS Coordinates: N-335216.94 W-805528.52
3. Pond (Gator) - Sample obtained from surface of pond. GPS Coordinates: N-335247.54 W-805517.46
4. Spillway - Sample obtained from between Lower Sunset Lake and Sunset Lake Swamp. GPS Coordinates: N-335234.72 W-805514.58

SNM-1107 Rev. 1 Page No. 96 Non-Proprietary Class 3

5. Causeway - Sample obtained from concrete flume connecting Upper and Lower Sunset Lakes. GPS Coordinates: N-335243.55 W-805524.
6. Roadway - Sample obtained from Plant side of roadway, where Control Valve A/B stream and Control Valve D/E stream connect. This is before the stream flows into Control Valve C. GPS Coordinates: N-335252.88 W-805520.68
7. Lower Sunset Lake -Sample obtained from plant side of lake. GPS Coordinates:

N-33°5243.49 W-80°5517.94

Sediment sampling locations:

1. Pond (Gator) - Sample obtained below water surface at the installed platform on the northern side of the pond. GPS Coordinates: N-335247.54 W-805517.46
2. Lower Sunset Lake -Sample obtained from plant side of lake. GPS Coordinates:

N-33°5243.49 W-80°5517.94

3. Congaree River diffuser discharge point.

A fish sample is taken annually from the Congaree River.

River water samples are taken at the following locations:

1. Blossom Street Bridge;
2. 500 yards above the discharge;
3. 500 yards below the discharge; and
4. Mill Creek where it converges with the Congaree River.

These sampling criteria, sensitivities, and/or locations can be changed without prior NRC Staff approval provided:

(a) A documented evaluation by the Environmental Protection Function demonstrates that the changes do not decrease the overall effectiveness of the environmental sampling and monitoring program; and,

(b) The changes are submitted to NRC Staff as part of the subsequent updates of this License Application to enable opportunity to inspect the evaluation.

10.1.5 Conceptual Site Model

Environmental monitoring data is input into a CSM on a periodic frequency. The CSM provides an understanding of how a contaminant release may be observed and measured currently in the site environmen t and identifies the fate and transport of the contaminant in the future. The model incorporates what is known about the sites hydrogeology, existing and past site activities that may have resulted in contaminant releases to the environment, the locations of those releases, the contaminants of concern, their fate and transport within the environment, and the receptors of those contaminants.

SNM-1107 Rev. 1 Page No. 97 Non-Proprietary Class 3

Table 10.1 Environmental Sampling Criteria

TYPE OF SAMPLE LOCATIONS ANALYSES MINIMUM SAMPLING FREQUENCY

Air Particulates 4 Alpha Continuous (Collection Weekly)

Site Surface Water 7 Isotopic Uranium; Tc-99 Quarterly

Groundwater 1181 Isotopic Uranium; Tc-99 Semi-Annually

Congaree River Surface Water 4 Isotopic Uranium; Tc-99 Quarterly

Sediment 3 Isotopic Uranium; Tc-99 Annually

Soil 5 Isotopic Uranium; Tc-99 Annually

Vegetation 4 Isotopic Uranium; Tc-99; Fluoride Annually

Congaree River Fish 1 Isotopic Uranium; Tc-99 Annually

Notes:

1. Westinghouse anticipates that the number and location of active wells used for monitoring purposes will evolve throughout the CA process. This number will be updated at the conclusion of the CA with all wells in active use at that time.

SNM-1107 Rev. 1 Page No. 99 Non-Proprietary Class 3

Table 10.2 Uranium and Tc-99 Groundwater Well Monitoring Network3 UraniumandTc99GroundwaterWellWaterMonitoringNetwork WRW1 W38 W68 W98 WRW2 W39 W69 W99 W3A W40 W70 W100 W4R W41R W71 W102 W62 W42 W72 W103 W7A W43 W73 W104 W10 W44 W741a W105 W112 W45 W751a W106 W13R W46 W76 W107 W14 W47 W771b W108 W152 W48 W781b W109 W16 W49 W79 W110 W17 W50 W80 W111 W18R W51 W81 W112 W19B W52 W82 W113 W20 W53 W83 W114 W22 W54 W84 W115 W23R W551a W85 W116 W24 W56 W86 W117 W25 W57 W87 W118 W26 W58 W88 W119 W272 W59 W89 W120 W281b W60 W90 W121 W29 W61 W91 W122 W30 W62 W92 W123 W32 W63 W931b W124 W33 W64 W94 W125 W35 W65 W95 W126 W36 W66 W96 W37 W67 W97

Notes:

1. For uranium;
a. Currently Well W-55 and W-56 are monitored to detect which has the maximum concentration. Wells W-74 and W-75 are monitored downgradient of the impacted area.
b. Currently well W-77 is monitored to detect maximum concentration and wells W-93, W-78 and W-28 are monitored downgradient of the impacted area.
2. For Tc-99, currently wells W-6 and W-11 are monitored to detect maximum concentration and wells W-15 and W-27 are monitored downgradient of the impacted area.
3. Westinghouse anticipates that the number and location of active wells used for monitoring purposes will evolve throughout the CA process. This list will be updated at the conclusion of the CA with all wells in active use at that time.

SNM-1107 Rev. 1 Page No. 100 Non-Proprietary Class 3

Table 10.3 Typical Environmental Programs Radiological Analytical Sensitivities

TYPE OF SAMPLE ANALYSES TYPICAL SAMPLE NOMINAL MINIMUM QUANTITY DETECTION LEVEL Air Particulates Alpha 571 Cubic Meters 6.0E-14 µCi/ml Surface Water Uranium 1 Liter 0.5 pCi/l Tc-99 1 Liter 50 pCi/l Groundwater Uranium 1 Liter 0.5 pCi/l Tc-99 1 Liter 50 pCi/l River Water Uranium 1 Liter 0.5 pCi/l Tc-99 1 Liter 50 pCi/l

Sediment Uranium 100 Grams 0.5 pCi/g Tc-99 100 Grams 50 pCi/g

Soil Uranium 100 Grams 0.5 pCi/g Tc-99 100 Grams 50 pCi/g

Fluoride 100 Grams Variable (based on dilution level)

Vegetation Uranium 100 Grams 0.5 pCi/g Tc-99 100 Grams 50 pCi/g

Fish Uranium 1 Kilogram 0.5 pCi/g Tc-99 100 Grams 50 pCi/g

SNM-1107 Rev. 1 Page No. 101