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{{#Wiki_filter: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-013      Received: November 19, 2021 PUBLIC SUBMISSION                                                E-RIDS=ADM-03 Status: Pending_Post ADD: Jean Trefethen, Tracking No. kw6-w7hp-dyks Antoinette Walker-Smith, Mary Neely Comments Due: November 19, 2021 Comment (5)          Submission Type: Web Publication Date:
{{#Wiki_filter:11/23/21, 10:42 AM blob:https://www.fdms.gov/5cbf8464-cf59-4025-bcfb-560a89b7fde5
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:
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:
and Editing Staff                                                  Our ref: LTR-RAC-21-77 November 19, 2021
9/28/2021 Docket: NRC-2015-0039 Citation: 86 FR 53694 Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility


==SUBJECT:==
Comment On: NRC-2015-0039-0088 Westinghouse Electric Company, LLC, Columbia Fuel Fabrication Facility
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:==
Document: NRC-2015-0039-DRAFT-0091 Comment on FR Doc # 2021-21053
(1) NUREG-2248, Environmental Impact Statement for the License Renewal of the Columbia Fuel Fabrication Facility in Richland 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 recommendation that the CFFF license be renewed for an additional 40 years. The enclosures provide comments 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 environmental 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 predictable response to any issues in the future.
Westinghouse has previously submitted a proposed license 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 monitoring program to the NRC for review and approval upon DHEC approval of the Remediation Investigation (RI) report 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 report to DHEC. These proposed commitments provide NRC with two additional opportunities to require adjustments 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.
Submitter Information
In addition to the many new environmental media sampling requirements in the license renewal application, Westinghouse is required to submit copies of groundwater reports to both DHEC and NRC and notify NRC of any National Pollutant Discharge Elimination System (NPDES) Notice of Violations.
Westinghouse has completed the remedial investigation fieldwork to fully characterize the site. This has significantly reduced uncertainties regarding the impact of existing contaminates. Westinghouse has been given authorization from DHEC to begin writing the Remedial 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 groundwater, 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 (PCE) and replaced it with a non-hazardous material; completed a Technetium-99 (Tc-99) source investigation which determined current site operations do not have the potential to introduce concentrations 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, disposed 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 infrastructure in preparation for an additional 40 years of operation. To ensure infrastructure longevity Westinghouse has replaced or refurbished key systems such as boilers, cooling towers, fire system, and underground piping, and executes a process to continually assess infrastructure and capital assets for future replacement and refurbishment.


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 4 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 : Substantive Comments Page Line      Current Wording          Suggested Wording                                    Justification 2-1  11      nuclear power          ...nuclear power reactors. Other products            Clarification of products fabricated by Westinghouse at reactors.              fabricated by WEC at CFFF include neutron            CFFF.
Email: malekem@westinghouse.com Organization: Westinghouse Electric Company LLC
absorbing assemblies such as Tritium-Producing Burnable Absorbers (TPBAR). TPBARs contain no radioactive material subject to NRC regulation.
TPBARs are used by the U.S. Department of Energys Tritium Readiness Program and are designed to produce tritium when placed in a low-enriched uranium fuel assembly and irradiated in a nuclear power reactor. The WEC..
2-6  1-12    The SOLX process        The SOLX process separates uranium from              The site discontinued use of PCE in April of 2020. All separates uranium from  contaminants, recovers it as clean UN solution,      PCE residual has been removed from the sites SOLX contaminants, recovers  and delivers it to storage tanks for conversion back  process. WEC is not generating any new containers it as clean UN solution, to usable product UO2. In 2019, the WEC              (Satellite Accumulation Area or otherwise) of WCM and delivers it to      modified its management practices for the SOLX        with PCE material or residual. Likewise, WEC is not storage tanks for        mixture containing PCE (WEC 2020-TN6844).            incinerating any new containers of WCM with PCE conversion back to      The WEC no longer adds SOLX mixture                  material or residual.
usable product UO2. In  containing PCE to wet combustible material 2019, the WEC            (WCM) and revised its process to segregate WCM modified its            containing the SOLX mixture any PCE residual management practices    into a dedicated Satellite Accumulation Area. The for the SOLX mixture    WEC has also ceased charging WCM containing (WEC 2020-TN6844).      the SOLX mixture PCE into the incinerator. Any The WEC no longer        bulk SOLX mixture that existed as of July 1, 2019 adds SOLX mixture to    was processed to recover uranium and then sent wet combustible          offsite to a licensed facility as mixed hazardous material (WCM) and      waste for treatment and disposal. In April 2020, revised its process to  the WEC eliminated its use of perchloroethylene segregate WCM            (PCE) in the SOLX process and replaced it with containing the SOLX      dodecane. In 2021, the WEC anticipates resuming mixture into a          the incineration of SOLX materials containing
                                                        © 2021 Westinghouse Electric Company LLC All Rights Reserved


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 5 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 dedicated Satellite      dodecane and will submit a revised air permit Accumulation Area.      application to reflect this change, including new The WEC has also        emissions calculations.
General Comment
ceased charging WCM containing the SOLX mixture into the incinerator. Any bulk SOLX mixture that existed as of July 1, 2019 was processed to recover uranium and then sent offsite to a licensed facility as mixed hazardous waste for treatment and disposal. In April 2020, the WEC eliminated its use of perchloroethylene (PCE) in the SOLX process and replaced it with dodecane. In 2021, the WEC anticipates resuming the incineration of SOLX materials containing dodecane and will submit a revised air permit application to reflect this change, including new emissions calculations.
2-11 11 levels were            levels were detected above the WEC-            WEC is using the most conservative clean-up standards detected above the      established residential cleanup standard. With    from NRC NUREG 1757, Volume 2, Rev 1, Appendix WEC-established          the


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 6 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 residential cleanup                                                          H and USEPA Regional Screening Levels. WEC did standard. With the                                                        not establish these standards.
See attached file
2-14 45-46 The lagoons are also  The lagoons are also inspected on an annual basis  The draft NPDES permit, to which WEC is already inspected on an annual  by the State by a South Carolina registered          complying for lagoon maintenance, requires annual basis by the State. professional engineer (PE) with knowledge            inspection of impoundment stability by a SC registered relevant to impoundment stability.                  PE. Additional inspections of lagoon liners are required either annually or biennially, also by a SC registered PE.
There are no prescribed inspections for lagoons by state officials in either the current NPDES permit or the draft NPDES permit.
2-21 13-16 Going forward, the      uranium or Tc-99, from a known or unknown          With the information collected during the RI, there is WEC will sample these  source, is moving offsite migrating.                assurance that radionuclides are not moving offsite.
groundwater wells and analyze for uranium and Tc-99 to determine (1) whether the source of the current shallow groundwater contamination is leaks from plant operation and/or (2) if existing contamination of uranium or Tc-99, from a known or unknown source, is moving offsite.
2-22 19-21 The WEC stated that    The WEC stated that the monthly Discharge          In the cited reference (TN6844 pg 16 of 74), WEC states the monthly Discharge  Monitoring reports sent to SCDHEC monthly, as        Effluent from the permitted wastewater treatment Monitoring reports sent required by the NPDES permit, will also be          system including the site lagoons is monitored according to SCDHEC monthly,      reported to the NRC on a semiannual basis (WEC      to the parameters and limits described in the site NPDES as required by the      2020-TN6844). Additionally, NRC regulations          permit. These data are submitted to SC DHEC through NPDES permit, will      require monitoring and reporting of radiological    required monthly Discharge Monitoring Reports also be reported to the effluents in order to estimate the potential dose to (DMRs).
NRC on a semiannual    public. These results are reported to the NRC on a basis (WEC 2020-        semi-annual basis.                                  Additionally, NRC regulations require monitoring and TN6844).                                                                    reporting of radiological effluents. These results,


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 7 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 including liquid discharges to the Congaree River in accordance with the NPDES permit, are reported to the NRC on a semi-annual basis.
Attachments
The paragraph beginning Additionally, NRC regulations require is meant to reference the semi-annual effluent report submitted to NRC as part of the 10 CFR 70.59 requirements to estimate potential dose to the public. The normal liquid discharge path for the CFFF is via the discharge line to the Congaree River.
WEC does not submit monthly DMRs to the NRC.
3-26 25-30 As described in          As described in Section 3.3.1 of this EIS, surface  Site data submitted with reference WEC 2021-TN6920 Section 3.3.1 of this    water quality on the CFFF site has been noticeably    and in Section 3.3.1 of the DEIS do not support the EIS, surface water        affected by past plant activities. The WECs          assertion that surface water quality on the CFFF site has quality on the CFFF      surface water sampling conducted as part of its      been noticeable affected by past plant activities. Suggest site has been            NRC license requirements has indicated elevated      deleting.
noticeably affected by    gross alpha and gross beta activities in CFFF site past plant activities. stormwater runoff sampled just before the control The WECs surface        valve point of discharge to the drainage ditch (i.e., Roadway is a specific name given to surface water water sampling            the Roadway sample location) and elevated gross      samples collected within a site drainage ditch conducted as part of its  beta in samples from the Gator Pond spring and        immediately upstream of C-valve but across the existing NRC license              the pond itself (WEC 2021-TN6920, WEC 2019-          roadway. Roadway samples are not collected directly requirements has          TN6423).                                            after rainfall events.
indicated elevated gross alpha and gross                                                          Westinghouse has instituted internal investigation beta activities in CFFF                                                        levels for gross alpha and gross beta. These site stormwater runoff                                                          investigation levels are delineated in CFFF procedure sampled just before the                                                        RA-434, Environmental Data Management.
control valve point of discharge to the                                                                The following justification is based on measured surface drainage ditch (i.e., the                                                      water values from January 2010 through May 2021.
Roadway sample location) and elevated                                                          Roadway:
gross beta in samples                                                          Since January 2010, the highest gross alpha from the Gator Pond                                                            measurement at the Roadway location was 46 pCi/L in


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 8 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 spring and the pond                                    July 2014. The next highest result was 26 pCi/L in Sept itself (WEC 2021-                                      2013. The average gross alpha measurement at the TN6920, WEC 2019-                                      Roadway is 8 pCi/L. Zero samples have exceeded the TN6423).                                              sites internal investigation level for gross alpha in surface water of 50 pCi/L at the Roadway location.
LTR RAC 21 77
Since January 2010, the highest gross beta measurement at the Roadway location was 52 pCi/L in Feb 2012. The next highest result was 37 pCi/L in November 2012.
The average gross beta measurement at the Roadway is 10 pCi/L. Zero samples have exceeded the sites internal investigation level for gross beta in surface water of 300 pCi/L at the Roadway location.
Gator Pond:
Since January 2010, the highest gross alpha measurement in Gator Pond was 11 pCi/L in Sept 2011.
The next highest result was 7 pCi/L in January 2020.
The average gross alpha measurement in Gator Pond is 1 pCi/L. Zero samples have exceeded the sites internal investigation level for gross alpha in surface water of 50 pCi/L in the Gator Pond location.
Since January 2010, the highest gross beta measurement in Gator Pond was 57 pCi/L in Feb 2020. The next highest result was 56 pCi/L in January 2016. The average gross beta measurement in Gator Pond is 25 pCi/L. Zero samples have exceeded the sites internal investigation level for gross beta in surface water of 300 pCi/L in the Gator Pond location.
Tc-99 was not detected above the MDC in any surface water samples collected during Phase I of the RI Work Plan, including location SW-23 which was in the Gator Pond (WEC 2020 TN6526).


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 9 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 3-26 46  Contaminated Mill      Contaminated Mill Creek sediments could are    The minor impact of this unlikely event is described on 3-27 1-7 Creek sediments could  unlikely to be transported offsite during flood page 3-28, lines 19-24.
blob:https://www.fdms.gov/5cbf8464-cf59-4025-bcfb-560a89b7fde5 1/1 WESTINGHOUSE NON-PROPRIETARY CLASS 3
be transported offsite  events; however if some of these sediments were during flood events. transported offsite during a flood event, they  A West II Lagoon rupture, which occurred in 1971 is the Sediment samples        would not be a risk to human health or the      likely source of contaminated sediment located in Upper obtained in 2019 from  environment.                                  Sunset Lake. At the time of the lagoon rupture, liquid and the Upper and Lower                                                    sediment wastes being held within the lagoon for Sunset Lake sections of                                                treatment contained higher levels of uranium than what is Mill Creek exceeded                                                    present now. Around 1980 the site installed a waterglass residential screening                                                  process to remove additional low-level uranium from levels for uranium                                                      liquid waste so that the uranium could be recycled. This (WEC 2020-TN6526).                                                      change also reduced the uranium content in process Mill Creek sediment                                                    lagoon sludges (calcium fluoride) such that it meets free samples obtained                                                        release criteria and can be recycled.
between the Lower Sunset Lake dike and                                                    As stated above, the draft NPDES permit, to which WEC the exit dike contained                                                is already complying for lagoon maintenance, requires uranium isotope                                                        annual inspection of impoundment stability by a SC activities below the                                                    registered PE. Additional inspections of lagoon liners are residential screening                                                  required either annually or biennially, also by a SC levels (the largest                                                    registered PE.
activity was about one-half of the residential                                                The Technical Basis Document (TBD), Remedial screening level) (WEC                                                  Investigation Phase II Sediment Sampling and Sediment 2020-TN6526).                                                          Transect Interim Evaluation for the Westinghouse Additional sediment                                                    Columbia Fuel Fabrication Facility was submitted to sampling in Mill Creek                                                  SCDHEC with the July 2021 CA Monthly Progress and Sunset Lake is                                                      Report. This document explains: Evaluation of the being conducted as part                                                elevated sediment results identified on CFFF property of the remedial                                                        could lead to three possible conclusions. First, the results investigation process                                                  could indicate an immediate need to take remedial action under the CA (WEC                                                      based on the determined level of risk. Second, the results 2020-TN6707).                                                          could indicate that further evaluation is warranted in the Feasibility Study (FS) that will be performed as part of the Consent Agreement, and third, the results could indicate that no action is necessary.


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 10 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 Based on this interim evaluation of the Phase II RI sediment sampling results, the follow up bounding sampling results, and the dose modeling/associated risk estimates, no immediate action is necessary. The results of these comprehensive sampling campaigns have defined the limited horizontal and vertical extent of sediment impact. There are no current or future concerns for contaminants to potentially move offsite, and the documented impacts pose no potentially significant threat to plant workers, the general public or the environment.
Westinghouse Electric Company LLC Columbia Fuel Site 5801 Bluff Road Hopkins, South Carolina 29061-9121 USA
Continued environmental monitoring per the sites NRC license and CFFFs procedure RA-434, Environmental Data Management, will be performed, and further evaluation in the areas of the site drainage ditch, Gator Pond and the Mill Creek Corridor will be included in the Final RI report and in the FS required by the Consent Agreement.
3-37 7-12 VOC contamination      VOC contamination south of the WWTP, north        Through extensive assessment with the RI, there is no south of the WWTP,      and east of Gator Pond, occurs at concentrations  reason to believe there is an independent or unidentified north and east of Gator above the MCL in the shallow surficial aquifer. source of PCE in this area. Suggest deleting.
Pond, occurs at        This portion of the PCE plume may be the result of concentrations above    the spreading of the main plume. or may have      Empirical data from RI soil gas surveys indicate two the MCL in the shallow  arisen from an independent, unidentified source. likely source areas alongside the main manufacturing surficial aquifer. This A second plume is identified in the CSM as        building.
portion of the PCE      occurring west of the main plume; this area is the plume may be the        subject of additional investigation as part of the The use of tetrachloroethylene was discontinued by the result of the spreading Phase II remedial investigation activities.      site in April of 2020.
of the main plume or may have arisen from an independent, unidentified source. A second plume is identified in the CSM as occurring west of the main plume; this


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 11 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 area is the subject of additional investigation as part of the Phase II remedial investigation activities.
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:
3-40 22-24 Therefore, it is not    Therefore, it is not immediately clear whether the Suggest deleting as speculation.
and Editing Staff Our ref: LTR-RAC-21-77
immediately clear        recent sampling results in 2018 and 2019 indicate whether the recent      that either or both of the CWW line leaks are the  All known historical leaks and potential sources have sampling results in      only sources of gross alpha and uranium levels. been entered into the site CSM and evaluated as part of 2018 and 2019 indicate                                                      the RI. Three Chemical Area Operating Unit sentinel that either or both of                                                      wells (W-55, W-56, and W-77) are currently impacted the CWW line leaks                                                          with U results above the drinking water MCL. The are the only sources of                                                      impacted wells are located in very close proximity to gross alpha and                                                              the manufacturing building. Sentinel wells are located uranium levels.                                                            on the western side (includes W-56 and W-57) and southern side (includes W-77) of the main manufacturing building.
Monitoring wells side gradient and downgradient of the previous three impacted sentinel wells do not contain U above the MCL, which indicates the limited extent of U in groundwater.
The sites groundwater monitoring network is comprised of four types of wells:
: 1. perimeter wells: to detect a potential release before it could migrate off-site;
: 2. sentinel wells: to detect a potential source or contaminant migration in an Operable Unit;
: 3. NPDES permit required wells: to detect a leak in and potential contaminant migration from the site wastewater treatment system; and
: 4. 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


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 12 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 is located to detect maximum concentration and two are located downgradient of the impacted area.
November 19, 2021
The pending Feasibility Study (FS) (as part of the Consent Agreement) will determine remedial actions needed for uranium impacts.
3-43 31-33 For example, the        For example, the source of VOC contamination in The source of VOC contamination in the Western source of VOC            the Western Groundwater AOC is uncertain, as is      Groundwater AOC is no longer uncertain. A contamination in the    the source of the Tc-99 contamination south of the preferential flow path was discovered during Remedial Western Groundwater      plant is uncertain.                                Investigation Work Plan (RIWP) Phase II investigative AOC is uncertain, as is                                                      activities that connect the Western GW AOC plume to the source of the Tc-99                                                      the main plume.
contamination south of the plant.
3-45 23-36 However, the CSM is    However, the CSM is currently mainly                WEC considers the CSM as a snapshot in time that currently mainly        qualitative, and is currently limited to a          illustrates to scale the analytical distribution of qualitative, and is      hydrogeologic description of the site, the potential contaminants in the subsurface. The CSM is not serving currently limited to a  sources of contamination, and the extent of          in a predictive capacity in the same way that a numerical hydrogeologic            existing contamination. The NRC staff                groundwater fate and transport model would do.
description of the site, acknowledges that the CSM is currently              However, it does show the most recent data and the the potential sources of investigatory and is intended to evolve as site      spatial interpolation of that data in the same way that a contamination, and the  investigation and remediation proceed and as new    snapshot within the numerical model would, to scale.
extent of existing      data are collected (WEC 2020-TN6526). The            The WEC CSM is based on analytical data to help contamination. The      WEC intends to use the CSM as a decision-making      evaluate data gaps and future remedial design to NRC staff                tool throughout the life of the facility. However,  generate the conclusions, and necessary next steps. The acknowledges that the    there are currently a number of uncertainties        CSM is not intended to replace a numerical groundwater CSM is currently        associated with the fate and transport of            model. It is meant to be the warehouse that integrates all investigatory and is    contaminants during the period of the proposed      data over time (including the results of any future fate intended to evolve as    action (40 years). For example, the degradation      and transport groundwater model, and the human health site investigation and  rate of VOCs, the role of the unsaturated zone as a  and ecological risks) to support comprehensive decision remediation proceed      reservoir of contaminants, and the effects of        making. These distinctions between groundwater and as new data are      lithologic heterogeneities on groundwater flow and  analysis tools (CSM, plume analytics and numerical collected (WEC 2020-    contaminant transport are currently undefined but    groundwater model) were incorporated into revision 1 of TN6526). The WEC        may be needed to properly interpret existing        site procedure RA-434, Environmental Data intends to use the CSM  observations and make inferences about future        Management.


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 13 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 as a decision-making    groundwater quality effects. The NRC staff finds tool throughout the life that the current CSM is insufficient for evaluating of the facility.        the future movement and ultimate fate of However, there are      contaminants in groundwater at the CFFF site that currently a number of    may occur as the result of future inadvertent uncertainties associated releases. The CSM is data driven and is primarily with the fate and        qualitative in all aspects. The CSM is a snapshot transport of            in time that illustrates the analytical distribution of contaminants during      contaminants in the subsurface to scale. The CSM the period of the        is not serving in a predictive capacity in the same proposed action (40      way that a numerical groundwater fate and years). For example,    transport model would do, however, it does show the degradation rate of  the most recent data and the spatial interpolation of VOCs, the role of the    that data in the same way that a snapshot within unsaturated zone as a    the numerical model would, to scale. The WEC reservoir of             CSM is driven from analytical data to help contaminants, and the    evaluate data gaps and future remedial design to effects of lithologic    generate the conclusions, and necessary next steps.
==SUBJECT:==
heterogeneities on       The CSM is not intended to replace a numerical groundwater flow and    groundwater model, it is meant to be the contaminant transport    warehouse that integrates all data over time are currently undefined  (including the results of a future numerical fate but may be needed to    and transport groundwater model, and the human properly interpret      health and ecological risks) to support existing observations    comprehensive decision making. The WEC plans and make inferences      to enhance the CSM as the remedial about future            investigation groundwater quality effects. The NRC staff finds that the current CSM is insufficient for evaluating the future movement and ultimate fate of contaminants in groundwater at the CFFF site that may
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]


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 14 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 occur as the result of future inadvertent releases. The WEC plans to enhance the CSM as the remedial investigation 3-48 41-45 These conservative      These conservative estimates may be appropriate    Fate and transport analysis will be included in the FS estimates may be        if the contaminants travel preferentially along      required by the Consent Agreement. Models are useful appropriate if the      higher-velocity flow paths within deposits of more  tools for projecting potential outcomes; however contaminants travel      permeable (sand, gravel) sediments. This could      existing data about current site conditions and plume preferentially along    result in contaminants traveling offsite more        velocities is also considered and evaluated.
==REFERENCE:==
higher-velocity flow    quickly (e.g., with a travel time less than 20 years paths within deposits    over a distance of 600 m) than suggested by the of more permeable        average groundwater velocity. The installed (sand, gravel)           groundwater monitoring well network is designed sediments. This could    to identify the potential movement of each plume, result in contaminants  and data is available to demonstrate that the traveling offsite more  current movement is significantly slower than the quickly (e.g., with a    most conservative estimates.
(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)
travel time less than 20 years over a distance of 600 m) than suggested by the average groundwater velocity.
(2) LTR-RAC-21-57, Westinghouse Revised SNM-1107 License Renewal Application, (September 2021) (ML21263A217)
3-50 33-40 All                      N/A - see Justification.                            The NRC has determined that there is a low potential for contaminants to move offsite, and has further determined that there are no groundwater withdrawals or consumptive uses onsite. Westinghouse agrees with these determinations.
Nevertheless, the staff goes on to conclude that impacts to groundwater resources from continued operation will be SMALL to MODERATE, rather than SMALL, apparently based on the assumption that future inadvertent releases of contaminants will lead to onsite impacts.


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 15 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 This broad-brush conclusion could leave stakeholders, including decisionmakers within the agency, with the misimpression that offsite impacts to groundwater resources might be something other than SMALL. To correct this potential misimpression, support informed decision-making, and ensure the final EIS is clear to all stakeholders, Westinghouse recommends that the NRC staff specifically clarify that offsite groundwater impacts from the proposed action are expected to be SMALL, and separate this conclusion from any final conclusion regarding onsite groundwater impacts.
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.
3-70 36 ..emissions from    N/A - see justification.            Westinghouse agrees with the conclusion that proposed continued                                        greenhouse gas (GHG) emissions from the continued operation of the CFFF                                    operation of CFFF would not be significant. The would not be                                              analysis presented and this conclusion, however, do not significant..                                            provide the full context of the environmental benefits of the proposed action.
Specifically, CFFF manufactures fuel that ultimately supports approximately 10% of US electricity generation, which amounts to the largest single source of low-emission electrical power generation capability in the United States. The minimal GHG emissions from CFFF operations and from the other stages of the nuclear fuel cycle in fact represent a significant environmental benefit, by providing substantial baseload electrical power with minimal GHG emissions in comparison to all reasonable alternatives. See, e.g., NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 6, Second Renewal, Regarding Subsequent License Renewal for Surry Power Station Units 1 and 2 (https://www.nrc.gov/docs/ML2007/ML20071D538.pdf)
(p. 4-127, tbl. 4-12). These positive environmental


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 16 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 impacts should be acknowledged and disclosed in Section 3.7.2.3.
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.
This point is also missed in the discussion of the impacts on Climatology, Meteorology, and Air Quality associated with the No-Action Alternative (Section 3.17.1.6). Specifically, under the No-Action alternative, the closure of CFFF in 2027 would reduce the supply of clean nuclear fuel in the United States and worldwide, thereby increasing the cost of such fuel and compounding the existing financial pressures on the nuclear industry. Given that many plants in the United States are already financially at risk of shutting down prematurely, the increased fuel costs stemming from the No-Action alternative would likely lead to the shutdown of existing low-emissions baseload electrical generation capacity. This would exacerbate the national and global problem of GHG emissions and resulting environmental impacts. By contrast, the 40-year license renewal requested by Westinghouse would secure the continued supply of nuclear fuel at the lowest cost, minimizing the potential for continued closures of valuable low-emission assets. The draft EIS alludes to this problem in Section 3.18.4.1 (Comparison of the Economic and Other Costs and Benefits). Westinghouse agrees that the economic costs of building a replacement facility elsewhere would greatly surpass the costs of continued operation, but it respectfully suggests that the draft EIS has not fully evaluated and disclosed the reasonably foreseeable environmental impacts of this fact.
To ensure fully informed decision-making and inform all stakeholders, including the public, of the full scope of environmental impacts of the proposed action, Westinghouse suggests that Sections 3.7.2.3, 3.17.1.6, and 3.18.4.1 be revised to disclose and more fully


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 17 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 explain the beneficial environmental impacts of renewing the CFFF license for 40 years.
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


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 18 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 : Editorial and Clarification Edits Page Line      Current Wording            Suggested Wording                                  Justification Shortly thereafter, in Shortly thereafter, in July 2018, there was a leak July 2018, there was a from equipment at the CFFF that resulted in leak from equipment at                                                          Metallic uranium (U) did not enter the subsurface. The uranium uranyl nitrate containing hydrofluoric xiii  13-15    the CFFF that resulted                                                          chemical that would have entered the subsurface is acid entering the subsurface under the facility in uranium entering the                                                        uranyl nitrate with up to 5% hydrofluoric acid.
© 2021 Westinghouse Electric Company LLC All Rights Reserved WESTINGHOUSE NON-PROPRIETARY CLASS 3
building.
subsurface under the facility building.
Additionally, the WEC initiated an investigation, under the purview of the South        Additionally, the WEC initiated an investigation, Carolina Department of      under the purview of the South Carolina Health and                  Department of Health and Environmental Control      Metallic uranium did not enter the subsurface. The xiii  14-17    Environmental Control      (SCDHEC), into a leak in 2011 from a buried pipe    material that contacted the soil was process wastewater (SCDHEC), into a leak      that also allowed process wastewaters containing    containing uranium.
in 2011 from a buried      uranium to enter the subsurface under the main pipe that also allowed      facility building.
uranium to enter the subsurface under the main facility building.
xv    44      The NRC staff also considered as an The NRC staff also considered as an alternative to alternative approving                                                          Missing word approving the WECs a license renewal request the WECs a license renewal request Suggest using Contaminants of Potential Concern (COPC) throughout for consistency with other sections COC constituent of xvii  34                                  COC constituent of concern                          in the DEIS. COPC is also used in documents prepared concern by WEC and its consultants that are submitted to SCDHEC.


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 19 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 See comments on pages 3-13.
Page 2 of 61 Our ref: LTR-RAC-21-77 November 19, 2021
1-1        No mention of the      Suggest incorporating language from the license  CFFF uses UF6 and uranyl nitrate (UN) to manufacture 33-36 uranyl nitrate process. renewal application.                              nuclear fuel.
1-7  11    into onsite water and  into onsite water and soil contamination under  Errant typo. The q should be an a.
soil contamination      aq under q 1-11 1-8  N/A                    East Lagoon Closure Plan                          There is no mention of the East Lagoon Closure Plan that was submitted to SCDHEC staff for approval prior to the decommissioning efforts. The former East Lagoon area is now green space, and its closure has been approved by SCDHEC.
The Remedial Investigation Report will be submitted to DHEC upon completion in 2022 for subsequent review, comment, and final approval.
1-11 36-37 Implementation of the  Implementation of the Phase II RIWP began in    The field investigation portion of the RI was completed Phase II RIWP began    November 2020 and is ongoing was completed in    in August 2021.
in November 2020 and    August 2021.
is ongoing.
1-12 3-4  Addendum 4 -          Addendum 4 - Sediment Sampling Plan to Bound    There are only 3 Addendums for the Consent Agreement Sediment Sampling      the Extent of Uranium Around SED-44 (WEC          Remedial Investigation.
Plan to Bound the      2021-TN7006).                                    Addendum 1: Southern Storage Area Extent of Uranium                                                        Addendum 2: East Lagoon Around SED-44 (WEC                                                        Addendum 3: Sanitary Lagoon 2021-TN7006).
There is no Addendum 4. The Sediment Sampling Plan to bound the Extent of Uranium Around SED-44 was an addendum to the Phase II RIWP scope of work.
2-1 34    Figure 2-3 shows that  Figure 2-2 2-3 shows that the remaining property Figure 2-2 is a better depiction of the undeveloped the remaining property  (approximately 441 ha [1,083 ac]) is mostly    property.
(approximately 441 ha
[1,083 ac]) is mostly


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 20 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 2-3 4    The WEC              The WEC CFFF manufactures nuclear fuel            Clarification manufactures nuclear  assemblies..
commitments, the license renewal would represent an approval of the environmental monitoring program for an initial period of five years or less.
fuel assemblies..
2-3 5    The WEC also          The WEC CFFF also produces..                    Clarification produces..
2-4 7    operations          operations involving encapsulated uranium and    Suggest adding the word uranium, as the reader may involving encapsulated sealed uranium materials for rod certification and not deduce from the text what encapsulated and and sealed materials  storage,                                        sealed materials are in reference to.
for rod certification and storage, 2-4 8    The WEC receives      The WEC CFFF receives cylinders                Clarification cylinders..
2-4 Note  In 2011, the WEC      In 2011, the WEC CFFF replaced .                Clarification 1    replaced 2-5 16-19 Low-level radioactive N/A                                                Suggest using a more current reference since the combustible scrap is                                                      submittal of license renewal application was in 2014.
incinerated to permit the recovery of uranium and to minimize the volume of waste disposal at a licensed low-level radioactive waste (LLRW) disposal facility. Typical incinerator feed materials include uranium-contaminated paper, shoe covers, gloves, mops, plastic bags, tape, and fiberboard containers (WEC 2012-TN7017).
2-5 23-25 The gases given off  The gases given off during the burning of solid  Suggested edit for accuracy.
during the burning of  wastes include carbon, carbon dioxide (CO2), and solid wastes are      mineral acid hydrochlorides (HCLs) and HF due to


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 21 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 carbon, carbon dioxide  the burning of rubber, plastics, and other (CO2), and mineral      chemicals.
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.
acid hydrochlorides (HCLs) and HF due to the burning of rubber, plastics, and other chemicals.
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.
2-6 13    The CFFF site has six  The CFFF site has six five lagoons that        The former East Lagoon area is now green space and its lagoons that            support                                        closure has been approved by SCDHEC.
support 2-6 14-16 The West Lagoons      Suggest deleting sentences.                      These sentences seem to describe the operable units Area includes the West                                                  (OUs) of the Remedial Investigation. These OU names, I and West II lagoons.                                                  although helpful for the RI work, are not used in site The Wastewater                                                          wastewater treatment procedures or SCDHEC permitting Treatment Area                                                          documents to describe the treatment processes at CFFF.
includes the South,                                                      Including them here could cause confusion.
North, and East Lagoons; and the Sanitary Lagoon Area includes the Sanitary Lagoon.
2-6 21-26 The East Lagoon has    The former East Lagoon hasd a 36 mil Hypalon    The former East Lagoon area is now green space and its a 36 mil Hypalon liner  liner (NRC 2018-TN6549) and was last relined    closure has been approved by SCDHEC.
(NRC 2018-TN6549)      around 1980 when the sites Waterglass system and 21 was last relined was installed (NRC 2019-TN6472). The WEC, around 1980 when the    however, has decided to decommission the East sites Waterglass      Lagoon (WEC 2020-TN6844). Characterization of system was installed    the East Lagoon sludge and closure processes are (NRC 2019-TN6472).      were completed ongoing in accordance with the The WEC, however,       Consent Agreement (CA) and the closure plan has decided to          approved by the South Carolina Department of decommission the East  Health and Environmental Control (SCDHEC)
Lagoon (WEC 2020-      (WEC 2020-TN7020, WEC 2020-TN7004).
TN6844).
Characterization of the East Lagoon sludge


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 22 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 and closure processes are ongoing in accordance with the Consent Agreement (CA) and the closure plan approved by the South Carolina Department of Health and Environmental Control (SCDHEC)
Westinghouse has made improvements to site operations to further assure that future operations are safe and protective of employees, the public and the environment.
(WEC 2020-TN7020, WEC 2020-TN7004).
2-7 Figure Figure 2-6 URRS        Replace Figure 2-6 with updated figure in            The East Lagoon appears in this image as a process unit.
2-6    Process Streams          Enclosure 3.                                          In 2019, when the ER (TN6510) was submitted, the East (Source: WEC 2019-                                                            Lagoon was still in service. The East Lagoon was TN6510)                                                                        decommissioned in 2021.
2-8 17-20 Consistent with the      Consistent with the WECs remediation activities    This section of the building is covered by the WECs remediation        procedure, the WEC will continue to monitor the      Decommissioning Funding Plan (DFP) and the cost activities procedure,    area and, based on the monitoring results, will      estimate includes removal and disposal of impacted soil the WEC will continue    determine when the area will be remediated (WEC      at the time of site decommissioning.
to monitor the area      2019-19 TN6546). Additionally, removal and and, based on the        disposal of this material has been added to the site monitoring results, will decommissioning plan.
determine when the area will be remediated (WEC 2019-19 TN6546).
2-10 33-39 The WEC also            The WEC also improved the design for both            Changed the tense to clearly communicate that this work improved the design      spiking stations and diked areas to prevent spills of is completed and not on-going.
for both spiking        process solution from impacting the concrete.,
stations and diked      protect The concrete is protected with a floor areas to prevent spills  coating that is impervious to acidic materials, and of process solution      guards against undetected deterioration of the from impacting the      concrete floor (WEC 2020-TN6521). In addition, concrete, protect the    the WEC described other modifications, such as concrete with a floor    replacinged tanks, installinged removable


WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 23 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 coating that is          polypropylene catch pans, replacinged couplings impervious to acidic      and piping, installinged automatic shutoff valves materials, and guard      to remove hydrofluoric system pressure, and against undetected        modifiedying the berms (WEC 2020-TN6521).
For example, over the past several years, Westinghouse has:
deterioration of the concrete floor (WEC 2020-TN6521). In addition, the WEC described other modifications, such as replacing tanks, installing removable polypropylene catch pans, replacing couplings and piping, installing automatic shutoff valves to remove hydrofluoric system pressure, and modifying the berms (WEC 2020-TN6521).
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.
2-11 4    The WEC has              The WEC has emptied all the intermodal storage  Clarification on completed work with the Southern emptied the intermodal    containers containing accountable uranium and    Storage Area Operable Unit (SSAOU). The WEC has storage containers.      uranium contaminated materials from, the southern emptied all the intermodal storage containers containing Some are sent offsite    storage area. Some were are sent offsite for    accountable uranium and uranium contaminated for                                                                      materials.
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.}}
2-11 5    recycling and           recycling and others are were reloaded and sent Clarification on completed work with the SSAOU.
others are reloaded and  offsite for disposal as low-level waste.
sent offsite for disposal as low-level waste.
2-11 18-19 The WEC is or will      The WEC is or will CFFF transported affected    Because it is included directly after the other sentences transport affected soil  soil to an approved LLRW disposal site (WEC      discussing PCE impacted soil, this sentence is to an approved LLRW      2019-TN6552).                                    inaccurate.
disposal site (WEC 2019-TN6552).                                                              Soil impacted with uranium and other constituents of concern is transported to an approved LLRW site.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 24 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 However, in the case of the soil impacted by PCE, it was NOT also impacted by uranium. Therefore, the PCE impacted soil was NOT sent to an LLRW facility but rather another approved TSDF.
2-11 19-21 The WEC anticipates                                                      CFFF emptied all the intermodal storage containers in completing the removal  The In 2021 the WEC CFFF completeding the        the southern storage area containing accountable of the remaining        removal of the remaining intermodal containers in uranium and uranium contaminated materials.
intermodal containers    the southern storage area that do not contain that do not contain      radioactive materials in 2021 (WEC 2020-radioactive materials in TN6844).
2021 (WEC 2020-TN6844).
2-12 14    N/A                                                                        Additional work was performed as part of the RIWP Phase II and completed as of August 2021.
Installed 14 new permanent groundwater monitoring wells Completed 43 lithologic soil borings (43 groundwater screening locations, 1-4 discrete intervals at each location)
Installed 3 additional staff gauges (7 total for all remedial investigation work)
Installed 17 pressure transducers o 6 at surface water locations o 10 in monitoring wells and 1 in piezometer PZ-1 Sediment sampling o 111 Total Phase II Sediment Samples o 20 new discrete locations (2-3 samples @
each location) o 15 samples from Gator Pond o 2 new sediment transects in Mill Creek (17 samples) o 16 new samples to bound areas around SED-44
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 25 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 Conducted PCE soil gas surveys (SGS) - 53 total samples o (25 samples were collected in the primary SGS area; later, 28 additional samples were collected by selecting closer sample intervals within the impacted area)
Collected soil samples from 26 locations within the former East Lagoon footprint (3-4 samples @ each location)
Collected 10 soil samples for grain size analysis Collected 28 Sanitary Lagoon sludge samples Slug tested 13 wells (aquifer hydraulic characterization)
Completed civil survey of well installations and drainage ditches.
2-12 15-25 The WEC has decided    The WEC has decided to decommissioned the          East Lagoon was decommissioned in 2021 and to decommission the    East Lagoon (NRC 2020-TN6935). Closure of the        contaminated sludge was removed per the plan.
East Lagoon (NRC        East Lagoon is planned forwas completed in 2021.
2020-TN6935).          The WECs plan to characterize the sludge in the Closure of the East    East Lagoon, was submitted in accordance with Lagoon is planned for  the CA, was and approved by SCDHEC via letter 2021. The WECs plan    dated October 2, 2019 (WEC 2019-TN6555, WEC to characterize the    2019-TN6555). The WEC submitted the results of sludge in the East      the characterization in the East Lagoon Lagoon, submitted in    Characterization Summary Report on December 6, accordance with the    2019 (WEC 2020-TN7021) and subsequently CA, was approved by    submitted a closure plan (WEC 2020-TN7020).
SCDHEC via letter      SCDHEC approved the closure plan on October dated October 2, 2019  14, 2020 (SCDHEC 2020-TN7012). The WEC (WEC 2019-TN6555,      intends to remove and removed contaminated WEC 2019-TN6555).      sludge according to the plan. Sixteen systematic The WEC submitted      sub-liner soil sampling locations were selected the results of the      according to a grid and also ten bias locations were characterization in the evaluated the East Lagoon liner, to the extent East Lagoon            practicable, to inform sampling locations.based on
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 26 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 Characterization        observed liner conditions after sludge was Summary Report on        removed. After removal of the liner, the WEC will December 6, 2019        collect and analyze sSoil samples were analyzed (WEC 2020-TN7021)        for constituents of potential concern (COPCs) and subsequently        included in the plan (WEC 2020-TN6844), and submitted a closure      remediate the soil, if needed (SCDHEC 2020-plan (WEC 2020-          TN7003; WEC 2020-TN7011). No residual TN7020). SCDHEC          elevated concentrations of either any non-approved the closure    radiological constituents of concern or radiological plan on October 14,      constituents above the Industrial Screening Level 2020 (SCDHEC 2020-      were left in place. Limited areas of soil containing TN7012). The WEC        radiological concentrations above Residential Soil intends to remove and    Screening Levels were left in place either because evaluate the East        removing them would undermine existing Lagoon liner, to the    structures or they are located below the water extent practicable, to  table. Areas of soil containing radiological inform sampling          concentrations above Residential Soil Screening locations. After        Levels will addressed at decommissioning and that removal of the liner,    information has been added to the the WEC will collect    decommissioning files.
and analyze soil samples for constituents of potential concern (COPCs) (WEC 2020-TN6844), and remediate the soil, if needed (SCDHEC 2020-TN7003; WEC 2020-TN7011).
2-13 9-15 uranium prior to      uranium prior to discharging effluents to the      The sentences are missing a citation for the source, discharging effluents to atmosphere. (WEC 2019-TN6510)                      which is the WEC 2019 Environmental Report (ER).
the atmosphere.
2-13 12  through the 47        through the 4247 exhaust stacks at the            CFFF has 42 monitored stacks. One previously exhaust stacks at the    CFFF,                                              independent stack originating from the chemical lab was CFFF,                                                                      tied into a larger, main ventilation system, reducing the
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 27 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 number of total stacks by one. Additionally, four additional sample locations (1240, 1242, 1243, and 1246) were removed from the total because these four systems are non-process related, do not exhaust to the atmosphere, and are recirculating comfort air systems.
2-14 17    The WWTP includes      The WWTP includes a system of six five            The former East Lagoon area is now green space. The a system of six        lagoonsNorth, South, West I, West II, East, and    lagoons function within the wastewater treatment lagoonsNorth,          Sanitary.                                          system was replaced with an above ground tank.
South, West I, West II, East, and Sanitary.
2-14 18-19 The East Lagoon is no  The East Lagoon is no longer in operation and the  The former East Lagoon area is now green space.
longer in operation and WEC anticipates was decommissioninged the the WEC anticipates    lagoon in the near future in 2021.
decommissioning the lagoon in the near future.
2-14 19-20 Figure 2-4 shows the  Figure 2-4 shows the location of the six five      These sentences seem to describe the operable units location of the six    remaining onsite lagoons and the former location    (OUs) of the Remedial Investigation. These OU names, onsite lagoon storage  of the East Lagoon. storage basins in the West      although helpful for the RI work, are not used in site basins in the West      Lagoons Area, Wastewater Treatment Area, and        WWT procedures or SCDHEC permitting documents to Lagoons Area,          Sanitary Lagoon Area.                              describe the treatment processes at CFFF. Including Wastewater Treatment                                                        them here could cause confusion.
Area, and Sanitary Lagoon Area.
2-14 20-24 These lagoons are for  These lagoons are for settling solids from treated Unlike the other lagoons, the Sanitary Lagoon does not settling solids from    process wastewater prior to discharging liquid      receive process wastewater. All lagoons are used to treated process        effluents to the Congaree River. Treated            settle solids from treated wastewater. The Sanitary wastewater prior to    wastewater from the West I and West II lagoons is  Lagoon aids in settling solids from the sites package discharging liquid      then sent to the North and or South Lagoons for    plant.
effluents to the        further treatment. The treated sanitary wastewater Congaree River.        is mixed with the stream from the North and or      Flow from the West I and West II lagoons is sent to Treated wastewater      South Lagoons, receives further                  either the North or South Lagoon, as these lagoons are from the West I and                                                        used alternately, not in parallel.
West II lagoons is then sent to the North and South Lagoons for
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 28 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 further treatment. The treated sanitary wastewater is mixed with the stream from the North and South Lagoons, receives further 2-14 32    portions of the        portions of the lagoon liners to identify          The inspections are to identify potential issues.
lagoon liners to          potential degradation of the liners, such as holes identify degradation of  and tears the liners, such as holes and tears 2-14 36    damage, such as        damage, such as rips, tears or punctures; ;        Suggest removing the extra punctuation.
rips, tears or punctures; spillway integrity; and changes in the discharge of
          ; spillway integrity;    all and changes in the discharge of all 2-15 12    which is then          which is then physically removed (via              The reference to centrifugation as a treatment for physically removed        centrifugation or by settling). The WEC sends the    ammonium fluoride in the sites ER was in error.
(via centrifugation or    calcium settling). The WEC sends the calcium 2-15 10-11 The main constituents    The main constituents of the process liquid waste  As written, the text does not address how uranium is of the process liquid    streams are uranium and ammonium fluoride.          removed from the sites liquid waste streams. Suggest waste streams are        Uranium is removed in the Waterglass treatment      adding wording that describes how uranium is removed uranium and              process, where the aqueous waste stream is          from process liquid waste streams.
ammonium fluoride.        contacted with sodium silicate solution. Sodium The ammonium              silicate entraps (flocculates) insoluble uranium and fluoride is mixed with    precipitates soluble uranium out of the liquid lime and caustic to      ammonia wastewater. The precipitated uranium is create an insoluble      processed through a filter plate system and calcium fluoride,      dewatered before being returned to the conversion process. The ammonium fluoride is mixed with lime and caustic to create an insoluble calcium fluoride,
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 29 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 2-15 25-26 The liquid waste      The liquid waste stream is discharged into the      To clarify the pipe location from the shoreline of the stream is discharged    Congaree River through a submerged pipe, located      Congaree River.
into the Congaree      within the riverbed about 6 m (20 ft) from the River through a        shore. The flow rate into the river is 405,000 liters submerged pipe, about  per day (L/d) 6 m (20 ft) from the shore. The flow rate into the river is 405,000 liters per day (L/d) 2-16 6-7  The process will also  The process will also included removal and          The former East Lagoon area is now green space.
include removal and    disposal of the lagoon liner and evaluation of the disposal of the lagoon  subsurface soils liner and evaluation of the subsurface soils 2-16 9-10  Additionally, the      Additionally, the WEC CFFF anticipates              The former East Lagoon area is now green space.
WEC anticipates        rerouteding the streams and replaced the lagoons rerouting the streams  current function with a storage tank, backfilling and the lagoons        backfilled the East Lagoon area with virgin current function with a materials, and seeding seeded the area for erosion storage tank,          control (WEC 2020-TN7015).
backfilling the East Lagoon area with virgin materials, and seeding the area for erosion control (WEC 2020-TN7015).
2-16 17-20 The WEC is also        The WEC CFFF is also installing installed an        Well W-100 (surficial-upper zone) was installed on Jan installing an upper and upper and lower two new groundwater wells in the      28, 2021 and well W-99 (surficial-lower zone) was lower surficial and a  surficial aquifer upper and lower zones (W-100        installed on Jan 27, 2021.
lower surficial zone    and W-99, respectively) and a lower surficial zone well west of the        well off the southwest of thecorner of the Sanitary  Prior to installation, the well names were unintentionally Sanitary Lagoon to      Lagoon. These wells will to collect groundwater      reversed in RAI correspondence sent to NRC on collect groundwater    quality data downgradient from the lagoon and        December 18, 2020. The information, which was quality data            anticipates evaluating the sediment quality          included in the response to RAI 11, identified W-99 as downgradient from the                                                        the upper zone well and W-100 as lower zone.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 30 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 lagoon and anticipates  downgradient of the lagoon near sediment sample evaluating the sediment  SED-16 (WEC 2020-TN6844).                          near sediment sample SED-16 was added for quality downgradient                                                          clarification.
of the lagoon (WEC 2020-TN6844).
2-16 31-37 Using the sampling      Using the sampling results, the WEC CFFF            CFFF has 42 monitored stacks. One previously results, the WEC        calculates the estimated dose to the public and      independent stack originating from the chemical lab was calculates the estimated worker. The WEC CFFF conducts representative        tied into a larger, main ventilation system, reducing the dose to the public and  stack sampling from 47 42 stacks to monitor          number of total stacks by one. Additionally, four worker. The WEC          gaseous effluents. Sampling and monitoring          additional sample locations (1240, 1242, 1243, and conducts representative  methods and frequencies are determined by the        1246) were removed from the total because these four stack sampling from 47  WEC CFFF per NRC guidance. The WEC also              systems are non-process related, do not exhaust to the stacks to monitor        samples its liquid effluents before they are        atmosphere, and are recirculating comfort air systems.
gaseous effluents.      discharged to the Congaree River. The NRCs Sampling and            limits for liquid and gaseous effluents are provided monitoring methods      in Table 2 of Appendix B to 10 CFR Part 20          Suggest removing the references to limits since those are and frequencies are      (TN283). For uranium, the limit is 300 pCi/L and    only for liquid effluents and this section discusses both determined by the        for Tc-99 it is 60,000 pCi/L.                        liquid and gaseous effluents. In addition, the limits are WEC. The WEC also                                                            referenced in the previous sentence.
samples its liquid effluents before they are discharged to the Congaree River. The NRCs limits for liquid and gaseous effluents are provided in Table 2 of Appendix B to 10 CFR Part 20 (TN283).
For uranium, the limit is 300 pCi/L and for Tc-99 it is 60,000 pCi/L.
Past laboratory        Past laboratory analysis had indicated that gross analysis had indicated  beta was a reasonable indicator of Tc-99; however, 2-17 8-10                                                                                Clarification.
that gross beta was a    a direct correlation between gross alpha and reasonable indicator of  uranium concentrations attributed to CFFF
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 31 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 Tc-99; however, a        operations was not as clear because of naturally direct correlation      occurring alpha emitters.
between gross alpha and uranium concentrations attributed to CFFF operations was not as clear.
Because there is known uranium in the    Because there is known naturally occurring subsurface, the WEC      uranium in the subsurface environment, the WEC 2-17 10-11                                                                          Clarification.
will be able to identify CFFF will be able to identify impacts on the impacts on the various  various mediums mediums 2-18 21    The ditch was          The ditch was identified on maps but has not    The ditch has been ground truthed as part of the 2-19 4    identified on maps but  been ground truthed at this time.              Remedial Investigation Work Plan Phase II activities.
has not been ground truthed at this time.
2-20 13    uranium and Tc-        uranium and Tc-99. This is the same            To remain consistent with the wording in other
: 99.                    monitoring the CFFF has conducted since the 2007 paragraphs of Section 2.2.2.1.2 Environmental license renewal.                                Monitoring Program.
2-21 10-11 As part of the          As part of the implementation of the Phase II  The site has installed 28 additional new groundwater implementation of the    RIWP, the WEC CFFF plans to installed 28        monitoring wells as a result of RIWP Phase II activities.
Phase II RIWP, the      additional new monitoring wells and replaced W-4 Well W-4 was replaced with W-4R when transducer WEC plans to install    with W-4R.                                      field data indicated that much of the water entering W-4 additional monitoring                                                    was surface water infiltration and not representative of wells.                                                                  groundwater.
2-21 19    WEC 2020-TN6875          N/A                                              This reference is not included in Section 6.0, References of the DEIS.
2-21 21    NPDES wells,          NPDES wells, sentinel wells, and plume area    The sites SNM-1107 license application refers to these sentinel wells, and      of impact wells:                                wells as area of impact wells.
plume wells:
2-21 22-23 Perimeter wells will    Perimeter wells will help the WEC detect a      To maintain consistency with the sites SNM-1107 help the WEC detect if  potential release before it if groundwater      license application.
groundwater              contamination is migratesing toward the site contamination is
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 32 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 migrating toward the    boundary. The perimeter wells are the outermost site boundary. The      monitoring wells at the CFFF site.
perimeter wells are the outermost monitoring wells at the CFFF site.
2-21 24    NPDES wells are        NPDES permit required wells are those identified    To maintain consistency with the sites SNM-1107 those identified in the  in the NPDES permit to detect a leaks in and          license application.
NPDES permit to          potential contaminant migration from the site detect leaks from the    WWTP.
WWTP.
2-21 25    Sentinel wells are the  Sentinel wells are the wells that detect a potential To maintain consistency with the sites SNM-1107 wells that monitor for  source or contaminant migration in an monitor for    license application.
releases from each      releases from each OU.
OU.
2-21 26-29 Plume wells are those  Plume Area of Impact wells are those that            To maintain consistency with the sites SNM-1107 that monitor for known  monitor for known groundwater contamination          license application.
groundwater              plumes.areas impacted by uranium and Tc-99. The contamination plumes. WEC CFFF will monitor, at a minimum, three The WEC will monitor,    wells per known plumefor each area impacted by at a minimum, three      uranium and Tc-99. of radioactive contamination, wells per known plume    with oOne well is located to detect monitoring the of radioactive          maximum concentration and two wells are located contamination, with      monitoring downgradient of the impacted area.
one well monitoring      These wells are expected to change as if the plume the maximum              area of impact moves.
concentration and two wells monitoring downgradient. These wells are expected to change as the plume moves.
2-21 29-30 Based on previous      Suggest starting new paragraph with the sentence      These two sentences are general statements regarding groundwater              Based on previous groundwater                      COPCs at the site and should not be attached to the area assessment activities,                                                        of impact well description, as that designation only COPCs in groundwater                                                          applies to radionuclide plumes.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 33 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 are chlorinated volatile 2-21 29-34  Based on previous      Based on previous groundwater assessment        To clarify the source (PCE used in solvent extraction) of groundwater              activities, COPCs in groundwater are chlorinated  CVOC contamination at the site and to communicate assessment activities,  volatile organic compound (CVOCs), nitrate,      that PCE is no longer used by the facility.
COPCs in groundwater    fluoride, uranium, and Tc-99 (WEC 2020-are chlorinated volatile TN6875). Tetrachloroethylene (PCE) is the COPC organic compound        that was previously used by the facility for the (CVOCs), nitrate,        solvent extraction process and the source of the fluoride, uranium, and  CVOC plumes at the site. Four types of CVOCs Tc-99 (WEC 2020-        were detected in the upper and lower zones of the TN6875). Four types of  surficial aquifer: PCE, trichloroethylene (TCE),
CVOCs were detected      cis-1,2-dichloroethene, and vinyl chloride [VC]
in the upper and lower  (WEC 2020-TN6875). TCE, cis-1,2-zones of the surficial  dichloroethene, and VC are natural aquifer: PCE,            degradation/daughter products of PCE. The site trichloroethylene        discontinued use of PCE in April of 2020.
(TCE), cis-1,2-dichloroethene, and vinyl chloride [VC]
(WEC 2020-TN6875).
2-22 Figure                          Suggest replacing Figure 2-9 with Enclosure 4. This figure was updated to included current well 2-9                                                                              installations and lithologic borings.
2-22 9-10  As a result,            As a result, groundwater monitoring requirements In the context of this paragraph, this statement is not groundwater              were added to the NPDES permit.                  true. There were no new groundwater monitoring monitoring                                                                requirements associated with the referenced SCDHEC requirements were                                                          notification. The sites most recent NPDES permit was added to the NPDES                                                        last issued in May of 2015 and is in timely renewal.
permit.                                                                  There are new groundwater monitoring requirements in the draft NPDES permit that has been noticed but not issued to the site.
2-22 13-15  The current NPDES      The current NPDES permit requires semi-annual    The site monitors semi-annually as required by the permit requires semi-    sampling, instead the WEC takes groundwater      permit.
annual sampling,        samples quarterly, typically in October, January, instead the WEC takes    April, and July.
groundwater samples
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 34 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 quarterly, typically in October, January, April, and July.
2-23 16    Under the CA, the      Under the CA, CFFF the WEC is also developing      The CSM is developed and is updated at minimum with WEC is also            developed and maintains a CSM (see Section          each groundwater sampling event.
developing a CSM (see  1.5.2.2.1 of this EIS).
Section 1.5.2.2.1 of this EIS).
2-24 1-3  The WEC has            The WEC has installed 29 new permanent            All planned well installations associated with the RIWP installed permanent    monitoring wells consistent with the                are complete.
monitoring wells        implementation of the Phase I RIWP (WEC 2019-consistent with the    TN6553), and installation of new monitoring wells  The Remedial Investigation Report will be submitted to implementation of the  continues under the implementation of the Phase II  DHEC upon completion in 2022 for subsequent review, Phase I RIWP (WEC      RIWP. 28 new permanent monitoring wells            comment, and final approval.
2019-TN6553), and      consistent with the implementation of the Phase II installation of new    RIWP.
monitoring wells continues under the implementation of the Phase II RIWP.
2-25 34-35 The NRC staff also    The NRC staff also considered as an alternative    Sentence requires rewording considered as an        approving the WECs a license renewal request alternative approving  for a shorter license renewal term, i.e., a renewal the WECs a license    term of 20 years, as an alternative.
renewal request for a shorter term . . . .
2-26 24    Whether the WEC        Whether the WEC CFFF operates                    Clarification operates 3-2 10    There is an electrical There is an electrical substation, owned by South  Dominion Energy bought SCE&G.
substation, owned by    Carolina Electric and GasDominion Energy, on South Carolina Electric and Gas, on 3-4 6    Conceptual Site      Conceptual Site Model (CSM) that will is          The CSM is an active tool used by the WEC.
Model (CSM) that will  being used by the WEC as a decision-making tool, be used by the WEC as  for
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 35 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 a decision-making tool, for 3-10 24  The Black Mingo        The Black Mingo Group includes the Rehms, and      Black Mingo group consists of younger Black Mingo Group includes the      Lang Syne, and Williamsburg formations shown        Confining Unit (Crouch Branch Confining Unit - Lang Rehms, Lang Syne,      in                                                Syne and Rhems) and the older, deeper Black Mingo and Williamsburg                                                            Aquifer (Crouch Branch Aquifer - Peedee/Steele Creek formations shown                                                            Formation) in 3-10 47  The WEC will          The WEC will continue to refine the                The field investigation portion of the RI was completed 3-11 1-2 continue to refine the  characterization of geologic heterogeneities of the in August 2021.
characterization of    subsurface at the CFFF site as it continues to geologic                complete activities in the Phase II Remedial        The Remedial Investigation Report will be submitted to heterogeneities of the  Investigation Work Plan (RIWP).                    DHEC upon completion in 2022 for subsequent review, subsurface at the CFFF                                                      comment, and final approval.
site as it continues to complete activities in the Phase II Remedial Investigation Work Plan (RIWP).
3-12 26                          CFFF completed assessments and modifications as    Include statement regarding of the prior Natural instructed by Temporary Instruction (TI) 2600/16,  Phenomena Hazards assessment and NRC inspection Inspection of Activities Associated with Nuclear    completed at CFFF in August 2016.
Regulatory Commission (NRC) Generic Letter 2015-01, Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities. NRC independently verified that CFFF was in compliance with regulatory requirements and applicable license conditions regarding the treatment of natural phenomena hazards (NPH) events as described in the Integrated Safety Analysis (ISA) (ML16225A386).
3-13 19  Biannual soil          BiaAnnual soil sampling conducted as part of the  Per the sites SNM-1107 license, soil sampling is sampling conducted as  environmental monitoring program                  conducted annually.
part of the environmental
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 36 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 monitoring program 3-13 35    The historical          The historical constituents of potential concern    Suggest using COPC throughout for consistency with constituents of concern  (COPCs) released to the soils or the subsurface are  other sections in the DEIS. COPC is also used in (COCs) released to the  nitrate;                                          documents prepared by WEC and its consultants that are soils or the subsurface                                                      submitted to SCDHEC.
are nitrate; 3-13 41    levels of COCs in      levels of COPCs in soils outside of the building Suggest using COPC throughout for consistency with soils outside of the    footprint and changes in facility operations that other sections in the DEIS. COPC is also used in building footprint and                                                        documents prepared by WEC and its consultants that are changes in facility                                                          submitted to SCDHEC.
operations that 3-13 37    [Tc-99]); volatile      [Tc-99]); volatile organic compounds (VOCs),        Consider using trichloroethylene in place of organic compounds        primarily perchloroethylene (PCE),                  trichloroethene to be consistent with use of preceding (VOCs), primarily        trichloroethylene                                  perchloroethylene and subsequent cis-1,2-perchloroethylene                                                            dichloroethlyene.
(PCE),
trichloroethene 3-15 14-15 however, the source    however, the source of the historic Tc-99          There are no current sources of Tc-99 at the levels seen of the Tc-99            contamination is unknown.                          in the groundwater. An investigation was completed in contamination is                                                              July 2020 to confirm that current operations are not the unknown.                                                                    source of the historic impact. Additionally, the Tc-99 source investigation report also concluded that current site operations do not have the potential to introduce Tc-99 levels above the MCL into the environment.
3-15 15-21 The WEC is              The CFFF WEC is completing completed a              These investigation activities are completed.
completing a shallow    shallow soil gas survey and soil sampling as part soil gas survey and soil of the remedial investigation process to evaluate sampling as part of the  the continuing presence of a VOC source in the remedial investigation  unsaturated sediments west of the main plant process to evaluate the  building and in the Western Groundwater Area of continuing presence of  Concern (AOC) (WEC 2020-TN6707). Soil a VOC source in the      samples will be were collected based on the results unsaturated sediments    of the soil gas survey from the surface to depths up west of the main plant  to 5.2 m (17 ft). As part of the Tc-99 Source building and in the      Investigation Study (completed in July 2020), two
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 37 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 Western Groundwater      soil borings were installed Soil sampling is Area of Concern          planned along the southern edges of the Sanitary (AOC) (WEC 2020-        and East Lagoons and will be were evaluated for TN6707). Soil samples    potential Tc-99 contamination (WEC 2020-will be collected based  TN6707).
on the results of the soil gas survey from the surface to depths up to 5.2 m (17 ft). Soil sampling is planned along the southern edges of the Sanitary and East Lagoons and will be evaluated for potential Tc-99 contamination (WEC 2020-TN6707).
3-17 4-5  A portion of Mill      The majority A portion of Mill Creek flow is      Based upon field observations and transducer data of Creek flow is diverted  diverted at the point where it enters the CFFF site surface water elevations within various points of Mill at the point where it    by a canal located                                Creek (including the canal), the majority of Mill Creek enters the CFFF site by                                                      flow is diverted through the canal.
a canal located 3-17 16-17 The irrigation ditch    The irrigation ditch rejoins Mill Creek near the  To clarify that the irrigation ditch was not constructed by rejoins Mill Creek near  point where the creek crosses the CFFF property    WEC/CFFF.
the point where the      line. These features existed prior to the creek crosses the CFFF  construction of the CFFF.
property line.
3-19 7    operations comes      operations comes from the City of Columbia,      Local and regional nomenclature for the water body is from the City of        which obtains water from Lake Murray Lake on        Lake Murray, not Murray Lake.
Columbia, which          the obtains water from Murray Lake on the 3-22 14    indicated levels of    indicated levels of gross beta, fluoride, and    Surface water samples are not within the scope of EPAs gross beta, fluoride,    nitrate above or at the respective MCLs.          drinking water standard and, as a result, no MCLs exist and nitrate above or at                                                      for these environmental sample types. In the absence of the respective MCLs.                                                        a regulatory standard, Westinghouse has instituted
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 38 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 internal investigation levels for gross alpha in surface water of 50 pCi/L and gross beta of 300 pCi/L. These investigation levels are delineated in CFFF procedure RA-434, Environmental Data Management.
The result for the Gator Pond was 44.2 pCi/L, which is not above the sites investigation level of 50 pCi/L that prompts subsequent speciation for Tc-99.
3-22 25    location on Mill      location on Mill Creek. During the period from Surface water and river water samples are not within the Creek. During the        2010 to 2018, gross beta exceeded the site      scope of EPAs drinking water standard and, as a result, period from 2010 to      investigation level 50 pCi/L in                no MCLs exist for these environmental sample types. In 2018, gross beta                                                          the absence of a regulatory standard, Westinghouse has exceeded 50 pCi/L                                                        instituted internal investigation levels for gross alpha in in                                                                      surface water (50 pCi/L) and river water (15 pCi/L).
3-22 40    Uranium was detected    Uranium was detected in all but one sample and  Surface water and river water samples are not within the in all but one sample    had a maximum Total U concentration of 1.78      scope of EPAs drinking water standard and, as a result, and had a maximum        µg/L less than 4 percent of the 30 g/L MCL. no MCLs exist for these environmental sample types. In concentration of less                                                    the absence of a regulatory standard, Westinghouse has than 4 percent of the 30                                                  instituted internal investigation levels for gross alpha in g/L MCL.                                                                surface water (50 pCi/L) and river water (15 pCi/L).
3-22 16-18 Fluoride was above      Fluoride was above the 4 mg/L MCL in the        Clarification.
the 4 mg/L MCL in the    Upper and Lower Sunset Lakes samples, the Gator Upper and Lower          Pond, and in drainage ditch samples collected Sunset Lakes samples    between the C control valve location and Upper and in drainage ditch    Sunset Lake.
samples collected between the C control valve location and Upper Sunset Lake.
3-22 37-39 MCLs were exceeded      MCLs were exceeded for fluoride in the Gator    According to September 2019 data, trichloroethylene for fluoride in the      Pond sample and for TCE tetrachloroethylene at  (TCE) was only detected in one location, and no Gator Pond sample and    two ditch locations below the drainage ditch    locations exceeded MCL. However, tetrachloroethylene for TCE at two ditch    connection (C valve) location.                (PCE) did exceed MCL in two ditch locations.
locations below the drainage ditch
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 39 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 connection (C valve) location.
3-24 18-19 workers. Excluding    workers. Excluding the lagoon samples, the      WEC has conducted multiple sediment sampling the lagoon samples, the  largest activity observed during RI Phase I        campaigns throughout the current RI and the 2013 RI.
largest activity        sampling was 117 pCi/g (for U- 233/234) in a      Including this information clearly identifies the data set observed was 117        sample from Lower Sunset Lake (location SED-      being referenced in the DEIS.
pCi/g (for U- 233/234)  22).
in a sample from Lower Sunset Lake.
3-24 28    Chlorinated VOCs        Chlorinated VOCs were not detected in sediments Per source WEC 2020 TN6526, one detection of PCE were not detected in    with the exception of a single ditch sample that  was reported in Sed-17 (5.5 g/kg). There were no sediments with the      contained TCE PCE (a duplicate sample from the    detections of TCE.
exception of a single    same location was below the detection level).
ditch sample that contained TCE (a duplicate sample from the same location was below the detection level).
3-24 31-32 Nitrate was detected    Nitrate was detected in about one-half of the    This is incorrect. Only 2 locations from July 2019 in about one-half of the sediment samples collected in July 2019. The only  sediment sampling exceeded 2 mg/kg for nitrate and samples at values        two results at values exceeding 2 mg/kg were in    they were SED-16 and SED-17. (Source: WEC 2020 exceeding 2 mg/kg in    lower ditch locations SED-16 (2.7 mg/kg) and      TN6526) lower ditch locations. SED-17 (2.1 mg/kg).
3-24 33    " Ammonia exceeded      " According to July 2019 sampling data,            This is incorrect. Based on July 2019 data (Source:
1,000 mg/kg in the      Aammonia exceeded 1,000 mg/kg in the lagoons      WEC 2020 TN6526) only one result in Upper Sunset lagoons and in some      and in some Upper Sunset Lake locations. one      Lake (SED-20) exceeded 1,000 mg/kg.
Upper Sunset Lake        sample from the Sanitary Lagoon (SED-25), one locations.              sample from the East Lagoon (SED-28), and one sample from Upper Sunset Lake (SED-20).
3-25 1-5  Surface water          Surface water withdrawals and Consumptive use    CFFF does not directly withdraw surface water. CFFF withdrawals and          of water for by CFFF operations would directly    receives water from the City of Columbia. Suggest consumptive use of      reduces the quantity of water available for other  rewording for clarification.
water for CFFF          uses and users of the same resource. Degradation operations directly      of water quality by the intentional or inadvertent reduces the quantity of  release of contaminants to surface water bodies
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 40 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 water available for      could potentially renders the water resource other uses and users of  unsuitable for other users and designated uses.
the same resource.
Degradation of water quality by the intentional or inadvertent release of contaminants to surface water bodies potentially renders the water resource unsuitable for other users and designated uses.
3-25 22    discharge of plant      discharge of treated plant effluents to the    To reaffirm that effluent discharges to the Congaree effluents to the        Congaree River and through the transport of      River have been treated by the WEC on-site wastewater Congaree River and      inadvertently                                  treatment plant.
through the transport of inadvertently 3-25 26    from the continued    from the continued discharge of treated liquid To reaffirm that effluent discharges to the Congaree discharge of liquid      effluents directly into the river. The WEC      River have been treated by the WEC on-site wastewater effluents directly into  discharges its                                treatment plant.
the river. The WEC discharges its 3-26 30-34 Sampling conducted      Sampling conducted as part of the remediation  Suggest deleting. No storm water runoff was sampled as as part of the          investigation activities under the CA has shown  part of the RIWP. The one mention of storm water remediation              VOC contamination in site runoff; fluoride      runoff in reference WEC 2020-TN6526 (Appendix B) is investigation activities contamination in site runoff, Gator Pond, and    in relation to a sediment sample location, SED-19.
under the CA has        Sunset Lake; and nitrate contamination in site shown VOC                runoff and Gator Pond (AECOM 2013-TN5508;        The site does sample stormwater runoff at the C valve contamination in site    WEC 2020-TN6526).                              location for ISO-U and Tc-99 quarterly, per procedure runoff; fluoride                                                          ROP-06-010.
contamination in site runoff, Gator Pond, and Sunset Lake; and nitrate contamination
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 41 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 in site runoff and Gator Pond (AECOM 2013-TN5508; WEC 2020-TN6526).
3-26 34-36 Recent sediment          Relocation to 3.3.1.3                                Because these sentences discuss sediment sampling provides        N/A                                                  contamination, CFFF suggests moving this content from additional evidence                                                            section 3.3.2.2, Onsite Surface Water to section 3.3.1.3, that the CFFF                                                                  Sediment.
operations have contributed Tc-99 contamination in Gator Pond and potentially uranium contamination in Sunset Lake (WEC 2020-TN6526).
3-26 40-43 Results from this        Results from this monitoring show minor            Suggest deleting extra words in the sentence.
monitoring show minor    differences in activities at the entrance and exit differences in activities locations for both gross alpha and gross beta at the entrance and exit  (WEC 2019-TN6423), indicating that radionuclide locations for both gross  releases from CFFF operations have a minor effect alpha and gross beta      on water quality in Mill Creek and are unlikely to (WEC 2019-TN6423),        move beyond the CFFF site boundary at indicating that          noticeable.
radionuclide releases from CFFF operations have a minor effect on water quality in Mill Creek and are unlikely to move beyond the CFFF site boundary at noticeable.
3-27 25-27 The NRC staff also      The NRC staff also assume that monitoring of        To clarify the future commitment in the license renewal assume that monitoring    surface water quality and sediment locations,        application to collect sediment annually at one location of surface water          including the new location identified in the license in Lower Sunset Lake.
quality, including Mill  application as Lower Sunset Lake Mill Creek Creek water quality
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 42 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 sediment                water quality sediment contamination would contamination would      continue as part of NRC license requirements.
continue as part of NRC license requirements.
3-28 9-10  However, uranium        However, uranium contamination in sediment of      Report section is entitled Surface Water Impacts and contamination in the    the upper and lower portions of Sunset Lake        this sentence addresses contamination related to upper and lower          currently exceeds the residential use screening    sediment, not surface water.
portions of Sunset      levels (based on 2019 and 2021 sampling).
Lake currently exceeds                                                      There is an extra space between the words of and the residential use                                                          Sunset.
screening levels (based on 2019 sampling).
3-28 19-21 Contaminated            Contaminated sediments could are unlikely to be    Same comment as made in the substantive section on sediments could be      transported offsite during significant flooding    page 3-26, line 46 and 3-27, line 1-7.
transported offsite      events however, a but the large volume of water during significant      involved in such an event is would be expected to flooding events, but the result in reduced contaminant concentrations when large volume of water    these if the sediments are were redeposited.
involved in such an event is expected to result in reduced contaminant concentrations when these sediments are redeposited.
3-30 9-10  The Tertiary-age        The Tertiary-age Gordon Crouch Branch              On page 3-10, lines 38-46, the geologic correlations are Gordon aquifer          aAquifer (correlated to the Black Mingo aquifer) is correct.
(correlated to the Black reported Mingo aquifer) is                                                            On page 3-30, lines 9-10, the text incorrectly correlates reported                                                                  Black Mingo Aquifer to early Tertiary aged Gordon Aquifer. The correlation should state Crouch Branch Aquifer.
The elevation of the                                                        The amount of variation that happens under the building The elevation of the shallow groundwater table 3-30 40-42 groundwater table                                                            footprints on site does not cause sufficient change in the surface onsite generally is a subdued replica generally is a subdued                                                      rate or direction of flow to deem it relevant.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 43 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 replica of the        reflection of the topographicy surface, except for topography, except for locations below the plant buildings and facilities.
locations below the plant buildings and facilities.
3-33 5    3.4.1 Groundwater Use  N/A                                                  Please note that the most recent groundwater data and Quality                                                                (through April 2021) was submitted in an annual report to SCDHEC on September 28, 2021. The report is available to the public by accessing the DHEC website.
3-33 23-24 the private water    the private water supply wells to the north of the  Groundwater does not flow upgradient off the WEC site supply wells to the    site are upgradient so that groundwater would not    property. This statement is supported by potentiometric north of the site are  normally flow from the site to these water          maps generated from the sites extensive groundwater upgradient so that    supply                                            monitoring network.
groundwater would not normally flow from the site to these water supply 3-35 35-38 The East Lagoon,      The former East Lagoon, which receiveds various    The former East Lagoon area is now green space, and its which receives various waste streams (including radioactive elements) and  closure has been approved by SCDHEC.
waste streams          had has been in service for almost 51 years. The (including radioactive East Lagoon was decommissioned in 2021, elements) has been in  including contaminated soil beneath the lagoons service for almost    liner. and is currently being closed and cleaned years and is currently (WEC 2020-TN6844). The lagoons function being closed and      within the wastewater treatment system was cleaned (WEC 2020-    replaced with an above-ground tank. Sludge in TN6844). Sludge in the from within the former East lagoon containsed East lagoon contains  elevated levels of fluoride and ammonia; elevated levels of fluoride and ammonia; 3-36 8    Figure 3-14 PCE        Include data for W-26                                Since 2004, CFFF has consistently monitoring VOCs in Concentrations in the                                                      four site wells (W-26, W-41R, W-48, and W-RW2) as Surficial Aquifer      Change the label in the figure from W-41 to W-      required by the sites NPDES permit issued by 41R.                                                SCDHEC. Figure 3-14 excludes data for W-26.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 44 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 The correct well designation is W-41R.
3-36 7    Beginning in late      Beginning in late 2018, the WEC CFFF also            Prior to 2018, CFFF was monitoring VOCs in four site 12    2018, the WEC also      started monitoring VOCs at the sites other          wells (W-26, W-41R, W-48, and W-RW2) as required started monitoring      existing wells (WEC 2019-TN6510).                    by the sites NPDES permit issued by SCDHEC.
VOCs at the sites                                                            Beginning in late 2018, the site began voluntarily existing wells (WEC                                                          sampling the remaining site wells to re-baseline VOC 2019-TN6510).                                                                data at the facility.
The WEC installed additional shallow and  The WEC CFFF installed additional shallow and This request is for consistency of terminology. AECOM intermediate-depth      intermediate-depth wells in the upper and lower 3-36 14-15                                                                              documents refer to the upper and lower zones of the wells as part of the    zones of the surficial aquifer as part of the Phase I surficial aquifer.
Phase I remedial        remedial investigation process.
investigation process.
3-37 23-24 highest nitrate      highest nitrate concentrations were often          The correct well designation is W-18R.
concentrations were    higher than 150 mg/L at wells W-18R, W-30, W-        The correct well designation is W-7A.
often higher than 150  32, W-23 29, and W-7A between 2004 and 2019 mg/L at wells W-18,    (AECOM 2013-TN5508; W-30, W-32, W-23 29, and W-7 between 2004 and 2019 (AECOM 2013-TN5508; 3-37 28-30 Nitrate concentrations Nitrate concentrations in well water from these      The reference for this data is the WEC 2020 -TN6526.
in well water from      two wells have decreased significantly from the      Table 3 of this document contains data from October these two wells have    peak values; recent values have been below the        2019 and reports nitrate for W-29 and W-30 as 11 mg/L decreased significantly MCL (WEC 2020-TN6526).                              and 120 mg/L, respectively. These reported values are from the peak values;                                                        above the drinking water MCL for nitrate, not below.
recent values have been below the MCL (WEC 2020-TN6526).
3-37 31    18 and W-7 have      18R and W-7A have been trending up; recent          The correct well designations are W-18R and W-7.
been trending up;      observed October 2019 values have been were 770      Define recent as October 2019.
recent observed values  mg/L and 390 mg/L, have been 770 mg/L and 390 mg/L, 3-37 34-35 2011 at wells W-39    2011 at wells W-39 and W-41R located west of The correct well designation is W-41R.
and W-41 located west  the lagoons (AECOM 2013-TN5508); recent              Define recent as October 2019.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 45 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 of the lagoons          October 2019 values have been were 73 and 65 (AECOM 2013-            mg/L, respectively (WEC 2020-TN6526).
TN5508); recent values have been 73 and 65 mg/L, respectively (WEC 2020-TN6526).
3-38 1    Recent well water      Recent October 2019 well water sampling from    Define recent as October 2019.
from the nine new      the nine new wells wells 3-38 3-4  concentrations were  concentrations were mostly below the MCL      W-59 concentration was 9.7 in October 2019, which is mostly below the MCL    except at wells W-58 and W-59 (WEC 2020-        less than MCL of 10 mg/L.
except at wells W-58    TN6875).
and W-59 (WEC 2020-TN6875).
3-38 8-9  During the response    During the response to the 2018 HFSS leak, the  No samples were taken around the facility. All samples to the 2018 HFSS leak,  WEC obtained fluoride concentrations up to 1,180 were collected underneath the concrete floor of the the WEC obtained        mg/kg from soil samples around and beneath the  manufacturing footprint.
fluoride concentrations facility.
up to 1,180 mg/kg from soil samples around and beneath the facility.
3-38 21    the highest          the highest concentration was 900 mg/L (at W-  The correct well designation is W-7A.
concentration was 900  7A) in 1981 mg/L (at W-7) in 1981 3-38 25-26 the maximum          the maximum concentration was reported to be  The correct well designation is W-18R.
concentration was      126 mg/L in W-18R (WEC 2020-TN6526).            The correct well designation is W-7A.
reported to be 126      Ammonia concentrations in wells W-32, W-22, mg/L in W-18 (WEC      and W-7A south of the WWTP appear to be 2020-TN6526).
Ammonia concentrations in wells W-32, W-22, and W-7 south of the WWTP appear to be
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 46 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 3-38 41    In the early 1980s,    In the early 1980s, five lagoons (West I, West II, The proper designation for the lagoon is West I.
five lagoons (West,      East, North, and West II, East, North, and 3-39 5    results exceeding      results exceeding the Residential Use            The screening level should be specified.
the screening levels for sScreening lLevels (RUSLs) for uranium, uranium, confirming      confirming the presence of uranium in the the presence of uranium in the 3-39 8-11  the WEC intends to    the WEC intends to complete closure of            The former East Lagoon area is now green space, and its complete closure of the  decommissioned the East Lagoon in 2021,            closure has been approved by SCDHEC.
East Lagoon in 2021,    including removing the East Lagoon and its liner including removing the  and remediating the soil, if needed (WEC 2019-      Sludge Sampling within the Sanitary Lagoon was East Lagoon and its      TN6555, WEC 2020-TN6707). The WEC intends          completed in June 2021. The sampling results were liner and remediating    to completed a sampling of Sanitary Lagoon          submitted with the August 2021 CA Monthly Progress the soil, if needed      sludge., The WEC intends to remove the sludge      Report.
(WEC 2019-TN6555,        from the Sanitary Lagoon, and close the lagoon WEC 2020-TN6707).        (WEC 2020-TN6707).
The WEC intends to complete sampling of Sanitary Lagoon sludge, remove the sludge from the lagoon, and close the lagoon (WEC 2020-TN6707).
3-39 21-23 Gross alpha and gross  Gross alpha and gross beta activities were both    Suggest comparing the U results from W-77 to the beta activities were    above screening levels in gGroundwater samples      drinking water MCL versus using the surrogates gross both above screening    recently obtained from a well (Well-77) in October  alpha and gross beta. The references to screening levels in groundwater    2019, which is downgradient from the HFSS          levels and recently obtained are also unclear.
samples recently        release exceeded the MCL for U of 30 µg /L obtained from a well    (WEC 2020-TN6526). Monitoring wells side (W-77) downgradient      gradient and downgradient of W-77 do not contain from the HFSS release    U above the MCL indicating the limited extent of (WEC 2020-TN6526).      U in groundwater.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 47 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 leak on one of the intermodal sea-land) leak on one of the intermodal sea-land) containers south of the                                                      The drums contain valuable material destined for containers south of the WWTP which storeds 3-39 24-25 WWTP which stores                                                            recycle/reclamation via incineration. The drums are not waste drums containing uranium-bearing waste drums containing                                                      waste material.
materials.
uranium-bearing materials.
The WECs inspection noted that the waste drums were    The WECs inspection noted that the waste          The drums contain valuable material destined for 3-39 25-26 degraded, and            drums were degraded, and contaminants may have      recycle/reclamation via incineration. The drums are not contaminants may have    leaked to soils under the container.              waste material.
leaked to soils under the container.
3-39 28-32 As described in        As described in Section 2.1.3.1, the WEC has      Clarification on completed work with the SSAOU.
Section 2.1.3.1, the    removed 62 intermodal containers as of November WEC has removed 62      2020 (WEC 2020-TN6844), and has removed intermodal containers    contaminated soil in accordance with its site as of November 2020      remediation procedure. The WEC has emptied all (WEC 2020-TN6844),      the intermodal storage containers in the southern and has removed          storage area containing accountable uranium and contaminated soil in    uranium contaminated materials. No groundwater accordance with its site contamination has been attributed to releases from remediation procedure. the Southern Storage Area Operable Unit.
No groundwater contamination has been attributed to releases from the Southern Storage Area Operable Unit.
3-39 34-37 Groundwater well        Groundwater well sampling results from the        Per CFFF procedure RA-434, Environmental Data sampling results from    WECs ongoing environmental monitoring              Management, the 15 pCi/L is an internal investigation the WECs ongoing        program show gross alpha activities have exceeded  level that if exceeded, prompts additional actions. The environmental            the 15 pCi/L screening internal investigation level value is not a screening level. Using correct monitoring program      in a number of wells around the WWTP lagoons        terminology is recommended to avoid confusion.
show gross alpha        since 2004 (AECOM 2013-TN5508; NRC 2018-
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 48 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 activities have        TN6549; WEC 2016-TN5723, WEC 2018-exceeded the 15 pCi/L  TN5722). Exceeding the WEC internal screening level in a    investigation level for gross alpha in groundwater number of wells        prompts isotopic speciation of U per CFFF around the WWTP        procedures.
lagoons since 2004 (AECOM 2013-TN5508; NRC 2018-TN6549; WEC 2016-TN5723, WEC 2018-TN5722).
3-39 41-46 Of those samples for  Of those samples for which the WEC CFFF            The correct well designation is W-18R.
which the WEC          completed isotopic analysis, the results showed completed isotopic      uranium below the MCL. In 2007, Oonly one well,    For samples where isotopic analysis was performed, the analysis, the results  W-18R with a uranium activity of 101 pCi/L, was    MCL should be the standard of comparison. There is no showed uranium below    above the activity-based limit of the WEC-derived  need to reference the activity-based limit obtained by the MCL/derived limit. criterion of 84 pCi/L (equivalent to drinking water mathematically converting the EPA drinking water MCL Only one well, W-18    MCL of 30 µg/L) in 2007, and it had a relatively    (30µg/L) to activity by using the CFFF specific activity.
with a uranium activity high gross alpha activity of 115 pCi/L (WEC of 101 pCi/L, was      2019-TN6546). Gross alpha activities in wells above the WEC-          located in the lagoon area and those located away derived criterion of 84 from plant buildings have not exceeded 60 pCi/L pCi/L in 2007, and it  since 2010.
had a relatively high gross alpha activity of 115 pCi/L (WEC 2019-TN6546). Gross alpha activities in wells located in the lagoon area and those located away from plant buildings have not exceeded 60 pCi/L since 2010.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 49 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 from beneath the from a subsurface process pipe beneath the Uranium Recycling 3-40 7-8                            Uranium Recycling and Recovery Services area        The sample was collected from a breached process pipe.
and Recovery Services had a total area had a total 3-40 20-22 Isotopic uranium        Isotopic uranium activities were above the        To provide the most current data on wells impacted by activities were above    derived level (84 pCi/L) and total uranium          U.
the derived level (84    concentration was above the 30 g/L MCL in three pCi/L) and total        of the wells (W-55, W-56, and W-59) during 2018. Source: 2020/2021 Westinghouse Annual Groundwater uranium concentration    However, W-59 did not exceed the derived level      Report was above the 30 g/L    or MCL values in January 2019 (WEC 2019-MCL in three of the      TN6876). W-59 remained below the MCL for wells (W-55, W-56,      total U in both the October 2019 and April 2020 and W-59) during 2018    sampling events. W-77, which was installed in (WEC 2019-TN6876).      Sept 2019 and sampled for the first time in October of 2019 exceeded the MCL for Total U with a result of 247 µg/L.
3-40 24-26 Well W-45, located at  Well W-45, located at the north end of the line of W-45 has been part of the sites routine monitoring the north end of the    wells along the west side of the building has had  program since 2018.
line of wells along the  not been routinely sampled, west side of the building has not been routinely sampled, 3-40 42-45 Residual Tc-99          Initially, CFFF evaluated potential sources and    Suggest reorganizing content to be in chronological 3-42 1-3  present in the enriched  mechanisms for Tc-99 releases to the environment    order.
uranium received for    and determined that a liquid release from the processing at the CFFF  cylinder recertification building was the most      The Tc-99 source investigation report concluded that has been postulated to  likely source of the Tc-99 releases (WEC 2019-      current site operations do not have the potential to be the source of the Tc- TN6510). The CSM identifies three mechanisms        introduce Tc-99 levels above the MCL into the 99 on the site (WEC      for releases from the recertification building as  environment.
2020-TN6538). The        potential sources for Tc-99 groundwater WEC evaluated            contamination (WEC 2020-TN6707). In 2020, potential sources and    CFFF completed a source investigation report for mechanisms for Tc-99    Tc-99. Residual Tc-99 present in the enriched releases to the          uranium received for processing at the CFFF has environment and          been postulated to be the source of the Tc-99 on determined that a        the site (WEC 2020-TN6538). The WEC
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 50 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 liquid release from the  evaluated potential sources and mechanisms for cylinder recertification Tc-99 releases to the environment and determined building was the most    that a liquid release from the cylinder likely source of the Tc- recertification building was the most likely source 99 releases (WEC        of the Tc-99 releases (WEC 2019-TN6510). The 2019-TN6510). The        CSM identifies three mechanisms for releases CSM identifies three    from the recertification building as potential mechanisms for          sources for Tc-99 groundwater contamination releases from the        (WEC 2020-TN6707).
recertification building as potential sources for Tc-99 groundwater contamination (WEC 2020-TN6707).
3-42 25-26 The WEC continues      The WEC continues to assess the source of the Tc-  Suggest deleting this sentence. The source investigation to assess the source of  99 contamination (WEC 2020-25 TN6707).              for Tc-99 is complete.
the Tc-99 contamination (WEC 2020-25 TN6707).
3-43 15    source of              source of contamination as long as it the        The greatest risks to the environment are process vessels contamination as long    lagoons remains in operation.                      and piping located within the subsurface. The majority as it remains in                                                            of the WWTP is above ground, with the exception of the operation.                                                                  lagoons themselves. For those appurtenances that are in the subsurface, CFFF has an underground piping inspection program to mitigate risk.
3-43 26-28 removal of            removal of potential contaminant sources (e.g.,  Suggest adding other significant source reduction potential contaminant    the former oil house, and southern storage area    activities.
sources (e.g., the      containers, legacy equipment on the roof, former oil house and    elimination of the nickel plating operations, and southern storage area    elimination of PCE use in the SOLX process), and containers), and        improved procedures (e.g., for materials handling, improved procedures      spill prevention, and inspection).
(e.g., for materials handling, spill prevention, and inspection).
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 51 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 3-43 38-40 Furthermore, the NRC  Furthermore, the NRC staff expects that any          Suggest adding the sentence to indicate the extensive staff expects that any  future releases may result in groundwater            nature of the sites 118 groundwater monitoring wells future releases may    contamination that exceeds MCLs, as has              and the new procedures for responding to low-level result in groundwater  happened on multiple occasions in the past.          events and events requiring remediation contamination that      However, an extensive groundwater monitoring exceeds MCLs, as has    network exists and is sampled semiannually to happened on multiple    identify any such releases so that additional occasions in the past. investigative measures can be implemented according to CFFF procedures RA-434, Environmental Data Management and RA-433, Environmental Remediation.
3-47 2-3  Figure 3-17 Gross      Figure 3-17 Gross Beta (open circles) and Tc-99      The text label underneath the figure references W-6 in Beta (open circles) and (filled circles) Activity at the Well Pair W-32 (red) error. W-11 is paired with W-32, as is properly depicted Tc-99 (filled circles)  and W-6 11 (blue) (Source: WEC 2020-TN6875).        on the actual figure.
Activity at the Well Pair W-32 (red) and W-6 (blue) (Source:
WEC 2020-TN6875).
3-48 8    As described in                                                              Suggest replacing the 0 with the proper section of Section 0 of this EIS,                                                        reference.
the majority of groundwater supply wells 3-49 36    obtained              obtained semiannually from 59up to 118 wells        The sites groundwater monitoring network has semiannually from 59    to monitor known contamination,)                    increased to 118 wells.
wells to monitor known contamination,)
3-49 44    Investigation        Investigation Report or within 5 years of the      Missing space between 5 and years.
Report or within 5years license renewal,...
of the license renewal,..
3-51 17    releases on future    releases on future decommissioning activities.      To clarify that the future commitment in the license decommissioning        The WEC has also agreed to two three new              renewal application will be for three new license activities. The WEC    license                                            conditions.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 52 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 has also agreed to two new license 3-52 9-10  The NRC staff          The NRC staff identified no existing survey data There is aquatic survey data available from the 1977 identified no existing  about these aquatic features during its review    NRC Environmental Impact Appraisal. Suggest survey data about these Aquatic Resources were evaluated as described in  replacing sentence.
aquatic features during the NRC 1977 Environmental Impact Appraisal.
its review.
3-52 5-6  Sunset Lake was        Sunset Lake was created by a man-made            For clarification that Sunset Lake was not constructed created by a man-made  impoundment of Mill Creek prior to CFFF          for the CFFF.
impoundment of Mill    construction.
Creek.
3-52 25    National Parks        National Parks Service (NPS 2020-TN6543).      NPS is an acronym for National Park Service.
Service (NPS 2020-TN6543).
3-53 3-4  which is              which is administered by the National Parks    NPS is an acronym for National Park Service.
administered by the    Service.
National Parks Service.
3-54 3    This includes the      This includes the treated effluent from fuel    Fuel processing, although not inaccurate could be treated effluent from  processing manufacturing operations and for      misinterpreted by some readers.
fuel processing and for sanitary purposes sanitary purposes 3-54 28-29 and habitats would    and habitats would be limited given that the    CFFF does not withdraw surface water.
be limited given that  WEC would does not directly obtain water from the WEC would not      surface water bodies.
directly obtain water from surface water bodies.
3-54 32    CFFF is not likely to  CFFF is not likely to adversely affect listed    Suggested correction for subject-verb agreement.
adversely affect listed sturgeons species because sturgeons species because A third potential Suggest removing all references to MCLs for surface aquatic concern is that 3-55 3-13                                                                            water.
Tc-99, uranium, and TCE were detected in
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 53 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 surface water samples                                      Surface water samples are not within the scope of EPAs taken at the CFFF site                                      drinking water standard and, as a result, no MCLs exist in 2019 (WEC 2020-                                          for these environmental sample types. In the absence of TN6526). However,                                          a regulatory standard, Westinghouse has instituted contamination levels                                        internal investigation levels for gross alpha in surface were below MCL                                              water of 50 pCi/L and gross beta of 300 pCi/L. These levels in Sunset Lake                                      investigation levels are delineated in CFFF procedure and will continue to be                                    RA-434, Environmental Data Management.
addressed via the CA with the SCDHEC.                                            https://www.epa.gov/dwreginfo/radionuclides-rule Regarding uranium, all samples from Sunset Lake were less than 7%
of the MCL (i.e., <2 ug/L of the 30 ug/L MCL [Table 4 in WEC 2020-TN6526]).
Similarly, all Tc-99 samples were also less than 7% of the MCL (i.e., <50 pci/L of the 900 pci/L MCL) in Sunset Lake and there is a low potential for contaminants to move offsite (see Section 3.4 of this EIS). Regarding TCE, high levels were found in the drainage ditch between the CFFF buildings and Sunset Lake (i.e., 14 and 16 ug/L compared to the 5 ug/L MCL);
however, TCE volatizes rapidly in
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 54 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 surface water (ATSDR 2019-TN6948) and that may explain why all of the samples taken in Sunset Lake were
          <21% of the MCL 5 ug/L (WEC 2020-TN6526).
3-55 20    in August 2019        in August 2019 of 27                            Missing space between of and 27.
of27 3-55 21-22 around the            around the discharge pipe into the Congaree      For clarification.
discharge pipe and      River and concluded that both uranium concluded that both uranium 3-55 31    The NRCs radiation    The NRC's radiation protection                  In this use, NRC is showing possession and should have protection                                                                an apostrophe.
3-62 23-25                                                                            Suggest removing all references to MCLs for surface water.
(2) onsite contaminations of Surface water samples are not within the scope of EPAs Sunset Lake (i.e.,
drinking water standard and, as a result, no MCLs exist uranium, Tc-99, TCE) for these environmental sample types. In the absence of during the 2019 site a regulatory standard, Westinghouse has instituted investigation have been internal investigation levels for gross alpha in surface below the MCLs water of 50 pCi/L and gross beta of 300 pCi/L. These
(<7%) and continue to investigation levels are delineated in CFFF procedure be addressed via the RA-434, Environmental Data Management.
CA with the SCDHEC; and" https://www.epa.gov/dwreginfo/radionuclides-rule 3-70 7    calciners, and six    calciners, and six five process scrubbers      There are only five process scrubbers (S-1008, S-1030, process scrubbers                                                        S-1190, S-958, and 2A/2B) since the plating operation was discontinued in February 2020.
3-70 13-14 The program includes  The program includes 4247 stacks as well as 4      WEC has 42 monitored stacks. One previously 47 stacks as well as 4  onsite locations ambient environmental air stations independent stack originating from the chemical lab was onsite locations                                                            tied into a larger, main ventilation system, reducing the
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 55 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 monitored for the      monitored for the presence of radioactive        number of total stacks by one. Additionally, four presence of radioactive material.                                        additional sample locations (1240, 1242, 1243, and material.                                                                1246) were removed from the total because these four systems are non-process related, do not exhaust to the atmosphere, and are recirculating comfort air systems.
The air sampling stations identified in the site SNM-1107 license are called Ambient Environmental Air Monitoring Stations per WEC procedure ROP-06-003.
3-70 25    and the WEC..        and the WEC CFFF                                Clarification.
3-71 17    The WEC monitors      The WEC monitors radiological gaseous            WEC has 42 monitored stacks. One previously radiological gaseous    emissions from 4247 stacks.                      independent stack originating from the chemical lab was emissions from 47                                                        tied into a larger, main ventilation system, reducing the stacks.                                                                  number of total stacks by one. Additionally, four additional sample locations (1240, 1242, 1243, and 1246) were removed from the total because these four systems are non-process related, do not exhaust to the atmosphere, and are recirculating comfort air systems.
3-72 32-33 However, the East      However, the East Lagoon was decommissioned      The former East Lagoon area is now green space, and its Lagoon and Sanitary    and the Sanitary Lagoon are being will be removed closure has been approved by SCDHEC.
Lagoon are being        under the CA, which would necessitate the use removed under the CA, which would necessitate the use 3-73 1    sensitive receptors  sensitive receptors (e.g., schools, hospitals,  Extra word.
(e.g., schools,        etc.) in nearby.
hospitals, etc.) in nearby.
3-73 18    Historic and Cultural  Westinghouse has contracted with a Brockington    Fieldwork and GPR for the site-wide cultural resources Resources              Cultural Resources Consulting to complete a      survey was completed in September 2021. Additional cultural resource survey at Columbia Fuel        GPR assessment of the Denley cemetery utilizing the Fabrication Facility (CFFF) in Richland County,  latest technology was also completed to update the South Carolina. The South Carolina State Historic previous GPR work performed in 2007.
Preservation Office (SHPO) has reviewed and approved the survey plan. The contractor completed the survey of the CFFF property in
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 56 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 September 2021, including additional GPR assessment of the Denley Cemetery. Submittal of the Draft Survey Report to the SHPO is expected by December 31, 2021.
The final report will include details presenting the setting of the CFFF, the results of the background research and field survey, descriptions of individual resources with recommendations concerning their eligibility for the Nation Register of Historic Places (NRHP), an assessment of the potential for the undertaking to affect any NRHP-eligible cultural resources with recommendations for actions to prevent or limit any adverse effects to these resources. A draft report will be provided to NRC and SHPO for their review and comment.
Once the final report is accepted any recovered artifacts from the field investigation will be forwarded to the University of South Carolina Institute of Archaeology and Anthropology (SCIAA) for permanent curation.
3-74 4      South Carolina        South Carolina Electric and Gas Dominion          Dominion Energy bought SCE&G.
Electric and Gas, on    Energy, on approximately 2.8 ha approximately 2.8 ha 3-75 Figure                                                                              Suggest adding an orange shaded box to the figure 3-20                                                                                legend that would represent the Area of Potential Effect.
3-76 44    While not listed in    While not listed in ArchSite, the Denley            The cemetery footprint is designated on some drawings ArchSite, the Denley    Cemetery was re-discovered on the CFFF site in      when the plant was constructed.
Cemetery was            2003 and discovered on the CFFF site in 2003 and 3-79 19-21  The WEC has            The WEC CFFF has proposed installedation of a      The field investigation portion of the RI was completed proposed installation of permanent monitoring well (W-98) near but          in August 2021.
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 57 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 a permanent            outside the southern edge of the original Denley monitoring well (W-    Cemetery,. but no investigations are planned to  The Remedial Investigation Report will be submitted to
: 98) near but outside  occur within the fenced area (WEC 2020-          DHEC upon completion in 2022 for subsequent review, the southern edge of    TN6871).                                        comment, and final approval.
the Denley Cemetery, but no investigations are planned to occur within the fenced area (WEC 2020-TN6871).
3-79 40    The WEC has            The WEC CFFF has established cultural            For clarification.
established procedures  resources procedures and and 3-79 45    resources or human    resources or human remains during the          Word is missing from the sentence.
remains during the      implementation of ground-disturbing activities implementation of      was ground-disturbing activities 3-92 19    solvents,            solvents, and lubricating and cutting oils, and On-site plating operations were discontinued in February lubricating and cutting spent plating solutions (WEC 2019-TN6510).      2020.
oils, and spent plating solutions (WEC 2019-TN6510).
3-93 14-16 The WEC is actively    The WEC CFFF has completed East Lagoon          The former East Lagoon area is now green space, and its pursuing closure and    decommissioning and is actively pursuing closure  closure has been approved by SCDHEC.
cleanup of the East    and cleanup of the East Lagoon and, disposal of Lagoon, disposal of    other contaminated materials, such as calcium other contaminated      fluoride and obsolete cylinders, and analyzing materials, such as      sludge in the Sanitary Lagoon to support closure calcium fluoride and    activities (WEC 2020-TN6844).
obsolete cylinders, and analyzing sludge in the Sanitary Lagoon to support closure activities (WEC 2020-TN6844).
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 58 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 3-95 21-22 while process        while process safety management of highly    WEC replaced its only PSM covered material, safety management of    hazardous chemicals are found at 21 29 CFR    anhydrous ammonia with aqueous ammonia and highly hazardous        1910.119,                                    therefore this regulation is not applicable.
chemicals are found at 21 29 CFR 1910.119, 3-96 30    ..held by the WEC..  ..held by the WEC for CFFF                  Clarification.
3-97 42    There are 47 exhaust  There are 4627 exhaust stacks that          WEC has 42 monitored stacks. One previously stacks that                                                          independent stack originating from the chemical lab was tied into a larger, main ventilation system, reducing the number of total stacks by one. Additionally, four additional sample locations (1240, 1242, 1243, and 1246) were removed from the total because these four systems are non-process related, do not exhaust to the atmosphere, and are recirculating comfort air systems.
3-  14    The WEC has            The WEC CFFF has approximately..            Clarification.
100        approximately..
3-  24    ..generated by the    ..generated by the WEC at CFFF..            Clarification.
101        WEC..
3-  38    to discharge from    to discharge from the 4247 exhaust stacks. WEC has 46 monitored stacks. One previously 101        the 47 exhaust stacks.                                                independent stack originating from the chemical lab was tied into a larger, main ventilation system, reducing the number of total stacks by one. Additionally, four additional sample locations (1240, 1242, 1243, and 1246) were removed from the total because these four systems are non-process related, do not exhaust to the atmosphere, and are recirculating comfort air systems.
3-  43    The CFFF has been      The CFFF has been below all regulatory limits Source WEC 2019-TN6510 does not state that sulfur 101  1-3  below all regulatory    for gaseous radiological effluents and        dioxide emissions from the site exceed regulatory limits.
3-        limits for gaseous      nonradiological effluents. except for sulfur  The WEC is a minor source and does not have 102        radiological effluents  dioxide. No actions by SCDHEC have been taken  requirements in its current SCDHEC air operating and nonradiological    for sulfur dioxide emission rates to date (WEC permit to monitor and measure for any gaseous effluents, except for  2019-TN6510).                                emissions. The site does monitor radiological emissions sulfur dioxide. No                                                    as part of its special nuclear material license with the actions by SCDHEC                                                      NRC.
have been taken for
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 59 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 sulfur dioxide emission rates to date (WEC 2019-TN6510).
3- 30-32 The WEC stored          The WEC stored drums of combustible waste,            Clarification on completed work with the SSAOU. The 102      drums of combustible    containing uranium waiting for uranium recovery        CFFF has emptied all the intermodal storage containers waste, containing        via onsite incineration, in intermodal containers      containing accountable uranium and uranium uranium waiting for      (sea-land containers) in an outdoor storage area.      contaminated materials uranium recovery via    The CFFF has emptied all the intermodal storage onsite incineration, in  containers in the southern storage area containing intermodal containers    accountable uranium and uranium contaminated (sea-land containers) in materials.
an outdoor storage area.
3- 37-38 The WEC is a large-    The WEC CFFF is a large-quantity generator of        On-site plating operations were discontinued in February 102      quantity generator of    hazardous wastes that include degreasing solvents, 2020.
hazardous wastes that    lubricating and cutting oils, spent plating solutions, include degreasing      and zirconium-laden wastes.
solvents, lubricating and cutting oils, spent plating solutions, and zirconium-laden wastes.
3- 30-31 Calcium fluoride, a    Calcium fluoride, a nonhazardous industrial          Calcium fluoride is dredged from the West Lagoons, 103      nonhazardous            waste, is removed from West Lagoons I and West        approximately every 2 years. The North and South industrial waste, is    Lagoon II approximately every 2 years and from        Lagoons are dredged less frequently, approximately removed from West        the North and South Lagoons less frequently.          every 8-10 years.
Lagoon I and West        Calcium fluoride, and is either recycled or Lagoon II, and is either disposed of offsite.
recycled or disposed of offsite.
3- 43    The WEC has seen.. The WEC CFFF has seen                              Clarification.
103
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 60 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 : Updated Figure 2-6 URRS Proceed Streams
 
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 61 of 61 Our ref: LTR-RAC-21-77 November 19, 2021 : Updated Figure 2-9 Groundwater Well Locations at the CFFF Site}}

Latest revision as of 04:15, 19 November 2024

Comment (5) of Elise Malek on Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility
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)
v • d • e


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.

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