ML21327A156
| ML21327A156 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/19/2021 |
| From: | Malek E Westinghouse |
| To: | Office of Administration |
| References | |
| 86FR53694 00005, NRC-2015-0039 | |
| Download: ML21327A156 (62) | |
Text
11/23/21, 10:42 AM blob:https://www.fdms.gov/5cbf8464-cf59-4025-bcfb-560a89b7fde5 SUNI Review Complete As of: 11/23/21 10:42 AM Template=ADM-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:
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 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.
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.
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.
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.
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.
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.
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.
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.
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.
3-40 22-24 Therefore, it is not Therefore, it is not immediately clear whether the Suggest deleting as speculation.
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.
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.
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
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.
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.
travel time less than 20 years over a distance of 600 m) than suggested by the average groundwater velocity.
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.
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.
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 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.
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.
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..
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.
acid hydrochlorides (HCLs) and HF due to the burning of rubber, plastics, and other chemicals.
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)
(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).
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).
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.
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