ML20245E575
| ML20245E575 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/31/2020 |
| From: | Issod A Sierra Club |
| To: | Office of Administration |
| References | |
| 85FR46193 00004, NRC-2015-0039 | |
| Download: ML20245E575 (6) | |
Text
Page 1 of 1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Jessie Quintero, Sarah Achten, Diana Toro As of: 9/1/20 5:11 PM Diaz, Mary Neely Received: August 31, 2020 Status: Pending_Post PUBLIC SUBMISSION Comment (4)
Publication Date:
Tracking No. 1k4-9ip5-rsrf 7/31/2020 Comments Due: August 31, 2020 CITATION 85 FR 46193 Submission Type: Web Docket: NRC-2015-0039 Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility Comment On: NRC-2015-0039-0073 Westinghouse Electric Co., LLC; Columbia Fuel Fabrication Facility; Intent to prepare an environmental impact statement and conduct a scoping process Document: NRC-2015-0039-DRAFT-0074 Comment on FR Doc # 2020-16150 Submitter Information Name: Andrea Issod Address:
Sierra Club Law Program 2101 WEBSTER ST STE 1300 OAKLAND, CA, 94612-3011 Email: andrea.issod@sierraclub.org General Comment Please see attached comments from Sierra Club Attachments Comment Westinghouse EIS Scoping_8_31 https://www.fdms.gov/fdms/getcontent?objectId=090000648482f2e8&format=xml&showorig=false 09/01/2020
August 31, 2020 Re: Docket ID NRC-2015-0039 Submitted via regulations.gov Sierra Club Scoping Comments on the Environmental Impact Statement for the Proposed Renewal of the Columbia Fuel Fabrication Facilitys License to Operate Sierra Club submits these preliminary comments to inform the Nuclear Regulatory Commissions scoping process for the Environmental Impact Statement regarding its review of whether to grant the forty-year renewal of the operating license for the Columbia Fuel Fabrication Facility (Columbia Fuel) in Hopkins, South Carolina. Sierra Club submits these scoping comments to identify areas that the EIS must rigorously and objectively investigate in order to fully inform its decision.
I. The EIS Must Address Emergency/Accident Response Plans Including Community Notification Columbia Fuel has experienced a number of known incidents in the last five years. These include uranium buildup in an air scrubber, employee accidents, improper storage, leaks of hydrofluoric acid and uranyl nitrate into soil, a storage container roof leak, leaking lagoon liner, and an explosion of a storage drum. The continuous string of incidents indicates that, in order to ensure safer future operations, the plants safety plans and operating permit needs significant review and updates.
Columbia Fuel has not fulfilled its duty as a responsible neighbor to inform local communities in a timely manner about problems at the plant. Local community members have a
right to know about any potential problems at Columbia Fuel that may impact them. Local communities often do not learn about malfunctions or accidents until they read about incidents in the newspaper several days after they occur. The plant has made commitments to improve their notification system several times at public meetings, but so far it has not honored this commitment. The EIS should carefully assess Columbia Fuels emergency response plans in light of the string of recent accidents and ensure that there is a robust community notification plan in place.
II. The EIS Must Address Continued Need for Nuclear Fuel Rods over the Duration of the Permit In determining whether to grant a renewal of the license, NRC must assess expected need for nuclear fuel rods in the future. In the last several years, many nuclear power plants have shut down or contemplated bankruptcy. 1 Additionally, costs of renewable energies and battery storage have been decreasing, making them increasingly attractive low carbon alternatives to nuclear power. 2 The EIS must assess if current demand for nuclear fuel can be supplied by other existing facilities, and whether the supply from this facility will be needed over the proposed forty additional years of a renewed license, considering both the no action alternative and a renewed license with a substantially shorter time frame that would allow continued assessment of need for fuel rods.
https://apnews.com/f9831eb0ddf44603abb2c9cb76d35f88#:~:text=(AP)%20%E2%80%94%20The%20m oney%2D,after%20Chicago%2Dbased%20Exelon%20Corp.
2 https://www.forbes.com/sites/energyinnovation/2020/01/21/renewable-energy-prices-hit-record-lows-how-can-utilities-benefit-from-unstoppable-solar-and-wind/#3635bb82c84e, https://www.utilitydive.com/news/electricity-costs-from-battery-storage-down-76-since-2012-bnef/551337/#:~:text=Going%20back%20to%202012%2C%20BNEF,the%20first%20half%20of%202019.
III. The EIS Must Investigate Existing Contamination, Impacts, and Cleanup.
The EIS must rigorously assess existing contamination at Columbia Fuels. This must include the contamination from a 2011 leak that went unreported for years and that Westinghouse has stated will not be remediated until the plant closes and water contamination potentially dating to a breach from 1971. 3 The EIS must examine potential for future leaks and contamination, as there have been several contamination events in the last few years, and determine what if anything can be done in addition to the insufficient current practices to ensure containment of hazardous materials. 4 IV. The EIS Must Disclose Air Quality and Related Human Health Impacts From the Facility The EIS should include information about all permits and regulations that govern air emissions from the facility, detail the facilitys history of compliance and any corrective measures in place to prevent future compliance problems. The operating permit governing air emissions from Columbia Fuels expired in February 2018. 5 An updated application for a renewal permit was submitted on May 30, 2019, which references an original application for renewal that was submitted within the required time frame. 6 The EIS should explain whether a renewal permit is being processed, the expected timeline, and opportunities for public involvement.
The environmental report states that WEC monitors radiological gaseous emissions from 47 stacks for compliance with the National Emission Standards for Hazardous Air Pollutants 3
https://www.thestate.com/article217529525.html, https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML20119B091 4
http://thestate.com/article242667201.html, https://www.thestate.com/article240309966.html, 5
http://pubdoc.dhec.sc.gov/AirPermitCoverage/1900-0050.pdf 6
https://www.scdhec.gov/sites/default/files/media/document/BAQ_WestinghouseRenewalPermit2019 07_0.pdf
under 40 CFR Part 61. 7 The EIS should include information from the last five years about the following:
- 1. Any exceedances of the NESHAP standards;
- 2. Any exceedances of offsite dose limits of radioactive materials or if any of the onsite ambient air monitors have reported high levels of radioactive materials;
- 3. Process upsets or equipment failures;
- 4. Startup and shutdown events that exceeded opacity or other standards; and
- 5. Information regarding expected maintenance and upgrades of the equipment at the facility.
If any exceedances or concerning level of pollutants have occurred, the EIS should also include information about corrective actions the facility has put in place to prevent future problems.
V. The EIS Must Address the Disproportionate Placement of Industrial Facilities in this Community and Disproportionate Impacts on Community Members.
Columbia Fuels is located in Lower Richland, outside of Columbus, in a majority Black community with lower median income than much of the rest of the Columbia area. This community is also home to a coal plant and a paper mill, and it has a disproportionately high rate of cancer and other illnesses associated with pollution. The community also uses well water, which gives them a higher risk of contamination from Colubmia Fuels than if their water was sourced from elsewhere. The EIS must rigorously assess the risks to the surrounding community 7
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18120A318
from this facility and also assess the cumulative risks from other surrounding facilities. Under Executive Order 12,898, federal agencies must determine whether a project will have a disproportionately adverse effect on minority and low-income populations.
VI. The NRC Should Extend the Deadline for Scoping Comments We are aware that several community members have requested an extension to the short 30-day comment period for scoping comments. Given this licensing decision will extend the life of this facility for four decades, that there is a history of problems at this facility and a lack of communication with the community, and especially given the current global pandemic, NRC should extend the comment period and accept comments for an additional 60 days at minimum.
Respectfully submitted on behalf of Sierra Club on the 31st day of August, 2020.
/s/ Andrea Issod Andrea Issod Sierra Club Environmental Law Program 2101 Webster Street, Suite 1300 Oakland, CA 94612 andrea.issod@sierraclub.org Virginia Sanders virginia.sanders@sierraclub.org