As part of our commitment to transformational change, excellent environmental stewardship and being good neighbors, the Columbia Fuel Fabrication Facility (CFFF) has developed an environmental improvement plan that is being executed in conjunction with the South Carolina Department of Health and Environmental Control (SCDHEC) Consent Agreement (CA) to actively address legacy environmental issues and reduce the future risk of environmental challenges at the site. As part of the agreement, we share weekly updates and submit monthly progress reports to SCDHEC. These reports are publicly available on SCDHEC and CFFF websites.
The initial step of this CA was the Remedial Investigation (RI), a highly in-depth study to gather data and samples needed to determine the presence and extent of contamination from historic operations at the site. We completed the first phase of the RI in 2019, then submitted an interim report containing the results on February 28, 2020. The data found no evidence of any off-site contamination.
Now we are working with SCDHEC to develop the scope of work for the investigation’s second phase. We will continue working with SCDHEC to complete the comprehensive site evaluation as part of our commitment to correct legacy environmental issues.
The CA also requires the elimination of older materials and equipment identified as obsolete due to the potential for environmental impact. Therefore, we have been diligently removing sealands that stored radioactive materials off-site and are planning to close the East Lagoon and replace it with an above-ground storage tank.
The closure of the East Lagoon is a critical part of our environmental improvement plan. The East Lagoon is located near the manufacturing building on the bluff and far from the site boundary. To date, there is no evidence that groundwater has been impacted by the Lagoon or that the Lagoon liner has failed.
The East Lagoon closure involves multiple regulatory bodies, including SCDHEC and the Nuclear Regulatory Commission (NRC). On Tuesday, May 12, we convened with the Nuclear Regulatory Commission (NRC) to discuss the submittal for Alternate Disposal under 10 CFR 20.2002. We discussed the request for NRC approval to dispose of specified low-activity radioactive material from CFFF to the US Ecology Idaho, Inc. (USEI) disposal facility in support of the closure of the East Lagoon.
This activity is to remediate on-site legacy issues from several decades ago. The request consists of disposal of the following waste:
A radiation exposure/dose evaluation was completed using NRC-approved USEI site-specific methodology. This evaluation concluded that the dose to workers and members of the public would be well below NRC limits and well within the “few mrem” criterion (equivalent to a chest x-ray) established in NRC guidance for alternate disposal requests.
During the meeting, we emphasized that this request is in support of ongoing cleanup and remediation of the CFFF site and that we are seeking approval no later than December 2020. We also stated that delaying this request after the renewal of the CFFF SNM-1107 license is not in the interest of any stakeholders. Still, we asked that this license action not impact the schedule or completion of the ongoing license renewal.
NRC stated that as they review the request, they will determine whether there are any potential impacts to the license renewal due to this submittal. They will notify us if such an impact is identified.
USEI stated that they have prepared and submitted a letter with the exemption request. This letter was sent to NRC in the mail. Due to the COVID-19 work from home restrictions, USEI will work to get NRC an electronic copy of this letter to support the submittal.
The remainder of the meeting was open for public comment. Below is a summary of the comments/questions:
The decommissioning of the East Lagoon exemplifies our commitment to handling site issues in a manner that is in the best interest of our employees, the public, and the environment. The necessary operational changes to replace the Lagoon with an above ground tank are in development. Removing any material that builds up in a lagoon over time is standard practice; accordingly, desludging it is part of the normal process to remove it from service.
The Lagoon contents will be appropriately disposed of per regulations, and the soil below the Lagoon will be sampled. Results will be shared with SCDHEC, and we will develop any necessary remediation strategy based upon those results. We will continue to be transparent and inform you about our progress. Each of these steps and phases will be documented in accordance with the Consent Agreement and the results made publicly available - as we have with all other efforts under the Consent Agreement to date.