No more than a 10 year license with strict conditions requiring good compliance
Testify at the webinar August 26th

(see instructions for participating here: https://www.nrc.gov/docs/ML2122/ML21223A340.pdf)

Email comments to:

WEC_CFFF_EIS@nrc.gov before September 20, 2021

  1. The existing NRC license failed to prevent extensive radioactive and hazardous pollution by the Westinghouse Nuclear Fuel Fabrication Facility over the last 50 years which threatens air quality, groundwater and surface water quality including the waters of Mill Creek which flows through the site and into the Congaree River;
  2. Under the existing NRC license Westinghouse has failed to demonstrate the necessary corporate character or competence to comply with regulatory requirements.  A history of spills, leaks, accidents and corporate malfeasance undermine assurance that Westinghouse will comply with future regulatory requirements under a new 40 year license;
  3. Under the existing license the NRC has failed to exercise sufficient oversight to prevent and remedy pollution discharges and violations by Westinghouse;
  4. Only through action by the local State authorities- SCDHEC- as recently as 2019, did Westinghouse disclose extensive radioactive and toxic contamination of groundwater at the site and sediments at the bottom of Mill Creek which flows to the Congaree River. Such sediment contamination includes radioactive Uranium and Technetium 99. The sources of such pollution remain unidentified and  its extent and remediation remain incomplete.  No new license should be approved until such historic pollution has been cleaned up and full corrective action to prevent future pollution has been implemented;

5.  The NRC and Westinghouse have failed to comply with Environmental Justice regulatory requirements. While acknowledging that the Westinghouse Nuclear Fuel Fabrication Facility is sited in a predominately African American and low income residential community, with numerous additional sources of environmental hazard including an adjacent Superfund Hazardous Waste Site and the nearby Wateree coal-fired power plant, NRC and Westinghouse have failed to properly address the disproportionate and harmful impacts of future  facility operations on the Environmental Justice (EJ) community or poverty area, including the cumulative and synergistic impacts of other sources.  The NRC and Westinghouse have failed to properly assess the  heightened impacts of facility pollution on subsistence hunting and fishing by members of the impoverished community in areas adjacent to the facility boundaries. Over the last 50 years of facility operations the NRC and Westinghouse have failed to effectively engage the local community to facilitate effective understanding of facility operations and impacts and effective public participation in facility regulation. Hopkins is designated by Health Resources and Services Administration (HRSA) as a medically underserved area (MUA) and
medically underserved population (MUP). As such, it deserves better protection from additional health threats.

  1. WFFF agreed to an Intensive Archaeological Survey, conducted late summer/early fall 2021, with final SHPO approval anticipated circa February 2022. The NRC staff anticipates publishing the final EIS in January 2022, and the Record of Decision in February 2022. An assessment about the license cannot be made without the results of the Intensive Archaeological
    Survey. The Pine Hill Indian Tribe is originally from the area. An important Native American cemetery site (Green Hill Mound), thought to be ancestral to the Pine Hill, that is presently not protected under the federal Native American Grave Protections and Repatriation Act (NAGPRA) law is in close proximity to WFFF. It is an Ancestral, generational heirloom to the Pine Hill Tribe. As such, its significance is priceless. The Area of Potential Effect of the new license
    should be increased to include this archaeological site. No new license should be approved without the results of the SHPO approved Intensive Archaeological Survey incorporated into theEIS.
  2. A historic African American cemetery, Denley Cemetery, thought to be potentially eligible to the National Register of Historic Places is located on the WFFF property. A test well has been installed in close proximity to the cemetery. Test wells should not be installed in such close proximity to significant archaeological resources.
  3. Westinghouse Government Services, LLC, a duly registered company with the SC secretary of state, appears to be operating under the same roof as the Westinghouse fuel fabrication facility, where uranium rods are fabricated for foreign and domestic nuclear power plants. Westinghouse Government Services, previously known as WesDyne, produces specialized rods
    that are irradiated to produce tritium gas for nuclear weapons. The Nuclear Regulatory Commission claims it does not regulate the facility and the SC Department of Health and Environmental Control says it has issued no permits to the facility and that waste goes to the fuel plant. It is unclear who is regulating the facility or what sort of contaminants it is generating.
    The tritium rod issue makes the Westinghouse plant a civilian-military “dual use” facility.