ML18275A120

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Submission of Integrated Confirmatory Order Actions Summary Table Required Pursuant to Section 16 of the March 28, 2017 Confirmatory Order
ML18275A120
Person / Time
Site: 04008903
Issue date: 09/28/2018
From: George G F
Davis Wright Tremaine, LLP
To:
Office of Nuclear Material Safety and Safeguards, NRC/OE
References
EA-16-114
Download: ML18275A120 (15)
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ir, DavisWright Ii!! Tremaine LLP September 28, 2018 BY OVERNIGHT MAIL AND ELECTRONIC MAIL Deputy Director 505 Montgomery Street Suite 800

  • San Francisco, CA 94111-6533 GERALD F. GEORGE 415.276.6526 tel 415.276.6599 fax geraldgeorge@dwt.com Director, Office of Enforcement

[OE] U.S. Nuclear Regulatory Commission Division of Decommissioning One White Flint North

  • 11555 Rockville Pike Rockville, MD 20852-2738 Uranium Recovery and Waste Programs [DUWP] Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Re: Submission of Integrated Confirmatory Order Actions Summary Table Required Pursuant to Section 16 of the March 28, 2017 Confirmatory Order

Dear Sir or Madam:

Enclosed please find the Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site.(as of September 28, 2018).

  • If you have any questions regarding this summary, please contact me as soon as possible.

Sincerely, Gerald F. George Counsel for Homestake Mining Company of California cc: NRC Document Control Desk (Hard Copy) Anne Boland, Director of OE ( email) Andrea Kock, Deputy Director ofDUWP (email) Jeffrey Whited (email)

  • Patrick Malone ( email) Clark Burton ( email) Tom Wohlford (email) Brad Bingham ( email) Michael McCarthy ( email) Michelle Burgess ( email) I Anchorage Bellevue Los Angeles I NewYork Portland San Francisco I Seattle Shanghai . Washington, D.C. 0£01 /t/1Vf5StJI
rJ/V/5S NIL/ t!JC www.dwt.com Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments -HMC receives Confirmatory Order (CO) from NRC 1 March 28, 2017 March 28, 2017 (ADAMS Accession Nos. ML17060A753 and -Day 1 of CO actions is March 29, 2017 MLI 7061A455).

2 HMC responds to NRC. --HMC submittal of third party consultant qualifications to -3 April 27, 2017

  • April 14, 2017 NRC for approval (ADAMS Accession No. MLI 7108A258).

' NRC submits comments on third party consultant

--4 NA April 19, 2017 qualifications to HMC (ADAMS Accession No. ML17114AI 06). NRC submits NRC inspection report and notice of violation HMC cited for failure to verify through appropriate testing and analysis that radon letter to HMC indicating one Severity Level IV violation releases did not exceed 20 pCi/m 2 s, failed to 5 NA April 20, 2017 as a result ofNRC inspection on August 24-25, 2016 ensure that a single set ofradon flux (ADAMS Accession No. MLI 7088A761).

Corrective actions for this violation will be evaluated in the Self-measurements were made, and failed to have Assessment.

required 100 measurements from each mill tailings pile. HMC re-submittal to NRC regarding NRC response to third 6 NA April 24, 2017 party consultant qualifications (ADAMS Accession No. --MLI 71 I 5A424). HMC adjusts RO Plant operations to better ensure 7 April 27, 2017 April 27, 2017 compliance with Ground Water Protection Standards

--(GWPSs) (ADAMS Accession No. MLI 7121A31 J). -.. Day I of 120-day period to complete Self-Assessment is May 4, 2017. Self-8 NA May 3, 2017 NRC approves third party consultant.

Assessment due to third-party for review by August 31, 2017. 1 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments HMC submits "Reply to Notice of Violation" (NOV) letter to HMC indicates "Reasons for Violations" and NRC dated May 16, 2017 (ADAMS Accession No. 'Corrective Action-Actions Already Taken 9 May 20, 2017 May 16, 2017 17143A271) in response to NRC's "Notice of Violation" letter dated April 20, 2017 (ADAMS Accession No. and Future Actions" in letter, in response to MLl7088A761).

the violation HMC submits letter to NRC dated May 17, 2017 indicating 10 NA May 17, 2017 the discontinuance of Tripolyphosphate Injection Pilot --Testing. NRC submits letter "Response to Notice of Violation" to NRC indicates that HMC completed and HMC (ADAMS Accession No. MLl 7145A572) replying proposed corrective actions appear to 11 NA May 26, 2017 to HMC letter dated May 16, 2017 "Reply to Notice of adequately address the regulatory Violation" (ADAMS Accession No. 17143A271).

noncompliance as described in the NOV dated April 20, 2017. HMC submits letter to NRC dated June 13, 2017 providing additional information regarding NOV on radon flux 12 NA June 13, 2017 measurements and requesting 90-day extension (to --September 13, 2017) for submittal of the procedure for demonstrating compliance with the radon flux standard.

13 June 16, 2017 June 16, 2017 HMC submits discussion materials to NRC on CO Discussions with NRC on the materials to Conditions 8 and 10. occur on June 26 14 NA June 21, 2017 HMC submits letter to NRC, EPA, NMED, and OSE with attached abandonment plan for 150 wells on top ofL TP. --15 June 26, 2017 June 26, 2017 Discussions with NRC on CO Conditions 8 and JO. Final submittal of analyses due to NRC on July 26, 2017 Submittal of Root Cause Protocol to Dr. Matt Arno for Root Cause Protocol marked-up with third-16 NA June 27, 2017 third-party review. party reviewer's comments/revisions due to NRC on July 26, 2017 2 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments NRC submits NRC inspection report and notice of violation Violations generally are 1) lack of standard procedures for all activities involving letter to HMC indicating 3 Severity Level IV violations radioactive materials, 2) lack of 17 NA July 6, 2017 as a result ofNRC inspection on April 24-26, 2017 environmental evaluation of all activities not (ADAMS Accession No. MLl 7164A088).

Corrective actions for these violations will be evaluated in the Self-previously assessed by the NRC, and 3) lack Assessment.

of cultural resources survey before engaging in any developmental activity.

18 July 20, 2017 July 20, 2017 Additional discussions with NRC on CO Condition 8 (re---injection impact analysis).

Submittal of Root Cause Protocol to NRC (Condition

1) Includes original version and third-party (ADAMS Accession No. ML17212A026).

reviewer's comments/revisions Submittal of re-injection impact analysis to NRC (Condition

8) (ADAMS Accession Nos. ML17212A027 and --MLI 7212A028).

19 July 26, 2017 July 26, 2017 Submittal of impact of RO plant exceedances analysis to NRC (Condition JO) (ADAMS Accession Nos. --ML17212A027 and ML17212A029).

Submittal of written procedures on monthly sampling of SP-2 to NRC (Condition

12) (ADAMS Accession No. --MLI 7212A025).

NRC acknowledgment letter that correspondence received 20 August 1, 2017 August 1, 2017 per Conditions 1, 8, 10, and 12 of the CO (ADAMS --Accession No. ML17213A291).

HMC submits "Reply to Notice of Violation" letter to NRC dated August 3, 2017 (ADAMS Accession No. HMC indicates "Reasons for Violations" and 21 August 3, 2017 August 3, 2017 MLl 7223A189) in response to NRC's "Notice of "Corrective Actions that Have Been Taken" Violation" letter dated July 6, 2017 (ADAMS Accession in letter, in response to 3 Level IV violations No. MLl 7164A088).

3 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments NRC submits letter to HMC dated August 21, 2017 (ADAMS Accession No. MLl 7229B212) indicating that completed 22 NA August 21, 2017 and proposed corrective actions appear to adequately Letter refers to HMC's response to 3 Level address the regulatory non-compliance.

Also, HMC does IV violations not need to submit SOPs to NRC, and NRC staff will review during future inspections.

NMED submits letter to HMC dated August 22, 2017 indicating that a public meeting is scheduled for Public meeting scheduled for September 14, 23 NA August 22, 2017 September 14, 2017 to discuss prohibition of private 2017. Attendees to include NRC, NMED, water wells in area impacted by the former Bluewater 0SE, DOE, EPA, and HMC. and Homestake uranium mills in Cibola County. HMC submits a request to the NRC to extend the due date of the Root Cause Analysis from Augusi 25, 2017 to 24 NA August 23, 2017 September 15, 2017. As a result, the submittal of --proposed corrective actions for the Root Cause Analysis would be revised to November 14, 2017. Via e-mail to HMC, NRC approves request to extend submittal of Root Cause Analysis to September 15, 25 NA August 24, 2017 2017. As a result, the submittal of proposed corrective

--actions for the Root Cause Analysis is revised to November 14, 2017 (or 60 days after September 15 1 h). 26 August 31, 2017 August 31, 2017 HMC submits Self-Assessment Report to Dr. Matt Arno of ' --Foxfire Scientific as third-party reviewer.

HMC submits draft versions of Land Application 27 NA September 12, 2017 Assessment Report and Self-Assessment Report to the --NRC for initial feedback.

I 28 NA September 12-14, 2017 NRC conducts inspection of Site artd CO-related activities.

--29 NA September 13, 2017 Conference call with NRC to get feedback on Self---Assessment Report 4 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments HMC submits a reply letter with attached tech memo to the NRC on radon flux NOV (ADAMS Accession No. MLl 7264A070), and requests a variance/exemption from 30 September 13, 2017 September 13, 2017 obtaining compliance with the radon flux standard for the --Large Tailings Pile (L TP) until groundwater restoration at. the Site is complete.

HMC needs to revise letter and provide substantial back-up to this information to the NRC. -* 31 NA September 14, 2017 Tour of Site with NRC, NMED, DOE, OSE, and EPA. --Public meeting with NRC, NMED, DOE, OSE, and EPA to 32 NA September 14, 2017 discuss prohibition of private water wells in area --impacted by the former Bluewater and Homestake uranium mills in Cibola County. 33 NA September 15, 2017 Conference call with NRC to get remaining feedback on --draft Self-Assessment Report. 34 September 15, 2017 September 15, 2017 HMC submits Root Cause Analysis to the NRC (ADAMS --Accession No. ML17263A125).

,, On behalf ofHMC, ERG submits an e-mail to the NRC providing additional information on the potential NOV This potential NOV will be evaluated during 35 NA September 18, 2017 identified during the NRC Site inspection for work on the 1,200 gpm zeolite water treatment system, and the Self-Assessment.

proposed corrective actions to be taken. Conference call with NRC to discuss extension of due date HMC will submit a formal written request 36 NA September 19, 2017 for Self-Assessment Report to the NRC to extend the due date of Self-Assessment Report 5 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments -HMC submits Land Application Assessment report to the NRC (ADAMS Accession No. ML17270A066).

HMC is not growing crops for human consumption on any 37 September 25, 2017 September 25, 2017 previously irrigated lands authorized previous to the --CO and will continue to prevent crops from being grown on those lands while fulfilling the CO. HMC intends to place a restrictive covenant on the deed(s) for those lands to prevent future cultivation of crops. 38 September 27, 2017 September 27, 2017 HMC submits Integrated Table of CO Actions to the NRC --(ADAMS Accession No. ML17272A137).

Conference call with NRC to discuss procurement of 39 NA September 28, 2017 potential contractors for the Self-Assessment Report, --guidance on CAP for RCA, and radon flux NRC acknowledgment letter that RCA Report received per Condition 2 of the CO (ADAMS Accession No. 40 NA October 19, 2017 ML17241A299).

Also, letter provides written formal --approval from the NRC for the extension of due dates for the RCA Report (to September 15, 2017) and RCA Corrective Action Plan (to November 14, 2017). -NRC letter to HMC (ADAMS Accession No. MLI 7292A953) indicating that HMC request for variance from radon flux standards regulatory requirements did not meet the intent of 10 CFR 40.14(a) for specific exemptions, and NRC advised HMC to 41 NA October 19, 2017 resubmit a request for a variance with sufficient detail so --the NRC could conduct a technicaf review of that request. On an interim basis, HMC's proposed procedure for monitoring radon flux presented in HMC's letter to NRC dated September 13, 2017 (ADAMS Accession No. MLl 7264A070) should be implemented until longer-term solutions are agreed. 42 NA October 24, 2017 Conference call with NRC to discuss proposed SOW for --additional soil sampling of the Land Application areas. 6 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments In response to NOV letter from the NRC dated July 6, 2017 (ADAMS Accession No. MLl 7164A088), HMC is to SOPs completed and contained in HMC SOP prepare SOPs for 1) handling material placed in pits on 43 NA November 1, 2017 top of the Small Tailings Pile (STP), 2) operation of the Manual, Revision 4, dated December 18, two zeolite water treatment systems, and 3) operation of 2017. the evaporation ponds. HMC meeting with and presentation to the NRC in 44 NA November 3, 2017 Rockville, MD to request an extension of the Self--Assessment due date. HMC submittal to NRC of proposed corrective actions based on the Root Cause Analysis of the apparent 45 November 14, 2017 November 14, 2017 violations documented in NRC's letter dated October 4, --2016 (ADAMS Accession Nos. ML17320Al28 and MLJ7320AJ29).

Submittal of "Final Status Survey Plan" for Land 46 NA November 15, 2017 Application areas to the NRC (ADAMS Accession Nos. --MLJ 7340A406 and MLJ 7340A407)

HMC submittal to NRC formally requesting an extension of 47 NA November 17, 2017 the Self-Assessment report due date to Sept 3, 2018 --(ADAMS Accession No. MLJ7325A023).

HMC submittal to NRC to update the groundwater monitoring plan in its NRC license (SUA-1471) to adjust 48 NA November 20, 2017 the compliance monitoring for the groundwater

--restoration areas at the Grants Reclamation Project site. (ADAMS Accession No. ML18018AI02) 49 NA November 21, 2017 HMC completed abandonment of 150 monitor wells on the LTP --HMC submittal to NRC of Revised Scope of Work -Re-50 NA November 29, 2017 Seeding of Former Land Application Areas for Dust --Control (ADAMS Accession No. ML17340A405) 7 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments 51 NA November 30, 2017 HMC submittal to NRC of Scope of Work for horizontal

--wells pilot test (ADAMS Accession No. MLl 7340A408) 52 NA December 4, 2017 HMC submittal to NM OSE of plugging plans for Wells 928, --943, 951, Deep Well #1, Deep Well #2, and Old Well #1 53 NA Status Survey work for Land Application areas initiated by --HMC on December 4, 2017. HMC request to NRC to amend Condition 35 of the License 54 NA December 11, 2017 to add two zeolite water treatment systems (ADAMS --Accession Nos. MLI 7361A007 through MLI 7361AOl 1). NRC Inspection Report 040-08903/2017-002 from inspection One URI related to regulatory compliance 55 NA December 20, 2017 at Grants site on September 13 and 14, 2017 (ADAMS with 10 CFR Part 20 requirements for Accession No. MLl7353A414).

internal occupational dose monitoring.

NRC approves request to extend d_ue date of Self-Assessment to September 3, 2018 (ADAMS Accession No. ML17340B341).

Also, Condition 44 of the License 56 NA December 26, 2017 was amended (License Amendment No. 50) to formally --approve extension of the due date of Conditions 2 and 4 of the CO (ADAMS Accession No. MLJ7340B369).

Condition 35 of the License also was amended to correct an administrative error. NRC notifies HMC of change of Project Manager (PM) for 57 NA December 28, 2017 the Grants site (ADAMS Accession No. --MLl 7354A086).

New NRC PM is Jeffrey A. Whited. HMC submittal to NRC of HMC's Self-Assessment Report,

  • Revised due date of September 3, 2018 58 December 29, 2017 -the third-party consultant's review report, and any approved by the NRC on December 26, modifications by HMC as a result of third-party consultant's report 2017 59 NA January 16, 2018 Kick-off meeting for the Self-Assessment contractor

--(ENERCON) at the HMC Grants site. 8 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments Monthly call between HMC and NRC PM (J. Whited) to 60 NA January 22, 2018 provide an update on the current status of --Confirmatory Order Actions. NRC letter from S. Koenick, 2017 Annual Surety Update for the Homestake Mining Company of California Grants 61 NA January 30, 2018 Reclamation Project, Amendment Number 51 to Source --Materials License SUA-1471, Docket Number 40-8903. (ADAMS Accession Nos. MLl 7346A341, MLl 7346A32, and MLl 7346A344).

62 NA February 5-9, 2018 HMC Site OSHA compliance inspection conducted by --ENERCON. The NRC staff was provided the opportunity to review the notification of a revised scope NRC letter from J. Whited to T. Wohlford, Re: Revised of work that does not involve an amendment 63 NA February 9, 2018 Scope of Work Re-seeding of Former Land Application to HMC's NRC license. The staff Areas for Dust Control. (ADAMS Accession No. coordinated its review with NMED. The staff ML18019A038) and NMED have completed the review and do not have any questions concerning the revised scope of work at this time. Monthly call between HMC and NRC PM (J. Whited) to 64 NA February 13, 2018 provide an update on the current status of --Confirmatory Order Actions. HMC drop-in visit with NRC senior staff in the Division of HMC provided an update on status of the 65 NA February 21, 2018 Decommissioning, Uranium Recovery, & Waste Self-Assessment (CO Condition

  1. 3) and Programs (DURWP) related activities 66 NA March 7-8, 2018 Pre-NRC Inspection site audit conducted by ENERCON --Team (John Madera and Steven Brown) Monthly call between HMC and NRC PM (J. Whited) to 67 NA March 12, 2018 provide an update on the current status of --Confirmatory Order Actions. 9 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments Development and initial presentation of an initial and 68 NA March 14, 2018 annual refresher training program for all individuals Condition 7 of the CO engaged in Licensed activities 69 NA March 26-27, 2018 NRC conducts inspection of Site and CO-related activities.

--70 March 28, 2018 March 28, 2018 HMC submittal of Integrated Table of CO Actions to the ADAMS Accession No. MLJ8092A099 NRC. 2017 Annual Monitoring Report/Performance Review, in 71 NA March 29, 2018 accordance with NRC License No. SUA 1471 and New ADAMS Accession Nos. ML18102A955

& Mexico Environment Department DP-200 Ground Water ML18I02A970 Discharge Plan 72 NA April 3, 2018 San Andres Well 943 -Pump Test Report ADAMS Accession No. ML18117A230 73 NA April 5, 2018 Updated Semi-Annual Environmental Monitoring Report for ADAMS Accession No. ML18102A605 Period January-June 2017 Monthly call between HMC and NRC PM (J. Whited) to 74 NA April 11, 2018 provide an update on the current status of --Confirmatory Order Actions. Request for Variance from Condition No. 4, items B, C, and 75 NA April 11, 2018 D of the Confirmatory Order for Previously Submitted ADAMS Accession No. ML 18106A043 Zeolite and Groundwater Monitoring Plan License Amendments Grants Reclamation Project, Source Materials License SUA-76 NA April 26, 2018 1471, Notification of Unplanned Release per 10 CFR ADAMS Accession No. ML18128A282 40.60(b)(2) and License Condition 41 77 NA May 3, 2018 Homestake Mining Company of California

-NRC Inspection ADAMS Accession No. ML18115A480 Report 04008903/2018001 Monthly call between HMC and NRC PM (J. Whited) to 78 NA May 9,2018 provide an update on the current status of --Confirmatory Order Actions. 10 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments NRC Letter -NRC Staff Response to the Homestake Mining 79 NA May 10, 2018 Company of California Well 943 Hydrologic Test ADAMS Accession No. ML18120A331 Report. 80 NA May 14, 2018 HMC-Transmittal of2018 Financial Surety, IAWNRC ADAMS Accession No. ML18141A434 License SUA-1471, Condition 28 RE: Grants Reclamation Project, Source Materials License 81 NA May 16, 2018 SUA-1471:

Retraction of April 26, 2018 Notification of ADAMS Accession No. ML18142A238 Unplanned Release under 10 CFR 40.60(b)(2)

Requirements Grants Reclamation Project, Discharge Permit DP-200: 82 NA May 23, 2018 Notification of Unplanned Release and Corrective ADAMS Accession No. ML18145Al0I Actions Taken per Condition

55. RE: Grants Reclamation Project, Source Materials License 83 NA June 4, 2018 SUA-1471:

Impact Analysis of the March and April ADAMS Accession No. ML18159A037 2018 Exceedances of Groundwater Protection Standards in Injection Water Monthly call between HMC and NRC PM (J. Whited) to 84 NA June 13, 2018 provide an update on the current status of --Confirmatory_

Order Actions. NRC Letter -Results of the NRC Acceptance Review of 85 NA June 15, 2018 Homestake Groundwater Monitoring Plan License ADAMS Accession No. ML 18117 A2 l 8 Amendment Request NRC Letter -NRC Acceptance Review of Homestake 86 NA June 15, 2018 License Amendment Request to Add Zeolite Water ADAMS Accession No. ML18117A242 Treatment System NRC Letter Re: Clarification to 12/26/17 Letter and ADAMS Accession Nos. ML18107A034

& 87 NA June 15, 2018 Response to HMC Request for Variance to Relax Certain Order Conditions, EA-16-114 ML18109A075 88 NA June 19, 2018 HMC Letter -Grants Reclamation Project -Reseeding of ADAMS Accession No. ML18178A175 Former Land Application Areas 11 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Dat_e Completed Action Comments 89 NA July 2, 2018 HMC Letter -Transmittal of Final Status Survey Report for ADAMS Accession Nos. ML18186A567

& HMC Land Application Areas ML18186A568 90 NA ' July 16, 2018 NRC Letter -Results of.the NRC Acceptance Review of ADAMS Accession No. ML18177A319 Homestake 2018 Financial Surety License HMC Letter -Update to Corrective Action Plan for 5 91 NA July 17, 2018 Apparent Violations from the Root Cause Analysis per ADAMS Accession No. ML18200A068 2017 Confirmatory Order Modifying License No. SUA-1417, Condition 2 Monthly call between HMC and NRC PM (J. Whited) to 92 NA July 18, 2018 provide an update on the current status of --Confirmatory Order Actions. HMC Letter -Proposed Adjustment in Groundwater 93 NA July 26, 2018 Monitoring of the San Andres-Glorieta Aquifer near the ADAMS Accession No. ML18236A552 Grants Reclamation Project 94 NA July 27, 2018 , HMC Letter -Abandonment of San Andres Old Well # 1 ADAMS Accession No. ML18213Al82 95 NA July 30, 2018 HMC Letter -Design Work Plan for Re-lining EP-1 ADAMS Accession No. ML18227Al55 NRC Letter -Request for Additional Information

-96 NA July 31, 2018 Compliance of Homestake Grants, New Mexico Site ADAMS Accession No. ML18159A366 with 10 CFR20.1301 and 10 CFR20.1302 97 NA August 2, 2018 HMC Letter-EP-1 Engineering Design Work Plan ADAMS Accession No. MLI8227A154 NRC Letter -Request for Additional Information

-NRC 98 NA August 17, 2018 Review of Land Application Area Report and Final ADAMS Accession No. ML18205A460 Status Survey Semi-Annual Environmental Monitoring Report for Period 99 NA August 20, 2018 January-June 2018, in accordance with License No. ADAMS Accession No. MLI8240A228 SUA-1471, and New Mexico Environmental Department DP-200 Ground Water Discharge Plan 12 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) Due Date Date Completed Action Comments*

HMC Letter -Reply to Request for Additional Information 100 NA August 20, 2018 Concerning Compliance of Homestake Grants, New ADAMS Accession No. ML18240A143 Mexico Site with 10 CPR 20.1301 and 10 CPR 20.1302 Monthly call between HMC and NRC PM (J. Whited) to 101 NA August 22, 2018 provide an update on the current status of --Confirmatory Order Actions. NRC L~tter -Request for Additional Information

-NRC 102 NA August 23, 2018 Review of Homestake 2018 Financial Surety License ADAMS Accession No. ML18215A460 Amendment Request HMC submittal to NRC of HMC's Self-Assessment Report, Revised due date of September 3, 2018 approved by the NRC on December 26, 103 September 3, 2018 August 31, 2018 the third-party consultant's review report, and any 2017 modifications by HMC as a result of third-party

  • consultant's report ADAMS Accession Nos. MLl 8248A259 & MLl 8248A260 104 NA September 10-12, 2018 NRC conducts inspection of Site and CO-related activities.

--105 September 28, 2018 September 28, 2018 HMC submittal of Integrated Table of CO Actions to the TBD NRC. NRC is currently reviewing the September 106 -NRC review of Land Application Assessment.

25, 2017, land application assessment report and the July 2, 2018 Final Status Survey Report/or HMC Land Application Areas. HMC preparation of a Corrective Action Plan for Land HMC will submit within 60 days of NRC's 107 TBD Application Areas (if needed). approval ofHMC's land application assessment (if needed). Any changes or additions to the license or procedures resulting from this Confirmatory Order, HMC will 108 TBD either (1) submit to the NRC a license amendment HMC will submit to the NRC within 60 days request(s),for NRC approval, or (2) update the of receiving the results of NRC's audit(s).

appropriate HMC procedure(s) after notification of the NRC. 13 Integrated Confirmatory Order Actions Summary-Homestake Grants, NM Site (as of September 28, 2018) ' Due Date Date Completed Action Comments 109 January 1, 2019 HMC preparation of revised groundwater Corrective Action Extension request will be submitted to the Plan (CAP). ' ' NRC 110 January 1, 2020 NRC review Qj revised groundwater CAP. Extension request will be submitted to the NRC I Notes:

  • NA= Not applicable
  • TBD = To Be Determined
  • Bold, italicized text reflects actions designated in the Confirmatory Order
  • Accession numbers for documents available in NRC's Agencywide Documents Access and Management System (ADAMS) as of September 25, 2018 are provided.

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