ML19212A126
| ML19212A126 | |
| Person / Time | |
|---|---|
| Site: | |
| Issue date: | 07/31/2019 |
| From: | Lux J Environmental Properties Management |
| To: | Davis P, Robert Evans, Kenneth Kalman Document Control Desk, Office of Nuclear Material Safety and Safeguards, NRC Region 4, State of OK, Dept of Environmental Quality (DEQ) |
| References | |
| Download: ML19212A126 (7) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com July 31, 2019 Mr. Ken Kalman U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Paul Davis Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101 Mr. Robert Evans U.S. Nuclear Regulatory Commission 1600 East Lamar Blvd; Suite 400 Arlington, TX 76011-4511 Re: Docket No.70-925; License No. SNM-928 Scope of Work for Technetium-99 Groundwater Assessment
Dear Sirs:
During our April 4-5 meetings, the Nuclear Regulatory Commission (NRC) asked if the proposed discharge to the Cimarron River will comply with effluent limits stipulated in 10 CFR 20.2001, after applying the unity rule and including technetium-99 (Tc-99) in the calculation. In developing a response to that question, Environmental Properties Management, Inc. (EPM) reviewed historic documentation related to Tc-99 in groundwater at the Cimarron site (the Site) as well as historical concentration data for Tc-99, gross alpha, and gross beta. EPM provided a summary of the evaluation conducted based on that information in a letter dated May 3, 2019.
Prior to 2013 the previous licensee did not consider the presence of Tc-99 in groundwater an issue of importance because Tc-99 concentrations in groundwater were far below the NRC criterion of 3,790 pCi/L site-wide. Review of available data indicates that Tc-99 data is available across a very small portion of the Site, the quality of some of that data is questionable, and a substantial fraction of the data is at least 15 years old.
The existing data appears to be biased toward locations that yielded higher Tc-99 concentrations.
However, using the groundwater data that is available, and an influent flow rate-weighted averaging methodology, similar to that used to estimate influent concentrations for other contaminants, the concentration of Tc-99 in the influent to the Western Area Treatment Facility (WATF) is expected to be well below the drinking-water-standard equivalent of 900 pCi/L (EPA).
Based on data obtained from treatability testing performed in 2014, it appears that Tc-99 will be adsorbed by the ion exchange resin used for the removal of uranium from groundwater, possibly
Ken Kalman, et. al.
July 31, 2019 Page 2 resulting in non-detectable effluent Tc-99 concentrations. Because Tc-99 removal was not a focus of the previous treatability testing, the treatability testing data are insufficient for determining the degree of Tc-99 removal by ion exchange. Residual Tc-99 in the ion exchange effluent is expected to be captured by the biomass generated by the biodenitrification process.
However, residual Tc-99 passing through both the ion exchange and biodenitrification systems may or may not be detectable in the WATF effluent that will be discharged to the Cimarron River or injected in the western upland areas.
Due to the limited distribution of groundwater sample locations for which existing Tc-99 data are available, it is impractical to use the existing data set to develop a defensible estimate of the influent Tc-99 concentration for the WATF. Data that is distributed more broadly throughout all remediation areas is needed to better define the distribution of Tc-99 (and in the case of BA1, to confirm the absence of Tc-99) in groundwater, as well as to more defensibly estimate the potential concentration of Tc-99 in influent to the WATF. This information, in conjunction with a focused treatability test to evaluate the adsorption of Tc-99 onto the proposed ion exchange resin is needed to address issues related to the presence of Tc-99 in treated effluent water treatment waste materials. EPM proposes to collect groundwater samples from select monitor wells and submit those samples for analysis of gross alpha, gross beta, and Tc-99 activity.
Section 15 of the Radiation Protection Plan specifies the locations which must be sampled and the parameters which must be analyzed for the annual environmental monitoring program. Each year, water samples from 29 monitor wells and 2 surface water locations are collected and analyzed for gross alpha, gross beta, uranium (both mass and activity concentration), nitrate, and fluoride. Groundwater samples collected from these locations already include analysis for gross alpha and gross beta activity, so adding analysis for Tc-99 to some of those samples can provide a portion of the needed data with minimal additional cost and effort.
provides a list of sample locations and analytes that includes the locations and analytes for both the annual environmental monitoring program and proposed additional locations. Monitor wells locations for which uranium, nitrate, and fluoride analyses are listed are the annual environmental monitoring program locations. Analysis for Tc-99 will be added to eighteen (18) of those locations; with the addition of two (2) duplicate samples, a total of twenty (20) samples will be analyzed for Tc-99. The rest of the locations listed are the supplemental locations. These thirty-two locations will be analyzed only for gross alpha, gross beta, and Tc-99 activity concentrations; with the addition of three (3) duplicate samples, a total of thirty-five (35) samples will be analyzed for these parameters.
Adding analysis for Tc-99 to the cost of sampling and analysis for the 2019 annual environmental monitoring sampling locations increases the cost of this event by approximately
Ken Kalman, et. al.
July 31, 2019 Page 3
$2,300. The cost for the annual environmental monitoring program has always been allocated to Task 2, License Compliance, which is paid out of the Federal Environmental Cost Account (the Federal Account). EPM proposes to charge this additional $2,300 to the Federal Account.
The collection and analysis of groundwater samples from the additional locations will cost approximately $10,000 for labor and expenses, and approximately $7,000 for laboratory analysis. EPM proposes to assign these costs to Task 6, Unanticipated Work, because the need for additional Tc-99 data was not anticipated when the proposed budget for 2019 was prepared.
EPM proposes to allocate 93.2% of this cost to the Federal Account, and 6.8% of this cost to the State Environmental Cost Account.
The 50 locations to be sampled and analyzed for Tc-99 represent approximately 20% of the monitor wells on site; however, the results should provide a sufficient quantity and distribution of Tc-99 data to estimate the WATF Tc-99 influent concentration and to definitively assess the presence or absence of Tc-99 in groundwater in BA1. This data set will also provide information needed to prepare a scope of work for the treatability test referenced above. The data may also indicate a need for additional groundwater assessment for Tc-99.
Because it would be most cost-effective to collect samples from both the annual environmental monitoring and the supplemental locations simultaneously, EPM will move forward with the sampling and analysis as approved via e-mail by the DEQ on June 4, 2019, and the NRC on July 23, 2019. This proposal is a formal submittal of the scope of work, estimated cost, and allocation of funds presented in EPMs May 13, 2019 e-mail, and EPM assumes that no further response from the NRC or the DEQ is needed to proceed with the work.
Should you have any questions or desire clarification, please contact me at (405) 641-5152.
Sincerely, Jeff Lux, P.E.
Project Manager cc:
NRC Public Document Room (filed electronically)
Ken Kalman, et. al.
July 31, 2019 Page 4 ATTACHMENT 1 TECHNETIUM-99 GROUNDWATER ASSESSMENT LOCATIONS AND ANALYTES Technetium-99 Groundwater Assessment Locations and Analytes Area Location Gross /
EPA 900 (pCi/L)
Uranium HASL 300 (pCi/L)
Nitrate EPA 353.2 (mg/L)
Fluoride EPA 300.0 (mg/L)
Tc-99 HASL 300 (pCi/L) 02W27 1
1 1
1 1
02W42 1
1 1
1 1
1314 1
1 1
1 1
1 TMW-08 1
1 1
1 1
1 02W02 1
1 02W09 1
1 1
1 1
02W28 1
1 1
1 1
1315R 1
1 TMW-09 1
1 1
1 1
1 TMW-09 DUP 1
1 1
1 1
1 02W06 1
1 1
1 1
1 02W08 1
1 1
1 1
1 02W16 1
1 1
1 1
02W17 1
1 1
1 1
02W19 1
1 02W32 1
1 1
1 1
02W32 DUP 1
1 1
1 1
02W35 1
1 1
1 1
02W43 1
1 1
1 1
02W44 1
1 1
1 1
1 1363 1
1 TMW-13 1
1 1
1 1
1 TMW-24 1
1 BA1-A (Sandstone B)
BA1-B BA1-A (Transition Zone)
Page 1 of 3 Technetium-99 Groundwater Assessment Locations and Analytes Area Location Gross /
EPA 900 (pCi/L)
Uranium HASL 300 (pCi/L)
Nitrate EPA 353.2 (mg/L)
Fluoride EPA 300.0 (mg/L)
Tc-99 HASL 300 (pCi/L) 1319B-1 1
1 1319B-2 1
1 WU-1348 1348 1
1 1351 1
1 1
1 1
1 1351 DUP 1
1 1
1 1
1 1352 1
1 1
1 1
1 1354 1
1 1
1 1
1356 1
1 1
1 1
1 MWWA-03 1
1 1
1 1
1 MWWA-09 1
1 1
1 1
1 1312 1
1 1313 1
1 1313 DUP 1
1 1395 1
1 1396 1
1 1336A 1
1 1336A DUP 1
1 1337 1
1 1347 1
1 1387 1
1 1389 1
1 1401 1
1 1402 1
1 1346 1
1 1346 DUP 1
1 WU-BA3 1206-NORTH WU-PBA WU-UP1 WU-UP2 (Sandstone B)
WU-UP2 (Sandstone A)
Page 2 of 3 Technetium-99 Groundwater Assessment Locations and Analytes Area Location Gross /
EPA 900 (pCi/L)
Uranium HASL 300 (pCi/L)
Nitrate EPA 353.2 (mg/L)
Fluoride EPA 300.0 (mg/L)
Tc-99 HASL 300 (pCi/L)
T-70R 1
1 1
1 1
T-76 1
1 1
1 1
1 T-77 1
1 1
1 1
T-79 1
1 1
1 1
1 T-82 1
1 1
1 1
T-54 1
1 T-55 1
1 T-56 1
1 T-57 1
1 T-58 1
1 T-62 1
1 1
1 1
1 T-63 1
1 T-64 1
1 1
1 1
1 T-86 1
1 T-87 1
1 T-59 1
1 T-60 1
1 T-90 1
1 WAA-WEST T-97 1
1 1201 1
1 1
1 1
1 1202 1
1 1
1 1
1 RIVER WAA-BLUFF WAA-EAST WAA U>DCGL Page 3 of 3