ML19218A351
| ML19218A351 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 08/06/2019 |
| From: | Lux J Environmental Properties Management |
| To: | Kenneth Kalman Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML19218A351 (16) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com August 6, 2019 Mr. Ken Kalman U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket No.70-925; License No. SNM-928 Comprehensive Set of Files for ADAMS
Dear Mr. Kalman:
Nuclear Regulatory Commission (NRC) personnel have requested access to numerous previously submitted documents to complete the technical review of the November 2018 Facility Decommissioning Plan - Rev 1 (the DP). Almost none of the documents requested for review and referenced in the DP are accessible in the Agencywide Document Access and Management System (ADAMS).
Environmental Properties Management LLC (EPM) provided electronic copies of the documents referenced in the DP on Universal Serial Bus (USB) flash drives during meetings conducted at NRC headquarters on April 4-5, 2019. However, the NRC prohibits the use of USB flash drives on its systems. On March 29, 2019, EPM placed electronic copies of those documents on a secure file sharing website, but the size of the files prevented NRC personnel from downloading those files. Finally, EPM sent electronic copies of the files on digital video disk (DVD), but computers issued to NRC personnel do not include compact disk (CD) or DVD drives.
Since the April meetings, it has been determined that in addition to documents referenced in the DP, there are other documents needed to complete the technical review of the DP. Numerous documents have been submitted to ADAMS through the NRCs Electronic Information Exchange (EIE); most were rejected, primarily because the resolution of the previously scanned images (hard copies are no longer available) is less than 300 dots per inch (dpi). These include:
- 1. Documents referenced in license conditions 10, 26, and 27(a).
- 2. Documents addressing the radiological survey of soils in Subarea F.
On Friday, August 2, 2019, you and Mr. Tony Conti contacted me to discuss alternative methods to gain access to these documents. The short-term goal is to provide a vehicle whereby NRC personnel can access these documents, even if not available in ADAMS. The long-term goal is to identify those documents which should be uploaded to the ADAMS public library and generate electronic copies which comply with the NRCs requirements for electronic submissions.
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 Page 2 Several alternatives were discussed, and it was concluded that the short-term goal may be most expeditiously achieved by EPM providing the NRC with a DVD containing electronic copies of all these files. The assumption is that NRC Information Technology (IT) personnel will scan the DVD for security protection and upload them to a server accessible only to NRC personnel.
Consequently, a DVD containing electronic copies of all the documents identified to date is enclosed with this letter. The DVD organizes those documents in five folders.
Folder Documents Reference in the DP This folder contains 69 documents (396 files) in three folders:
- 1. Confirmatory Survey Reports
- 2. Final Status Survey Plans & Reports
- 3. References Generated by the Licensee (in addition to final status survey plans and reports)
Folder License Condition Tie-Downs This folder contains the 58 documents (58 files) referenced in license conditions 10, 26, and 27(a) in three folders:
- 1. Condition 10 Tie-Downs
- 2. Condition 26 Tie-Downs
- 3. Condition 27(a) Tie-Downs Folder Submittals Since Feb 28, 2019 This folder contains 11 documents (21 files) which are directly related to the DP, and which were submitted to the NRC since the NRCs February 28, 2019 request for supplemental information.
Folder Other Submittals This folder contains 13 documents (29 files) which were submitted to the NRC since May 2017, but which have been rejected for uploading to ADAMS.
Folder Subarea F Soil Files This folder contains 15 documents (95 files) which provide information on the radiological survey of both surface and subsurface soil in Subarea F.
The NRC requested those documents because the re-defined licensed area proposed in the DP would require the release of most of Subarea F from the license. However, EPM has since
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 Page 3 revised the proposed re-defined licensed area to include all of Subarea F, so NRC personnel no longer need these documents for the technical review of the DP. However, some of those documents should be uploaded to ADAMS, so they were provided in the enclosed DVD.
Attachments 1 Through 5 Attachments 1 through 5 list the documents stored in the above folders. They are arranged by the date the document was submitted to the NRC and identify the accession number of each document that was submitted for uploading to ADAMS via the EIE.
- Documents for which an accession number is assigned have been submitted for uploading to ADAMS. Documents for which no accession number is assigned have not been submitted for uploading to ADAMS.
- Documents for which an accession number is assigned but the word Rejected is shown under the heading In Public Library? were submitted to ADAMS. However, they were rejected because they did not comply with the NRCs criteria for electronic submissions.
- Documents for which an accession number is assigned but the word NO is shown under the heading In Public Library? were submitted to ADAMS. However, although no notice of rejection was received, these documents are not available in the ADAMS public library. This may be because NRC personnel have not yet approved their inclusion to the public library.
- Several of the documents listed in Attachments 2 and 5 were also referenced in the DP; these were identified by the words (in DP Ref) following the document description.
- Three documents listed Attachment 2 were listed in both License Condition 10 and License Condition 26; these were identified by the words (also in Condition 10) following the document description.
It is understood that there may be no reason to upload some of the documents provided on the above-referenced DVD to ADAMS. For instance, many of the documents referenced in License Conditions 10, 26, and 27(a) refer to documents that have superseded them, to organization changes within previous licensees, etc. To achieve the long-term goal stated above, NRC personnel will identify those documents which should be uploaded to the ADAMS public library.
If the native-format (e.g., Microsoft Word, Microsoft Excel, etc.) files from which those submittals were generated exist within EPMs document repository, those documents may be convertible to.pdf-formatted files which can be accepted for uploading to ADAMS. If not, it may be possible to print those documents, scan them at a resolution of at least 300 dpi, and submit them for uploading to ADAMS via the EIE.
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 Page 4 Path Forward Regarding documents for which accession numbers are assigned and no rejection notice was received, EPM requests that NRC either approve their inclusion in the public library or notify EPM of their rejection due to non-compliance with NRC criteria for electronic submissions.
For those documents for which no accession number is assigned, EPM requests that the NRC inform EPM which documents will require submission to the ADAMS public library.
A copy of this letter (with enclosed DVD) is being provided to the Oklahoma Department of Environmental Quality (DEQ). A copy of this letter will also be provided to the NRCs Region IV office, but without the DVD, because these files will be made available to NRC Region IV personnel via NRCs server.
Please call me at 405-642-5152 should you desire clarification or additional information regarding this submittal. A copy of this letter, with attachments but without the electronic files contained on the DVD, will be submitted to the NRC for uploading to ADAMS.
Sincerely, Jeff Lux, P.E.
Project Manager Enclosure cc: Tony Conti, Nuclear Regulatory Commission Robert Evans, Nuclear Regulatory Commission Region IV (excluding the DVD)
Paul Davis, Oklahoma Department of Environmental Quality
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 ATTACHMENT 1 DOCUMENTS REFERENCED IN FACILITY DECOMMISSIONING PLAN - REV 1
Cimarron Environmental Response Trust Documents Referenced in Facility Decommissioning Plan - Rev 1 Document Date Description In Public Library?
Accession #
Date Submitted 12/1/1988 Decon and Decom of Plutonium Plant Rejected ML19100A140 4/10/2019 9/12/1989 Site Investigation Report NO 11/18/1991 Confirmatory Survey for Sanitary Lagoons Rejected ML19100A137 4/10/2019 11/25/1991 Final Status Survey Report for Burial Ground #1 NO 7/22/1992 Confirmatory Survey for Former Burial Ground Rejected ML19100A125 4/10/2019 7/7/1993 Final Status Survey Report for Coal-Warehouse Yard NO ML19100A120 4/10/2019 8/1/1993 Random Sampling of Backfilled Areas NO ML19100A113 4/10/2019 8/23/1993 Confirmatory Survey for Wet Ceramics Area Rejected ML19100A114 4/10/2019 1994-10-XX Radiological Characterization Report NO 10/24/1994 Final Status Survey Plan for Unaffected Areas Rejected ML19100A108 4/10/2019 10/31/1994 Confirmatory Survey for Two Soil Stockpiles Rejected ML19100A106 4/10/2019 4/19/1995 Site Decommissioning Plan NO 8/9/1995 Final Status Survey Report for Phase I Areas NO 11/13/1995 Confirmatory Survey for South Uranium Yard Rejected ML19100A105 4/10/2019 10/24/1995 Final Status Survey Plan for Phase II Areas NO 5/29/1996 Final Status Survey Report for Subarea L Subsurface Soil NO 3/12/1996 Confirmatory Survey - Phase I Areas NO ML19100A103 4/10/2019 6/24/1997 Final Status Survey Plan for Phase III Areas NO 9/5/1997 Final Status Survey Report for Subarea J NO 3/10/1998 Final Status Survey Report for Concrete Rubble in Subarea F NO 3/12/1998 Final Status Survey Report for Subarea O Subsurface Soil NO 7/27/1998 Final Status Survey Report for Subarea L Surface Soil NO 7/30/1998 Decommissioning Plan - Groundwater Evaluation Report NO 9/17/1998 Risk Assessment for Groundwater Rejected ML19100A097 4/10/2019 11/16/1998 Final Status Survey Report for Sub-Area H NO 12/31/1998 Final Status Survey Report for Subarea M YES ML19154A192 6/3/2019 2/9/1999 Final Status Survey Report for Subarea O Surface Soil NO 6/29/1999 Final Status Survey Report for Subarea I NO 10/21/1999 Final Status Survey Report for Subarea G NO August 5, 2019 Page 1 of 2
Cimarron Environmental Response Trust Documents Referenced in Facility Decommissioning Plan - Rev 1 Document Date Description In Public Library?
Accession #
Date Submitted 2/15/2000 Final Status Survey Report for Subarea K NO 2001-12-XX BTP Option 2 On-Site Disposal Cell Report NO 1/31/2002 Final Status Survey Report For Subarea N NO 3/31/2004 Uranium Travel Time and Max Concentration Rejected ML19100A094 4/10/2019 8/29/2005 Final Status Survey Report for Sub-Area F NO 6/20/2006 Dynamic Elution & Adsorption Studies NO 6/22/2006 ENSR Pump & Treat 30% Design NO 10/19/2006 Conceptual Site Model - Revision 1 NO 10/23/2006 Final Groundwater Modeling Report NO Burial Area 1 Subsurface Soils Report - Cover Letter Rejected ML19100A154 4/10/2019 Burial Area 1 Subsurface Soils Report - Appendix 1 Rejected ML19100A156 4/10/2019 Burial Area 1 Subsurface Soils Report - Appendix 2 Rejected ML19100A157 4/10/2019 Burial Area 1 Subsurface Soils Report - Appendix 3 Rejected ML19100A158 4/10/2019 Burial Area 1 Subsurface Soils Report - Appendix 4 Rejected ML19100A159 4/10/2019 Burial Area 1 Subsurface Soils Report - Figure 1 Rejected ML19100A160 4/10/2019 Burial Area 1 Subsurface Soils Report - Figure 2 Rejected ML19100A161 4/10/2019 Burial Area 1 Subsurface Soils Report - Figure 3 Rejected ML19100A163 4/10/2019 Burial Area 1 Subsurface Soils Report - Figure 4 Rejected ML19100A164 4/10/2019 Burial Area 1 Subsurface Soils Report - Figure 5 Rejected ML19100A165 4/10/2019 Burial Area 1 Subsurface Soils Report - Report Text Rejected ML19100A166 4/10/2019 3/30/2012 Sample & Analysis Plan NO ML19100A079 4/10/2019 3/15/2013 Hydrogeologic Pilot Test Report NO ML19099A476 4/9/2019 3/13/2013 Pneumatic Slug Testing NO ML19099A477 4/9/2019 4/26/2013 Site Health and Safety Plan for Cimarron Site NO ML19099A475 4/9/2019 9/30/2013 Quality Assurance Program Plan - Rev 2 NO ML19099A471 4/9/2019 5/8/2015 2014 Design Investigation Report NO ML19099A470 4/9/2019 9/30/2013 Quality Assurance Program Plan - Rev 2 NO 1/6/2014 Groundwater Flow Model Update NO 7/5/2016 Distribution Coefficient Determination NO 3/2/2017 2016 Groundwater Evaluation Rejected ML17303A765 10/30/2017 11/20/2007 August 5, 2019 Page 2 of 2
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 ATTACHMENT 2 DOCUMENTS REFERENCED IN LICENSE CONDITIONS 10, 26, AND 27(A)
Cimarron Environmental Response Trust Documents Referenced in License Conditions 10, 26, and 27(a)
Document Date Description In Public Library?
Accession #
Date Submitted 11/19/1985 License Amendment Request for 6000 kg of Th NO 3/3/1986 License Amendment Request for 6000 g of U NO 9/4/1987 License Amendment Request for On-Site Disposal of Soil NO 11/2/1989 List of Final Release Surveys for Plutonium Plant NO 8/22/1990 Request to Discontinue Effluent Release Report NO 9/14/1990 Permission to Discontinue Effluent Release Reports NO 6/24/1992 Miscellaneous Administrative Matters NO 2/25/1993 Information re On-Site Disposal of Soils NO 4/19/1994 Soil Disposal Plan NO 5/31/1994 Response to NRC Comments on Soil Disposal Plan NO 7/20/1994 Collecting Soil Samples to Estimate Kd NO 9/21/1994 Response to NRC Review of On-Site Soil Disposal NO 11/3/1994 Response to Concern re-Worker Exposure During Soil Disposal NO 11/15/1994 License Amendment Request to Delete Tie-Downs NO 12/16/1994 License Amendment Request for RSO Change NO 4/12/1995 Response to Comments on South U-Yard Remediation NO 6/5/1995 Resume for Karen Morgan NO 7/5/1995 South U-Yard Decontamination NO 7/25/1995 Final Status Survey Plan for Phase II Areas (in "DP Ref")
NO 8/9/1995 Final Status Survey Report for Unaffected Areas (in "DP Ref")
NO 11/13/1995 Response to NRC Comments on FSSR for Phase 1 Areas NO 1/23/1996 License Amendment Request for Organization Change NO 4/25/1996 Soil Characterization Procedure Change NO 6/10/1996 NRC Approves Soil Characterization Procedure Change NO 8/28/1996 DAP-4 Hot Spot Averaging NO 9/20/1996 Revised Annex A and License Amendment 14 Wording Request NO 11/20/1996 Lung Fluid Solubility Test NO 1/2/1997 Response to Comments on Radiation Protection Plan NO License Condition 10 August 5, 2019 Page 1 of 2
Cimarron Environmental Response Trust Documents Referenced in License Conditions 10, 26, and 27(a)
Document Date Description In Public Library?
Accession #
Date Submitted License Condition 10 1/28/1997 Response to Comments on Phase II Final Status Survey Plan NO 5/6/1997 Response to Comments on 1996 Decommissioning Plan NO 5/16/1997 Response to Comments on Radiation Protection Plan NO 12/5/1997 Response to Comments on Phase III Final Status Survey Plan NO 2/10/1998 Phase III Final Status Survey Plan (in "DP Ref")
NO 6/26/1998 Response to Comments on Phase III Final Status Survey Plan NO 7/2/1998 Response to NRC Comments from 7-01-98 Telecon NO 2/15/2000 Subarea K Final Status Survey Report (in "DP Ref")
NO 2/20/2001 Response to Comments on Subarea K Final Status Survey Report NO 4/17/2002 Decommissioning Schedule NO 5/10/2002 Decommissioning Schedule NO 9/20/1996 Revised Annex A and Amendment 14 (also in Condition 10)
NO 1/2/1997 Response to Comments on RPP (also in Condition 10)
NO 5/16/1997 Response to Comments on RPP (also in Condition 10)
NO 6/30/1997 Radiation Protection Plan Info for License Amendment Request NO 1/23/1998 License Amendment Request for Organization Change NO 6/29/1998 Response to NRC Comments on License Amendment Request NO 10/26/1998 Organizational Change and Guard Discontinuance NO 12/11/1998 Discontinuance of Security Guards NO 4/19/1995 1995 Decommissioning Plan (in "DP Ref")
NO 9/10/1996 Response to Comments on 1995 Decommissioning Plan NO 5/6/1997 Response to Feb 25 Comments on 1995 Decommissioning Plan NO 8/26/1997 Response to July 7 Comments on 1995 Decommissioning Plan NO 3/10/1998 Final Status Survey Report for Rubble in Sub-Area F (in "DP Ref")
NO 3/12/1998 Final Status Survey Report for Sub Area O - Subsurface (in "DP Ref")
NO 6/15/1998 Response to Comments on Subarea F Rubble FSSR NO 10/6/1998 Response to Comments on Residual Inhalation Dose from Rubble NO 3/4/1999 Response to Comments on D-Plan - Groundwater Evaluation Report NO License Condition 26 License Condition 27(a)
August 5, 2019 Page 2 of 2
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 ATTACHMENT 3 DOCUMENTS RELATED TO FACILITY DECOMMISSIONING PLAN - REV 1 SUBMITTED SINCE NRCS FEBRUARY 28, 2019 REQUEST FOR INFORMATION
Cimarron Environmental Response Trust Documents Related to Facility Decommissioning Plan - Rev 1 Submitted Since NRC's February 28, 2019 Request for Information Document Date Description In Public Library?
Accession #
Date Submitted 5/25/2017 Response to February 9, 2017 RAIs NO ML17164A243 6/13/2017 4/16/2019 Groundwater and Soil Characterization and Well Abandonment Scope of Work Rejected ML19106A169 4/16/2019 5/7/2019 Response to February 28, 2019 Request for Supplemental Information NO ML19129A290 5/9/2019 6/3/2019 CERT - Radiological Surveys of Subsurface Material NO ML19154A597 6/3/2019 7/10/2019 Revised Calculation of Potential Intake NO ML19204A021 7/23/2019 7/10/2019 Decommissioning Plan Figures Showing Subareas NO ML19204A022 7/23/2019 7/31/2019 Scope of Work for Technetium-99 Groundwater Assessment NO ML19212A126 7/31/2019 8/2/2019 Proposed Revisions to In-Process Monitoring & Waste Characterization NO ML19213A311 8/2/2019 August 5, 2019 Page 1 of 1
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 ATTACHMENT 4 OTHER DOCUMENTS SUBMITTED TO ADAMS
Cimarron Environmental Response Trust "Other" Documents Submitted to ADAMS Document Date Description In Public Library?
Accession #
Date Submitted 5/23/2017 Request for approval of change in scope of work for 2017 NO ML17143A106 5/23/2017 7/21/2017 Approval of change of 2017 scope of work NO ML17195A065 8/3/2017 4/18/2018 Cover Letter for U-235 Enrichment Levels for Groundwater NO ML19212A650 7/31/2019 5/25/2018 Notes on May 16-17 Meetings on 2017 Pilot Test & 1206 Drainage NO ML18165A403 6/14/2018 5/25/2018 Letter explaining 1206 Drainage Plans NO ML18165A411 6/14/2018 5/25/2018 2018-05-25 List of Changes to D-Plan NO ML18173A174 6/22/2018 6/18/2018 2018-06-18 EPM - Disposition of 1206 Drainage Sediment NO ML18171A317 6/20/2018 001 Pilot Test Rpt Text - Tables - Figures NO ML18171A300 6/20/2018 002 Pilot Test Rpt - Appendices A - M NO ML18171A305 6/20/2018 003 Pilot Test Rpt - Appendix N NO ML18171A309 6/20/2018 004 Pilot Test Rpt - Appendices O - W NO ML18171A310 6/20/2018 005 Pilot Test Rpt - Appendices X - AA NO ML18171A316 6/20/2018 NO ML18180A248 6/29/2018 NO ML18282A355 10/9/2018 12/7/2018 Pilot Test Frac Tank Summary NO ML18347A464 12/13/2018 NO ML19021A010 1/21/2019 NO ML19024A019 1/24/2019 NO ML19024A420 1/24/2019 NO ML19032A019 2/1/2019 2/1/2019 Report of 27(e) Changes in 2018 NO ML19036A654 2/1/2019 Notes from Meetings Conducted April 4-5, 2019 YES ML19148A543 5/28/2019 Remediation Overview Presentation 4/4/19 Meeting NO ML19085A542 5/28/2019 Water Treatment Presentation 4/4/19 Meeting NO ML19085A544 5/28/2019 Radiation Protection Presentation 4/4/19 Meeting NO ML19085A545 5/28/2019 Treated Water Discharge & Injection Presentation 4/4/19 Meeting NO ML19085A546 5/28/2019 Pre-Construction & Construction Presentation 4/4/19 Meeting NO ML19085A547 5/28/2019 Remediation Duration Presentation 4/4/19 Meeting NO ML19085A548 5/28/2019 Post Decommissioning & Savings Presentation 4/4/19 Meeting NO ML19085A549 5/28/2019 6/19/2018 5/23/2019 Treatability Testing of Ion Exchange Resin in 2019 1/18/2019 6/29/2018 Mass concentration vs. activity August 5, 2019 Page 1 of 1
Mr. Ken Kalman U.S. Nuclear Regulatory Commission August 6, 2019 ATTACHMENT 5 DOCUMENTS RELATED TO SOIL IN SUBAREA F
Cimarron Environmental Response Trust Documents Related to Soil in Subarea F Document Date Description In Public Library?
Accession #
Date Submitted 11/25/1991 Burial Ground #1 Final Status Survey Report (in "DP Ref")
NO 1/25/1994 Survey of Burial Ground #1 and Sanitary Lagoons Backfill NO 3/10/1998 FSSR for Concrete Rubble in Subarea F (in "DP Ref")
NO 11/20/2007 Subarea F Subsurface Soils Report (in "DP Ref")
NO 1/23/2008 Burial Area #1 Subsurface Soil Data NO 8/25/2016 Report on Subarea F Soil Outside of Proposed Licensed Area NO 3/1/1999 NRC Comments on Final Status Survey Report for Subarea F NO 9/8/2005 Final Status Survey Report for Subarea F (in "DP Ref")
NO 12/21/2005 NRC Comments on Final Status Survey Report for Subarea F NO 3/8/2006 NRC Comments on Response to NRC Comments NO 3/12/2012 Unresolved Issues - Tc-99 and Subarea F Soil NO 7/2/2012 NRC Inspection Report 070-00925/12-001 NO 9/7/2012 Release of Subarea F Rubble NO 8/31/2016 E-mail Requesting Feedback on Key Issues NO August 5, 2019 Page 1 of 1