ML19254A585
| ML19254A585 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 09/10/2019 |
| From: | Lux J Environmental Properties Management |
| To: | Kenneth Kalman Division of Decommissioning, Uranium Recovery and Waste Programs |
| Kalman K | |
| Shared Package | |
| ML19254A583 | List: |
| References | |
| Download: ML19254A585 (2) | |
Text
Batch Treatability Testing for Tc-99 Evaluation of the presence of technetium-99 (Tc-99) in groundwater in relation to the planned water treatment process has identified previously unanticipated radiological impacts to ion exchange resin and bioreactor solids. Previous treatability testing demonstrated that the ion exchange resin will adsorb Tc-99 but did not produce the data needed to determine if essentially all the Tc-99 in the groundwater that was treated was retained by the resin. Consequently, the potential for Tc-99 to be present in effluent from the proposed ion exchange system and the potential for Tc-99 to accumulate in bioreactor solids produced during biodenitrification needs to be evaluated.
Detection limit issues we addressed during our August 29th meeting result in a limitation to the information that can be gleaned from a treatability test. The treatability test may determine that bioreactor solids definitely will be categorized as low level radioactive waste (LLRW), but it cannot determine that bioreactor solids definitely wont be categorized as LLRW. Consequently, the 90%
design for the water treatment and waste management systems will accommodate the worst case scenario; that is, bioreactor solids will accumulate Tc-99 and be disposed of as LLRW.
Because the approved scope of work and budget for 2019 did not include treatability testing, approval of a scope of work and cost estimate must be approved to proceed with treatability testing. This e-mail provides a scope of work and estimated cost to perform batch treatability testing for Tc-99, with a proposed means to fund the treatability testing. The following scope of work is generic; a more detailed work plan will be finalized through collaboration with the laboratory after obtaining approval of scope and funding from the NRC and the DEQ.
It is our understanding that, because the design of decommissioning facilities and processes is based upon the worst case scenario (i.e., bioreactor solids are LLRW), treatability testing need not be completed for the NRC and the DEQ to initiate detailed technical review of the decommissioning plan and radiation protection plan.
Scope of Work Upon approval of the scope of work and funding, Veolia Nuclear Solutions -Federal Services (VNSFS) will generate a detailed work plan for treatability testing. Environmental Properties Management (EPM) and Burns & McDonnell Engineering Company, Inc. (BMcD) will review the work plan prior to submission to GEL.
Upon execution of a contract for treatability testing, GEL will obtain sufficient Ambersep 21K XLT to set up batch treatability tests.
Enercon Services (Enercon) will obtain groundwater from existing monitor wells selected jointly by VNSFS and BMcD based on historic data. A larger groundwater sample will be obtained from one selected well for sediment quantification. Groundwater samples will be shipped to GEL.
GEL will filter > 10 micron sediment from the larger sample to determine the quantity of > 10 micron sediment that may be filtered from in influent to the water treatment facilities.
GEL will filter > 10 micron sediment from each groundwater sample and acidify the filtrate to the design pH.
GEL will conduct batch tests for the groundwater from up to three wells in accordance with the treatability testing work plan.
VNSFS and EPM will receive the treatability test data from GEL. VNSFS will Q-review and evaluate the data and generate a draft report on the results of the treatability test.
EPM and BMcD will review and comment on the draft report.
VNSFS will produce a final report based on comments from EPM and BMcD.
EPM will submit the final treatability test report to the NRC and the DEQ.
EPM has received the estimated cost for each company to perform their portion of this scope of work. Both VNSFS and BMcD have already incurred costs for work performed. They reviewed the results of the 2013 treatability tests, estimated influent concentrations, evaluated the concentration of Tc-99 from the influent to the bioreactor to the bioreactor sludge, communicated with GEL regarding setting up batch tests, detection limits and costs, and communicated with Dupont about resin availability. The following cost estimates include approximately $17,000 in previously incurred costs for VNSFS and BMcD. Estimated costs by vendor are:
VNSFS - $35,000 GEL - $30,000 BMcD - $15,000 Enercon - $3,500 EPM - $6,000 Total cost - $89,500 The approved budget for 2019 already provides $85,499 in funding for Task 6, Unanticipated Work.
However, the approved budget states that unanticipated work cannot be performed without NRC and DEQ approval of a scope of work, estimated cost, and allocation of costs. Task 6 of the approved budget for 2019 already provides the following funding:
$15,499 for EPM costs
$50,000 for Subcontractor costs
$20,000 for Other Expenses EPM proposes that most of funding be assigned to existing funding for Task 6, and that the remaining needed funding be re-allocated from Task 4 Site Decommissioning to Task 6. EPM proposes to allocate the costs for treatability testing as follows:
VNSFS - Assign $20,000 to existing Subcontractor funding for Task 6 and re-allocate $15,000 from VNS-FS Support in existing Task 4 to Subcontractor funding for Task 6 GEL - Assign all $30,000 to existing Subcontractor funding for Task 6 BMcD - Assign all $15,000 to existing Other Expenses funding for Task 6 Enercon - Assign all $3,500 to existing Other Expenses funding for Task 6 EPM - Assign all $6,000 to existing funding for EPM on for Task 6 The net result of this proposal is that funding for only one line in Task 6, Subcontractor, is increased by
$15,000, and there is not net increase in authorized funding for 2019. Because requests for bids and evaluation of those bids will not be completed before the 2020 budget is approved, no funding needs to be added to the 2019 budget. EPM proposes that, as with other remediation costs, 93.2% of these costs be funded from the Federal Environmental Cost Account and 6.8% of these costs be funded from the State Environmental Cost Account. Upon approval of this scope of work and cost allocation, EPM will prepare and submit a schedule for treatability testing.