ML19256A446
| ML19256A446 | |
| Person / Time | |
|---|---|
| Site: | 07000925 (SNM-0928) |
| Issue date: | 10/03/2019 |
| From: | Patricia Holahan Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Halliburton B Cimarron Environmental Response Trust, Environmental Properties Management |
| Kalman K | |
| References | |
| Download: ML19256A446 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 3, 2019 Mr. Bill Halliburton, Administrator Cimarron Environmental Response Trust c/o: Environmental Properties Management, LLC.
9400 Ward Parkway Kansas City, MO 64114
SUBJECT:
APPROVAL TO REALLOCATE FUNDS IN CIMARRONS 2019 BUDGET TO PERFORM A TECHNETIUM-99 BATCH TREATABILITY TEST
Dear Mr. Halliburton,
By letter dated September 12, 20191, the Cimarron Environmental Response Trust (CERT) requested approval to reallocate funds previously approved in the 2019 Cimarron Budget2 to fund a Batch Treatability Test (BTT) for Technetium-99 (Tc-99). This letter documents the U.S.
Nuclear Regulatory Commission (NRC) staffs approval of this request.
As noted in the September letter, CERTs evaluation of the presence of Tc-99 in groundwater, in relation to the planned water treatment process, has identified unanticipated potential radiological impacts to the 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 this resin will adsorb all the Tc-99 in the groundwater being treated or if some Tc-99 will remain in the effluent. The BTT would provide the additional data needed and may also confirm whether the bioreactor solids will need to be treated as low-level radioactive waste (LLRW).
To be conservative, CERT committed to use the worst-case scenario (bioreactor solids will accumulate Tc-99 and be disposed of as LLRW) in its 90% design for the water treatment and waste management systems. Therefore, the NRC staff will proceed with its detailed technical review of Cimarrons decommissioning plan and the radiation protection plan using this worst-case scenario assumption.
The 2019 Cimarron Budget had allocated $85,499.00 for Task 6 Out of Scope Work. Task 6 addresses unplanned work such as the Tc-99 BTT. However, the total estimated cost of the Tc-99 BTT is $96,431.00. To make up for the $10,932.00 increase, $11,000.00 of the
$1,181,000.00 approved in the 2019 Budget for Task 4 Site Decommissioning activities conducted by Veolia Nuclear Solutions - Federal Services (VNSFS) would be reallocated to Task 6 to fund VNSFS work on the Tc-99 BTT that was not included in the 2019 Cimarron Budget.
1 Agencywide Documents Access and Management System (ADAMS) Accession No ML19256A026 2 ADAMS Accession No. ML19108A272
The NRC staff reviewed the scope of work and estimated cost to perform the BTT for Tc-99.
We understand that this scope of work is generic and that a more detailed work plan will be finalized through collaboration with CERTs contractors.
The NRC staff approves CERTs request to reallocate funds as described in the September 12, 2019, letter. Please submit the detailed work plan and schedule for the Tc-99 BTT before beginning work related to the Tc-99 BTT.
In accordance with the Title 10 Code of Federal Regulations Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this letter, please contact Kenneth Kalman at 301-415-6664 or via email at Kenneth.Kalman@nrc.gov.
Sincerely, Patricia K. Holahan, Director Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 70-0925 License No.: SNM-928 cc: Cimarron Site Service List
B. VonTill*
B. Pham*
for P.Holahan DATE 9/16/19 9/19/19 9/23/19 10/3/19