ML19284A853
| ML19284A853 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 09/19/2019 |
| From: | Lux J Environmental Properties Management |
| To: | Davis P, Robert Evans, Kenneth Kalman Division of Decommissioning, Uranium Recovery and Waste Programs, NRC Region 4, State of OK, Dept of Environmental Quality (DEQ) |
| Kalman K | |
| References | |
| Download: ML19284A853 (5) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com September 19, 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 Schedule for Review and Approval of the Site Decommissioning Plan
Dear Sirs:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a draft schedule for the review and approval of Facility Decommissioning Plan - Rev 1 (the DP).
During an August 29, 2019 meeting with the US Nuclear Regulatory Agency (the NRC) and the Oklahoma Department of Environmental Quality (the DEQ), the NRC provided EPM a schedule for the review of information, issuance of RAIs, response to RAIs, review of responses, all the way through approval of the decommissioning plan. That schedule provided durations for activities in calendar days; consequently, some activities take place during the weekend.
That schedule was transferred to a Microsoft Project schedule, changing durations from calendar days to working days; this prevented activities from being scheduled during the weekend. This schedule maintains durations and finish dates as closely as is reasonable to the schedule provided to EPM during the meeting. This schedule is provided herein as Attachment 1.
The NRCs schedule started at the beginning of January, assuming that all the submittals needed to initiate their detailed technical review would have been received by January 1, 2020. Burns &
McDonnell Engineering Company, Inc., Veolia Nuclear Solutions-Federal Services, and Enercon Services Inc. provided schedules for the development and submission of the following documents. It is our understanding that the NRC must receive all the following documents before they can initiate the detailed technical review of the DP:
Mr. Ken Kalman, et. al.
U.S. Nuclear Regulatory Commission September 19, 2019 Page 2
- 1. A report on the revision of groundwater flow models to assess the potential impact of shortened extraction well screens on the capture zone.
- 2. A report on the assessment of Tc-99 in groundwater, including an updated estimate of the anticipated initial concentration of Tc-99 in the influent(s) to the water treatment system(s).
- 3. A report on the vertical distribution of uranium and/or nitrate in the Western Alluvial Area and Burial Area #1 at proposed extraction well locations.
- 4. Revisions to Appendix J, the 60% design drawings for groundwater remediation facilities (the 90% drawings).
- 5. Revisions to Appendix K, the 60% design drawings for groundwater treatment facilities (the 90% drawings).
- 6. A report addressing the need to specifically list Tc-99 in the license.
- 7. Proposed revisions to the Radiation Protection Plan (also the Decommissioning Plan) based on a detailed review of NUREG-1757.
Number 6 listed above was included in this schedule. It is believed that Tc-99 will not need to be specifically listed in the license. However, for the sake of completeness, this activity was included in the schedule because if Tc-99 does need to be specifically listed, the listing of Tc-99 could derail the schedule completely.
The finish dates of the seven activities listed above (except for activity #6) were assigned as predecessors to the start date for the detailed technical review of the DP. As a result, the start date for the detailed technical review has been pushed back approximately three months. EPM will strive to accomplish these activities in less time; it may be possible to complete the vertical profiling effort a month or more earlier than the schedule shows. However, all three companies provided EPM dates they were confident they could achieve, and EPM cannot commit them to a deadline they arent confident they can achieve.
Redefinition of the licensed area is not included in this schedule because it is no longer a part of the decommissioning plan review. That would require another set of both CERT and agency tasks. If you would like to prepare a separate schedule for the issuance of that license amendment, Id be happy to collaborate with you on that as well.
(the rest of this page was left blank intentionally.)
Mr. Ken Kalman, et. al.
U.S. Nuclear Regulatory Commission September 19, 2019 Page 3 As always, please feel free to contact me at 405-642-5152 if you have questions or would like to discuss this.
Sincerely, Jeff Lux, P.E.
Trustee Project Manager Attachment cc: NRC Public Document Room (electronic copy only)
ATTACHMENT 1 SCHEDULE FOR REVIEW AND APPROVAL OF FACILITY DECOMMISISONING PLAN - REV 1
ID Task Name Duration Start Finish Predecessors 1
CERTSubmittals 162days Mon8/26/19 Tue4/7/20 2
RevisionstoAppendixMGroundwaterFlow ModelUpdate 76days Thu9/19/19 Thu1/2/20 3
Tc99GroundwaterAssessment 93days Mon8/26/19 Wed1/1/20 4
Tc99GroundwaterSampling 10days Mon8/26/19 Fri9/6/19 5
Tc99GroundwaterLaboratoryTAT 19days Mon9/9/19 Thu10/3/19 4
6 Tc99GroundwaterAssessmentReport 64days Fri10/4/19 Wed1/1/20 5
7 VerticalProfiling 147days Mon9/16/19 Tue4/7/20 8
AccessRoadBidding,Contracting,Construction 71days Mon9/16/19 Mon12/23/19 9
VerticalProfilingBidding,Contracting,FieldWork 15days Thu1/2/20 Wed1/22/20 10 VerticalProfilingLaboratoryTAT 19days Thu1/23/20 Tue2/18/20 9
11 VerticalProfilingReport 35days Wed2/19/20 Tue4/7/20 10 12 RevisionstoAppendixJ1throughJ6;BMcD90%
DesignDrawings 15days Wed3/18/20 Tue4/7/20 11FF,2 13 RevisionstoAppendicesK1throughK7;VNSFS 90%DesignDrawings 79days Thu9/12/19 Tue12/31/19 14 Tc99LicensingLetter 50days Mon9/16/19 Fri11/22/19 15 RevisionstoDraftRPPRev.4 65days Mon9/16/19 Fri12/13/19 16 IssueSafetyandEnvironmentalRAIstoCERT 112days Wed4/8/20 Thu9/10/20 17 Staffbeginsdetailedtechnicalreview 0days Wed4/8/20 Wed4/8/20 2,6,12,13,15 18 PMreceivessafetyandenvironmentalRAIs 64days Wed4/8/20 Mon7/6/20 17 19 PMsubmitsRAIstoBC 20days Tue7/7/20 Mon8/3/20 18 20 MPobtainsBCcommentsonRAIs 9days Tue8/4/20 Fri8/14/20 19 21 PMresolvesBCcommentsonRAIs 16days Mon8/17/20 Mon9/7/20 20 22 PMissuesRAIs 3days Tue9/8/20 Thu9/10/20 21 23 DraftEA,SER,andDraftLicense 246days Fri9/11/20 Fri8/20/21 24 CERTrespondstoRAIs 42days Fri9/11/20 Mon11/9/20 22 25 StaffacceptancereviewofRAIresponses 15days Tue11/10/20 Mon11/30/20 24 26 StaffsubmitsdraftSERtoPM 58days Tue12/1/20 Thu2/18/21 25 27 PMrespondstostaffdraftSER 25days Fri2/19/21 Thu3/25/21 26 28 PMdevelopsdraftlicense 25days Fri3/26/21 Thu4/29/21 26,27 29 StaffresolvesPMcomments 20days Fri4/30/21 Thu5/27/21 27,28 30 PMsubmitsSERanddraftlicensetoBC 40days Fri5/28/21 Thu7/22/21 29 31 BCreviewsSERanddraftlicense 10days Fri7/23/21 Thu8/5/21 30 32 PMresolvesBCcommentsonSERanddraftlicense 10days Fri8/6/21 Thu8/19/21 31 33 PMsubmitsSERanddraftlicensetoOGC 1day Fri8/20/21 Fri8/20/21 32 34 OGCReviewtoIssuanceofLicense 188days Mon8/23/21 Wed5/11/22 23 35 OGCcommentsonSERanddraftlicense 30days Mon8/23/21 Fri10/1/21 33 36 PMresolvescommentsandobtainsNLO 15days Mon10/4/21 Fri10/22/21 35 37 PMsubmitsSERanddraftlicensetoBC 1day Mon10/25/21 Mon10/25/21 36 38 BCreviewsSERanddraftlicense 15days Tue10/26/21 Mon11/15/21 37 39 PMresolvesBCcommentsonSERanddraftlicense 10days Tue11/16/21 Mon11/29/21 38 40 DUWPemailsdraftlicensetoCERT 1day Tue11/30/21 Tue11/30/21 39 41 CERTsubmitsinputondraftlicense 10days Wed12/1/21 Tue12/14/21 40 42 DUWPaddressesCERTcommentsondraftlicense 15days Wed12/15/21 Tue1/4/22 41 43 CERTconsentstodraftlicense 15days Wed1/5/22 Tue1/25/22 42 44 BCconcursonSERandfinallicense 10days Wed1/26/22 Tue2/8/22 43 45 PMtransmitsSERandfinallicensepackagetoDD 1day Wed2/9/22 Wed2/9/22 44 46 DDcommentsonSERandfinallicense 15days Thu2/10/22 Wed3/2/22 45 47 PMresolvesDDcommentsonSERandfinallicense 15days Thu3/3/22 Wed3/23/22 46 48 PMresolvesDDcommentswithOGC 15days Thu3/24/22 Wed4/13/22 47 49 PMfinalizesSER 15days Thu4/14/22 Wed5/4/22 48 50 PMissuesamendedlicense 5days Thu5/5/22 Wed5/11/22 49 4/8 Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May 2019 Qtr 4, 2019 Qtr 1, 2020 Qtr 2, 2020 Qtr 3, 2020 Qtr 4, 2020 Qtr 1, 2021 Qtr 2, 2021 Qtr 3, 2021 Qtr 4, 2021 Qtr 1, 2022 Qtr 2, 2022 CERT DECOMMISSIONING PLAN APPROVAL SCHEDULE Page1