ML19357A145
| ML19357A145 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 11/02/2018 |
| 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) |
| Shared Package | |
| ML19352E486 | List: |
| References | |
| Download: ML19357A145 (5) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com November 2, 2018 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 Submission of Facility Decommissioning Plan - Rev 1
Dear Ladies and Gentlemen:
Environmental Properties Management LLC (EPM) submits herein as a license amendment request Facility Decommissioning Plan - Rev 1 (the Plan). This document is submitted as a license amendment request, and although the decommissioning plan is a license amendment request, it includes license-condition-specific amendment requests in Section 6 of the Plan.
Facility Decommissioning Plan was submitted to the NRC on December 31, 2015. In a letter dated April 7, 2016, NRC stated, additional information is needed before the DP can be accepted for detailed technical review. The additional information requested in that letter was provided in a May 20, 2016 submittal. In a letter dated September 6, 2016, NRC stated, The NRC staff has completed its administrative review of the December 31, 2015 and the May 20, 2016 submittals and has accepted the DP for detailed technical review.
Following detailed technical review, the NRC sent RAIs in a letter dated February 9, 2017. EPM provided responses to the RAIs in submittals dated May 25, 2017 and July 14, 2017. Although NRC never formally responded to those submittals, a November 28, 2017 e-mail stated, Response to February 9, 2017 Request for Additional Information, dated May 25, 2017, The NRC staff has no questions regarding the approaches proposed by the licensee to address the groundwater and remedial design related requests for additional information (RAIs) associated with the Cimarron Site Decommissioning Plan (DP).
Since NRC acceptance of the responses to RAIs, EPM directed several activities to reduce cost to decommission or stated uncertainty associated with the groundwater remediation plan.
Mr. Ken Kalman U.S. Nuclear Regulatory Commission November 2, 2018 Page 2 Plan Revisions Not Associated with Achieving the Decommissioning Criteria The groundwater remediation design in the 2015 Facility Decommissioning Plan was prepared, at the direction of the NRC and the DEQ, with the goal of reducing the concentration of all chemicals of concern (COCs) in groundwater in all areas in which NRC and/or State Criteria were exceeded. The decommissioning cost estimate provided in that plan indicated that funding was not sufficient to achieve both NRC and State Criteria in all areas. EPM proposed, and the NRC and the DEQ approved, the removal of much of the infrastructure in the Cimarron River floodplain from the design which was to be used for remediation of groundwater that only exceeded the State Criteria. The revised infrastructure significantly reduced the recovery and treatment of groundwater that already complies with decommissioning criteria but exceeded the State Criteria. The reduction in influent flow resulted in the elimination of one ion exchange treatment system and one biodenitrification system. This change is related only to the remediation of groundwater that already complies with the NRC decommissioning criterion. It has no impact on the decommissioning the site to achieve termination of the NRC license.
Quarterly sampling of groundwater samples demonstrated that the concentration of COCs in groundwater in the area surrounding Burial Area #2 (BA2) had declined to less than both NRC and State Criteria for uranium in groundwater. The NRC and the DEQ approved the removal of infrastructure from the groundwater remediation design for this area. This change is related only to the remediation of groundwater that already complies with the NRC decommissioning criterion. It has no impact on the decommissioning the site to achieve termination of the NRC license.
In the 2015 decommissioning plan, the Western Area Treatment Facility (WATF) was to be constructed over treated water injection trenches in the Uranium Pond #1 area. To alleviate construction scheduling issues, reduce geotechnical issues associated with constructing the facility over operating trenches, and enable addition to or maintenance of injection infrastructure, EPM proposed, and the NRC and the DEQ approved, the relocation of the WATF away from those injection trenches. The relocation of the WATF does not impact the licensees ability to decommission the site, and both agencies have already approved the relocation.
In the 2015 decommissioning plan, influent concentrations were calculated from analytical results for COCs in groundwater for samples collected that year. Those concentrations were the
Mr. Ken Kalman U.S. Nuclear Regulatory Commission November 2, 2018 Page 3 basis for the determination of projected remediation durations, quantities of waste generated, etc.
In 2016, review of historical data showed that COC concentrations in 2015 were anomalously low compared to previous years. Influent concentration estimates were revised, based on 95%
upper confidence level COC concentrations calculated using data obtained over multiple years.
Use of these higher concentration values resulted in higher COC concentrations. The use of these higher concentrations reduces the uncertainty associated with projecting the duration of remediation. Use of these higher concentrations did not result in any change to the groundwater remediation infrastructure or treatment system design.
The design of the biodenitrification system was simplified and relocated to within the WATF.
The biodenitrification system is needed only to comply with groundwater remediation and discharge limits set by the DEQ. Modifying the biodenitrification system has no impact on the decommissioning of the site to achieve termination of the NRC license.
Plan Revisions Related to Achieving the Decommissioning Criteria Review of historical soil data from the 1206 Drainage triggered additional investigation, and it was determined that excavation of sediment that complies with the decommissioning criterion for soil will significantly expedite the remediation of groundwater in this area. EPM proposed, and the NRC and the DEQ approved, the excavation of this sediment. The revision of the Plan to reflect this change has already been reviewed and approved.
According to the 2015 decommissioning plan, the first phase of construction was to involve constructing portions of the groundwater extraction and injection infrastructure. A pilot test would be conducted to determine if extraction and injection rates developed through groundwater flow modeling could be achieved. If not, construction would be halted, and the infrastructure would be re-designed based on the results of the pilot testing. NRC recommended that a pilot test be conducted prior to the submittal of this Plan so that if design changes were needed, they would be in the decommissioning plan approved by the agencies. Pilot tests were conducted in late 2017 and early 2018, and the data obtained indicated that estimates of groundwater extraction rates were greatly over-estimated, while treated water injection rates were greatly under-estimated. A report on the pilot test was submitted to the NRC and the DEQ in June 2018.
Mr. Ken Kalman U.S. Nuclear Regulatory Commission November 2, 2018 Page 4 The pilot test results triggered a re-evaluation of the area within Burial Area #1 (BA1) in which the groundwater extraction trench was installed for the pilot test. Enhanced 3-dimensional modeling of the subsurface lithology was performed. A report presenting the results of the 3-dimensional modeling was submitted to the NRC and the DEQ in April 2018.
As a result of the pilot test, the following changes were made to the groundwater remediation design:
In BA1, one groundwater extraction injection trench was relocated from Sandstone B to the Transition Zone In BA1, two treated water injection trenches were relocated in Sandstone B to enhance the head pressure on groundwater migrating to groundwater extraction trenches In the Uranium Pond #1 area, treated water injection trenches were relocated and approximately 500 feet of injection trench was eliminated In the Uranium Pond #2 area, approximately 400 feet of treated water injection trenches were eliminated The first two changes are related to the remediation of groundwater to comply with the decommissioning criteria for groundwater. The last two are related to the remediation of groundwater to achieve the State Criteria for groundwater; groundwater in these areas already comply with the NRC decommissioning criteria.
Multiple reports, meetings, and teleconferences have been conducted with both the NRC and the DEQ to ensure that agency personnel are familiar with these revisions to the decommissioning plan, and to provide opportunity for agency personnel to request additional information.
This Plan contains:
The information that was presented in the 2015 decommissioning plan, with revisions already presented to the NRC and the DEQ All the information that was requested during the acceptance review of the 2015 decommissioning plan
Mr. Ken Kalman U.S. Nuclear Regulatory Commission November 2, 2018 Page 5 All the information to which the May 2017 response to RAIs committed, and which the NRC accepted as sufficient Additional information related to material control and accountability, groundwater monitoring, remediation duration estimates, etc.
As Trustee for the Cimarron Environmental Response Trust, EPM is very conscientious of the cost of delay. This Plan contains significantly more information than the 2015 decommissioning plan, including all the information which NRC required to complete the acceptance review of that submittal.
The decommissioning cost estimate provided in this Plan indicates that, with the addition of a 25% contingency, the remaining funds are not sufficient to achieve license termination. Every month spent added to the schedule presented in Section 9 of this Plan reduces the available funding.
In submitting this Plan, EPM is withdrawing the 2015 Facility Decommissioning Plan as instructed. EPM requests that NRC expedite the review process for this Plan to the extent possible.
Sincerely, Jeff Lux, P.E.
Project Manager Enclosure cc: Michael Broderick, Oklahoma Department of Environmental Quality