ML20014E732
| ML20014E732 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 01/13/2015 |
| From: | - No Known Affiliation |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML20014E732 (9) | |
Text
NRC - DEQ - EPM Telecon Notes May 12, 2015 (Red text indicates who will take the next action) 1 of 2 Attendees Ken Kalman Paul Davis Jeff Lux Varughese Kurian David Cates John Hesemann Lifeng Guo Micheal Jordan Gerald Schlapper Pam Dizikes Torrie Wale Administrative Issues 2016 Budget - EPM submitted a draft proposed budget for 2016 (Revision 1) to NRC and DEQ via e-mail on February 8th. Submittal of the revised budget had been delayed due to the identification of waste processing and disposal alternatives. Addition of funding to provide for waste processing alternatives was considered, but evaluation of potential cost savings to the Trust eventually ruled out pursuing those alternatives. Upon approval of Revision 1, the proposed budget will be submitted to all parties identified in the Trust Agreement as a final budget. NRC and DEQ 2015 Q4 Financial Report EPM sent the financial report for year-end and 4th quarter 2015 to NRC, DEQ, EPA and DOJ on January 29th. An electronic copy will be sent to Ken Kalman and Paul Davis via e-mail. EPM JP Morgan Letter re: Resignation as Trustee for Standby Trust NRC sent a letter accepting the resignation of Bank One Trust Company (now known as J.P.
Morgan Chase Bank) as Trustee for the Cimarron Standby Trust Fund on January 13, 2016. No further action required.
Kurion Treatability Test Report DEQ noted that the treatability test report submitted November 2015 had a note in the footer of each page reading CONFIDENTIAL AND PROPRIETARY. The information in the report does not appear to warrant such a designation. EPM will contact Kurion to see if this footer was inadvertently applied, or if there is information in the report that should be treated as proprietary information. EPM Groundwater Design Issues Decommissioning Plan A decommissioning plan for the Cimarron site was submitted to NRC and DEQ on December 31, 2015. The decommissioning plan addresses all groundwater remediation activity through the point when the NRC license can be terminated. NRC pointed out that three years of post-remediation monitoring had been discussed rather than eight. EPM will check to see if the Decommissioning Plan provides for at least 12 quarters of post-remediation monitoring. EPM Quarterly Groundwater Sampling An activity plan has been prepared for the sampling and analysis of over 40 monitoring wells at the Cimarron Site. NRC requested a list of the sampling locations and analytes. NRC also requested that depth-to-groundwater be measured in all wells on Site each quarter. EPM
NRC - DEQ - EPM Telecon Notes May 12, 2015 (Red text indicates who will take the next action) 2 of 2 Sampling and Analysis for Plutonium The activity plan for quarterly groundwater sampling will include collection of groundwater from Monitor Wells 1331 and 1377 for plutonium analysis. EPM License Issues Personnel on Site EPM noted that NRCs attorney recently interpreted the reference to personnel in License Condition 27(d) to mean personnel employed by the Licensee, not personnel who are retained by the licensee. This was based on the absence of language referring to authorized personnel.
However, contractors retained by the Licensee have been the only personnel on site most of the time since 2007, and no observation regarding compliance with License Condition 27(d) was identified in any of the six NRC inspections performed since then. EPM will review License Condition 27 (including the section on the composition of the ALARA Committee) to determine if there is justification in the license for a different interpretation of License Condition 27(d).
EPM Dose Model On November 11, EPM sent a dose model to NRC via e-mail. The document calculated the potential dose that would result from harvesting grass at the Site for cattle feed. NRC requested that the dose model be submitted formally, and the dose model was submitted in both hard copy and electronic formats on December 9, 2015. EPM is waiting on NRC concurrence with this dose model before pursuing a potential lease agreement for mowing and harvesting grass from the Site. NRC NRC Inspection An NRC inspection, coupled with a meeting to walk through the decommissioning plan, is tentatively schedule for the week of April 25th. NRC
NRC - DEQ - EPM Telecon Notes November 1, 2016 (Red text indicates who will take the next action) 1 of 4 Attendees Ken Kalman Paul Davis Jeff Lux Lifeng Guo David Cates Bill Halliburton Alan Bjornsen Mike Broderick John Hesemann Bob Nelson Jordan Caldwell Gerald Schlapper Torrie Wale Don Stearns Mike Stickney Administrative Issues Proposed 2017 Budget - A draft budget for 2017 was submitted to NRC and DEQ on October 25th. Based on comments from NRC and DEQ, EPM sent alternative schedule scenarios to NRC and DEQ in an e-mail dated October 28th. EPM will send an e-mail describing the revised schedule and proposing to divide Task 4 into Tasks 4a and 4b. NRC and DEQ will approve or comment on EPMs approach, and EPM will submit a revised budget proposal. EPM e-mail, then NRC & DEQ comment, then EPM re-submit.
2016 Q3 Financial Report - The financial report for the third quarter of 2016 was sent to NRC and DEQ on October 31st. No further action needed Sale of Southwest Quarter of Section 12 - In letters dated June 17th and June 20th, DEQ and NRC (respectively) agreed to pursue the sale of the southwest quarter of Section 12 to Mr. Tom Stewart. After internal legal review of a draft sale agreement was completed, EPM submitted the draft sale agreement to NRC and DEQ for review on August 17th. The southwest quarter section was surveyed, and a plat and legal description of the property was received by EPM on October 7th. EPM needs NRC and DEQ comment on, or approval of, the sale agreement to proceed with the sale of the property. NRC & DEQ please review and comment or approve.
Bob Sands Request for Q3 Data - Bob Sands is a reporter for OETA (public television station) in Oklahoma City. He receives the quarterly public information updates, and requested a copy of the results for the third quarter groundwater sampling event on October 19th. EPM sought guidance on how to respond to this request on October 21st. EPM met with Mr. Sands October 31st, and provided an overview of the DP, the upcoming revision, and the 3rd quarter data (with explanation of the reason for and meaning of the data). No further action required.
Licensing/Permitting Issues Annual Environmental Monitoring Data - Groundwater samples were collected from 29 monitor wells and surface water samples were collected from the Cimarron River upstream and downstream from the site. Samples were collected from May 9th through May 12th in conjunction with the second quarter groundwater sampling event. Laboratory results for the annual environmental samples were submitted to NRC and DEQ via e-mail July 8th. No further action needed Subsurface Soil in Subarea F - During meetings conducted in June, NRC noted that, if the area in Subarea F that will remain under license is only a portion of Subarea F, amending the license
NRC - DEQ - EPM Telecon Notes November 1, 2016 (Red text indicates who will take the next action) 2 of 4 would in effect release a portion of Subarea F for unrestricted use when NRC has not documented that the area complies with decommissioning criteria. NRC requested that EPM submit subsurface soil data for that portion of Subarea F that would not be under license. EPM sent a report providing both soil and groundwater data for the portion of Subarea F that would not be under license on August 31st. DEQ stated that DEQ has no objections to the letter or report, and that this is a matter between the Licensee and NRC in a letter dated October 4th.
NRC review is needed, because if any additional sampling and analysis is required, this is a multi-month impact. NRC needs to comment on the completeness of the data set.
OPDES permit application modification - DEQ sent a Notice of Deficiency (NOD) on October 4th. The NOD stated that replacement pages reflecting changed flow rates and influent concentrations must be submitted as a modification of the permit application. Revision of groundwater flow models, needed for calculation of influent concentrations, is complete.
Calculations of influent concentrations should be complete within another two weeks. Revised pages for the OPDES permit application should be submitted by the end of the month. EPM needs to submit replacement pages for OPDES permit application.
Groundwater results for DDT - DEQ sent an NOD on August 9th, requiring that groundwater samples be analyzed for DDT, as a result of data review which showed one detection in a monitor well in 2001. Groundwater samples were collected from the same 4 monitor wells on August 11th. Samples were analyzed for DDT, and the results were sent to DEQ September 9th.
DDT was not detected in any of the samples. This resolves the DDT issue. No further action required.
RAIs for Environmental Assessment - Requests for additional information related to the environmental assessment will be issued by NRC by November 30th. NRC needs to issue RAIs.
RAIs for Safety Evaluation Report - Requests for additional information related to the safety evaluation report will be issued by NRC by December 30th. NRC needs to issue RAIs.
Transfer of Archived Files from Tronox - Tronox has notified EPM that they have 590 file boxes containing files for which Cimarron is included in the index. A list that generically describes the contents of each box was provided to EPM. EPM has identified 75 boxes which should be reviewed to determine if they contain records which should be transferred to the Trust. EPM included a provision for digitizing needed files in the proposed budget for 2017. EPM needs to identify files which should be transferred to the Trust.
NRC notified EPM that a revised radiation protection plan (RPP) and a revised Quality Assurance Program Plan (QAPP) will need to be appended to Revision 1 of the Decommissioning Plan. Revisions will address the conditions and processes contained in the Decommissioning Plan. EPM will revise the RPP and QAPP and submit with Revision 1.
Groundwater Design Issues Remediation Approach - EPM met with DEQ in August to present three alternatives to the remediation approach proposed in the Decommissioning Plan. Based on feedback from DEQ
NRC - DEQ - EPM Telecon Notes November 1, 2016 (Red text indicates who will take the next action) 3 of 4 after that meeting, EPM will incorporate the alternative presented as Option 2 into Revision 1 of the Decommissioning Plan. EPM sent an overview of the changes to the Decommissioning to NRC and DEQ in an e-mail dated October 7th. Although the purpose of the overview was to ensure that EPM, NRC, and DEQ all have the same understanding of what this alternative consists of, EPM needs feedback from NRC and DEQ regarding either changes that need to be made or information that would be needed. This will enable EPM to address these issues in the revised Decommissioning Plan. NRC and DEQ need to review the overview and comment as appropriate.
Revision of Influent Concentrations - The Option 2 alternative discussed above results in different pumping rates from different extraction components to Trains 1 and 2 (no changes for Burial Area #1). Groundwater flow models and particle tracking models are being revised to optimize flow rates. Based on the revised flow rates, influent concentrations are being re-calculated. At this time, it appears that both Train 1 and Train 2 will require treatment for both uranium and nitrate. EPM will complete revision of flow models and calculate influent flows and concentrations. A report on the flow model revision will be submitted by the end of the year. Revised flows and influent concentrations will be incorporated into the revised Decommissioning Plan.
Relocation of Western Area Treatment Facility - In August, Burns & McDonnell and Kurion engineers proposed the relocation of the Western Area Treatment Facility. Geotechnical information is needed to be able to design the water treatment facilities to relocate the treatment systems to the corner of Subarea N southeast of the U-Pond #1 Area. A geotechnical investigation is pending, and the revised design will be incorporated into the revised Decommissioning Plan. EPM needs to manage the completion of the geotechnical investigation and provide the geotechnical report to Burns & McDonnell and Kurion.
Determination of Distribution Coefficient - During the June meetings, NRC requested a paper presenting the work that has been done to determine the distribution coefficients for various soil types at the Cimarron site. On July 5th, EPM submitted Distribution Coefficient Determination for the Cimarron Site. EPM does not believe that additional sampling and analysis for Kd determination is justifiable. DEQ requested clarifications and further information both by e-mail and phone. DEQ concurred that further sampling and analysis is not needed in a letter dated August 31st. EPM needs NRC review of the report, because if they require additional sampling and analysis, this will add months to the schedule unless it can be done prior to revision of the D-Plan.
During the discussion, NRC asked about the vertical distribution of contaminants in the transition zone and alluvial material, where interspersed zones of higher and lower hydraulic conductivity may impact the concentration of contaminants in the extracted groundwater and the rate of cleanup. This can be addressed in a subsequent technical teleconference. NRC needs to review and comment on the paper. EPM will schedule a conference call to address vertical differences in conductivity and contaminant concentration.
NRC - DEQ - EPM Telecon Notes November 1, 2016 (Red text indicates who will take the next action) 4 of 4 Quarterly groundwater sampling and analysis - Groundwater samples were collected from 45 monitor wells from August 8th through August 10th. Laboratory data was received, reviewed, and submitted to NRC and DEQ on September 12th. No further action is needed.
Groundwater assessment report - Burns & McDonnell has compiled groundwater elevation and COC concentration data from 2001 through the 3rd quarter of 2016. They are evaluating the data to identify increasing or decreasing trends, to evaluate seasonal variations, and to determine if there is a relationship between groundwater elevation (or saturated thickness) and COC concentration. A report on the groundwater evaluation will be submitted to NRC and DEQ by the end of the year. EPM needs to complete the evaluation and submit the report by December 31st.
Groundwater sampling and analysis for plutonium - Groundwater samples were collected from Monitor Wells 1331 and 1377 on August 8th, and were analyzed for plutonium activity. Results were submitted to NRC and DEQ on September 12th. This was the 3rd consecutive quarter for which plutonium was not detected in either of the samples. The current plan is to sample these two wells for plutonium during the 4th quarter (this sampling event took place October 17th through October 19th). EPM does not plan to analyze groundwater for plutonium in 2017. NRC needs to notify EPM if plutonium analysis must continue, even if plutonium is not detected in the 4th quarter samples.
NRC - DEQ - EPM Telecon Notes December 14, 2016 (Red text indicates who will take the next action) 1 of 3 Attendees Ken Kalman Paul Davis Jeff Lux Lifeng Guo Jordan Caldwell Bill Halliburton Gerald Schlapper Torrie Wale Don Stearns Administrative Issues Proposed 2017 Budget - A draft budget for 2017 was submitted to NRC and DEQ on October 25th. Based on comments from NRC and DEQ, EPM sent alternative schedule scenarios to NRC and DEQ in an e-mail dated October 28th. EPM sent an e-mail describing the revised schedule and proposing to divide Task 4 into Tasks 4a and 4b. NRC verbally approved that approach December 12th. EPM will submit a revised budget proposal. EPM will submit a revised budget proposal for 2017.
Sale of Southwest Quarter of Section 12 - EPM has revised the Purchase and Sale Agreement (Agreement) for the proposed sale of the southwest quarter of Section 12 to Cimarron Holdings LLC, in accordance with agency comments. After internal legal review of the revised Agreement, EPM will submit the revision for DEQ approval. Upon DEQ approval of the Agreement, EPM will proceed with the sale of the property. EPM will submit a revised Agreement to NRC and DEQ for comment or approval.
OETA Report on Cimarron Holdings - Bob Sands, a reporter for OETA, the public television station in Oklahoma City, had requested a copy of the data from the 3rd quarter groundwater sampling event. After walking through the data with Mr. Sands, he asked about the pending sale of the southwest quarter section. While describing the development of the property by Cimarron Holdings, Mr. Sands contacted Tom Stewart and visited the Cimarron site in November. OETA aired a report on Cimarron Holdings development of the property on December 9th. To download the video, go to http://videos.oeta.tv/video/2365913954/. No further action required.
Licensing/Permitting Issues Subsurface Soil in Subarea F - During meetings conducted in June, NRC noted that, if the area in Subarea F that will remain under license is only a portion of Subarea F, amending the license would in effect release a portion of Subarea F for unrestricted use when NRC has not documented that the area complies with decommissioning criteria. NRC requested that EPM submit subsurface soil data for that portion of Subarea F that would not be under license. EPM sent a report providing both soil and groundwater data for the portion of Subarea F that would not be under license on August 31st. DEQ stated that DEQ has no objections to the letter or report, and that this is a matter between the Licensee and NRC in a letter dated October 4th.
NRC review is needed, because if any additional sampling and analysis is required, this is a multi-month impact. NRC will comment on the completeness of the data set by the end of February 2017.
OPDES permit application modification - DEQ sent a Notice of Deficiency (NOD) on October 4th. The NOD stated that replacement pages reflecting changed flow rates and influent
NRC - DEQ - EPM Telecon Notes December 14, 2016 (Red text indicates who will take the next action) 2 of 3 concentrations must be submitted as a modification of the permit application. Revision of groundwater flow models, needed for calculation of influent concentrations, is complete.
Calculations of influent concentrations should be complete within another two weeks. Revised pages for the OPDES permit application will be submitted as soon as anticipated influent concentrations and flows, as well as groundwater processing plans, are finalized. EPM to submit replacement pages for OPDES permit application.
Evaluation of Enrichment Analysis - License SNM-928 stipulates a 1,200 gram possession limit for U-235. Evaluation of enrichment calculations based on historical results indicates that, for low concentrations of uranium in groundwater, enrichment values for groundwater extracted from the same well vary widely. EPM is collecting groundwater samples from several wells and requesting analysis of multiple aliquots of each sample by both alpha spectroscopy and ICPMS.
Results will help Enercon develop a sampling and analysis plan for the nuclear material control program. EPM will notify NRC and DEQ of the results of the evaluation.
RAIs - Requests for additional information (RAIs), both related to the environmental assessment and the safety evaluation report will be issued by NRC, hopefully by the end of the year, but if not, by the end of the 2nd week of January. NRC will issue RAIs.
Transfer of Archived Files from Tronox - Tronox has notified EPM that they have 590 file boxes containing files for which Cimarron is included in the index. A list that generically describes the contents of each box was provided to EPM. EPM has requested Tronox obtain the first 12 of the 75 boxes which should be reviewed to determine if they contain records which should be transferred to the Trust. EPM will review the files and retain any that should be transferred to the Trust. EPM will identify files which should be transferred to the Trust.
Groundwater Design Issues Determination of Distribution Coefficient - During the June meetings, NRC requested a paper presenting the work that has been done to determine the distribution coefficients for various soil types at the Cimarron site. On July 5th, EPM submitted Distribution Coefficient Determination for the Cimarron Site. EPM does not believe that additional sampling and analysis for Kd determination is justifiable. DEQ requested clarifications and further information both by e-mail and phone. DEQ concurred that further sampling and analysis is not needed in a letter dated August 31st. NRC has indicated that additional sampling will not be needed, and that a letter providing comments on the report will be issued shortly. NRC will address issus related to the distribution coefficient in the RAIs. No further action needed.
Revision of Influent Concentrations - Groundwater flow models and particle tracking models were revised to optimize flow rates based on the revised remediation approach. Groundwater data extending back to 2011, and results from the quarterly sampling program, was evaluated to develop maximum anticipated influent concentrations for uranium and nitrate. Both Train 1 and Train 2 (in the Western Area Treatment Facility) will require treatment for both uranium and nitrate. EPM will submit a report on the revised groundwater flow models.
NRC - DEQ - EPM Telecon Notes December 14, 2016 (Red text indicates who will take the next action) 3 of 3 Relocation of Western Area Treatment Facility - In August, Burns & McDonnell and Kurion engineers proposed the relocation of the Western Area Treatment Facility. A geotechnical investigation was conducted to obtain the information needed to be able to design the water treatment facilities to relocate the treatment systems to the corner of Subarea N southeast of the U-Pond #1 Area. A report on the geotechnical investigation is due to be delivered to EPM before the end of the year, and the revised design will be incorporated into the revised Decommissioning Plan. EPM will transmit the report to Burns & McDonnell and Kurion, and the results will be used in the relocation of the Western Area Treatment Facility in Facility Decommissioning Plan - Revision 1.
Determination of Vertical Distribution of Uranium in Alluvium - Groundwater samples are being collected from geoprobe borings near existing monitor wells at two foot intervals to evaluate the vertical distribution of uranium in alluvial material. A report will describe the sample collection and analysis, evaluate the vertical distribution relative to the distance from the source, and explain the impact of the evaluation on the design of groundwater extraction wells.
EPM will submit the report to NRC and DEQ.
Groundwater Assessment Report - Burns & McDonnell has compiled groundwater elevation and COC concentration data from 2001 through the 3rd quarter of 2016. They are evaluating the data to identify increasing or decreasing trends, to evaluate seasonal variations, and to determine if there is a relationship between groundwater elevation (or saturated thickness) and COC concentration. A report on the groundwater evaluation will be submitted to NRC and DEQ by the end of the year. EPM will complete the evaluation and submit the report to NRC and DEQ.