ML20023A024
| ML20023A024 | |
| Person / Time | |
|---|---|
| Site: | 07000925 (SNM-0928) |
| Issue date: | 03/30/2020 |
| From: | Patricia Holahan Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Halliburton B Environmental Properties Management |
| Kalman K | |
| References | |
| Download: ML20023A024 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2020 Mr. Bill Halliburton Administrator, Cimarron Environmental Response Trust C/o Environmental Properties Management, LLC 9400 Ward Parkway Kansas City, MO 64114 Dear Mr. Halliburton
SUBJECT:
THE U.S. NUCLEAR REGULATORY COMMISSION APPROVAL FOR THE CIMARRON ENVIRONMENTAL RESPONSE TRUST TO FUND OUT OF SCOPE WORK AT THE CIMARRON SITE The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the December 13, 2019, letter from Environmental Properties Management (EPM), the Trustee for the Cimarron Environmental Response Trust (CERT) (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20020A012). In this letter, EPM requested NRCs approval for the Trust to pay costs for out of scope work and NRC oversight fees exceeding the 2019 Budget. Pursuant to a request from NRC staff, EPM provided additional information regarding costs by email dated January 9, 2020 (ADAMS Accession No. ML20063L848).
The NRC staff has been reviewing EPMs Facility Decommissioning Plan, Rev 1 (DP) submitted by letter dated November 2, 2018 (ADAMS Accession No. ML18323A197). In a February 28, 2019, letter to EPM (ADAMS Accession No. ML19056A513) the NRC staff identified supplemental information needed to complete its acceptance review of the DP. This resulted in out of scope work and NRC oversight fees exceeding the funding provided in the 2019 Budget.
Without NRC approval for additional funding, EPMs contractors will have to cease work and EPM will not be able to pay for the fourth quarter of 2019 NRC oversight fees. To meet its financial obligations and avoid delays in completing necessary work, EPM is requesting the NRCs approval to pay these costs while the proposed 2020 Budget Proposal is under review.
Based on its review of the December 13, 2019 letter, the NRC staff determined that a total of
$826,000 is needed for the Trustee to meet its financial obligations. Some of these obligations will be covered by funds in the 2019 Budget. Funding provided for Tasks 1 (Administration) and 5 (State Agency Fees) in the 2019 Budget are sufficient to cover ongoing work on these tasks until a budget for 2020 is approved. Funding in Task 6 (Unanticipated Work) is sufficient to cover Technetium-99 (Tc-99) treatability testing, a task that is necessary for the overall design of Cimarrons groundwater remediation system.
However, as shown in the table below, additional funding is needed for Tasks 2 (License Compliance), 3 (Federal Agency Fees), and 4 (Site Decommissioning):
B Halliburton Task Description 2019 Budget Funding Requested Additional Funding Reason Revised Budget 1
Administration
$313,576
$0 Funding is sufficient
$313,576 2
License Compliance
$565,866
$255,000 Cultural resources survey and document submittal for ADAMS
$820,866 3
Federal Agency Fees
$600,000
$400,000 NRC fees exceeded the approved budget
$1,000,000 4
Site Decommissioning
$3,414,082
$171,000 Out of scope work performed by Veolia Nuclear Solutions was not provided for in the approved budget
$3,585,082 5
State Agency Fees
$70,000
$0 Funding is sufficient
$70,000 6
Unanticipated Work
$85,499
$0 Funding is sufficient
$85,499 Total
$5,049,023 $826,000
$5,875,023 Additional funding needed for Tasks 2, 3, and 4 is described below:
Task 2 License Compliance Burns & McDonnell The approved budget for 2019 is $60,000, and nearly all of that has been spent. Funding is requested for two additional tasks:
Cultural Resources Survey - $175,000 Prepare historic documents for uploading to ADAMS - $30,000 EPM stated that Essentially all of this work will be paid for in 2020, but approval to spend the additional $205,000 prior to approval of the 2020 budget is needed.
The NRC staff notes that the Cultural Resource Survey is needed to complete its Environmental Assessment of the DP and that the uploading of documents presently not in ADAMS is necessary as these documents are referenced in the DP and other submittals.
Enercon Services EPM stated that the 2019 Budget allocated $387,000 for Enercon Services, and nearly all of that has been spent. The three tasks listed in the December 13, 2019 letter require an additional $50,000. EPM stated that work has nearly been completed, but remaining funding is insufficient to cover the cost of that work. Essentially all this work will be paid for in 2020, but approval to spend the additional $50,000 prior to approval of the 2020 budget is needed.
B Halliburton Task 3 Federal Agency Fees EPM requested approval to increase the funding for NRC oversight fees from $600,000 to
$1,000,000.
The NRC staff notes that allocating $600,000 for Federal Agency Fees in 2019 and previous years proved to be sufficient. However, since EPM submitted its proposed DP in November 2018, NRC staff work has increased and 2019 Federal Agency Fees for the first three quarters of 2019 already exceed $600,000.
Task 4 Site Decommissioning Veolia Nuclear Solutions - Federal Services - Decommissioning The approved budget for 2019 is $1,181,000, and all of that has been spent. As noted in the January 9, 2020, email from EPM, the following out of scope work requires additional funding:
Project Management - Increased cost due to numerous additional activities - $10,000 Uranium treatment and resin processing design - for backup power, pre-filtration, floor drains & sumps, addition of HVAC fire protection, and other related tasks - $307,000 Biodenitrification and solids processing design - to increase potential nitrate influent concentrations to 150 ppm, address Tc-99 treatment and biomass issues and other related tasks - $130,000 Tc-99 treatability testing - $26,000 Total cost for out of scope work - $473,000 Eliminating responding to requests for additional information ($10,000) and preparing requests for bid, evaluating bids, and selecting contractors ($292,000) saved $302,000 from the approved funding for 2019. However, an additional $171,000 is needed to pay for the out of scope work. This increases the total approved funding for work performed in 2019 from
$1,181,000 to $1,352,000.
The NRC staff notes that most of the Task 4 costs were covered by deferring some of the decommissioning activities approved in the 2019 budget. The additional funding is needed for Veolia Nuclear Solutions to continue its work.
The NRC staff approves the Trustees request for funding in the amount of $826,000.
In accordance with 10 CFR 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 NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
B Halliburton If you have any questions concerning this letter, please contact Ken 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 SNM-928 cc: Cimarron Site Service List Patricia Holahan Digitally signed by Patricia Holahan Date: 2020.03.31 13:05:26
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ML20023A024 *via email OFFICE DUWP DUWP DUWP NAME KKalman SAchten BvonTill DATE 01/23/2020 03/06/2020 03/23/2020 OFFICE OGC DUWP NAME EHouseman PHolahann DATE 03/04/2020*
03/30/2020