ML20317A221
| ML20317A221 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 11/11/2020 |
| From: | Dulle E Burns & McDonnell |
| To: | Christine Pineda NRC/NMSS/DREFS/ERMB |
| C. Pineda | |
| Shared Package | |
| ML20317A219 | List: |
| References | |
| Download: ML20317A221 (3) | |
Text
November 11, 2020 Ms. Christine Pineda U.S. Nuclear Regulatory Commission Mail Stop: TWFN/4B72 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket No. 070-00925; License No. SNM-928 Cimarron Remediation Site - Cultural Resources Survey Report - Revision 1
Dear Ms. Pineda:
As per your request, Burns & McDonnell Engineering Company Inc. (Burns & McDonnell) has prepared this letter summarizing the proposed activities associated with the Cimarron Environmental Response Trust (CERT) groundwater remediation project. Specifically, this information is intended to present a summary of proposed ground-disturbing activities and the locations in relation to cultural resources identified on the property. We understand you will provide this information to the Oklahoma State Historic Preservation Office (SHPO) in response to their request for additional information.
As detailed in the Phase I Cultural Resources Survey of the Cimarron Environmental Response Trust Property (Report), seven resources were identified within the area designated as the Area of Potential Interest (APE). These resources include three buildings (Resources 01-03), a structure associated with Resource 01 (Resource 01a) and three diesel water pumps (Resources 04-06) historically associated with the former Kerr-McGee Nuclear Corporations Cimarron Fuel Fabrication Plant (operational from 1966 to 1975). One historic metal corral was recorded in the floodplain which likely pre-dates Kerr-McGee ownership of the property (Resource 07). Resource 03 is currently being used as an office building for CERT personnel and contractors and will continue to be in use during proposed construction activities. The approximate locations of these resources are illustrated on Figure 1.
A detailed description of proposed decommissioning activities was presented in the Facility Decommissioning Plan - Rev 1 (the DP). In general, decommissioning of former impoundments, waste burials, pipelines, and soils is complete. The only decommissioning activities that remain are associated with the removal of contaminants from groundwater in areas where groundwater exceeds unrestricted release criteria. Groundwater recovery and treatment will generally be accomplished via installation of groundwater extraction wells and trenches, treated water injection wells and trenches, construction of groundwater treatment facilities, and installation of associated conveyance piping, electrical, and controls infrastructure.
The proposed infrastructure required to facilitate groundwater remediation, in relation to the existing resources listed above, is depicted on Figure 1. Additionally, the estimated areas that 425 South Woods Mill Road \ Suite 300 \ Chesterfield, MO 63017 O 314-682-1500 \ F 314-682-1600 \ burnsmcd.com
Ms. Christine Pineda November 11, 2020 Page 2 will likely be disturbed during installation of this infrastructure, due to equipment access, clearing and grubbing, soil stockpiling/staging, erosion control measure installation, etc., are also depicted as red shading on Figure 1.
Prior to the start of construction activities, stormwater management controls (BMPs) will be implemented in accordance with a site-specific Storm Water Pollution Prevention Plan (SWPPP), with silt fence (or equivalent) being installed around the downslope side(s) of disturbed areas until permanent vegetation is established. In general, extraction and injection wells will be installed using standard drilling methods and extraction and injection trenches will be installed using heavy earthwork equipment (i.e., excavators). Extraction and injection trenches will be approximately 3 feet wide and installed to depths of up to 30 feet below grade.
Utilities, including electric and communications cable and water conveyance piping, will be routed via trenches installed from the treatment facilities to each extraction/injection well/trench.
Planned locations and routes of utility trenches are depicted on Figure 1. Utility trenches will be generally constructed to a minimum 3-foot deep (as required by the regional frost depth) and have widths generally ranging from 2 to 5 feet (depending on the overall utility types and quantities).
A groundwater treatment facility will be constructed for groundwater treatment and discharge/injection. Additionally, utilities required to support the Western Area (WA) facility include electric, potable water, communications, and septic sewerage. Potable water and communications will be supplied via connection to an existing force main and communications junction box, respectively, located along Highway 74 near the facility entrance. These utilities will be routed to the WA facility via underground utility trench installed approximately 100 feet south of Resources 02 and 03 (see Figure 1). Electricity will be supplied to the WA facility via existing overhead power infrastructure located within the OG&E easement. Utilities will be routed from the WA to Burial Area #1 (BA1) treatment facility via one of two underground utility corridors, as illustrated on Figure 1.
A pair of drainage channels (1206 North Drainage) located west of the WA treatment facility will require additional clearing and sediment removal to support remediation. The 1206 North Drainage consists of a western branch, an eastern branch, and a confluence area. As detailed in the D-Plan, sediment within the eastern and western branches of the 1206 North Drainage will be excavated and mixed with excess spoils generated during injection trench excavation.
This will be completed using similar heavy earthwork equipment required for injection and 425 South Woods Mill Road \ Suite 300 \ Chesterfield, MO 63017 O 314-682-1500 \ F 314-682-1600 \ burnsmcd.com
Ms. Christine Pineda November 11, 2020 Page 3 extraction trench installation. The approximate extent of excavation related to the 1206 Drainage are illustrated on Figure 1.
Construction of both the WA and BA1 treatment facilities will generally include site grading, stormwater controls installation, foundation installation, surface course installation, and restoration. The WA treatment facility will include construction of a pre-engineered metal building and the BA1 treatment facility will include placement of modular enclosures housing treatment equipment.
Overall, land disturbance is not anticipated beyond the red shaded limits depicted on Figure 1.
The resources located within the floodplain (R-04 through R-07) are over 200 feet from the nearest planned construction activities. As noted above, the WA communication and potable water supply utility trench will be installed approximately 100 feet south of R-03. This building is currently used as an office and will continue to be used throughout full-scale construction. The buildings identified as Resources 01 through 02 are also located over 100 feet away from construction activities related to the 1206 North Drainage remediation and utility trenching.
If you have any questions regarding the description of proposed construction activities presented herein, please do not hesitate to contact me at edulle@burnsmcd.com or (314).375.3288.
Sincerely, Eric Dulle, PE Project Engineer
Enclosure:
Figure 1 - Construction Impact Analysis cc: Jeff Lux (EPM)
John Hesemann (Burns & McDonnell)
Bill Halliburton (Burns & McDonnell) 425 South Woods Mill Road \ Suite 300 \ Chesterfield, MO 63017 O 314-682-1500 \ F 314-682-1600 \ burnsmcd.com