ML22088A133

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Cimarron Environmental Response Trust Lack of Clarification of Nrc'S January 31, 2022 Comments
ML22088A133
Person / Time
Site: 07000925
Issue date: 03/29/2022
From: Lux J
Environmental Properties Management
To: Davis P, Robert Evans, James Smith
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML22088A133 (13)
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Text

March 29, 2022 Mr. James Smith 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. 07000925; License No. SNM-928 Cimarron Environmental Response Trust Lack of Clarification of NRCs January 31, 2022 Comments

Dear Sirs:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) has requested concurrence and clarification related to U. S.

Nuclear Regulatory Commission (NRC) comments on the decommissioning plan for the Cimarron site. Response to those requests is needed to enable EPM to complete and submit a decommissioning plan to the NRC.

The NRC issued a request for supplemental information (RSI) based on the acceptance review of Facility Decommissioning Plan - Rev 2 in a letter dated August 11, 2021. Responding to those requests for information required significant revision of the decommissioning plan. To expedite the acceptance review/RFI/technical review process, EPM informally submitted (via a Microsoft TEAMS site) a draft Facility Decommissioning Plan - Rev 3 (the DP) to the NRC for a pre-application audit.

The NRC scheduled a January 7, 2022, meeting to discuss the findings of the pre-application audit. During that meeting, it was discovered that the NRC had not accessed the file containing the text of the DP, and some of the comments they had developed during the pre-application audit may be resolved upon review of the DP text.

On January 31, having reviewed the DP text, the NRC issued comments on EPMs responses to the NRCs pre-application audit. On February 1, 2022, I requested clarification of some of the NRCs January 31, 2022, requests for information. To enable us to adequately respond to the 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

NRCs comments, there were a few comments I need to better understand. Attachment 1 is the request for clarification that was attached to the February 1 email.

The following paragraphs summarize the issues addressed in previous communications and provide (in red text) questions for which we request a response from the NRC. Resolution of these issue is needed for EPM to complete revision of the DP.

RSI-1

1. RSI-1 contains two paragraphs addressing the DPs commitment to collect groundwater samples for Tc-99 analysis during the first four quarters of post-remediation monitoring.

The NRC emphasized at the time of license termination. Does this mean that the DP should be revised to collect groundwater samples for Tc-99 analysis during the last four quarters of post-remediation monitoring?

2. Regarding analyzing groundwater samples for Tc-99, the NRC referred to an unreasonable request. We are not aware the DP indicates that the NRCs request to analyze groundwater samples for Tc-99 after groundwater remediation is complete is unreasonable. What are the NRCs expectations regarding responding to that comment?
3. The NRC recommends removal of a paragraph from Page 15-9 of the DP. That paragraph appears to be appropriate to include in this section of the DP and is identical to a paragraph which appears earlier in the DP. Does the NRC object to the substance of this paragraph (such that the NRC doesnt want it included in either location), or is there a reason the NRC objects to it being included in Section 15?
4. The NRC implies that the request and justification for an alternate schedule appears only in the cover letter for the response submittal, but not in the DP. It stated, Unfortunately, regardless of the technical merits of the justification a license amendment request for an alternate schedule poses difficulties from a regulatory perspective. Our response stated that the request and justification for an alternate schedule was included in Section 9.5 of the DP. Does the NRC maintain that a schedule showing that DP review, license issuance, construction, and groundwater remediation will require 15 years does not provide sufficient justification for an alternate schedule?

RSI-3

1. The NRC noted that Section 9.3.2 and Figure 9-3 both say that it is estimated it will take 147 months for groundwater in the WAA U>DCGL area to comply with the NRC criterion, and Section 3.5.3 says it will take 38 months. The NRC noted that Section 9.3.2 (addressing extending operation of western area remediation systems until the license criterion is achieved in Burial Area #1) implies that the goal is to achieve the greatest removal of contaminant mass rather than to obtain license termination.

Groundwater in the WAA U>DCGL area should comply with the NRC criterion in 38 months, but the plan was to continue operation of all western area remediation systems until in-process monitoring indicates that the NRC criterion has been achieved in BA1.

Section 9.3.2 and Figures 9-3 inadvertently reflected operation of the western area systems for 147 months but failed to clarify that the NRC criterion would be achieved long before the systems were shut down. Section 9.3.2 will be revised to show that the 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

NRC Criterion will be achieved in 38 months. In addition, to maximize the potential for funding to be sufficient to achieve license termination, the DP will be revised to state that operation of western area systems will be terminated when groundwater in all western remediation areas achieves the NRC criterion. Do these revisions satisfactorily address NRCs comment?

RSI-5

1. The NRC pointed out that the license requires eight quarters of post-remediation groundwater monitoring, and there is no formal documentation of a requirement to conduct 12 quarters of post-remediation groundwater monitoring. The NRC requested the rationale for the post-remediation groundwater monitoring schedule. The commitment to perform 12 quarters of post-remediation groundwater monitoring was the result of conversations with the NRC. With no formally documented requirement for greater-than-eight-quarter post-remediation monitoring duration, would the NRC prefer that the DP be revised to specify eight quarters of post-remediation groundwater monitoring per License Condition 27c?

RSI-6

1. RSI-6B stated, Data submitted by letter dated October 4, 2021 (letter is not in ADAMS)

EPM provided excel files containing groundwater elevations, groundwater quality data and pertinent well details. Was the NRC simply providing EPM some information, or is there something in this statement to which we should respond?

2. The NRC pointed out that some groundwater elevation data exists in some reports that was not included in the October 4, 2021, Excel files. Attachment 2 to this letter is the January 12, 2022, email in which I explained that the Excel files EPM provided contained the groundwater elevation data that was used to calculate mean groundwater elevations, which was the data the NRC had requested. The NRC verbally agreed that the data provided was sufficient. Will the NRC provide written concurrence that the data provided was sufficient?

RSI-7

1. The first paragraph of the NRCs comment does not request any information; it just states that there are multiple sources of information of river elevation levels. Monitor wells would be submerged if the 100-year flood elevation was 945 feet above mean sea level (AMSL) or 951 feet AMSL (or 955 or 960), and j-plugs have been installed in all monitor wells in the floodplain to prevent flooding the wells during inundation. EPM does not understand why spending time and effort to more rigorously define the elevation of the 100-year floodplain is justifiable, since it would not impact the design of groundwater remediation infrastructure in the floodplain. Does the NRC require more justification for the 951 feet AMSL 100-year flood elevation identified in the DP?
2. The February 1, 2022, response to NRC comments explained that a dilution factor calculation was provided to the NRC because the NRC appeared to misunderstand a statement in Section 5.6.4, thinking that the reason for remediating groundwater is to protect the Cimarron River. The NRC appears to believe that the dilution factor 9400 Ward Parkway
  • Kansas City, MO 64114 Tel: 405-642-5152
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calculation is somehow significant, stating, The NRC desires justification for using the low-water median flow as the benchmark rather than more commonly used benchmarks. If the use of more commonly used benchmarks would reduce the dilution factor from in Burial Area #1 from 1,000:1 to 500:1, or 100:1, that wouldnt change the fact that the reason we are remediating groundwater is to achieve license termination based upon license criteria. Does the NRC want EPM to use more commonly used benchmarks when discussing the dilution factor? EPM does not feel changing the benchmark to more commonly used benchmarks will provide sufficient benefit, accuracy, or appropriateness to offset the cost to conduct additional evaluation.

In light of our current understanding that if feedback is not formally documented, it cannot be relied upon as guidance from the NRC, I would appreciate written clarification of these comments from the NRC. But over seven weeks have passed since I requested clarification, and during our March 23 teleconference, it appears that NRC was unaware that EPM still needs clarification of these comments to address them adequately in the DP.

If you have any questions or desire clarification, please call me at (405) 641-5152.

Sincerely, Jeff Lux, P.E.

Project Manager cc: Michael Broderick, Oklahoma Department of Environmental Quality (electronic copy only)

John Saxton, US Nuclear Regulatory Commission (electronic copy only)

NRC Public Document Room 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

ATTACHMENT 1 REQUESTS FOR INFORMATION RELATED TO NRC COMMENTS FROM THE PRE-APPLICATION AUDIT FOR FACILITY DECOMMISSIONING PLAN - REV 3 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

REQUESTS FOR INFORMATION RELATED TO NRC COMMENTS FROM THE PRE-APPLICATION AUDIT FOR FACILITY DECOMMISSIONING PLAN - REV 3 REQUESTS FOR SUPPLEMENTAL INFORMATION RSI Last Paragraph on Page 8-48, First Paragraph on Page 8-49, and First Paragraph on Page 15-9 The NRCs first comment indicates that NRC believes the commitment in Section 8.8 of the decommissioning plan to conduct four quarters of groundwater monitoring is considered to be an unreasonable request, and that the text implies that this sampling will be performed pro forma. I can only assume that the use of the word request in the DP text was taken to mean that the collection of these samples is not required but will be performed as a courtesy to the NRC. There is nothing in the text that states or implies that this is the case. That text was written using the exact same terminology that the NRC used in the April 22, 2013, letter to which the comment refers, which read, the NRC staff requests that the post-remediation monitoring plan leading to license termination includes four calendar quarters of monitoring for Tec-99 to be collected, shortly before requesting license termination, to confirm that previous concentrations have remained below NRCs DCL.

The NRCs comment also emphasized by underlining that this sampling should document existing residual contamination at the time of license termination . It is our understanding that collecting and analyzing groundwater samples for Tc-99 during four quarterly sampling events during post-remediation monitoring provides exactly the data that the NRC requested in the April 2013 letter.

Two previous versions of the decommissioning plan have been accepted for detailed technical review with the same commitment to collect and analyze groundwater samples for Tc-99 during the first four quarterly post-remediation monitoring events; does this comment indicate that this commitment is in some way deficient?

NRC staff also recommends that the first full paragraph on page 15-9 be removed, without explaining the basis for that recommendation. That paragraph is identical to the last full paragraph on page 4-3 of the DP. It simply states that the EPA criterion for Tc-99 in groundwater is 900 pCi/L, and that the DEQ has adopted that value as their criterion for the release of the site without restriction. As previous paragraphs in RSI-1 pointed out, the MOU between the NRC and the EPA requires the NRC to notify the EPA regarding residual contamination at license termination. It seems logical to provide this information in the DP just as the EPA criterion for uranium in groundwater, also adopted by the DEQ as their unrestricted release criterion, is provided. What is the justification for NRC staffs recommendation to remove that paragraph from page 15-9 of the DP, while accepting it on page 4-3 of the DP?

RSI Chapter 9.5 Schedule Changes This comment implies that the request and justification for an alternate schedule appears only in the cover letter for the response submittal, but not in the DP. It recommends that the request and the justification for requesting an alternate schedule be included in the DP.

The last paragraph in Section 9.5 of the DP reads, The schedules presented herein do not comply with the two-year time frame for decommissioning specified in 10 CFR 70.38(g)(4)(vii). The schedules presented herein demonstrate the need for an alternative schedule in accordance with 10 CFR 70.38(g)(2).

The licensee herein requests NRC approval of this alternative schedule.

If schedules for pre-construction, construction, remediation, and post-remediation activities, showing that decommissioning cannot be completed within 15 years, do not provide the needed justification, please let us know what additional justification is needed.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

RSI-3, Second and Third Paragraphs The schedule and the cost estimate in the DP was based on an assumption that groundwater extraction, treatment, and injection and discharge would continue in the western area (WA) until groundwater in Burial Area #1 (BA1) complies with the NRC criterion. The cost savings associated with shutting down the WA systems were believed to be a small fraction of the cost of continuing to man the site, maintain the building, and operate the BA1 remediation systems. We believed the removal of additional uranium (stated in the DP as the greatest removal of contaminant mass) justified the incremental cost increase.

It appears that the NRC interpreted this statement to imply that the goal of the remediation was to achieve the greatest removal of contaminant mass rather than to obtain license termination. If the NRC would prefer to leave as much uranium in the groundwater as possible while achieving the NRC criterion, so that it is clear that the primary objective is to achieve the NRC criterion, the DP can be revised to state that all WA systems will be shut down as soon as the NRC criterion are achieved in all WA remediation areas.

RSI-5 It appears that the NRC takes exception to the statement in the DP that says the NRC requires 12 quarters of post-remediation groundwater monitoring, when license condition 27(c) requires only eight quarters of post-remediation monitoring. We can only assume that this comment is a result of the complete changeover of NRC staff associated with the Cimarron license.

Between 2003 and 2009, the licensee submitted several decommissioning plans proposing to use in situ biological immobilization to reduce the concentration of uranium in groundwater to less than the NRC criterion. The former NRC Project Manager (PM) was Ken Kalman, who served as the PM from 1996 through much of 2020. During numerous telephone calls with the previous and current licensees, Mr.

Kalman stated that the eight quarters of post-remediation groundwater monitoring required by license condition 27(c) was based upon monitored natural attenuation (MNA) being the means by which groundwater would achieve the NRC criterion.

Based on guidance from the two previous hydrogeological support staff, Mr. Kalman was concerned that groundwater extraction will create cones of depression, and the return of groundwater elevations to pre-remediation levels post-remediation will provide an opportunity for uranium in the unsaturated zone created by pumping to desorb and result in a rebound in uranium concentrations. Uranium concentrations could rebound for the first quarter or two after terminating groundwater extraction. Consequently, adding four quarterly post-remediation sampling events should be sufficient to generate eight quarters of data showing that after rebounding, uranium concentrations still do not exceed the NRC criterion.

Between 2000 and 2020, the licensee requested that the license be amended several times to remove from the license tie downs that no longer apply to the site, to revise the environmental monitoring program, etc. Mr. Kalman was not willing to amend the license to reflect the current status of site decommissioning until the license could be amended to include a groundwater remediation plan.

Unfortunately, neither the NRC nor the licensee documented these conversations.

If the NRC desires, the DP can be revised to provide only eight quarters of post-remediation monitoring.

If the issue is that the NRC objects to the statement that the NRC requires 12 quarters of post-remediation monitoring because the NRC never documented that desire, there is no reason to revise the DP. If there is in this section of the DP some deficiency that would impact the detailed technical review of the DP, please advise us accordingly.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

RSI-6 A)

It appears that in generating this comment, the NRC reviewer was reading the response letter that was initially placed on the Microsoft TEAMS site. In an email dated November 23, 2021, I notified you and all the NRC reviewers that I had replaced the letter of submittal on the Microsoft TEAMS site, as a found some incorrect numbers, section references, etc. The letter of submittal that I uploaded to the Microsoft TEAMS site replaced the references to Tables 2-11 through 2-13 with references to Tables 2-10 through 2-12. There is no Table 2-13 in the DP tables. The calculation of the mean values in all three tables will be reviewed and revised as appropriate.

RSI-6 B)

Im not sure if this is just informing us that the October 4, 2021, letter of submittal for a CD containing Excel and PDF files is not in ADAMS, or if this letter should be electronically submitted to be uploaded to ADAMS. Either way, this does not appear to be identifying a deficiency in the DP; please clarify if this is the case.

It was the licensees understanding that a licensee cannot electronically submit an Excel file to the Document Control Desk for uploading to ADAMS, but that the NRC PM could work with NRC personnel to have the Excel and PDF files uploaded to ADAMS. Does the NRC PMs collaboration with Document Control Desk personnel include the cover letter in the files that would be uploaded? Please advise if you want the cover letter to be submitted to the Document Control Desk.

RSI First Paragraph This paragraph appears to be saying that the DP is deficient because it doesnt provide more information on the elevation of the 100-year flood. Previous versions of the DP, which cited a 100-year elevation of 960 feet above mean sea level (AMSL) had been accepted for detailed technical review. After receiving previous requests for information, other information was presented that indicated that the 100-year flood elevation may be lower (951 feet AMSL). This comment state than a 1993 measurement recorded a peak elevation (for that flood event) of 945.8 feet AMSL.

Why is it necessary to more precisely determine the 100-year flood elevation? Monitor wells in the floodplain have been inundated multiple times during the past 20 years. J-plugs have been installed in all monitor wells with a top-of-casing elevation below 960 feet AMSL. The NRCs concern appears to be the inundation of monitor wells in the floodplain during flood events. If the NRC could explain why more study/research should be performed to more precisely define the 100-year flood elevation, additional resources could be spent conducting such evaluation. However, it is not clear that any changes would be made to the DP if the 100-year flood elevation is a few feet above or below the 951-foot AMSL elevation currently referenced in the DP; in short, it doesnt appear that the benefit of more evaluation is worth the cost.

RSI Second Paragraph The NRC desires justification for using the low-water median flow as the benchmark rather than more commonly used benchmarks. The purpose for this calculation was to address a comment by NRC staff that the first paragraph of Section 5.6.4 in DP - Rev 2 implied that the reason for remediating the groundwater was to protect the Cimarron River. That paragraph was revised to clarify that groundwater remediation is needed to comply with license criteria. The dilution calculation was only provided to demonstrate that even without groundwater remediation, licensed material would never measurably impact the Cimarron River.

The low-water median flow was easily available and had been acceptable to hydrogeological review staff during two previous acceptance reviews of the DP. Using the low-water median flow to calculate dilution 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

factors yielded dilution of greater than 1,000:1 for the WA and greater than 2,000:1 for BA1. With this degree of dilution, licensed material would never be detectable in the Cimarron River even with no groundwater remediation.

If the NRC is concerned that the use of more commonly used benchmarks such as the 7-day average low flow every 2 years could so reduce dilution factors that licensed material would materially impact the Cimarron River, additional time and money can be spent to refine that calculation. However, because that calculation does not appear in the DP, it is probably not worth the additional effort to further evaluate various benchmarks for low flow unless NRC staff feels it could result in the reduction of dilution factors by more than an order of magnitude.

REQUESTS FOR CLARIFICATIONS Soil Regarding Subareas F, G, and N, the NRC states that there has been no regulatory action to release these subareas from the license and they are therefore not released from license controls as stated by the licensee. Final status surveys and confirmatory surveys have been performed which demonstrated to the NRCs satisfaction that both surface and subsurface soils comply with license criteria for soils.

In addition, the February 16, 2011, License Transfer Order (published in the Federal Register on February 28, 2011), which transferred license SNM-928 to the CERT states, Final status surveys and confirmatory surveys have confirmed that Subareas G and N are releasable for unrestricted use, but NRC has determined that these areas should not be released until groundwater remediation is complete. Because groundwater exceeds license criteria in Subarea F, this area cannot be released for unrestricted use until groundwater remediation is complete. Because the NRC has documented that Subareas G and N are releasable for unrestricted use, these portions of the site, as well as all the areas that have been released from the licensed, should be exempt from license controls.

The NRC has released from the license areas within which uranium concentrations exceed license criteria for groundwater. Consequently, EPM has submitted a license amendment request to bring the appropriate portions of the site back under license. There should be no need to conduct any radiological surveys for soil in areas that have been released from the license; for the NRC to require continuing surveys to evaluate soil against the decommissioning criteria is unwarranted.

The licensee has proposed to continue to conduct radiological surveys to identify material that may have been buried of which no one currently involved with the site may be aware. The reason for conducting these surveys is not to continue to evaluate soils against decommissioning criteria. We acknowledge that gamma surveys cannot demonstrate compliance with decommissioning criteria for soil, but gamma surveys can identify non-native material brought to the surface that needs to be further evaluated. For example, when a piece of concrete in the Uranium Pond #1 area was brought to the surface during the excavation of a pilot test trench in 2017, a gamma survey identified a spot of contamination; this triggered surface contamination measurements that identified an area that exceeds surface contamination limits.

There is no real justification for conducting the survey of the sediment/spoils mixture that we have agreed to perform. We will be taking soil from two areas in which the soil has already been accepted by the NRC as complying with license criteria, and which have been released from the license, and surveying them as though they are potentially contaminated above license criteria. We are bending over backward trying to satisfy NRCs concerns, and this is costing time and money that the NRC should be committing to remediating groundwater, not revisiting soil that has already been released from the license.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

We will be willing to revise the DP so that there is no distinction between soil from one foot to three feet in depth and greater than three feet in depth, performing a gamma survey and further investigating any material exceeding 2 times background. We will be willing to revise the DP so that there is no distinction between soil from one foot to three feet in depth and greater than three feet in depth, performing an exposure rate survey and further investigating any material exceeding the license criterion of 10 µR/hr at one meter from the soil. However, the NRC should explain why radiological surveys of soil that the NRC has documented are releasable for unrestricted use should be surveyed at all, because the additional expense associated with continuing to conduct such surveys diverts needed funds from the remediation of groundwater which does exceed license criteria.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

ATTACHMENT 2 TEXT FROM JANUARY 12, 2022, EMAIL FROM JEFF LUX OBSERVATION RE: GROUNDWATER ELEVATION DATA 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

During our Friday, January 7 meeting to discuss the results of the NRCs pre-application audit, you mentioned that the 2018 Groundwater Evaluation Update report presented depth to water (DTW) or groundwater elevation data that were not included in the file CERT JUL 2021 Evaluated Gauging Data, which was electronically submitted to the NRC on October 4, 2021.

In the NRCs August 11, 2021 request for supplemental information, item RSI -6 read, The DP does not provide a listing of groundwater and surface water quality and elevations. Many figures and tables are based on data averaged over several years or a combination of data for individual sampling events, maximum values, or a statistical evaluation of the mean. Please provide a listing of groundwater and surface water quality and elevations, and available boring logs or reference to documents which has been submitted to NRC and contains a boring log. It is preferred that the quality and elevations be submitted in an electronic format (e.g., excel spreadsheet) as well.

In previous submittals of the decommissioning plan, groundwater elevation data was only used to develop potentiometric surface maps (presented in Figures 2-9 and 2-10 in the draft Facility Decommissioning Plan - Rev 3). During telephone conversations conducted to clarify what information was needed to respond to the NRCs request for supplemental information, you pointed out that the figures depicting potentiometric surface maps included a table listing the mean groundwater elevation data for each monitor well used to generate the potentiometric surface maps. You requested that we provide the NRC the groundwater elevation data upon which those mean groundwater elevations were based.

The spreadsheet CERT JUL 2021 Evaluated Gauging Data includes all the groundwater elevation data upon which the mean groundwater elevation data tabulated in Figures 2-9 and 2-10 were based. That is the only groundwater elevation data that was used in the preparation of the decommissioning plan; consequently, we believe that data fully responds to the NRCs request for supplemental information related to the decommissioning plan.

We acknowledge that DTW measurements have been recorded during other sampling events.

During a design investigation activity performed in 2014, DTW measurements were made over a period of several months as field activities proceeded. Because that groundwater elevation data was collected over an extended period of time, it was not considered representative of a snapshot of groundwater elevations for a single monitoring event; it was not included in the evaluated gauging data spreadsheet.

The 2018 Groundwater Evaluation Update incorporated groundwater elevation data as far back as 2000 to determine if there is a correlation between saturated thickness or seasonality and contaminant concentrations. Those evaluations were performed at the request of the NRC, and the NRC was satisfied that there is no correlation between saturated thickness or seasonality and contaminant concentrations. That data is not needed to develop a decommissioning plan to remediate groundwater at the Cimarron site.

It would require significant effort (and expense) to go through the records of all prior sampling events to incorporate all past DTW measurements into the evaluated gauging data spreadsheet.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

The DTW data from all prior sampling events was not used in the preparation of the decommissioning plan and is not relevant to the decommissioning plan. Consequently, we request NRC concurrence that the data provided in CERT JUL 2021 Evaluated Gauging Data is sufficient for NRC to conduct both the acceptance review and the detailed technical review of the decommissioning plan.

Jeff Lux, P.E.

Project Manager Environmental Properties Management LLC A Subsidiary of Burns & McDonnell Engineering Company, Inc.

405-642-5152 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com
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