ML23222A100
| ML23222A100 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 07/26/2023 |
| From: | Cimarron Environmental Response Trust |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| Download: ML23222A100 (1) | |
Text
Cimarron Environmental Response Trust July 26, 2023, Project Status Teleconference Notes Page 1 of 4 Attendees:
NRC DEQ EPM Jim Smith Rachel Miller Jeff Lux Kevin Hayes Paul Davis Marla Morales Stephanie Anderson Lifeng Guo Christine Pineda Isaac Johnston Administrative Issues Exemption from NRC and DEQ Oversight Fees In a letter dated April 17, EPM submitted a letter to the Chief Financial Officer of the NRC, requesting an exemption from NRC oversight fees.
In a May 1st letter to the Chief Financial Officer of the NRC, Oklahomas Secretary of the Environment stated, If NRC is unwilling or unable to waive its fees associated with oversight activities, we ask that NRC agree to defer its fee reimbursement for the duration of the project to enable this project to continue to completion and then recapture fees from any remaining funds.
DEQ is willing to waive or defer its reimbursement of oversight costs as well.
In a letter dated June 23, the NRC stated, Based on the information you provided, I conclude that it is in the public interest to approve this exemption. Given the financial situation and limited resources of CERT, an exemption will permit the CERT to preferentially utilize available funds to assure public health and safety at the Cimarron site and to advance remediation of the site.
However, NRC staff has also determined that the agency reserves the right to bill and collect on any current or future charges incurred should CERTs financial situation change in the future.
The decision to defer both NRC and DEQ oversight fees will have a significant impact on the Trusts ability to achieve the license criteria for uranium in groundwater at the Cimarron site.
No further action is needed.
Agency Personnel Notifications The following is a list of personnel who will be notified of future teleconferences:
NRC: Jim Smith, Karen Pinkston, Marla Morales, Christie Pineda, Glenn Tuttle, Jeremy Munson, Logan Crevelt, Kevin Hayes, Lifeng Guo, Martha Poston-Brown, Trent Wertz, Bill Von Till, Sarah Achten, Christina England, Angela Coggins, James Rubenstone, Jason Piotter, Isaac Johnstone, Ian Irvin, Adam Gendelman, Fred Miller, Dante Johnson, and Brandon Ward.
DEQ: Kelly Dixon, Jonathan Reid, David Cates, Rachel Miller, Paul Davis, and Keisha Cornelius.
The following is a list of personnel who will be copied on routine correspondence:
Cimarron Environmental Response Trust July 26, 2023, Project Status Teleconference Notes Page 2 of 4 NRC: Jim Smith and the Document Processing Center (personnel will be notified per the NRCs Cimarron license listserv).
DEQ: Rachel Miller, Paul Davis, Pam Dizikes, David Cates, Jonathan Reid, and Keisha Cornelius, and vcpsubmittals.deq.ok.gov.
EPM has revised the distribution lists accordingly.
No further action is required.
Licensing Issues Overview Presentations NRC and DEQ personnel attended presentations providing an overview of the following aspects of Facility Decommissioning Plan - Rev 3 (the D-Plan):
- 1. Regulatory and licensing issues (June 27).
- 2. Criticality and material control and accounting (June 29).
During the presentation on licensing issues, EPM identified two issues related to the language in Section 6 of the D-Plan. Section 6.5 contained an inaccurate statement regarding the release status of Subarea N. The NRC concurs that it is releasable for unrestricted use, but it has not been released from the license as stated in Section 6.5. The text that was included in Section 6.7.2 to replace License Condition 27(b) did not reflect the difference in post-remediation requirements for uranium and Tc-99. EPM submitted a letter dated July 12 providing replacement language for these two sections of the D-Plan.
During the presentation on criticality, the NRC asked a question regarding whether sufficient drums of spent resin could be stored in a manner that would exceed the bounding conditions of the fissile exemption criteria in 10 CFR 71.15. EPM submitted a letter dated July 21 providing information on the bounding conditions described in NUREG/CR-7239, Review of Exemptions and General Licenses for Fissile Material in 10 CFR 71, related to the development of the fissile exemption criteria. It is believed that the bounding conditions cannot be exceeded during storage of low-level radioactive waste that complies with these criteria.
These letters requested feedback from NRC on the acceptability of the text. The NRC wont respond with a letter; these documents have been listed as part of the D-Plan submittal. If the information provided is not acceptable, that will be addressed in a RAI.
Decommissioning Issues Addressing 10 CFR 74 in the D-Plan In an email dated January 13, 2023, the NRC advised EPM that the D-Plan did not state that the recordkeeping and reporting requirements of 10 CFR Part 74. On February 2, EPM proposed that certain text be added to Appendix M, Radiation Protection Plan - Rev 5, addressing those recordkeeping and reporting requirements. EPM requested that the NRC provide feedback on the acceptability of the language and the inclusion of that language in the radiation protection plan.
Cimarron Environmental Response Trust July 26, 2023, Project Status Teleconference Notes Page 3 of 4 This letter requested feedback from NRC on the acceptability of the text. The NRC wont respond with a letter; this document has been listed as part of the D-Plan submittal. If the information provided is not acceptable, that will be addressed in a RAI.
Acceptance of the Decommissioning Plan In an email dated May 25, the NRC sent EPM a copy of the Federal Register Notice announcing the acceptance of the D-Plan. The schedule for the NRC staff review is as follows:
Issue environmental review Request for Additional Information - October 2, 2023.
Issue safety review RAIs - October 2, 2023.
Receive response from licensee to Safety review RAIs - January 1, 2024.
Receive response from licensee to Environmental review RAIs - January 1, 2024.
Issue draft Environmental Assessment (EA) to the State of Oklahoma - June 1, 2024.
Final Environmental Assessment - November 30, 2024.
Finalize Safety Evaluation Report - November 30, 2024.
Issue Amended License Acceptance - December 31, 2024.
No further action is required.
DEQ Comments on the Decommissioning Plan In a letter dated June 13, the DEQ asked a question regarding the difference between the EPA requirements for a Quality Assurance Project Plan and the CERT Quality Assurance Program Plan (the CERT QAPP) provided in Appendix O of the D-Plan. EPM met with DEQ on June 20 to explain that:
The CERT QAPP provides the quality assurance management requirements, Activity Plans provide the sampling locations, media sampled, and the needed analyses for each activity, and The Sampling and Analysis Plan (SAP) contains the requirements for analytical methods, containers, etc., and SAP procedures tell how to:
o Collect samples of different environmental media, o Sample identification and control, o Decontamination procedures for sampling equipment, o Packaging and shipping samples, etc.
The DEQ was satisfied that the concerns they had regarding the CERT QAPP were addressed by the activity plans, the SAP, and SAP procedures, which are generated and followed as described in the CERT QAPP.
No further action required.
Cimarron Environmental Response Trust July 26, 2023, Project Status Teleconference Notes Page 4 of 4 Overview Presentations NRC and DEQ personnel attended the following presentations providing an overview of various aspects of Facility Decommissioning Plan - Rev 3 (the D-Plan):
- 1. An overview of the entire decommissioning plan (June 14 and June 23).
- 2. Groundwater flow models and calculation of the duration of remediation (July 24).
EPM will submit a letter addressing questions related to the determination of the distribution coefficients (Kd) used to calculate the duration of remediation. The July 12, 2016 report on the determination of Kd values will be file-shared to provide reviewers access to the native (Excel) file of data referenced in the report.
Status of Detailed Technical Review NRC reviewers are reviewing the D-Plan. RAIs related to the Environmental Assessment may be issued separately from RAIs related to the Safety Evaluation Report.
The NRC will conduct a review meeting on August 7 to check on the status of all D-Plan reviews in an effort to make sure the October 2 deadline can be met.
Schedule for the Next Teleconference The next project status teleconference will be conducted August 24, 2023.