ML23256A353
| ML23256A353 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 08/24/2023 |
| From: | Cimarron Environmental Response Trust |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| Download: ML23256A353 (1) | |
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Cimarron Environmental Response Trust August 24, 2023, Project Status Teleconference Notes Attendees:
NRC DEQ EPM Jim Smith Paul Davis Jeff Lux Lifeng Guo David Cates Glenn Tuttle Pam Dizikes Karen Pinkston Rachel Miller Christine Pineda Jon Reid Logan Crevelt Marla Morales Administrative Issues Preparation of Proposed Scope of Work and Budget for 2024 EPM is beginning to develop a scope of work for its primary contractors:
Enercon Services LLC (Enercon)
Burns & McDonnell Engineering Company, Inc. (BMcD)
Veolia Nuclear Solutions - Federal Services (VNSFS) for the time period January 1, 2024, through March 31, 2025. The scope of work will be based on the following schedule provided by the NRC:
Requests for Additional Information (RAIs) will be received by October 2, 2023.
Responses to RAIs will be submitted to the NRC by December 29, 2023.
A draft Environmental Assessment will be received by June 1, 2024.
An amended license approving the D-Plan will be issued by December 31, 2024.
EPM has authorized VNSFS to begin advancing drawings for the Western Area Treatment Facility (WATF) and the Burial Area #1 Remediation Facility (BARF). EPM will authorize BMcD to begin advancing drawings for remediation infrastructure after receipt of RAIs.
After drawings and specifications have been finalized, requests for +/- 10% bids will be sent to potential vendors for fabrication of equipment and the construction of remediation infrastructure, the WATF, and the BARF. Vendors will be selected based on the bids, and a construction funding request will be prepared to obtain approval of funds for construction. This funding request may be separate from the annual budget request. EPM will negotiate contractual terms with its contractors while VNSFS and BMcD will negotiate contractual terms with the vendors who will be fabricating/constructing in accordance with their construction scopes. Our goal is to be ready to execute contracts for construction as soon as the amended license is received.
EPM will submit a proposed scope of work and budget for 2024 before the end of October.
Decommissioning Issues Determination of Kd During the July 24, 2023, presentation on the groundwater flow models and estimated durations of remediation, NRC asked about the development of distribution coefficient (Kd) values and their impact on remediation duration estimates. In a letter dated August 8, 2023, EPM provided information on the determination of Kd values, and what EPM believed had been NRC acceptance of those values.
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Cimarron Environmental Response Trust August 24, 2023, Project Status Teleconference Notes This document has been identified as part of the D-Plan submittal. If the information provided is not acceptable, the NRC will request additional information when RAIs are issued.
Groundwater Extraction and Treated Water Injection in Transition Zones During that July 24 presentation, NRC expressed concerns about the treated water injection and groundwater extraction components ability to maintain saturation of impacted water-bearing zones. If subsurface material that contains groundwater exceeding the decommissioning criterion (the DCGL) is within the zone of drawdown, sorbed uranium could desorb and cause a rebound in uranium concentrations in groundwater when the extraction and injection systems are shut down.
EPM assumes that an RAI will be issued to address this concern. Regardless, EPM believes that to achieve the DCGL, uranium needs to be removed from only the more highly permeable material in the transition zones. Burns & McDonnell is preparing a technical memorandum (tech memo) to demonstrate:
- 1. Data shows that elevated concentrations of uranium in groundwater and soil are found within the more permeable soil in the transition zones.
- 2. The groundwater flow model for the BA1 transition zone shows that nominal flow rates for both groundwater extraction and treated water injection will maintain saturation of and capture of groundwater from the more permeable zones.
The tech memo will also explain that it is important to remember that the groundwater flow models (and the results from pilot tests performed in 2017) enabled Burns & McDonnell to locate and determine initial flow rates for groundwater extraction and treated water injection components. The goal is to maintain sufficient head in injection trenches to keep those more permeable zones saturated.
Transducers will be installed in both injection and extraction trenches, and if in-process monitor wells are properly located, monitoring the elevation of groundwater (and treated water near injection trenches) will determine if any flow rates need to be adjusted to maintain saturation of the more permeable zones.
This tech memo will be submitted after receiving RAIs to ensure that it will contain all the information the NRC requests related to this issue.
Monitor Well Abandonment and Installation During that July 24 presentation, NRC noted that a number of monitor wells will have to be abandoned to construct extraction and injection trenches. The D-Plan does not identify those monitor wells or indicate that they will be replaced. In addition, the locations of existing monitor wells arent in locations that would provide optimal in-process groundwater monitoring data.
EPM agrees that simply replacing existing monitor wells that will be abandoned to construct extraction and injection trenches will not produce the data needed for an effective in-process groundwater monitoring program.
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Cimarron Environmental Response Trust August 24, 2023, Project Status Teleconference Notes EPM assumes that an RAI will be issued to address this concern. Burns & McDonnell is preparing a response that provides revised figures, drawings, and tables which identify those monitor wells that will be abandoned and the locations of new monitor wells that will be installed for in-process and post-remediation groundwater monitoring.
This tech memo will be submitted after receiving RAIs to ensure that it will contain all the information the NRC requests related to this issue. Upon acceptance of the response by the NRC, the revised figures, drawings, and tables will replace those in the draft D-Plan.
Nuclear Criticality Safety During a June 29, 2023, presentation on nuclear criticality safety and material control and accounting, NRC asked questions regarding the nuclear criticality safety evaluation. The response was that all the information needed should be in D-Plan Appendix N. Upon reviewing Appendix N, it is possible that the appendix doesnt contain all the information described by the NRC reviewer. Enercon Services has reviewed Appendix N and the technical information upon which Appendix N was based when initially prepared in 2017.
Appendix N will be revised to include information requested in RAIs. It may also be revised to include current information on anticipated influent concentrations and enrichment values, which are lower than the values that were anticipated based on the infrastructure being considered when Appendix N was generated in 2017.
Status of RAI Development RAIs are nearly complete and are expected to be issued by October 2, 2023. Nuclear criticality safety RAIs may be issued shortly after October 2nd.
NRC will issue RAIs after obtaining concurrence review.
Environmental RAIs and Section 106 Consultation NRC staff indicated the request for information for the EA would be provided to CERT shortly.
NRC staff provided an update on the Section 106 consultation process. The next steps are presented in the action item below.
The NRC will provide the public with an opportunity to review the historic and cultural resources section of the EA. The NRC will send a letter to the SHPO and State Archaeologist enclosing the survey report and providing NRC conclusions about the proposed projects effects on identified resources.
Date and Time of the Next Teleconference The next project status teleconference will be conducted at 1:30 pm Central time, 2:30 Eastern Time, on September 20, 2023.
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