ML23346A262
| ML23346A262 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 12/08/2023 |
| From: | Lux J Cimarron Environmental Response Trust |
| To: | Miller R, James Smith Document Control Desk, Office of Nuclear Material Safety and Safeguards, State of OK, Dept of Environmental Quality (DEQ) |
| References | |
| Download: ML23346A262 (1) | |
Text
December 8, 2023
Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738
Ms. Rachel Miller Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101
Re: Docket No. 07000925; License No. SNM-928 Cimarron Environmental Response Trust Response to October 2, 2023, Request for Additional Information
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein responses to requests for additional information (RAIs) issued by the U. S. Nuclear Regulatory Commissi on (NRC) on October 2, 2023. It is our understanding that these RAIs constitu te one of three sets of RAIs that the NRC will issue based on the detailed technical review of Facility Decommissioning Plan - Rev 3 (D-Plan Rev 3) submitted to the NRC on October 7, 2022. Enclosure 1 presents each RAI, followed by a response. Figures, tables, or attachments related to an RAI response immediately follow each response.
Responses to some of the RAIs state that changes will be made to text, tables, or figures in D-Plan Rev 3 and/or the Radiation Protection Plan (RPP). EPM assumes that the license amendment that approves D-Plan Rev 3 will include the D-Plan that was submitted on October 7, 2022, as a tie-down, along with other documents submitted to the NRC after October 7, 2022 (including the enclosed responses to RAIs). Once this license amendment is issued, EPM will incorporate the changes identified in those post-October 2022 submittals into Facility Decommissioning Plan - Rev 4 (D-Plan Rev 4).
License Condition 27(e) authorizes the licensee to make changes to the D-Plan and/or the RPP without NRC approval, providing those changes satisfy certain requirements. License Condition 27(e) also states that the licensee must submit an annual report to NRC, containing a description of all changes, tests, and experiments made or conducted pursuant to this condition, including a summary of the safety and environmental evaluation of each such action. As part of this annual report, the licensee shall include any DP or RPP pages revised pursuant to this condition.
It is assumed that all changes incorporated into D-Plan Rev 4, based on tie-downs included in the forthcoming license amendment, have been a pproved by the NRC, unless they are explicitly
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
rejected by the NRC. Additional changes to the D-Plan and RPP will only be made if they meet License Condition 27(e) requirements. EPM will perform an evaluation of such changes to document compliance with License Condition 27(e) requirements. EPM will attach to the annual report of 27(e) changes those pages of D-Plan Rev 4 and RPP Rev 5 that have been revised, showing changes to text in tracked changes format. Changes to tables and/or figures will be addressed by providing copies of each table or figure from the D-Plan or RPP that was revised, followed by the revised table or figure in D-Plan Rev 4 or the final RPP Rev 5.
If clarification or additional information is needed, please notify us as soon as possible to minimize any potential delay in th e issuance of an amended license.
Sincerely,
Jeff Lux Trustee Project Manager
cc: (electronic copies only)
Stephanie Anderson and Linda Gersey, NRC Region IV Paul Davis, Keisha Cornelius, Pam Dizikes, David Cates, and Jonathan Reid, DEQ NRC Public Document Room vcpsubmittals@deq.ok.gov
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
ENCLOSURE 1 RESPONSE TO RAIS RELATED TO THE SAFETY EVALUATION REPORT
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
1.0 GWRM FLOW MODEL CALIBRATION AND MONITORING LOCATIONS 1.1 NRC RAI:
1.1.1 Description of the Issue Section 8.2, Groundwater Extraction and suppor ting documentation in Appendix K, Basis of Design (ML22308A076) indicate that extraction tr enches proposed for the Transition Zone (TZ) in Burial Area 1 (BA-1) were designed and evaluated based primarily on the results documented in the 2018 Remediation Pilot Test Report (ML18171A300) rather than the groundwater flow modeling runs included in the 2022 Gro undwater Flow Model Report (Appendix L; ML22308A183). The groundwater flow and partic le transport modeling indicate limited capture associated with the extraction trenches using hydraulic conductivity (K) values of 3 feet/day up to 50 feet/day in the vicinity of the trenches. These K values are significantly higher than the < 1 foot/day values which most closely reproduce the results of the 2017-2018 remediation pilot testing results which effectively dried out the trench following 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of pumping at approximately 16 gallons/minute (GPM). Althoug h lower pumping rates of 7 GPM are proposed for each of the two extraction trenches (GETR-BA1-01 and GETR-BA1-02; 14 GPM total for both trenches) and injection trench GWI-BA1-04, located between the two extraction trenches, is proposed at 10 GPM of water injection into th e TZ, it appears that the relatively low K values within the TZ will significantly limit the recovery and injection volumes for the trench system in BA-1 resulting in a limited capture zone footprint for the extraction system. Slug test data for TZ wells provided in the 2013 Hydrogeologic Pilot T est Report (ML20213C658) indicated six of the seven tested wells exhibited K values ranging from 0.0290 to 0.615 feet/day.
1.1.2 Basis of the Request Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities.
1.1.3 RAI:
Please provide an explanation as to why this is not a concern, or potential remedial alternatives or adjustments to the proposed system if the BA-1 trench extraction and injection system is unable to address the magnitude and extent of contamination within the TZ (transition zone) in a timely manner. Please summarize the types of in-process remedial data needed to evaluate potential system adjustments and the schedule for collection and review of these data during system operation. Please provide sufficient detail to a llow staff to properly evaluate the proposed alternatives or adjustments to the remedial design.
1.2 EPM Response:
1.2.1 Groundwater Contamination is Essentia lly Restricted to Permeable Zones Table GWRM-1-1 shows uranium concentrations in soil samples collected during boring and well installation. As demonstrated in the table, elevat ed uranium concentrations are almost exclusively associated with the more permeable, coarse-grained soils (sands and silty sands; referred to above as interconnected sand channel deposits). Out of 333 samples, there are four exceptions to this observation (see Table GWRM-1-1). In the case of these four exceptions, the soil sample in question was collected in an area of transition from a more permeable unit above to a less permeable unit below.
Slug test data for TZ wells provided in the 2013 Hydrogeologic Pilot Test Report (ML20213C658) indicated that six of the seven tested wells exhibited K values ranging from 0.0290 to 0.615 feet/day. Generally, these wells are located on the edge of the TZ where the more permeable sands and silty sands are thin, and the so ils predominately consist of clays and/or clay rich deposits. At the time when the slug testing was performed, the groundwater elevation for the TZ was generally below the permeable sands and silty sands at these locations. As a result, the hydraulic conductivity calculated from the slug test data is indicative of the lower permeability clays and clay rich deposits, and does not repr esent the more permeable, overlying sands and silty sands.
The objective and the subsequent design of the BA1 extraction and injection system proposed by Burns & McDonnell will maximize the flow of gr oundwater through the more permeable sands and silty sands. The BA1 groundwater remediation system is specifically designed to minimize drawdown in the extraction trenches. This will pr omote flow within the coarse-grained sands and silty sands of the TZ, thereby flushing and rec overing uranium from the subsurface in a timely manner.
1.2.2 Hydraulic Conductivity Values Used in the 2022 Groundwater Flow Model Comparatively higher hydraulic conductivity values were used in the 2022 modeling effort for the BA1 area (derived by evaluation of the 2018 reme diation pilot test data and the subsequent environmental sequence stratigraphy [ESS] study) because the data generated from this event provided actual in situ data representative of site aquifer conditions. During the 2018 remediation pilot test, groundwater was extracted from Extraction Trench GETR-BA1-01 at a rate of approximately 16 gpm. The pilot test was term inated at approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when the drawdown in the extraction trench GETR-BA1-01 approached the top of the pump assembly.
While the constant rate pumping test indicates that the trench cannot sustain a pumping rate of 16 gpm, the step test conducted prior to the constant rate test indicated that 13 gpm may be a sustainable extraction rate based on the asymptotic nature of the drawdown curve (flattening of the drawdown curve at 13 gpm).
The 2018 remediation pilot test demonstrated lowe r-than-anticipated extraction and capture rates and an ESS study was conducted to further evaluate the aquifer. In conjunction with the uranium concentration data for soil referenced above, the ESS study identified the interconnected sand channel deposits as the primary pathway for contaminants in the TZ. The 2018 ESS study was useful in refining the BA1 remedial action impl ementation plans and led to the design of a second extraction trench that maximizes access to the interconnected sand channel deposits. The values were updated in the 2022 modeling effort to reflect hydraulic conductivities across the site strata more accurately. The groundwater model was then run to simulate pumping and injection scenarios. Particle tracking based on the 2022 gr oundwater model depicts flow paths resulting from injection and extraction; it also demonstrat es hydraulic capture of groundwater in all areas in which groundwater exceeds the NRC Criterion, including the permeable TZ soils.
The average hydraulic conductivity data from the 2018 pilot test calculated from the 2018 Pilot Test data using the Cooper-Jacob straight line me thod was approximately 20 feet per day (ft/day).
This calculated value influenced the 2022 groundw ater flow model update. The 20 ft/day average hydraulic conductivity derived from the 2018 pilot t est is representative of the average across all lithological layers in the area influenced by th e pumping test. The hydraulic conductivity values from the 2018 Pilot Test are not solely representa tive of the high hydraulic conductivity sands and were biased low by the fine-grained gully f ill deposits that comprise the majority of the saturated zone. The higher conductivity values used in the 2022 modeling data are more representative of the interconnected sand channel de posits that will be targeted for groundwater recovery. Although the results of the 2018 pilot test were not directly used in the 2022 modeling, data from this pilot test was considered when deriving the 2022 modeling data and in the BA1 groundwater treatment remedial design.
The calculated value from the 2018 pilot test w as also considered in the BA1 groundwater treatment remedial design. The groundwater m odel is best used for evaluating pumping and injection scenarios and for estimating flow path s resulting from active remediation and hydraulic capture of key areas and permeable TZ soils.
The design extraction rate for each of the two extraction trenches (GETR-BA1-01 and GETR-BA1-02) during full system operation is 7 gpm per tr ench, well below the constant rate test of 16 gpm and the optimum step test rate of 13 gpm. Consequently, even though GETR-BA1-01 pumped dry during the pilot test, the combined design groundwater extraction rate of 14 gpm, which serves as the basis for BA1 TZ remediation timeframe estimates, is anticipated to be achievable.
In addition to a groundwater extraction test, an injection test was conducted during the 2018 remediation pilot test using injection trench GW I-BA1-01. The injection test was performed over a 13-day period. For the first 370 minutes of the test, potable water containing Rhodamine WT dye was injected into GWI-BA1-01 at a rate of 1.6 gpm. After 370 minutes, the injection rate was increased to 20 gpm. After 1,440 minutes (1 day), the flow rate was again increased to 30 gpm during working hours, and approximately 3 to 7 gpm during unattended nighttime hours. From 3 days until the test was terminated after 13 days, the flow rate was maintained at approximately 10.2 gpm, with a resulting groundwater mound ra nging from 10 to 15 feet above the static groundwater level, as measured under non-pumping conditions. The design flow rate for the proposed BA1 groundwater injection trenches GWI-BA1-01 and GWI-BA1-04 is 10 gpm, and 4 gpm each for GWI-BA1-02 and GWI-BA1-03. The injection test performed during the 2018 remediation pilot test demonstrated that this ra te can be sustained by the system without excessive mounding or flooding of the ground surface.
1.2.3 In Process Remedial Data During operation of the BA1 extraction/injection system, drawdown will be measured in the in-process monitor wells. Real-time adjustments to extraction and injection rates will be made to achieve the maximum zone of hydraulic influen ce while minimizing drawdown. Flow rates will be adjusted as necessary to maximize the groundwater extraction rates and minimize the remediation timeframe.
1.2.4 Additional Monitoring Locations The response to RAI GWRM-2 discusses the need for and provides the locations of new monitor wells that will be installed around and in-betw een the BA1 extraction and injection trenches.
these monitor wells will be added to the in-pro cess groundwater monitoring program. The entire in-process groundwater monitoring network is presented in the response to RAI GWRM-2.
Drawdown measured in observation wells during the 2018 remediation pilot test as a function of groundwater extraction under pumping conditions indicated influe nce extending approximately 40 to 45 feet away from the extraction trench. Using the Cooper-Jacob straight line method, drawdown was estimated to extend approximately 50 to 55 feet from the trench, while extracting groundwater at a rate of 16 gallons per minute ( gpm). However, the pilot test constant rate pumping test was terminated before steady-state conditions were achieved.
1.3 Conclusion During operation of the BA1 extraction/injection sy stem, drawdown will be measured using the in-process groundwater monitoring wells. Real-time adjust ments to the extraction/injection will be made to achieve the maximum zone of hydraulic influence while minimizing drawdown and mounding.
Flow rates will be adjusted as necessary to minimize drawdown while maximizing the groundwater extraction rates and minimizing the remediation timeframe.
New monitor wells will be installed; these will provide data that will enable effective evaluation of system performance around and in-between the extr action and injection trenches. The response to RAI GWRM-2 lists and shows the locations of new in-process monitor wells.
TABLE GWRM-1-1 URANIUM CONCENTRATIONS IN BA1 SOILS
2.0 GWRM WELL FIELD CLARIFICATION 2.1 NRC RAI:
2.1.1 Description of the Issue Section 8.6.1, Groundwater Extraction Monitoring, lists the in-process groundwater monitoring wells proposed for monitoring in both the BA-1 and Western Remedial Areas. Table 8-2 and Figure 8-8 list nine TZ groundwater monitoring wells in the vicinity of the two extraction trenches and injection trench GWI-BA1-04 with in BA-1A remediation area. The proposed well network within the BA-1A area leaves noticeable areas of data gaps, particularly southwest of proposed extraction trench GETR-BA1-02 and exte nding to the southeast of existing extraction trench GETR-BA1-01 (see attached Figure 8-8). Gi ven the complex, heterogeneous nature of the subsurface hydrogeology within the TZ, it is unclear how additional groundwater monitoring wells will not be required in order to properly ev aluate the performance of the extraction/injection trench system within the TZ. It is unclear how the significant uncertainties regarding the hydraulic conductivity values within the TZ do not warrant a more robust groundwater monitoring network in the vicinity of the trench es. It is also unclear whether the additional groundwater monitoring wells in the TZ will be properly developed, gauged, and sampled for uranium and other appropriate analytes prior to system startup.
It is also unclear how the horizontal extent of the induced drawdown created by the trench system will be determined without the addition of existing monitoring wells to the east of existing extraction trench GETR-BA-1-01, particularly TMW-5, 02W10, and 02W09, to determine groundwater level elevations prior to and during the trench operations.
2.1.2 Basis Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities.
2.1.3 RAI:
Provide construction specifics, locational informa tion, and the proposed monitoring schedule for any additional groundwater monitori ng wells planned in light of the uncertainties outlined in the RAIs above. Consideration of the installation of nested monitoring wells with screen intervals isolated within lithologic zones of interest ( sand interval(s) within permeable channel sand deposits; silt/clay deposits within saturated Upper Gully Fill/Lower Gully Fill (UGF/LGF) units) is recommended. The hydrologic responses of these isolated monitoring well screened intervals to injection and extraction in the BA-1A reme diation area, as well as groundwater sampling analytical results, would provide valuable info rmation on system capture and cleanup efficiency.
An updated Figure 8-8 and Table 8-2 would also be needed if additional wells are added.
2.2 EPM Response:
New monitor wells will be installed and added to the in-process gr oundwater monitoring network for the BA1 and Western Remediation Areas. Seventeen new monitor wells will be installed in BA1, and five new monitor wells will be installed in the 1206-NORTH remediation area. The additional wells in the BA1 and Western remediation areas will provi de data from the vicinity of injection and/or extraction trenches. The expanded monitoring networ k will be used to monitor both groundwater elevations and contaminant concentrations. The revised in-process groundwater monitoring network is presented in revised versions of Table 8-2 and Figures 8-7a, 8-7b, 8-8a and 8-8b, which are attached to and follow this response. Due to the de nsity of monitor wells in the vicinity of the BA1 extraction trenches, Figure 8-8a covers the entiret y of BA1, and Figure 8-8b provides an expanded view of the area surrounding the BA1 extraction trenches. Similarly, Figure 8-7a covers the entirety of the Western Remediation Area and Figure 8-7b provides an expanded view of the area surrounding the extraction trenches. All in-process groundwater monitor wells will be gauged and sampled for isotopic uranium mass concentration prior to system startup.
Construction of injection and extraction trench es will require seven BA1 monitor wells and one Western Area monitor well to be abandoned prior to trench construction. In BA1, Monitor Wells 02W01, 02W02, 02W27, 1316R, 02W53, TMW-09, a nd TMW-21 will be abandoned. In the Western Area, Monitor Well MWWA-03 will be abandoned.
The use of nested monitor wells was evaluated and dismissed following a review of historical site documentation. In January 2003, Cimarron Co rporation (Cimarron) submitted the paper Justification for Utilization of Fully Penetrating Groundwater Monitoring Wells in Shallow Alluvial Aquifer at the Cimarron Facility (ML030350236). This report presents both hydrogeological and future land use information that explains the rationale behind Ci marron's decision to install monitor wells screened across the full saturated thickness of the alluvial aquifer. The NRC criterion for groundwater is based on a drinking water scenario, and water wells insta lled for future groundwater use would be installed with screens that maximize water production. These wells would not be constructed with short, discrete screen intervals within a 20- to 30-foot-thick aquifer.
Fully penetrating monitor wells will provide suffi cient information to demonstrate remediation efficiency, compliance with the NRC criterion, and evaluation of plume capture. Monitor well abandonment, installation, and development w ill be conducted in accordance with the CERT Procedure SAP-110, Well Installation and Aband onment. Table 8-2 indicates the frequency with which these new monitor wells will be measured for de pth to water and sampled for uranium analysis.
The use of nested monitor wells in place of fu lly penetrating monitor wells would not provide information that is useful to evaluate system capt ure, cleanup efficiency, or compliance monitoring. It has been demonstrated that uraniu m within upland areas at the site is contained almost exclusively within fractures in sandstone formations, or with in interconnected sand channel deposits in the TZ formation. Historically, attempts to collect dept h-discrete groundwater samples within the TZ have been unsuccessful due to the low-permeability nature of the gully fill sequence. Fully penetrating monitor wells will provide in-process data for evalua ting plume capture and remediation by providing access to the interconnected sand channel deposits that are present at variable depths within BA1.
2.3 Conclusion The expanded monitoring network will provide the da ta needed to evaluate the hydraulic performance of injection and extraction components during syst em operation. In-process monitoring data will also be used to evaluate contaminant plume capture and remediation efficiency. Nested monitor wells need not be installed as a part of the expanded monitoring network.
When the amended license approving Facility Decommissioning Plan - Rev 3 (the D-Plan) is issued, the following will replace existing D-Plan tables and figures:
Table 8 Revision 1, In-Process Groundwater Monitoring Locations Figure 8-7a - Revision 0, Western Area In-Process Groundwater Monitoring Locations Figure 8-7b-Revision 0, Western Area In-Process Groundwater Monitoring Locations -
U>DCGL Areas Figure 8-8a - Revision 0, Burial Area #1 In-Process Groundwater Monitoring Locations Figure 8-8b - Revision 0, BA1 In-Process Groundw ater Monitoring Locations - Trench Area The text of D-Plan Section 8.6, In-Process Groundwater Monitoring will be revised to address the abandonment of several monitor wells and the installation of the additional monitor wells.
TABLE 8 REVISION 1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS
Table 8 Revision 1 Prepared by: Stephen Wood In-Process Groundwater Monitoring Locations Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment MonitoringLocation Uranium DTW 02W25 A Q 02W30 A Q 02W40 Q Q 02W41 A Q 02W42 A Q 02W47 Q 02W50 A Q 02W51 A Q 1409 A Q 1416 Q Sandstone B 1417 Q 1418 Q 1419 Q 1420 Q 1421 A Q 1422 A Q TMW01 A Q TMW02 A Q BA1A TMW08 A Q TMW-18 A Q TMW-20 Q Q TMW25 A Q Sandstone C TMW-17 A Q 02W03 Q Q 02W06 Q 02W10 A Q 02W20 Q Q 02W25 A Q 02W26 Q Q 02W28 A Q Transition Zone 02W39 A Q 1315R Q Q 1404 Q Q 1405 Q Q 1412 Q Q 1413 Q Q 1414 Q Q 1415 Q Q
Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 1 of 3 Table 8 Revision 1 Prepared by: Stephen Wood In-Process Groundwater Monitoring Locations Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment MonitoringLocation Uranium DTW 1423 Q Q 1424 Q Q BA1-A Transition Zone 1425 Q Q (continued) (continued) 1426 Q Q TMW05 A Q TMW06 Q Q TMW07 A Q 02W04 A Q South of GEBA102 02W32 Q Q TMW13 Q Q North of GEBA102 / 02W07 Q Q South of GEBA103 02W08 Q Q 02W14 A Q BA1B 02W19 Q Q North of GEBA103 / 02W18 A Q South of GEBA104 02W37 A Q 02W38 A Q 02W44 Q Q 1410 Q Q North of GEBA104 02W43 A Q 1411 Q Q MWWA09 Q Q 1206NORTH 1429 Q Q 1430 Q Q 1431 A Q T62 Q Q T63 Q Q T64 Q Q T65 Q Q T66 A Q WAA U>DCGL T68 Q Q T69 A Q T72 Q Q T75 A Q T76 A Q T77 A Q T79 A Q
Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 2 of 3 Table 8 Revision 1 Prepared by: Stephen Wood In-Process Groundwater Monitoring Locations Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment MonitoringLocation Uranium DTW T84 A Q WAA U>DCGL T104 Q Q (continued) T105 Q Q 1427 A Q 1428 A Q 1351 Q Q 1352 Q Q WUBA3 1356 Q Q 1358 Q 1359 A Q
Notes:
- DTW depth to water DTW measurement frequency for the first 3 months of operation is in Section 8.6.1.
- Q quarterly
- A annually
- Frequency of analysis for uranium may change as data trends are established.
Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 3 of 3 FIGURE 8-7A WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS
FIGURE 8-7B WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS U>DCGL AREAS
FIGURE 8-8A BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS
FIGURE 8-8B BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS TRENCH AREA
3.0 GWRM GROUNDWATER FLOW MODEL EVALUATION 3.1 NRC RAI:
3.1.1 Description of the Issue The BA-1A remedial plan, included in Decommissioning Plan Version 3, primarily focuses on recovery and treatment of uranium contaminated groundwater in the shallow sandstone bedrock and the Transition Zone soils. The TMW-8 well, completed in Sandstone B and screened from approximately 10 to 24 feet below ground surface (BGS), is listed with a uranium concentration of 2,589 ug/L in the plan. Located upgradient of the Transition Zone area, this well represents the highest uranium concentration in a Sandstone B well in the BA-1 remediation area. As described in Section 8.4.1, Water Injection Trenches, of the Decommissioning Plan, Version 3, Injection Trench GWI-BA1-01 is in the southern portion of the former burial trenches, approximately 100 to 120 feet south of TMW-8, with Injection Trenches GWI-BA1-02 and 03 located to the west and northwest, respectively. Each trench is proposed for completion in the Sandstone B Unit.
Based on the flow modeling results presented in Figure 4-3 of the Decommissioning Plan, only water injected from the GWI-BA1-01 trench tr avels through the TMW-8 hot spot area (see attached Figure 4-3). Evaluation of the groundwat er flow model calibration data set and process presented in the 2022 Groundwater Flow Mode l Report (Appendix L; ML22308A183) indicates that overestimation of water level elevations in certain Sandstone B wells included in the calibration (1314; 02W50, and 02W52) and omissi on of the 02W51 well as a calibration point could have resulted in an unde restimation of the easterly to east-northeasterly groundwater flow direction in the vicinity of Injection Trench GWI-BA1-01 (see attached Figure 3-2). Contoured groundwater flow maps of observed groundwater levels in the Sandstone B Wells from December 2012, March 2015, Augus t 2016, and July 2020 (see attached Flow Maps 1 through 4) illustrate the accentuated easterly and east-northeasterly flow not captured by the flow model. This apparent discrepancy in the modeled groundwater flow and the resulting particle tracking, as well as the presence of preferential pathways north of the eastern portion of the injection trench (toward well 1409) noted in the 2018 Remediati on Pilot Test Report (ML18171A300), may result in reduced effectiveness of the injection and flus hing in the TMW-8 hot spot area that does not appear to have been addressed in the application.
3.1.2 Basis Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities.
3.1.3 RAI:
Please evaluate the potential implications of the flow model calibration and the preferential pathway issue on the design and operation of Injection Trench GWI-BA1-01 and the adjacent system components. Explain why, at a minimum, additional in-process monitoring points, including, but not limited to, Sandstone B we lls 1409, TMW-20, 02W25, 02W51, TMW-2, and 02W50, are not necessary in the proposed groundwat er monitoring locations in the D-Plan (see attached Figure 8-8 for the listed monitori ng well locations). Monitoring for potential groundwater seeps during trench operation, particularly on the topographic slope east of the 1409 well, may be warranted based on the potential prefer ential pathway noted in area in the previous pilot test report. Also explain why Sandstone B Monitoring well TMW-18, located at the northern end of Injection Trench GWI-BA1-03 should not be included in the in-process groundwater monitoring locations.
3.2 EPM Response:
3.2.1 Concentration of Uranium in TMW-08 and 02W39 As discussed in the response to RAI GW RM-1, Table GWRM-1-1 presents uranium concentration data for soil samples collected dur ing soil borings and well installations conducted in 2002. Elevated uranium concentrations are almost invariably associated with the more permeable, coarse-grained sand channel deposits (sands and silty sands) present within the TZ.
TMW-08 was observed to have elevated uranium concentrations in samples collected in 2013, 2016, and 2017. Table GWRM-3-1 and Figure GWRM 1 show that the uranium concentration in TMW-08 has trended downward from the 2,5 89 micrograms per liter (µg/L) observed in 2017 to 96 µg/L in 2023 (below the DGCL of 201 µg/L). A similar trend has been observed for nearby Monitor Well 02W39, with a reduction from the 851 µg/L observed in 2013 to 260 µg/L in 2023 (see Figure GWRM-3-1). These data indicate that the significantly elevated uranium concentrations previously reported in TMW- 08 have migrated downgradient (i.e., TMW-08 should no longer be considered a uranium plume hot spot).
3.2.2 Groundwater Flow Direction Evaluation The 2022 Groundwater Flow Model Report provided as Appendix L to the D-Plan included high groundwater elevations in certain Sandst one B wells (1314, 02W50, and 02W52) in the calibration, but omitted the groundwater elevati on for 02W51. Further evaluation was performed to determine the validity of the groundwater el evation data. Anomalous groundwater elevations were observed in Monitor Wells 1407, 1408, 02W01, 02W25, and 02W51. The boring log for 02W51, in conjunction with the historical water le vels, indicates that this well monitors a perched water zone. Similarly, examination of th e boring log for Monitor Well 02W25, located approximately 70 feet to the north, indicates wa ter was encountered 7.5 feet bgs during drilling.
Soils deeper than 7.5 feet were described as d amp; this indicates a possible perched water zone.
The boring log for 02W01 notes that soils deeper than 5 feet were dry.
The boring logs and construction details for we lls 1407 and 1408, located approximately 50 and 110 feet to the northeast of 02W51 respectively, were also reviewed. Similar to 02W51, these two wells are located inside the former waste burial trenches. Historically, these wells have exhibited groundwater elevations four to five feet hi gher than adjacent wells (less than 10 feet away) located just outside the waste trenches. Both wells have total depths of approximately 11 feet bgs and appear to be monitoring a shallower zone of groundwater than the surrounding wells.
Boring logs for Monitor Wells 1407, 1408, 02W01, 02W25, and 02W51 can be found in Attachment GWRM-3-1. Due to their apparently anomalous groundwater elevations, these wells were eliminated from groundwater flow model calibration.
Discrepancies between the groundwater flow model, particle tracking data and actual groundwater elevations could indicate reduced effectiveness of the extraction and injection systems. Additional evaluation of the modeled groundwater flow was conducted to evaluate consistency with the particle tracking model.
The potentiometric surface map shown on Figure GWRM-3-2 was generated based on groundwater elevations measured on August 23, 20 19. This map shows that the groundwater flow direction is initially north and then turns to the northwest along the flow path of interest. This interpretation is further supported by the hist orical mapping of the uranium plume which has consistently followed the same north to northwest orientation. The interconnected sand channel deposits mapped during environmen tal sequence stratigraphy (ESS) evaluation were observed to follow a similar orientation. Based on these re-interpreted groundwater contour and flow maps, there does not appear to be a flow path that is oriented to the northeast.
Once installed, in-process groundwater monitori ng will provide the data needed to adjust injection and extraction flow rates to optim ize contaminant removal. Should groundwater elevation data indicate unexpected directions of groundwater flow, additional extraction wells will be considered to achieve and maintain capture of uranium exceeding the NRC Criterion.
3.2.3 Potential Impact to Ephemeral Stream An ephemeral stream exists to the east of the BA-1 remediation area. Existing Monitor Wells 02W20 and 02W26 are located between Injec tion Trench GWI-BA-1-01 and the ephemeral stream. Both monitor wells are included in th e in-process groundwater monitoring program, and will be measured for depth to groundwater on a quarterly basis. The average static (existing condition) groundwater elevation in these two monito r wells will be compared with the elevation of the stream bed near these wells.
Based on groundwater elevation data collected during site-wide depth to water measurements from December 2012 through July 2023, the mean plus two standard deviations (plus-2) groundwater elevation in 02W20 is 939.17 feet AMSL (the mean value is 937.80). The elevation of the streambed near 02W20 is approximately 938 feet AMSL. The mean-plus-2 groundwater elevation in 02W26 is 938.33 feet AMSL (the mean value is 936.25). The elevation of the streambed near 02W26 is approximately 937 feet AMSL.
The response to RAI GWRM-2 shows that 02W20 and 02W26 will be included in the in-process groundwater monitoring program, and that both wells will be sampled on a quarterly basis for analysis for uranium. If for either monitor well:
The concentration of uranium > 30 ug/L and The groundwater elevation exceeds the streambed elevation and The streambed has flowing water in it a surface water sample will be collected from the stream for analysis for uranium in accordance with CERT Procedure SAP-103, Surface Water Sampling.
3.2.4 Monitor Well TMW-18 Sandstone B Monitor Well TMW-18, located at the northern end of Injection Trench GWI-BA1-03, will be included in the in-process groundwater monitoring network. This well will provide data that will be used to monitor the hydraulic influence of Injection Trench GWI-BA1-03. The inclusion of Monitor Well TWM-18 in the in-p rocess groundwater monitoring network is further discussed in the response to RAI GWRM-4. It should be noted that the concentration of uranium in any surface seepage emanating from the northern end of GWI-BA-03 is expected to be below the NRC Criterion.
3.3 Conclusion Groundwater elevation data from all monitor wells in the area were used to generate the potentiometric surface map presented in Figure GWRM-3-2. This potentiometric surface map shows that groundwater in the vicinity of Monitor We ll TMW-08 does not flow to the northeast as depicted in potentiometric surface maps drawn using a portion of the data. Flow directions depicted in Figure GWRM-3-2 conform to the orientation of the uranium plume as well as the interconnected sand channel deposits mapped during ESS evaluation, affirming the interpreted groundwater flow directions.
The concentration of uranium in TMW-08 has d eclined to less than the NRC Criterion and is approaching the NRC Criterion in nearby Monitor Well 02W39. Regardless, groundwater in the vicinity of Monitor Well TMW-08 should be captured by Extraction Trench GETR-BA1-01.
Groundwater elevations and uranium concentrati ons in Monitor Wells 02W20 and 02W26 will be monitored; surface water samples will be collected from the nearby ephemeral stream for analysis for uranium if conditions specified above are identified.
When the amended license approving the D-Plan is is sued, the text of Section 8.6 of the D-Plan will be revised to incorporate the monitoring descr ibed in Section 1.2.3 above in the in-process groundwater remediation monitoring program.
TABLE GWRM-3-1 URANIUM CONCENTRATION IN MONITOR WELLS TMW-08 AND 02W39
ATTACHMENT GWRM-3-1 SOIL BORING LOGS
MONITORING WELL INSTALLATION DIAGRAM
Protective Pipe -Casing Cap Vent 1 Yea Q No 0" Yet No D Lock ? Yes O No Steel PVC ^Weep Hole ? Yea No 0^
Surveying Pin ? -------- Concrete Pad __M______Ft. x H Ft.x JzL. Inehes Yea 0 No O DRILLING INFORMATION:
I. Borehole Diameter* ^_____ Inchea.
Concrete E. Were Drilling Additivee Used ? YeaO No Q Revert Q Bentonite O Water 0 Solid Auger Hollow Stem Auger 0^
- 3. Wee Outer Steel Caeing Used f Yea Q No0
Cement/Bentonite Grout Mix ' Depth* A/A to AjA Feet.
Yee No£f 4. Borehole Diameter for Outer Casino ^ inchea.
5.5 Gallons Water to WELL CONSTRUCTION INFORMATION:
94Lb. Bag Cement &. I.Type of Caeing: PVC Ef Galvanized Taflon 3 5 Lb. Bentonite Powder Stainless Q Other---------------------------------------------
Others 2. Type of Casing Joints: Screw Couple 0 Glue Couple Other____________________
- 3. Type of Well Screens PVC 0 Galvanized Q Stainless 0 Teflon Q Other Bentonite Seal 4. Diameter of Casing and Well Screen:
Pellets Ef Slurry Q Casing inches. Screen9 inches.
- 5. Slot Size of Screen: l e/
Filter Pack 6. Type of Screen Perforation: Factory Slotted Above Screen Hacksaw 0 Drilled Other____________
- 7. Installed Protector Pipe w/Lock: Yes 0 No WELL DEVELOPMENT INFORMATION:
I. How was Weil Developed ? Bailing fjjj Pumping Air Surging CAIr or Nitrogen) 0 Other__________
FILTER PACK MATERIAL Silica Sand Ef 2. Time Spent on Well Development ?
/----------------Minutea/Hours Waehed Sand 0 3. Approximate Water Volume Removed ?___. Gallons
Pea Gravel 4. Water Clarity Before Development t Clear 0 Turbid 0 Opague 0 Others 5. Water Clarity After Development ? Clear 0
^2/2 0 Turbid 0 Opaque 0 Sand Size S. Did Water have Oder t Yea 0 No 0
If Yes, Describe_________________________
- Donee Pfiaee Sampling Cup ?>> Did Water-have any Color ? Yee 0 No0 Bottom Plug If Yes, Describe Yee El NoQ WATER LEVEL INFORMATION:
Over drilled Material Water Level Summary (From Top of Casing)
Backfill During Drilling - - Ft. Date_______
Grout 0 Sand Before Development i%2.L Ft. Date ll_fz I /26f J Caved Material 0 Others___________ After Development______ Ft. Date
DrIIlerXFfrm /^AST-AO£ Drill Rig TypeDate. Installed l(./£/bz_
Drill.Crew K, J-C ^/%elf No. 1%1 Hydrologist J- ^xJCPtrt' ms jaaj ui sjduios pajaAODay jo ^Sual pnpy S3AYNIOMOOO ai<<3 MO NOJAVOOI A3AVTD Blduii>s JO tuo^og puo dol ipdaQ Hld3Q
AVID j A83AOD3H aaiawvs aanvM38 m nswv idl NOU.VA313 30VM9 ONLLSIX3 ' A11IS I ON snonNiiNOD *NIHl
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(Pi I^ql
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b-X 0S 1\\N Z+iVl-SVid t^oj Ajp tSZ) 1JQS (9/h'ZQl) -i-7/S D3H Hid3G 3 *0N SSVTD SOol NOIldlHOSSa DIOOlOHin 1333o SNOiivAaasao aiau (uidd) 1003 raid HO SMHVW3H aid H3d nos Nl aidwvs nos SMOia CBUINfl Hidia
LOhl H38WnN 9NIH0S NOIlVOOl MuZ> £i.8s>l,____ loaroud ANVdWOO
901 ONUdOa nos MONITORING WELL INSTALLATION DIAGRAM
Protective Pipe -Casing Cap Vent ? Ye* Q No Ye* 0f No Lock ? Yes No Steel PVC O ^Weep Hole ? Ye* No O'
Surveying Pin ? Ft*Concrete Pad !ji____ Ft.* V Ft. x Inches Yee Cl No DRILLING INFORMATION:
- 1. Borehole Diameters__________Inches.
Concrete 2. Were Drilling Additives Used t YesQ No Q Revert Q Bentonite O Water Q,
Solid Auger Q Hollow Stem Auger 0
- 3. Was Outer Steel Casing Used ? Yea Q NoO
Cement/Bentonite Grout Mix Depth= f/4 to Feet.
Ye* No O' 4* Borehole Diameter for Outer Casing. Inches.
5.5 Gallons Water to WELL CONSTRUCTION INFORMATION:
94 Lb. Bag Cement &. I.Type of Casings PVC 0! Galvanized Q Teflon Q 3 5 Lb. Bentonite Powder Other: Stainless Q Other__________________,_______
- 2. Type of Casing Joints: Screw Couple S' Glue-Couple Other_________._________________
/' 25 H.is 3. Type of Well Screens PVC QK Galvanized Q Stainless Teflon Other_________________
Bentonite Seal 4. Diameter of Casing and Well Screen:
Pellets 0^Slurry Q Casing _ % _ inches. Screen ^
3-7S Go Inches.
- 5. Slot Size of Screen: Q.O f Filter Pack Zb Ft. 6. Type of Screen Perforation: Factory Slotted Above Screen l/i Hacksaw Q Drilled Other.
- Jr*' 7. Installed Protector Pipe w/Lockx Yes Ef No Q 5-2S So I. V.
WELL DEVELOPMENT INFORMATION:
I. How was Well Developed? Bailing Pumping Q Air Surging (Air or Nitrogen) 0 Other FILTER PACK MATERIAL Silica Sand gj^ 2. Time Spent on Well Development ?
5 Ft. ------------------/.----------------Mlnutea/Houra Washed Sand Q 3. Approximate Water Volume Removed ?___, Gallons
Pea Gravel Q 4. Water Clarity Before Development ? Clear Q Turbid Opaque Others__________________ 5. Water Clarity After Development ? Clear Q
Sand Size /2.0 Turbid Q Opaque
- 6. Did Water have Oder t Yes No in.zs 13-b If Yes, Describe_____________
- Dense Phase Sampling Cup 7* Did Water-have any Color ? Yes Q No Q Bottom Plug If Ye*
- Describe____
Ye>>0f NoQ WATER LEVEL INFORMATION:
Overdrilled Material Water Level Summary (From Top of Casing)
Backfill During Drilling_______.. Ft. Date______ _
Grout Sand Before Development fr3/.Ft. Data 1(1 7 Caved Material Q Others____________ After Development________ Ft. Date,
_5cf/U^ I is n Drlller/Flrm CASc**c Drill Rig Type Data Installed
Drill Crew F. HA/r> J-VfoUEfltA ^ %^W*H No. 1^0$ Hydrologist jl $ rsz 111 SOIL BORING LOG
PROJECT LOCATIONBORING Bu^s i cc f68"7y Cccr ~Y NUMBER Was
DEPTH u UNIFIED BL0W5 SOIL SAMPLE go SOIL P1D REMARKS OR IN LITHOLOGIC DESCRIPTION l9 HELD PER (ppm) FIELD OBSERVATIONS FEET o CLASS FOOT NO. DEPTH REC.
Slt-T-dark. r&ddiTh bfouiA 3/(A Soft-dry. ta>>pl<<^'uy J ML S-o
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to Z © to
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JL Water Table (24 Hour) GRAPHIC LOG LEGEND DATE DRILLED DEBRIS ?l/f5/?pn 1 ) °f I Water Table (Time of Boring) CLAY 9?FILLdril lin g meth od PID Photoionization Detection (ppm)
NO. Identifies Sample by Number HIGHLY TYPE Sample Collection Method SILT OftGANCpEM}
[S?l SANDY CA$>CAQE ~ !). (j /Z-CSHA/^
SPLIT-ROCK SAND E£JClAY BARREL AUGER CORE 1^1 CLAYEY LOGGED BY.
§I £13 GRAVEL (ibJ SAND J-Bv^h
THIN-CONTINUOUS NO wq SILTY EXISTING GRADE ELEVATION (FT. AMSU WALLED SAMPLER S RECOVERY l2s3 CLAY TUBE nE DEPTH. Depth Top and Bottom of Sample J] CLAYEY LOCATION OR GRID COORDINATES REC. Actual Length of Recovered Sample in Feet E3 SILT.
KERR-McGEE CORPORATION HYDROLOGY DEPARTMENT MONITORING WELL INSTALLATION DIAGRAM
Protective Pipe - ------Caelng Cep Vent t Yee QNo
Yee 53 No................Lock T Yee No Steel PVC §0,-Weep Hole t Yee No
Surveying Pin ? ___ __ Concrete Pad A Ft. x 4 Ft. x Inchee Yee No Q DEPTH DRILLING INFORMATION:
FROM 1. Borehole DIameter= 3 VT Inchee.
Concrete TOP OF 2. Were Drilling Addltlvea Ueed 1 Yee0 No Q CASING Revert Q BentonlteQ WaterD Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Caelng Ueed f Yee Q No(2f
Cement/Bentonite Grout Mix Depths__________to___________ Feet.
Yee 0 NoQ 4. Borehole Diameter for Outer Caelng_______ Inchee.
5.5 Gallons Water to WELL CONSTRUCTION INFORMATION:
94Lb. Ba9 Cement &.
3 5 Lb. Bentonite I.Type of Caelng: PVC Galvanized 0 TeflonQ Powder Stalnleee Q Other____________________________
Others ____ 2. Type of Caelng Jointer Screw-Couple (3 Glue-
Couple 0 Other____________________
- 3. Type of Well Screen: PVC Galvanized Stalnleee 0 Teflon O Other______________
Bentonite Seel 4. Diameter of Caelng and Well Screen:
Pellets^ Slurry 0 Caelng cX Inchee. Screen a Inchee.
- 5. Slot Size of Screen:- 0,0 iO Filter Pack 6. Type of Screen Perforation: Factory Slotted 0 Above Screen HackeawQ Drilled Q Other____________________
- 7. lnetalled Protector Pipe w/Lock: Yee (3 NoQ
WELL DEVELOPMENT INFORMATION:
- 1. How wae Well Developed f Balling Q Pumping 0 Other FILTER PACK MATERIAL -falocgL.
Silica Sand ^ 2.
QD -jtinutep^Houre
Waehed Sand 0 3. Approximate Water Volume Removed f Gallone
Pea Gravel Q 4. Water Clarity Before Development f Clear 0 Turbid 0 Opaque Otheri_______ 5. Water Clarity After Development f Clear 0
Sand Size <^-0 Turbid §3 Qpaque 0
- 6. Did Water have Oder f YeiQ No H?
If Yee>> Describe___________________________
Denee Phaee Sampling Cup q 7. Did Water have any Color lolor IMYesCa* No Q
Bottom Plug If Yee, Doacrlbe Yee (3 No 0 WATER LEVEL INFORMATION:
Overdrilled Material Water Level Summary (From Top of Casing}
Backfill During Drilling______, Ft* Ddtd..
Grout Sand 0 Ft. Date ~l Caved Material 0 Before Development.
Otheri_________ After Development _ Ft. Date______________
Drill Rig Type SfrgAaSt<<xrlDD>te Drlller/Flrm AEX lnetalled 71/5/02.
Kerr McGee \\ 0 Drill Crew GfA<A.YA Well No. & & W I Hydrologlet V/* lOO\\
SOIL BORING LOG KM 5655-A KERR-McGEE CORPORATION HYDROLOGY DEPARTMENT MONITORING WELL INSTALLATION DIAGRAM
Protective Pipe--------------- __ Casing Cap Vent T Yes 0 No Q Yee No Q- ________Lock? Ye* No
Steel PVC ~,Weep Hole T Yes 0 No 0 Surveying Pin ? ____Ft. Concrete Pad 4 Inches 4 Ft. x 4 Ft.x Ye* 0 No 0 DRILLING INFORMATION:
DEPTH FROM 1. Borehole Diameter= 8 ¥/ Inches.
Concrete Ft.BELOWTOP OF 2. Were Drilling Additives Used T Yes0 No GRADE CASING Revert 0 Bentonite 0 Water 0 Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Casing Used ? Ye* Q No0^
Cement/8entonIte Grout Mix Depth=__________ to___________Feet.
Y**D No0 4. Borehole Diameter for Outer Casing_______ Inches.
5.5 Gallons Water to WELL CONSTRUCTION INFORMATION:
94Lb. Bag Cement & _________Ft-3 5 Lb. Bentonite 1. Type of Casing: PVC Ej Galvanized Q TeflonQ Powder Stainless 0 Other___________________________
Other:_______ 2. Type of Casing Joints: Screw Couple IS Glue-
Couple 0 Other ______________________________
- 3. Type of Well Screen* PVC ^ Galvanized Q Stainless O Teflon D Other__________________
Bentonite Seal £ r Ft. 4. Diameter of Caeing and Well Screen;
Pellet* QZ] Slurry 0 9.5 Casing <^y Inches. Screen Inches.
- 5. Slot Size of Screen*
- Q t O l O Filter Pack SK Ft. 6. Type of Screen Perforation: Factory Slotted Above Screen Hacksaw 0 Drilled 0 Other________________
)1 -t? 7. Installed Protector Pip* w/Lock* Yes (3 No 0 WELL DEVELOPMENT INFORMATION:
I. How was Well Developed f Bailing Q Pumping 0 Air Surging (Air or Nitrogen) fiQ Other FILTER PACK MATERIAL AwAop sayA. pacE Sura
- 2. Time Spent on Well Development f ^
Silica Sand ^
-/- Minutes/Hour*
Washed Sand 0 3. Approximate Water Volume Removed Gallons
Pea Gravel Q 4. Water Clarity Before Development ? Clear 0 Turbid 0 Opaque 0 Other*___________________ 5. Water Clarity After Development 7 Clear 0
Turbid 0 Opaque 0 Sand Size 6. Did Water have Oder ? Yes 0 No 0
If Yes. Describe___________________
Dense Phase Sampling Cup q 3 Ft. 7. Did Water have any Color f Yes 0 No 0
Bottom Plug If Yea. Describe_________________
Yes No Q WA TER LEVEL INFORMATION:
Overdrilled Material Water Level Summary (From Top of Casing)
Backfill Ft. I During Drilling_________________Ft. Date--------------
Grout Q Sand Before Development. Ft. Date.
Caved Material Q X_. 52-*S'"
After Development _ Ft. Date.
Other*_____
Drlller/Flrm /V hi X {Ooate Installed 7 - O 2*
Drill Rig Type Kerr McGee EZ"P Drill Crew v )ol\\v\\r\\M GircxVv\\Qw\\ Well No. O 2-VJ Zff~ Hydrologist \\^r Poor k^ie.1 -sh SOIL BORING LOG KM 5655-A KERR-McGEE CORPORATION KM SUBSIDIARY BORING.. _ _
Hydrology Dept. Engineering Services C.UY\\Ourf Or\\ OK Arms C i F NUMBER OZ. W Z. b
DEPTH UNIFIED BLOWS SOIL SAMPLE IN LITHOLOGIC DESCRIPTION IS SOIL PER PID REMARKS OR FEET OC -* FIELD FOOT (ppm) NO. DEPTH REC.FIELD OBSERVATIONS O CLASS.
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Water Table (24 Hour) GRAPHIC LOG LEGEND OATE DRILLED DEBRIS 7-^-oi of 2_
Water Table (Time of Boring) CLAY S FILL DRILLING METHOD Photoionization Detection (ppm) f\\S>A ~ (jO>>Avt\\tAOULS Sa^Wt' Identifies Sample by Number HCHir Sample Collection Method SILT SORGANIC (?EW)DRtLlFnHY >> 1
PS3 SANDY AE1\\ ~ j. 6lreJkcx^vT SPUT-ROCK E&3 SAND QiJJ CtAY BARREl AUGER CORE LOGGED BY
£12 GRAVEL fv7l CLAYEY y-^ - P&oV^'"
iiSL^ANO THIN-CONTINUOUS NO RSI SILTY EXISTING GRADE ELEVATION IFT AMSU)
WAtlED SAMPLER RECOVERY CU CLAY TUBE IE s SToNe DEPTH. Depth Top and Bottom of Sample ffl3SfeT LOCATION OR GRID COORDINATES REC. Actual Length of Recovered Sample in Feet ?2.4>>AJ i/zs B SOIL BORING LOG KM 5655-A KERR-McGEE CORPORATION KM SUBSIDIARY BORING ^._____
Hydrology Dept. Engineering Services Cimarron OK Ar^O-S CiF NUMBER (7^U3 oiS
DEPTH UNIRED BLOWS SOIL SAMPLE IN UTHOLOGIC DESCRIPTION IS SOIL PER PID REMARKS OR FEET IVO REID FOOT (ppm) NO. DEPTH REC.FIELD OBSERVATIONS CUSS.
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-2. Water Table (Time of Boring)
PID Photoionization Detection (ppm) CLAY lS FILL DRILLING METHOD NO. Identifies Sample by Number =3 HCHW (ASA-Co>^ VY\\M-OCa-S> Sa?r^leJ-TYPE Sample Collection Method SILT zd ORGANC (PEAT)SfitTraaY 1
- SANDY SPUT- [I ROCK tim SAND CLAY AE\\ ~ J. 6iroJkcxi^
BARREL AUGER CORE LOGGED BY
- T!I CLAYEY vV Pso>r £- ^>5
£ia GRAVEL SAND THIN-I CONTINUOUS NO \\JSI SILTY EXiSTING GRADE ELEVATION I FT AMSLJ WAUED SAMPLER RECOVERY LSCJ CLAY Hat*
I TUBE SToNEf DEPTH Depth Top and Bottom of Sample ffTTI CLAYEY LOCATION OR GRID COORDINATES REC. Actual Length of Recovered Somple in Feet my silt u t § KERR-McGEE CORPORATIOl HYDROLOGY DEPARTMENT MONITORING WELL INSTALLATION DIAGRAM
Protsctfv* Pipe -------------- ___ ____Casing Cap Vent ? Yes 0 No Q Yee Q No Or _________Lock f Yes Q No Q Steel PVC..Weep Hole ? Yes Q No Surveying Pin T ~ __Ft. Concrete Pad Ft. x 4 Ft. x4 4 Inches Ye* No Q DRILLING INFORMATION:
DEPTHFROM
- 1. Borehole Diametar= 8 ¥/ Inches.
Concrete Ft.BELOWTOP OF 2. Were Drilling Additives Used T YeeQNo ^
GRADE CASING Revert 0 Bentonite 0 Water Q
- -;'r Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Casing Used 7 Ye>>0 Noffif
Cement/Bentonite Grout Mix Depth=__________ to___________Fast.
Ym No0 4. Borehole Diameter for Outer Caalng______ Inches.
5.5 Gallon* Water to Ft. WELL CONSTRUCTION INFORMATION:
94Lb. Bag Coment & _
3 5 Lb. Bentonite V^: I.Type of Casing: PVC gj Galvanized 0 Teflon Powder
- Stainless 0 Other____________________________
Other:___________________ 2. Type of Casing Joints: Screw Couple 0 Glue-
Couple Q Other _____________________________
- 3. Type of Well Screen: PVC (3 Galvanized 0 Stainless 0 Teflon 0 Other__________________
Bentonite Seal Ft. 4. Diameter of Casing and Well Screen:
Pellets Qijj Slurry 0 Casing Inches. Screen Inches.
- 5. Slot Size of Screens
- Q, O l O Filter Pack 6. Type of Screen Perforation: Factory Slotted 0 Above Screen a-Ft. Hacksaw 0 Drilled 0 Other____________________
43 7. Installed Protector Pips w/Lock: Yes (3 No 0
WELL DEVELOPMENT INFORMATION:
I. How was Wall Developed f Balling 0 Pumping 0 Air Surging CAir or Nitrogen) K) Other FILTER PACK MATERIAL A^vxAop SAr&- Sujr^j> HioeK.
Silica Sand ^ 2. Thao Spent on Well Development 7
/------------------Minutes/Hours Washed Sand 0 Ft. 3. Approximate Water Volume Removsd 7______Gallons
Pea Gravel 0 4. Water Clarity Before Development I Clear 0 Turbid 0 Opaque 0 Other*___ 5. Water Clarity After Development 7 Clear 0
Turbid 0 Opaque 0 Sand Size 334 6. Did Water have Oder 7 Yes 0 No 0
If Yes. Describe______________________
Dense Phase Sampling Cup Q 3 Ft.' Did Water have any Color 7 Yes 0 No 0 Bottom Plug ; o j 34.0 If Yes t Describe Yea $ No Q WATER LEVEL INFORMATION:
Overdrilted Material l Water Level Summary (From Top of Casing)
Backfill Ft-J During Drilling_________________ Ft. Date________
Grout Q Sand 0 Before Development____________ Ft. Date________
Caved Material 0 X_______J Other: After Development____________Ft. Date________
Drlller/Flrm Ahl l0iDate Installed <bfcHo'z-Drill Rig Type Drill Crew _v^o]r\\lr\\r\\traWw\\ obv V 5f Kerr McGee 0* Poor Well No. Hydrologiet
£ SOIL BORING LOG KM 5655-A FIGURE GWRM-3-1 URANIUM CONCENTRATION TREND IN MONITOR WELLS TMW-08 AND 02W39
FIGURE GWRM-3-2 BA1 POTENTIOMETRIC ELEVATIONS
IT 4.0 GWRM INJECTION FACILITATING VERTICAL MIGRATION 4.1 NRC RAI:
4.1.1 Description of the Issue The Decommissioning Plan, Version 3, does not include water level elevation or historical groundwater analytical data for vertical extent well TMW-17, screened within Sandstone C in the Transition Zone area (located close to Transition Zone 1315R on the s ubmitted site maps; see attached Geologic Cross Section in Figure 2-5). This monitoring point is well positioned in the BA-1A remediation area to provide confirmation th at the injection activities in the Sandstone B injection trenches are not facilitating vertical migration of uranium contamination into the deeper water-bearing unit.
4.1.2 Basis Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities 4.1.3 RAI:
Please provide the requested water level elevation and groundwater laboratory analytical data for the TMW-17 monitoring well. Please add the TMW-17 well to the in-process groundwater monitoring locations in the Decommissioning Plan or explain why doing so is not necessary. Less frequent monitoring of the vertical extent well may be appropriate if no significant impacts to the water-bearing zone are observed following an appr opriate monitoring period of the injection operations.
4.2 EPM Response:
Uranium concentration and groundwater elevati on data for Monitor Well TMW-17 is presented in Table GWRM-4-1, Data for Monitor Wells TWM-17 and 1315R. The proximity of Monitor Well 1315R (screened in a shallower interval than T MW-17) was noted when evaluating the data for TMW-17. Uranium concentration and groundwater el evation data for 1315R is also presented in Table GWRM-4-1 to inform this response.
Monitor Well 1315 was installed in February 1985. The boring log shows Sandstone B extending downward to approximately 923 feet above m ean sea level (AMSL), with sandy siltstone, mudstone, and claystone (later collectively referred to as Mudstone B) present from approximately 923 to 917 AMSL. The boring log al so shows a top elevation for Sandstone C of approximately 917 feet AMSL. Monitor Well 1315 was screened from approximately 930 to 915 feet AMSL; therefore, it was screened in the bottom of Sandstone B, through the aquitard, and extending into the top of Sandstone C.
In July 2002, Monitor Well 1315 was abandoned and replaced with 1315R, which is screened from approximately 937 to 922 feet AMSL; the screened in terval included only Sandstone B and the top of the underlying Mudstone B. Boring logs for and mo nitor well installation diagrams for Monitor Wells TMW-17, 1315 and 1315R are presented in A ttachment GWRM-4-1, Soil Boring Logs.
Monitor Well TMW-17 was installed in April 2000. The 2000 boring log for TMW-17 begins at a depth of 35 feet bgs (912 feet AMSL); the boring log for 1315 was used as a proxy to prescribe placement of the screen in TMW-17. The screen exte nds from approximately 910 to 900 feet AMSL; therefore, the screened interval is entirely within Sandstone C. Because Monitor Wells TMW-17 and 1315R are in close proximity to each other, compar ing the data for these wells is informative. The findings of groundwater elevation and uranium conc entration data for these two wells are presented below in Sections 4.2.1 and 4.2.2.
4.2.1 Groundwater Elevation Data Groundwater elevation data for TMW-17 and 1315R are presented in Table GWRM-4-1 for four groundwater sampling events in which groundwater elevation was measured in both wells within a synoptic timeframe of approximately two weeks. With one exception, which may have been an anomalous result in 2013, the data demonstrates that there has consistently been a significant downward gradient (between Sandstone B to Sa ndstone C) in the vicinity of these wells.
4.2.2 Uranium Concentration Data The earliest available uranium concentration result for Monitor Well 1315 (a December 1, 1988, sample) was 5,642 picocuries per liter (pCi/L), indicating high uranium con centrations have been present in Sandstone B at the 1315R location for ov er 35 years. If an effective aquitard did not exist between Sandstone B and Sandstone C, elevat ed concentrations of uranium would also be present in TMW-17 (screened within Sandst one C); this has never been the case.
Uranium concentration data available for TMW-17 are also presented in Table GWRM-4-1. The uranium concentration reported for TMW-17 has co nsistently been than 10 pCi/L and 10 µg/L.
Uranium concentrations have consistently been mo re than three orders of magnitude higher in 1315R, despite nearly always having a vertically downward hydraulic gradient in this area. Based on this data, it is presumed that Mudstone B, lo cated between Sandstone B and Sandstone C, is an effective aquitard and represents a barrier to the downward migration of contamination from the higher to the lower water-bearing unit.
Appendix I-4, Drawing C103 in the D-Plan shows that the elevation of treated water in Injection Trench GWI-BA1-03, located upgradient of TMW-17, will be maintained at approximately 942 feet AMSL. Treated water containing less than 30 µg/L (approximately 27 pCi/L) of uranium will be injected across the entire saturated thickn ess of GWI-BA1-03, which extends from 942 to 922 feet AMSL. The injection of clean water across the entire saturated thickness of Sandstone B will result in essentially horizontal flow through th e aquifer, flushing groundwater with elevated uranium concentrations to the nor th for capture by the Burial Area #1 (BA1) extraction trenches.
Treated water injection is not expected to result in the vertical migration of uranium contamination from Sandstone B, through several feet of low permeability Mudstone B, into the deeper water-bearing unit (Sandstone C).
4.3 Conclusion EPM believes there is little concern that contaminati on will be driven down to Sandstone C due to the injection of treated water upgradient of the BA1 uranium groundwater plume. Nevertheless, TMW-17 will be added to the list of in-process monitoring locations. Depth to water will be measured on a quarterly basis and a groundwater sample will be collected from TMW-17 for analysis for uranium on an annual basis.
TABLE GWRM-4-1 DATA FOR MONITOR WELLS TMW-17 AND 1315R
ATTACHMENT GWRM-4-1 SOIL BORING LOGS
5.0 GWRM INCLUSION OF TMW-08 AND TMW-13 IN POST REMEDIATION MONITORING 5.1 NRC RAI:
5.1.1 Description of the Issue Section 8.8, Post-Remediation Groundwater Monitoring, of the Decommissioning Plan, Version 3, does not include Sandstone B monitoring we ll TMW-8 or BA-1B alluvial monitoring well TMW-13 (see attached Figure 8-10 for well locations). The response of groundwater in the vicinity of both source area monitoring wells to the remediation activities is critical to an evaluation of the efficiency of the system. For this reason, TMW-8 and TMW-13 appear necessary for the in-process groundwater monitoring program. Likewise, confirmation of groundwater uranium levels remaining below N RC-license requirements in the post-remediation period is of equal importance.
5.1.2 Basis Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities 5.1.3 RAI:
Please include the TMW-8 and TMW-13 wells in the post-remediation monitoring program for the BA-1 remediation area or explain why the inclusion of these wells is unnecessary.
5.2 EPM Response:
TWM-08 and TMW-13 are included in the list of in-process monitoring locations and have been added to the list of post-remediation monitoring locations. Uranium concentration data for TWM-08 and TMW-13 from 2011 through 2023 are presented in Table GWRM-5-1, Uranium Concentration Data for Monitor Wells TMW-08 and TMW-13".
5.2.1 TMW-08 As shown on Figure GWRM-3-2, TMW-08 is located approximately three-quarters of the way between Injection Trench GWI-BA1-01 and the s outhern end of Extraction Trench GETR-BA1-
- 01. This is near the southern end of the area within which uranium concentrations exceed the NRC Criterion for uranium in groundwater. Groundwater exceeding the NRC Criterion migrates downgradient (toward the north-northwest) while background-quality groundwater flows into Burial Area #1 (BA1) from the south.
Background-quality groundwater is approaching the southern end of Extraction Trench GETR-BA1-01. This is evidenced by the concentration of uranium in groundwater samples collected from TMW-08; as discussed in the response to RA I GWRM-3, the concentration has declined significantly since 2011, to concentrations that are near or below the NRC Criterion.
Monitor Well TMW-08 is an in-process groundw ater monitoring location, and the uranium concentration for the last sample collected from TMW-08 on July 14, 2023, is already below the NRC Criterion. Groundwater samples will continue to be collected from TMW-08 and analyzed for uranium annually as part of the in-pro cess groundwater monitoring program. Groundwater samples from TMW-08 will likely yield uranium con centrations that are below the NRC Criterion for numerous years before the last in-process monitor well in the BA1 remediation area yields groundwater that complies with the NRC Criterion. Consequently, TMW-08 was not included in the list of post-remediation groundwater monito ring locations. However, TMW-08 will be added to the list of post-remediation monitoring locations.
The post-remediation monitoring locati ons are presented in the following:
Table 8 Revision 1, Post-Remediation Monitoring Locations Figure 8 Revision 1, Western Area Post-Remediation Monitoring Locations Figure 8-10a - Revision 0, BA1 Post-Remediation Monitoring Locations Figure 8-10b - Revision 0, BA1 Post-Remediation Monitoring Locations - Trench Area 5.2.2 TMW-13 TMW-13 is located in close proximity to Extr action Well GE-BA1-02. TMW-13 is an in-process groundwater monitoring location in the BA1-B reme diation area. Projections of the duration of remediation indicate that groundwater in remediation area BA1-B will achieve compliance with the NRC Criterion long before BA1-A. Con sequently, groundwater samples collected from TMW-13 are expected to yield less than the NRC Criterion for numerous in-process sampling events before post-remediation monitoring begins. However, TMW-13 will be added to the list of post-remediation monitoring locations.
5.3 Conclusion Monitor Wells TMW-08 and TMW-13 have been a dded to the list of post-remediation monitoring locations in the D-Plan. When the amended license approving the D-Plan is issued, the following will replace corresponding D-Plan tables and figures:
Table 8 Revision 1, Post-Remediation Monitoring Locations Figure 8 Revision 1, Western Area Post-Remediation Monitoring Locations Figure 8-10a - Revision 0, BA1 Post-Remediation Monitoring Locations Figure 8-10b - Revision 0, BA1 Post-Remediation Monitoring Locations - Trench Area In addition, the text of Section 8.8, Post-Reme diation Groundwater Monitoring, will be revised to state that if samples collected from either monitor well yields groundwater containing uranium concentrations less than the NRC Criterion for eight consecutive in-process groundwater monitoring events, it will be removed from the post-remediation groundwater monitoring list.
TABLE GWRM-5-1 URANIUM CONCENTRATION DATA FOR MONITOR WELLS TMW-08 AND TMW-13
TABLE 8 REVISION 1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
Table 8 Revision 1 Prepared by: S. Wood Post-Remediation Groundwater Monitoring Locations Date: 11-30-23 Reviewed by: J.Feild Date:11-30-23
Area Monitoring Uranium Tc99 Location TMW08 X TMW-18 X 1416 X BA1A Sandstone B 1417 X 1419 X 1420 X 1422 X 02W28 X 1315R X 1412 X BA1A 1413 X Transition Zone 1414 X 1415 X 1423 X 1424 X 1426 X TMW-13 X 02W08 X BA1-B 02W19 X 02W43 X 1411 X MWWA09 X 1206NORTH 1429 X 1430 X 1431 X T62 X T104 X WAA U>DCGL T105 X T68 X 1427 X 1428 X WUBA3 1351 X 1356 X 1336A X Uranium Pond #2 1402 X 1346 X
Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 1 of 1 FIGURE 8-9 WESTERN AREA POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
FIGURE 8-10A BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
FIGURE 8-10B BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS TRENCH AREA
6.0 GWRM REMEDIAL ACTION REPORTING 6.1 NRC RAI:
6.1.1 Description of the Issue The Decommissioning Plan Version 3 does not specify any reporting of remedial system construction, start up, operations & maintenan ce, or sampling/monitoring results to the NRC during site remediation. Periodic reporting to NRC of remedial progress, including reports summarizing remedial system operational parameters (system run time, individual well and trench flow rates, influent and effluent concentr ations, total treatment volumes, resin status etc.)
with tables and figures, including static a nd dynamic groundwater flow maps and uranium groundwater plume maps for each remediation area, are generally included as part of the decommissioning plan and requested at 6 months and one year following startup with annual reports requested thereafter. The first report gene rally includes a summary of the system startup activities and any pertinent informati on related to system functionality.
6.1.2 Basis Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 70.38 (g)4(ii), the plan must include a description of planned decommissioning activities.
6.1.3 RAI Provide the plan for reporting of remedial progr ess, including the details summarized above, to NRC.
6.2 EPM Response:
6.2.1 Construction Reporting Reports of construction progress will be submitted quarterly during construction. Quarterly construction progress reports will generally incl ude progress for the following major activities:
Mobilization and installation of stormwater controls; Installation of groundwater extraction, treated water injection, and discharge components; Construction of the Western Area Treatment Facility and Burial Area 1 Remediation Facility; and Installation of groundwater treatment and resin processing systems and all ancillary equipment (e.g., influent and effluent tanks, injection skids, utilities and piping, etc.).
In addition, these reports will include:
A summary of permits obtained to date and an update on the status of the OPDES discharge permit (to be obtained);
A summary of work completed to date as comp ared with the baseline construction schedule; Issues encountered and corresponding changes, if any; A summary of the results of radiological surveys performed; and Anticipated impacts to construction cost.
6.2.2 Startup of Remediation and Groundwater Treatment A System Startup Report will be prepared and s ubmitted to the NRC within six months following startup and commissioning activities. The System Startup Report will include:
Static (prior to system startup) groundwater elevation data and potentiometric surface maps; Baseline (prior to system startup) in-process monitor well groundwater sampling results; Daily, weekly, and monthly groundwater elev ation data, and potentiometric surface maps based on groundwater elevation data collected during the third month of system operations; Treatment process water sampling results for th e first three months of system operations; Groundwater sampling results for the groundwat er monitoring event conducted during the third month of system operations; A description of the operation of groundwater extraction systems, treatment systems, discharge and injection systems, facilities, etc.;
A summary of data collected from system ope rations components such as overall system run time, individual well and trench extraction/injec tion flow rates, influent and effluent water concentrations, total treatment volumes, resin usag e and status, etc. for the first three months of system operations; and, A summary of the results of radiological surveys.
6.2.3 Groundwater Remediation Remediation Progress Reports will be submitted at six months and one year following system startup and annually thereafter. Remediation Progress Reports will generally include the following:
Summary of activities performed during the reporting period; Groundwater sampling activities, results, and anal ysis (including depictions of groundwater potentiometric surface maps, groundwater uranium concentration maps, groundwater concentration trend charts, etc.);
Remediation system operational summary (inc luding system operational times; individual and cumulative groundwater recovery, treatment, and injection rates/volumes; water treatment media usage, inventory, and treat ment efficiency; influent/effluent water concentration data and trends; etc.);
Treatment material control (resin usage, invent ory, and deliveries, pre-treatment chemical usage, inventory, and deliveries, etc.);
Waste material management and control (spent resin inventory, quantities/frequencies of waste shipments, waste uranium and Tc-99 concentration data, etc.);
Contingency measures implemented (as applicable);
Evaluation of progress towards decommissioning; and, Summary of planned activities for the subsequent reporting period.
7.0 HP CLARIFICATION OF FINAL STATUS SURVEY 7.1 NRC RAI:
7.1.1 Description of the Issue Section 8.9 of the D-PLAN states that the WATF will remain onsite following the completion of groundwater remediation activities. The WATF Buildi ng will be subject to a final status survey after all equipment and material used for uranium treatment and spent resin processing, and all packaged LLRW have been removed. But Secti on 15.4 of the D-PLAN states that Within the licensed area, only the WATF building and the concrete slabs outside of the WATF building and in the BARF will remain on the Site. The WATF building is an asset to be transferred to a subsequent owner upon disposition of the property by the Trust. A final status survey plan providing a detailed description of the final status survey will be submitted to the NRC NRC staff needs to understand the rationale used by the licensee in the determination of what remains onsite after the completion of groundwat er remediation activities and what will be subject to final status surveys to support license termination.
7.1.2 Basis This information is needed to determine compliance with the following requirements:
10 CFR 70.38(g)(1) procedures and activities n ecessary to carry out decommissioning not previously approved by the Commission.
10 CFR 70.38(g)(3)(vi) description of th e planned final radiation survey.
7.1.3 RAI Please provide clarification as to what will remain onsite following the completion of groundwater remediation and license termination, and for those structures and slabs left behind, what will be subject to a final status survey.
7.2 EPM Response:
The description of the issue in the NRCs October 2, 2023, request for additional information stated, NRC staff needs to understand the rationale used by the licensee in the determination of what remains onsite after the completion of groundwater re mediation activities and what will be subject to final status surveys to support license termination. This response will therefore:
- 1. Provide the rationale behind the decision to rem ove or leave materials or structures on site,
- 2. Identify materials or structures that will be removed from the site prior to conducting a final status survey,
- 3. Identify remaining materials or structures that w ill not be subject to final status survey, and
- 4. Identify remaining materials or structures that will be subject to final status survey.
7.3 Rationale for Leaving Material or Structures on Site The Environmental Response Trust Agreement (Cimarron), herein referred to as the Trust Agreement defines the role of the Cimarron Trus tee in Section 2.2, Objective and Purpose. In addition to acting as the successor to the Debtors (former licensee), remediating the site and carrying out administrative functions, the Cimarron Trust mu st ultimately sell, transfer or otherwise dispose or facilitate the reuse of all or part of the Cimarron Trust Assets The Trustee intends to maximize the value of the decommissioned site, which requires:
- 1. The retention of material and structures that are likely to enhance both the value and desirability of the property.
- 2. The removal of material and structures that would detract from either the value or the desirability of the property.
7.4 Material/Structures That Will Be Removed Prior to Fina l Status Survey Section 8.9 of the D-Plan provides a generic list of ma terials that will be removed prior to final status survey. From the Western Area Treatment Facility (WATF), that includes all tanks, the filtration systems, ion exchange systems, the spent resin processing system and the injection skid. From the Burial Area #1 Remediation Facility (BARF) that includes all tanks, the injection skid, the transfer pump, and the emergency generator.
These materials will be subject to radiological surveys to determine if they exceed unrestricted release criteria. If so, they will be disposed of as low-level radioactive waste (LLRW). If not, they will be recycled, salvaged, or disposed of as solid waste. One exception is subsurface piping; if releasable for unrestricted use, subsurface piping will be left in place; if sufficient funding is available, it may be removed to be recycled, salvaged, or disposed of as solid waste.
A more detailed list of those materials follows.
7.4.1 External to the WATF Building
Influent tanks and associated piping/controls Acid tank and associated piping/controls BA1 effluent tank and associated piping/controls Backwash water tank and associated piping/controls WA effluent tank and associated piping/controls Injection skid and associated piping/controls Treated water piping and vaults Utility and instrumentation wiring Extraction and monitor wells Subsurface piping 7.4.2 Inside the WATF Building
Filtration systems and associated piping/controls Ion exchange systems and associated piping/controls Spent resin processing facility and associated piping/controls Jersey barriers in the LLRW storage area All electrical controls associated with groundwater remediation (not facility utilities)
All equipment and furnishings in th e RP instrument room (RM 102)
All equipment and furnishings in the RP staff office (RM 104)
The equipment and furnishings in the RP instrume nt room and the RP staff office will remain until the license is terminated. It will then be removed for recycling, salvage, or disposal.
7.4.3 The BARF
Emergency generator and associated piping/controls Injection skid and associated piping/controls Influent and effluent tanks and associated piping/controls Transfer pump and associated piping/controls Fencing and gates Bollards 7.5 Remaining Materials/Structures Not Subject to Final Status Survey The NRC has already documented that, excludi ng groundwater, all of the site except the approximately 20 acres comprising Subarea F is releasable for unrestricted use. EPM has provided significant data demonstrating that, excluding groundwater, both surface and subsurface soil in Subarea F is also releasable for unrestricted use. Investigations performed in 1991 involved the collection of over 900 surface and subsurface soil samples; 14 exceeded the NRC Criterion, and the areas yielding those samples were excavated for disposal. Investigations performed in 1996 and 1999 involved the collection of nearly 1,600 more surfa ce and subsurface soil samples; none of the samples exceeded the NRC Criterion. The compiled results of these investigations were reported in the November 20, 2007, report, Burial Area #1 Subsurface Soil Assessment (ML20043D187). To date, EPM has not received the results of NRC staff review of this report.
Section 12.5 of the Radiation Protection Plan - Rev 5, which is Appendix M to the D-Plan, describes the radiological surveys that will be conducted any time subsurface material is brought to the surface.
During construction and operation of groundwater remediation opera tions, radiological surveys will be conducted to demonstrate that subsurface material brought to the surface does not alter the radiological status of the land surface, so that it continues to comply with the decommissioning criteria. Consequently, final status surveys will not be needed for the land surface or subsurface soil outside of those areas in which groundwater exce eding the decommissioning criteria is brought to the surface for transport or treatment, or where LLRW is loaded onto trucks for shipment to a licensed disposal facility.
Room numbers can be found on Drawing A-100 in Appendix J-2 of the D-Plan. These areas will be subject to routine surveys throughout operations b ased on their proximity to affected" areas. If the surface of any equipment or material exceeds decommissioning criteria for surfaces during operation, it will be disposed of as LLRW and the area will be evaluated for inclusion as an affected area. If unaffected, subsequent routine surveys will demonstrate that these rooms and the material/equipment in them comply with criteria fo r unrestricted release. Furnishings, equipment, and materials in these rooms may be left for future users. Conducting and documenting routine surveys throughout operations will circumvent th e need for final status surveys.
Areas, equipment, or material that will be subject to routine surveys throughout operations follow.
7.5.1 External to the WATF Building Diesel generator and concrete pad Two air handling units Transformer and concrete pad 7.5.2 Inside the WATF Building Hallways (not numbered)
Electrical room (RM 101)
Janitor closet (RM 113)
CERT offices (RM 103 and RM 105)
Storage/Reproduction room (RM 107)
Break room (RM 111)
Control room (RM 106)
Conference room (not numbered)
Storage room (RM 115)
Data room (RM 114) 7.5.3 The BARF With the possible exception of a utility pole and tran sformer (if installed inside the fence), there will be no materials or equipment within the fenced area of the BARF that is not subject to final status survey.
7.6 Remaining Materials/Structures Subject to Final Status Survey 7.6.1 External to the WATF Building
Concrete foundations for all tanks Concrete pad for injection skids Surfaces of trash enclosure 7.6.2 Inside the WATF Building Instrument room (RM 102)
ENERCON office (RM 104)
Floor and bottom 2 meters of walls and doors of the processing area (the large room outside of the offices.
Floor and bottom 2 meters of walls and doors of the LLRW storage area Bottom 2 meters of exterior walls and doors 7.6.3 The BARF Influent and effluent tank foundations Injection skid foundation Diesel generator concrete foundation Transfer pump foundation In addition to materials and foundations, the entir e fenced area within which both the WATF and the BARF are located will be subject to a final status survey. Portions of the fenced areas, as well as the interior of the WATF will be designated as aff ected or unaffected areas based on knowledge of releases, routine survey results, etc., in accordance with NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination. Which areas would be designated affected or unaffected areas cannot be made prior to completing groundwater remediation.
8.0 HP CLARIFICATION OF SOIL SURVEYS 8.1 NRC RAI:
8.1.1 Description of the Issue Section 12.5.2, Soil Disturbances, of the RPP (Appendix M to the D-PLAN) states that walkover gamma surveys will be performed to verify the net concentrations are at 30pCi/gm U or less for all disturbed soils and specifies that this app lies to shallow excavations, foreign or suspect materials, soils removed from deep excavations, area graded for construction, well cores and 1206 Sediment. However, Section 13.1.3, Volumetrically Contaminated Materials, is the only part of the D-PLAN that mirrors this language and list, implying that the surveys will only be done as part of the process for identifying waste for shipment offsite. Surveys associated with disturbed soils are not mentioned at all in Section 15 of the D-PLAN and many sections of the D-PLAN talk about how the surface soils and subsurf ace soils either were released or are releasable.
Additionally, commitments for surveys of subsurface soils were made in previous versions of the D-PLAN (ML20094L181) and RPP (ML19154A597) that do not appear to be in the current D-PLAN.
NRC Staff needs to understand the circumstanc es under which soil and subsurface soil surveys will or will not be performed.
8.1.2 Basis NRC staff needs this information to be able to adequately assess the proposed program against the criteria of NUREG-1757 Volume 1 Revision 2 Se ction 16.4.3, Soils - Radiological Status of the Site, 16.4.4 Subsurface Soils - Radiological St atus of the Site and 17.1.3 Soils - Planned Decommissioning Activities.
8.1.3 RAI Please clarify survey methods to be used in radiological surveys of surface and subsurface soils that are disturbed during construction and decommissioning of the groundwater treatment equipment and facilities.
8.2 EPM Response:
Section 13.1.3 of the D-Plan addresses how surveys of volumetrically contaminated material will be handled at the Cimarron Site. These requirements are also included in section 12.5.2 of the RPP. The two documents that discussed plans fo r soil surveys referenced in Description of Issue for this RAI above, Facility Decommissioning Plan - Rev 3 (ML20094L181) and Radiation Protection Plan - Rev 5 (RPP) (ML19154A597) dated June 7, 2019, and May 24, 2019, respectively.
Revision 5 of the RPP was never approved due to comments on the 2019 submittal. The version of RPP - Rev 5, submitted with the D-Plan on October 7, 2022, reflects the results of discussions with the NRC staff that supersede the two documents referenced by NRC staff. It contains greater detail on how surface and subsurface soils will be surveyed to ensure continued compliance with applicable license conditions.
The Basis for this RAI discusses the need to address criteria of NUREG-1757 Volume 1 Revision 2 Section 16.4.3, Soils - Radiological Status of the Site, 16.4.4, Subsurface Soils - Radiological Status of the Site and 17.1.3, Soils - Pla nned Decommissioning Activities. Details on addressing these criteria are provided in Section 12.5 of the RPP:
Section 12.5.1.2 discusses Background Levels of Uranium in Soil. The RPP states, As discussed in section 3.6.1 of the D-Plan, the NRC ag reed that if alpha spectroscopy is used to analyze samples, a value of 2.8 pCi/g tota l uranium is acceptable for use as the background activity concentration for soil. This value will a pply site-wide. When soil is analyzed for mass concentration, analysis will be for U-235 and U-238 (the mass of U-234 is negligible). A U-235 enrichment of [U-235/(U-235 + U-238)] will be u sed to convert the mass concentration for U-234, U-235, and U-238 to activity concentration for comparison with decommissioning criteria.
Section 12.5.2 provides details related to Soil Disturbances. Surveys of subsurface soil brought to the surface during installation of injection and extraction trenches, monitoring wells, trenches for piping and utilities, etc., will be performed. This section of the RPP states that Section 3.3 of the D-Plan provides information that both surf ace and subsurface material at the Cimarron Site has been demonstrated to comply with NRC Cr iteria Site-wide. There is a detailed discussion regarding how the NRC Criteria has already been satisfied; however, in agreement with the NRC staff, CERT will perform surveys of disturbed soils to ensure unexpected legacy contamination is not encountered.
The subsections of Section 12.5.2 parallel the re quirements detailed in Section 13.1.3 of the D-Plan and discuss requirements for surveying and sam pling subsurface material at the Site. Results will demonstrate that the subsurface soil contains contamination less than or equal to a net 30 pCi/g uranium. Prior to disturbing the soil and following final grading of soil, walk-over gamma surveys will determine relative levels of radioactivity (counts per minute) using a gamma sensitive detection instrument, such as a 2-inch by 2-inch NaI detector. Instrument selection will be approved by the Radiation Safety Officer and identified in the applicable desk instruction or activity plan. As discussed in the subsections be low, (with one minor clarification as noted below for Foreign or Suspect Materials), gamma walk -over surveys where elevated readings are identified (i.e. two times background), will require collection and analysis of a soil sample to demonstrate that the 30 pCi/g limit has not b een exceeded. In addition, soil samples will be methodically collected as summarized in the following RPP Sections:
Section 12.5.2.1, Foreign or Suspect Material s - This subsection will be revised to specify that elevated gamma counts per minute is two times background.
Section 12.5.2.2, Shallow Excavation - A soil sample will be taken every 100 feet along the length of the spoils (from the excavation) at the location with the highest count rate.
Locations where the count rate exceeds two times background will be identified and evaluated to determine if additional sampling should be collected for laboratory analysis.
Section 12.5.2.3, Deep Excavation - A soil sample will be taken every 50 feet along the length of the spoils (from the excavation) at the location with the highest count rate.
Locations where the count rate exceeds two times background will be identified and evaluated to determine if additional sampling should be collected for laboratory analysis.
Section 12.5.2.4, Borings and Wells - A minimum of one soil sample shall be collected from each five-foot depth interval, at the location where the highest gamma count rate is detected, for laboratory analysis Section 12.5.2.5, Western Area Treatment Facility Disturbed Area - This section provides the methodology for performing soil sampling cons istent with the guidance provided in NUREG-5849.
Section 12.5.2.6, Burial Area 1 Remediati on Facility Disturbed Area - This section provides the methodology for performing soil samp ling consistent with the guidance provided in NUREG-5849.
Section 12.5.2.7, 1206 Sediment/Soils Mixture - This section provides a detailed discussion of how soil sampling will be c onducted both for locations where soil contamination is less than or equal to 30 pC i/g and any locations where soil contamination exceeds 30 pCi/g.
Section 15.4.3 of the D-Plan, Areas Not Subject to Final Status Survey (Land Surface), states that radiological surveys will be performed whenever subsurface material is brought to the surface.
Section 15.4.3 will be clarified to reference RPP Section 13.1.3 where details regarding these radiological surveys are discussed.
9.0 HP USE OF CLASS Y FOR INTERNAL DOSE ASSESSMENT 9.1 NRC RAI:
9.1.1 Description of the Issue:
Discussion in Appendix A to the Radiation Protection Plan, Revision 5 states in Section 5.1 ALI for inhalation that all soluble uranium salts, like those present in the groundwater at the Cimarron site, are Type F which is equivalent to Class D used in NRC regulations but the comparison of ALI for inhalation is based on Class Y material. There is no justification provided for this, even though Section 5.2. ALI for Oral Ingestion indicates that Class D Uranium for dose to bone surfaces is the limiting factor for internal dose. There also does not appear to be consideration for the fact that, due to the low en richment, (modelled at 2.9% and 5% in Appendix A) for Class D uranium enrichments 10% or greater, the radiological dose is the limiting factor and below 10% enrichment, the chemical toxicity is considered the limiting factor for personnel exposure since an acute inhalation of 40 mg of Class D uranium can result in permanent renal damage.
Section 6.6 of the RPP, Internal Exposure Monitoring stated that internal monitoring is not warranted but later states if internal monitoring is needed, they will establish actions levels for intake based on chemical toxicity if soluble U is present, indicating that the licensee is aware of the chemical toxicity of the lower enrichment. This statement seems to conflict with the statement in Section 5.1 NRC needs to better understand the basis behind using Class Y for modeling inhalation dose at the low enrichment values. NRC needs to understand why the licensee would not establish uranium intake action levels based on chemical toxicity levels and performed internal dose estimates to support the decision to not conduct internal monitoring using Class Y while acknowledging Class D is present in the groundwater.
9.1.2 Basis NRC needs this clarification/justification to determine if the licensee has adequately addressed NUREG-1757 Volume 1 Revision 2 Criteria for Section 17.3.1.3 Internal Exposure Evaluation.
9.1.3 RAI Please provide a justification for the use of Class Y uranium for determining the dose from inhalation as modelled in Appendix A to the Radi ation Protection Plan, Rev 5 that was provided as Appendix M to the Decommissioning Plan.
9.2 EPM Response:
In preparing our response to this RAI, we noticed an error in the description of the potential intake calculation results provided in the first bullet under Section 6.1 of the RPP. The discussion implies that the calculation in Appendix A of the RPP provides the potential intake for oral ingestion of uranium (Class Y) rather than Class D. There is no oral intake ALI for Class Y uranium in 10 CFR 20 Appendix B; only a Class D ALI is provided. Sect ion 6.1 of the RPP will include corrections and clarifications in the final version of Revision 5 of the RPP when it is resubmitted with the D-Plan for NRC approval.
The clarifications will address that Class Y is the limiting ALI for assessment of potential intakes through inhalation of uranium. As previously discussed with the NRC staff, the use of Class Y uranium for the potential intake calculation is justified because it is more protective of workers. The lowest ALI for inhalation of uranium is Class Y. Intakes were postulated based on an assumed release of spent resin that would be dispersed in the air breathed by workers, without considering the particle size of resin beads (approximately 575 microns) which are not respirable.
Assuming an airborne release of spent resin is respirable and the conservative Class Y, the calculated intake that a worker could have is a small frac tion of the Class Y ALI (conservatively, 1.14% ALI).
The potential mass intake in a year for uranium would be 1.92 E-04 grams (0.192 milligrams), which is significantly below the values discussed in Footnote 3 to Appendix B of 10 CFR 20 and 10 CFR 20.1201(e).
Section 6.1 will also include clarification that the limiting pathway for oral intakes of uranium is through oral consumption of grou ndwater. Because of the negligible potential mass intake through inhalation, the limiting (bounding) pathway for potentia l intake of uranium is through consumption of groundwater. Drinking groundwater at the Cimarron S ite is explicitly prohibited as it is not potable.
However, the calculated volume of contaminated gr oundwater that would result in the 10 mg/week limit in 10 CFR 20.1201(e) are presented in Appendix A to the RPP.
Assuming a uranium concentration of 3,516 µg/L (fro m a single monitor well), ingestion of 2.84 liters of water within a week would result in an intake of 10 mg soluble uranium. The highest projected concentration of uranium in influent to the treatment facility is 1,018 µg/L; ingestion of 9.82 liters of water, in a week, would result in an intake of 10 mg soluble uranium. Engineering controls prevent access to both groundwater in monitor wells and in the treatment process; consequently, there is negligible potential for ingestion of even a small fraction of these quantities of contaminated groundwater.
10.0 HP USE OF NUREG-1556 VOLUME 7 FOR RPP AUDIT 10.1 NRC RAI:
10.1.1 Description of the Issue The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the Radiation Protection Plan included as Appendix M to the Decommissioning Plan Revision 3 submitted for approval on November 7, 2022. The purpose of the review was to ensure that the radiation protection program submitted to support decommissioning was compliant with the requirements for a special nuclear material licensee undergoing decommissioning and proposing the treatment of groundwater by collecting uranium-235 in resin beds. NUREG-1556 Volume 7 is specific to limited scope academic or research and development licensees and does not seem appropriate for development of a radiation safety program for a facility that is proposing remediation of groundwater using resin beds and planning for the collection of uran ium-235 (U-235). It should also be noted that Appendix H in NUREG-1556 Volume 7 is Considerations for Laboratory Animal and Veterinary Medicine Uses. It is much more likely that the reference was meant to be Appendix H to NUREG-1556 Volume 7 Revision 1 which is Sample Audit Program.
Volume 7 of NUREG-1556 suggests that a decomm issioning plan includes the establishment of a radiation safety program that meets the requirements of 10 CFR 19, Notices, Instructions and Reports to Workers; Inspections and Investig ations, 10 CFR 20, Standards for Radiation Protection, 10 CFR 70, Domestic Licensing of Special Nuclear Material, and 10 CFR 71, Packaging and Transportation of Radioactiv e Material as recommended in NUREG-1520, Revision 2, Standard Review Plan for Fuel Cycle License Applications.
Whereas NUREG-1556 Volume 17, Program-Specific Guidance About Special Nuclear Material of Less than Critical Mass Licenses - Final Report and NUREG-2212 (DRAFT) - Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but Not Subject to the Requirements in 10 CFR part 70, Subpart H, also suggests a radiation safety program that meets the requirements of Parts 19, 20, 70 and 71, NUREG-1556 Volume 17 also includes the requirements of 10 CFR Part 37 as well as financial assurance, environmental monitoring, waste management and effluent monitoring requirements, and NUREG-2212 (Draft) also adde d 10 CFR 73.67 (in-transit requirements for SNM) and 10 CFR 21.21 (Notification of failu re to comply or existence of a defect).
NRC staff needs to understand the rationale used by the licensee to limit the radiation safety program audit and to support the use of an aud it checklist that was not specific to a license for possession of special nuclear material when special nuclear material audit guidance is available.
10.1.2 Basis:
This information is needed to determine compliance with the following requirements of Title 10 of the Code of Federal Regulations (10 CFR) Pa rt 20.1101(a) which requires Each licensee shall develop, document, and implement a radiation pr otection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance and 10 CFR 20.1101(c) requires the licensee to periodically (at least annually) review the radiation protection program content and implementation.
10.1.3 RAI Provide justification for use of the Appendix H of NUREG-1556 Volume 7, Program-Specific Guidance About Academic, Research and Development, and Other Licenses of Limited Scope, Including Electron Capture Devices and X-Ray Fluorescence Analyzers as the guide for audit of the radiation protection program for this speci al nuclear material license to satisfy the requirements of 10 CFR 20.1101(c) as stated in Section 5.2 of Appendix M to the Decommissioning Plan, Revision 3.
10.2 EPM Response:
RPP - Rev 5 reflected commitments related to its radiation protection annual audit program that had been approved by the NRC many years ago. During the 2022 annual review of the RPP, the ALARA Committee determined that Volume 17, Appendix E to NUREG-1556 should be incorporated into the checklist used to guide the 2023 annual audit of the RPP.
In preparation for groundwater processing, th e audit checklist has already been revised for consistency with the checklist provided in Volume 17, Appendix E of NUREG-1556, which incorporates additional items related to criticality saf ety and licensed material security. This revised checklist will be used by the Quality Assurance Coordinator for audits of the RPP in 2023 and subsequent years.
Appendix M of the D-Plan containing Revision 5 of the RPP will be updated to identify NUREG-1556, Volume 17, Appendix E in Section 5.2, Audits, and Section 17.0, References.