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
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com 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 Commission (NRC) on October 2, 2023. It is our understanding that these RAIs constitute 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 approved 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 the 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
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 supporting documentation in Appendix K, Basis of Design (ML22308A076) indicate that extraction trenches 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 Groundwater Flow Model Report (Appendix L; ML22308A183). The groundwater flow and particle 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). Although 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 the 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 Test 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 allow staff to properly evaluate the proposed alternatives or adjustments to the remedial design.
1.2 EPM Response:
1.2.1 Groundwater Contamination is Essentially 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, elevated 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 soils 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 represent 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 groundwater 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 promote flow within the coarse-grained sands and silty sands of the TZ, thereby flushing and recovering 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 remediation 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 terminated 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 lower-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 implementation 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 groundwater model depicts flow paths resulting from injection and extraction; it also demonstrates 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 method was approximately 20 feet per day (ft/day).
This calculated value influenced the 2022 groundwater flow model update. The 20 ft/day average hydraulic conductivity derived from the 2018 pilot test is representative of the average across all lithological layers in the area influenced by the pumping test. The hydraulic conductivity values from the 2018 Pilot Test are not solely representative of the high hydraulic conductivity sands and were biased low by the fine-grained gully fill 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 deposits 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 was also considered in the BA1 groundwater treatment remedial design. The groundwater model is best used for evaluating pumping and injection scenarios and for estimating flow paths 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 trench, 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 GWI-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 ranging 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 rate 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 influence 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-between the BA1 extraction and injection trenches.
these monitor wells will be added to the in-process 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 influence 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 system, drawdown will be measured using the in-process groundwater monitoring wells. Real-time adjustments 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 extraction 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
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 907 1222 8
4 6.1 X
X Clay and sand layers between 8 and12 feet bgs 907 1222 15 5
3.0 X
X Clay and sand layers between 15 and 20 ft bgs 915 1225 0
1 2.7 X
X 915 1225 1
1 2.9 X
X 915 1225 2
1 2.8 X
X 915 1225 3
1 7.4 X
X 915 1225 4
1 9.6 X
X 915 1225 5
1 12.8 X
X 915 1225 6
1 12.8 X
X 915 1225 7
1 8.6 X
X 915 1225 8
1 8.0 X
X 915 1225 9
1 7.7 X
X 915 1225 10 1
5.8 X
X 915 1225 11 1
5.1 X
X 915 1225 12 1
3.2 X
X 915 1225 13 1
3.1 X
X X
915 1225 14 1
4.1 X
X 915 1225 15 1
3.1 X
X 915 1225 16 1
2.6 X
X 915 1225 17 1
2.4 X
X 917 1202 8
5 9.1 X
X Clay and sand layers between 8 and 13 ft bgs 917 1202 15 3
2.6 X
X No boring log info 923 1189 3
2 3.3 X
X 923 1189 9
1 3.4 X
X 923 1189 10 5
4.1 X
X 923 1189 15 1
1.6 X
X 936 1186 5
5 3.0 X
X Clay and sand layers between 5 and 10 ft bgs 936 1186 10 5
2.1 X
X 955 1182 0
1 2.2 X
X 955 1182 1
1 2.9 X
X 955 1182 2
1 3.3 X
X 955 1182 3
1 2.4 X
X 955 1182 4
1 1.8 X
X 955 1182 5
5 2.5 X
X 955 1182 20 1.5 1.2 X
X 954 1193 5
5 2.9 X
X Clay and sand layers between 5 and 10 feet 954 1193 10 5
2.0 X
X 954 1193 15 5
2.3 X
X 954 1193 20 2
0.8 X
X 02W05 02W06 02W07 02W01 02W02 02W03 02W04 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 1 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 956 1208 0
1 2.6 X
X 956 1208 1
1 2.8 X
X 956 1208 2
1 2.9 X
X 956 1208 3
1 1.8 X
X 956 1208 4
1 2.4 X
X 956 1208 10 1
3.6 X
X 956 1208 11 1
3.1 X
X 956 1208 12 1
2.5 X
X 956 1208 13 1
2.2 X
X 956 1208 14 1
2.7 X
X 956 1208 15 1
1.4 X
X 956 1208 16 1
2.7 X
X 956 1208 17 1
1.9 X
X 956 1208 18 1
1.5 X
X 956 1208 20 1
3.1 X
X 956 1208 21 1
3.7 X
X 956 1208 22 1
2.1 X
X 879 1269 8.5 5
1.8 X
X 879 1269 17.5 5
1.9 X
X 899 1264 7.5 5
2.2 X
X 899 1264 15.5 5
3.3 X
X 969 1222 8
1 2.9 X
X 969 1222 20 5
1.6 X
X 963 1226 8
5 2.3 X
X Sand and clay layers between 8 and 13 ft bgs 963 1226 20 5
1.5 X
X 947 1234 7
5 2.4 X
X One sand layer, but mostly clay 947 1234 19 5
1.6 X
X 1' clay, sand, 1' mudstone at bottom 969 1208 8
5 3.2 X
X Sand and clay layers between 8 and 13 ft bgs 969 1208 21 5
1.7 X
X 02W15 921 1174 9.5 2.5 1.8 X
X 936 1170 8
2 1.9 X
X Half sand, half clay 936 1170 15 2
2.1 X
X 1' sand, 1' mudstone 955 1167 8
5 2.2 X
X 955 1167 15 7.5 1.3 X
X 955 1167 22.5 0.5 0.6 X
X 981 1194 0
1 2.2 X
X 981 1194 1
1 2.6 X
X 981 1194 2
1 2.7 X
X 981 1194 3
1 1.8 X
X 981 1194 4
1 2.0 X
X 981 1194 5
1 2.0 X
X 981 1194 6
1 1.8 X
X 981 1194 10 5
3.0 X
X 981 1194 15 5
1.5 X
X 981 1194 25 0.5 0.8 X
X 981 1194 25.5 0.5 0.3 X
X 02W13 02W14 02W16 02W17 02W18 02W09 02W10 02W08 02W11 02W12 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 2 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 969 1188 7.5 7.5 2.1 X
X 969 1188 15 5
2.4 X
X 846 1292 0
1 2.2 X
X 846 1292 1
1 3.6 X
X 846 1292 2
1 3.0 X
X 846 1292 3
1 3.2 X
X 846 1292 4
1 2.5 X
X 846 1292 5
1 1.8 X
X 846 1292 6
1 2.9 X
X 846 1292 7
1 2.1 X
X 846 1292 8
1 3.0 X
X 846 1292 9
1 2.1 X
X 846 1292 10 1
1.9 X
X 846 1292 11 1
2.3 X
X 846 1292 12 1
2.6 X
X 846 1292 13 1
2.5 X
X 846 1292 14 1
2.8 X
X 846 1292 15 1
0.4 X
X 846 1292 16 1
2.0 X
X 846 1292 17 1
1.8 X
X 846 1292 18 1
1.8 X
X 846 1292 19 1
2.8 X
X 846 1292 20 1
0.4 X
X 846 1292 21 1
1.9 X
X 846 1292 22 1
1.9 X
X 970 1149 0
5 2.7 X
970 1149 11 1.5 1.3 X
970 1149 20 5
1.9 X
933 1154 0
5 1.2 X
933 1154 8
5 2.0 X
955 1152 9.5 5.5 1.0 X
955 1152 20 2.5 1.9 X
969 1167 9
7 1.8 X
969 1167 23 1
1.8 X
969 1167 24 1
2.2 X
969 1167 25 0.5 1.4 X
02W20 02W21 02W22 02W23 02W24 02W19 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 3 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 846 1228 0
1 3.1 X
X 846 1228 1
1 1.9 X
X 846 1228 2
1 3.0 X
X 846 1228 6
1 3.7 X
X 846 1228 7
1 3.5 X
X 846 1228 8
1 2.9 X
X 846 1228 9
1 4.7 X
X 846 1228 10 1
6.3 X
X 10.0 to 10.7 clay. 10.7 to 11.0 sand.
846 1228 11 1
16.4 X
X Low permeability layer located directly on top of mudstone at the base of higher permeability material 846 1228 12 1
3.7 X
X 846 1228 13 1
2.5 X
X 846 1228 14 1
3.1 X
X 846 1228 15 1
2.0 X
X 846 1228 16 1
2.8 X
X 846 1228 17 1
2.4 X
X 846 1228 18 1
0.8 X
X 846 1228 22 1
1.8 X
X 846 1228 23 1
1.3 X
X 846 1228 24 1
1.5 X
X 846 1228 25 1
0.9 X
X 846 1228 26 1
1.5 X
X 846 1228 27 1
1.4 X
X 846 1228 30 1
2.2 X
X 846 1228 31 1
2.0 X
X 863 1280 0
5 3.2 X
X 863 1280 5
5 2.1 X
X 863 1280 10 5
2.2 X
X 863 1280 15 5
2.8 X
X Mostly sand, small clay seam 863 1280 20 4
2.6 X
X 02W27 899 1208 13 3
1.8 X
X 900 1251 9.5 5
4.3 X
X Sand and silt 900 1251 18 5
2.1 X
X Clay to Silty Sand 877 1256 9.5 5
4.6 X
X 877 1256 14.5 5.3 8.1 X
X 02W30 880 1230 17.5 5
2.1 X
909 1240 5.5 5
6.2 X
909 1240 15 5
4.1 X
941 1219 9.5 5
2.7 X
941 1219 14.5 5.5 1.3 X
02W33 927 1164 6
5 1.7 X
02W34 984 1145 9
5 1.6 X
02W35 1001 1166 9
5 1.1 X
02W36 984 1165 20 5
1.4 X
02W37 1000 1188 20 5
1.8 X
02W38 982 1208 21 5
1.4 X
871 1263 10 5
3.5 X
871 1263 17 5
5.6 X
02W26 02W28 02W29 02W31 02W32 02W39 02W25 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 4 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 848 1249 17 5
2.2 X
848 1249 25 5
1.8 X
02W41 854 1263 23 5
0.6 X
02W42 868 1230 23 5
2.5 X
02W43 1016 1188 20 7.5 1.7 X
999 1203 10 5
1.2 X
999 1203 22 4.5 1.6 X
1014 1178 10 5
2.0 X
1014 1178 23 5
3.8 X
923 1232 10 5
2.8 X
923 1232 15 4
3.5 X
837 1246 10 5
2.0 X
837 1246 25 5
1.2 X
1075 1219 5
5 1.5 X
1075 1219 10 5
1.6 X
1075 1219 15 5
2.6 X
1075 1219 20 5
2.4 X
1075 1219 25 5
2.2 X
1075 1219 29 5
1.8 X
1075 1219 34 5
1.5 X
1075 1219 39 5
1.2 X
1075 1219 44 5
2.1 X
942 1197 6
12 1.8 X
942 1197 18 1
1.9 X
820 1246 17 3
1.2 X
820 1246 20 5
1.4 X
820 1246 25 3
1.2 X
820 1246 28 5
2 X
826 1230 4.5 4.5 1.7 X
826 1230 30 4
1.3 X
820 1257 10 14 1.0 X
820 1257 28 5.5 2.4 X
898 1203 10 5
1.0 X
898 1203 15 5
1.5 X
922 1195 0
1 3.0 X
X 922 1195 1
1 1.4 X
X 922 1195 2
1 2.1 X
X 922 1195 3
1 2.6 X
X 922 1195 4
1 3.3 X
X 922 1195 5
1 5.1 X
X 922 1195 6
1 3.6 X
X 922 1195 7
1 14.9 X
X 922 1195 8
1 6.9 X
X 922 1195 9
1 8.4 X
X 922 1195 10 1
2.1 X
X 922 1195 11 1
8.4 X
X 922 1195 12 1
5.9 X
X 922 1195 13 1
1.0 X
X 02W54 02W45 02W46 02W47 02W49 02W50 02W48 02W51 02W52 02W53 02W40 02W44 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 5 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 911 1210 0
1 2.5 X
X 911 1210 1
1 2.3 X
X 911 1210 2
1 3.2 X
X 911 1210 3
1 2.8 X
X 911 1210 4
1 3.3 X
X 911 1210 5
1 4.9 X
X 911 1210 6
1 8.2 X
X 911 1210 7
1 9.5 X
X 911 1210 8
1 8.7 X
X 911 1210 9
1 8.7 X
X 911 1210 10 1
21.3 X
X 911 1210 11 1
16.2 X
X Clay and sand layers 911 1210 12 1
18.5 X
X Clay and sand layers 911 1210 13 1
12.8 X
X 911 1210 14 1
20.9 X
X 911 1210 15 1
7.0 X
X 911 1210 16 1
4.0 X
X 911 1210 17 1
3.4 X
X 911 1210 18 1
3.3 X
X 911 1210 19 1
1.4 X
X 911 1210 20 1
1.6 X
X 911 1210 21 1
2.2 X
X 02W56 939 1122 0
8 2.1 X
X 915 1255 0
1 7
X X
915 1255 1
1 3
X X
915 1255 2
1 2
X X
915 1255 3
1 7
X X
915 1255 4
1 No Sample X
915 1255 5
1 6
X X
915 1255 6
1 2
X X
915 1255 7
1 9
X X
915 1255 8
1 3
X X
915 1255 9
1 No Sample X
915 1255 10 1
3 X
X 915 1255 11 1
5 X
X 915 1255 12 1
3 X
X 915 1255 13 1
5 X
X 915 1255 14 1
3 X
X 915 1255 15 1
3 X
X 915 1255 16 1
4 X
X 915 1255 17 1
4 X
X 915 1255 18 1
10 X
X 915 1255 19 1
6 X
X 915 1255 20 1
5 X
X 915 1255 21 1
3 X
X 915 1255 22 1
4 X
X 915 1255 23 1
3 X
X 915 1255 24 1
2 X
X 02W55 TMW-5 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 6 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 890 1280 0
1 3
X X
890 1280 1
1 5
X X
890 1280 2
1 3
X X
890 1280 3
1 7
X X
890 1280 4
1 5
X X
890 1280 5
1 4
X X
890 1280 6
1 5
X X
890 1280 7
1 6
X X
890 1280 8
1 3
X X
890 1280 9
1 5
X X
890 1280 10 1
5 X
X 890 1280 11 1
2 X
X 890 1280 12 1
4 X
X 890 1280 13 1
3 X
X 890 1280 14 1
3 X
X 890 1280 15 1
5 X
X 890 1280 16 1
11 X
X Located far northeast of eastern trench.
Average throughout this boring is 4.5 Ci/g (background).
890 1280 17 1
4 X
X 890 1280 18 1
4 X
X 890 1280 19 1
4 X
X 890 1280 20 1
6 X
X 890 1280 21 1
2 X
X 890 1280 22 1
4 X
X 890 1280 23 1
5 X
X 890 1280 24 1
3 X
X 890 1280 25 1
7 X
X 890 1280 26 1
3 X
X 890 1280 27 1
5 X
X 890 1280 28 1
3 X
X 890 1280 29 1
3 X
X 920 1241 0
1 4
X X
920 1241 1
1 5
X X
920 1241 2
1 6
X X
920 1241 3
1 6
X X
920 1241 4
1 No Sample X
920 1241 5
1 8
X X
920 1241 6
1 5
X X
920 1241 7
1 9
X X
920 1241 8
1 6
X X
920 1241 9
1 No Sample X
920 1241 10 1
5 X
X 920 1241 11 1
6 X
X 920 1241 12 1
7 X
X 920 1241 13 1
7 X
X 920 1241 14 1
9 X
X Low permeability layer located directly on top of mudstone at the base of higher permeability material TMW-7 (also SB-14)
TMW-6 Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 7 of 8
Cimarron Environmental Response Trust Response to October 2, 2023, RAIs Table GWRM-1 Uranium Concentrations in BA1 Soils Prepared by:Stephen Wood Date:11/14/2023 Reviewed by:Jim Feild Date:11/14/2023 Sample Station Northing (feet)
Easting (feet)
Depth (feet)
Sample Length (feet)
Total U (pCi/g)
Soil Concentrations Less than
Background
<7 pCi/g Soil Concentrations Between 7-9 pCi/g Soil Concentrations Above
Background
>9 pCi/g Very Low Permeability (Bedrock)
Low Permeability (Clay)
Medium Permeability (Silt)
High Permeability (Sand)
Notes 900 1235 0
1 7
X X
900 1235 1
1 4
X X
900 1235 2
1 7
X X
900 1235 3
1 No Sample X
900 1235 4
1 No Sample X
900 1235 5
1 11 X
X 900 1235 6
1 15 X
X 900 1235 7
1 32 X
X 900 1235 8
1 17 X
X 900 1235 9
1 16 X
X 900 1235 10 1
15 X
X 900 1235 11 1
16 X
X 900 1235 12 1
18 X
X 900 1235 13 1
16 X
X 900 1235 14 1
15 X
X 900 1235 15 1
11 X
X 900 1235 16 1
12 X
X 900 1235 17 1
12 X
X 900 1235 18 1
11 X
X 900 1235 19 1
19 X
X 900 1235 20 1
17 X
X Low permeability layer located directly on top of mudstone at the base of higher permeability material 900 1235 21 1
10 X
X Low permeability layer located directly on top of mudstone at the base of higher permeability material 900 1235 22 1
3 X
X 900 1235 23 1
4 X
X Notes:
TMW-9 Light fill indicates uranium soil concentrations between 7-9 pCi/g Dark fill indicates uranium soil concentrations above 9 pCi/g Source: Burial Area #1 Groundwater Assessment Report January 2003 Page 8 of 8
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 within 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 extending to the southeast of existing extraction trench GETR-BA1-01 (see attached Figure 8-8). Given 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 evaluate 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 trenches. 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 information, and the proposed monitoring schedule for any additional groundwater monitoring 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 remediation area, as well as groundwater sampling analytical results, would provide valuable information 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 groundwater 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 provide data from the vicinity of injection and/or extraction trenches. The expanded monitoring network 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 density of monitor wells in the vicinity of the BA1 extraction trenches, Figure 8-8a covers the entirety 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 trenches 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, and 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 Corporation (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 Cimarron'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 installed 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 sufficient information to demonstrate remediation efficiency, compliance with the NRC criterion, and evaluation of plume capture. Monitor well abandonment, installation, and development will be conducted in accordance with the CERT Procedure SAP-110, Well Installation and Abandonment. Table 8-2 indicates the frequency with which these new monitor wells will be measured for depth to water and sampled for uranium analysis.
The use of nested monitor wells in place of fully penetrating monitor wells would not provide information that is useful to evaluate system capture, cleanup efficiency, or compliance monitoring. It has been demonstrated that uranium within upland areas at the site is contained almost exclusively within fractures in sandstone formations, or within interconnected sand channel deposits in the TZ formation. Historically, attempts to collect depth-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 evaluating 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 data needed to evaluate the hydraulic performance of injection and extraction components during system 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 Groundwater 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 In-Process Groundwater Monitoring Locations Prepared by: Stephen Wood Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment Monitoring Location 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 1417
Q 1418
Q 1419
Q 1420
Q 1421 A
Q 1422 A
Q TMW01 A
Q TMW02 A
Q 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 02W39 A
Q 1315R Q
Q 1404 Q
Q 1405 Q
Q 1412 Q
Q 1413 Q
Q 1414 Q
Q 1415 Q
Q Sandstone B BA1A Transition Zone Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 1 of 3
Table 8 Revision 1 In-Process Groundwater Monitoring Locations Prepared by: Stephen Wood Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment Monitoring Location Uranium DTW 1423 Q
Q 1424 Q
Q 1425 Q
Q 1426 Q
Q TMW05 A
Q TMW06 Q
Q TMW07 A
Q 02W04 A
Q 02W32 Q
Q TMW13 Q
Q 02W07 Q
Q 02W08 Q
Q 02W14 A
Q 02W19 Q
Q 02W18 A
Q 02W37 A
Q 02W38 A
Q 02W44 Q
Q 1410 Q
Q 02W43 A
Q 1411 Q
Q MWWA09 Q
Q 1429 Q
Q 1430 Q
Q 1431 A
Q T62 Q
Q T63 Q
Q T64 Q
Q T65 Q
Q T66 A
Q T68 Q
Q T69 A
Q T72 Q
Q T75 A
Q T76 A
Q T77 A
Q T79 A
Q North of GEBA103 /
South of GEBA104 South of GEBA102 North of GEBA102 /
South of GEBA103 BA1-A (continued)
Transition Zone (continued)
North of GEBA104 BA1B 1206NORTH WAA U>DCGL Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 2 of 3
Table 8 Revision 1 In-Process Groundwater Monitoring Locations Prepared by: Stephen Wood Date: 11-14-23 Reviewed by: Jim Feild Date:11-14-23 Remediation Area Plume Segment Monitoring Location Uranium DTW T84 A
Q T104 Q
Q T105 Q
Q 1427 A
Q 1428 A
Q 1351 Q
Q 1352 Q
Q 1356 Q
Q 1358
Q 1359 A
Q Notes:
- A annually
- Q quarterly
- DTW depth to water
- Frequency of analysis for uranium may change as data trends are established.
WUBA3 DTW measurement frequency for the first 3 months of operation is in Section 8.6.1.
WAA U>DCGL (continued)
Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 3 of 3
FIGURE 8-7A WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS
1427 1431 1430 1428 1429 MWWA-09 MWWA-03 1321 1338 1341 1345 1346 1382 1384 1386 1388 1390 1391 1392 1394 1311 1312 1313 1320 1324 1331 1335A 1336A 1337 1340 1347 1348 1350 1351 1352 1354 1355 1356 1357 1358 1359 1360 1377 1378 1379 1381 1383 1385 1387 1389 1393 1403 1402 1401 1400 1399 1398 1397 1396 1395 TR-01 TR-02 TR-03 TR-04 TR-05 TMP-UP2-01 TMP-UP2-02 1343 T-51 T-52 T-53 T-54 T-55 T-56 T-57 T-58 T-59 T-60 T-61 T-62 T-63 T-64 T-65 T-66 T-67 T-68 T-69 T-70R T-72 T-73 T-74 T-75 T-76 T-77 T-78 T-79 T-81 T-82 T-83 T-84 T-85 T-86 T-87 T-88 T-89 T-90 T-91 T-93 T-94 T-95 T-96 T-97 T-98 T-99 T-101 T-102 T-103 T-92R T-104 T-105 2023 BURNS & McDONNELL ENGINEERING COMPANY, INC.
Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-7_WA In-process GW Mon Locations FIGURE 8-7A WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS FACILITY DECOMMISSIONING PLAN REVISION 3 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017
- 2) ALL NEW WELL LOCATIONS ARE SUBJECT TO ADJUSTMENT BASED ON FIELD CONDITIONS AT THE TIME OF CONSTRUCTION.
0 390 780 SCALE IN FEET Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 AREA SHOWN ON FIGURE 8-7B MONITOR WELL TO BE ABANONED EXISTING IN-PROCESS MONITOR WELL ADDITIONAL IN-PROCESS GROUNDWATER MONITORING LOCATION NEW IN-PROCESS MONITORING WELL INSTALLATION
- TRANSITION ZONE WESTERN AREA TREATMENT FACILITY TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP EXTRACTION TEST WELL MONITOR WELL IN TRANSITION ZONE MONITOR WELL IN SANDSTONE C MONITOR WELL IN SANDSTONE B MONITOR WELL IN SANDSTONE A MONITOR WELL IN ALLUVIUM LEGEND NEW IN-PROCESS MONITORING WELL INSTALLATION
- ALLUVIUM
FIGURE 8-7B WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS U>DCGL AREAS
1430 1431 1427 1428 1429 MWWA-09 MWWA-03 1321 1341 1345 1346 1382 1392 1311 1312 1313 1320 1331 1335A 1336A 1340 1350 1351 1352 1354 1355 1356 1357 1358 1359 1360 1377 1378 1379 1381 1393 1401 1400 1399 1398 1397 1396 1395 TR-01 TR-02 TR-03 TR-04 T-54 T-55 T-57 T-58 T-62 T-63 T-64 T-65 T-66 T-67 T-68 T-69 T-70R T-72 T-73 T-74 T-75 T-76 T-77 T-78 T-79 T-81 T-83 T-84 T-85 T-104 T-105 2023 BURNS & McDONNELL ENGINEERING COMPANY, INC.
Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-7_WA In-process GW Mon Locations FIGURE 8-7B WESTERN AREA IN-PROCESS GROUNDWATER MONITORING LOCATIONS FACILITY DECOMMISSIONING PLAN REVISION 3 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017 0
200 400 SCALE IN FEET Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 GETR-WU-01 GWI-WU-01 MONITOR WELL TO BE ABANONED EXISTING IN-PROCESS MONITOR WELL ADDITIONAL IN-PROCESS GROUNDWATER MONITORING LOCATION NEW IN-PROCESS MONITORING WELL INSTALLATION
- TRANSITION ZONE WESTERN AREA TREATMENT FACILITY TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP EXTRACTION TEST WELL MONITOR WELL IN TRANSITION ZONE MONITOR WELL IN SANDSTONE C MONITOR WELL IN SANDSTONE B MONITOR WELL IN SANDSTONE A MONITOR WELL IN ALLUVIUM LEGEND NEW IN-PROCESS MONITORING WELL INSTALLATION
- ALLUVIUM
FIGURE 8-8A BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS
1425 1424 1423 02W01 02W02 02W03 02W09 02W10 02W13 02W20 02W26 02W28 02W39 1315R TMW-05 TMW-06 TMW-07 TMW-09 1406 1405 1404 TR-08 TR-09 TR-10 1415 1414 1412 1426 1413 02W48 TMW-17 TMW-23 02W25 02W27 02W30 02W40 02W41 02W42 02W47 02W50 02W51 02W52 02W53 1314 1316R TMW-01 TMW-02 TMW-08 TMW-18 TMW-19 TMW-20 TMW-21 TMW-25 1408 1407 1409 TR-06 TR-07 1420 1421 1418 1417 1416 1422 1419 02W04 02W05 02W06 02W07 02W08 02W11 02W12 02W14 02W15 02W16 02W17 02W18 02W19 02W21 02W22 02W23 02W24 02W32 02W33 02W34 02W35 02W36 02W37 02W38 02W43 02W44 02W45 02W62 1344 1361 1362 1363 1364 1365 1366 TMW-13 TMW-24 1370 1371 1367 1368 1372 1373 1369 1411 1410 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017
- 2) ALL NEW WELL LOCATIONS ARE SUBJECT TO ADJUSTMENT BASED ON FIELD CONDITIONS AT THE TIME OF CONSTRUCTION.
FIGURE 8-8A BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS FACILITY DECOMMISSIONING PLAN REVISION 3 0
100 200 SCALE IN FEET Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-8_BA1 In-process GW Mon Locations 2021 BURNS & McDONNELL ENGINEERING COMPANY, INC.
MONITOR WELL TO BE ABANONED EXISTING IN-PROCESS MONITOR WELL ADDITIONAL IN-PROCESS GROUNDWATER MONITORING LOCATION NEW IN-PROCESS MONITORING WELL INSTALLATION
- TRANSITION ZONE TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP MONITOR WELL IN TRANSITION ZONE MONITOR WELL IN SANDSTONE C MONITOR WELL IN SANDSTONE B MONITOR WELL IN ALLUVIUM LEGEND NEW IN-PROCESS MONITORING WELL INSTALLATION
- ALLUVIUM NEW IN-PROCESS MONITORING WELL INSTALLATION
- SANDSTONE B AREA SHOWN ON FIGURE 8-8B
FIGURE 8-8B BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS TRENCH AREA
!?
!?
!?
!?
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
MM M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M M
M 1425 1424 1423 GWI-BA1-03 GWI-BA1-02 GWI-BA1-04 GWI-BA1-01 GETR-BA1-02 GETR-BA1-01 GWI-BA1-02A GWI-BA1-03A GWI-BA1-04 GWI-BA1-01A GE-BA1-02 GE-BA1-03 GETR-BA1-02A GETR-BA1-01A GETR-BA1-01B 02W01 02W02 02W03 02W09 02W10 02W13 02W20 02W26 02W28 02W39 1315R TMW-05 TMW-06 TMW-07 TMW-09 1406 1405 1404 TR-08 TR-09 TR-10 1415 1414 1412 1426 1413 1315R TMW-17 TMW-23 02W25 02W27 02W30 02W40 02W41 02W42 02W47 02W50 02W51 02W52 02W53 1316R TMW-01 TMW-02 TMW-08 TMW-18 TMW-19 TMW-20 TMW-21 TMW-25 1408 1407 1409 TR-06 TR-07 1420 1421 1418 1417 1416 1422 1419 02W04 02W05 02W07 02W08 02W11 02W12 02W14 02W18 02W19 02W32 02W38 TMW-13 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017 FIGURE 8-8B BURIAL AREA #1 IN-PROCESS GROUNDWATER MONITORING LOCATIONS - TRENCH AREA FACILITY DECOMMISSIONING PLAN REVISION 3 0
40 80 SCALE IN FEET o
Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-8_BA1 In-process GW Mon Locations 2021 BURNS & McDONNELL ENGINEERING COMPANY, INC.
MONITOR WELL TO BE ABANONED EXISTING IN-PROCESS MONITOR WELL ADDITIONAL IN-PROCESS GROUNDWATER MONITORING LOCATION NEW POST-REMEDIATION MONITORING WELL INSTALLATION - TRANSITION ZONE TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP
!?
MONITOR WELL IN TRANSITION ZONE M
MONITOR WELL IN SANDSTONE C M
MONITOR WELL IN SANDSTONE B M
MONITOR WELL IN ALLUVIUM M
LEGEND NEW POST-REMEDIATION MONITORING WELL INSTALLATION - ALLUVIUM NEW POST-REMEDIATION MONITORING WELL INSTALLATION - SANDSTONE B
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 travels through the TMW-8 hot spot area (see attached Figure 4-3). Evaluation of the groundwater flow model calibration data set and process presented in the 2022 Groundwater Flow Model 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 omission of the 02W51 well as a calibration point could have resulted in an underestimation 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, August 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 Remediation Pilot Test Report (ML18171A300), may result in reduced effectiveness of the injection and flushing 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 wells 1409, TMW-20, 02W25, 02W51, TMW-2, and 02W50, are not necessary in the proposed groundwater monitoring locations in the D-Plan (see attached Figure 8-8 for the listed monitoring 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 preferential 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 GWRM-1, Table GWRM-1-1 presents uranium concentration data for soil samples collected during 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-3-1 show that the uranium concentration in TMW-08 has trended downward from the 2,589 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 Sandstone B wells (1314, 02W50, and 02W52) in the calibration, but omitted the groundwater elevation for 02W51. Further evaluation was performed to determine the validity of the groundwater elevation 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 levels, indicates that this well monitors a perched water zone. Similarly, examination of the boring log for Monitor Well 02W25, located approximately 70 feet to the north, indicates water was encountered 7.5 feet bgs during drilling.
Soils deeper than 7.5 feet were described as damp; 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 wells 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 higher 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, 2019. 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 historical mapping of the uranium plume which has consistently followed the same north to northwest orientation. The interconnected sand channel deposits mapped during environmental 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 monitoring will provide the data needed to adjust injection and extraction flow rates to optimize 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 Injection Trench GWI-BA-1-01 and the ephemeral stream. Both monitor wells are included in the 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 monitor 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-process 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 Well 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 declined 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 concentrations 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 issued, the text of Section 8.6 of the D-Plan will be revised to incorporate the monitoring described 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
Cimarron Environmental Response Trust Table GWRM-3-1 Uranium Concentration in Monitor Wells TMW-08 and 02W39 Prepared by: S Wood Date: 11/14/2023 Reviewed by: J Feild Date: 11/29/2023 Year (pCi/L)
(ug/L)
Year ug/L Q1 Q2 Q3 Q4 2,589 Representative 1,100 2011 532 2011 2012 546 2012 2013 2,091 2013 851 2014 685 2014 2015 526 2015 537 2016 1,841 2016 600 429 469 425 2017 1,499 2,330 2017 344 383 392 309 2018 279 335 2018 234 435 232 223 2019 200 185 2019 2020 446 250 2020 214 175 160 2021 364 409 2021 176 301 378 146 2022 28 268 2022 176 166 165 2023 92 96 2023 260 Uranium Concentration TMW-08 Representative 02W39 Uranium Concentration Page 1 of 1
ATTACHMENT GWRM-3-1 SOIL BORING LOGS
Protective Pipe Yet No D Steel PVC Surveying Pin ? --------
Yea 0 No O Concrete Cement/Bentonite Grout Mix Yee No£f 5.5 Gallons Water to 94Lb. Bag Cement &.
35 Lb. Bentonite Powder Others Bentonite Seal Pellets Ef Slurry Q Filter Pack Above Screen MONITORING WELL INSTALLATION DIAGRAM
-Casing Cap Vent 1 Yea Q No 0" FILTER PACK MATERIAL Silica Sand Ef Waehed Sand 0 Pea Gravel Others Sand Size
- Donee Pfiaee Sampling Cup Bottom Plug Yee El Over drilled Material Backfill Grout 0 Sand Caved Material 0 Others___________
Lock ? Yes O No
^Weep Hole ? Yea No 0^
Concrete Pad __ M______ Ft. x H
Ft.x JzL.
Inehes
^2/2 0 NoQ DrIIlerXFfrm
/^AST-AO£ Drill Rig Type DRILLING INFORMATION:
I. Borehole Diameter* ^_____ Inchea.
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
' Depth*
A/A to AjA Feet.
- 4. Borehole Diameter for Outer Casino ^ inchea.
WELL CONSTRUCTION INFORMATION:
I.Type of Caeing: PVC Ef Galvanized Taflon Stainless Q Other---------------------------------------------
- 2. Type of Casing Joints: ScrewCouple 0 Couple Other____________________
Glue
- 3. Type of Well Screens PVC 0 Galvanized Q Stainless 0 Teflon Q Other
- 4. Diameter of Casing and Well Screen:
Casing inches. Screen
- 5. Slot Size of Screen:
l
- 6. Type of Screen Perforation: Factory Slotted Hacksaw 0 Drilled Other____________
9 inches.
e/
- 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__________
- 2. Time Spent on Well Development ?
/---------------- Minutea/Hours
- 3. Approximate Water Volume Removed ?___
. Gallons
- 4. Water Clarity Before Development t Clear 0 Turbid 0 Opague 0
- 5. Water Clarity After Development ? Clear 0 Turbid 0 Opaque 0 S. Did Water have Oder t Yea 0 No 0 If Yes, Describe_________________________
?>> Did Water-have any Color ? Yee 0 If Yes, Describe No0 WATER LEVEL INFORMATION:
Water Level Summary (From Top of Casing)
During Drilling
- Ft. Date_______
Before Development i%2.L Ft. Date ll_fz I /26f J After Development______ Ft. Date Date. Installed l(./£/bz_
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35 Lb. Bentonite Powder Other:
Bentonite Seal Pellets 0^Slurry Q Filter Pack Above Screen MONITORING WELL INSTALLATION DIAGRAM
-Casing Cap Vent ? Ye* Q No Concrete Pad Lock ? Yes No
^Weep Hole ? Ye* No O'
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FILTER PACK MATERIAL Silica Sand gj^
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DRILLING INFORMATION:
- 1. Borehole Diameters__________ Inches.
- 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 f/4 to Feet.
Inches.
Depth=
4* Borehole Diameter for Outer Casing.
WELL CONSTRUCTION INFORMATION:
I.Type of Casings PVC 0! Galvanized Q Teflon Q Stainless Q Other__________________
/' 25 H.is 3-7S Go 5-2S So
- 2. Type of Casing Joints: ScrewCouple S' Glue-Couple Other_________._________________
- 3. Type of Well Screens PVC QK Galvanized Q Stainless Teflon Other_________________
Inches.
- 4. Diameter of Casing and Well Screen:
Casing _
_ inches. Screen ^
- 5. Slot Size of Screen: Q.O f
- 6. Type of Screen Perforation: Factory Slotted Hacksaw Q Drilled Other.
- 7. Installed Protector Pipe w/Lockx Yes Ef No Q WELL DEVELOPMENT INFORMATION:
I. How was Well Developed? Bailing Pumping Q Air Surging (Air or Nitrogen) 0 Other
- 2. Time Spent on Well Development ?
/.---------------- Mlnutea/Houra
- 3. Approximate Water Volume Removed ?___
, Gallons in.zs 13-b
- 4. Water Clarity Before Development ? Clear Q Turbid Opaque
- 5. Water Clarity After Development ? Clear Q Turbid Q Opaque
- 6. Did Water have Oder t Yes No If Yes, Describe_____________
7* Did Water-have any Color ? Yes Q No Q If Ye*
- Describe____
WATER LEVEL INFORMATION:
Water Level Summary (From Top of Casing)
During Drilling_______.
Before Development fr3/
After Development________
. Ft. Date______ _
.Ft. Data 1(1 Ft. Date, 7
Drlller/Flrm CASc**c Drill Rig Type
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LITHOLOGIC DESCRIPTION u
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KERR-McGEE CORPORATION HYDROLOGY DEPARTMENT MONITORING WELL INSTALLATION DIAGRAM Protective Pipe-Yee 53 No Steel PVC §0 Surveying Pin ?
Yee No Q Concrete Cement/Bentonite Grout Mix Yee 0 NoQ 5.5 Gallons Water to 94Lb. Ba9 Cement &.
35 Lb. Bentonite Powder Others ____
Caelng Cep Vent t Yee Q
................ Lock T Yee No
,-Weep Hole t Yee No A
Concrete Pad DEPTH FROM TOP OF CASING Bentonite Seel Pellets^ Slurry 0 Filter Pack Above Screen FILTER PACK MATERIAL Silica Sand ^
Waehed Sand 0 Pea Gravel Q Otheri_______
Sand Size <^-0 Denee Phaee Sampling Cup q Bottom Plug Yee (3 No 0 Overdrilled Material Backfill Grout Sand 0 Caved Material 0 Otheri_________
No Ft. x 4
Ft. x Inchee DRILLING INFORMATION:
- 1. Borehole DIameter= 3 VT Inchee.
- 2. Were Drilling Addltlvea Ueed 1 Yee0 No Q Revert Q BentonlteQ WaterD Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Caelng Ueed f Yee Q No(2f Depths__________to___________ Feet.
- 4. Borehole Diameter for Outer Caelng_______ Inchee.
WELL CONSTRUCTION INFORMATION:
I.Type of Caelng: PVC Galvanized 0 TeflonQ Stalnleee Q Other____________________________
- 2. Type of Caelng Jointer Screw-Couple (3 Couple 0 Other____________________
Glue-
- 3. Type of Well Screen: PVC Galvanized Stalnleee 0 Teflon O Other______________
- 4. Diameter of Caelng and Well Screen:
Caelng cX Inchee. Screen a Inchee.
- 5. Slot Size of Screen:- 0,0 iO
- 6. Type of Screen Perforation: Factory Slotted 0 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
-falocgL.
2.
QD
-jtinutep^Houre
- 3. Approximate Water Volume Removed f Gallone
- 4. Water Clarity Before Development f Clear 0 Turbid 0 Opaque
- 5. Water Clarity After Development f Clear 0 Turbid §3 Qpaque 0
- 6. Did Water have Oder f YeiQ No H?
If Yee>> Describe___________________________
- 7. Did Water have any Color If Yee, Doacrlbe lolor I M
YesCa* No Q WATER LEVEL INFORMATION:
Water Level Summary (From Top of Casing}
During Drilling______
Before Development.
After Development _
, Ft* Ddtd..
Ft. Date ~l Ft. Date______________
Drlller/Flrm AEX Drill Crew GfA<A.YA Drill Rig Type SfrgAaSt<<xrlDD>te lnetalled Well No. & & W I 71/5/02.
KerrMcGee \\
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SOIL BORING LOG KM5655-A
KERR-McGEE CORPORATION HYDROLOGY DEPARTMENT MONITORING WELL INSTALLATION DIAGRAM Protective Pipe---------------
Yee No Steel PVC
~
Surveying Pin ?
Ye* 0 No 0 Ft.
Concrete Ft.
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_________Ft-35 Lb. Bentonite Powder Other:_______
Bentonite Seal Pellet* QZ] Slurry 0 Filter Pack Above Screen
£ r Ft.
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FILTER PACK MATERIAL Silica Sand ^
Washed Sand 0 Pea Gravel Q Other*___________________
Sand Size Q-Dense Phase Sampling Cup q Bottom Plug Yes No Q 3 Ft.
Overdrilled Material Backfill Grout Q Sand Caved Material Q Other*_____
__Casing Cap Vent T Yes 0 No Q
________ Lock? Ye* No
,Weep Hole T Yes 0 No 0 Concrete Pad DEPTH FROM TOP OF CASING BELOW GRADE 9.5
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Ft. I X_.
52-*S'"
4 Ft. x 4
Ft.x 4
Inches DRILLING INFORMATION:
- 1. Borehole Diameter= 8 ¥/ Inches.
- 2. Were Drilling Additives Used T Yes0 No Revert 0 Bentonite 0 Water 0 Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Casing Used ? Ye* Q No0^
Depth=__________ to___________Feet.
- 4. Borehole Diameter for Outer Casing_______ Inches.
WELL CONSTRUCTION INFORMATION:
- 1. Type of Casing: PVC Ej Galvanized Q TeflonQ Stainless 0 Other__________________ _________
- 2. Type of Casing Joints: ScrewCouple IS Glue-Couple 0 Other ______________________________
- 3. Type of Well Screen* PVC ^ Galvanized Q Stainless O Teflon D Other__________________
- 4. Diameter of Caeing and Well Screen; Casing <^y Inches. Screen Inches.
- 5. Slot Size of Screen*
- Q t O l O
- 6. Type of Screen Perforation: Factory Slotted Hacksaw 0 Drilled 0 Other________________
- 7. Installed Protector Pip* w/Lock* Yes (3 No 0 WELL DEVELOPMENT INFORMATION:
I. How was Well Developed f Bailing Q Pumping 0 Other Air Surging (Air or Nitrogen) fiQ AwAop sayA. pacE Sura
- 2. Time Spent on Well Development f ^
-/-
Minutes/Hour*
- 3. Approximate Water Volume Removed
- 4. Water Clarity Before Development ? Clear 0 Turbid 0 Opaque 0
- 5. Water Clarity After Development 7 Clear 0 Turbid 0 Opaque 0
- 6. Did Water have Oder ? Yes 0 No 0 If Yes. Describe___________________
Gallons
- 7. Did Water have any Color f Yes 0 If Yea. Describe_________________
No 0 WA TER LEVEL INFORMATION:
Water Level Summary (From Top of Casing)
During Drilling_________________Ft. Date--------------
Before Development.
After Development _
Ft. Date.
Ft. Date.
Drlller/Flrm /V hi X Drill Crew v )ol\\v\\r\\M GircxVv\\Qw\\
Drill Rig Type Well No. O 2-VJ Zff~
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BLOWS PER FOOT PID (ppm)
SOIL SAMPLE NO.
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REMARKS OR FIELD OBSERVATIONS 4-7 A
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Yee Q No Steel PVC Surveying Pin T ~
Ye* No Q Ft.
Concrete Ft.
Cement/Bentonite Grout Mix Ym No0 5.5 Gallon* Water to 94Lb. Bag Coment &
35 Lb. Bentonite Powder Other:___________________
Bentonite Seal Pellets Qijj Slurry 0 Ft.
Ft.
Filter Pack Above Screen a-Ft.
FILTER PACK MATERIAL Silica Sand ^
Washed Sand 0 Pea Gravel 0 Other*___
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Or
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No Q Concrete Pad Ft. x 4
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DRILLING INFORMATION:
- 1. Borehole Diametar= 8 ¥/ Inches.
- 2. Were Drilling Additives Used T YeeQ Revert 0 Bentonite 0 Water Q Solid Auger 0 Hollow Stem Auger 0
- 3. Was Outer Steel Casing Used 7 Ye>>0 Noffif Depth=__________ to___________ Fast.
- 4. Borehole Diameter for Outer Caalng______ Inches.
WELL CONSTRUCTION INFORMATION:
I.Type of Casing: PVC gj Galvanized 0 Teflon Stainless 0 Other____________________________
- 2. Type of Casing Joints: ScrewCouple 0 Glue-Couple Q Other _____________________________
- 3. Type of Well Screen: PVC (3 Galvanized 0 Stainless 0 Teflon 0 Other__________________
- 4. Diameter of Casing and Well Screen:
Casing Inches. Screen Inches.
- 5. Slot Size of Screens
- Q, O l O
- 6. Type of Screen Perforation: Factory Slotted 0 Hacksaw 0 Drilled 0 Other____________________
- 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 A^vxAop SAr&-
Sujr^j> HioeK.
- 2. Thao Spent on Well Development 7
/------------------Minutes/Hours
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- 4. Water Clarity Before Development I Clear 0 Turbid 0 Opaque 0
- 5. Water Clarity After Development 7 Clear 0 Turbid 0 Opaque 0
- 6. Did Water have Oder 7 Yes 0 No 0 If Yes. Describe______________________
Did Water have any Color 7 If Yes t Describe Yes 0 No 0 WATER LEVEL INFORMATION:
Water Level Summary (From Top of Casing)
During Drilling_________________ Ft. Date________
Before Development____________ Ft. Date________
After Development____________ Ft. Date________
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SOIL BORING LOG KM5655-A
FIGURE GWRM-3-1 URANIUM CONCENTRATION TREND IN MONITOR WELLS TMW-08 AND 02W39
FIGURE GWRM-3-2 BA1 POTENTIOMETRIC ELEVATIONS
IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT IT ET ET ET ET ET ET ET ET ET ET ET ET ET ET ET ET ET TR-08 GETR-BA1-01A TR-07 1408 TR-06 1407 1405 1409 TMW-02 02W51 02W52 02W47 02W25 02W40 TMW-20 TMW-01 TMW-21 02W41 TMW-25 02W20 02W39 02W02 TMW-09 TMW-07 02W09 1315R 02W30 TMW-17 TMW-08 TMW-06 02W29 (ABANDONED) 02W50 02W26 1316R 02W27 02W53 02W01 TMW-05 02W10 1406 02W31 (ABANDONED)
TMW-18 02W03 02W04 02W15 TR-09 TR-10 02W28 02W42 GWI-BA1-01A GWI-BA1-01 GWI-BA1-02 GWI-BA1-03 GETR-BA1-02 GWI-BA1-04 GETR-BA1-01 NORTH Inches Date:
of sheet sheets contract rev.
file S.Wood 11/30/2023 J. Feild 11/30/2023 Cimaron Environmental Response Trust BA1 POTENTIOMETRIC ELEVATIONS 2019 STATIC CONDITIONS FIGURE GWRM-3-2 1
1 OKLAHOMA FIRM LICENSEE NO. 421 816-333-9400 KANSAS CITY, MO 64114 9400 WARD PARKWAY 0
SCALE IN FEET 20' 40' project Reviewed by:
Prepared by:
Date:
LEGEND GROUNDWATER SURFACE ELEVATION (2019) 965.31 NM NOT MEASURED FORMER BURIAL TRENCH LOCATIONS EXISTING INJECTION TRENCH IT FUTURE INJECTION TRENCH IT ET EXISTING GROUNDWATER EXTRACTION TRENCH ET FUTURE GROUNDWATER EXTRACTION TRENCH MAJOR GROUNDWATER CONTOUR (2019)
MINOR GROUNDWATER CONTOUR (2019)
APPROXIMATE LIMITS OF EPHEMERAL CREEK GROUNDWATER FLOW DIRECTION APPROXIMATE LIMITS OF CONTAMINANT PLUME (250 ug/L)
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 submitted 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 that 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 appropriate monitoring period of the injection operations.
4.2 EPM Response:
Uranium concentration and groundwater elevation 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 TMW-17) was noted when evaluating the data for TMW-17. Uranium concentration and groundwater elevation 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 mean 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 also 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 interval included only Sandstone B and the top of the underlying Mudstone B. Boring logs for and monitor well installation diagrams for Monitor Wells TMW-17, 1315 and 1315R are presented in Attachment 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 extends 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, comparing the data for these wells is informative. The findings of groundwater elevation and uranium concentration 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 Sandstone 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 concentrations have been present in Sandstone B at the 1315R location for over 35 years. If an effective aquitard did not exist between Sandstone B and Sandstone C, elevated concentrations of uranium would also be present in TMW-17 (screened within Sandstone 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 consistently been than 10 pCi/L and 10 µg/L.
Uranium concentrations have consistently been more 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, located 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 thickness 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 the aquifer, flushing groundwater with elevated uranium concentrations to the north 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 contamination 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
Table GWRM-4-1 Data for Monitor Wells TMW-17 and 1315R Prepared by: Jeff Lux Date: 11/15/2023 Reviewed by: Jim Feild Date: 11/16/2023 Differential Head Date Concentration Unit Groundwater Elevation Date Concentration Unit Groundwater Elevation (feet) 7/5/2000 6.48 pCi/L 12/5/2000 5.66 pCi/L 7/2/2001 4.66 pCi/L 8/27/2002 5.54 pCi/L 932.76 8/27/2002 2,175 pCi/L Not Measured 9/13/2004 4.67 pCi/L 934.1 8/25/2004 1,793 & 1,561 pCi/L 935.9 1.8 6.96 pCi/L 5/23/2013 1,234 pCi/L 7.86
µg/L 5/23/2013 1,510
µg/L 1.87 pCi/L 3/25/2015 865 pCi/L 2.98
µg/L 3/25/2015 1,101
µg/L 4/25/2017 2.75
µg/L 934.17 4/25/2017 723
µg/L 936.05 1.88 Notes:
- 5. A positive value in the Differential Head column indicates a downward gradient, while a negative value indicates an upward gradient.
- 3. Monitor Well TMW-17 is screened in Sandstone C.
- 4. Elevations are in feet above mean sea level.
- 2. Monitor Well 1315R is screened in Sandstone B.
- 1. Monitor Well 1315R was installed in 2002, replacing Monitor Well 1315.
-0.01 2.88 5/23/2013 3/25/2015 TMW-17 1315R 934.27 932.07 934.26 934.95 Page 1 of 1
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 well 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 NRC-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 southern 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 RAI 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 groundwater 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-process groundwater monitoring program. Groundwater samples from TMW-08 will likely yield uranium concentrations 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 monitoring locations. However, TMW-08 will be added to the list of post-remediation monitoring locations.
The post-remediation monitoring locations 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 Extraction Well GE-BA1-02. TMW-13 is an in-process groundwater monitoring location in the BA1-B remediation 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. Consequently, 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 added 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-Remediation 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 GWRM-5-1 Uranium Concentration Data for Monitor Wells TMW-08 and TMW-13 Prepared by: S. Wood Date: 11-30-23 Reviewed by: J.Feild Date:11-30-23 Year (pCi/L)
(µg/L) 2,589 Q1 Q2 Q3 Q4 2011 532 Representative 3,520 2012 546 2012 1,206 1,380 2013 2,091 2013 1,179 1,170 2014 685 2014 1,912 2,540 2015 526 2015 859 852 2016 1,841 2016 4,001 4,510 2017 1,499 2,330 2017 2018 279 335 2018 162 227 224 2019 200 185 2019 1,742 1,480 2,564 2020 446 250 2020 488 357 722 521 2021 364 409 2021 1,969 460 1,022 1,480 1,115 2022 28 268 2022 425 596 492 264 209 2023 92 96 2023 293 364 Uranium Concentration TMW-08 Representative Uranium Concentration TMW-13
(µg/L)
(pCi/L)
Year Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 1 of 1
TABLE 8 REVISION 1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
Table 8 Revision 1 Post-Remediation Groundwater Monitoring Locations Prepared by: S. Wood Date: 11-30-23 Reviewed by: J.Feild Date:11-30-23 Area Monitoring Location Uranium Tc99 TMW08 X
TMW-18 X
1416 X
1417 X
1419 X
1420 X
1422 X
02W28 X
1315R X
1412 X
1413 X
1414 X
1415 X
1423 X
1424 X
1426 X
TMW-13 X
02W08 X
02W19 X
02W43 X
1411 X
MWWA09 X
1429 X
1430 X
1431 X
T62 X
T104 X
T105 X
T68 X
1427 X
1428 X
1351 X
1356 X
1336A X
1402 X
1346 X
BA1A Sandstone B BA1A Transition Zone Uranium Pond #2 WUBA3 WAA U>DCGL 1206NORTH BA1-B Cimarron Environmental Response Trust Facility Decommissioning Plan - Rev 3 Page 1 of 1
FIGURE 8-9 WESTERN AREA POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
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1431 MWWA-09 1430 1429 1321 1341 1345 1346 1382 1386 1392 1394 1311 1312 1313 1320 1331 1335A 1336A 1340 1347 1350 1351 1352 1354 1355 1356 1357 1358 1359 1360 1377 1378 1379 1381 1385 1393 1402 1401 1400 1399 1398 1397 1396 1395 TR-01 TR-02 TR-03 TR-04 TMP-UP2-01 TMP-UP2-02 T-54 T-55 T-56 T-57 T-58 T-62 T-63 T-64 T-65 T-66 T-67 T-68 T-69 T-70R T-72 T-73 T-74 T-75 T-76 T-77 T-78 T-79 T-81 T-83 T-84 T-85 T-104 T-105 1427 1428 2023 BURNS & McDONNELL ENGINEERING COMPANY, INC.
Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-7_WA In-process GW Mon Locations FIGURE 8 REV 1 WESTERN AREA POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS FACILITY DECOMMISSIONING PLAN REVISION 3 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017 0
200 400 SCALE IN FEET o
Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 1 EXISTING POST-REMEDIATION MONITOR WELL ADDITIONAL POST-REMEDIATION GROUNDWATER MONITORING LOCATION WESTERN AREA TREATMENT FACILITY TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH MONITOR WELL IN TRANSITION ZONE M
MONITOR WELL IN SANDSTONE C M
MONITOR WELL IN SANDSTONE B M
MONITOR WELL IN SANDSTONE A M
MONITOR WELL IN ALLUVIUM M
LEGEND GETR-WU-01 GWI-WU-01
FIGURE 8-10A BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS
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- 1) BASEMAP: GOOGLE EARTH 2017 FIGURE 8-10A BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS FACILITY DECOMMISSIONING PLAN REVISION 3 0
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Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-8_BA1 In-process GW Mon Locations 2021 BURNS & McDONNELL ENGINEERING COMPANY, INC.
EXISTING POST-REMEDIATION MONITOR WELL ADDITIONAL POST-REMEDIATION GROUNDWATER MONITORING LOCATION TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP
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FIGURE 8-10B BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS TRENCH AREA
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M GWI-BA1-03 GWI-BA1-02 GWI-BA1-04 GWI-BA1-01 GETR-BA1-02 GETR-BA1-01 GWI-BA1-02A GWI-BA1-03A GWI-BA1-04 GWI-BA1-01A GE-BA1-02 GE-BA1-03 GETR-BA1-02A GETR-BA1-01A GETR-BA1-01B 02W03 02W09 02W10 02W13 02W20 02W26 02W28 02W39 1315R TMW-05 TMW-06 TMW-07 1423 1406 1405 1404 TR-08 TR-09 TR-10 1415 1414 1412 1426 1413 1425 1424 TMW-17 TMW-23 02W25 02W30 02W40 02W41 02W42 02W47 02W50 02W51 02W52 TMW-01 TMW-02 TMW-08 TMW-18 TMW-19 TMW-20 TMW-25 1408 1407 1409 TR-06 TR-07 1420 1421 1418 1417 1416 1422 1419 02W04 02W05 02W06 02W07 02W08 02W11 02W12 02W14 02W15 02W18 02W19 02W32 02W38 TMW-13 NOTES
- 1) BASEMAP: GOOGLE EARTH 2017 FIGURE 8-10B BURIAL AREA #1 POST-REMEDIATION GROUNDWATER MONITORING LOCATIONS -
TRENCH AREA FACILITY DECOMMISSIONING PLAN REVISION 3 0
40 80 SCALE IN FEET o
Coordinate System NAD 1983 StatePlane Oklahoma North FIPS 3501 Feet Preparer:
Reviewer:
Date:
Date:
RLEFAIVRE SWOOD 12/4/2023 12/4/2023 Rev No: 0 Z:\\Clients\\ENS\\CERT\\_ClientInfo\\Sites\\Database\\Geospatial\\Maps & Dwgs\\ArcGIS\\BMCD_Files\\Arcdocs\\2020\\2022 - Decommissioning Plan\\Figure 8-8_BA1 In-process GW Mon Locations 2021 BURNS & McDONNELL ENGINEERING COMPANY, INC.
EXISTING POST-REMEDIATION MONITOR WELL ADDITIONAL POST-REMEDIATION GROUNDWATER MONITORING LOCATION TREATED WATER INJECTION TRENCH GROUNDWATER EXTRACTION TRENCH INJECTION WELL EXTRACTION WELL/SUMP
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MONITOR WELL IN SANDSTONE B M
MONITOR WELL IN ALLUVIUM M
LEGEND
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 & maintenance, 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 concentrations, total treatment volumes, resin status etc.)
with tables and figures, including static and 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 generally includes a summary of the system startup activities and any pertinent information 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 progress, 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 include 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 compared 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 submitted 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 elevation data, and potentiometric surface maps based on groundwater elevation data collected during the third month of system operations; Treatment process water sampling results for the first three months of system operations; Groundwater sampling results for the groundwater 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 operations components such as overall system run time, individual well and trench extraction/injection flow rates, influent and effluent water concentrations, total treatment volumes, resin usage 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 analysis (including depictions of groundwater potentiometric surface maps, groundwater uranium concentration maps, groundwater concentration trend charts, etc.);
Remediation system operational summary (including system operational times; individual and cumulative groundwater recovery, treatment, and injection rates/volumes; water treatment media usage, inventory, and treatment efficiency; influent/effluent water concentration data and trends; etc.);
Treatment material control (resin usage, inventory, 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 Building 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 Section 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 groundwater 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 necessary to carry out decommissioning not previously approved by the Commission.
10 CFR 70.38(g)(3)(vi) description of the 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 remediation 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 remove 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 will 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 Trustee 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 must 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 Final Status Survey Section 8.9 of the D-Plan provides a generic list of materials 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 the RP instrument room (RM 102)
All equipment and furnishings in the RP staff office (RM 104)
The equipment and furnishings in the RP instrument 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, excluding 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 surface 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 operations, 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 exceeding 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 based 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 for unrestricted release. Furnishings, equipment, and materials in these rooms may be left for future users. Conducting and documenting routine surveys throughout operations will circumvent the 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 transformer (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 entire 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 affected 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 applies 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 subsurface 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 circumstances 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 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 - 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 for 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 - Planned 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 agreed that if alpha spectroscopy is used to analyze samples, a value of 2.8 pCi/g total uranium is acceptable for use as the background activity concentration for soil. This value will apply 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 used 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 surface and subsurface material at the Cimarron Site has been demonstrated to comply with NRC Criteria 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 requirements detailed in Section 13.1.3 of the D-Plan and discuss requirements for surveying and sampling 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 below, (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 been exceeded. In addition, soil samples will be methodically collected as summarized in the following RPP Sections:
Section 12.5.2.1, Foreign or Suspect Materials - 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 consistent with the guidance provided in NUREG-5849.
Section 12.5.2.6, Burial Area 1 Remediation Facility Disturbed Area - This section provides the methodology for performing soil sampling 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 conducted both for locations where soil contamination is less than or equal to 30 pCi/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 enrichment, (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 Radiation 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. Section 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 fraction 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 groundwater. Because of the negligible potential mass intake through inhalation, the limiting (bounding) pathway for potential intake of uranium is through consumption of groundwater. Drinking groundwater at the Cimarron Site is explicitly prohibited as it is not potable.
However, the calculated volume of contaminated groundwater 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 (from 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 uranium-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 decommissioning 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 Investigations, 10 CFR 20, Standards for Radiation Protection, 10 CFR 70, Domestic Licensing of Special Nuclear Material, and 10 CFR 71, Packaging and Transportation of Radioactive 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 added 10 CFR 73.67 (in-transit requirements for SNM) and 10 CFR 21.21 (Notification of failure 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 audit 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) Part 20.1101(a) which requires Each licensee shall develop, document, and implement a radiation protection 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 special 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, the 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 safety 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.