ML24107A767
| ML24107A767 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 04/03/2024 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML24107A767 (1) | |
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NRC - DEQ - EPM Telecon Agenda April 3, 2024 - 2:30 Eastern, 1:30 Central Page 1 of 3 Attendees:
NRC DEQ EPM Jim Smith Rachel Miller Jeff Lux Christine Pineda David Cates John Hesemann Lifeng Guo Paul Davis Martha Poston-Brown Administrative Issues Proposed Scope of Work and Budget for 2024 The NRC approved the proposed scope of work (SOW) and budget for 2024 in a letter dated April 2, 2024.
EPM will convert the proposed SOW and budget to a final SOW and budget and submit the approved budget to all beneficiaries of the Trust. EPM plans to execute contracts with Burns
& McDonnell, ENERCON Services, and VNS - Federal Services within a week.
Trust Agreement Section 3.2.5 VNS - Federal Services (VNSFS) prepared the design for all water treatment systems and resin processing systems. Because procurement, installation, and startup are not engineering or architectural services, Section 3.2.5 of the Trust Agreement would require the Trustee to select a contractor by competitive bidding. However, Section 3.2.5 enables the lead agency to grant a waiver from that requirement. EPM submitted a letter to the NRC, the DEQ, and the DOJ requesting that they provide a written waiver to allow EPM to retain VNSFS for procurement, installation, and startup. EPM will require VNSFS to demonstrate that all subcontractors and suppliers are selected via competitive bidding.
The three agencies listed above will confer on whether they should provide the requested waiver.
Status of Work and Submittals NRC Inspection NRC Region IV has scheduled an inspection for April 16 - 17, 2024. The NRC invited DEQ personnel to attend and observe the inspection. This inspection will be conducted when groundwater and surface water samples are collected for the annual environmental monitoring program.
Representatives of EPM, ENERCON Services, and Burns & McDonnell will attend the inspection.
NRC Review of the Responses to RAIs for the Environmental Assessment EPM and Burns & McDonnell environmental assessors provided information on the environmental survey of potential bat roosting trees in areas that will be cleared to install groundwater remediation infrastructure and facilities in a teleconference with the NRC on February 14th. The NRC requested documentation describing the survey.
NRC - DEQ - EPM Telecon Agenda April 3, 2024 - 2:30 Eastern, 1:30 Central Page 2 of 3 Similarly, EPM and Burns & McDonnell environmental assessors discussed the potential impact of the designation of the Cimarron River as a protected habitat for the Arkansas River Shiner and the peppered chub. Although these fish are not present in the river, its designation as a protected habitat requires that impact of the discharge of treated water to the river be evaluated.
Information needed includes the quantity and quality of the water to be discharged, the planned design of the discharge, and the minimum and average flow rates for the Cimarron river.
Reports on both habitat surveys were submitted to the NRC and the DEQ on March 29, 2024. A providing information on the quantity and quality of the water to be discharged, the planned design of the discharge, and the minimum and average flow rate for the Cimarron river is being prepared by Burns & McDonnell.
The NRC and the DEQ will review the documentation on both the bat roosting tree survey and on the discharge to the Cimarron River, and notify EPM if additional information is needed.
NRC Review of Responses to RAIs for the Safety Evaluation Report The NRC expressed a concern that the injection of treated water into Injection Trench GWI-BA1-01 could create a sufficient groundwater mound to create seeps on the ground surface or discharge into a drainage channel east of the injection trench. EPM submitted a letter addressing this concern on February 21, 2024. The letter included a proposal to conduct and document visual observations of the area of concern on a monthly basis during monthly routine radiological surveys.
On March 20, 2024, the NRC informed EPM that the responses were satisfactory.
The DEQ requested a TEAMS meeting to discuss the February 21, 2024, submittal. The TEAMS meeting is scheduled for 11:00 Central Time on April 4, 2024.
EPM will respond to any request for information that is identified during the April 4 TEAMS meeting.
Revision of the Annual Environmental Monitoring Program Section 15 of the Radiation Protection Plan describes the environmental monitoring program, which includes the collection of groundwater and surface water samples on an annual basis for analysis of gross alpha and beta, isotopic uranium concentrations, nitrate, and fluoride. Analysis for gross alpha and beta is no longer relevant. Nitrate and fluoride arent present in Burial Area
- 1 (where half of the samples are collected); so analysis for these parameters is only meaningful in the western areas. Because analyzing samples for isotopic uranium mass concentration provides all the data we need to decommission the site, there is no longer a need to analyze samples for both activity concentration and mass concentration.
If EPM could discontinue analyzing samples for gross alpha and beta and isotopic uranium activity concentration from all samples site-wide, and discontinue analysis for nitrate and fluoride for samples collected in Burial Area #1, the cost of laboratory analysis will drop from approximately $15,000 to less than $4,000. EPM submitted a request to modify the annual environmental monitoring program to the NRC and the DEQ in a letter dated March 1, 2024.
NRC - DEQ - EPM Telecon Agenda April 3, 2024 - 2:30 Eastern, 1:30 Central Page 3 of 3 After discussion with Jim Smith, EPM agreed that this change could be made in accordance with license condition 27(e); that addresses the issues from a radiation protection standpoint. But feedback from the DEQ is still desired, particularly as it relates to the non-radiological analyses for nitrate and fluoride.
EPM will prepare a 27(e) evaluation to authorize these changes. The DEQ will provide feedback on the proposed changes.
Date and Time of Next Teleconference May 15, 2024, at 2:30 Eastern, 1:30 Central