ML24213A252
| ML24213A252 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 07/24/2024 |
| From: | - No Known Affiliation |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| Download: ML24213A252 (1) | |
Text
NRC - DEQ - EPM Project Status Meeting Notes July 24, 2024 - 2:30 Eastern, 1:30 Central Page 1 of 4 Attendees:
NRC DEQ EPM Jim Smith Paul Davis Jeff Lux Lifeng Guo Jon Reid Matt Crawford Stephanie Anderson Rachel Miller John Hesemann Lee Dooley David Cates Administrative Issues Continuity Planning EPM has been conducting biweekly meetings to plan and document succession planning. Jeff Lux has generated documents to capture institutional knowledge, such as the history of decommissioning activities at the site, issues related to surface and subsurface soil in Subarea F, the impact of decommissioning under the SDMP instead of the LTR, and the reason for repeated revision of the decommissioning plan. He has also conducted training on technical/radiological aspects of decommissioning and is preparing a document listing recurring administrative, legal/financial, managerial, and technical/regulatory actions to assist a successor in maintaining an uninterrupted flow of operations.
EPM will continue to prepare for upcoming transfer of Trustee Project Manager responsibilities.
Semi-Annual Projection of Administrative Expenses Section 2.4.5 of the Cimarron Trust Agreement states that the Cimarron Trustee shall provide the NRC and the State of Oklahoma with an update of anticipated future Administrative Costs of the Cimarron Trust. The proposed budget for 2024 included $10,000 for legal support in Budget Task 1 - Administration. Retaining Stinson LLP to assist EPM in the development of contracts and contractual terms and conditions for construction will require significantly more than $10,000.
It appears that the continuity planning process described above requires more time than had been anticipated.
EPM will submit an update of anticipated future administrative costs to the NRC and the DEQ near the end of July. EPM will monitor administrative costs and will notify the NRC and the DEQ if it appears that the approved funding for Task 1 Administration may not be adequate.
Q2 2024 Financial Statement The financial statement for the 2nd quarter and year-to-date for 2024 will be submitted to the NRC and the DEQ by the end of July.
Insurance for Facilities On July 9, 2024, the Department of Justice sent an email stating, the United States hereby directs (jointly with Oklahoma) that the Cimarron Trustee investigate the possible purchase of an insurance policy to cover future Environmental Actions and general liability at the Cimarron Site.
NRC - DEQ - EPM Project Status Meeting Notes July 24, 2024 - 2:30 Eastern, 1:30 Central Page 2 of 4 EPM will investigate the availability and cost to insure the water treatment facilities and the potential requirements that obtaining such insurance would impose upon the Trust.
Status of Work and Submittals Environmental Assessment EPM commented on the NRCs Draft Environmental Assessment report in a letter dated July 3, 2024.
The NRC requested a figure similar to Figures 6-2 and 6-3 in the decommissioning plan, showing the proposed license area in a site-wide figure. Figure 6-4, depicting the entire proposed licensed area, was submitted to the NRC as an addendum to the decommissioning plan.
The NRC also requested an updated map showing wetland areas identified during the recent wetland delineation effort.
The site-wide map showing the updated wetland areas was submitted to the NRC via Microsoft Office file share on July 24,2024. NRC will finalize the Environmental Assessment report after receiving feedback from the DEQ and the Fish and Wildlife Service.
Annual Environmental Monitoring Program Water samples were collected from 29 monitor wells and 2 surface water locations the week of April 15 - 19, 2024. All samples were analyzed for isotopic uranium mass concentration.
Samples collected from the monitor wells in western areas and both surface water samples were also analyzed for nitrate and fluoride. Reducing the analytes to those needed resulted in an analytical cost of less than $5,000, compared to $15,000 for the previous list of analytes.
The tabulated data from that sampling event was submitted to the NRC and the DEQ on July 3, 2024. Data from this sampling event has been imported to the Trusts EQuIS database, but exporting a revised Comprehensive Analytical Data spreadsheet will be deferred until after data from the BA1 sampling event has been imported.
No further action is needed. EPM will submit an updated Comprehensive Analytical Data spreadsheet after data from the upcoming BA1 sampling event after the data has been reviewed and imported into the Trusts EQuIS database.
Additional Information for Area East of BA1 Injection Trench EPM submitted a letter addressing the potential for surface water seepage due to injection of treated water in GETR-BA1-01 on February 21, 2024. The letter included tabulated data and a figure showing the concentration of uranium in groundwater in this area. The letter also 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 met with EPM on April 4, 2024, to discuss the February 21 letter, and two issues were identified:
NRC - DEQ - EPM Project Status Meeting Notes July 24, 2024 - 2:30 Eastern, 1:30 Central Page 3 of 4
- 1. The Comprehensive Analytical Data spreadsheet used to tabulate the data was missing some data for uranium in groundwater in this area.
- 2. There was no recent (within the past 7 years) data for some of the locations shown in the Figure.
In addition, EPM attempted to conduct a visual survey of the area, and discovered that the wooded area has become so thick with underbrush that visual observation for seepage isnt currently practical.
In a letter dated May 7, 2024, the DEQ proposed the collection and analysis of groundwater samples to establish a baseline concentration for uranium before trench operations.
EPM submitted additional information, including data for locations not included in the February 21 letter and revised figure presenting data in the area, on July 9, 2024.
Groundwater samples will be collected from the five additional monitor wells on July 31st.
Once that data has been imported into the EQuIS database, an updated Comprehensive Analytical Data spreadsheet will be submitted to the NRC and the DEQ.
U-235 Enrichment in Environmental Media In reviewing Section 6 of the decommissioning plan, the NRC noted text that stated that environmental media do not contain uranium exceeding 5% enrichment. On May 23, the NRC asked if there is a document that states or implies that (other than the decommissioning plan), or if that assertion comes from final status surveys. On May 28, 2024, EPM provided information on the basis for that assertion. DEQ responded in a letter dated July 10, 2024, saying it looks forward to NRCs response. The NRC said that the response was accepted, and that a formal response will consist of reference to that document in the Safety Evaluation Report.
No further action is needed.
Requests for Bid EPM anticipates receiving request for bid packages for review by the end of July; we are a week or two behind schedule.
Burns & McDonnell is assisting EPM in preparing requests for bid for:
General Contracting for the bulk of site construction work Abandoning and installing monitor wells and installing extraction wells Designing, fabricating, and delivering injection systems Veolia is assisting EPM in preparing requests for bid for the procurement, testing, and delivery of:
Filter skid Ion exchange vessels Ion exchange skids Resin processing mezzanine
NRC - DEQ - EPM Project Status Meeting Notes July 24, 2024 - 2:30 Eastern, 1:30 Central Page 4 of 4 Resin blending system Numerous tanks Pumps Safety Evaluation Report The Safety Evaluation Report is nearly complete. There are several issues that need to be addressed from a legal/regulatory perspective. One example is the status of Subareas G and N, which the NRC concurs are releasable for unrestricted use, but which the 2011 License Transfer Order states should not be released until groundwater remediation is complete. Redefining the licensed area as proposed in Section 6 of the decommissioning plan would result in the release of large portions of Subareas G and N.
NRC will finalize the Safety Evaluation Report when these issues have been resolved.
Wetland Delineation The last time a wetland survey was conducted to determine if the construction of proposed groundwater remediation infrastructure would impact wetlands was in 2015. Burns &
McDonnell conducted a wetland delineation at the site on May 8-9, 2024. The NRC requested an updated wetlands map that would replace the map provided in response to requests for additional information related to the EA.
EPM will submit the updated wetlands report to the NRC and the DEQ by the end of the month.
Date and Time of Next Teleconference Via Microsoft Teams on August 21, 2024, at 2:30 Eastern, 1:30 Central