ML25162A065
| ML25162A065 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 06/05/2025 |
| From: | Melissa Crawford Environmental Properties Management |
| To: | James Smith Document Control Desk, Office of Nuclear Material Safety and Safeguards, State of OK, Dept of Environmental Quality (DEQ) |
| References | |
| Download: ML25162A065 (1) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 June 5, 2025 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 Unanticipated Design Approval Request
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a request for U. S. Nuclear Regulatory Commission (NRC) and Oklahoma Department of Environmental Quality (DEQ) approval to fund key critical path design and pre-construction activities utilizing Task 5 - Unanticipated Work funding from the 2025 Scope & Budget.
There are key critical path design and pre-construction activities included in the Construction Budget Request (submitted June 5, 2025); EPM believes expediting approval to conduct them will shorten the overall construction duration. These activities include:
Authorizing O6 Environmental LLC (O6) to advance the pre-engineered metal building (PEMB) design to 100% Issue-for-Construction (IFC). Veolia Nuclear Solutions - Federal Services (VNSFS) requires the PEMB 100% IFC package to advance the Western Area Treatment Facility (WATF) design to 100% IFC. Additionally, O6 requires the WTF foundation design to be at 100% IFC before they can begin earthwork at the WTF.
Authorizing O6 to develop a comprehensive critical path method construction schedule that incorporates both their construction tasks and the individual procurement schedules (injection skids, filter skids, vertical blender, resin handling system, ion exchange vessels, and ion exchange skids) and hold pre-construction planning meetings with EPM, Burns & McDonnell, and VNSFS.
Expediting development of this schedule allows O6 to understand what phases of the project include critical path activities, allowing them to efficiently execute their pre-construction efforts (i.e., subcontracting plans, procurement plans, labor and equipment allocations, etc.)
Authorizing VNSFS to contract with their selected vendors to advance the filter skid and vertical blender designs to 100%. Due to long fabrication times (greater than 6 months), expediting the 100% design of the filter skid and vertical blender will allow fabrication to begin shortly after receipt of NRC and DEQ approval of the Construction Budget Request. Doing so would mitigate the risk of the procurement delays extending the construction schedule.
June 5, 2025 Page 2 The 2025 Scope & Budget was submitted to NRC and DEQ on January 22, 2025 and EPM is anticipating approval of this scope and budget by June 13, 2025_. Upon approval of the 2025 Scope & Budget, EPM proposes to utilize the 2025 Scope & Budget Task 5 - Unanticipated Work budget of $71,072 to conduct these activities while the Construction Budget Request is under review. Expenditures associated with the above detailed scope will be allocated equally to the Federal Environmental Cost Account and the State Environmental Cost Account. Because funding for the activities is also included in the construction budget, EPM will reallocate these expenditures against the construction budget once its approved.
Upon NRC and DEQ approval of the 2025 Scope & Budget and approval to utilize Task 5 -
Unanticipated Work to utilize existing approved funding from the 2025 budget, EPM will contract with O6 and VNSFS to complete the activities detailed above. Your expedited approval is requested.
If you have any questions or desire clarification, please call me at 816-652-2784.
Sincerely, Mathew Crawford, Trustee Project Manager cc: (electronic copies only)
Rob Yalen, Office of the United States Attorney for the Southern District of New York Stephanie Anderson and Linda Gersey, NRC Region IV Paul Davis, Lee Dooley, David Cates, and Jonathan Reid, DEQ NRC Public Document Room vcpsubmittals@deq.ok.gov