ML24282A738

NRC - DEQ - EPM Project Status Meeting Notes

ML24282A738
Person / Time
Site:	07000925
Issue date:	09/18/2024
From:	- No Known Affiliation
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
Download: ML24282A738 (1)

Text

NRC - DEQ - EPM Project Status Meeting Notes September 18, 2024 - 2:30 Eastern, 1:30 Central Page 1 of 4 Attendees:

NRC DEQ EPM Jim Smith Paul Davis Jeff Lux Martha Poston-Brown Carol Paden John Hesemann Rachel Miller Matt Crawford Administrative Issues Semi-Annual Projection of Administrative Expenses EPM submitted an update of anticipated future administrative costs in a letter dated August 21, 2024. The letter stated that the proposed budget for 2024 did not include funding for some continuity planning effort and legal support, but that EPM believes that work may be able to be completed without increasing the total Administrative Account budget.

EPM will monitor administrative costs. EPM will notify the NRC and the DEQ if it appears that the approved funding for Task 1 Administration is not adequate and request approval for additional funding if needed.

Re-allocation to Administration and License Compliance Throughout 2024 EPM has been assigning tasks such as document management, monitoring training requirements, and preparing documents for submission to the NRC Electronic Information Exchange to Burns & McDonnell personnel. The result is that Burns & McDonnell is spending more time on Administrative Support and License Compliance Support functions than had been anticipated.

Due to changes in the contracting strategy, Burns & McDonnell anticipates coming in far enough under budget in Decommissioning Support to cover the increased cost for Administrative and License Compliance support.

EPM will monitor costs for Burns & McDonnells Administration, License Compliance, and Decommissioning support. Should it be necessary, EPM will re-allocate money from Burns &

McDonnells Decommissioning budget to cover the increased cost of Administrative or License Compliance support.

Proposed Scope of Work and Budget for 2025 EPM is focusing its attention on responding to requests for information submitted by remediation construction bidders in the hopes that EPM can submit contractor selection evaluations and initial funding authorization requests for design work to be performed by contractors to NRC and DEQ by the end of October 2024.

EPM plans to submit a proposed scope of work and budget for all of 2025, including construction and all routine support, within three weeks following submission of the contractor selection and initial funding authorization requests. This is discussed more fully in Requests for Bids and Limited Notice to Proceed (LNTP) below.

NRC - DEQ - EPM Project Status Meeting Notes September 18, 2024 - 2:30 Eastern, 1:30 Central Page 2 of 4 License Amendment Process Area East of the Burial Area #1 Injection Trench On July 29, 2024, groundwater samples were collected for laboratory from five monitor wells that had not been sampled since 2017 or 2018. The data was received in late August, and on September 9, 2024, EPM submitted updated information on this area. The good news is that all monitor wells east of treated water Injection Trench GWI-BA1-01 yield groundwater containing uranium concentrations that are less than the DCGL; most are below the MCL.

This does not mean that there is no need to inject treated water into GWI-BA1-01. However, it does mean that evaluation of groundwater flow paths once groundwater elevations stabilize during operations may justify decreasing the injection rate. Decreasing the injection rate will minimize the potential for seepage of groundwater to emerge from the surface in this area.

No further action is needed.

OPDES Permit Limits The DEQ Water Quality Division has determined that permit limits will not be required for nitrate and fluoride. Although a permit limit for uranium is not required based on discharge flow rate relative to the Cimarron River low-flow rate, a permit limit will likely be established to ensure that effluent concentrations remain well below NRC effluent limits.

EPM will meet with DEQ Water Quality Division and Land Protection Division to discuss appropriate potential permit limits for uranium.

Environmental Assessment NRC extracted the NHPA section of the EA and put it out for public comment and notified those tribes that have requested to be informed. Comments from the US Fish and Wildlife Service (USFWS) are due before the end of September 2024.

NRC will finalize the Environmental Assessment based on comments received from the USFWS, if any, in October.

Safety Evaluation Report The Safety Evaluation Report has been through technical review and is in concurrence review.

The NRC will provide for EPM review of the SER prior to issuing the amended license.

Particular attention will be paid to the license conditions.

Planning for Decommissioning Contracts and Terms and Conditions for Contractors EPM is reviewing and commenting on draft contractual documents provided by Stinson LLP.

Bidders will be given one or two weeks after EPM sends the final contract documents to submit their bids.

EPM will expedite the production of final contract documents to the extent practicable.

NRC - DEQ - EPM Project Status Meeting Notes September 18, 2024 - 2:30 Eastern, 1:30 Central Page 3 of 4 Requests for Bids EPM has issued requests for Bid (RFBs) to bidders for the General Contractor, the design and fabrication of the Injection Skids, and a Driller. EPM will evaluate bids and conditionally select contractors. EPM will submit:

A description of the evaluation of contractors and the selected contractor, A request for approval of selected contractors, A request to approve the funding needed to advance the design for the pre-engineered metal building (PEMB), the integrated control system, and the injection skids to Issue For Construction (IFC) status, A request to approve the funding needed to abandon monitor wells and install groundwater injection wells.

VNSFS has issued RFBs to bidders for the fabrication, testing, and delivery of:

IX Treatment Skids Filter Skid - this subcontractor will advance the design for the filter skid Resin Vessels Resin Processing System (the mezzanine structure and associated pumps, tanks, and piping)

Vertical Blender - this subcontractor will advance the design for the blender VNSFS will evaluate bids and conditionally select contractors. EPM will submit a request to approve the funding needed to advance the design for the filter skid and the vertical blender to IFC status.

Expediting the advancement of these designs will enable the designs to be completed before mobilization for construction and will reduce the potential for design issues to impact the fabrication and construction schedules. Monitor wells must be abandoned prior to construction, and installing extraction wells prior to mobilization will minimize potential problems connecting extraction wells to the extraction vaults installed by the General Contractor.

EPM hopes to submit the contractor selection evaluations and initial funding authorization requests described above by the end of October.

General Contractor Issue EPM submitted RFBs to four pre-qualified companies. A pre-bid meeting was conducted on August 8, 2024; this meeting included a site walk and discussion on the radiation protection survey requirements that are related to all subsurface excavation, drilling, trenching, etc.

Two of the four contractors have notified EPM that they will decline to bid. The other two contractors decided they can provide the best proposal if they partner together. Consequently, EPM will receive only one bid.

EPM will identify additional Contractors to whom requests for bid can be sent in order to comply with the Trust Agreement require to select contractors based on competitive bidding.

NRC - DEQ - EPM Project Status Meeting Notes September 18, 2024 - 2:30 Eastern, 1:30 Central Page 4 of 4 Limited Notice to Proceed (LNTP)

Upon obtaining approval of contractor selection and funding for design tasks, EPM will issue a LNTP authorizing contractors to advance the designs for the following to IFC status:

1. The PEMB

2. The integrated control system

3. The injection skids

4. The filter skid

5. The vertical blender EPM will also issue a LNTP to the Driller to abandon monitor wells and install groundwater extraction wells.

EPM hopes to issue the LNTP by the end of November 2024.

Full Construction Funding with 2025 Budget EPM hopes to be able to submit a proposed budget for 2025 by Thanksgiving. The proposed budget will include the budget for routine administrative, license compliance, and decommissioning activities as well as fabrication, construction, startup and commissioning of all groundwater remediation facilities and water treatment and resin processing systems.

Note: Bidders will provide +/- 10% cost estimates in their bids. EPM plans to request funding for the + 10% values because approval of the budget and issuance of SNM-928 Amendment 22 will occur several months after bids were submitted. EPM will request Best and Final Price (BAFP) estimates from the selected contractors before executing contracts. If the BAFP estimates exceed approved funding, EPM will monitor costs during construction and request approval for additional funding if it is needed.

Date and Time of Next Teleconference Via Microsoft Teams on October 16, 2024, at 2:30 Eastern, 1:30 Central