ML22095A152

Follow Up Email Regarding Public Meeting Notice Regarding Discussions of pre-application Audit Meeting, March 10, 2022, Containing Emails Between Jlux and Jsaxon Dated April 5, 2022 Regarding RAI 11 Clarification

ML22095A152
Person / Time
Site:	07000925
Issue date:	04/05/2022
From:	Lux J Environmental Properties Management
To:	Saxton J NRC/NMSS/DDUWP/URMDB
Smith J
References
Download: ML22095A152 (3)

Text

From: Lux, Jeff J To: Saxton, John

Subject:

[External_Sender] RE: RAI 11 Clarification Date: Tuesday, April 5, 2022 9:56:51 AM Attachments:

Excellent response, John! I think I was running around in mental circles, trying to find the wrong document, and the detail you provided below really helped me understand better.

Since 2018, groundwater extraction has been removed from the WAA-WEST, WAA-EAST, and WAA-BLUFF remediation areas, and we added a second extraction trench in the BA1 transition zone. Now we are committing to add treated water injection between the two BA1 extraction trenches, and we anticipate extracting more of the BA1 groundwater from the transition zone than we had planned on even in the draft Rev 3.

Because of these changes, Im asking Enercon to revisit the calculations in the 2017 spreadsheet (regarding enrichment) and Burns & McDonnell to revisit the basis of design (regarding influent concentrations). I anticipate replacing that 2017 document with a revised version when we formally submit D-Plan Rev 3.

Jeff Lux, P.E.

Project Manager Environmental Properties Management LLC A Subsidiary of Burns & McDonnell Engineering Company, Inc.

405-642-5152 From: Saxton, John <John.Saxton@nrc.gov>

Sent: Tuesday, April 5, 2022 6:13 AM To: Lux, Jeff J <jlux@burnsmcd.com>

Cc: Smith, James <james.smith@nrc.gov>

Subject:

RAI 11 Clarification Youve requested clarification on the comment in RSI-11 of the January 31, 2022, email (ML22031A175). Specifically, you could not identify a discrepancy.

The discrepancy is as follows:

On PDF Page 66 of 197, the Basis of Design memorandum states Remediation Goals The Nuclear Regulatory Commission (NRC) uranium remediation goal (i.e., the DCGL) of 180 picoCuries per liter (pCi/L) applies to all Remediation Areas at the site; however, the equivalent DCGL mass concentration varies across the Site as the Uranium 235 enrichment varies. DCGL mass concentration equivalent calculations and results are contained within an MS Excel workbook entitled Uranium Activity vs. Mass Concentration_Rev. A (07-30-18).xlsx. (color emphasis added)

The Basis of Design also includes the following statement and table:

An entry found in your excel listing of ADAMS submitted documents that was provided to the NRC is found for the following document:

The date for that document is listed approximately 1 month prior to the document listed in the Remediation goals (see red highlighted text above); however, no document exists in ADAMS with a July 30, 2018 date.

In any event, that document includes calculations for three areas.

For BA3:

For BA1:

For WAA U>DCGL

None of the three calculated values listed in that document match those listed in the Basis of Design; hence the discrepancy, i.e., 212.34 ug/L v. 201 ug/L for BA1, and ,131.34 ug/L 115.78 ug/L, or average or . v. 119 ug/L for the western area.

The RSI asked if the July 30, 2018, document exists, which is probably an update to the June 29, 2018, document, and provide it to NRC.