ML20247J557

Environmental Properties Management, LLC - Proposed Scope of Work and Budget for Decommissioning Plan Revision

ML20247J557
Person / Time
Site:	07000925
Issue date:	08/28/2020
From:	Lux J Environmental Properties Management
To:	Davis P, Robert Evans, James Smith Document Control Desk, Office of Nuclear Material Safety and Safeguards, NRC Region 4, State of OK, Dept of Environmental Quality (DEQ)
References
Download: ML20247J557 (8)

Text

August 28, 2020 Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Paul Davis Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101 Mr. Robert Evans U.S. Nuclear Regulatory Commission 1600 East Lamar Blvd; Suite 400 Arlington, TX 76011-4511 Re: Docket No. 070-00925; License No. SNM-928 Proposed Scope of Work and Budget for Decommissioning Plan Revision

Dear Sirs:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a proposed scope of work and cost estimate to obtain approval to proceed with a revision of the Facility Decommissioning Plan.

The Decommissioning Cost Estimate that was provided in the November 2018 Facility Decommissioning Plan - Rev 1 (the DP) indicated that sufficient funds were available in Trust accounts to achieve license termination.

Since November 2018, advancing the design to the 90% design stage resulted in numerous changes to the design of the water treatment facility, and to a lesser extent the groundwater extraction, injection, and discharge infrastructure. In addition, the schedule for approval of the DP has been extended significantly and the US Nuclear Regulatory Commission (NRC) advised the Trustee that the annual amount for the NRCs full cost recovery would increase significantly from the previous estimated costs.

In March 2020, Range of Magnitude (ROM) cost estimates for achieving license termination were generated when evaluating the potential impact of Tc-99 to the cost of disposing biomass generated by the biodenitrification nitrate treatment system. The ROM cost estimate to achieve license termination was significantly greater than the funding available to the Trust. The ROM cost estimate did not include the cost of changes to the water treatment facility and groundwater extraction, injection, and discharge infrastructure, or the cost to dispose of biomass.

9400 Ward Parkway

• Kansas City, MO 64114 Tel: 405-642-5152

• jlux@envpm.com

Mr. James Smith U.S. Nuclear Regulatory Commission August 28, 2020 Page 2 The highest priority objective of the Trust is to achieve termination of the NRC license. To achieve license termination, the concentration of uranium in groundwater must be less than the derived concentration goal level (DCGL) of 180 picocuries per liter (pCi/L) in every monitor well. To accomplish this with the available funding, the Oklahoma Department of Environmental Quality (DEQ) has promoted the elimination of the biodenitrification system and as much infrastructure as reasonably possible without adversely impacting the Trusts ability to achieve license termination.

EPM and the DEQ discussed the possibility of implementing a phased approach to site remediation. Phase I would consist of the construction and operation of only those groundwater extraction, injection, and discharge components, and water treatment and waste processing systems that are required to reduce the uranium groundwater concentration below the DCGL in areas where concentrations exceed the DCGL. Groundwater extraction, injection, treatment and discharge components not necessary for addressing groundwater exceeding the DCGL will not be installed until and if Phase II is implemented. A general description of the revised path forward for both phases (Phase I and Phase II) of the phased remediation approach are provided below.

Phased Remediation Concept: Phase I - Remediate Groundwater Exceeding the DCGL

1) Groundwater will only be extracted from wells and trenches that recover groundwater from areas with uranium concentrations exceeding the DCGL.

2) Western Area (WA) groundwater will be pumped to a dedicated influent tank located in the Western Area Treatment Facility (WATF) for treatment via a dedicated uranium ion exchange (UIX) skid.

3) A portion of the effluent from the WA UIX skid will be routed to an injection skid; the rest of the WA treated water will be pumped to the single effluent tank.

4) The biodenitrification and biomass processing systems will not be installed in the WATF.

5) Groundwater recovered from Burial Area #1 (BA1) will be pumped from the BA1 influent tank to a dedicated influent tank located in the WATF.

6) Water will be pumped from the BA1 influent tank located in the WATF through a dedicated UIX skid for treatment.

7) A portion of the BA1 UIX skid effluent will be pumped back to BA1 to what was previously identified as the BA1 effluent tank (now the BA1 injection tank). The rest of the treated BA1 water will be pumped to the single effluent tank located in the WATF.

8) The combined WA and BA1 treated water will be discharged from the WATF effluent tank to the Cimarron River via Outfall 001.

9) Groundwater will be extracted from the WAA U>DCGL and 1206-NORTH remediation areas such that:

Mr. James Smith U.S. Nuclear Regulatory Commission August 28, 2020 Page 3 a) Extraction will achieve capture of the uranium plume located in the U>DCGL remediation area.

b) Water injected in the Western Upland Burial Area #3 (WU-BA3) remediation area, and groundwater displaced by this injection process, will be captured.

c) Compliance with the DCGL will be achieved in all western area wells before DCGL compliance is achieved in BA1.

d) The nitrate concentration in water discharged to Outfall 001 will be less than 30 milligrams per liter (mg/L).

To the extent reasonable, the remediation system design will remain unchanged from what was submitted in the November 2018 DP to address the installation of Phase II groundwater remediation infrastructure in the future should sufficient funding be available or additional funding be received from another Tronox Trust. The installation of these components would facilitate a return to a treat all areas for all constituents of concern (COCs) remediation strategy.

A process flow diagram for Phase I of the remediation approach is provided as Attachment 1 to this letter.

Phased Remediation Concept: Phase II - Expand Groundwater Remediation The endpoint for Phase I remediation occurs when all wells in areas in which uranium currently exceeds the DCGL yield uranium concentrations less than the DCGL. Phase II will begin with an evaluation of the cost of post-remediation activities, including groundwater monitoring, decontamination and demobilization, final status surveys, and license termination. If remaining funding only provides for post-remediation activities, groundwater remediation will cease.

If sufficient funding remains, operation of Phase I groundwater extraction, treatment, and injection systems may continue. Alternatively, Phase II may include the expansion of the remediation program to address other areas or COCs. It is likely this would require an infusion of additional funding. Phase II could consist of additional remediation efforts ranging from incremental expansion to construction and operation of all systems presented in the current DP.

During the August 19, 2020 Cimarron status teleconference, how to proceed toward a phased remediation approach without the expenditure of unnecessary funds and unnecessary schedule extension was discussed. The decision was made to submit a second revision of the decommissioning plan if it is first determined that a phased approach could enable the Trust to achieve license termination with available funding.

Scope of Work - Feasibility of Phased Approach The following activities must be completed to determine if the Trust can achieve license termination with available funding:

Mr. James Smith U.S. Nuclear Regulatory Commission August 28, 2020 Page 4

1) Hydrological Evaluation - Reducing the groundwater extracted from the WA as described in

1. 9 above will change the extent of the zone of capture and may result in the extraction of higher-nitrate groundwater located east of the WAA U>DCGL remediation area. Revision of the existing groundwater flow models is needed to determine if satisfying the criteria stipulated in #9 above is achievable. If so,

2) Decommissioning Cost Estimate (DCE) Preparation - A full DCE that includes changes made when design drawings were advanced from 60% to 90% design must be prepared. If the DCE indicates that available funding is sufficient to achieve license determination, then revision of the decommissioning plan will be performed. Some preliminary design work will need to be done to generate the cost estimate, so the cost to prepare the DCE cannot be separated from the cost to revise the decommissioning plan.

Scope of Work - Revised Decommissioning Plan Generation of Facility Decommissioning Plan - Rev 4 (the DP) will consist of:

1) SP Section 5.6.13, Permits, will be revised to reflect the change from two discharge outfalls to one outfall during Phase I operations.

2) DP Section 8, Planned Decommissioning Activities, (and related figures) will provide additional information describing the installation of groundwater extraction and treatment systems and treated water injection and discharge systems that will be installed during Phase I. It will also present a revised in-process monitoring program for Phase I. The complete set of groundwater extraction infrastructure, treatment systems, and injection and discharge components and in-process and post-remediation monitoring programs will not be removed from the DP, so that installation of all infrastructure and programs are already defined if funding is sufficient to expand to other areas.

3) DP Section 9, Schedule, will provide additional information on the duration of remediation as a result of implementing Phase I operations. The schedule that assumes post-remediation monitoring and license termination will follow Phase I operations will replace the schedule that was in the 2018 Facility Decommissioning Plan - Rev 1.

4) Section 11, Radiation Protection Program, of the DP will be reviewed. It is assumed that the implementation of Phase I will not result in revision of the radiation protection program, but if so, the text in Section 11 (and Appendix N, the Radiation Protection Plan) will be revised accordingly.

5) Section 12, Environmental Monitoring and Control, will be reviewed. In-process and post-remediation monitoring are addressed in Section 8, so revision of Section 12 may not be necessary, but if so, revisions to the text will be made.

Mr. James Smith U.S. Nuclear Regulatory Commission August 28, 2020 Page 5

6) Section 14, Quality Assurance, will be reviewed. Revision of Section 14 may not be necessary, but if so, revisions to the text (and Appendix O, the Quality Assurance Program Plan) will be made.

7) Section 15, Facility Radiation Surveys, will be reviewed. Revision of Section 14 may not be necessary, but if so, revisions to the text to address the radiological survey of sediment from the 1206 drainage will be made.

8) Section 16, Financial Assurance, will be revised. The DCE that assumes post-remediation monitoring and license termination will follow Phase I operations will replace the DCE that was in the 2018 Facility Decommissioning Plan - Rev 1.

9) Design drawings will be added to Appendix J, Remediation Infrastructure Design Drawings, and Appendix K, Groundwater Treatment System Design Drawings, to depict the groundwater extraction and treatment, and treated water injection and discharge systems that will be installed during Phase I operations.

Cost Estimate Hydrological Evaluation Burns & McDonnell Engineering Company $55,000.00 DP Revision Burns & McDonnell Engineering Company $110,000.00 DP Revision Veolia Nuclear Solutions - Federal Services $180,000.00 DP Revision Enercon Services $40,000.00 The current 2020 approved scope of work and budget for Burns & McDonnell Engineering Company (Burns & McDonnell) includes $136,000 for responding to Agency RAIs and revisions to the DP, and $318,000 for advancing design of control systems and updating the 90%

design. Because RAIs will not be issued until well into 2021, responding to RAIs and advancing control system design and 90% design drawings cannot be completed within the time frame provided for in the approved scope of work and budget. Consequently, no additional funding is needed in 2020 for Burns & McDonnell to complete their revised scope of work.

The current approved scope of work and budget for Veolia Nuclear Solutions - Federal Services (VNSFS) includes $312,000 for responding to Agency RAIs, and $419,000 for advancing design of control systems and updating the 90% design. Because RAIs will not be issued until well into 2021, responding to RAIs and advancing control system design and 90% design drawings cannot be completed within the time frame provided for in the approved scope of work and budget.

Consequently, no additional funding is needed in 2020 for VNSFS to complete their scope of work.

The approved scope of work and budget for Enercon Services (Enercon) includes $53,000 for license compliance support, a portion of which is for revision of the DP. Funding is not sufficient to complete the scope of work listed above. EPM proposes to transfer excess 2020

Mr. James Smith U.S. Nuclear Regulatory Commission August 28, 2020 Page 6 budget funding from VNSFS or Burns & McDonnell (for work which must be deferred due to the time required to revise the DP) to fund Enercons scope of work.

Schedule The following milestone schedule is based on NRC and DEQ approval of the above described scope of work and funding by October 2, 2020:

Hydrological evaluation complete by November 26, 2020 Decommissioning schedule and cost estimate complete by December 31, 2020 Facility Decommissioning Plan - Rev 2 submitted by January 31, 2021 This is an aggressive schedule, because EPM has emphasized to its contractors that NRC cannot complete the technical review of the decommissioning plan and issue its request for additional information without this submittal - it is critical path. We will strive to meet this schedule.

EPM requests the NRC and the DEQ to approve the above-described scope of work and the re-allocation of funding from activities that had been planned for 2020 to this scope of work. If either the hydrogeological evaluation or the decommissioning cost estimate indicate that available funding is not sufficient to achieve license termination, EPM will propose to complete the revision of the DP as described above, because potential to achieve license termination will still be much greater with a phased approach to groundwater remediation.

The revised DP will include all the revisions submitted in response to requests for supplemental information, as well as the above-described revisions. Except for schedule and cost information, which will be replaced with the schedule and cost for Phase I, none of the infrastructure or operations of what may be installed for Phase II will have been removed from the DP. It is our understanding that there will therefore be no need to another acceptance review, and the NRC can proceed with the technical review of the DP upon receipt of the entire package.

Please call me at (405) 642-5152 or e-mail me at jlux@envpm.com if you desire clarification or if additional information is needed for approval of the requested scope of work and re-allocation of funding.

Sincerely, Jeff Lux, P.E.

Trustee Project Manager Attachment - Generic Process Flow Diagram - Phase I Remediation

ATTACHMENT 1 GENERIC PROCESS FLOW DIAGRAM - PHASE I REMEDIATION

Generic Process Flow Diagram - Phase I Remediation