ML24345A150
| ML24345A150 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 11/20/2024 |
| From: | Environmental Properties Management |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| Download: ML24345A150 (1) | |
Text
NRC - DEQ - EPM Project Status Meeting Notes November 20, 2024 - 2:30 Eastern, 1:30 Central Page 1 of 4 Attendees:
NRC DEQ EPM Jim Smith Paul Davis Jeff Lux Courtney Redmond Lee Dooley John Hesemann Christine Pineda Rachel Miller Matt Crawford Lifeng Guo Carol Paden Penn Mouluh Jon Reid David Cates Administrative Issues Continuity Planning Matt Crawford continues to work with Jeff Lux in transferring institutional knowledge of the Cimarron Environmental Response Trust and is on schedule to formally take over as Trustee Project Manager (PM) on January 1, 2025.
In December, Matt will officially relinquish his role as Burns & McDonnell Project manager and focus his efforts on his transition to Trustee PM.
Proposed Scope of Work and Budget for 2025 Environmental Properties Management, LLC (EPM) is actively working on developing the Scope of Work and Budget for 2025 and finalization is pending evaluation of the General Contractor (GC) bid and procurement vendor bids (detailed below).
EPM intends to submit one budget package for Agency review. The package will include:
- An evaluation of bids and vendor selection for GC, injection skid design and fabrication, and abandonment and installation of wells.
- A request for Lead Agency approval of vendor selections.
- A proposed scope of work and budget for all of 2025, including construction and administrative and license compliance support.
EPM intends to submit this budget package by December 31; however, the process of evaluating and selecting the GC and procurement venders may not be complete in time for a 2024 submission. In that event, EPM will submit a proposed scope of work and budget for administrative, license compliance, and decommissioning support not including fabrication and construction by December 31 and then submit a separate construction budget package in early January.
EPM will also be submitting by December 31, 2024 a Notification per Trust Agreement Section 3.2.4 that contractual and other obligations are projected to exhaust 25% of the Cimarron Federal Environmental Cost Account in 2025.
Status of Work/Submittals Permitting
- Oklahoma Pollutant Discharge Elimination System (OPDES) Industrial Permit - Per Oklahoma Department of Environmental Qualitys (DEQ) October 11, 2024 letter, DEQ
NRC - DEQ - EPM Project Status Meeting Notes November 20, 2024 - 2:30 Eastern, 1:30 Central Page 2 of 4 has indicated that there will be no limits for nitrate, fluoride, or Tc-99 and that the uranium limit will be no lower than 30 micrograms per liter (µg/l), and no higher than 100 µg/L.
At the request of DEQ, EPM will finalize an evaluation of how uranium limits of 30, 50, 75, and 100 mg/L will affect treatment time and the Decommissioning Cost Estimate and provide that to DEQ in early 2025. Following a meeting with DEQ to discuss the findings, EPM will submit the OPDES permit application.
- Stormwater Pollution Prevention Plan (SWP3) & Notice of Intent (NOI) - The SWP3 &
NOI are in final review and will be submitted upon selection of the General Contractor.
- Logan County Flood Plain Permit - The permit application is in final review and will be submitted in early December.
- Nationwide Permit #7 - the permit application is in final review and will be submitted in early December.
- Underground Injection Control (UIC) - David Cates (DEQ) confirmed that the proposed injection trenches/wells are classified as Class 5 wells which are permitted by rule. As a result, EPM will need to submit a modification to the well inventory submitted in 2016.
This modification will identify existing injection trenches (installed for pilot testing) that will be and will not be used, as well as those that will be constructed for full-scale remediation. Additionally, EPM will provide a revised estimate for the nitrate concentrations expected in the water (approximately 40 mg/L) to be injected in the Burial Area 3 injection trench, along with an explanation regarding why this concentration should be considered acceptable.
EPM will prepare and submit the request for approval and associated well inventory in early 2025.
Christine Pineda indicated that the Environmental Assessment (EA) would be revised to state that the injections trenches/wells proposed in Decommissioning Plan - Rev 3 will be operated in accordance with DEQ UIC regulations which state that the injection trenches/wells are permitted by rule. Additionally, Christine indicated that the EA was in legal review, and she anticipated it being uploaded to the Agencywide Documents Access and Management System on November 29, 2024.
Obtaining Bids for Remediation EPM has encountered challenges obtaining bids for the remedial construction effort due to limited interest in the GC role, as well as the development of terms & conditions for contracts related to the remedial construction effort requiring more time and effort than expected.
- General Contractor - EPM submitted requests for bid to seven companies. All but two informed EPM that they were declining to bid, and those two combined to submit a single
NRC - DEQ - EPM Project Status Meeting Notes November 20, 2024 - 2:30 Eastern, 1:30 Central Page 3 of 4 bid - from O6 Environmental. EPM is in the process of evaluating the bid and is striving to complete the evaluation to request Lead Agency approval of O6 in December.
- VNSFS - VNSFS has received bids from their vendors and are awaiting final terms &
conditions before they can issue their contractor selection package. EPM anticipates finalizing terms and conditions this month and VNSFS to provide their bids in December.
- Injection Skid - Injection Skid vendors have their bids prepared and are awaiting final contract terms before they submit their bids. EPM anticipates sending the terms to the vendors this month and receiving bids in December.
- Driller - The driller RFB is complete and submittal to drilling contractors is pending final contract terms. EPM expects to submit RFBs to drilling contractors along with the terms
& conditions this month and will receive bids in December.
Construction Status EPM received O6 Environmental s bid on November 15th. Due to the development of contract terms for VNSFS procurements requiring more time than anticipated, the bidding process has been extended into December. EPM is working diligently to obtain and evaluate all bids and submit the construction cost estimate and bidder selection letter by the end of 2024.
VNSFS has indicated that the procurement schedules for the IX vessels, IX treatment skids, filter skids, vertical blender, and resin processing system extend further than originally anticipated. As a result, procurement of these items could become critical path. VNSFS can advance the design for the resign handling system, IX vessels, and the IX skids to 100% Issue for Construction (IFC) based on comments and Requests for Information theyve received from the procurement vendors utilizing their approved scope of work and budget; however, VNSFS requires the vertical blender design to advance the resin handling design to 100% IFC. VNSFS is underbudget on their 2024 scope of work, therefore EPM will request that a portion of the remaining VNSFS decommissioning budget be reallocated to advancing the design of the vertical blender and filter skids to expedite those procurements and the advancement of the resin handling design to 100% IFC.
EPM will expedite the process of vendor selection and budget preparation to the extent possible.
Status of Amended License The NRC anticipates issuing a draft amended license before the end of November and plans to issue the final amended license before the end of 2024.
Jim Smith indicated that the NRC will not be able to provide a draft copy of the Safety Evaluation Report (SER) prior to issuing the amended license; however, he indicated that the SER had already been through Office of General Counsel review and was currently in management review. While a draft copy of the SER could not be provided, Jim was able to provide Jeff Lux a draft copy of the amended license which was prepared in part based on the findings of the SER. Jeff reviewed the draft copy and provided Jim comments which Jim indicated he was working to address. Jim indicated that the NRC still intends to issue the amended license in 2024.
NRC - DEQ - EPM Project Status Meeting Notes November 20, 2024 - 2:30 Eastern, 1:30 Central Page 4 of 4 EPM will review the draft amended license (revised to address EPMs initial comments) upon receipt.
Date and Time of Next Teleconference Via Microsoft Teams on December 18, 2024, at 2:30 Eastern, 1:30 Central