ML020360485

Regulatory Treatment of Uranium-Contaminated Ground Water Plume in Subareas F and C of the Cimarron Site

ML020360485
Person / Time
Site:	07000925
Issue date:	02/05/2002
From:	Kenneth Kalman NRC/NMSS/DWM
To:	Lux J Cimarron Corp
References
-RFPFR
Download: ML020360485 (5)

Text

February 5, 2002 Mr. Jeff Lux, Manager Planning and Regulatory Compliance Cimarron Corporation P.O. Box 315 Crescent, OK 73028

SUBJECT:

REGULATORY TREATMENT OF URANIUM-CONTAMINATED GROUNDWATER PLUME IN SUBAREAS F AND C OF THE CIMARRON SITE

Dear Mr. Lux:

I am sending this letter regarding the Cimarron site pursuant to: (1) the Cimarron pathway analysis submitted on May 3, 2001; (2) the September 20, 2001, biweekly telephone conference between Cimarron and U.S. Nuclear Regulatory Commission (NRC) staff and; (3) our December 11, 2001 telephone conference. All three of these items pertain to the uranium-contaminated groundwater plume emanating from Subarea F, which is still under your license, into Subarea C, which has been released from your license.

May 3, 2001, Pathway Analysis The NRC staff reviewed your dose assessment for human consumption of cattle and deer meat raised in the vicinity of Subareas F and C. Because of the low dose (0.02 mrem/yr) for these pathways, there is no need to take specific action to restrict access to these pathways. The threshold for taking immediate action to restrict access to a pathway is 100 mrem/yr.

Cimarron staff have advised us that Cimarron Corporation still owns the subareas that NRC has released from its license for unrestricted use and is no longer allowing cattle to graze on Cimarron property. We also understand that Cimarron Corporation intends to maintain control over the Cimarron property until its license has been terminated. The NRC considers this a prudent approach in light of the discovery of a groundwater plume in Subareas F and C.

Please advise us in writing, immediately, if you transfer control of any portion of the Cimarron site to another person, or if others resume non-licensed activities at the site (such as cattle grazing or hunting) before the license is terminated.

September 20, 2001, Telephone Conference During the September 20, 2001, telephone conference, Cimarron staff requested written documentation regarding the NRC staffs position as to the regulatory treatment of the uranium-contaminated plume which emanates from a subarea of the site that is still under license to a subarea that has been released from license. The NRC staff has considered the regulatory issues regarding the groundwater plume and determined that it should be remediated under Site Decommissioning Management Plan (SDMP) criteria. However, the total uranium

Mr. J. Lux 2 concentration for groundwater in this plume will be subject to the 180 picocuries per liter release criteria, pursuant to License Condition 27(b) of your license (SNM-928).

December 11, 2001, Telephone Conference During our December 11, 2001, telephone conference, NRC and Cimarron staff agreed that additional characterization of the groundwater plume is needed before developing a groundwater remediation plan. We also discussed the advisability of Cimarron submitting a groundwater evaluation workplan to NRC. As I noted, this workplan should also include a schedule that would cover such activities as, characterization, decision on groundwater remediation approach, and groundwater remediation implementation.

As I have noted in several previous telephone conferences with Cimarron staff and with you during our December 11, 2001, telephone conference, although decommissioning of the Cimarron site has been grand fathered under SDMP criteria, which are concentration-based, the NRC is mindful of the potential doses to the public from licensed sites being released for unrestricted use, including those being released under the SDMP criteria. Therefore, the Commission has directed the NRC staff to perform a dose assessment before recommending license termination. The Commission has directed that this dose assessment reflect contributions from the entire original site, including subareas previously released. Therefore, you may consider performing your own dose assessment for the site before requesting license termination.

If you have any questions regarding this letter, please contact me at (301) 415-6664 or by e-mail at KLK@NRC.GOV.

Sincerely,

/RA/

Ken Kalman, Environmental Scientist Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No.70-925 License No. SNM-928 cc: Cimarron distribution list

Cimarron Corporation Distribution List - Letter dated ___________

Karen Morgan Cimarron Corporation P.O. Box 315 Crescent, OK 73028 Mike Broderick Radiation Management Section Land Protection Division Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73102-6087

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