ML19029A683

NRC Staff Approval of Proposed 2019 Cimarron Budget

ML19029A683
Person / Time
Site:	07000925
Issue date:	03/20/2019
From:	Bo Pham Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Halliburton B Cimarron Environmental Response Trust, Environmental Properties Management
K KALMAN DUWP
References
Download: ML19029A683 (4)

Text

March 20, 2019 Mr. Bill Halliburton, Administrator Cimarron Environmental Response Trust c/o Environmental Property Management, LLC 9400 Ward Parkway Kansas City, MO 64114

SUBJECT:

APPROVAL OF CIMARRON ENVIRONMENTAL RESPONSE TRUST PROPOSED 2019 BUDGET- FOR THE CIMARRON FACILITY IN CRESCENT, OKLAHOMA

Dear Mr. Halliburton:

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Cimarron Environmental Response Trust (CERT) Proposed 2019 Budget that was submitted by letter dated November 21, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19029A122). The NRC staff identified three concerns that were discussed with Mr. Jeff Lux of your staff:

Task 2 Activity 10 Perform probabilistic dose modeling using reasonable exposure scenarios and known uranium enrichment values to evaluate possible area-specific alternative derived concentration guideline levels (DCGL).

During our January 24, 2019 teleconference, the NRC staff noted that changes in DCGLs would cause Cimarron to no longer be grandfathered under the Site Decommissioning Management Plan (SDMP). Mr. Lux stated that CERT is evaluating the option of staying under the SDMP or switching to the license termination rule.

The NRC staff cautions that it is important for Cimarron to fully understand the costs as well as the benefits when considering whether to use alternative DCGLs.

Task 4 Activity 6 Conduct a treatability test for Ambersep 21K resin, the resin which has replaced the former Dow product, Dowex 1.

During our January 10, 2019 teleconference, the NRC staff noted that the Veolia Support line item budget of $1,347,000 includes a cost of $166,000 for additional pilot testing of water resins.

The NRC staff questioned this item because treatability tests were already performed for Dowex 1 resin. Mr. Lux explained that Dowex 1 is no longer available for future use and has been replaced by Ambersep 21K. At the NRC staffs request, Mr. Lux submitted technical specifications on Ambersep 21K and a summary of available literature relating to the application of Ambersep 21K in removing uranium in contaminated groundwater.

B. Halliburton 2 The NRC staff reviewed this material and finds that CERT has not yet demonstrated exactly what resin testing is necessary, what the cost of that testing would be, and whether the testing is cost beneficial. Therefore, the NRC staff does not approve the $166,000 for additional resin testing at this time. The NRC staff requests that CERT submit, for NRC review and approval, a cost benefit analysis of conducting additional testing of resins and an amendment to the budget to add this item.

Task 4 Activity 7 Vertical Aquifer Profiling/Delineation and Well Installation/Abandonment.

The NRC staff found the wording in the breakdown of Task 4 Activity 7 to be somewhat confusing. As discussed with Mr. Lux, please change the last sentence to read, This work will be performed, after receipt of the request for additional information (RAI), provided that environmental property management does not relocate extraction, injection, or monitor wells in response to the RAIs.

Conclusion The NRC reviewed the proposed 2019 budget for the Cimarron site and has three comments:

1. CERT should decide whether to stay grandfathered under SDMP criteria or change to the LTR criteria as this will impact the NRC staffs current review of the Decommissioning Plan for the Cimarron Facility.

2. Delete the $166,000 for additional testing of resin from Task 4 Activity 6. When CERT is better able to specify what testing is needed, the cost, and the cost benefit of the testing, CERT can request an amendment to the 2019 budget to conduct the necessary testing.

3. In Task 4 Activity 7, revise the last sentence to read, This work will be performed, after receipt of the request for additional information (RAI), provided that environmental property management does not relocate extraction, injection, or monitor wells in response to the RAIs.

Please make the above noted changes and resubmit the final budget for NRC approval.

In accordance with Section 2.390 of Title 10 of the Code of Federal Regulations of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.

B. Halliburton 3 If you have any questions concerning this letter, please contact Mr. Kenneth Kalman at (301) 415-6664 or via email at Kenneth.Kalman@nrc.gov.

Sincerely,

/RA C. MCKENNEY FOR/

Bo Pham, Acting Director Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards cc: Cimarron Site Service List

B. Halliburton 4

SUBJECT:

APPROVAL OF CIMARRON ENVIRONMENTAL RESPONSE TRUST PROPOSED 2019 BUDGET- FOR THE CIMARRON FACILITY IN CRESCENT, OKLAHOMA DATE: March 20, 2019 ADAMS Accession No.: ML19029A683 *via email OFFICE DUWP DUWP OGC DUWP DUWP NAME KKalman CHolston EHousman* BVontill BPham CMcKenney for DATE 2/5/19 2/5/19 2/22/19 2/28/19 3/20/19