ML20014E728

NRC - DEQ - EPM Telecon Notes

ML20014E728
Person / Time
Site:	07000925
Issue date:	01/08/2013
From:	- No Known Affiliation
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
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Download: ML20014E728 (30)

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NRC - DEQ - EPM Telecon Notes January 8, 2013 (Red text indicates who will take the next action)

Attendees Mike Logan Bill Elalliburton Ken Kalman Lifeng Guo Kurian Varughese David Cates Mike Broderick Kelly Pham Paul Davis Administrative Issues December 11 telecon notes - No comments were received. Final notes will be sent by January

18. EPM Proposed 2013 budget - The proposed budget for 2013 was submitted to the recipients identified in the Trust agreement on December 27th. A breakdown of costs for tasks was e-mailed to NRC and DEQ separately on December 19th. The proposed budget does not include costs for analysis of NRC-selected soil samples from Subarea F, each of which EPM will send a split to GEL for comparative analysis. It also does not include costs for additional aquifer testing, but it is possible the existing budget can support that work.

The revised budget was submitted as revision 1 to the proposed budget on November 29. Rev 1 does not include money for additional aquifer testing, nor does it include money to install new monitor wells. DEQ requested a breakdown of costs for tasks. EPM will provide a breakdown of costs for activities within tasks in a separate submittal. EPM DEQ reimbursement - DEQs accounting department will send statements for the 2nd and 3rd quarter of 2012, likely before the end of the year. DEQ License Issues Response to letter on Tc NRC will send a letter addressing Tc-99. Key concepts in the letter include:

1. Tc-99 activity is below NRC limit site-wide, but exceeds EPA dose-based limit in a couple locations

2. No remediation will be required for Tc-99

3. Annual environmental monitoring will need to retain gross beta analysis for trending purposes

4. Post-remediation groundwater monitoring will need to include four consecutive quarters of analysis for Tc-99 to include in dose modeling for license termination.

NRC Confirmatory survey for subsurface soil in Subarea F - EPM is storing duplicate samples of all the samples identified in boring logs, pending NRC selection of samples to use as confirmatory samples. NRC will notify EPM which samples to send for analysis. NRC Annual environmental sampling - It appears that uranium is not fully delineated in Burial Area

1. 1, and nitrate is not yet fully delineated in the Western Alluvial Area. EPM recommended the installation of additional monitor wells, which should be sampled simultaneously with those in the list sent November 16th. This information is needed for groundwater remediation design, so 1 of 3

EPM desires to install the wells in March and conduct sampling in March - April. Approval or comments from NRC and DEQ are needed. NRC and DEQ Release surveys for frac tanks used to store development, purge, and pump test water will begin after the water is removed for disposal. Two tanks are empty, the rest are being emptied. EPM Groundwater Design Issues Hydrogeologic pilot test - EPM will prepare a report on the hydrogeologic pilot test describing the work performed, providing the aquifer test data and the interpretation of that data, and discussing the impact of the work on the groundwater remediation design. EPM Groundwater remediation plan - The groundwater remediation plan now consists of:

1. Groundwater extraction wells in the Western Alluvial Area (WAA) and Burial Area #1 (BA1).

2. Groundwater recovery trenches will be installed in the transition zones instead of vertical groundwater pumping wells.

3. A substantially greater volume of water will be produced from the Western Alluvial Area than had been thought.

4. Groundwater from the Well 1319 area will be piped to one of the water treatment areas.

5. A water treatment system will remove uranium from the BA1 groundwater.

6. All BA1 treated water not reinjected into upland sandstones to flush chemicals of concern to the alluvium will be discharged to the Cimarron River, along with all groundwater produced from the WAA.

7. Horizontal injections wells will be used in the Well 1348, Western Upland, U-Pond #1, and U-Pond #2 Areas instead of vertical groundwater pumping wells.

8. A water storage tank battery (or batteries) will be installed instead of an impoundment.

9. A second treatment system, removing uranium and at least some nitrate from WAA groundwater, may be added to the groundwater remediation plan to keep nitrate in the discharge to the Cimarron River below daily loading limits.

10. A second discharge line from the second treatment plant may be permitted to provide for the greater anticipated total flow.

11. If nitrate concentrations indicate the need to distribute the discharge in the river, rather than install a point source discharge, a diffusion system will be included in the design.

These changes will be reflected in a revised conceptual plan, presenting approximately the same level of detail as presented in the conceptual plan presented to the public on June 4th. EPM OPDES permit application - Due to the changes listed above, the OPDES permit application initially submitted in April 2012 was withdrawn November 29th. The letter requested feedback from DEQ regarding concentration limits as a function of receiving stream flow. DEQ rejected concentration limits as a function of effluent flow. Consequently, the question was not answered. EPM will attempt to obtain verbal feedback. EPM Water treatability study - Resin within the resin columns can accumulate more than ten times the Appendix C quantity of uranium, so the area within which the test will be conducted will be NRC - DEQ - EPM Telecon Notes January 8, 2013 (Red text indicates who will take the next action) 2 of 3

designated a radiologically restricted area, and radiological controls will be implemented during the test. In addition, because the storage tanks located near the office building will contain greater than ten times the Appendix C limit of uranium, a containment structure will be constructed over and around the influent tanks, and this containment will be designated a restricted area. Clean Harbors will visit the site January 17th to discuss the setup of the water treatment test. Clean Harbors will discuss loading, flow rates, the probable duration of the test, etc. while on site. The water treatment test is expected to begin in February. EPM Other Issues Section 13 property - EPM received an e-mail from Tronox explaining why Tronox owns mineral rights to Section 13 and other property which may have been owned by Cimarron Corporation as of the Effective Date. EPM requests confirmation of the adequacy of Tronox explanation from NRC and DEQ.EPM forwarded that e-mail to NRC and DEQ on November 19th. EPM continues to receive offers for oil and gas leases related to this property. NRC and DEQ Property west of Highway 74 - EPM drafted a sales agreement which will include an agreement not to install water, oil or gas wells on this property. The draft sales agreement is in legal review, and will be sent to NRC and DEQ after revision from legal review. Upon NRC and DEQ approval, an auction will be scheduled for the sale of the property. EPM

© 25-acre property with buildings - EPM drafted an as is - where is sales agreement which will include an agreement not to install water, oil or gas wells on this property.

The property addressed by the sales agreement does not include the area within which groundwater exceeds cleanup criteria in the Well 1319 Area. The draft sales agreement is in legal review, and will be sent to NRC and DEQ after revision from legal review.

Upon NRC and DEQ approval, an auction will be scheduled for the sale of the property.

EPM NRC - DEQ - EPM Telecon Notes January 8, 2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes February 12, 2013 (Red text indicates who will take the next action)

Attendees Mike Logan Bill Flalliburton Ken Kalman Lifeng Guo Kurian Varughese Blair Spitzberg Gerald Schlapper David Cates Paul Davis Pam Dizikes Mike Broderick Kate Deaton Ray Roberts Administrative Issues January 8 Telecon Notes - No comments were received. Final notes were sent February 8th.

Proposed 2013 Budget - The proposed budget for 2013 was submitted to the recipients identified in the Trust agreement on December 27th. A breakdown of costs for tasks was e-mailed to NRC and DEQ separately on December 19th. NRC and DEQ will send EPM a letter approving the proposed budget. NRC and DEQ Fourth Quarter 2012 Financial Report - The financial report for the 4th quarter had not been received by Ken Kalman. Keith McConnells name still appears in the list of addressees instead of Drew Persinko. Addressees will be revised prior to the submittal of the next report. A copy of the fourth quarter financial report will be sent to NRC and DEQ via e-mail. EPM DOJ Request for Projected Expenditures - Rob Yalen has requested anticipated expenditures by account for the next several years. DOJ wants to determine the adequacy of funding for various trusts. EPM will submit a cost projection to DOJ and copy NRC and DEQ so they can comment on the projection if desired. EPM Groundwater Design Issues Hydrogeologic Pilot Test - EPM is preparing a report on the hydrogeologic pilot test describing the work performed, providing the aquifer test data and the interpretation of that data, and discussing the impact of the work on the groundwater remediation design. Only a potentiometric surface map and figures need preparation to complete the report. December groundwater elevation data yields several anomalous groundwater elevations. EPM will revisit several wells on February 15th to check on the usability of the data. A map with groundwater elevation data posted, and the proposed locations of additional monitoring wells, will be sent to NRC and DEQ on February 15th. EPM Pneumatic Slug Tests - Pneumatic slug tests were performed on approximately 13 monitor wells located throughout the Western Alluvial Area the week of February 4th. Data generated during the slug tests is being input into AQTESOLV. A report on the results of the test, and how derived hydraulic conductivity values will be used in the groundwater flow model for the Western Alluvial Area will be submitted to NRC and DEQ once the data evaluation is complete.

EPM Water Treatability Study - The outside containment in which the two 2,500-gallon influent tanks are housed is complete. EPM will install the secondary containment box in the sample 1 of 3

preparation room and prepare postings, etc. on the 14th and 15th. Tests will be conducted on monitor wells 02W32 and T-62 to either demonstrate that they will produce sufficient water for the test, or additional wells will be selected and tested, also on the 14th and 15th. Clean Harbors will visit the site February 21st to setup the water treatment test columns, pumps, etc. The water treatment test is scheduled to begin February 21st. EPM License Issues Response to Tc-99 Request - NRC will send a letter addressing Tc-99. Key concepts in the letter include:

1. Tc-99 activity is below NRC limit site-wide, but exceeds EPA dose-based limit in a couple locations

2. No remediation will be required for Tc-99

3. Annual environmental monitoring will need to retain gross beta analysis for trending purposes

4. Post-remediation groundwater monitoring will need to include four consecutive quarters of analysis for Tc-99 to include in dose modeling for license termination. NRC Confirmatory Survey for Subsurface Soil in Subarea F - NRC has selected the confirmatory soil samples for Subarea F and Region IV has sent an address to which samples should be sent. EPM will send the selected samples for isotopic analysis of uranium to ORAU February 15th. EPM Annual Environmental Sampling and Uranium and Nitrate Delineation - EPM will e-mail a site map with groundwater elevation posted at wells, and showing proposed locations of additional monitor wells. EPM will recommend sampling the wells listed in the November 16 e-mail, plus the proposed new monitor wells, during March. It is hoped that this will complete both the requirements for annual environmental sampling and the delineation of nitrate and uranium for the groundwater remediation plan. EPM Frac Tank Demobilization - A release survey was performed on the frac tank which contained both development water and the water from the GE-WA-01 aquifer test. Because it included well development water, it is judged most likely to contain sediment from well development. All measurements were significantly below the limit for removable surface contamination. On the basis of this survey, six frac tanks, all of which contained water from the GE-WA-01 aquifer test, will be demobilized from the site. The remaining frac tank contained development water and the water from the GE-BA1-01 aquifer test. It still contains approximately 4,000 gallons of water.

Once ORI Environmental has disposed of that water, a release survey will be conducted on that frac tank. If releasable, it will either be demobilized or relocated near the office building to store effluent from the water treatment test. EPM NRC - DEQ - EPM Telecon Notes February 12, 2013 (Red text indicates who will take the next action)

Other Issues

© Section 13, Southwest Quarter - EPM is communicating with Rob Yalen of DOJ regarding the potential to obtain the mineral rights to this property, since Tronox claims the mineral rights are still owned by Cimarron Corporation. EPM

o Sales Agreements for Property Disposition - EPM drafted a sales agreement which included an agreement not to install water, oil or gas wells on this property. During legal review, the agreement was modified to impose restrictions on the property west of the highway, which would be appropriate for the property containing the former process buildings. EPM will split the agreement into two separate agreements, and will send both to NRC and DEQ for review and comment. Upon NRC and DEQ approval, an auction will be scheduled for the sale of the property west of the highway, and Stewart Industries will be sent a copy of the agreement for their consideration. EPM NRC - DEQ - EPM Telecon Notes February 12, 2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes March 12,2013 (Red text indicates who will take the next action)

Attendees Mike Logan Bill Halliburton Ken Kalman Lifeng Guo Kurian Varughese Gerald Schlapper David Cates Paul Davis Pam Dizikes Mike Broderick Kate Deaton Monty Elder Administrative Issues February 12 Telecom Notes - No comments were received. Final notes will be sent by the end of the week. EPM Proposed 2013 Budget - NRC approved the 2013 budget in a letter dated February 11, 2013.

DEQ will send EPM a letter approving the proposed budget shortly. DEQ Groundwater Design Issues Hydrogeologic Pilot Test - The Hydrogeologic Pilot Test Report will be sent to DEQ and NRC approximately March 15, 2013. EPM Pneumatic Slug Tests - Pneumatic slug tests were performed on approximately 13 monitor wells located throughout the Western Alluvial Area the week of February 4th. Data generated during the slug tests was input into AQTESOLV. A report on the results of the test, and how derived hydraulic conductivity values will be used in the groundwater flow model for the Western Alluvial Area will be submitted to NRC and DEQ by March 15th. EPM Water Treatability Study - The column tests began Thursday February 22nd. Flow rates were acceptable, averaging 9 gallons per hour (gph). By Friday, pressures had climbed and flow rates declined. Communicating with Clean Harbors (CH) personnel, EPM worked for over two weeks, adjusting flows, replacing gauges and filters, and replacing resin. It was determined that the resin was being plugged by unknown precipitates. After consulting with Siemens, CH concluded that calcium and magnesium in the groundwater was reacting with the cation resin and plugging the resin columns. The test was terminated on March 12th. Four sampling events had been conducted, on days 0, 3, 9, and 16 (sampling was delayed due to one-day interim shut-downs). The test will be resumed after CH modifies the system to provide for calcium and magnesium removal via anionic resin exchange prior to treating the softened water with the same anion resin used in the initial trial. Startup of the modified test should begin mid-April.

Prior to beginning a new test, EPM will revise the activity plan to reflect changes in the plan.

CH will provide a document describing the problem that occurred in the initial test, as well as how the addition of an anion resin prior to the cation resin will resolve the problem. EPM will send both documents to NRC and DEQ for review and comment prior to beginning the next test.

EPM 1 of 3

NRC - DEQ - EPM Telecon Notes March 12,2013 (Red text indicates who will take the next action)

License Issues Response to Tc-99 Request - This item has remained unchanged since the last teleconference.

NRC will send a letter addressing Tc-99. Key concepts in the letter include:

1. Tc-99 activity is below NRC limit site-wide, but exceeds EPA dose-based limit in a couple locations

2. No remediation will be required for Tc-99

3. Annual environmental monitoring will need to retain gross beta analysis for trending purposes

4. Post-remediation groundwater monitoring will need to include four consecutive quarters of analysis for Tc-99 to include in dose modeling for license termination. NRC Confirmatory Survey for Subsurface Soil in Subarea F - ORAU Radioloanalytical Laboratory issued a report on the analysis of the seven soil samples selected by NRC for analysis.

Analytical results were comparable for those samples analyzed by GEL. None of the samples yielded uranium activity exceeding 1/3 of the unrestricted release limit. EPM will distribute the analytical report to NRC headquarters and DEQ. EPM Annual Environmental Sampling and Uranium and Nitrate Delineation -EPM recommends sampling a total of 156 wells and two surface water locations, which include eleven proposed new monitor wells. It is hoped that this will complete both the requirements for annual environmental sampling and the delineation of nitrate and uranium for the groundwater remediation plan. NRC and DEQ will review the groundwater elevation maps sent via e-mail and comment on the adequacy of the proposed new monitor well locations within two weeks.

NRC and DEQ Frac Tank Demobilization - Release surveys are complete, and all but three frac tanks have been demobilized. The rest should be removed within by March 15th.

Other Issues

© TiCU Discovery - While removing a large plastic container from the metal shed next to the Ti02 Building, a fitting connecting tubing to an instrument rack was bumped, and began to emit a white vapor. Signs on the building indicate that material formerly processed in the building may be reactive; the posting indicated a health rating of 3 and a reactivity rating of 2, and a Warning - Use No Water posting was displayed near the doorway. The building was vacated, and after several days, the release stopped. EPM contacted Tronox personnel, described the nature of the release, and was informed that this was probably a release of TiCU. EPM will obtain a material safety data sheet for this material and will determine if it is possible that a reportable quantity exists. EPM

© Section 13, Southwest Quarter - EPM is communicating with Rob Yalen of DOJ regarding the potential to obtain the mineral rights to this property. Tronox believes the mineral rights are still owned by Cimarron Corporation. EPM will inform NRC and DEQ whether the DOJ intends to pursue this issue or accept Tronox assertion. EPM

© Sales Agreement for Property West of Highway 74 - EPM submitted a draft sales agreement for this property to NRC and DEQ for review and comment. Upon NRC and 2 of 3

DEQ approval, public notice will be given, and an auction will be scheduled for the sale of the property. NRC and DEQ Sales Agreement for Property with Buildings - EPM submitted a draft sales agreement for this property to NRC and DEQ for review and comment. Upon NRC and DEQ approval, public notice that the property sale will be given, and Stewart Industries will be sent a copy of the agreement for their consideration. NRC and DEQ NRC - DEQ - EPM Telecon Notes March 12,2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes April 9,2013 (Red text indicates who will take the next action)

Attendees Mike Logan Ken Kalman David Cates Bill Elalliburton Lifeng Guo Kate Deaton Jennifer McAlister Marc Hullinger Administrative Issues March 12 Telecom Notes - A few comments were received. Final notes were sent April 9, after the April teleconference.

Proposed 2013 Budget - DEQ approved the 2013 budget in a letter dated March 27, 2013.

A financial statement for the first quarter of 2013 will be sent to the beneficiaries within the next few weeks. EPM Mike Norato has replaced Paul Michalak as Branch Chief, Decommissioning Branch.

Groundwater Design Issues Hydrogeologic Pilot Test - The Hydrogeologic Pilot Test Report was sent to DEQ and NRC March 15, 2013.

Pneumatic Slug Tests - Pneumatic slug tests were performed on approximately 14 monitor wells located throughout the Western Alluvial Area the week of February 4th. A report on the results of the test, and how derived hydraulic conductivity values will be used in the groundwater flow model for the Western Alluvial Area was submitted to NRC and DEQ March 15th.

Water Treatability Study - The column tests began Thursday February 22nd and was terminated on March 12th due to plugging of the resin. Four sampling events had been conducted, on days 0 (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the test), 3, 9, and 16. Samples of resin were submitted for total metals analysis, and samples of each influent were submitted for pH, conductivity, and common cations and anions. Clean Harbors will prepare a document that describes/explains:

1. How the resin absorbs the uranium (and other ions)

2. What caused the problem in the first run of the test

3. What we are doing to ensure that we define the problem fully so as to not experience the same kind of problem again

4. How we will modify the pilot test system to re-run the test with a far lower likelihood that well experience additional problems

5. You cant foresee all potential problems until you run a pilot test; thats why were doing this; so CH can design a water treatment plant that the pilot test demonstrates will work.

EPM will send this document to NRC and DEQ for review and comment prior to beginning the next test, and will schedule a teleconference with NRC, DEQ, and Clean Harbors should that be desired. EPM

NRC - DEQ - EPM Telecon Notes April 9,2013 (Red text indicates who will take the next action)

License Issues Response to Tc-99 Request - This item has remained unchanged since the last teleconference.

NRC will send a letter addressing Tc-99. Key concepts in the letter include:

1. Tc-99 activity is below NRC limit site-wide, but exceeds EPA dose-based limit in a couple locations

2. No remediation will be required for Tc-99

3. Annual environmental monitoring will need to retain gross beta analysis for trending purposes

4. Post-remediation groundwater monitoring will need to include four consecutive quarters of analysis for Tc-99 to include in dose modeling for license termination. NRC Confirmatory Survey for Subsurface Soil in Subarea F - ORAU Radioloanalytical Laboratory issued a report on the analysis of the seven soil samples selected by NRC for analysis.

Analytical results were comparable for those samples analyzed by GEL. EPM will request NRC approval to dispose of the remaining soil samples. EPM Well Installation and Groundwater Assessment Sampling - EPM recommended the installation of eleven new monitoring wells in the Hydrogeologic Pilot Test Report. DEQ and NRC responded by eliminating two wells and relocating several others. Part of the re-location is contingent on potential problems with TOC elevations. Older wells were surveyed at different times by different surveyors, so several wells were surveyed in four areas with a level to see if differences in TOC elevations agree with past survey data. It was discovered that in several areas it appears that TOC elevations may be off by 0.5 to nearly 2.0 feet. However, this survey indicated that the data in the northern part of the Western Alluvial Area is sufficiently accurate.

Consequently, nine new wells will be installed as located by NRC and DEQ, and after installation all wells on the site will be surveyed and leveled to produce accurate TOC elevations.

Comprehensive groundwater sampling will be conducted as and after these nine new wells are installed.

The groundwater flow models for the Western Alluvial Area and Burial Area #1 will be revised after the data is received from the surveyor and the laboratory. NRC and DEQ Land Application of Wastewater - DEQ previously stated that, due to the presence of uranium above drinking water standards in the water, DEQ cannot issue a land application permit to use irrigation to dispose of recovered groundwater. EPM will request that DEQ inform EPM if a land application permit could be issued if uranium, fluoride, and Tc-99 are all below drinking water criteria, and only nitrate (which beneficiates the soil, functioning as a nutrient for vegetation) exceeds drinking water criteria. EPM Other Issues

• TiCU Discovery - During the March teleconference, DEQ requested that EPM obtain an MSDS for TiCU and to determine if it is possible that a reportable quantity (RQ) was 2 of 3

released. Several MSDS were obtained, and it was determined that the RQ for TiCU is 1,000 pounds. A reportable quantity was not released, and is not likely to be present in the Ti02 building.

© Section 13, Southwest Quarter - Tronox will discuss this issue with DOJ and will advise NRC and EPM of the resolution of this issue. EPM Sales Agreement for Property West of Ehghway 74 - EPM submitted a draft sales agreement for this property to NRC and DEQ for review and comment. Upon NRC and DEQ approval, public notice will be given, and an auction will be scheduled for the sale of the property. NRC and DEQ Sales Agreement for Property with Buildings - EPM submitted a draft sales agreement for this property to NRC and DEQ for review and comment. Upon NRC and DEQ approval, public notice that the property sale will be given, and Stewart Industries will be sent a copy of the agreement for their consideration. NRC and DEQ NRC - DEQ - EPM Telecon Notes April 9, 2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes May 14, 2013 (Red text indicates who will take the next action)

Attendees Mike Logan Bill Halliburton Ken Kalman Lifeng Guo Varughese Kurian Gerald Schlapper David Cates Kate Deaton Paul Davis Pam Dizikes Administrative Issues April 9 Telecom Notes - One comment was received. Final notes were sent May 24, 2013.

Bonus Check for Forced Pooling - EPM received a check for approximately $77,000 as a bonus payment for the Trusts share of mineral rights in Section 11. EPM requested guidance on the distribution of these funds between the State, Federal, and Administrative Accounts. NRC will distribute a draft proposal which presents a recommended distribution of funds. The same distribution may apply to funds received as a result of the sale of portions of Trust property.

NRC Lease Offer for Section 12 - EPM received a letter from a land agent proposing either participation in the drilling of an oil well that will extract minerals from beneath property the Trust owns in Section 12, or the execution of an oil and gas lease. This is similar to the offer made for Section 11 property. EPM notified them that the Trust will not participate in the drilling of the well, and will not execute a lease. The result will be another forced pooling of the minerals under Section 12, as occurred with the Section 11 property. NO FURTHER ACTION REQUIRED Standby Trust Fund - Due to an inability to get JP Morgan to eliminate the provisions of their proposed side letter, NRC requested that EPM consider using a different financial institution to function as trustee for the Standby Trust Fund. NRC suggested that EPM check ADAMS for documents that identify other financial institutions that function as trustee for other licensees standby trust funds. EPM may also contact Kenneth Kline for additional information. EPM First Quarter Public Information Notice - Information on the status of and upcoming work for the Cimarron site was sent to members of the public via e-mail and hard copy, and the information was posted to www.certoklahoma.com. NO FURTHER ACTION REQUIRED Groundwater Design Issues Hydrogeologic Pilot Test - EPM asked if either NRC or DEQ have any preliminary comments on the report, issued March 15, 2013. NRC and DEQ will not provide comments until they have completed their review of the report within the next few weeks. NRC AND DEQ Groundwater Flow Models - A groundwater flow model is scheduled to be submitted to DEQ and NRC by July 12, 2013. Calibration of the flow model cannot be completed until groundwater elevation data for all wells on site is collected during the sampling events that will occur in May. The groundwater flow model will later incorporate groundwater extraction, after concentration/activity data is obtained from the laboratory for the wells sampled in May. EPM 1 of 2

Water Treatability Study - In accordance with the site-specific quality assurance program, EPM generated a Notice of Deficiency to identify the causes of problems encountered in the first run of the water treatability study, and describing corrective actions that will be implemented in the second run. EPM generated a draft activity plan which addressed the issues discussed in the April 18 e-mail; Clean Harbors will complete revision of the activity plan to prepare for Run 2.

Cation removal will be performed by running the groundwater through anionic resin beds prior to the influent tanks, after which removal of anions will be achieved in a manner similar to Run

1. EPM Groundwater Assessment - Nine new monitor wells were being installed the week of the teleconference, at locations agreed upon by NRC and DEQ. In conjunction with the annual environmental sampling, 128 additional groundwater monitor wells will be sampled to fully delineate uranium, nitrate, and fluoride exceedences. This information is needed to design groundwater extraction trenches and wells throughout the contaminant plumes. Soil boring logs and monitor well installation diagrams will be e-mailed to NRC and DEQ upon completion of the work. EPM License Issues Annual 27(e) Report - License condition 27(e) requires the submission of an annual report identifying changes made to the Radiation Protection Plan and/or Decommissioning Plan in accordance with this condition. EPM submitted this report on April 16, 2013; no changes had been made to either plan. NO FURTHER ACTION REQUIRED Response to Tc-99 Request - In a letter dated April 22, 2013, NRC agreed that continued monitoring for Tc-99 can be discontinued until data is required for preparation of a final dose model for license termination. Until that time, annual environmental sampling will include analysis for gross alpha and gross beta; the gross beta activity will function as an indicator of Tc-99 activity. NO FURTHER ACTION REQUIRED Confirmatory Survey for Subsurface Soil in Subarea F - ORAU Radioloanalytical Laboratory issued a report on the analysis of the seven soil samples selected by NRC for analysis.

Analytical results were comparable for those samples analyzed by GEL. NRC will approve disposal of the remaining soil samples via e-mail. NRC Annual Environmental Monitoring - The sampling of 29 groundwater monitor wells and two surface water locations, in accordance with Section 15 of the Radiation Protection Plan, will begin as soon as the installation of the nine new groundwater monitor is complete.

Other Issues Sale of Two Properties - EPM has finalized sales agreements for these properties. EPM will retain Bums & McDonnell personnel with experience in real estate transactions to prepare a proposal describing the process whereby notice will be made, sales agreements distributed to interested parties, and an auction or other action be performed to sell the property. Upon NRC and DEQ approval, EPM will start the process. EPM NRC - DEQ - EPM Telecon Notes May 14, 2013 (Red text indicates who will take the next action) 2 of 2

Attendees Ken Kalman David Cates Jeff Lux Lifeng Guo Kate Deaton Bill EDlliburton Varughese Kurian Mike Broderick Mike Logan Marc Hullinger Pam Dizikes Jennifer McAllister NRC - DEQ - EPM Telecon Notes July 09, 2013 (Red text indicates who will take the next action)

Administrative Issues June 11 Telecom Notes - No comments were received. Final notes were sent July 9, 2013.

Bonus Check for Forced Pooling - EPM received a check for approximately $77,000 as a bonus payment for the Trusts share of mineral rights in Section 11. Until distribution of funds is established for each of the Trust accounts, the check will be deposited in the Administrative Account, and EPM will notify the agencies when the deposit has been made. EPM Standby Trust - EPM will send copies of the relevant trust documents to US Bank and will continue to explore transfer of the Standby Trust funds to US Bank as trustee. EPM Seismic Study on Section 11 Property - Nodal Seismic (Nodal) has permission from mineral rights owners and an OCC permit to perform a 2-D seismic survey on property the Trust owns in Sections 11 and 12. Nodal revised the permit letter to EPM to include providing the seismic data from Sections 11 and 12 to EPM. Slawson Exploration (Slawson) is Nodals client, and has a license for the software required to interpret the data. Slawson will issue a license to to EPM so EPM can interpret the data. EPM will fill out the permit form and send it to DEQ and NRC for review. EPM will also contact OCC and Nodal regarding bonding, a damage deposit, insurance with the Trust named as additional insured, and reimbursement of cost for damages, and will report information gained from these conversations to NRC and DEQ. EPM will be on site when Nodal arrives to provide access, and will obtain well depth and groundwater elevations measurements pre-and post-seismic survey to assess potential damage to monitor wells. EPM will notify DEQ of the date Nodal should arrive on site, and will take photographs of the seismic setup and operation to send to NRC and DEQ. EPM Authority to Access Trust Property - DEQ has determined, through review of statutes and conversations with OCC that owners of mineral rights have priority over surface owners regarding granting access for minerals development. Surface owners can negotiate terms of access, but cannot deny access, if mineral rights owner (s) grant access to a developer of minerals. This pertains to drilling of oil wells, installation of ancillary facilities, etc. EPM will inform NRC and DEQ of any developments that extend beyond the current seismic survey, and will strive to maintain the maximum degree of control over third parties to whom access to develop minerals is granted.

Proposals to Sell Properties - EPM prepared proposals to sell the property west of Elighway 74 (117-acre parcel) and the property containing the former process buildings (24-acre parcel).

Each proposal contains a description of the property, its environmental and regulatory status, the 1 of 3

rationale for immediate sale of the property and benefits to the trust, the process of public notice, and a proposed sale agreement. The proposals were sent to NRC, DEQ, and the DOJ. As requested EPM will prepare an updated estimated value of both parcels based upon the 2011 appraisals and Logan County appraised values. EPM will also prepare an estimate of the potential future cost to the Trust associated with the 24-acre property for two scenarios:

1. The Trust retains ownership of the property, with responsibility for groundwater remediation, removal of wastes and contaminated equipment, demolition of the buildings, and disposal of the buildings and uncontaminated equipment and

2. The Trust sells the property as-is and retains responsibility for groundwater remediation only.

DOJ sent additional language and examples of evaluations for other Tronox Trust property sales; EPM has provided these documents to outside counsel for review, and will revise the proposals and sale agreements as appropriate based on comments received to date and will submit the revised documents for review by NRC and DEQ. NRC and DEQ will re-evaluate the need for restrictions on the 117-acre parcel, in light of the fact that a mineral right owner can grant access regardless of the surface owners agreement. EPM will request teleconferences as needed to discuss any or all of these issues. EPM Interview by Wall Street Journal Reporter - John Emshwiller, a reporter for the Wall Street Journal, contacted NRC Region IV regarding the Cimarron Site, and was provided information regarding the formation and goal of the Trust, along with Jeff Lux contact information. Mr. Lux referred Mr. Emshwiller to www.certoklahoma.com, which contains the evaluation of potential alternative groundwater remediation technologies and quarterly information updates. Should Mr.

Emshwiller contact Mr. Lux again, Mr. Lux will refrain from discussing topics other than plans to remediate groundwater, and will refer Mr. Emshwiller to the certoklahoma website. EPM will generate a 2013 Q2 information update for NRC and DEQ review, and upon revision of the information update, will post it to the certoklahoma website. EPM Groundwater Design Issues Hydrogeologic Pilot Test Report - Bums & McDonnell requested schedule availability to schedule a teleconference with NRC and DEQ personnel to discuss responses to comments on the Hydrogeologic Pilot Test Report. NRC and DEQ will provide this information to Pat Higgins and Jeff Binder to discuss how to respond to their comments. NRC and DEQ Site-Wide Groundwater Assessment Data - Data for all 156 wells sampled, plus 16 duplicates, has been received from the laboratory and is being reviewed. Once data review is complete and all necessary qualifiers have been added to the data, tabulated results will be sent to NRC and DEQ and posted to the Sharepoint site. EPM Monitor Well Top of Casing (TOC) Elevation Survey - Huddleston Surveying has completed a survey of all 195 wells remaining on the site. EPM reviewed the differences between current TOC elevations, and the significant differences noted based on old TOC elevations are now resolved. EPM input the X, Y, and Z (TOC elevation) into the monitor well inventory NRC - DEQ - EPM Telecon Notes July 09, 2013 (Red text indicates who will take the next action) 2 of 3

spreadsheet, sent the file to NRC and DEQ, and uploaded it to the Sharepoint site under Shared Documents / Data / Monitor Well Records. EPM also uploaded revised boring log and well installation diagrams to the Sharepoint site under the same folder. EPM Groundwater Flow Models - A groundwater flow model is scheduled to be submitted to DEQ and NRC by July 12, 2013. Groundwater elevation data for all wells on site has just been received, and the first revision of the groundwater models (groundwater flow only) will be completed as soon as possible. A second revision of the groundwater flow model will incorporate groundwater extraction, after receiving comments on the flow model from NRC and DEQ, and after concentration/activity data has been reviewed for the wells sampled in May.

EPM Water Treatability Study, Run 2 - Clean Harbors is revising the Notice of Deficiency from Run 1 and is revising the activity plan EPM drafted to complete the instructions for Run 2. Clean Harbors is scheduled to arrive at the site July 22nd to install equipment needed for Run 2. They plan to start the test the same week. As soon as EPM receives the revised activity plan, EPM will send it to DEQ and NRC for review and comment; it will also be sent to the RSO and QAC, as their comment and/or approval is needed prior to starting the test. EPM will also send the 27(e) evaluation performed by the ALARA Committee to conduct this test to NRC. EPM Land Application Permit - If treatment of groundwater from the Western Alluvial Area to remove nitrate is needed to obtain a discharge permit, it may be much more economical and environmentally beneficial to remove the uranium from both BA1 and WAA groundwater, assuming that DEQ would issue a land application permit for this water (for disposal by irrigation). EPM requested a meeting with DEQ Water Quality Management to see if land application of nitrate-impacted wastewater with uranium below drinking water criteria (in the range of background?) could be permitted. EPM will schedule a meeting to discuss this issue with DEQ. EPM License Issues Annual Environmental Monitoring - Data for the 29 groundwater monitor wells and two surface water locations was received from the laboratory. The tabulated results were sent to NRC and DEQ via e-mail and posted to the Sharepoint site on June 26. EPM License Amendment Request - Work has continued on the decommissioning plan, specifically those portions that document completed decommissioning activities and other site background information. The intent is to complete those sections not dependent upon the groundwater remediation design before the design is complete. EPM will continue preparation of the decommissioning plan, such that as soon as the treatability test is complete, only those aspects of the decommissioning plan that involve groundwater treatment and disposal must be prepared before the license amendment request can be submitted. EPM NRC - DEQ - EPM Telecon Notes July 09, 2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes August 13, 2013 (Red text indicates who will take the next action)

Attendees Ken Kalman Varughese Kurian David Cates Mike Broderick Paul Davis Tad Dow Jeff Lux Bill Halliburton Mike Logan Administrative Issues July 9 Telecom Notes - Final notes were sent August 22, 2013. No further action required.

Bonus Check for Forced Pooling - The $77,000 bonus payment for the Trusts share of mineral rights in Section 11 was deposited in the Administrative Account. These funds, as well as funds that the Trust may receive in the future, will be distributed between the Administrative, Federal, and State accounts as agreed upon by NRC and DEQ. NRC and DEQ will provide EPM guidance on the distribution of these funds. NRC and DEQ Standby Trust - US Bank notified EPM that their annual fee for administration of the Standby Trust would be $5,000, which seems high. EPM requested approval to approach another institution to see if one would administer the trust for a lower annual fee. NRC and DEQ approved this, as long as the cost of continuing to look for another trustee would not cost more than the annual fee US Bank proposed. EPM Seismic Study on Section 11 Property - Nodal Seismic (Nodal) has placed several dozen geophones on property the Trust owns in Sections 11 and 12. Nodal will have vibe trucks on site the week of 8/19 to conduct the seismic survey. EPM will be on site when Nodal arrives to provide access, and will obtain well depth and groundwater elevations measurements pre-and post-seismic survey to assess potential damage to monitor wells. EPM will notify DEQ of the date Nodal should arrive on site, and will take photographs of the seismic setup and operation to send to NRC and DEQ. EPM Proposals to Sell Properties - EPM will prepare an updated estimated value of both parcels based upon the 2011 appraisals and Logan County appraised values. EPM will also prepare an estimate of the potential future cost to the Trust associated with the 24-acre property for two scenarios:

1. The Trust retains ownership of the property, with responsibility for groundwater remediation, removal of wastes and contaminated equipment, demolition of the buildings, and disposal of the buildings and uncontaminated equipment and

2. The Trust sells the property as-is and retains responsibility for groundwater remediation only.

DOJ sent additional language and examples of evaluations for other Tronox Trust property sales; EPM has provided these documents to outside counsel for review, and will revise the proposals and sale agreements as appropriate based on comments received to date and will submit the revised documents for review by NRC and DEQ. NRC and DEQ will re-evaluate the need for 1 of 3

restrictions on the 117-acre parcel, in light of the fact that a mineral right owner can grant access regardless of the surface owners agreement. EPM, DEQ, and NRC NRC - DEQ - EPM Telecon Notes August 13, 2013 (Red text indicates who will take the next action)

Groundwater Design Issues E[ydrogeologic Pilot Test Report - EPM will notify NRC and DEQ of the anticipate date of submittal of an addendum to the ITydrogeologic Pilot Test Report, responding to agency comments, will be submitted. EPM Site-Wide Groundwater Assessment Data - Data for all 156 wells sampled, plus 16 duplicates, was received, reviewed, and submitted to NRC and DEQ. The data was also posted on the Sharepoint site. No further action required.

Monitor Well Top of Casing (TOC) Elevation Survey - Ehiddleston Surveying has completed a survey of all 195 wells remaining on the site. EPM reviewed the differences between current TOC elevations, and the significant differences noted based on old TOC elevations are now resolved. EPM input the X, Y, and Z (TOC elevation) into the monitor well inventory spreadsheet, sent the file to NRC and DEQ, and uploaded it to the Sharepoint site under Shared Documents / Data / Monitor Well Records. No further action required.

Groundwater Flow Models - Groundwater flow model input will be submitted to DEQ and NRC prior to completing model revision. EPM will notify NRC and DEQ of the anticipate date of submittal. EPM Land Application Permit - If treatment of groundwater from the Western Alluvial Area to remove nitrate is needed to obtain a discharge permit, it may be much more economical and environmentally beneficial to remove the uranium from both BA1 and WAA groundwater, assuming that DEQ would issue a land application permit for this water (for disposal by irrigation). EPM will schedule a meeting with DEQ Water Quality Management to see if land application of nitrate-impacted wastewater with uranium below drinking water criteria (in the range of background?) could be permitted. EPM License Issues Release from Water Treatability Study - EPM notified NRC and DEQ of a release from the WAA side of the treatability test. A cap on the bottom of the first column in the WAA treatment train cracked, and water sprayed out onto the floor. EPM vacuumed the water up (both inside and outside the containment, sampled it for laboratory analysis, and will retain the water until analytical results are received. The floor of the room in which the water was spilled was surveyed for alpha and beta surface contamination (direct and removable) and exposure rate. All alpha and exposure rate readings were at background levels, and all beta measurements were either at or slightly above background levels. (Note: The following was not discussed during the telecom, hut is included to provide this information to NRC and DEQ. The maximum direct beta measurement was 96 cpm/100 cm2 (1,000 dpm/100 cm2) above background, and the highest removable beta measurement was 10 cpm/100 cm2 (30 dpm/100 cm2) above background. The 2 of 3

free release limits for maximum direct and removable beta surface contamination are 15,000 and 1,000 dpm/100 cm2, respectively.) A Notice of Deficiency was initiated, and the test will be resumed after corrective action (including replacement of the entire column) has been completed.

EPM Radiation Worker and Instrument Training - EPM and Enercon is conducting Radiation Worker training and task qualification training for instruments on August 13 and 14. EPM has revised forms and generated desk instructions to improve the instrument program at the Cimarron site.

EPM offered to provide detailed review of the instrument program, including training on specific instruments, to NRC and/or DEQ personnel if desired. No further action required.

License Amendment Request - Work has continued on the decommissioning plan, specifically those portions that document completed decommissioning activities and other site background information. The intent is to complete those sections not dependent upon the groundwater remediation design before the design is complete. EPM will continue preparation of the decommissioning plan, such that as soon as the treatability test is complete, only those aspects of the decommissioning plan that involve groundwater treatment and disposal must be prepared before the license amendment request can be submitted. EPM NRC - DEQ - EPM Telecon Notes August 13, 2013 (Red text indicates who will take the next action) 3 of 3

Attendees Ken Kalman David Cates Jeff Lux Gerald Schlapper Mike Broderick Bill Halliburton Paul Davis Mike Logan Carol Paden Tad Dow Pam Dizikes Kate Deaton NRC - DEQ - EPM Telecon Notes September 10, 2013 (Red text indicates who will take the next action)

Administrative Issues August 13 Telecom Notes - Final notes were sent September 10, 2013. No further action required.

Bonus Check for Forced Pooling - The $77,000 bonus payment for the Trusts share of mineral rights in Section 11 was deposited in the Administrative Account. These funds, as well as funds that the Trust may receive in the future, will be distributed between the Administrative, Federal, and State accounts as agreed upon by NRC and DEQ. NRC and DEQ will provide EPM guidance on the distribution of these funds. NRC and DEQ Standby Trust - US Bank notified EPM that their annual fee for administration of the Standby Trust would be $5,000. EPM approached to other institutions regarding serving as Trustee.

Wells Fargo declined, stating the amount was too small and the duration too short to recoup their cost to set up the Trust. Country Club Bank is willing to establish the Trust, and notified EPM that their annual fee for administration of the Standby Trust would be $10,000. EPM will request approval (via e-mail) to establish the Standby Trust with US Bank as Trustee. EPM Seismic Survey - Nodal Seismic (Nodal) completed the seismic survey August 20th. Depth-to-water and total well depth measurements obtained before and after the vibrations indicate no impact from the seismic test. EPM will send Nodal the cost to EPM to collect these measurements and will request reimbursement. Nodal will send a copy of the data to EPM. The data will be archived. EPM Proposals to Sell Properties - EPM has revised the sale agreements for both properties based on DOJ recommendations. EPM has the information needed to estimate the potential future cost to the Trust associated with the 24-acre property for two scenarios:

1. The Trust retains ownership of the property, with responsibility for groundwater remediation, removal of wastes and contaminated equipment, demolition of the buildings, and disposal of the buildings and uncontaminated equipment and

2. The Trust sells the property as-is and retains responsibility for groundwater remediation only.

NRC and DEQ will re-evaluate the need for restrictions on the 117-acre parcel west of highway 74 and will notify EPM if the restrictions listed in Section 5.4 of the sale agreement for the 24-acre property should be retained in both sale agreements. EPM will complete revision of the 1 of 3

proposals and sale agreements and re-distribute to NRC, DEQ, and DOJ, requesting approval to initiate the sale process. EPM, DEQ, and NRC NRC - DEQ - EPM Telecon Notes September 10, 2013 (Red text indicates who will take the next action)

Groundwater Design Issues E[ydrogeologic Pilot Test Report Addendum - EPM submitted an addendum to the Hydrogeologic Pilot Test Report to DEQ and NRC on September 6. NRC and DEQ will review the addendum and approve or provide additional comments. NRC and DEQ Comprehensive Groundwater Data - An Excel file containing all analytical data for groundwater, surface water, coal tar, and treatability study samples was submitted to NRC and DEQ on September 6. The data was also posted on the Sharepoint site. No further action required.

Groundwater Flow Models - Groundwater flow model input was submitted to DEQ and NRC on September 6. EPM anticipates completing revision of the groundwater flow model (without groundwater extraction) within four weeks of receiving comment from DEQ on the model input.

NRC and DEQ Land Application Permit - If treatment of groundwater from the Western Alluvial Area to remove nitrate is needed to obtain a discharge permit, it may be much more economical and environmentally beneficial to remove the uranium from both BA1 and WAA groundwater, assuming that DEQ would issue a land application permit for this water (for disposal by irrigation). Land application of this water would also remove the potential for creation of algal blooms in the Cimarron River should nitrate be discharged during groundwater remediation.

EPM will schedule a meeting with DEQ Water Quality Management to see if land application of nitrate-impacted wastewater with uranium below drinking water criteria could be permitted.

EPM License Issues Release from Water Treatability Study - EPM notified NRC and DEQ of a release from the BA1 side of the treatability test. A cap on the top of the first column in the BA1 treatment train cracked, and water sprayed out through a slit in the plastic curtain onto the floor. EPM vacuumed the water up, sampled it for laboratory analysis, and will retain the water until analytical results are received. The floor of the room in which the water was spilled was surveyed for alpha and beta surface contamination (direct and removable) and exposure rate. All alpha and exposure rate readings were at background levels, and all beta measurements were either at or slightly above background levels. A Notice of Deficiency was initiated, and a Plexiglas hood was built to hang over the entire test apparatus. The test will only be resumed if Clean Harbors determines additional data is needed from the WAA treatment process, after all corrective actions have been completed. EPM Inspection - Because 2014 will be occupied with the preparation and review of the groundwater remediation plan, the conclusion of the treatability test is the last activity of any radiological 2 of 3

significance that will occur between now and 2015. EPM will notify NRC and DEQ as soon as it is determined whether the treatability test will be shut down. NRC may schedule an inspection at that time. EPM NRC - DEQ - EPM Telecon Notes September 10, 2013 (Red text indicates who will take the next action) 3 of 3

NRC - DEQ - EPM Telecon Notes October 8, 2013 (Red text indicates who will take the next action)

Attendees Ken Kalman David Cates Jeff Lux Lifeng Guo Pam Dizikes Bill Halliburton Rob Evans Paul Davis Carol Paden Tad Dow Administrative Issues September 10 Telecom Notes - Final notes were sent October 7, 2013. No further action required.

Bonus Check for Forced Pooling - The $77,000 bonus payment for the Trusts share of mineral rights in Section 11 was deposited in the Administrative Account. These funds, as well as funds that the Trust may receive in the future, will be distributed between the Administrative, Federal, and State accounts as agreed upon by NRC and DEQ. NRC and DEQ will provide EPM guidance on the distribution of these funds. NRC and DEQ Royalties for Well in Section 13 - The well in Section 11 was completed and is now producing.

EPM will check on the status of royalty payments for this well. EPM Standby Trust -EPM sent Trust Agreement documents to US Bank and is awaiting their response. The annual fee for US Bank to serve as Trustee of the Standby Trust will be $5,000.

EPM will notify NRC and DEQ when US Bank responds. EPM Proposals to Sell Properties - EPM revised the proposals and purchase and sale agreements for both properties based on DOJ recommendations, and sent the revised documents to NRC and DEQ on September 30. Comments were received from DEQ, which included input from NRC.

EPM will revise the documents accordingly and re-distribute to NRC and DEQ. Once NRC and DEQ agree that their comments have been addressed, they will authorize EPM to initiate public notification and proceed with the auction and sale of the properties. EPM Financial Reports - The financial report for the third quarter of 2013 is expected to be submitted approximately the third week of October. The financial report for the fourth quarter of 2013 (year-end report) is expected to be submitted shortly after the end of 2013. EPM 2014 Budget - A proposed budget for 2014 is expected to be submitted to NRC and DEQ on or around October 15th. EPM Groundwater Design Issues Addendum to the Etydrogeologic Pilot Test - This was submitted to DEQ and NRC on September 6. This is now complete. No further action required Groundwater Flow Models - Groundwater flow model input was submitted to DEQ and NRC on September 6. Bums & McDonnell personnel will prepare a letter-report responding to NRC and 1 of 2

DEQ comments, with both groundwater flow models (without groundwater extraction). EPM anticipates submittal of the groundwater flow models by the end of October. EPM Treatability Test Status - EPM will resume the test this week. It was thought all the data needed to go to full-scale design had been obtained. However, the last data set identified two issues:

1. The uranium concentration in the effluent from Column BA1-A increased to over 8,000 ug/1 uranium (significantly higher than the influent concentration)

2. The uranium concentration in the effluent from Column WAA-A appears to show that it became saturated after 21 days, just like Column BA1-A. This surprised us because the uranium concentration in the WAA influent is 1/16th the concentration of the BA1 influent.

Clean Harbors believes the reason for both observations is due to sulfate in the influent. That is, in the BA1 treatment train, the resin was able to absorb much more uranium than in the WAA treatment train, because the concentration of sulfate in the BA1 influent is much lower than in the WAA influent. The sulfate:uranium ratio in BA1 influent is 40:1, whereas the sulfate:uranium ratio in WAA influent is 426:1 (both on an equivalent basis).

The resin preferentially absorbs uranium, but eventually the sulfate starts replacing the uranium; when this occurs the effluent uranium concentration can exceed the influent uranium concentration. Unfortunately, effluent from anion resin columns has not been analyzed for sulfate. The system will be turned on for another week, and sulfate will be added to uranium and nitrate in subsequent analyses. Samples will be collected on a daily basis for a week. The uranium concentration in Column BA1-B effluent should transition from less than to greater than the influent concentration. It is posited that the sulfate concentration in the effluent will decrease in proportion to the increase in uranium concentration. If this is the case, Clean Harbors should have the information data needed to complete the full-scale design. EPM Land Application Permit - DEQ Water Quality Management requested analysis of effluent for phosphorus, Total Kjeldahl Nitrogen (TKN) and ammonia to evaluate land application of nitrate-impacted wastewater with uranium below drinking water criteria. EPM will re-start the treatability test (likely later this week), and will collect effluent samples for these analyses.

Analytical results will be provided to DEQ within four weeks of sample collection. EPM License Issues Inspection - Because 2014 will be occupied with the preparation and review of the groundwater remediation plan, the conclusion of the treatability test is the last activity of any radiological significance that will occur between now and 2015. EPM will notify NRC and DEQ when the treatability test will be shut down. NRC may schedule an inspection at that time. EPM NRC - DEQ - EPM Telecon Notes October 8, 2013 (Red text indicates who will take the next action) 2 of 2

NRC - DEQ - EPM Telecon Notes November 19, 2013 (Red text indicates who will take the next action)

Attendees Ken Kalman Lifeng Guo Varughese Kurian Gerald Schlapper David Cates Pam Dizikes Tad Dow Paul Davis Jeff Lux Bill E[alliburton Mike Logan Administrative Issues October 8 Telecom Notes - Final notes were sent November 19, 2013. No further action required.

Proposed 2014 Budget - A proposed budget for 2014 was submitted to NRC and DEQ on October 24th. NRC and DEQ will comment on the draft budget, and EPM will revise accordingly. NRC and DEQ Bonus Check for Forced Pooling - The $77,000 bonus payment for the Trusts share of mineral rights in Section 11 was deposited in the Administrative Account. An additional check for

$180,761.24 was received as a bonus payment for Section 12 property which is being force pooled. These funds, as well as royalty checks the Trust may receive in the future, will be distributed as follows: 10% to the Administrative Account, 10% to the Federal Account, and 80% to the State Account, as agreed upon by NRC and DEQ and approved by EPA and DOJ.

NRC and DEQ will be notified when the transfer of funds is complete. EPM Royalties for Well in Section 11 - The well in Section 11 was completed and is now producing.

Thus far, EPM has learned that royalty payments are typically issued on an annual basis. EPM will attempt to determine the production of the well and estimate potential royalty payments based on current production. EPM will attend a seminar in Oklahoma City covering land law and oil and gas rights and payments. EPM Standby Trust -EPM sent Draft Trust Agreement documents, including markups from US Bank, to NRC and is awaiting their review and response to edits made to the Model Agreement. NRC Proposals to Sell Properties -DEQ noted that the revised proposal and sale agreement submitted October 8th, contained quitclaim deeds that, in conflict with the sale agreement to which they were attached, transferred mineral rights to the buyer. In addition, the proposals to sell the properties did not contain the new distribution of funding agreed upon by DEQ and NRC.

Finally, DEQ noted that Section 5.4(d) of the sale agreement for the 24-acre property stated that use restrictions would be lifted when Site remediation is complete. However, unless the concentrations of COCs in groundwater underlying the property are below MCLs, the restrictions will not be lifted. EPM will revise the documents to reflect these comments, re-submit them to NRC and DEQ, and initiate public notification that the properties will be sold.

EPM 1 of 3

Financial Reports - The financial report for the third quarter of 2013 was submitted October 31st. The financial report for the fourth quarter of 2013 (year-end report) is expected to be submitted shortly after the end of 2013. EPM Public Information Notice - EPM revised the public information notice in accordance with comments received by DEQ. The notice will be distributed the week of November 25 - 27.

EPM Damage to MOFF Building - The front door and one window in front of the MOFF building have been broken. EPM will report the damage to the County sheriff. EPM will check to see if there is a key to the lock on the front door, and will install plywood in the door and window. If a key to the existing lock is not found, EPM will arrange to have the lock on the front door. EPM Groundwater Design Issues Groundwater Flow Models - Bums & McDonnell personnel are preparing a letter-report responding to NRC and DEQ comments, with both groundwater flow models (without groundwater extraction). EPM anticipates submittal of the groundwater flow models by the end of the year. EPM Treatability Test Status - The test treatability test was resumed, with samples collected from all columns on a daily basis for seven days. The data from these results (data review and validation is not complete for this data) identified three issues:

1. The uranium concentration in the effluent from Column BA1-A increased to over 13,000 ug/1 uranium (significantly higher than the 4,500 ug/1 influent concentration), and then began to decline. A similar trend was noted in the effluent from Column WAA-A.

2. Following the initial spike, the concentration in the effluent from both columns declined each day samples were collected, but remained above influent concentrations.

3. The cation resin, used to remove calcium and magnesium from influent water prior to uranium removal, may have retained between 2% and 3% of the uranium in the influent.

The influent and effluent concentration results are not so precise that this could not be an artifact of analytical uncertainty.

NRC - DEQ - EPM Telecon Notes November 19, 2013 (Red text indicates who will take the next action)

The resin contained in all ten anion resin columns will be sampled and analyzed for uranium concentration, nitrate, and sulfate. A sample of the top foot of resin in each cation resin tank, as well as a composite sample, will be analyzed for the same parameters, plus calcium and magnesium. Three anion resin column samples (which contain the highest concentrations of uranium) will also be analyzed for select transuranics. Transuranic analysis is needed to determine if the resin can be a candidate for uranium recovery rather than disposal. With reciept of the resin data, Clean Harbors will the data needed to complete the full-scale design. EPM Land Application Permit - DEQ Water Quality Management requested analysis of effluent for phosphorus, Total Kjeldahl Nitrogen (TKN) and ammonia to evaluate land application of nitrate-impacted wastewater with uranium below drinking water criteria. EPM collected effluent 2 of 3

samples for these analyses. Analytical results have been received and will be provided to DEQ as soon as data review has been completed. EPM License Issues Proposed Change to 10 CFR 74 - NRC published proposed changes to 10 CFR 74 in the November 8, 2013 Federal Register. 10 CFR 74 contains the requirements for a material controls and accountability (MC&A) program. The current version references an effective kilogram as the trigger for development and implementation of an MC&A program; the new version cites a 350-gram possession limit as the trigger. Consequently, the proposed rule would require the development of an MC&A program for the Cimarron site. EPM, along with EPMs health physics contractor, Enercon Services, will review the proposed rule and submit comments as appropriate. EPM Inspection - Because 2014 will be occupied with the preparation and review of the groundwater remediation plan, the conclusion of the treatability test is the last activity of any radiological significance that will occur between now and 2015. EPM will notify NRC and DEQ when the treatability test will be shut down and release surveys performed. NRC will likely schedule an inspection during the first quarter of 2014 to review records generated during and after the treatability test. EPM NRC - DEQ - EPM Telecon Notes November 19, 2013 (Red text indicates who will take the next action) 3 of 3

The purpose of these notes is to document the status of various activities on the Cimarron site in lieu of a monthly teleconference.

Administrative Issues November 19 Telecom Notes - Final notes were sent December 10, 2013. No further action required.

Proposed 2014 Budget - A proposed budget for 2014 was submitted to NRC and DEQ on October 24th. NRC commented on the draft budget. EPM will revise and resubmit by 12/13.

EPM Bonus Check for Forced Pooling - A total of $257,761.24 in bonus payments for Section 11 and 12 property has been received. These funds, as well as royalty checks the Trust may receive in the future, will be distributed as follows: 10% to the Administrative Account, 10% to the Federal Account, and 80% to the State Account. NRC and DEQ will be notified when the transfer of funds is complete. EPM Royalties for Well in Section 11 - An oil well drilled in Section 11 is now in production. On December 11, EPM will attend a seminar in Oklahoma City covering land law and oil and gas rights and payments, and will notify NRC and DEQ when more information is available. EPM Standby Trust -EPM sent Draft Trust Agreement documents, including markups from US Bank, to NRC and is awaiting their review and response to edits made to the Model Agreement. NRC Proposals to Sell Properties - EPM has directed Bums & McDonnell Real Estate personnel to initiate the public notification process for the sale of both parcels of property. EPM will send copies of notices to NRC and DEQ and keep them apprised of progress made toward the disposition of these properties. EPM Damage to MOFF Building - The front door and several windows in the MOFF building have been broken. EPM reported the damage to the County sheriff. EPM will arrange to have expanded steel placed over the doors and windows along with other work (e.g., locksmith to install a lock on the front door) to prevent unauthorized access. EPM Groundwater Design Issues Groundwater Flow Models - Bums & McDonnell personnel are preparing a letter-report responding to NRC and DEQ comments, with both groundwater flow models (without groundwater extraction). EPM anticipates submittal of the groundwater flow models by the end of the year. EPM Treatability Test Status - The resin contained in all ten anion resin columns will be sampled and analyzed for uranium concentration, nitrate, and sulfate. A sample of the top foot of resin in each cation resin tank, as well as a composite sample, will be analyzed for the same parameters, plus calcium and magnesium. Several anion resin column samples (which contain the highest concentrations of uranium) will also be analyzed for select transuranics. Transuranic analysis is Cimarron Status Update December 10, 2013 (Red text indicates who will take the next action) 1 of 2

needed to determine if the resin can be a candidate for uranium recovery rather than disposal.

With receipt of the resin data, Clean Harbors prepare a report on the treatability test for submittal to NRC and DEQ. EPM Land Application Permit - DEQ Water Quality Management requested analysis of effluent for phosphorus, Total Kjeldahl Nitrogen (TKN) and ammonia to evaluate land application of nitrate-impacted wastewater with uranium below drinking water criteria. EPM collected effluent samples for these analyses. Analytical results have been provided to DEQ. EPM EPM has scheduled a kick-off meeting for EPM, Bums & McDonnell, Clean Harbors, and Enercon personnel who will prepare various sections of the Decommissioning Plan.

License Issues Proposed Change to 10 CFR 74 - The proposed rule requires the development of an MC&A program for the Cimarron site. EPM, along with EPMs health physics contractor, Enercon Services, will review the proposed rule and submit comments as appropriate. EPM License Possession Limit - License amendment No. 4, issued in April 1986, authorized possession of 6,000 grams of < 5 weight percent U-235. This license amendment was requested an amendment to provide latitude for the licensee to accumulate sufficient material on site to load several trucks with contaminated material for transportation to a licensed disposal facility.

EPM does not desire to increase possession limit for U-235 beyond 1,500 grams, but is considering requesting that U-235 contained in resin packaged in containers for shipment for disposal or recycle not be included in the possession limit to provide flexibility in groundwater remediation. EPM will schedule a teleconference with NRC personnel in 2014 to discuss this further. EPM Inspection - Because 2014 will be occupied with the preparation and review of the groundwater remediation plan, the conclusion of the treatability test is the last activity of any radiological significance that will occur between now and 2015. EPM will notify NRC and DEQ when the treatability test will be shut down and release surveys performed. NRC will likely schedule an inspection during the first quarter of 2014 to review records generated during and after the treatability test. EPM Cimarron Status Update December 10, 2013 (Red text indicates who will take the next action) 2 of 2