ML20087H742

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Environmental Properties Management, LLC - License Amendment Request to Redefine the Licensed Area
ML20087H742
Person / Time
Site: 07000925
Issue date: 03/24/2020
From: Lux J
Environmental Properties Management
To: Kenneth Kalman
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML20087H742 (3)
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Text

March 24, 2020 Mr. Ken Kalman U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket No.70-925; License No. SNM-928 Addendum 2 to the November 22, 2019 License Amendment Request to Redefine the Licensed Area

Dear Sirs:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submitted on November 22, 2019, to the US Nuclear Regulatory Commission (NRC), a request to amend License SNM-928 to re-define the area under license. The license amendment request (LAR) included three figures showing the proposed licensed area and those areas within the proposed licensed area to which access will be controlled to restrict access to licensed material or radioactivity. Those three figures were provided in Attachment 1 to the LAR.

The Cimarron Site had been divided into 15 Subareas which had been delineated for the purpose of conducting final status surveys for buildings, equipment, and soil. As Subareas were demonstrated to be decommissioned to comply with release criteria, the NRC performed confirmatory surveys to demonstrate that the Subareas satisfied the criteria stipulated in the license, and they were released from the license. The current license is now defined by the three Subareas (Subareas F, G, and N) which the NRC has not released for unrestricted use.

It was later determined that portions of Subareas which had been released from license SNM-928 contained groundwater in which the concentration of uranium exceeds the criterion stipulated in the license. The decommissioning of the site will involve the extraction, transfer, and treatment of groundwater, and remediation and treatment components will be constructed in areas which are no longer licensed by the NRC. The November 2019 LAR proposes to redefine the licensed area so that areas which are (and will remain) releasable are not licensed, and all areas within which groundwater exceeds license criteria, or in which licensed material will be accumulated in treatment media will be brought under license.

In an e-mail dated February 14, 2020, you requested an addendum to the November 2019 LAR that provided a map showing both the current licensed area and the proposed licensed area. That addendum was submitted on February 24, 2020.

On March 20, 2020, you requested a second addendum to the LAR which identifies the number of acres in each Subarea that has been released from the license which is proposed to be brought back under the license, and the number of acres in Subareas still under license that will be

released from the license in the process of redefining the licensed area. Figure 3-R (enclosed) is a replacement for Figure 3 from the November 2019 LAR. Per your request, a table listing the number of acres in each Subarea that will remain under license has been added to Figure 3. In addition, now that the 90% design has been completed, it shows the piping runs as they will be shown in 90% design drawings.

Approximately 52 acres of property are currently under license. The NRC has performed confirmatory surveys demonstrating that approximately 32 acres of that property, consisting of Subareas G and N, are releasable for unrestricted us. The license amendment defining the licensed area in accordance with the November 2019 LAR will result in a total of 54.3 acres under license.

EPM requests that Figure 3-R be accepted as a replacement for Figure 3 in the November 22, 2091 license amendment request. License Condition 9 can then be amended to designate as the Authorized Place of Use the area delineated in Attachment 2 and Figure 3-R of the November 22, 2019 license amendment request, as amended in letters dated February 24, 2020, and March 20, 2020. (or equivalent language).

Please contact me at (405) 642-5152 or e-mail me at jlux@envpm.com if you have questions or desire clarification. Thank you.

Sincerely, Jeff Lux, P.E.

Project Manager Cc:

Robert Evans, NRC Region IV Paul Davis, DEQ Michael Broderick, DEQ NRC Public Document Room (electronic copy)

Enclosure

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MM SUBAREA A SUBAREA B SUBAREA C SUBAREA E SUBAREA D SUBAREA H SUBAREA G SUBAREA I SUBAREA F SUBAREA N SUBAREA K SUBAREA L SUBAREA O SUBAREA M SUBAREA O GE-WU-01 GE-WAA-15 GE-WAA-14 GE-WAA-13 GE-WAA-12 GE-WAA-11 GE-WAA-10 GE-WAA-09 GE-WAA-08 GE-WAA-07 GE-WAA-06 GE-WAA-03 GE-WAA-02 GE-WAA-01 GE-WAA-04 GE-WAA-05 GE-BA1-09 GE-BA1-08 GE-BA1-07 GE-BA1-06 GE-BA1-05 GE-BA1-04 GE-BA1-03 GE-BA1-02 GETR-WU-02A GETR-WU-01A GETR-BA1-01B GETR-BA1-01A GETR-BA1-02A Pit 1 Pit 2 Pit 3 1369 1373 1372 1368 T-99 T-98 T-97 1367 1371 T-96 T-95 T-94 T-93 T-91 T-90 T-89 T-88 T-87 T-86 T-85 T-84 T-83 T-82 T-81 T-79 T-78 T-77 T-76 T-75 T-74 T-73 T-72 T-68 T-67T-66 T-65 T-64 T-63 T-62 T-61 T-60 T-59 T-58 T-57 T-56 T-55 T-53 T-52 T-51 1365 1363 1344 1343 T-92R T-103 T-102 T-101 T-70R 02W62 02W45 02W44 02W38 02W36 02W35 02W33 02W23 TMW-24 1395 1396 1397 1398 1399 1400 1401 1402 1403 1393 1389 1387 1385 1383 1381 1380 1379 1378 1377 1376 1375 1374 1360 1359 1358 1357 1355 1354 1353 1352 1350 1349 1348 1347 1340 1337 1334 1333 1331 1330 1329 1326 1325 1324 1322 1320 1313 1312 1311 TR-05 TR-04 TR-03 TR-01 1336A 1335A 1327B 1319A-3 1409 1407 1408 1394 1392 1391 1390 1388 1386 1384 1382 1345 1341 1338 1314 TR-07 TR-06 1316R 02W53 02W52 02W51 02W41 02W25 1319B-5 1319B-4 1319B-2 1339 1332 1328 1323 1321 1319C-3 1319C-2 TR-09 MWWA-09 MWWA-03 2092000 2092000 2094000 2094000 2096000 2096000 320000 320000 322000 322000 Path: C:\\Users\\belockwood\\Desktop\\CERT 2020 Decomm Plan GIS\\Licensed and Controlled Areas - 2019 Updates\\Figure 3-R_ Licensed Corridor.mxd COPYRIGHT © 2018 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Legend M

MONITORING WELL IN ALLUVIUM M

MONITORING WELL IN SANDSTONE A M

MONITORING WELL IN SANDSTONE B M

MONITORING WELL IN SANDSTONE C M

MONITORING WELL IN TRANSITION ZONE EXTRACTION WELL INJECTION WELL INJECTION PIPING EXTRACTION PIPING EXTRACTION TRENCH INJECTION TRENCH CONTROLLED AREA TREATMENT FACILITY BUILDING SURVEYED ROAD CENTERLINE LICENSED AREA BURIAL AREA 4 (BA4)

FINAL STATUS SURVEY SUBAREAS MODIFIED SUBAREAS G & N COORDINATES :

(NAD 83) STATE PLANE OKLAHOMA NORTH FEET DATE :

REVISION 0 PRODUCED - 3/25/2020+/-

0 425 850 Feet FIGURE 3-R LICENSED AND CONTROLLED AREAS - SITE WIDE Notes:

1) The controlled area is the fenced area.
2) Hatched areas denote parts of subareas G & N that do not fall within the licensed areas.
3) Acreage calculated from subareas within the licensed area.

IMAGE SOURCE: GOOGLE EARTH JUNE 2017 AREA TOTAL ACRES LICENSED AREA 54.3 SUBAREA B 0.04 SUBAREA C 2.02 SUBAREA D 4.63 SUBAREA E 1.69 SUBAREA F 19.16 SUBAREA G 1.56 SUBAREA H 18.75 SUBAREA I 0.96 SUBAREA L 0.10 SUBAREA M 1.95 SUBAREA N 1.76 SUBAREA O 1.66

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