ML20253A327

Cimarron Remediation Site - Cultural Resources Survey Report, Revision 1

ML20253A327
Person / Time
Site:	07000925
Issue date:	09/09/2020
From:	Lux J Environmental Properties Management
To:	Christine Pineda Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20254A140	List: ML20253A327
References
Download: ML20253A327 (2)

Text

September 9, 2020 Ms. Christine Pineda U.S. Nuclear Regulatory Commission Mail Stop: TWFN/4B72 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket No. 070-00925; License No. SNM-928 Cimarron Remediation Site - Cultural Resources Survey Report - Revision 1

Dear Ms. Pineda:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein three copies of Phase I Cultural Resources Survey of the Cimarron Environmental Response Trust Property. This report has been revised based on comments received from the Oklahoma Archeological Society (OAS) and the Oklahoma Historic Preservation Office (OHPO).

You had noted that the report did not make it clear that the 530 acres of property designated as the Area of Potential Interest (APE) included property not owned by the CERT. Approximately 24 acres of property containing the MOFF Building and Warehouse #4 were sold to Cimarron Holdings LLC in 2015, and approximately one acre of property containing the Emergency Response Building was sold to Cimarron Holdings LLC in 2018. You requested that the reason for including property not owned by the CERT be addressed in a revision of the report.

In the Purchase & Sale Agreement executed for the sale of the 24-acre property, the Trust retained responsibility for any remediation that would be needed to achieve State remediation criteria. The Buyer granted access to the properties as needed to install infrastructure, run utilities, and complete remediation of the groundwater on that property.

Consequently, approximately 25 acres containing several of the former operating buildings is currently owned by Cimarron Holdings, LLC. Because the CERT retains responsibility for any groundwater remediation that may occur on that property, the Decommissioning Plan includes design drawings for the following activities associated with groundwater remediation:

Installation of utilities, Installation of a groundwater extraction well with associated piping, controls, etc., and Conducting periodic groundwater monitoring.

9400 Ward Parkway

• Kansas City, MO 64114 Tel: 405-642-5152

• jlux@envpm.com

Ms. Christine Pineda U.S. Nuclear Regulatory Commission September 9, 2020 Page 2 Consequently, the decision was made to include that property in the APE, and the owner authorized the CERT to include the property in the cultural resources survey. This was explained briefly in Section 1.1 of the enclosed report.

Since the submission of the initial report in July 2020, information on the historic structures identified in the survey was input into the OHPOs Historic Preservation Resource Identification Forms. Those forms have been attached to the revised report as an Appendix D.

It is our understanding that you will forward copies of the report to the OAS and the SHPO.

Please notify us when this effort should be considered finished and we will revise Section 5 of the decommissioning plan and add this report to Appendix E of the decommissioning plan.

Thanks.

Sincerely, Jeff Lux, P.E.

Trustee Project Manager Enclosure cc: NRC Public Document Room (electronic copy only)

James Smith, NRC (accession number only)

Robert Evans (accession number only)

Paul Davis (electronic copy only)