ML21076A456

Cimarron Environmental Response Trust Facility Decommissioning Plan, Revision 2

ML21076A456
Person / Time
Site:	07000925
Issue date:	02/26/2021
From:	Lux J Environmental Properties Management
To:	Davis P, Robert Evans, James Smith Office of Nuclear Material Safety and Safeguards, NRC Region 4, State of OK, Dept of Environmental Quality (DEQ)
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Download: ML21076A456 (2)

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environmental properties management. LLC February 26, 2021 Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Washington, DC 20555-0001 Mr. Paul Davis Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101 Mr. Robert Evans U.S. Nuclear Regulatory Commission 1600 East Lamar Blvd.

Arlington, TX 76011-4511 Re: Cimarron Environmental Response Trust Facility Decommissioning Plan - Revision 2 Docket No. 070-00925; License No. SNM-928

Dear Sirs:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein to the U. S. Nuclear Regulatory Commission (NRC) and the Oklahoma Department of Environmental Quality (DEQ) Facility Decommissioning Plan - Rev 2 (the DP).

The 2015 Facility Decommissioning Plan was submitted to NRC on December 31, 2015. The NRC completed both the acceptance review and the detailed technical review of that document, and EPM responded to the RAIs that resulted from the detailed technical review. Responding to RAIs resulted in the need to perform additional field work to complete responses to RAIs and to prepare the 2018 submittal of Facility Decommissioning Plan - Rev 1.

Following NRCs acceptance review of the 2018 Facility Decommissioning Plan - Rev 1, the NRC issued a February 28, 2019 request for supplemental information. Responding to that request for supplemental information resulted in the need to perform additional field work and to evaluate the revise the estimated cost to operate remediation systems and dispose of wastes generated by water treatment systems. Available funding was determined to be insufficient to provide for full implementation of the decommissioning plan, and the NRC and the DEQ agreed that a phased approach to decommissioning must be developed and implemented.

9400 Ward Parkway

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

• jlux@envpm.com

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environmental properties management. LLC Mr. James Smith, et. al.

February 26, 2021 Page 2 Both agencies agreed that the highest priority is the removal of sufficient uranium from groundwater to achieve termination of the NRC license. The decommissioning plan was therefore revised to provide for a phased approach to groundwater remediation, in which the first phase targets only those areas in which the concentration of uranium in groundwater exceeds the NRC criterion for unrestricted release. The cost and schedule to achieve license termination, based upon the implementation of only Phase I, would be estimated to determine if available funding is sufficient to achieve license termination.

Should funding be available when the NRC criterion is met, groundwater treatment could continue to further reduce the concentration of uranium in groundwater, or groundwater remediation could be expanded to other areas to address non-radiological contaminants. Because the extent of additional groundwater remediation that could be implemented after reaching the NRC criterion cannot be defined, the decision was made to retain all the groundwater extraction and treatment infrastructure in this Facility Decommissioning Plan - Rev 2 (this Plan) that was provided for in the groundwater extraction and treatment systems for all areas that had been addressed in the 2018 Facility Decommissioning Plan - Rev 1.

To eliminate the need for agency personnel to review the numerous documents submitted between the November 2018 submittal of Facility Decommissioning Plan - Rev 1 and the submittal of this Plan (Rev 2), we have incorporated all responses to the NRCs request for supplemental information. EPM believes this Plan may be treated as a comprehensive document resulting from the February 2019 request for supplemental information, and the NRC may proceed directly to the detailed technical review this Plan.

Please call me at (405) 642-5152 or e-mail me at jlux@envpm.com if you desire clarification or if additional information is needed.

Sincerely, Jeff Lux, P.E.

Trustee Project Manager Enclosure