ML21230A250

Email Dated 5/3/2021 from J. Lux, Environmental Properties Management, LLC, to J. Smith, NRC, Cimarron Environmental Response Trust Regarding License Application for the Re-Definition of the Licensed Area

ML21230A250
Person / Time
Site:	07000925
Issue date:	05/03/2021
From:	Lux J Environmental Properties Management
To:	Jennifer Davis, Saxton J, James Smith NRC/NMSS/DDUWP/MDB
James Smith, 301-415-6103
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ML21230A245	List: ML21230A249 ML21230A250
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Download: ML21230A250 (2)

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From: Lux, Jeff J To: Smith, James; Saxton, John; J. Paul Davis; Michael Broderick (mike.broderick@deq.ok.gov); Evans, Robert Cc: Halliburton, Bill; Jay Maisler; Charles Beatty

Subject:

[External_Sender] License Application for the Re-Definition of the Licensed Area Date: Monday, May 03, 2021 2:49:45 PM Attachments: 2021-05-03 EPM - LAR - Licensed Area.pdf Attached please find a license amendment request (LAR) to re-define the licensed area at the Cimarron Site. I believe it addresses all of the issues that have been identified since the submittal of the original LAR in November 2019, including the impact of the decision to implement a phased approach to groundwater remediation. To send this via e-mail, I had to compress it; Jill Zaitz will make it acceptable to ADAMS and electronically submit it.

There is one issue about which we did not specifically say what we would like the license to read: the Authorized Place of Use. The address that is in the current license isnt exactly correct, and it certainly doesnt reflect what we need, but Im not sure how it should be addressed. Rather than include a lot of verbiage that just sounds like we dont really know what we want, I thought I would provide a little background for you.

Many years ago, Cimarron Corporation opened a post office box in Crescent, OK, because most of the people still working at the site lived in or near Crescent. Because FedEx, UPS. etc., cant deliver to a PO box, the licensee started using 1/2 mile North of the Highway 33 and Highway 74 near Crescent Oklahoma, and that became the Authorized Place of Use.

The Crescent PO box was closed long ago, and the office was moved from temporary trailers set up near the former warehouse building. The licensee asked the Post Office for a street address, and the Site was given the address 100 Highway 74 North, Guthrie, OK 73044.

Before the CERT was created and the license transferred, most of the property (including the former buildings) was released from the license and is no longer licensed by the NRC (per SNM-928). So the licensees office (now the CERT office) is no longer on licensed property. So the licensed site is no longer at 100 Highway 74 North, but the licensees office is. And the licensed site has no address and no buildings in which to store drums of contaminated material or sources used to source-check instruments.

The licensed area needs to include all the area shown in the attached LAR, but Im not sure how to address the CERT office not being in the licensed site, particularly since the office will be relocated as soon as construction is complete, before groundwater remediation begins. Im open to suggestions, which you all may want to address in your acceptance or technical review.

This is not an easy thing to communicate in writing, so if you need clarification, please call me at 405-642-5152. Thanks.

Jeff Lux, P.E.

Project Manager Environmental Properties Management LLC A subsidiary of Burns & McDonnell Engineering Company

405-642-5152