ML22228A196

Letter Dated May 31 2022, from P. Davis, Oklahoma Department of Environmental Quality, to J. Lux, Cimarron, Regarding Uranium Daughters in Groundwater

ML22228A196
Person / Time
Site:	07000925
Issue date:	05/31/2022
From:	Jennifer Davis State of OK, Dept of Environmental Quality (DEQ)
To:	Lux J Cimarron Environmental Response Trust, Environmental Properties Management, Office of Nuclear Material Safety and Safeguards
James Smith, 301-415-6103
References
Download: ML22228A196 (1)

Text

Scott A. Thompson Ol(LAHOMA Kevin Stitt Executive Director Environmental Governor Quality May 31 , 2022 Mr. Jeff Lux, Senior Project Manager Environmental Properties Management LLC 615 N. Hudson; Suite 200 Oklahoma City, OK 73102 Re: Uranium Daughters in Groundwater Cimarron Environmental Response Trust, NRC Lice nse No. SNM-928

Dear Mr. Lux:

Thank you for the subject letter, dated May 2, 2022, in response to an infom1atio n request by the Nuclear Regulatory Commission (NRC). As a Beneficiary of the Trust, DEQ has the following questions, intended to clarify the subject letter, and perhaps expedite NRC approval of the Decommissioning Plan (DP) . DEQ does not require a direct response.

In Attachment 3, should the third and fourth table both be labeled " Activity (pCi/µg) of total U"? Both appear to describe the same four samples, but the third table appears to describe calculated activity of each isotope per microgram of material and the fourth appears to describe calculated activity of each isotope as a percentage of the total activity of the sample.

The section " Daughter Radionuclides in the Feedstock" estimates the time for various Uranium daughters to reach seven half-lives and approx imate the ac ti vity of the parent isotope. For the decay chain for the remaining Uranium-235 (U-235), would the time fo r Protactinium-231 (Pa-231) to achieve the act ivity of the parent be *'over two centuries", which is less than one half-life (32,760 years) for Pa-231 , or "over two hundred millennia?

Simila rly, for the decay chain for the remaining U-238 , should the time for "newly-grown U-234" (i .e., not received in the feedstock) to achieve the same acti vity as the U-238 be " most of two millennia which is less than one half-life (245,500 years) fo r U-234) or *'well over a m illion years"?

If you have questions or comments, I can be reached by telephone at 405-702-5132 or by email at j.paul .davis(cv,deq.ok.gov.

Environmental Programs Specialist, LPD c: ;Jmnes Smi~h, NRG.

Robert Evans, NRC 707 N. ROBINSON ST.. OKLAHOMA CITY, OK 73102

• OFFICE : 405-702-0100 STATE OF OKLAHOMA

• OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

• DEQ.OK.GOV