ML22284A145

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Cimarron Environmental Response Trust, Cimarron Site Decommissioning Plan
ML22284A145
Person / Time
Site: 07000925
Issue date: 10/07/2022
From: Lux J
Environmental Properties Management
To: Davis P, Robert Evans, James Smith
Document Control Desk, Office of Nuclear Material Safety and Safeguards
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ML22286A041 List:
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Download: ML22284A145 (2)
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environmental October 7, 2022 properties management, LLC Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 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; Suite 400 Arlington, TX 76011-4511 Re: Docket No. 07000925; License No. SNM-928 Cimarron Environmental Response Trust Cimarron Site Decommissioning Plan

Dear Sirs:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein Site Decommissioning Plan - Rev 3 (D-Plan) to the U. S. Nuclear Regulatory Commission (NRC) and the Oklahoma Department of Environmental Quality (DEQ). Section 6 of the D-Plan, Revisions to the License, contains requests to amend the license to:

  • Authorize the possession of Tc-99 as a contaminant in groundwater, and distinguish between the possession limit for in-process U-235 and U-235 in packaged waste that complies with fissile exemption criteria,
  • Clarify the authorized place of use to include areas in which groundwater exceeding the NRC Criterion is present in the subsurface and area where such licensed material will be transported or managed,
  • Eliminate references to documents that are no longer relevant to ongoing decommissioning activities, and
  • Approve the D-Plan.

The CERTs ability to perform this decommissioning effort is constrained by the funding available to the Trust. Consequently, it is imperative that the NRC complete the review and approval of this D-Plan as expeditiously as is practical.

9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com

EPM believes that both NRC and DEQ personnel have reviewed most of the content of this D-Plan several times, and we believe that acceptance of this D-Plan and expeditious technical review is not only a reasonable expectation, but is in the best interest of both regulatory agencies, in that it preserves the maximum amount of funding for the actual decommissioning of the site.

Please contact me atjlux@envpm.com or at 405-642-5152 should you desire any further information concerning this submittal. Thank you.

Sincerely, Jeff Lux, P.E.

Project Manager cc: Michael Broderick, Oklahoma Department of Environmental Quality NRC Public Document Room vcpsubmitals@deq.ok.gov 9400 Ward Parkway

  • Kansas City, MO 64114 Tel: 405-642-5152
  • jlux@envpm.com
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