ML23188A087
| ML23188A087 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 06/27/2023 |
| From: | Cimarron Environmental Response Trust, Environmental Properties Management |
| To: | NRC Region 4, Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML23188A087 (1) | |
Text
Cimarron Environmental Response Trust Regulatory and Licensing Issues PRESENTED TO:
U.S. NUCLEAR REGULATORY COMMISSION U.S. NUCLEAR REGULATORY COMMISSION - REGION IV OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY JUNE 27, 2023
Licensing History SNM-928 - URANIUM FUEL PRODUCTION Issued 1965 Renewed 1983 - 21 amendments since then 35-12636 SOURCE MATERIAL LICENSE FOR SEALED SOURCES Issued 1965 Terminated 1998 SNM-1174 - MIXED OXIDE FUEL PRODUCTION Issued 1970 Terminated 1993
Licensee History
Decommissioning History Impoundments & Pipelines 1978 - Decommissioned 2001 - Released from License Buildings 1990 - MOFF Decommissioned 1993 - MOFF License Terminated 1997 - All Buildings Decommissioned 2002 - All Buildings Released Waste & Soil 2001 - Decommissioned All This Decommissioning Was Complete Pre-Trust
Cimarron Environmental Response Trust Funding Tronox settlement Letter of credit Anadarko litigation Interest Income from oil & gas leases Four Trust Accounts Administrative Account Federal Cost Account State Cost Account Standby Trust Objective - Remediate to Federal and State Criteria
SDMP vs. LTR (Cimarron is SDMP, not LTR)
SDMP 1981 Branch Technical Position for Soil/Waste 1987 Guidelines for Surface Contamination NUREG/CR-5849 for Final Status Surveys 180 pCi/L Total Uranium for Groundwater (DCGL?)
License Termination Based on Concentration LTR Derived Concentration Goal Levels (DCGLs) for Soil/Waste/Groundwater MARSAME for Release of Facilities & Equipment MARSSIM for Final Status Surveys License Termination Based on Residual Dose
Triggering the LTR 1997 - Subpart E states that if a decommissioning plan is approved by August 20, 1999, the licensee remains under the SDMP.
2000 - 2004 - NRC believed that submitting a new decommissioning plan triggered the LTR.
2005 - NRC ruled that as long as the licensee does not propose to change any decommissioning criteria, the licensee can complete decommissioning under the SDMP.
Only proposing to change the decommissioning criteria will force Cimarron to comply with the LTR.
Impact of Transfer to the LTR Development of DCGLs Soil Criterion < 30 pCi/g Uranium?
Groundwater Criterion < 180 pCi/L?
Dose Impact of Tc-99?
Final Status Survey Soil Data Compliant with MARSSIM?
Re-visit Release of All Former Subareas?
Impact on Divested Properties?
License Termination Not Possible With Existing Funding
1999 Environmental Assessment NRC staff finds it more appropriate to use the 0.1 mSv/yr (100 mrem/yr) dose limit of 10 CFR 20.1301 for individual members of the public for groundwater and all other exposure pathways at the Cimarron site.
The impact of this statement on the termination of SNM-928 has never been determined.
Addressing Tc-99 in SNM-928 1996 - NRC has determined that you should request an amendment to your license for possession of Technetium-99 (Tc-99).
1997 - the maximum contamination level is 3,790 pCi/L. and NRC staff has determined that radiological contaminants need not be specifically listed Many times the 100 µCi licensable quantity of Tc-99 will accumulate in ion exchange resin, so Tc-99 will be listed in the license.
Released and Divested Property CERT received ~ 800 acres of property.
52 acres of that property were under license.
NRC agrees that Subareas G and N (32 acres) are releasable.
Most groundwater exceeding DCGL is not in licensed property
Released and Divested Property CERT received ~ 800 acres of property.
Approximately 280 acres (4 parcels) have been divested.
NRC & DEQ approved the divestiture with no requirement to isolate or maintain control
Prior to CERT, licensee committed to retain property until license termination.
CERT Trust Agreement provides for divestiture of property that has been released.
NRC stated that the CERT needs to maintain control and isolation of divested property.
NRC states that dose from divested property will be included in dose assessment prior to license termination.
Released and Divested Property
The D-Plan proposes to bring under license areas where:
Uranium concentration in groundwater exceeds the DCGL.
Extracted groundwater is stored and/or transferred to the WATF for treatment.
Uranium is accumulated in ion exchange resin in groundwater treatment systems.
Spent resin and other LLRW is stored.
Re-define Licensed Area
Re-define Licensed Area Western Area Burial Area #1
Possession limit of 1,200 grams U-235 applies to in-process material only.
Possession limit for total uranium on site is 0.5 effective kilograms Possession Limit for Uranium and U-235
The D-Plan proposes to amend no-longer-relevant license conditions:
Condition 10 - Final surveys and on-site disposal.
Condition 23 - Authorizes burial of contaminated soil in an on-site disposal cell.
Condition 26 - Tie-down documentation related to previous radiation protection documents.
Amending License Conditions (Obsolete Conditions)
Condition 27 - Site Decommissioning 27.a - Supplements to the 1995 Decommissioning Plan.
27.b - All wells < DCGL for 8 quarters.
27.c - Volumetric averaging in two Subarea O areas.
27.d - Access control provisions Amending License Conditions (Ongoing Site Decommissioning)
QUESTIONS?