ML24109A171
| ML24109A171 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 04/17/2024 |
| From: | Lux J Cimarron Environmental Response Trust, Environmental Properties Management |
| To: | James Smith Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| Download: ML24109A171 (1) | |
Text
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com April 17, 2024 Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket No.70-925; License No. SNM-928 Cimarron Environmental Response Trust License Condition 27(e) Annual Report for 2023
Dear Sirs:
The purpose of this letter is to update our annual report (for Calendar Year 2023) on changes, tests, or experiments made or conducted pursuant to License No. SNM-928, Amendment 21, Condition 27(e) that was submitted on March 7, 2024. As discussed in our previous report, this License Condition authorizes the licensee to make certain changes to the NRC-approved Decommissioning Plan (D-Plan) and Radiation Protection Plan (RPP) without NRCs approval, if these changes are consistent with the ALARA principle and decommissioning process. Our letter stated that no changes to the RPP or D-Plan were made in calendar year 2023, although Revision 3 to the D-Plan, including Revision 5 to the RPP was formally submitted to the NRC for review and approval.
Following further evaluation of the requirements in License Condition 27(e), we noted that our annual report to the NRC must include a description of all changes, tests, and experiments made or conducted pursuant to this condition.
The March 7, 2024, letter inadvertently omitted a description of a test that was evaluated under this License Condition. The ALARA Committee approved a test involving the evaluation of geochemical characteristics of groundwater in the Burial Area #1 Extraction Trench GETR-BA1-01. The test involved the collection of groundwater samples for laboratory analysis, followed by the evaluation of bacterial communities in and near the extraction trench. The ALARA Committee concluded that the test met the criteria stipulated in Condition 27(e);
consequently, the test could be conducted without prior NRC approval. Attachment 1 to this letter is a copy of the evaluation form documenting the Condition 27(e) evaluation.
As previously reported, the Cimarron Environmental Response Trust has not implemented Revision 3 to the D-Plan nor Revision 5 to the RPP as the Site ALARA Committee determined that changes to these documents require NRC approval prior to implementation. Both documents are being updated to address NRC staff requests for additional information provided in calendar year 2023. Final versions of the D-Plan and RPP will be implemented following NRC approval of these documents, as supplemented by responses to the additional information provided to the NRC.
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com This report is being submitted only in electronic format. Hard copies will be provided upon request. If you have any questions or desire clarification, please call me at (405) 641-5152.
Sincerely, Jeff Lux, P.E.
Project Manager cc:
Robert Evans, Stephanie Anderson, and Linda Gersey, NRC Region IV Rachel Miller, Paul Davis, Keisha Cornelius, Lee Dooley, David Cates, and Jon Reid, DEQ vcpsubmittals@deq.ok.gov NRC Public Document Room
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com ATTACHMENT 1 LICENSE CONDITION 27(e) EVALUATION FORM 2023 BA1 EXTRACTION TRENCH EVALUATION AND SAMPLING
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Digitally signed by Jay Maisler, CHP Date: 2023.12.08 16:43:28 -05'00' Digitally signed by Jay Maisler, CHP Date: 2023.12.08 16:44:07 -05'00' Date: 2023.12.09 05:55:22 -06'00' Charles R. Beatty Jr.
Digitally signed by Charles R. Beatty Jr.
Date: 2023.12.11 13:46:37 -05'00'
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