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Category:Letter
MONTHYEARML24226A0902024-07-25025 July 2024 Cert Wetland Delineation Report ML24191A4512024-07-0909 July 2024 Cimarron Environmental Response Trust, Updated Information Regarding Potential for Seepage in Burial Area 1 ML24185A0932024-07-0303 July 2024 Environmental Properties Management LLC, Cimarron Environmental Response Trust Annual Environmental Monitoring Program Data ML24173A2662024-06-19019 June 2024 Letter Dated 06/19/2024 from J.P.Davis and Rmiller, Odeq, to Jhesemann, Cimarron Environmental Response Trust, (Cert) Regarding Letter Dated June 13, 2024 to Engage Legal Counsel for Construction Contracting Support ML24173A2582024-06-19019 June 2024 Letter Dated 06/19/2024 from J.P.Davis and Rmiller, Odeq, to Jhesseman, Cimarron Environmental Response Trust, (Cert) Regarding Letter Dated May 31, 2024, Regarding Intent Investigate Insurance for Water Treatment Facility ML24165A2722024-06-13013 June 2024 Environmental Properties Management, LLC, Cimarron Environmental Response Trust Intent to Engage Legal Counsel for Construction Contracting Support ML24156A0672024-05-31031 May 2024 Environmental Properties Management, LLC, Cimarron Environmental Response Trust Corrected Decommissioning Cost Estimate ML24173A2722024-05-31031 May 2024 Letter Dated 05/31/2024, John R. Hesemann, Cimarron Environmental Trust, to Jsmith, NRC, Rmiller, Odeq Regarding Request for Approval to Investigate Insurance for Water Treatment Facility ML24151A3812024-05-29029 May 2024 Letter from R.Yalen Chief, Environmental Protection Unit, Department of Justice to J.Lux, Cimarron Environmental Response Trust Regarding Request for One-Time Waiver of Section 3.2.5 of Trust Agreement Addressed in Letter, Dated April 1, 2 ML24149A3662024-05-28028 May 2024 Cimarron Environmental Response Trust U-235 Enrichment in Environmental Media at the Cimarron Site ML24179A2862024-05-0707 May 2024 Letter Dated 05072024 from J.P.Davis and Rmiller, Odeq, to Jlux, Cimarron Environmental Response Trust, (Cert) Regarding Response to NRC Concerns Regarding Seepage at Burial Area 1 (February 21, 2024) ML24115A2422024-04-25025 April 2024 Cimarron Environmental Response Trust - NRC Inspection Report 07000925/2024001 ML24116A1712024-04-24024 April 2024 Cimarron Environmental Response Trust Updated Decommissioning Cost Estimate ML24109A1712024-04-17017 April 2024 Cimarron Environmental Response Trust License Condition 27(e) Annual Report for 2023 ML24017A0552024-01-17017 January 2024 Cimarron Environmental Response Trust Burial Area 1 Redox Evaluation Report ML23346A2622023-12-0808 December 2023 Cimarron Environmental Response Trust, Response to October 2, 2023, Request for Additional Information ML23319A2032023-11-15015 November 2023 Cimarron Environmental Response Trust - Response to November 1, 2023, Request for Additional Information Related to Nuclear Criticality Safety ML23317A1112023-11-13013 November 2023 Cimarron Environmental Response Trust - October 18, 2023, Project Status Teleconference Notes ML23335A1482023-11-0606 November 2023 Letter from Oklahoma State Historic Preservation Office Historic Properties at the Cimarron Site ML23319A2522023-11-0303 November 2023 Cimarron Environmental Response Trust - Response to September 6, 2023, Request for Additional Information ML23335A1492023-11-0303 November 2023 Letter from Oklahoma Archeological Survey Historic Properties at the Cimarron Site ML20336A2062023-10-10010 October 2023 Letter to Ok Shpo Re Recommendations of Eligibility for Historic Properties at the Former Cimarron Fuel Fabrication Facility ML23279A1282023-10-10010 October 2023 Letter to Ok Archeological Survey Re Recommendations of Eligibility for Historic Properties at the Former Cimarron Fuel Fabrication Facility ML23251A2122023-10-0202 October 2023 Cimarron - Cover Letter with Request for Additional Information for the Safety Review of the Decommissioning Plan ML23268A4422023-09-15015 September 2023 Cimarron Environmental Response Trust - Clarification of On-Site Disposal Vs. Soil Laydown Area ML23270B9152023-09-13013 September 2023 Letter from Rachel Miller, Oklahoma Department of Environmental Quality, Cimarron Environmental Response Trust Bounding Conditions for Fissile Exempt Material, Dated 9/13/2023 ML23230B2172023-09-0606 September 2023 Request for Additional Information for the Environmental Assessment of the Decommissioning Plan for the Cimarron Site Near Crescent, Oklahoma ML23248A4542023-09-0505 September 2023 NRC Copy of Rachel Miller, Odeq Letter to Jeff Lux Regarding the Cimmarron Environmental Response Trust Dated September 5, 2023 ML23248A4642023-08-24024 August 2023 Letter from J.Paul Davis, Odeq, and Rachel Miller, Odeq to Jeff Lux the Cimarron Environmental Response Trust to NRC Dated August 24/2023 ML23222A1342023-08-0808 August 2023 Environmental Properties Management, LLC, Cimarron Environmental Response Trust, Determination of Distribution Coefficients for Use in the Cimarron Decommissioning Plan ML23205A1792023-07-21021 July 2023 Cimarron Environmental Response Trust, Bounding Conditions for Fissile Exempt Material ML23193A8432023-07-12012 July 2023 Cimarron Environmental Response Trust Revision of License Amendment Requests in Section 6 of Decommissioning Plan - Rev 3 ML23171A9212023-06-13013 June 2023 Letter from J. Paul Davis, Odeq, Dated 6/13/2023 Regarding Letter from the Cimarron Environmental Response Trust to NRC- Dated April 17 2023 ML23152A0222023-06-0101 June 2023 Response to Letter Dated April 17 with Respect to Schedule for Processing License Amendment Request for Special Nuclear Material License SNM-928 Cimarron 5 24 2023 ML23139A0782023-05-17017 May 2023 Letter from J.Paul Davis, Odeq to Jlux, Cimarron Environmental Properties, Dated 5 17 2023 Regarding Addendum to License Application Addressing Cimarron Environmental Response Trust - Addressing 10 CFR Part 74 in the Cert Decommissioning Pl ML23142A1142023-05-0101 May 2023 Incoming Fee Exemption Request from State of Oklahoma on Behalf of Cimarron ML23109A1432023-04-18018 April 2023 Environmental Properties Management, LLC - Application for Exemption of Fees Pursuant to 10 CFR 170.12 Docket No. 07000925; License No. SNM-928 ML23108A0372023-04-17017 April 2023 Cimarron Environmental Response Trust NRC Schedule for Review of License Amendment Request ML23066A0382023-03-0707 March 2023 Cimarron Environmental Response Trust - License Condition 27(e) Annual Report for 2022 ML23065A0882023-03-0606 March 2023 Cimarron Environmental Response Trust - Funding for Abandonment of Monitor Wells ML23034A1682023-02-0303 February 2023 Cimarron Environmental Response Trust - Addressing 10 CFR Part 74 in the Cert Decommissioning Plan ML22350A0482022-12-15015 December 2022 Cimarron Environmental Response Trust Proposal to Abandon Monitor Wells T-99, T-100, and 1371 - 1373 - Corrected ML22350A0582022-12-15015 December 2022 Cimarron Environmental Response Trust Proposal to Abandon Monitor Wells on Divested Property ML22350A0722022-12-15015 December 2022 Cimarron Environmental Response Trust, Proposal to Abandon Monitor Wells T-99, T-100, and 1371 - 1373 - Corrected ML22313A1582022-11-29029 November 2022 Letter to Stacy Mitchell, Vice President, U.S. Bank National Association Regarding Change in Project Manager from Kenneth Kalman to James Smith ML22284A1452022-10-0707 October 2022 Cimarron Environmental Response Trust, Cimarron Site Decommissioning Plan ML22257A2472022-09-0808 September 2022 Cimarron Environmental Response Trust, Proposal to Abandon Monitor Wells T-99, T-100, and 1371 - 1373 ML22217A0252022-08-0808 August 2022 Cimarron Inspection Report 2022-001 ML22235A7612022-08-0808 August 2022 Trustee for Cimarron Environmental Response Trust/Nrc ML22228A1312022-08-0101 August 2022 Letter from B. Halliburton, Cert, Dated August 1, 2022 with Financial Statements for the Cimarron Environmental Response Trust January 1, 2022 - June 30, 2022 2024-07-09
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May 28, 2024
Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738
Ms. Rachel Miller Oklahoma Department of Environmental Quality 707 North Robinson Oklahoma City, OK 73101
Re: Docket No. 07000925; License No. SNM-928 Cimarron Environmental Response Trust U-235 Enrichment in Environmental Media at the Cimarron Site
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a response to a May 23, 2024, email from the U. S. Nuclear Regulatory Commission (NRC) regarding the enrichment of uranium in environmental media. Section 6.2 of Facility Decommissioning Plan - Rev 3 (the DP) states, Because environmental media do not contain uranium exceeding 5% enrichment, decontamination cannot produce material exceeding 5% enrichment.
The May 23 email asked, Is there one document from the NRC or the CERT that states or implies that environmental media do not contain uranium exceeding 5% enrichment or is it conclusion from an amalgam of Final Status Surveys?
Section 3.5.3 of the DP describes the extent of uranium in groundwater at the Cimarron site.
Figures 3-5 and 3-6 from the DP (in ML22285A091) present maps delineating enrichment values for uranium in groundwater in all monitor wells in the western area (WA) and in Burial Area #1 (BA1), respectively. These enrichment values are based on isotopic mass concentration analysis of groundwater samples collected from 173 WA and BA1 monitor wells in 2017. Section 3.5.3 of the DP states that samples were collected from 197 monitor wells, but the data from those wells that were outside of any remediation area were not evaluated for enrichment. The analytical data upon which these maps are based is tabulated on Figures 3-5 and 3-6.
Enrichment values were calculated by dividing the U-235 concentration by the sum of the U-235 and U-238 concentrations (multiplying by 100 to obtain percent values). Groundwater samples were not analyzed for U-234, because 1) this would require analysis by another method, increasing the cost of analysis, and 2) the concentration of U-234 in low-enriched uranium is much less than 1% of the total mass - including the concentration of U-234 in the equation would have a negligible effect on the calculated enrichment value.
9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
In BA1, groundwater samples were collected from 68 monitor wells for analysis. Enrichment values do not vary greatly because there was only source of uranium to impact the groundwater -
the solid waste buried in the four trenches in BA1. The average enrichment for uranium in all monitor wells in BA1 is approximately 1.3%, and the highest enrichment value obtained was 2.3%, in groundwater collected from Monitor Well 02W47. Consequently, it is reasonable to assert that the enrichment of uranium in groundwater in BA1 does not exceed 5%.
In the WA, groundwater samples were collected from 105 monitor wells for analysis.
Enrichment values are variable, because there were multiple sources of uranium - liquid waste from the original impoundments (the source of the linear plume extending north in the Western Alluvial Area, a.k.a. the WAA), Uranium Ponds #1 and #2 (sources of contamination in Sandstones A and B as well as the WAA), and solid waste with still different waste characteristics in Burial Area #3. Enrichment values vary based on the source of groundwater impact. The average enrichment for all monitor wells is approximately 1.5%. The highest enrichment values are observed in the linear plume generated by a leaking pipeline carrying wastewater from the original sanitary lagoons. Even in this area, the highest enrichment obtained was 4.4%, in groundwater collected from Monitor Well T-75. Groundwater samples collected from only two monitor wells in the WA yielded an enrichment of 4% or greater. Consequently, it is safe to assert that the enrichment of uranium in groundwater in the WAA does not exceed 5%.
Section 6.2 asserts that the enrichment of uranium in environmental media (both soil and groundwater) does not exceed 5%. Whether licensed material in groundwater is adsorbed by soil, or whether licensed material desorbs from soil into groundwater, the chemical reaction does not vary by isotope. Consequently, U-234, U-235, and U-238 will sorb or desorb in the same isotopic proportions as are in the source.
In addition, because licensed material from multiple locations will be blended together in both the BA1 and the WA influent streams, the enrichment of the influent will be much closer to the average enrichment in the area than to the enrichment in any single location. EPM asserts that the licensed material that accumulates in ion exchange resin during groundwater treatment will be well below 5% in both waste streams.
License Condition 8 imposes a possession limit of 100 grams of contained U-235 if the enrichment exceeds 5.0 weight percent U-235. It refers to a note that states, If during the decontamination of the facilities and equipment at the Cimarron Plant, uranium solutions or compounds are generated that have a U-235 isotopic content greater than 5.0 wt. percent, prompt action shall be taken to degrade these materials to below 5.0 wt. percent U-235.
Section 6.2 requests the deletion of this possession limit (and the associated note) as unnecessary.
Page 2 of 3 EPM believes that Section 3.5.3 satisfactorily addresses the concern that licensed material exceeding 5% enrichment may be encountered during the extraction and treatment of groundwater at the Cimarron site.
If you have any questions or desire clarification, please contact me at (405) 642-5152 or at jlux@envpm.com.
Sincerely,
Jeff Lux Project Manager
cc: (electronic copies only)
Stephanie Anderson and Linda Gersey, NRC Region IV Paul Davis, Keisha Cornelius, Christopher Robinson, David Cates, and Jonathan Reid, DEQ NRC Public Document Room vcpsubmittals@deq.ok.gov
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