ML24218A172
| ML24218A172 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 08/02/2024 |
| From: | Jennifer Davis, Miller R State of OK, Dept of Environmental Quality (DEQ) |
| To: | Christine Pineda, James Smith Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML24218A172 (1) | |
Text
Robert Singletary Executive Director August 2, 2024 Mr. James Smith Ol{LAHOMA Environmental Quality U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 James.Smith@nrc.gov Christine Pineda U.S. Nuclear Regulatory Commission Mailstop T4B72 11545 Rockville Pike Rockville, MD 20852 Christine.Pineda@nrc.gov
Subject:
Docket No. 07000925; NRC License No. SNM-928 Cimarron Environmental Response Trust Environmental Assessment for the Decommissioning Plan and Proposal to Remediate Groundwater at the Cimarron Site in Logan County, Oklahoma - Draft for State Review (May 31, 2024)
Dear Mr. Smith,
Thank you for providing DEQ with the Environmental Assessment for the Decommissioning Plan (D-Plan) and Proposal to Remediate Groundwater at the Cimarron Site in Logan County, Oklahoma - Draft for State Review. DEQ has reviewed the document and has the following comments.
Section 2.1.2.1 Construction Please provide D-Plan reference to a temporary building at Burial Area l (BA 1 ).
Section 2.1.2.2 - Groundwater Treatment Operations The new permit will have a limit for nitrate of 10 mg/L in addition to its discharge being reported. DEQ Water Quality Division (WQD) requires 180 days for issuing new permits. While not expected, the fluoride and uranium discharge limits could potentially change in the new permit.
While DEQ does not expect any beta emitter exceedances, the Oklahoma Water Quality Standard is currently 50 pCi/L.
Section 2.1.8 - Final Status Survey, License Termination, and Subsequent Activities After the site has been released from the NRC license, DEQ plans to file a Notice of Remediation for Land Use Controls and Groundwater Restrictions.
707 N ROBINSON AVE.. PO BOX 1677, OKLAHOMA CITY. OK 73101-1677 - OFFICE: 405-702-0100 STATE OF OKLAHOMA OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY, DEQ.OK.GOV Kevin Stitt Governor
Mr. Smith & Ms. Pineda Cimarron Environmental Response Trust August 2, 2028 Page l2 Section 3.1.1 - Site Description While Figure 3-l "View of Cimarron Site Entrance From Highway 74, Looking East" is the view from Highway 74, DEQ recommends using a current photograph of the actual site entrance. The photograph currently included may suggest to the public that the former plutonium plant and other buildings are associated with the Cimarron Environmental Response Trust (CERT) site. Additionally, perhaps installing signs directing to the Licensed Areas could be helpful. Photos of these could be substituted for Figure 3-1.
Section 3.3.1.2 - Potential Surface Water Impacts Influent Tc-99 concentrations are below the drinking water standard and DEQ is not expecting effluent to be of concern for the new OPDES permit, DEQ will need confirmation the gross-Beta emissions will not exceed the state standard of 50 pCi/L. While no Drinking water standard exists for Tc-99, Oklahoma has adopted the effluent concentration limit of 60,000 pCi/L provided in Title l O Code of Federal Regulations Part 20, Appendix B.
Section 3.3.2.2 - Contaminant Concentrations Please clarify if uranium concentrations are referring to the entire Western Area (WA) and BAI or footprint area where uranium activity is greater than the Derived Concentration Goal Limits (DCGL).
Section 3.3.2.2 Potential Groundwater Impacts DEQ agrees with the statement "The treatment system is not designed to reduce the concentration of the other known contaminants of concern: nitrate, fluoride, or Tc-99. Concentrations ofnitrate and Tc-99 in the extracted, untreated groundwater influent are expected to be below OPDES permit limits that the Oklahoma DEQ establishes, and fluoride concentrations would be below the l O mg/L discharge permit limit (EPM 2022a).
Currently there is not an Oklahoma Tc-99 State Criteria. However, the gross-Beta criteria is 50 pCi/L.
DEQ concurs that the proposed action would have beneficial impacts on groundwater supply. DEQ recommends replacing "Groundwater treatment operations would improve the quality of groundwater at the site and prevent contaminated groundwater from continuing to migrate toward and into the Cimarron River" with, "Groundwater treatment operations would improve the quality of groundwater at the site."
DEQ will work with EPM to address Tc-99, nitrate, and fluoride concentrations in groundwater during and after decommissioning.
Please provide documentation that DEQ has determined the licensee does not need an underground injection control (UIC) permit.
707 N. ROBINSON ST., PO BOX 1677 OKLAHOMA CITY. OK 73101-1677
- OFFICE: 405,702-0100 STATE OF OKLAHOMA
Mr. Smith & Ms. Pineda Cimarron Environmental Response Trust August 2, 2028 Page l3 Section 3.6.2. l Nonradiological Impacts See Section 3.3.2.2 comments above.
DEQ recognizes groundwater may not meet EPA Maximum Contaminant Level (MCLs) after NRC goals are met. DEQ expects the licensee to continue to monitor and operate the system as funding allows.
DEQ plans to file a Notice of Remediation for Land Use Controls and Groundwater Restrictions.
Section 5.0 Conclusion and Finding of No Significant Impact When the license has been terminated, treatment to reduce the concentrations of Tc-99, fluoride, nitrate, and uranium will no longer be possible. DEQ will file institutional controls to limit exposure to contaminated water.
Please contact Rachel Miller at 405-702-5140 or Rachel.Miller@deq.ok.gov with any comments or questions.
Since
. a I Davis Rachel Miller Environmental Programs Specialist Land Protection Division Environmental Programs Specialist Land Protection Division cc:
John Hesemann, Bums & McDonnell, JHesemann@bumsmcd.com Jeff Lux, Bums & McDonnell, JLux@bumsmcd.com Matt Crawford, Burns & McDonnell, MDCrawford@burnsmcd.com NRC Public Document Room 707 N. ROBINSON ST.. PO BOX 1677, OKLAHOMA CITY. OK 73101-1677
- OFFICE: 405-702--0100 STATE OF OKLAHOMA
- CEO.OK.GOV