ML24309A252

Letter from Oklahoma Department of Environmental Quality DEQ Response to Environmental Assessment for the Decommissioning Plan and Proposal to Remediate Groundwater at the Cimarron Site in Logan County, Oklahoma - Draft for State Review

ML24309A252
Person / Time
Site:	07000925
Issue date:	10/11/2024
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: ML24309A252 (1)

Text

October 11, 2024

Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 James.S mith@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 DEQ Response to Environmental Assessment for the Decommissioning Plan and Proposal to Remediate Groundwater at the Cimarron Site in Logan County, Oklahoma - Draft for State Review (August 2, 2024)

Dear Mr. Smith and Ms. Pineda,

This letter is intended to provide an update on the anticipated permit limits for the Cimarron Site, following DEQs August 2, 2024, response to the NRCs draft Environmental Assessment.

As you may recall, the comment for Section 2.1.2.2 - Groundwater Treatment Options stated that the new permit would likely include a nitrate limit of 10 mg/L and require reporting of discharge. We also noted that fluoride and uranium discharge limits could potentially change. On September 19, 2024, DEQ representatives from the Water Quality Division (WQD) and Land Protection Division (LPD) met with Jeff Lux and Matt Crawford to discuss the potential OPDES permit discharge limits. Based on this meeting, the permit will not include limits for nitrate, fluoride, or Tc-99. Additionally, the uranium limit will be no lower than the Maximum Contaminant Level (MCL) of 30 mg/L, and no higher than 50% of the NRC's effluent standard. These limits were determined based on the projected effluent data provided and existing beneficial uses of the receiving stream.

While not seen as likely, the receiving streams beneficial uses could change or a uranium criterion might be developed.

Please find the meeting summary attached for your reference. The final OPDES permit limit for uranium will be determined early 2025 pending receival of application.

Please contact Rachel Miller at 405-702-5140 or Rachel.Miller@deq.ok.gov with any comments or questions.

Sincerely,

J. Paul Davis Rachel Miller Environmental Programs Specialist Environmental Programs Specialist Land Protection Division Land Protection Division

cc: John Hesemann, Burns & McDonnell, JHesemann@burnsmcd.com Jeff Lux, Burns & McDonnell, JLux@burnsmcd.com Matt Crawford, Burns & McDonnell, MDCrawford@burnsmcd.com NRC Public Document Room

MEETING

SUMMARY

September 19, 2024

DEQ (LPD and WQD)/B&M Meeting

Jeff Lux, Matt Crawford (Burns & McDonnell)

Jon Reid, Paul Davis, Rachel Miller (DEQ LPD)

Carol Paden, Penn Mouluh (DEQ WQD)

DEQ's Land Protection Division (LPD) and Water Quality Division (WQD) are collaborating with Burns & McDonnell to develop the upcoming Oklahoma Pollutant Discharge Elimination System (OPDES) permit.

DEQ must establish a discharge limit to 1) address public concerns, 2) comply with NRC regulations, and 3) protect Oklahomas wate r quality. A higher discharge limit could reduce treatment time and costs, potentially freeing up funds for decommissioning the treatment facility after treatment has completed (including two years of post-remediation monitoring, final NRC surveys, and application for license termination). However, DEQ must balance these factors with community satisfaction and technical requirements.

To determine the appropriate uranium discharge limit, effluent concentrations are calculated based on data in Table 8-7c of the D-Plan. This table summarizes the sum of fractions, which must be less than 1 to meet NRC requirements. Without treatment, the effluent is expected to contain 669 P g/L, resulting in a sum of fractions of 2.81. To achieve a sum of fractions close to 1, the discharge is estimated to be around 200 P g/L of total uranium.

The goal of the treatment process is to extract uranium from groundwater using ion exchange until the monitoring well with the highest uranium concentration falls below the NRC limit (approximately 200 P g/L). The DEQ's decision on the uranium permit limit will significantly impact the duration of the treatment process and save money for other decommissioning activities afterwards.

Page 1 of 3 LPD and WQD plan to evaluate different permit limits to determine their potential impact on treatment completion dates and budget. Jeff Lux will present his findings at the next meeting on October 10th. Rachel, Paul, Jon, Carol, and Penn plan to meet with LPD and WQD Division Directors to discuss Jeffs results and potential OPDES uranium limits early 2025 (before the permit application is submitted).

WQD predicts that nitrate, fluoride, and Tc-99 limits will not be necessary due to changes in treatment systems processes. The permit limits will now be based on the receiving river's capacity rather than the treatment system's capabilities. WQD suggests monitoring effluent on a quarterly basis.

Next Steps:

A letter will be sent to Christine Pineda at NRC to inform her of the preliminary assessment: no nitrate, fluoride, or Tc-99 limits will be included in the upcoming OPDES permit. Uranium limits will be no lower than MCL (30 P g/L) but no higher than 50% of NRC's effluent standard (200 P g/L).

DEQ will meet with Jeff Lux to review end of treatment time/cost scenarios based on potential OPDES uranium limits.

Early 2025 meeting with LPD and WQD Division Directors to discuss Jeffs results and potential OPDES uranium limits.

Page 2 of 3 Page 3 of 3