ML25115A153
| ML25115A153 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 04/24/2025 |
| From: | Melissa Crawford Environmental Properties Management |
| To: | James Smith NRC/NMSS/DDUWP/URMDB |
| References | |
| Download: ML25115A153 (1) | |
Text
April 24, 2025 Mr. James Smith U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Re:
Docket No. 07000925; License No. SNM-928 Cimarron Environmental Response Trust License Amendment Request Related to License Condition 27(e)
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) submits herein a request to amend U. S. Nuclear Regulatory Commission (NRC) License SNM-928 to reference the Environmental Assessment (EA) and the radiological Safety Evaluation Report (SER) that the NRC prepared in November 2024 for License Amendment 22. The license currently references the EA and SER prepared in 1999.
License Condition 27(e)(iv) states, The licensee shall not be required to file an application for an amendment to the license when the following conditions are satisfied; a) The change, test, or experiment does not conflict with requirements specifically stated in the license (excluding those aspects addressed in Part 1 of this condition), or impair the licensee=s ability to meet all applicable NRC regulations; b) There is no degradation in safety or environmental commitments addressed in the NRC-approved DP or RPP, or have a significant adverse effect on the quality of the work, the remediation objectives, or health and safety; and c) The change, test, or experiment is consistent with the conclusions of actions analyzed in the Environmental Assessment (dated July 29,1999) and Safety Evaluation Report (dated August 20, 1999).
According to an email dated March 25, 2025, the NRC chose to keep the references to the 1999 EA and SER in License Condition 27(e) because they identified the analysis for gross alpha and gross beta in effluent (liquid and airborne monitoring). However, as described in the following sections, analysis for gross alpha and gross beta is no longer necessary for the purpose of determining if Technetium-99 (Tc-
- 99) analysis is required.
The 1999 EA and SER The 1999 EA and SER were prepared for License Amendment 15, which authorized the licensee to decommission the site in accordance with the 1995 Site Decommissioning Plan (and associated tie-
April 25, 2025 Page 2 downs). The 1999 EA never mentioned analysis for gross alpha and gross beta in effluents. The 1999 SER stated that as part of its annual environmental monitoring program, the licensee would analyze:
Air samples for gross alpha and gross beta, Surface water and groundwater samples for fluoride, nitrate, gross alpha, gross beta, and total uranium, and Vegetation samples for uranium.
Revision of the Environmental Monitoring Program Analysis of air samples was discontinued several years after the License Amendment 15 was issued because decommissioning of equipment, buildings, impoundments, and pipelines had been completed, and soil exceeding decommissioning criteria had been either shipped to a licensed disposal facility or buried in the on-site disposal cell.
Analysis of vegetation samples for analysis was also discontinued within two years after Amendment 15 was issued, as uranium was not detected in vegetation.
Analysis of Water for Gross Alpha and Gross Beta In the 1990s, gross alpha and gross beta activity data were useful because in some areas, the gross beta activity exceeded the alpha activity by a factor of three or more. This could not be attributed to the licensed material based on the ratio of beta to alpha emitting radionuclides in the uranium decay chain.
This elevated beta activity indicated there was another beta-emitting radionuclide present in groundwater at the site. In 1996, it was determined that the elevated beta activity was due to the presence of technetium-99 (a beta-emitting radionuclide) in groundwater. Tc-99 was a contaminant in the uranium hexafluoride feedstock the facility had received in the early 1970s from the US Department of Energys Paducah, Kentucky facility.
The licensee began including Tc-99 analysis for groundwater samples in which the gross beta concentration exceeded 3 times the gross alpha concentration. When license amendment 15 was issued in 1999, the full extent of Tc-99 in groundwater had not been defined. The 1999 SER statement, The licensee will measure for fluoride, nitrate, gross alpha, gross beta, and total uranium in each of the samples., was included in the SER because the beta:alpha ratio was the factor that determined whether a sample should be analyzed for Tc-99. Surface water samples have never yielded detectable concentrations of T-99.
After completing final status surveys for Subareas G and K, the licensee requested that these subareas be released from the license. In a letter dated March 12, 2002, the NRC stated, NRC staff has decided to amend the Cimarron license to release Subarea K, pending submittal of an acceptable decommissioning schedule, but withhold release of Subarea G until Cimarron addresses the onsite Tc-99 contamination.
Subarea G was withheld from release because gross beta concentrations in groundwater being significantly higher than gross alpha concentrations.
As a result of the 2002 decision to withhold release of Subarea G until Tc-99 contamination had been addressed, the licensee conducted a groundwater investigation; the December 2003 Draft Tc-99 Groundwater Assessment Report showed that Tc-99 was present in Subarea G at elevated concentrations,
April 25, 2025 Page 3 which did not exceed the NRC release criterion of 3,790 pCi/L, but did exceed the State Criterion of 900 pCi/L in several monitor wells.
Analysis of groundwater samples for gross alpha, gross beta, and Tc-99 continued for several years, until, in a letter dated April 4, 2012, the NRC stated, As groundwater concentrations of Tc-99 have remained below the NRCs DCL since 2004, the NRC staff has concluded that Tc-99 will not have to be addressed in the groundwater remediation plan. However, the NRC staff requests that the post-remediation monitoring pan leading to license termination includes four calendar quarters of monitoring for Tc-99 to be collected, shortly before requesting license termination, to confirm that previous concentrations have remained below NRCs DCL.
Further Revision of the Environmental Monitoring Program Because there is no longer a need to analyze groundwater or surface water samples for Tc-99, there is no longer a need to analyze groundwater or surface water samples for gross alpha or gross beta. In a letter dated March 1, 2024, EPM requested a change in the annual environmental monitoring program that would remove gross alpha and gross beta, along with analysis for nitrate and fluoride in Burial Area #1 (where nitrate and fluoride are only present at background concentrations), from the list of analytes.
Neither the NRC nor the Oklahoma Department of Environmental Quality objected to the proposed change. Both agencies agreed that it should be acceptable to eliminate any unnecessary sampling.
Consequently, EPM conducted an evaluation in accordance with License Condition 27(e), indicating that this change was consistent with the conclusions of actions analyzed in the Environmental Assessment (dated July 29,1999) and Safety Evaluation Report (dated August 20, 1999). Just as analysis of air and vegetation samples is no longer necessary, analysis for gross alpha and gross beta is no longer necessary.
Current Applicability of the 2024 EA and SER The 1999 SER was prepared for a decommissioning plan that did not include active remediation of groundwater. The 1995 Site Decommissioning Plan did not mention groundwater remediation and the 1998 Decommissioning Plan - Groundwater Evaluation Report assumed that the method of remediation would be natural attenuation. The radiological considerations evaluated for the 1999 SER are not relevant to any active remediation method; therefore there is no reason to reference 1999 SER (or the 1999 EA) for future construction and operations related to the groundwater remedy planned for the site.
The 2022 Facility Decommissioning Plan - Rev 3 was prepared because natural attenuation cannot attain uranium groundwater concentrations consistent with decommissioning criteria in a reasonable timeframe.
Instead, contaminated groundwater will be extracted and piped to an on-site treatment facility where enriched uranium will be removed via an ion exchange treatment process.
The 2024 SER (and the 2024 EA) were prepared to address radiological safety concerns related to this active remediation process. For instance, the 2024 SER addresses the accumulation of enriched uranium in ion exchange resin, the potential for personnel to receive internal and/or external radiological dose, in-process treatment system and discharge monitoring, and radiation surveys. The only mention of gross alpha and gross beta-gamma measurements relate to past measurements for concrete rubble; the 2024 SER appears to recognize that there is no continuing need to analyze either groundwater or treated water for gross alpha or gross beta activity.
April 25, 2025 Page 4 Requested License Amendment EPM requests that License Condition 27(e)(iv)(c) be amended to read, c) The change, test, or experiment is consistent with the conclusions of actions analyzed in the November 2024 Environmental Assessment and the November 2024 Safety Evaluation Report.
Should the NRC agree to amend License Condition 27(e) as requested, EPM recommends that the NRC also correct three minor errors:
- 1. In the last sentence of the second-to-last paragraph of License Condition 27(d), a parenthesis appears to have been inadvertently superscripted when the numeral 2 was superscripted.
- 2. In License Condition 27(e)(iv)(a), an equal sign should be replaced with an apostrophe.
- 3. Page 9 of 10 is blank. Presumably a hard return was inserted. The entire license should contain only nine pages.
If you have any questions or desire clarification, please call me at 816-652-2784.
Sincerely, Mathew Crawford, Trustee Project Manager cc: (electronic copies only)
Stephanie Anderson and Linda Gersey, NRC Region IV Rachel Miller, Paul Davis, and Keisha Cornelius, DEQ NRC Public Document Roomcpsubmittals@deq.ok.gov