ML25218A178
| ML25218A178 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 08/06/2025 |
| From: | Melissa Crawford Environmental Properties Management |
| To: | Miller R, James Smith Document Control Desk, Office of Nuclear Material Safety and Safeguards, State of OK, Dept of Environmental Quality (DEQ) |
| References | |
| Download: ML25218A178 (1) | |
Text
August 6, 2025 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
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environmental properties management, LLC Report of 27 ( e) Changes Made Relating to Construction of Remediation Infrastructure
Dear Recipients:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) reports herein to the U.S. Nuclear Regulatory Commission (NRC) and the Oklahoma Department of Environmental Quality (DEQ) four changes to the Facility Decommissioning Plan -Rev 3 (the D-Plan) and/or the Radiation Protection Plan -Rev 5 (the RP). The need for these changes became apparent during the review of the schedule and cost estimates related to the construction of remediation infrastructure and facilities.
All of these proposed changes were reviewed by the ALARA Committee and determined to meet the conditions required by License Condition 27(e) for making changes to the D-Plan and/or the RPP without obtaining approval by the NRC. The changes are:
- 1. Evaluation 2025 Replacing the use of an inorganic slurry with a low-biological oxygen demand (BOD) organic slurry based on:
- a.
The low-BOD organic slurry will have significantly lower organic material content than the slurry used to construct the pilot groundwater extraction trench in 2017.
- b. The trench construction plan calls for developing the slurry trenches and initiating groundwater extraction immediately following construction, thereby minimizing the distribution of organic matter into the aquifer.
- 2. Evaluation 2025 Replacing the laboratory analysis of all soil samples collected from each boring for uranium with the analysis of the sample from each boring yielding the highest scan measurement only. If any sample submitted for laboratory analysis exceeds the NRC Criterion for soil, all samples collected from that boring will be subsequently submitted for laboratory analysis
- 3. Evaluation 2025-03-Eliminating the requirement to collect soil samples from excavated trenches at a rate of one sample per "X" feet of trench for soil that will be transported to the 9400 Word Parkway* Konsos City, NO 64114
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envi ronmenta I properties management, LLC excavated soil mixing area. This will eliminate unnecessary duplication of sampling for this material.
- 4. Evaluation 2025 Replacing the plan to submit a soil sample from every IO-meter grid cell in the Western Area Treatment Facility for laboratory analysis of uranium with a plan to submit soil samples from the 10 grid locations yielding the highest scan measurements, with no further sample analysis if none of these 10 samples contain uranium exceeding the NRC Criterion.
EPM understands that the NRC will likely conduct an inspection during the construction of remediation infrastructure and facilities during the third or fourth quarter of 2025. Consequently, EPM elected to inform the NRC of these changes before the next NRC inspection, rather than waiting until the first quarter of 2026, when the annual notification of changes required by License Condition 17 ( e) has typically been submitted.
Documentation related to these four 27(e) evaluations is provided as Attachments 1 through 4 to this submittal. If you have questions or require 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 Paul Davis, Keisha Cornelius, Courtney Redmond, Lee Dooley, David Cates, and Jonathan Reid, DEQ NRC Public Document Room vcpsubmittals@deq.ok.gov Attachments: - 27(e) Evaluation 2025 Use of a Low-BOD Organic Slurry in Trenches Constructed in Transition Zone Material - 27(e) Evaluation 2025-02-Analysis of Soil Samples from Borings - 27(e) Evaluation 2025-03 -Analysis of Soil Samples from Trenches - 27(e) Evaluation 2025-04-Analysis of Soil Samples from the Western Area Treatment Facility 9400 Word Parkway* Konsos City, NO 64! 14
ATTACHMENT 1 27(e) Evaluation 2025-01 Use Of A Low-BOD Organic Slurry In Trenches Constructed In Transition Zone Material
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 1 of 6 Rev. 3.1 Constructed in Transition Zone Material Submitted By (Signature/Date):
Preparer: Jeff Lux Approved By (Signature/Date):
Radiation Safety Officer:
Quality Assurance Coordinator:
Project Manager:
Trust Administrator:
Date: 2025.08.04 06:45:33 -05'00'
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Digitally signed by Jay Maisler, CHP DN: C=US, E=jmaisler@enercon.com, O=Cirrnarron Site, OU=Radiation Safety Officer, CN="Jay Maisler, CHP" Date: 2025.08.05 10:50:39-04'00' Digitally signed by Charles Beatty Charles Beatt\\'/ DN: C=US, E=cbeatty@enercon.com, 1 ~ CN=Charles Beatty Date: 2025.08.05 14:00:48-04'00' John R.
Digitally signed by Mathew D Crawford Date: 2025.08.05 16:46:43-05'00' Digitally signed by John R. Hesemann DN: C=US, E=jhesemann@burnsmcd.com, Hesemann O=Burns & McDonnell, CN=John R.
Hesemann Date: 2025.08.05 17:39:20-05'00' Page 1 of 6
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 2 of 6 Rev. 3.1 Constructed in Transition Zone Material 1.0 Description of Proposed Revision, Test, and/or Experiment:
During the 2017 Trenching Pilot Test, an organic biopolymer (Rantec G150 BioPolymer) was used to create slurry to aid in the construction of Groundwater Extraction Trench GETR-BA 1-01.
Although some groundwater was extracted from the trench during the aquifer pumping test conducted upon completion of the trench, the trench was not fully developed. Complete trench development would have removed a significant portion of the dissolved organic compounds introduced to the surrounding aquifer when the slurry was placed in the trench, and after the slurry was "broken" using organic enzymes.
Quarterly groundwater sampling events conducted after completion of the pilot test showed dramatic declines in the concentration of uranium in monitor wells constructed within, adjacent to, and slightly downgradient of Trench GETR-BA 1-01. It was suspected that the presence of residual dissolved organics resulted in the establishment of reducing conditions within the aquifer, which resulted in the conversion of uranium from soluble to nearly insoluble (sorbed) form. A more in-depth groundwater assessment conducted over the next several years provided data supporting this assertion. This assessment also demonstrated it would take several years for the original aquifer redox conditions to be restored.
Based on effects of the biopolymer slurry on aquifer redox conditions and uranium solubility, as demonstrated by the groundwater assessment, Sections 8.2.2 and 8.4.4 of Facility Decommissioning Plan - Rev 3 (the D-Plan) state that an inorganic slurry will be used in the construction of extraction trenches completed in unconsolidated transition zone material.
Discussions with 06 Environmental (06), the General Contractor selected for construction of the trenches described in the D-Plan, identified concerns regarding the ability to properly develop the injection/extraction trenches if an inorganic slurry is used for their construction.
06 proposed using an organic slurry product (SlurryPro CDP) containing significantly less organic material than the Rantec G150 BioPolymer slurry used in 2017. The biological oxygen demand (BOD) of SlurryPro CDP is an order of magnitude lower that that of the Rantec G150 product. EPM requested that Burns & McDonnell Engineering Company, Inc. (BMcD) generate a technical memorandum (tech memo) evaluating the potential for use of the SlurryPro product to result in the same shifts in aquifer redox and uranium solubility observed in 2017. The BMcD tech memo, Evaluation of Low-Biochemical Oxygen Demand Slurry for Trench Installation, (Attachment 1) concluded that the SlurryPro CD P's lower BOD, along with the immediate development of each extraction trench, followed by continuous groundwater extraction and during operations (after construction), should prevent the use of this slurry from adversely affecting aquifer redox and uranium solubility.
This evaluation was conducted to determine if NRG approval is necessary to change Sections 8.2.2 and 8.4.4 of the D-Plan to authorize the use of the organic slurry product SlurryPro CDP during the construction of trenches constructed in transition zone material.
Page 2 of 6
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 3 of 6 Rev. 3.1 Constructed in Transition Zone Material 2.0 Does the proposed revision, test, and/or experiment ("action") represent a change to the NRC-approved Decommissioning Plan or Radiation Protection Plan?
X Yes If "Yes", proceed to section 4.0 for evaluation of the action.
No If "No", proceed to section 3.0 for evaluation of the action.
3.0 Is the proposed test or experiment present in the NRC-approved Decommissioning Plan or applicable license conditions?
Yes If "Yes", there is no need to conduct an evaluation.
No If "No", proceed to Section 4.0 for evaluation of the action.
4.0 Evaluation
LICENSE REQUIREMENT YES NO 4.1 Does the action conflict with requirements specifically stated in the license, other than the RPP YES NO or DP?
a) Does the action involve material not authorized by X
the license?
b) Are either the use or the place of use different X
from what the license authorizes?
c) Will the action violate training requirements?
X d) Are there procedures or procedure revisions X
which have not been approved bv the RSO?
e) Does the action involve work in Restricted Areas or with licensed material not addressed in RP X
Procedures?
f)
Does the action conflict with requirements in tie-downs stipulated in license conditions 10, 26, X
27(a), or 27(c)?
g) Does the action result in contamination exceeding X
limits stipulated in license condition 27?
N/A N/A Page 3 of 6
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 4 of 6 Rev. 3.1 Constructed in Transition Zone Material LICENSE REQUIREMENT YES NO N/A 4.2 Does the action impair Cimarron Environmental Response Trust's ability to meet all applicable NRC YES NO N/A regulations?
a) Will the action cause an exceedance of dose limits for workers and members of the public?
X b) Does the action establish limits other than approved decommissioning criteria?
X c) Does the action violate requirements for surveys and monitoring, control of internal and external X
exposure, and control of licensed material?
d) Will the action violate precautionary procedures (posting, labeling, etc.)?
X e) Does the action violate waste disposal or record keeping requirements?
X 4.3 Does the action result in degradation of safety or environmental commitments addressed in the NRC-YES NO N/A approved RPP and/or DP, or health and safety?
a) Does the action result in greater release of licensed material to air or liquid effluents than X
planned actions?
b) Does the action result in the spread of licensed material to uncontaminated areas more than X
planned actions?
c) Does the action result in the loss of control over X
licensed material?
d) Have data quality objectives that achieve the X
required level of data quality not been addressed?
4.4 Does the action pose a significant adverse effect on YES NO N/A the quality of the work or the remediation objectives?
a) Does the action modify the intent to release the X
site for unrestricted use?
b) Does the action result in significant increase in the volume of material contaminated above license X
criteria?
Page 4 of 6
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 5 of 6 Rev. 3.1 Constructed in Transition Zone Material LICENSE REQUIREMENT YES NO N/A c) Does the action contaminate unrestricted areas to X
the extent they will require decommissioninQ?
4.5 Does the action conflict with the conclusions of actions analyzed in the Environmental Assessment, YES NO N/A dated July 29, 1999 and Safety Evaluation Report dated August 20, 1999?
a) Does the action render the environmental monitoring program unable to detect a release of X
licensed material to the environment?
b) Does the action increase the release of licensed X
material to Qroundwater, surface water, or air?
c) Does the action create the potential for an X
accident worse than that in the dose assessment?
d) Does the action result in an adverse X
socioeconomic impact to the community?
e) Does the action create other than short duration X
and minor imoacts to air?
f)
Does the action adversely impact potential future X
land use?
g) Does the action adversely impact transportation X
clans for shioments to a licensed disoosal site?
h) Does the action adversely impact endangered X
species?
i)
Does the action impact historic or archeological X
sites?
NOTE: If "YES" was answered in any of the Section 4 evaluation questions, the action cannot be performed without NRG approval. Provide any basis for determination of each answer provided in Section 4 as comments in Section 5.0, as appropriate.
5.0 Comments
The use of SlurryPro CDP is the most viable and cost-effective option for the installation of groundwater extraction/injection trenches in unconsolidated material.
6.0 Results
Page 5 of 6
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Cimarron Environmental Response Trust environmental License Condition 27(e) Change Evaluation 2025-01 properties management, LLC Form QAI P 2.2-1, Use of a Low-BOD Organic Slurry in Trenches Page 6 of 6 Rev. 3.1 Constructed in Transition Zone Material I Revision, Test, or Experiment Approved:
Yes X
No Page 6 of 6
- Low-BOD Technical Memorandum
Memorandum Date 07/01/2025 To From Subject Mr. Mathew Crawford Trustee Project Manager Environmental Properties Management, LLC Burns & McDonnell Evaluation of Low-Biochemical Oxygen Demand Slurry for Trench Installation This memo addresses concerns regarding slurry selection for constructing groundwater extraction trenches at the Cimarron Environmental Response Trust site near Guthrie, Oklahoma. During the 2017 Pilot Test 1, Groundwater Extraction Trench GETR-BA1-01 was constructed in the transition zone material of Burial Area #1 (BA 1 ). An organic biopolymer slurry (Rantec G150 Bio Polymer) was used to prevent collapse of the unconsolidated material during construction. The density of this slurry also minimized the infiltration of uranium-contaminated groundwater into the trench. Following the construction of the trench to the target depth, the slurry material was 'broken' using an enzyme mixture and removed from the trench to the extent practical. Groundwater sampling in December 2017 and subsequent months indicated a significant decrease in uranium concentrations in several monitor wells downgradient from GETR-BA1-01. This suggested that dissolved organics from the degraded slurry had migrated downgradient. Biodegradation by indigenous microorganisms created reducing conditions, causing precipitation of uranium from groundwater. To address a concern that a reduction in aqueous uranium concentrations could reduce the rate of uranium recovery and extend the timeframe to achieve remediation objectives, a sampling program was established to track oxidation-reduction (redox) conditions and aqueous uranium concentrations to evaluate the long-term impacts of the biopolymer slurry. Over time, redox conditions in the aquifer generally returned to baseline, pre-pilot test conditions. Long-term changes in uranium concentrations at individual monitor wells over time are predominantly attributed to natural plume migration, with minor residual impacts observed from the pilot test, as documented in the BA1 Redox Evaluation 2.
Two additional groundwater extraction (GETR-WU-01 and GETR-BA 1-02)3 trenches and one injection trench (GWI-BA 1-01 )4, will be constructed in the unconsolidated materials during full-scale construction. Draft Facility Decommissioning Plan - Rev 3 (D-Plan Rev 35) was prepared while the redox evaluation was ongoing. Therefore, an inorganic high-density slurry or other physical trench stabilization equipment was recommended to maintain an open trench during excavation in the unconsolidated transition zone materials, in lieu of the organic biopolymer slurry used during the pilot test, to minimize potential impacts to aquifer red ox conditions.
However, discussions with contractors has shown that the use of an inorganic (i.e., bentonite) slurry provides challenges as well. For example, if residual solids are not removed effectively, achievable groundwater extraction flow rates from these trenches may be less than target flow rates, potentially extending the timeframe to achieve remediation objectives.
Following the completion of the red ox evaluation, and upon further evaluation of inorganic slurry options, it appears that three factors could alleviate the potential to creating reducing conditions in the aquifer; the use of a different biopolymer slurry, trench development (GETR-BA1-01 was not developed after construction), and beginning groundwater extraction 1 Burns & McDonnell Engineering Company. Remediation Pilot Test Report, Cimarron Environmental Response Trust, Guthrie, Oklahoma. June 2018 2 Burns & McDonnel Engineering Company. Burial Area #1 Redox Evaluation, Cimarron Environmental Response Trust, Guthrie, Oklahoma. January 2024 3 Burns & McDonnel Engineering Company. "Extraction Trench Details." Drawing No. BMCD-GWREMED-C101. July 2024.
4 Burns & McDonnel Engineering Company. "Injection Trench Details." Drawing No. BMCD-GWREMED-C103. July 2024.
5 Environmental Properties Management, LLC. Cimarron Environmental Response Trust Facility Decommissioning Plan -
Rev 3, Guthrie, Oklahoma. 2015
shortly after completing trench construction.
To mitigate the potential reducing effects of the organic slurry, an alternative product will be used. A different slurry product (SlurryPro CDP) contains nearly an order of magnitude lower Biochemical Oxygen Demand (BOD) than the Rantec G150 BioPolymer used in the pilot study (140 mg/L vs. 1200 mg/L, respectively). Second, the proposed trench development procedures will increase the volume of water extracted during the slurry-breaking process and include a sampling regimen to track the removal of slurry-impacted water. Finally, operational startup of the groundwater extraction system shortly after trench construction will minimize the distance that residual dissolved organics can migrate from extraction trenches, minimizing the potential for stagnant residual organic material to create reducing conditions in the aquifer.
Trench Development and Slurry Removal Trench development will begin with slurry removal, minimizing residual dissolved organic material in the trench and the surrounding aquifer. Trench development will involve initially breaking the slurry with a sodium hypochlorite solution and pumping the broken slurry to frac tanks near the excavation and stored on-site for subsequent monitoring of water quality. The trench will be allowed to recharge with formation groundwater for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after purging the broken slurry.
This step includes developing the trench, similar to traditional development techniques for vertical pumping wells.During trench development, clean water is added to the trench until the water level rises one foot above the natural groundwater level. The water level is then monitored every twenty minutes until it drops back to the static water level.
Following this, water is pumped from the trench using appropriate equipment until either the water level drops below the pump intake in the base of the trench or stabilizes, and at least two full trench volumes have been removed. The extracted water is stored in designated frac tanks, and key water quality parameters-such as pH, oxidation-reduction potential, temperature, and turbidity-are recorded throughout the process. After pumping ceases, the trench is allowed to naturally recharge to at least 80% of the original groundwater level. If this recharge is not achieved by the following morning, the development cycle is repeated. This sequence of water addition, observation, and removal is performed once daily for a total of three complete cycles to facilitate effective trench development.
Effects of Treatment System Extraction As discussed above, extraction was ceased after the aquifer test was completed for the pilot study, allowing the residual organic material to remain in the aquifer and cause reducing conditions. Unlike during the pilot study, the groundwater treatment system will be operational and begin continuouse extraction of groundwater from the aquifer surrounding the extraction trenches following slurry removal and development which will facilitate removal of any remaining residual organic material from the slurry Conclusion and Recommendations The 2017 pilot study highlighted the risk of using high-BOD slurries, which created reducing conditions in the aquifer, temporarily reducing aqueous uranium concentrations. SlurryPro CD P's significantly lower BOD, coupled with trench development and groundwater extraction startup as soon as possible following development, will minimize residual organic material and impacts to aquifer redox conditions. Therefore, the proposed approach balances effective trench stabilization while maintaining the objectives of the treatment design.
Eric Dulle, PE 2
ATTACHMENT 2 27(E) Evaluation 2025-02 Analysis Of Soil Samples from Borings
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-02 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Borings I Page 1 of 5 Submitted By (Signature/Date):
Preparer: Jeff Lux Approved By (Signature/Date):
Radiation Safety Officer:
Quality Assurance Coordinator:
Project Manager:
Trust Administrator:
Date: 2025.08.04 06:46:24 -05'00'
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Digitally signed by Jay Maisler, CHP DN: C=US, E=jmaisler@enercon.com, O=Cimarron Site, OU=Radiation Safety Officer, CN="Jay Maisler, CHP" Date: 2025.08.05 10:56:40-04'00' Digitally signed by Charles Beatty Charles Beatty DN: C=US, E=cbeatty@enercon.com, CN=Charles Beatty Date: 2025.08.05 14:01 :13-04'00' John R.
Digitally signed by Mathew D Crawford Date: 2025.08.05 16:47:07-05'00' Digitally signed by John R. Hesemann DN: C=US, Hesemann E=jlilesemann@burnsmcd.com, O=Burns
& McDonnell, CN=John R. Hesemann Date: 2025.08.05 17:38:56-05'00' Page 1 of 5
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-02 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Borings I Page 2 of 5 1.0 Description of Proposed Revision, Test, and/or Experiment:
Section 13.1.3 of Facility Decommissioning Plan - Rev 3 (the D-Plan) and Section 12.5.2 of Radiation Protection Plan - Rev 5 (the RPP) present a plan for the collection of soil samples from borings completed for the installation of groundwater monitor wells and groundwater extraction wells. During construction, 24 monitor wells will be installed, and 7 extraction wells will be installed, yielding a total of 31 soil borings.
According to the D-Plan and the RPP, the core extracted from these borings will be scanned with a gamma survey meter. One soil sample would be collected from each 5-foot interval at the location within that interval exhibiting the highest gamma survey measurement. All soil samples were then to be submitted to an offsite laboratory for analysis for uranium mass concentration.
The average depth of monitor wells and groundwater extraction wells is approximately 30 feet, so each boring would yield six soil samples. Collection of six samples from each monitor well would result in 186 soil samples. Adding 10% duplicates yields a total of 204 samples. At a cost of $85.60 per sample, the cost of analysis alone would be approximately $17,460.
All monitor wells and extraction wells will be installed in areas where hundreds of soil samples have been collected and analyzed, none of which have yielded uranium concentrations exceeding the decommissioning (NRC) criterion of 30 picocuries per gram (pCi/g) total uranium above background. With a background value of 2.8 pCi/g uranium, the criterion is 32.8 pCi/g including background. In Burial Area #1, that would equate to approximately 32 micrograms (total uranium) per gram (of soil) (µg/g); in the Western Area that would equate to approximately 22 µg/g. The exact conversion from mass to activity will be determined based on the U-235 enrichment in the soil.
Incurring the cost to analyze this many soil samples in areas within which it is highly improbable that the decommissioning criterion could be exceeded is not supported under the As Low As Reasonably Achievable (ALARA) principle. Therefore, all of the samples described in the D-Plan and the RPP will be collected, but only one sample from each boring - the sampling exhibiting the highest gamma count for that boring - will be initially shipped to an off-site laboratory for uranium analysis. Should any such sample collected from a boring yield greater than 32.8 pCi/g, then all of the samples collected from that boring will be submitted for laboratory analysis.
This process will result in the identification of soil exceeding the NRG criterion without requiring the unnecessary expenditure of funds to analyze soil that complies with the NRG criterion for uranium.
Page 2 of 5
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-02 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Borings I Page 3 of 5 2.0 Does the proposed revision, test, and/or experiment ("action") represent a change to the NRC-approved Decommissioning Plan or Radiation Protection Plan?
X Yes If "Yes", proceed to section 4.0 for evaluation of the action.
No If "No", proceed to section 3.0 for evaluation of the action.
3.0 Is the proposed test or experiment present in the NRC-approved Decommissioning Plan or applicable license conditions?
Yes If "Yes", there is no need to conduct an evaluation.
No If "No", proceed to Section 4.0 for evaluation of the action.
4.0 Evaluation
LICENSE REQUIREMENT YES NO 4.1 Does the action conflict with requirements specifically stated in the license, other than the RPP YES NO or DP?
a) Does the action involve material not authorized by X
the license?
b) Are either the use or the place of use different X
from what the license authorizes?
c) Will the action violate training requirements?
X d) Are there procedures or procedure revisions X
which have not been approved by the RSO?
e) Does the action involve work in Restricted Areas or with licensed material not addressed in RP X
Procedures?
f)
Doe the action conflict with requirements in tie-downs stipulated in license conditions 10, 26, X
27(a), or 27(c)?
g) Does the action result in contamination exceeding X
limits stipulated in license condition 27?
N/A N/A Page 3 of 5
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-02 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Borings I Page 4 of 5 4.2 Does the action impair Cimarron Environmental Response Trust's ability to meet all applicable NRC YES NO N/A regulations?
a) Will the action cause an exceedance of dose limits for workers and members of the public?
X b) Does the action establish limits other than approved decommissioning criteria?
X c) Does the action violate requirements for surveys and monitoring, control of internal and external X
exposure, and control of licensed material?
d) Will the action violate precautionary procedures (posting, labeling, etc.)?
X e) Does the action violate waste disposal or record keeping requirements?
X 4.3 Does the action result in degradation of safety or environmental commitments addressed in the NRC-YES NO N/A approved RPP and/or DP, or health and safety?
a) Does the action result in greater release of licensed material to air or liquid effluents than X
planned actions?
b) Does the action result in the spread of licensed material to uncontaminated areas more than X
planned actions?
c) Does the action result in the loss of control over X
licensed material?
d) Have data quality objectives that achieve the X
required level of data quality not been addressed?
4.4 Does the action pose a significant adverse effect on YES NO N/A the quality of the work or the remediation objectives?
a) Does the action modify the intent to release the X
site for unrestricted use?
b) Does the action result in significant increase in the volume of material contaminated above license X
criteria?
c) Does the action contaminate unrestricted areas to X
the extent they will require decommissioning?
Page 4 of 5
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-02 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Borings I Page 5 of 5 4.5 Does the action conflict with the conclusions of actions analyzed in the Environmental Assessment, YES NO N/A dated July 29, 1999 and Safety Evaluation Report dated August 20, 1999?
a) Does the action render the environmental monitoring program unable to detect a release of X
licensed material to the environment?
b) Does the action increase the release of licensed X
material to groundwater, surface water, or air?
c) Does the action create the potential for an X
accident worse than that in the dose assessment?
d) Does the action result in an adverse X
socioeconomic impact to the communitv?
e) Does the action create other than short duration X
and minor impacts to air?
f)
Does the action adversely impact potential future X
land use?
g) Does the action adversely impact transportation X
plans for shipments to a licensed disposal site?
h) Does the action adversely impact endangered X
species?
i)
Does the action impact historic or archeological X
sites?
NOTE: If "YES" was answered in any of the Section 4 evaluation questions, the action cannot be performed without NRG approval. Provide any basis for determination of each answer provided in Section 4 as comments in Section 5.0, as appropriate.
5.0 Comments
This change is consistent with the ALARA principle of making every reasonable effort to maintain exposures to radiation as far below the dose limits in 10 CFR 20 as is practical, consistent with the purpose for which the licensed activity is undertaken.
Allocating additional resources (labor and money) to confirm that areas that have been demonstrated to be releasable under the NRG criteria meet the criteria does not result in any reduction in dose to workers or the public.
6.0 Results
I Revision, Test, or Experiment Approved:
Yes X
No Page 5 of 5
ATTACHMENT 3 27(E) Evaluation 2025-03 Analysis Of Soil Samples from Trenches
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 1 of 6 Submitted By (Signature/Date):
Preparer: Jeff Lux Approved By (Signature/Date):
Radiation Safety Officer:
Quality Assurance Coordinator:
Project Manager:
Trust Administrator:
Date: 2025.08.04 06:43:25 -05'00'
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Digitally signed by Jay Maisler, CHP DN: C=US, E=jmaisler@enercon.com, O=Cimarron Site, OU=Radiation Safety Officer, CN="Jay Maisler, CHP" Date: 2025.08.05 11 :03:32-04'00' Digitally signed by Charles Beatty Charles BeattV DN: C=US, E=cbeatty@enercon.com, r CN=Charles Beatty John R.
Date: 2025.08.05 14:01 :36-04'00' Digitally signed by Mathew D Crawford Date: 2025.08.05 16:46:17-05'00' Digitally signed by John R. Hesemann DN: C=US, Hes em an n E=jflesemann@burnsmcd.com, O=Burns
& McDonnell, CN=John R. Hesemann Date: 2025.08.05 17:39:49-05'00' Page 1 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 2 of 6 1.0 Description of Proposed Revision, Test, and/or Experiment:
Section 13.1.3 of Facility Decommissioning Plan - Rev 3 (the D-Plan) and Section 12.5.2 of Radiation Protection Plan - Rev 5 (the RPP) present a plan for the collection of soil samples from both shallow (less than 4 feet below grade) and deep (greater than 4 feet below grade) excavations during construction. These requirements apply to the construction of utility, piping, and instrumentation trenches as well as trenches dug to install effluent discharge piping and fiber optic cable. There is no need to conduct radiological surveys for surface soil (the top foot below grade), so this evaluation does not address any plans for surface soil.
The D-Plan and the RPP are written as though all soil excavated from trenches will be placed along the trenches in a linear fashion and surveyed and sampled as described in D-Plan Section 13.13 and RPP Section 12.5.2. Because most of the trenches are located either in the 100-year floodplain or adjacent to drainages or heavily wooded areas, it may not always be possible to manage excavated soil in this manner. Instead, soil excavated from excavations below 1 foot below grade (spoils) which is not acceptable for use as backfill may be transported to the excavated soil mixing area, to be mixed with sediment from the 1206 Drainage remediation area. Soil transported directly to the excavated soil mixing area would not be surveyed in accordance with D-Plan Section 13.13 and RPP Section 12.5.2. However, after mixing, the spoils/sediment in the excavated soil mixing area will be sampled in accordance with the requirements of NUREG-4859 as a "final status survey" of the excavated soil mixing area.
Shallow Trenches D-Plan Section 13.1.3 and RPP Section 12.5.2 state that after scanning subsurface soil with a gamma-sensitive survey instrument, one soil sample will be collected for laboratory analysis of total uranium for every 100 feet of trench length, and at "hot spot" locations identified by the gamma survey. Soil excavated from more than 1 foot below grade that is acceptable for use as backfill will be surveyed as described in D-Plan Section 13.1.3 and RPP Section 12.5.2. Soil excavated from more than 1 foot below grade that is deemed unacceptable for use as backfill will be transferred to the excavated soil mixing area.
Subsurface soil in trenches completed in the upland area (underlain by mostly sandstone) is expected to be unusable as backfill. This soil will be transferred to the excavated soil mixing area to be mixed with sediment and other soil. There will be approximately 72,000 cubic feet (ft3) of soil transferred from shallow trenches to the excavated soil mixing area.
Approximately 4,800 feet of shallow trenches will be completed in upland areas, so the D-Plan and RPP would require a minimum of 48 soil samples to be collected for laboratory analysis.
This represents approximately one sample per 1,500 ft3 of soil excavated from shallow trenches. Following placement of trench spoils transferred to the excavated soil mixing area, one sample of the spoils/sediment mixture will be collected at one-foot depth increments on a 10-meter grid. This represents one soil sample per 1,090 ft3. Consequently, there is no need to collect soil samples from shallow trenches completed in upland areas prior to transporting it to the excavated soils mixing area since it will be sampled in the excavated soil mixing area.
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 3 of 6 Deep Excavations D-Plan Section 13.1.3 and RPP Section 12.5.2 describe the same RP survey process for deep excavations, for all soil excavated from 1 foot below grade to total depth, with the exception that soil samples are to be collected at 50-foot intervals rather than at 100-foot intervals.
Soil excavated from 1 foot below grade to 3 feet below grade will be returned to the trench after installing gravel from three feet below grade to total depth. This soil will be laid out (either in windrows or spread over an area) near the trench or in an area outside of the 100-year floodplain. This soil will be surveyed in accordance with the D-Plan and the RPP at a frequency of one sample per 50 feet of trench.
Soil (or a soil/slurry mix) greater than 3 feet below grade will be transferred to the excavated soil mixing area to be mixed with sediment and other soil. There will be approximately 48,300 ft3 of soil transferred to the excavated soil mixing area.
At one soil sample per 50 feet of trench, the D-Plan and RPP would require a minimum of 20 soil samples to be collected. This represents approximately one sample per 2,400 ft3 of soil.
One soil sample of the spoils/sediment mixture in the excavated soil mixing area will be collected at 1-foot depth increments on a 10-meter grid. This represents 1 soil sample per 1,090 ft3 of soil. Because spoils in the excavated soil mixing area will be sampled at a greater frequency than that specified in the DP and the RPP, there is no need to collect soil samples prior to transferring this material to the excavated soil mixing area.
Conclusion Incurring the cost to submit soil samples upon excavation and again in the excavated soil mixing area for the same material is not justifiable on an As Low As Reasonably Achievable (ALARA) basis. This evaluation was conducted to determine if NRG approval is required to eliminate duplicative sampling of soil excavated from below 1 foot below grade in shallow trenches constructed in upland areas, and for soil excavated below 3 feet below grade in deep trenches.
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 4 of 6 2.0 Does the proposed revision, test, and/or experiment ("action") represent a change to the NRC-approved Decommissioning Plan or Radiation Protection Plan?
X Yes If "Yes", proceed to section 4.0 for evaluation of the action.
No If "No", proceed to section 3.0 for evaluation of the action.
3.0 Is the proposed test or experiment present in the NRC-approved Decommissioning Plan or applicable license conditions?
Yes If "Yes", there is no need to conduct an evaluation.
No If "No", proceed to Section 4.0 for evaluation of the action.
4.0 Evaluation
LICENSE REQUIREMENT YES NO 4.1 Does the action conflict with requirements specifically stated in the license, other than the RPP YES NO or DP?
a) Does the action involve material not authorized by X
the license?
b) Are either the use or the place of use different X
from what the license authorizes?
c) Will the action violate training requirements?
X d) Are there procedures or procedure revisions X
which have not been approved by the RSO?
e) Does the action involve work in Restricted Areas or with licensed material not addressed in RP X
Procedures?
f)
Doe the action conflict with requirements in tie-downs stipulated in license conditions 10, 26, X
27(a), or 27(c)?
g) Does the action result in contamination exceeding X
limits stipulated in license condition 27?
N/A N/A Page 4 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 5 of 6 4.2 Does the action impair Cimarron Environmental Response Trust's ability to meet all applicable NRC YES NO N/A regulations?
a) Will the action cause an exceedance of dose limits for workers and members of the public?
X b) Does the action establish limits other than approved decommissioning criteria?
X c) Does the action violate requirements for surveys and monitoring, control of internal and external X
exposure, and control of licensed material?
d) Will the action violate precautionary procedures (posting, labeling, etc.)?
X e) Does the action violate waste disposal or record keeping requirements?
X 4.3 Does the action result in degradation of safety or environmental commitments addressed in the NRC-YES NO N/A approved RPP and/or DP, or health and safety?
a) Does the action result in greater release of licensed material to air or liquid effluents than X
planned actions?
b) Does the action result in the spread of licensed material to uncontaminated areas more than X
planned actions?
c) Does the action result in the loss of control over X
licensed material?
d) Have data quality objectives that achieve the X
required level of data quality not been addressed?
4.4 Does the action pose a significant adverse effect on YES NO N/A the quality of the work or the remediation objectives?
a) Does the action modify the intent to release the X
site for unrestricted use?
b) Does the action result in significant increase in the volume of material contaminated above license X
criteria?
c) Does the action contaminate unrestricted areas to X
the extent they will require decommissioning?
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-03 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 I Analysis of Soil Samples from Trenches I Page 6 of 6 4.5 Does the action conflict with the conclusions of actions analyzed in the Environmental Assessment, YES NO N/A dated July 29, 1999 and Safety Evaluation Report dated August 20, 1999?
a) Does the action render the environmental monitoring program unable to detect a release of X
licensed material to the environment?
b) Does the action increase the release of licensed X
material to groundwater, surface water, or air?
c) Does the action create the potential for an X
accident worse than that in the dose assessment?
d) Does the action result in an adverse X
socioeconomic impact to the communitv?
e) Does the action create other than short duration X
and minor impacts to air?
f)
Does the action adversely impact potential future X
land use?
g) Does the action adversely impact transportation X
plans for shipments to a licensed disposal site?
h) Does the action adversely impact endangered X
species?
i)
Does the action impact historic or archeological X
sites?
NOTE: If "YES" was answered in any of the Section 4 evaluation questions, the action cannot be performed without NRG approval. Provide any basis for determination of each answer provided in Section 4 as comments in Section 5.0, as appropriate.
5.0 Comments
This change is consistent with the ALARA principle that means making every reasonable effort to maintain exposures to radiation as far below the dose limits in 10 CFR 20 as is practical consistent with the purpose for which the licensed activity is undertaken. Allocating additional resources (labor and money) to confirm that areas that have been demonstrated to be releasable under the NRG criteria does not result in any reduction in dose to workers or the public.
6.0 Results
I Revision, Test, or Experiment Approved:
Yes X
No Page 6 of 6
ATTACHMENT 4 27(E) Evaluation 2025-04 Analysis Of Soil Samples from the Western Area Treatment Facility
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Submitted By (Signature/Date):
Preparer: Jeff Lux Approved By (Signature/Date):
Radiation Safety Officer:
Quality Assurance Coordinator:
Project Manager:
Trust Administrator:
Analysis of Soil Samples from the Page 1 of 6 Western Area Treatment Facility Date: 2025.08.04 06:44:33 -05'00' Digitally signed by Charles Beatty Charles Beatt\\1/ DN: C=US, E=cbeatty@enercon.com, 1-CN=Charles Beatty Date: 2025.08.05 14:02:03-04'00' John R.
Digitally signed by Mathew D Crawford Date: 2025.08.05 16:45:53-05'00' Digitally signed by John R. Hesemann DN: C=US, E=jhesemann@burnsmcd.com, Hesemann O=Burns & McDonnell, CN=John R.
Hesemann Date: 2025.08.05 17:39:34-05'00' Page 1 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Analysis of Soil Samples from the Page 2 of 6 Western Area Treatment Facility 1.0 Description of Proposed Revision, Test, and/or Experiment:
Section 13.1.3 of Facility Decommissioning Plan - Rev 3 (the D-Plan) and Section 12.5.2 of Radiation Protection Plan - Rev 5 (the RPP) present a plan for the collection of soil samples from the Western Area Treatment Facility (WATF) during construction. These requirements apply to the surface soil (the top foot of soil) when the contractor achieves final grade, prior to constructing small excavations for footings and foundations, and to surface soil in the shallow excavations for footings and foundations.
Following the establishment of final grade in the WATF, the D-Plan and the RPP require a ten-meter grid to be established over the entire area (approximately 375 feet by 425 feet). A gamma walk-over survey of the disturbed area will be conducted, and the location within each 10-meter grid exhibiting the highest gamma scan reading will be flagged. A soil sample will be collected from each flagged location for laboratory analysis of total uranium. If all samples were submitted for laboratory analysis, Including 10% duplicates, this process is expected to generate approximately 170 soil samples requiring laboratory analysis, at cost of over $14,000 for laboratory analysis alone.
Both surface and subsurface soil have been demonstrated to comply with the decommissioning (NRG) criterion for unrestricted release throughout the WATF area. In addition, there were no burial trenches or impoundments historically present in the WATF area. A pipeline that transferred impacted water to Uranium Ponds #1 and #2 ran along the road on the eastern and northern edge of the WATF area. Final Status Survey Report for Subarea "N"presents the results of the final status survey conducted after the pipeline was removed. Soil samples were collected on a 5-meter grid throughout the area where the pipeline was located at depth intervals of 0'-6", 6-12", 1-2', 2-3', and 3-4'. Of over 1,000 soil samples collected along the pipeline route, only 1 soil sample exceeded the NRG criterion. Soil at this sample location was over-excavated and buried in the on-site disposal cell later designated Burial Area #4.
The WATF area is located within Subareas I and N. The NRG agreed that Subareas I and N were releasable for unrestricted use. At the request of the licensee, the WATF area was brought under license in Amendment 22 in NRG License SNM-928 because groundwater will be delivered via pipeline to the WATF area for treatment, and uranium-impacted resin will be stored on site for shipment to a licensed disposal facility.
EPM will revise the radiological survey requirement for laboratory analysis of soil samples in the WATF area as follows. Samples will be collected in accordance with Section 13.1.3 of the D-Plan; however, only the ten samples from locations yielding the highest gamma scan measurements, and any soil sample collected from a location where the gamma scan measurement exceeds two times background, will be submitted for laboratory analysis of uranium. If none of those samples yield concentrations exceeding the decommissioning criterion, no other soil samples will be submitted for laboratory analysis as the other samples would be expected to contain lower uranium concentrations. If anv soil sample vields Page 2 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Analysis of Soil Samples from the Page 3 of 6 Western Area Treatment Facility concentrations exceeding the decommissioning criterion, additional soil samples will be submitted for laboratory analysis in accordance with Section 13.1.3 of the D-Plan.
Page 3 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Analysis of Soil Samples from the Page 4 of 6 Western Area Treatment Facility Does the proposed revision, test, and/or experiment ("action") represent a change to the NRC-ap d D Pl R d" r p t r Pl
?
I:>rove ecomm1ss1omna an or a 1a 10n ro ec 10n an.
X Yes If "Yes", proceed to section 4.0 for evaluation of the action.
No If "No", proceed to section 3.0 for evaluation of the action.
2.0 Is the proposed test or experiment present in the NRC-approved Decommissioning Plan or applicable license conditions?
Yes If "Yes", there is no need to conduct an evaluation.
No If "No", proceed to Section 4.0 for evaluation of the action.
3.0 Evaluation
LICENSE REQUIREMENT YES NO 4.1 Does the action conflict with requirements specifically stated in the license, other than the RPP YES NO or DP?
a) Does the action involve material not authorized by X
the license?
b) Are either the use or the place of use different X
from what the license authorizes?
c) Will the action violate training requirements?
X d) Are there procedures or procedure revisions X
which have not been approved by the RSO?
e) Does the action involve work in Restricted Areas or with licensed material not addressed in RP X
Procedures?
f)
Doe the action conflict with requirements in tie-downs stipulated in license conditions 10, 26, X
27(a), or 27(c)?
g) Does the action result in contamination exceeding X
limits stipulated in license condition 27?
N/A N/A Page 4 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Analysis of Soil Samples from the Page 5 of 6 Western Area Treatment Facility 4.2 Does the action impair Cimarron Environmental Response Trust's ability to meet all applicable NRC YES NO N/A regulations?
a) Will the action cause an exceedance of dose limits for workers and members of the public?
X b) Does the action establish limits other than approved decommissioning criteria?
X c) Does the action violate requirements for surveys and monitoring, control of internal and external X
exposure, and control of licensed material?
d) Will the action violate precautionary procedures (posting, labeling, etc.)?
X e) Does the action violate waste disposal or record keeping requirements?
X 4.3 Does the action result in degradation of safety or environmental commitments addressed in the NRC-YES NO N/A approved RPP and/or DP, or health and safety?
a) Does the action result in greater release of licensed material to air or liquid effluents than X
planned actions?
b) Does the action result in the spread of licensed material to uncontaminated areas more than X
planned actions?
c) Does the action result in the loss of control over X
licensed material?
d) Have data quality objectives that achieve the X
required level of data quality not been addressed?
4.4 Does the action pose a significant adverse effect on YES NO N/A the quality of the work or the remediation objectives?
a) Does the action modify the intent to release the X
site for unrestricted use?
b) Does the action result in significant increase in the volume of material contaminated above license X
criteria?
c) Does the action contaminate unrestricted areas to X
the extent they will require decommissionina?
Page 5 of 6
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Cimarron Environmental Response Trust envi ronmenta I License Condition 27(e) Change Evaluation 2025-04 properties management. LLC Form QAIP 2.2-1, Rev. 3.1 Analysis of Soil Samples from the Page 6 of 6 Western Area Treatment Facility 4.5 Does the action conflict with the conclusions of actions analyzed in the Environmental Assessment, YES NO N/A dated July 29, 1999 and Safety Evaluation Report dated August 20, 1999?
a) Does the action render the environmental monitoring program unable to detect a release of X
licensed material to the environment?
b) Does the action increase the release of licensed X
material to groundwater, surface water, or air?
c) Does the action create the potential for an X
accident worse than that in the dose assessment?
d) Does the action result in an adverse X
socioeconomic impact to the community?
e) Does the action create other than short duration X
and minor impacts to air?
f)
Does the action adversely impact potential future X
land use?
g) Does the action adversely impact transportation X
plans for shipments to a licensed disposal site?
h) Does the action adversely impact endangered X
species?
i)
Does the action impact historic or archeological X
sites?
NOTE: If "YES" was answered in any of the Section 4 evaluation questions, the action cannot be performed without NRG approval. Provide any basis for determination of each answer provided in Section 4 as comments in Section 5.0, as appropriate.
5.0 Comments
This change is consistent with the ALARA principle that means making every reasonable effort to maintain exposures to radiation as far below the dose limits in 10 CFR 20 as is practical consistent with the purpose for which the licensed activity is undertaken. Allocating additional resources (labor and money) to confirm that areas that have been demonstrated to be releasable under the NRC criteria does not result in any reduction in dose to workers or the public.
6.0 Results
I Revision, Test, or Experiment Approved:
Yes X
No Page 6 of 6