ML25241A037
| ML25241A037 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 09/17/2025 |
| From: | James Smith NRC/NMSS/DDUWP/URMDB |
| To: | Cimarron Environmental Response Trust |
| Shared Package | |
| ML25241A034 | List: |
| References | |
| Download: ML25241A037 (1) | |
Text
Enclosure 2 Safety Evaluation Report DATE:
August 25, 2025 DOCKET:
070-00925 LICENSEE:
Cimarron Environmental Response Trust (CERT)
SITE:
Cimarron Fuel Processing Facility Cimarron, Oklahoma PROJECT MANAGER:
James Smith TECHNICAL REVIEWER:
Marti Poston
SUBJECT:
REQUEST TO AMEND LICENSE SNM-928 TO MODIFY REFERENCES IN LC 27(e)(iv)(c) AND CORRECT SOME TYPOGRAPHICAL ERRORS
SUMMARY
In its letter dated April 25, 2025, Agencywide Document Access and Management System (ADAMS) (ML25115A153), the Cimarron Environmental Response Trust (CERT) requested that its license be amended to revised to modify references in LC 27(e)(iv)(c) and correct some typographical errors.
LC 27(e)(iv)(c) REVISION:
The License Amendment Request seeks to revise LC 27(e)(iv)(c) to change the references from the 1999 Safety Evaluation Report (SER) and the 1999 Environmental Assessment (EA), to references to the 2024 Environmental Assessment, dated November 29, 2024, ADAMS (ML24334A062) and the 2024 Safety Evaluation Report, dated December 20, 2025 ADAMS (ML24264A155), for License Amendment 22 (ML24339A701), approving Decommissioning Plan, Rev.3.
Specifically, the licensee asks that License Condition (LC)27(e)(iv)(c) be revised from its current condition in Amendment 22:
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).
To the proposed rewrite:
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.
2 TYPOGRAPHICAL ERRORS:
Additionally, EPM recommends that the NRC also correct three minor errors in Amendment 22:
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.
The staff concludes that these are typographical errors, and as such, they will be corrected in Amendment 23, without further analysis or discussion.
EVALUATION:
In this amendment, the licensee seeks to amend the 1999 SER and EA references contained in LC 27(e)(iv)(c) to instead reference the 2024 SER and EA that analyzed the most recent and approved Decommissioning Plan (DP). According to the licensee, the 1999 references currently in LC 27(e)(iv)(c) require effluent sampling and analysis for gross alpha and gross beta to determine technicium-99 content in effluents; however, with the 2024 approval of the most recent DP which now seeks to actively remediate the groundwater, this monitoring is no longer required.
Since the NRCs approval of the Cimarron Decommissioning Plan in 1999, Amendment 15 (ML092680911) the site has been in a decommissioning status, materials and equipment, buildings and structures, and surface and subsurface soils have been decommissioned and much of the original site has been released from the license. However, the groundwater continues to not meet the uranium concentrations for release.
When Amendment 15 was issued, the site relied upon monitored natural attenuation (MNA) to reduce uranium concentrations in the groundwater to levels that would meet the groundwater release criteria specified in the license. It was assumed that MNA would gradually reduce the concentration of uranium in the groundwater sufficiently enough to meet the release criteria for uranium, allowing the license to be terminated. However, by 2015, since in some portions of the site, uranium in the groundwater continued to exceed those levels long after the surface structures, soils, and other contaminated items were removed from the site, the CERT made a determination that MNA was not going to be successful in reducing uranium concentrations in groundwater to unrestricted release criteria in an acceptable timeframe. Therefore, in a letter dated, December 31, 2015 (ML16194A333), the CERT requested revisions to the DP to modify the plan from MNA to allow for active groundwater remediation with the goal of meeting the previously approved 180 picocuries per liter (pCi/L) total uranium criteria for unrestricted use in a reasonable timeframe.
In the intervening years, the CERT proposed several revised version DPs, culminating with the submittal of the 2022 Facility Decommissioning Plan - Rev 3, which successfully addressed technical, regulatory, legal, and financial issues, and was approved by the NRC in December 2024. According to this DP, instead of the MNA, an active remediations system will be built, where contaminated groundwater will be extracted and piped to an on-site treatment facility and 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
3 remediation process. 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.
The staff concludes that the 1999 SER (ML092680911) was prepared for a decommissioning plan that did not include active remediation of groundwater, as is now the plan under the approved Facility Decommissioning Plan - Rev 3, which was approved in 2024. The radiological considerations evaluated for the 1999 SER are not relevant to any currently active remediation method; therefore, there is no reason to reference 1999 SER (or the 1999 EA (ML092680912))
for future construction and operations related to the groundwater remedy planned for the site.
Instead, the staff has determined that amending the license condition to reference the 2024 SER and EA is appropriate, and, therefore, approves the amendment request.
CATEGORICAL EXCLUSION The staff has further determined that Amendment 23 to License SNM-928 qualifies for categorical exclusions under 10 CFR 51.22(c)11 because the amendment to License Condition 27(e)(iv)(c) is administrative, procedural, organizational, or result in a change in process operations or equipment where (i) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (ii) there is no significant increase in individual or cumulative occupational radiation exposure, (iii) there is no significant construction impact, and (iv) there is no significant increase in the potential for or consequences from radiological accidents. The staffs determination, which is also described in the Safety Evaluation Report for this amendment, is based on the following NRC staff findings:
This amendment is an administrative change that meets the specific criteria in 10 CFR 51.22(c)11. This amendment seeks no changes to the decommissioning processes as approved in the DP Rev 3. The original LC 27(e)(iv)(c) referred to the 1999 Environmental Assessment (EA) and the 1999 Safety Evaluation Report (SER), and this amendment seeks to update these references to instead cite to the 2024 SER and 2024 EA, which support the DP Rev 3. The only practical difference in updating the citations in the license condition from citing the 1999 SER and EA to cite the 2024 SER and EA is that the 1999 SER and EA required effluent monitoring that is no longer needed under the most recently approved DP - Rev 3, as the site is now under active groundwater remediation. Therefore, this amendment does not impact the types or amounts of any effluents that may be released; does not result in a significant increase in individual or cumulative occupational exposure; does not result in significant construction impacts; and does not result in significant increase in the potential for or consequences from radiological accidents.
CONCLUSION:
Based on this evaluation, the staff has concluded that amending the license to correct minor editorial errors (as noted above), and to update the references in License Condition (LC)27(e)(iv)(c) is appropriate. Therefore, LC 27(e)(iv)(c) will be revised, as follows:
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.