ML25365A982

Environmental Properties Management, Llc., License Amendment Request RSO Change

ML25365A982
Person / Time
Site:	07000925 (SNM-0928)
Issue date:	12/31/2025
From:	Melissa Crawford Environmental Properties Management
To:	James Smith Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
Download: ML25365A982 (0)

Text



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December 31, 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 RSO Change

Dear Recipients:

Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) hereby notifies the U.S. Nuclear Regulatory Commission (NRC) that Mr. Jay Maisler, Radiation Safety Officer (RSO) for the Cimarron Environmental Response Trust, will retire effective December 31, 2025. Accordingly, EPM submits a request (Attachment 1) to amend U.S.

Nuclear Regulatory Commission License SNM-928 to designate Mr. Dane Watson of Enercon Services, Inc. (ENERCON) as the new RSO.

Mr. Watson has supported the Cimarron Site decommissioning project since joining ENERCON in 2020.

Since August 2021, he has served as the ENERCON Project Manager and has been actively engaged in all aspects of ENERCONs support at the Site, including radiation protection, quality assurance, environmental monitoring, and licensing activities. As documented in Mr. Watsons résumé (included in ), he provides technical support for radiation safety, radiological effluent monitoring, and radioactive waste management associated with the Site.

Mr. Watson has served as the RSO alternate for the past five years and has over 13 years of experience supporting decommissioning projects. Through this work, he has gained extensive experience in the development and implementation of radiation protection programs..

If you have any questions or desire clarification, please call me at 816-652-2784.

Sincerely, Mathew Crawford, Trustee Project Manager

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envi ronmenta I properties management. LLC

December 31, 2025 Page 2



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cc: (electronic copies only)

Stephanie Anderson and Linda Gersey, NRC Region IV Jonathan Reid, Rachel Miller, Paul Davis, Ellen Isbel, and Keisha Cornelius, DEQ NRC Public Document Roomcpsubmittals@deq.ok.gov R4licensing@nrc.gov Attachments:

• - Form 313 LAR - SNM-928

NRC FORM 313 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0120 EXPIRES: 07/31/2026 (11 2025) f>R REGu(

Estimated burden per response to comply with this mandatory collection request: 4.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Submittal of the application is 10 CFR 30, 32,

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necessary to determine that the applicant is qualified and that adequate procedures exist to protect the public health and safety.

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APPLICATION FOR Send comments regarding burden estimate to the FOIA, Library, and Information Colections Branch (T-6 A10M), U.S. Nuclear 37, 39, and 40

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0 Regulatory Commission, Washington, DC 20555-0001, or by email to lnfoccllects.Resource@nrc.gov, and the 0MB Reviewer at:

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MATERIALS LICENSE 0MB Office of Information and Regulatory Affairs, (3150-0120), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 C

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ii; 17th Street NW, Washington, DC 20503. The NRC may not conduct or sponsor, and a person is not required to respond to, a

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collection of information unless the document requesting or requiring the coleclion displays a currently valid 0MB control number.

INSTRUCTIONS: SEE THE CURRENT VOLUMES OF THE NUREG-1556 TECHNICAL REPORT SERIES ("CONSOLIDATED GUIDANCE ABOUT MATERIALS LICENSES") FOR DETAILED INSTRUCTIONS FOR COMPLETING THIS FORM: http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/. SEND ONE COPY OF THE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW OR ONLINE AT https://www.nrc.gov/securitl1lbl1Product/ism11/wbl.html.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH:

IF YOU ARE LOCATED IN:

MATERIALS SAFETY AND LICENSING BRANCH ILLINOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO, OR WISCONSIN, SEND DIVISION OF MATERIALS SAFETY, SECURITY, STATE AND TRIBAL PROGRAMS APPLICATIONS TO:

OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS U.S. NUCLEAR REGULATORY COMMISSION MATERIALS LICENSING BRANCH 11555 ROCKVILLE PIKE DIVISION OF RADIOLOGICAL SAFETY AND SECURITY ROCKVILLE, MD 20852-2738 U.S. NUCLEAR REGULATORY COMMISSION, REGION Ill

• NOTE: The preferred method to submit NRC Form 313 is online at 2056 WESTINGS AVENUE, SUITE 400 htt11s://www nrc ggv/s!,CYri!Yil1lll!rQdyct/ism11/wbl html or email at NAPERVILLE, IL 60563-2657 LBLiQ.ensingA~§i~tant B.e~QUCQe@nrQ gQv.

• NOTE: The preferred method to submit NRC Form 313 is online at Any other documents (e.g., financial assurance documents) should be sent via email.

https:llwww nrc ggv/securilwbllPrQduct/ismJlliYQ!.hlm! or email at R3-DRSSMAIL Resgurce@nrc ggv.

Any other documents (e.g., financial assurance documents) should be sent via email.

ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS:

IF YOU ARE LOCATED IN:

IF YOU ARE LOCATED IN:

ALABAMA, CONNECTICUT, DELAWARE, DISTRICT OF COLUMBIA, FLORIDA, ALASKA, ARIZONA, ARKANSAS, CALIFORNIA, COLORADO, HAWAII, IDAHO, KANSAS, GEORGIA, KENTUCKY, MAINE, MARYLAND, MASSACHUSETTS, NEW HAMPSHIRE, LOUISIANA, MISSISSIPPI, MONTANA, NEBRASKA, NEVADA, NEW MEXICO, NORTH NEW JERSEY, NEW YORK, NORTH CAROLINA, PENNSYLVANIA, PUERTO RICO, DAKOTA, OKLAHOMA, OREGON, PACIFIC TRUST TERRITORIES, SOUTH DAKOTA, TEXAS, RHODE ISLAND, SOUTH CAROLINA, TENNESSEE, VERMONT, VIRGINIA, VIRGIN UTAH, WASHINGTON, OR WYOMING, ISLANDS, OR WEST VIRGINIA, SEND APPLICATIONS TO:

SEND APPLICATIONS TO:

LICENSING ASSISTANCE TEAM MATERIALS LICENSING BRANCH DIVISION OF RADIOLOGICAL SAFETY AND SECURITY DIVISION OF RADIOLOGICAL SAFETY AND SECURITY U.S. NUCLEAR REGULATORY COMMISSION, REGION I U.S. NUCLEAR REGULATORY COMMISSION, REGION IV 475 ALLENDALE ROAD, SUITE 102 1600 E. LAMAR BOULEVARD KING OF PRUSSIA, PA 19406-1415 ARLINGTON, TX 76011-4511

• NOTE: The preferred method to submit NRC Form 313 is online at

• NOTE: The preferred method to submit NRC Form 313 is online at https:llwww nrc gQV/J;!lCYrilll/bllPrQdyct/ismJlliYQ!.hlm! or email at https:llwww nrc ggv/wcurit:,dbl/PrQdycUismp/wbl html or email at R41irensing@nrc ggv.

R1 DRSSMail R!asQyrc!,@nrc gov.

Any other documents (e.g., financial assurance documents) should be sent via email.

Any other documents (e.g., financial assurance documents) should be sent via email.

PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULA TORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISDICTIONS.

1. THIS JS AN APPLICATION FOR (Check appropriate item)

2. NAME AND MAILING ADDRESS OF APPLICANT (Include zip code)

A. NEW LICENSE c/o Environmental Properties Management, LLC 0 B. AMENDMENT TO LICENSE NUMBER SNM-928 9400 Ward Parkway C. RENEWAL OF LICENSE NUMBER Kansas City, MO 64114

3. LIST ADDRESS AND/OR TEMPORARY JOB SITE (T JS) ADDRESS, WHERE LICENSED MATERIALS WILL BE USED OR POSSESSED

4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION The licensee's Cimarron Uranium Plant, located 1/2 mile Matt Crawford North of Hwy 33 and Hwy 7 4 junction near Crescent, BUSINESS TELEPHONE NUMBER I

BUSINESS CELLULAR TELEPHONE NUMBER Oklahoma, with areas defined by the map in Figure 6-4, 816 652-2784 785 317 -4535 in Attachment 3 to EPM's July 3, 2024, comments on the BUSINESS EMAIL ADDRESS draft Environmental Assessment (ML24185A228).

mdcrawford@burnsmcd.com SUBMIT ITEMS 5 THROUGH 11 ON 8-1/2 X 11" PAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED JS DESCRIBED IN THE APPLICABLE LICENSING GUIDANCE.

5. RADIOACTIVE MATERIAL

6. PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED.

a. Element and mass number; b. chemical and/or physical form; and c. maximum amount

7. INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND which will be possessed at any one time.

EXPERIENCE.

8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS.

9. FACILITIES AND EQUIPMENT.

10. RADIATION SAFETY PROGRAM.

11. WASTE MANAGEMENT.

12. LICENSE FEES (Fees required only for new applications, at time of application submission, with few exceptions*)

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AMOUNT I I

(See 10 CFR 170 and Section 170.31) cA-iE~"oRv P~?o8V~A $

• Amendments/Renewals that increase the scope of the existing license to a new or higher fee category will require a fee.

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PER THE DEBT COLLECTION IMPROVEMENT ACT OF 1996 (PUBLIC LAW 104-134), YOU ARE REQUIRED TO PROVIDE YOUR TAXPAYER IDENTIFICATION NUMBER. PROVIDE THIS INFORMATION BY COMPLETING NRC FORM 531 : https:l[www.nrc.gov/reading-rm/doc-<:ollections/forms/nrc531info.html. FAX THE COMPLETED NRC FORM 531 TO (301) 415~725.

13. CERTIFICATION. (Must be completed by applicant) THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPL/CATION ARE BINDING UPON THE APPLICANT.

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT, NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS PREPARED IN CONFORMITY WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30, 32, 33, 34, 35, 36, 37, 39, AND 40, AND THAT ALL INFORMATION CONTAINED HEREIN JS TRUE AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF.

WARNING: 18 U.S.C. SECTION 1001 ACT OF JUNE 25, 1948, 62 STAT. 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION.

CERTIFYING OFFICER - TYPED/PRINTED NAME AND TITLE

'SIGNATURE ~

Digitally signeddr:1hew D Mathew Crawford - Trustee Project Manager Crawford Date: 2025.12. 1 09:13:52-06'00'

Attachment to License Amendment Request SNM-928 Item Description 5

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Cimarron Environmental Response Trust requests a license amendment naming Mr. Dane Watson as the radiation safety officer for the Cimarron site.

NUREG-1556, Volume 17, Section 8. 7.1 discusses information that an Applicant must provide for the Radiation Safety Officers(RSO). An RSO must have training and specific experience appropriate for the types and quantities of licensed material to be authorized on the license. NRC believes that to demonstrate adequate training and experience, the RSO should have:

(1) sufficient knowledge of physical, chemical, biological sciences, or engineering; and (2) training and experience commensurate with the scope of proposed activities.

Further, Section 3.9 of the Cimarron Radiation Protection Plan (RPP) requires the RSO to document qualifications of individuals designated to perform specific RSO responsibilities. Consistent with Section 3.9.1 of the RPP, prior to designating Dane Watson as the interim RSO, Mr. Watson was considered using the following criteria:

• The designated individual should have a bachelors' degree in the physical sciences, industrial hygiene or engineering from an accredited college or university: Mr. Watson earned a Master of Science in Mechanical Engineering from the Naval Postgraduate School. He earned his Bachelor of Science degree in Aeronautical Engineering from the United States Naval Academy. This education meets the requirement for a bachelor's degree in engineering.

• The designated individual should have at least one year of work experience in applied health physics, industrial hygiene or similar work relevant to radiological hazards associated with site remediation. This experience should involve actually working with radiation detection and measurement equipment, not simply administrative or "desk" work: Mr. Watson has worked in several capacities on various decommissioning projects where he gained valuable experience with radiation protection program development and implementation for 13 years. Mr. Watson has worked on the Cimarron Site decommissioning project since joining ENERCON in 2020. Since August 2021, Mr. Watson has served as the ENERCON Project Manager engaged with all aspects of ENERCON support at the Site, including radiation protection, quality assurance, environmental monitoring, and licensing.

Mr. Watson provides technical support for radiation safety, radiological

Attachment to License Amendment Request SNM-928 effluent monitoring, and radioactive waste management associated with the Site. He has served as the RSO backup for 5 years. His broader experience includes radiation protection-related experience on other radiological remediation projects, including license termination. Prior to joining ENERCON, Mr. Watson served as the site manager of a group that specialized nuclear and environmental remediation and restoration He led the team that decontaminated, decommissioned, and demolished four separate buildings in support of Naval Reactors at Bettis Laboratory.

• The designated individual should have a thorough knowledge of the proper application and use of all health physics equipment used for the radionuclides present at the Site, the chemical and analytical procedures used for radiological sampling and monitoring, and methodologies used to calculate personnel exposure to the radionuclides present at the Site: Commensurate with his experience described above, Mr. Watson has been engaged with all aspects of radiological sampling and monitoring used at the Cimarron Site. He has frequently provided evaluation and training of Health Physics Task Qualified Individuals at the Cimarron Site. He has demonstrated his understanding of the methodologies used to calculate personnel exposure to uranium to the extent applicable at the Cimarron Site. He has worked on other projects dealing with calculating personnel exposures to radionuclides used at other licensed facilities that are not encountered at the Cimarron Site.

• The individual must have the appropriate specialized knowledge to perform the designated responsibility: Mr. Watson has broad experience and knowledge related to various aspects of decommissioning activities at the Cimarron Site. His broad experience includes, leadership and management, project planning and execution, mechanical design and operation, environmental licensing, cost estimation, and decontamination and decommissioning. Mr. Watson has also developed and provided training programs on occupational radiation safety, use of radiological instrumentation, survey techniques, and industrial safety.

The NRC was notified on November 19,2025 during the Cimarron Decommissioning Project Status meeting. Meeting minutes can be found at accension ML25342A084. A copy of Mr. Watson's resume is attached.

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ENERCON DANE M. WATSON. PMP Manager, Environmental Licensing Professional Years of Experience - 19 EDUCATION:

Master of Science, Mechanical Engineering, Naval Postgraduate School Bachelor of Science, Aeronautical Engineering, United States Naval Academy PROFESSIONAL ASSOCIATIONS:

Project Management Professional (PMP #2010241)

Engineer in Training TRAININGS:

Naval Nuclear Power School and Protype Training, U.S. Navy, 2009 Facility Decommissioning Training Course, ANL, 2015 40-Hour HAZWOPER Training, Safety Unlimited, 2020 (maintained current) 8-Hour HAZWOPER Supervisor Training, Safety Unlimited, 2023 40-Hour Radiation Safety Officer Online Training Course, ORAU, 2025 NOTABLE SKILLS: Experience in leadership and management, project planning and execution, mechanical design and operation, environmental licensing, cost estimation, and decontamination and decommissioning. Experience providing and developing training programs on occupational radiation safety, use of radiological instrumentation, survey techniques, and industrial safety.

SUMMARY

Mr. Watson manages nuclear and environmental decommissioning projects across the United States and Canada. He manages a diverse staff of engineers and technicians that provide support to clients at any stage of decommissioning, from transition to operations straight to license termination. Mr. Watson manages the decommissioning cost estimate team, an ENERCON group which provides services to all sectors of the nuclear industry from initial licensing through the generation of a license termination plan.

Mr. Watson also manages ENERCON's radiological service team which can provide support to clients with various services and positions like instrument technicians, radiological waste shipping, or Radiation Safety Officers. Mr. Watson is also a project manager and subject matter expert for several environmental licensing projects, to include construction permit applications, early site permits, and subsequent license renewal.

Previous to ENERCON, Mr. Watson was the site manager of a multi-discipline team responsible for planning and execution of a multi-year decommissioning and decontamination project, facility infrastructure/support, and underground hydrological monitoring projects at Bettis Laboratory (part of Naval Nuclear Laboratory) in West Mifflin, PA. Prior to that, Mr. Watson did six years of active-duty military, serving as a Surface Warfare Commissioned Officer in the U.S. Navy. He trained and qualified as a Nuclear Officer, responsible for the operation of the engineering plant aboard a nuclear-powered aircraft carrier.

ENERCON PROFESSIONAL EXPERIENCE Cimarron Decommissioning / Cimarron, OK 10/20 - Present Mr. Watson has been a radiological subject matter expert for the project since October 2020 which provides decommissioning, radiological protection, and licensing support to the former fuel fabrication facility. He has been the ENERCON PM since August 2021 and is responsible for providing qualified technicians for decommissioning operations. Mr. Watson provides technical support for radiation safety, radiological effluent monitoring, and radioactive waste programs associated with the site. He has been designated as the Radiation Safety Officer (RSO) when the RSO is absent from the site due to vacation or illness.

ENERCON Environmental and Radiation Safety Programs Manager, Curtiss-Wright 02/23 - 11/24 The Curtiss-Wright Electro-Mechanical Division in Cheswick, Pennsylvania holds three radioactive material licenses which require a qualified Radiation Safety Officer. Responsibilities include managing the environmental and radiation safety staff, implementing the radiation safety and regulatory compliance programs for the facility, managing radioactive shipments, and acting as the primary contact for regulatory interface for all aspects of the environmental and radiation safety programs.

Former Beta Chem Laboratory Material Removal / Lenexa, KS 05/24 - Present Mr. Watson managed the effort that utilized ENERCON's radioactive material license to remove remaining equipment and building material from a former source laboratory. The effort involved identifying the hazards associated with a lab that was left dormant for over a decade, determining a safe method for removal, and finding a destination and dispositioning the Carbon-14 waste. Once the equipment and material were removed from the lab, a final survey was conducted to determine the level of effort remaining for license termination.

Walthousen Decommissioning Plan/ Schenectady, NY 06/23 - Present Mr. Watson led the effort to perform radiological and environmental characterization of the facility to independently determine the Decommissioning Cost Estimate (DCE) required for the Walthousen Reactor Critical Facility (RCF) in Schenectady, New York. The DCE was prepared to support development of a detailed Decommissioning Plan to decommission the facility and terminate the license.

Project Cost Estimating / Canadian Nuclear Labs/ Port Hope, Ontario 04/22 - Present Mr. Watson led the development of cost estimates to support remediation of residential and industrial sites in Port Hope. The cost estimates account for direct and indirect labor, equipment, and material costs to remediate the environmental hazards at each project site.

Vallecitos Nuclear Center Decommissioning/ Sunol, CA 10/21 -12/22 Mr. Watson supported the license termination of three legacy small nuclear reactors. Proper nuclear, environmental, and hazardous characterization of the containments, support buildings and surround land is necessary to terminate the Nuclear Regulatory Commission licenses.

PREVIOUS PROFESSIONAL EXPERIENCE awxr Jechno!ogjes October 2012-September 2020 Site Manager/ Site D&D Subcontractor I West Mifflin, PA Mr. Watson was the site manager of a group that specialized nuclear and environmental remediation and restoration. Mr. Watson led the team that decontaminated, decommissioned, and demolished four separate buildings in support of Naval Reactors at Bettis Laboratory in West Mifflin, PA. Mr. Watson has been the lead auditor for two separate radiological audits, while participating as an auditor for countless more evaluations Voited states Naw May 2006 - September 2012 Nuclear Officer/ USS GEORGE H. W. BUSH While stationed on the USS GEORGE H W BUSH, Mr. Watson was responsible for water chemistry and radiological control. He qualified Navy Engineer and Engineering Officer of the Watch, accountable for all operations within the engineering plant, to include the safety and maintenance of personnel and equipment Primary responsibilities included review of periodic primary and secondary chemistry results, radiological survey review, external radiological dose monitoring, radiological source inventory, radioactive material control, and emergency response. In addition to his operational experience, Mr. Watson developed the audits and assessment program for the Reactor Department.