ML20029C862
| ML20029C862 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 04/14/1994 |
| From: | Fauver D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9405020155 | |
| Download: ML20029C862 (2) | |
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UNITED STATES Qj j-NUCLEAR REGULATORY COMMISSION
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W A S HIN G T O N. D.C. 20S55-0001 G
Docket No. 70-1193 License No. SNM-ll74 MEMORANDUM FOR:
John H. Austin, Chief low-level Waste and Dev
~ssioning Projects Branch Division of Waste Management, NMSS FROM:
David N. Fauver low-Level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS
SUBJECT:
SUMMARY
OF MEETINGS AND TELEPHONE CONVERSATIONS WITH KERR-MCGEE REPRESENTATIVES REGARDING THE FINAL SAMPLING PROTOCOL FOR THE S0ll TO BE PLACED IN THE DISPOSAL CELL AT THE CIMARR0N SITE One meeting, on March 25, 1994, and three telephone conversations, on March 30, March 31, and April 8,
1994, were conducted with Kerr-McGee Corporation _-
representatives to discuss the final sampling plan for the soil to be placed in the disposal cell at the Cimarron site.
A summary. of each meeting / call is discussed below.
On March 31, 1994, Henry Morton, a consultant for Kerr-McGee Corporation, met with me at White Flint to discuss Kerr-McGee's onsite disposal plan submitted February 22, 1994.
Several issues related to the disposal plan were discussed including: 1) how will Kerr-McGee verify the accuracy of the soil surveys using a gamma probe; 2) how will Kerr-McGee average the results; and 3) what criteria will be used to determine if additional soil is required to be shipped offsite.
Mr. Morton indicated that he would discuss these issues with Kerr-McGee.
On March 30, 1994, I received a telephone call from Ed Still and Roy Smith to discuss the items from the March 31, 1994, meeting, that had been relayed to them by Mr. Morton. During this discussion, I stated that the survey of the soil to be placed in the dispaal cell is classified as a final survey for the material since the objective was to release the material for unrestricted use.
I indicated that the sampling information contained in the February 22,1994, Kerr-McGee disposal plan was insufficient to address two items: 1) assurance that the data quality af the surveys using a gamma probe is sufficient to use to demonstrate unrestricted use; and 2) the averaging criteria to be used to determine if additional offsite disposal would be required.
Kerr-McGee indicated that they intended to use a different sampling plan than described in their February 22, 1994, submittal. The revised plan would consist of sampling on a 5 m grid every 0.5 m in depth in the pile before any material was moved. They proposed to average the material to ensure that the average was less than 100 pCi/g and dispose offsite any material exceeding 250 pCi/g.
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Kerr-Mcgee's position was that the volume of material exceeding 100 pCi/g should 4
not.be h consideration when determining the need for offsite disposal as long as the average of the entire pile was less than 100 pCi/g. This position was based on Kerr-McGee's assertion that NRC provided guidance early in the project that 250 pCi/g would be the limit applied and that therefore material greater than 250 pCi/g was shipped offsite to a licensed disposal and material less than 250 pCi/g remained onsite. Subsequently, the issues of solubility was raised and Kerr-McGee lowered the threshold for offsite shipment to 150 pCi/g to account for the potential for a fraction of the material being soluble.
Kerr-McGee's position is that since it is possible, although they believe unlikely, that significant volumes of material may be between 100 and 250 pCi/g but that the material was sorted in accordance with NRC guidance, that no volume criteria should be used to require offsite shipment.
I indicated that if Kerr-McGee could demonstrate that NRC guidance was that any material less than 250 pCi/g could be left onsite that it appeared reasonable to approve their averaging strategy.
I indicated that I would address the averaging issue with NRC management when the revised sampling plan was submitted. At this time I clarified with Kerr-McGee that I was not making any approvals during the telephone conversation but that I would make the final approval af ter reviewing their revised sampling plan.
On the following day, March 31, 1994, I telephoned Ed Still to discuss further the issue of averaging.
He committed to submit with the sampling plan a description of the procedures used to initially excavate and sort the soil and any documentation of NRC guidance provided on the issue of excavation and sorting.
On April 7, 1994, I received a telephone call from Roy Smith of Kerr-McGee. He indicated that Kerr-McGee was prepared to initiate sampling of the pile on a 5 m grid on Monday April 11, 1994.
I indicated that I had not r acei":J a sampling plan and that any sampling would be at Kerr-McGee's risk.
I clarified that the regulations require that a final survey plan be submitted since Kerr-McGee proposed to release the soil for unrestricted use.
Roy Smith expressed his consternation regarding the requirement to submit a survey plan, and that in his opinion, the process of completing the disposal was again being delayed.
DdSbn@y David N. Fauver Low-Level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS QlSTRIBUTION: Central File DWM r/f NMSS r/f RNelson LBell s
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