ML20029D653

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Forwards Kerr-McGee Corp Cushing,Ok Refinery Site,Site Decommissioning Plan, Per 10CFR70.38(c)(2)(iii) & Reg Guide 3.65
ML20029D653
Person / Time
Site: 07003073
Issue date: 04/27/1994
From: Rich Smith
KERR-MCGEE CORP.
To: Joseph Austin
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20029D654 List:
References
RTR-REGGD-03.065, RTR-REGGD-3.065 NUDOCS 9405090169
Download: ML20029D653 (2)


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- ' xtnitucate crutta. OKLAHOMA CITY, OKLAHOMA 73125 t :

TECHNOLOGY & ENGINEER;NG DIVISION E

Mr"eniEs,, cuvisOnutuvat orenArious 27 April 1994

- Dr; John 11. Austin i

Chief, Decommissioning and Regulatory issues Branch F}x U.S. Nuclear Regulatory Commission

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-Washington, D.C. 20555

~ RE: Cushin'g Site Decommissioning Plan

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Docket 70-3073, Lie'ense SNM-1999 t

Dear Dr. Austin:

Materials License SNM-1999 specifies that Kerr-McGee submit a proposed plan to decommission its Cushing site. A plan developed to meet requirements of 10 CFR Part l

70.38'(c)(2)(iii) and generally conforming to Regulatory Guide 3.65 is included

? herewith, KerrAlcGee requests that its license, SNM-1999, be amended to approve this -

plan.?The plan includes the following elements:

historical licensed ~ material and decommissioning activities,'

planned cleanup and restoration activities, radiation safety program for protecting workers and the environment y

- final radiation survey plan, and organization and admmistration (stablished to ca y out the plan.'

A cost estimate and pmvisions to assure decommissioning funding were submitted with s

the rev;sul application tor a Materials License on September 25,1992J Condition 11.B of LicenO SNM-1999 requests descriptions of niethods KMC proposes 1)'to measure

.l and contici sortingtf contaminated material to be transported to temporary storage areas,

2) to neutralize acidic, cominiihated sludge in Pit 4,3) to ' demolish potentially~

' contaminated structures, and 4) an analysis of the ability of the storage areas to resist' i

erosion by wind and water? Items 1,2, and 4 are described in section 3 of the plan.

L License condition 11.b.3: requires a description of methods to be used to demolish

potentially contaniinated structures prior to demolition. KMC intends to provide the 1,

- specifics of such a plan to;the Commission st'a liter date as an amendment' to this

.decominigioning plan :It has long been realized that the amount of contaminated soil at form lerif used tiraniurif anhliorldmprocessink sites is very large, yet tiie concentration l

Luffadioactive material is ofles loiv enough to justify _their disposal onsite rathiir than to R

o transport it to a' commercial disposal site NV.J. Dircks,'NRC[ branch technidal' position on Dispo;al or Onsite Storage of Reyluk Thorium or.. Uranium from Past OperationdECY 81-576 & 46 FR 52061 Ottober 23,_

1 1981.

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1 initn egral part of the Cushing site decommissioning plan is an engineered cell onsite in which qualified radioactively contaminated material may be disposed. A preliminary analysis supports the feasibility of such an engineered cell onsite for this purpose. When Kh1C has the information and analyses confirming the safety of the engineered cell, we intend to provide that to the Commission along with a request for its approval pursuant to 10 CFR Part 20.2002.

Kh1C will presently submit a final survey plan for delineated areas that are not affected by licensed material. While Kh1C wants to obtain recognition that certain designated areas are demonstrated by a final radioactivity survey to be free of contamination by licensed material, please note that KhtC is not requesting that the four unaffected areas be deleted as authorized places of use after it has been determined that they are suitable for unrestricted use. We plan to use a portion or portions of unaffected areas to dispose of soil meeting the branch technical position 2 Option I specifications for unrestricted release and to site the engineered cell. Once the designated areas are recognized as such by the Commission, Kh1C would want to discontinue radiation monitormg until we begin placing licensed material in the engineered cell. in all four unaffected areas, we need NRC concurrence that the land is clean before grading or restoration activities are begun.

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Kerr-htcGee is interested in completing decommissioning at its Cushing site as soca as is practicable. To facilitate approval of the plan, we will provide whatever information is necessary to expedite approval of this plan.

Sincerely yours, f

%./ nw n

Roy Smith j

Vice President, Environmental Operations Enc.

cc:

Bob Evans, NRC Region IV Gene Smith, ODEQ Scott Thompson, ODEQ Rick Reiley, Cushing Citizens Oversight Committee I

2 lbid.