ML20046B469
| ML20046B469 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1993 |
| From: | Selin I, The Chairman NRC COMMISSION (OCM) |
| To: | Synar M HOUSE OF REP., GOVERNMENT OPERATIONS |
| References | |
| CCS, NUDOCS 9308040248 | |
| Download: ML20046B469 (24) | |
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S UNITED STATES
[ j c., ; "] j NUCLEAR REGULATORY COMMISSION l
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jg]y 9, '993 CHAIRMAN The Honorable Mike Synar, Chairman i
Subcommittee on Environment, Energy, and Natural Resources l
Committee on Government Operations United States House of Representatives Washington, D.C.
20515 i
Dear Mr. Chairman:
i
- a writing to inform you at the status of the Nuclear Regulatory i
Commission's efforts to improve regulatory oversight of the decommissioning of nuclear facilities.
The need to strengthen NRC's decommissioning program was underscored during the August 3, 1989 Subcommittee hearing that you chaired, i
The issues identified during the hearing led to the NRC development of the Site Decommissioning Management Plan (SDMP) in early 1990.
We provided you the original SDMP in April 1990, and revisions in May 1991 and July 1992.
, contains the most recent revision of the SDMP (SECY-93-179, June 24, 1993).
The SDMP contains updates on the status of decommissioning activities at 48 radioactively contaminated sites.
Since 1990, two sites have been successfully decommissioned and have been removed from the SDMP list.
Overall, decommissioning progress is accelerating, and we expect five or six additional sites to be released for unrestricted use and removed from the SDMP over the next year.
You have expressed a particular interest in four SDMP sites:
Cushing, Oklahoma: Crescent, Oklahoma; Pawling, New York; and the West Lake Landfill in St. Louis, Missouri.
For your convenience, the descriptions of the decommissioning status of the aforementioned four sites have been extracted from the SDMP and placed in Enclosure 2.
The SDMP also describes the progress.made in resolving significant decommissioning issues since the August 3, 1989 Subcommittee hearing.
Two of the more important issues -- developing radiological criteria for decommissioning and developing timeliness criteria for decommissioning j
facilities -- are being addressed in rulemakings.
For the rulemaking on radiological criteria for decommissioning, we have sought enhanced levels of public participation to allow the concerns of various affected parties, such j
as citizen and environmental groups, States, Indian Tribes, and professional societies, to be aired and considered in the early stages of the rulemaking.
To encourage and promote public participation, NRC conducted seven workshops around the country from January through May 1993.
A proposed rule on radiological criteria for decommissioning is scheduled to be issued for public comment in April 1994.
Regarding decommissioning timeliness criteria, a
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proposed rule was issued in January 1993 (58 LR 4099).
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9308040248 930709 i PDR COMMS NRCC hk CORRESPONDENCE PDR;
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The SDMP has proved to be an effective management strategy for addressing i
decommissioning issues and contaminated sites.
I want to assure you that we intend to decommission each contaminated site in accordance with NRC requirements and guidance.
We will continue to work to ensure proper control and disposal of radioactive material that is within the jurisdiction of NRC
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and will continue to keep you informed of progress in our decommissioning program.
i Sincerely,
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pfyMb Ivan Selin
Enclosures:
1.
SDMP (SECY-93-179), June 24, 1993
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2.
Decommissioning Status of
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Four Selected Sites t
cc: Rep. William F. Clinger, Jr.
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SECY-93-179 -- Updated Report on Site Decommissioning Management Plan l
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Chevron Corporation (formerly Gulf United Nuclear fuels Corporation) l.
Site Identification-Chevron Corporation Nuclear Lake Pawling, fly License flo..
SNM-871 Docket No..
070-00903 License Status:
Terminated in 1975 Project Manager:
M. (Sam) Nalluswami i
2.
Site and Goerations 2
The 4.6E6 m (ll37-acre) site is located in a wooded, rural area near Pawling in Dutchess County, New York, about equidistant between Pough-
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keepsie, New York, and Danbury, Connecticut.
The site includes a dammed 2
lake of about 2.0E5 m (50 acres), known locally as Nuclear Lake. The site now contains a portion of the Appalachian Trail.
i Beginning in 1958, licensed nuclear fuels research and development were conducted at the site.
Facilities included laboratories for fabrication I
and testing of uranium, thorium, and plutonium fuels, a hot cell, three research reactors (Docket'Nos. 050-0023, 050-00101, and 050-00290), and a sodium test loop.
The original site owner and licensee was Nuclear i
Development Associates, which later became United Nuclear Corporation j
i (UNC). The licenses were transferred in 1971 to a partnership formed by i
t Gulf General Atomics (GA) (itself a partnership of Gulf Dil and Royal Dutch Shell) and UNC, known as Gulf United Nuclear Fuels Corporation (GUNFC). UNC retained ownership of the site and also was a co-licensee with GUNFC for the remaining two reactors, Docket Nos. 050-00101 and 050-00290.
(One react'or license,-Docket No._050-0023, had been terminated and replaced with a new license in June 1961.) Activities at the site were never resumed after December 1972, when a glove box explosion in the plutonium laboratory building resulted in substantial A-73 NUREG-1444 1
contamination.
License renewal was still being actively pursued by GUNFC, however, as late as mid-1973.
As of September 27, 1973, GUNFC was a wholly-owned subsidiary of Gulf.
UNC had no further responsibility to the NRC at this point since GUNFC continued as the licensee and continued to be responsible for all matters of NRC regulatory compliance.
UNC continued to own the site and buildings which were leased to GUNFC.
On November 19, 1973, General Atomics Company (GAC) applied to the AEC for consent to acquire all the interests of Gulf (aud GUNFC) in a number of licenses. including both the Pawling, NY reacto" licenses (R-49 and CX-25) and the special nuclear material license (SNM-871).
Consent to the transfer was provided by letter from the AEC to GAC, dated Decem-ber 14, 1973.
Consent was provided with the understanding that GAC would assume all the " rights, duties, responsibilities, liabilities, and obligations of the Gulf Oil Corporation."
i Upon completion of decommissioning and survey work, Gulf Nuclear Fuels Company (GNFC) sent a letter and a supporting survey report _ to the AEC dated March 11, 1974, requesting that Pawling, NY be deleted from SNM-871. The letter indicated that the absence of contamination had been verified at all buildings.
A letter from GNFC to the AEC, dated May 9, 1974, requested that the licensee name be changed to GAC.
The. letter stated that GNFC (formerly GUNFC) would become part of GAC retroactive to January 1,1974.
By letter dated May 23, 1974, License No. SNM-871 was amended to specify GAC as the licensee. Also, on July 19, 1974, a renewed License No. SNM-871 was issued to GAC.
A closecut survey and inspection was conducted by the AEC at the site during April 1974 (inspection report 70-903/74-01).
According to the-AEC inspection report dated April 24, 1974, remediation had been performed to levels specified as acceptable for unrestricted use at all the buildings.
Following further removal of plutonium-contaminated soil from the Pawling, NY site, License No. SNM-871 was terminated on A-74 NUREG-1444
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July 14, 1975.
The remaining reactor licenses had been terminated in i
June 1974 (Docket lios. 50-101 ana 50-290).
l Subsequently, there was a partial distribution of the assets of GAC to l
the partners (under which GA Technologies Inc., wholly-owned by Gulf 011 f
Corporation, undertook all the f4RC licenses of GAC) and GAC was renamed as Valley Pines Associates (VPA) as of fiovemDer 30, 1982. VPA continued l
to be owned by Gulf Oil Corporation and Scallop tiuclear, Inc. The names 4
of the partners owning VPA have changed and VPA is now owned by Chevron 1
U.S.A. Inc. (a wholly-owned subsidiary of Chevron Corporation and formerly Gulf Oil Corporation) and Shell Oil Company.
l The site itself was sold in 1979 by Harpoon, Inc., a wholl y-owned subsidiary of United fluclear Corporation, to the U.S. Department of f
Interior (D01) for use by the flational Park Service (t4PS).
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Radioactive Wastes In February 1984 fluclear Energy Services of Danbury, Connecticut, conducted a radiological survey of the site for the site owner, the tips.
l During the course of that survey, it was discovered that a small area of i
the concrete floor in what was the waste storage buildi.,9 had fixed
'l beta-gamma radiation levels of 0.25 to 0.35 mSv (25 to 35 mrem)/hr.
The j
tips notified f4RC Region I of this condition by letter dated March 12, 1984.
A verification survey was conducted by the f4RC on May 22, 1984.
Most of this contamination was removed from the area by destructive j
sampling on February 25 and 26,1985.
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l The Oak Ridge Institute for Science and Education conducted a site-wide radiological survey for the f4PS September 18 through 23, 1986.
The ORISE survey report, issued in July 1988, identified limited areas. of residual contamination in the p%tonium laboratory and the multiple failure building.
In the pl'utonium laboratory, there is fixed alpha 2
(plutonium) contamination ranging to'0.6 MBq (3400 dpm)/100 cm in the 2
concrete flooring of five separate rooms, totaling approximately 230 m 2
(2500 ft ).
In the same five rooms there are two areas, totaling about 2
z 15 m (170 ft ), of fixed beta-gamma (Cs-137) contamination ranging to A-75 t1UREG-1444
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2 23 MEc (12,000,000 dpm)/100 cm. ORISE reported the externai exposure
' ate la be 7.7 nC/kg (30 pR)/hr at a height of 1 meter at the location
- ::e a( beta-gamma contamination.
The surface contamination in the ultiole f ailure building consists of only beta-gamma (Cs-137) 2
- ntamination ranging to 6.6 MBq (110,000 dpm)/100 cm over an area of
- everai square meters.
ORISE found surface Pu-239/ 240 contamination in
- il. in isolated locations outside the buildings, ranging to 3.4 Bq (91 i
- Ci)/g, and subsurface Cs-137 contamination at two other locations anging from about 0.74 to 1.8 Bq (20 to 48 pCi)/g.
A sample of sludge
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' rom tne plutonium laboratory septic' tank had 1.5E-2 Bq (0.41 pCi)/g of I
A single soil sample from under a downspout at the shield
- ck-un building had 0.6 Bq (15.5 pCi)/g of Cs-137.
"agnetcmetry and ground-penetrating radar showed 50 to 60 magnetic
" anomalies" and " targets" within Nuclear Lake.
Subsequent investigation ty scuba divers has confirmed that the " anomalies" and " targets" consist cf a jeep, an aluminum boat, and natural matter such as rocks and tree stumps not contaminated with radioactive materials.
Sediment samples from Nuclear Lake indicate Cs-137 ranging to 0.4 Bq (9.9 pCi)/g and U-j 238 ranging to 0.6 Bq (16.5 pCi)/g.
The peak Cs-137 concentration occurs near the location of the previous liquid waste discharge point.
Sediment concentrations downstream from the dam are within the range of rackground or slightly above.
Wastes produced during remediation would include concrete rubble or 2
2 scabbling waste from remediation of about 230 m (2500 ft ) of concrete floor and some contaminated soil. Other wastes could develop if further studies identify additional contamination.
4 escriotion of Radioloaical Hazard he site poses no immediate threat to the public.
The NPS controls access to the site and has a full-time caretaker on site. The building
- onta.ination above acceptable levels is fixed contamination and does not constitute a significant exposure hazard because of its limited use.
I he soil contamination is not severe and is not widespread.
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tion levels of sediment within and downstream of Nuclear Lake are slight and do not pose a radiological hazard. There is no evidence of contamination of water in the lake.
5.
Financial Assurance / Viable Resoonsible Oroanization At the time of license termination in 1975, the licensee was GAC.
GAC's successor in interest is VPA, a subsidiary of Chevron Corporation (Chevron).
Chevron has undertaken the role of its subsidiary, VPA, and has been discussing site remediation with NRC and NPS.
Chevron submit-ted a work plan for the soil remediation, and a health and safety plan.
Chevron also submitted a decommissioning plan for the plutonium facility and the multiple failure building.
6.
Status of Decommissionino Activities i
On September 26, 1989, the NPS, NRC, and ORAU held a joint meeting to discuss options available to the NPS for additional surveys and remediation of the site.
It was decided to contact the former licensee to determine its willingness to assume responsibility for remediation of the site.
NRC staff and representatives of Chevron, GA, and VPA held a telephone conference on February 14, 1990, to discuss the residual contamination and responsibility of the parties.
On April 3,1990,. representatives of the NPS, NRC, and VPA met at the Pawling site to tour the site and dis-cuss various remediation options.
On November 27, 1990, a Chevron attorney met with NMSS staff.
It was explained that NRC could hold the last licensee responsible for all site remediation even though residual contamination might be the result of previous operations conducted by a former licensee.
The Chevron repre-sentative indicated that Chevron would provide its position concerning further site characterization and remediation by January 1991.
Subsequently, a letter was received from Chev on dated January 24, 1991, stating that they were continuing to review the matter internally, and l
A-77 NUREG-1444
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.l asking questions acout remediation criteria, further site characteriza-tion, waste disposal, and release for unrestricted use.
NRC staff provided a response to Chevron's questions, including specifi~c remedi-ation criteria in a letter dated April 22, 1991.
The letter stated that the NRC was looking to VPA to provide the necessary site remediation because VPA is the' immediate successor in interest to the last licensee, GAC.
i Further communications dwelled on Chevron's position that UNC as the former licensee, and site owner throughout licensed operations, should-l also be held responsible for site remediation. This was discussed in a l
conference call on July 25, 1991, and in a detailed explanation of NRC's position sent to Chevron in a letter dated August. 20, 1991, and again, at length, in a meeting at NRC offices on November 20, 1991.
In this.
meeting, Chevron indicated some willingness to participate in site remediation if certain concerns were adequately addressed.
(On Au-gust 9,1991, a site visit and tour was conducted, at Chevron's request, for the purpose of familiarizing three potential remediation contractors with the site and remediation needs.)
In another meeting held on December 13, 1991, at the Department'of the Interior building in Washington, D.C., Chevron indicated their intent to provide a remediation proposal to the NPS by the end of the year.
A By letter dated February 13, 1992, Chevron proposed to the NPS to pro-vide project management for remediation of known areas of contamination, j
and to pay 50 percent of the cost of remediation work.
Under the i
Chevron proposal, NPS would pay 50 percent of remediation costs, and I
100 percent of the costs of radioactive waste disposal and nonradiologi-l cal building demolition' and debris removal.
The NPS responded to Chevron's proposal by letter dated March 12, 1992, and indicated that there was no basis for assigning any portion of the remediation costs to l
the NPS.
f On April 3, 1992, Chevron wrote a letter to NPS indicating that although Chevron has expended a great deal of effort and presented a significant l
offer to the NPS, to date, the NPS has not come forth with anything to j
A-78 NUREG-1444 i
satisfy Chevron's two fundamental requirements of cost sharing and an assurance that this would be Chevron's final remediation oligation.
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Due this situation, Chevron wrote that they cannot justifj expending any 3
more resources at this site and would take no further action.
The negotiations between Chevron and the NPS continued. NRC encouraged j
the negotiations and supported the shared responsibility retween Chevron
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and the NPS in a letter dated October 30, 1992.
Chevron submitted a i
work plan for soil remediation, and a health and safety plan.
The work plan, and the health and safety plan were reviewed and approved by the NRC staff on December 11, 1992.
Chevron also submitted on February 17, i
1993, a decommissioning plan for the plutonium facility and the multiple failure building. NRC reviewed the decommissioning plan for the l
Plutonium Facility and the Multiple Failure Building and requested additional information on April 20, 1993.
Chevron and NPS have signed a
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cooperative agreement to remediate the site.
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Other involved Parties I
l The New York State Department of Environmental Conservation sent
.-I representatives to the August 9,1991 site visit and tour, and is being kept advised of significant developments.
3.
NRC/ Licensee Actions and Schedule t
NRC Issues Confirmatory Order TBD l
Chevron submits revised plan May 1993 NRC approves decommissioning plan for Plutoniem Facility and Multiple Failure Building June 1993 Chevron submits termination survey report September 1993 NRC performs confirmatory survey October 1993 NRC staff prepares Commission paper December 1993 A-79 NUREG-1444
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' f4RC releases Chevron site for unrestricted
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use and removes site from SDMP list March 1994
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Problems / Issues l
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Kerr-McGee, Cimarron Plant
~~te Mentification Kerr-McGee Cimarron Plant (Cimarron Corporation)
Crescent, OK License Nos.
SNM-928 (Uranium), SNM-Il74 (Mixed-Oxide)
Docket '40s:
070-00925 (Uranium), 070-01193 (Mixed-Oxide)
License Status:
Active - Possession only/ Decommissioning Pro. ject Manager:
G. Comfort, FCSS LLWM Monitor:
W. Lahs 2.
Site ana Goerations The 445-hectare (1100-acre) site is located in a rural part of central Oklahoma, 48 km (30 miles) north of Oklahoma City, in a predominantly
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farming area.
There are two non-operating fuel fabrication plants on the site; one was used for mixed-oxide fuels and one for EU fuels.
Fuel fabrication operations at both plants were terminated ir,1975.
In addition to the fuel fabrication plants, there were eight waste-water treatment settling ponds, of which three are currently open, and burial areas (for burials previously allowed under s20.304), which were i
licensed as part of the uranium plant.
Five of the eight waste water treatment ponds were closed in 1977 and 1978.
4 As a result of operations, both fuel fabrication buildings were contami-nated, with uranium and plutonium respectively.
The settling ponds are contaminated with uranium, while the burial areas (two additional areas recently discovered) contain uranium and trace amounts of thorium from.
i waste disposal associated with offsite activities.
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Radioactive Wastes Low-solubility EU (ranging 2 to 9.1 percent uranium-235) contamination exists in the soil around the uranium plant and in the building itself, l
as well as in soil around the settling ponds and the burial grounds.
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The total volume of contaminated soil is greater than 14,000 m (500,000 ft ), mostly with uranium concentrations between 1.1 Bq/g 3
(30 pCi/g) and 3.7 Bq/g (100 pCi/g) of about 3 percent average enrich-j ment.
Uranium contamination has also been found in the ground water below the exhumed 20.304 burial area, r.long with chemical contamination.
l There is also a small amount of thorium contamination in the soil around i
this burial area.
I The mixed-oxide plant has been remediated to below current standards.
There is no significant plutonium contamination inside or outside the building.
The mixed-Oxide license has been terminated and that part of the site has been removed form the SDMP l
4.
Descriotion of Radiological Hazard l
This acress-controlled site poses no immediate threat to the public health and safety.
Uranium and thorium contamination currently exists i
l only in on-site soils, in low concentrations.
The plutonium facility has been remediated.
Confirmatory surveys were conducted by ORISE, an f4RC contractor, in August 1988 and October 1989.
These surveys concluded that criteria in " Policy and Guidance Directive FC 83-23:
Termination of Byproduct, Source and Special Nuclear Material Licenses," dated November 4, 1983, have been met..
5.
Financial Assurance / Viable Resoonsible Organization The site is owned by Kerr-McGee's Cimarron Corporation and all licensed activities were conducted by Kerr-McGee. Kerr-McGee has provided a l
parent-company guarantee for $750,000 applicable to the uranium license.
6.
Status of Decommissionino Activities Kerr-McGee submitted decommissioning plans for the mixed-oxide plant, that were approved by the NRC.
Kerr-McGee discussed plans for the-uranium plant decommissioning with NRC. These plans have been partly approved.
Kerr-McGee is performing remediation operations in accordance A-ll4 flVREG-1444
1 with SNM-928, License Condition flo. 20 (uranium license). The f4RC staff
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requested additional information on the extent of uranium contamination in on-site soil.
In August 1989, f4RC approved a Kerr-McGee proposed method for neasuring total uranium in soil.
Kerr-McGee has completed remediation of the mixed-oxide plant. The remediation of the uranium plant is currently in progress. Kerr-McGee has exhumed and shipped contents of the initially-identified 20.304 burial area and continues to remediate the building.
It has surveyed for uranium contamination in the soil around the building and submitted a request for authorization (pursuant to 10 CFR s20.302) to dispose of 3
3 11,000 m (400,000 ft ) of uranium-contaminated soil on the site under
% tion 2 of the Branch Technical Position entitled " Disposal or Onsite Storage of Thorium and Uranium Wastes From Past Operations" (46 FR 52051, October 23, 1981).
During the week of October 13, 1991, Kerr-McGee notified f1RC Region III that two additional 20.304 burial pits were discovered about 50 meters (165 feet) east of the Mixed-0xide plant boundary fence.
Kerr-McGee is presently recharacterizing the site, including these burial areas.
On December 9,1991, ORAU conducted, and f4RC Region III witnessed, a confirmatory survey of the exhumed 20.304 burial area and the older j
sanitary sewage lagoons with their associated berms and a loading dock.
The survey confirmed that the area had been adequately decontaminated.
i f4RC staff has prepared an Environmental Assessment (EA) in support of the termination of the mixed-oxide plant 1 hense and published a Finding of fio Significant Impact on February 12, 1993.
The mixed-Oxide license was terminated in February 1993.
NRC staff prepared an EA to evaluate a proposed disposal of uranium-contaminated soil on the Uranium plant site.
Subject to conditions regarding the concentrations and solubility of the uranium, the staff has recommended that the disposal be approved as a step toward decommis-sioning the entire Uranium plant site.
tiRC staff prepared a Commission Paper (SECY 91-398, December 9, 1991) on the Mixed-0xide plant license termination and the proposed on-site disposal of uranium, as requested A-115 fiUREG-1444 1
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in the Staff Requirements Memorandum of January 31, 1990.
On October 30, 1992, the Commission approved, with minor comments, the proposed ictions outlined in the Commission Paper.
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Other involved Parties This site is one of eight specifically addressed in the May 1989 General Accounting Office report "NRC's Decommissioning Procedures Criteria Need to be Strengthened."
The Oklahoma State Department of Health has been involved with regard to the chemical contamination at the site.
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NRC/ Licensee Actions and Schedule NRC approves onsite disposal request May 1993 1
j Uranium Plant License Termination Mid-1994 (at the earliest)
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7 Kerr-McGee, Cushing Plant i
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Si:e Identification Kerr-McGee Cushing Plant Cusning, OK License fio. :
Sf4M-1999 Docket flo..
070-03073 Project Manager: D. Fauver 2.
Site and Operations l
The site is located halfway between Oklahoma City and Tulsa. Under At:mic Energy Comnission (AEC) licenses 5f4M-695 and SMB-664, Kerr-McGee chemically processed enriched,. normal, and depleted uranium and natural thorium at this site from 1962 through 1966.
During this period, Kerr-McGee owned approximately '62 hectares (400 acres) of property to conduct AEC-licensed activities and operate an oil refinery. Materials were received in the form of UF, mill concentrates, unirradiated scrap 6
fuel elements, and various chemical compounds. The licensee converted uranium to other compounds suitable for use in the nuclear fuel cycle j
and produced metal alloys of uranium and thorium.
In 1966, the site was decommissioned in accordance with practices at the time and the license was terminated.
Between 1972 and 1982, Kerr-McGee further decontaminated the site by shipping the more. highly radioactive materials off site and burying some of the contaminated soil and trash in an existing refinery waste sludge pit. (pit. number.4) or in trenches located in the northeast corner of the tank farm area.
Some soil.
contamination has been detected at levels higher than the Option 1 criteria of the Branch Technical Position (BTP) on. uranium and thorium wastes around and in the former process buildings.
A-ll7 f4UREG-1444
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Radioactive Wastes The Kerr-McGee, Cushing site contains approximately 500 kg l
(1,100 pounds) of uranium and 2000 kg (4,400 pounds) of thorium, in f
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about 18,000 m (500,000 ft ) of contaminated soil, sediment, buried trash, and building rubble.
The former process building is also j
contaminated.
i There are areas of contamination, containing thorium and uranium
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exceeding 1.3 Bq/g (35 pCi/g), in and around the former processing building.
Kerr-McGee has found more uranium contamination under the building than anticipated, which may require removal of the building to gain access to contaminated soils.
The soils and rediments in Skull Creek, which was a discharge point for processing effluent, contain l
concentrations up to 10 Bq/g (279 pCi/g) thorium and 36 Bq/g (968 pCi/g) uranium.
1 The northern area of the tank farm contains discrete and general areas of uranium and thorium contamination.
Pit 4 contains hazardous waste.
and radionuclides with concentrations up to 1.3 Bq/g (34 pCi/g) of-thorium.. and 0.6 Bq/g (18 pCi/g) of uranium.
The hazardous waste in Pit 4 is an oily-acid sludge which will be neutralized and made non-hazardous.
A few tank berms contain radioactive waste,-and closed 1
trenches, located in the northeast area of the tank farm area, were used for contaminated soil burial during previous decommissioning activities.
The terms and trenches contain up to 1.1 Bq/g (31 pCi/g) thorium and 0.8 Bq/g (21 pCi/g) uranium. The northern area also contains a berm previously used as a disposal area for laboratory trash and soil con-i taminated with up to 1.2 Bq/g (33 pCi/g) thorium and 4.0 Bq/g (107 pCi/g) uranium.
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A small area south of the process buildings contain soil contaminated with Ra-226.
The Ra-226 resulted from a small pipe scaling operation associated with the oil refinery and is not subject to NRC license.
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Description of Radioloaical Hazcrd i
This site poses no immediate threat to the public health ano safety.
The concentration of uranium and thorium in soils is low and the mate-i rial does not become airborne readily.
Kerr-McGee controls access to the site.
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Financial Assurance / Viable Responsible Oraanization Kerr-McGee owns the tank farm area and the former processing building and has pursued acquisition of other land and buildings that were owned by Kerr-McGee at the time of AEC-licensed operations.
Kerr-McGee i
appears willing and able to remediate radiologically contaminated site areas. An acceptable decommissioning funding was submitted as part of the license application to possess the contamination at the site.
6.
Status of Decommissionina Activities Decommissioning work completed to date has been in response to the consent order with the State of Oklahoma.
NRC has been apprised of significant activities conducted under the consent order. A site characterization report summarizing the radiological conditions of the Cushing site was submitted on May 4, 1991.
Additional characterization
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may be required.
The remediation of the contaminated soil around the process building, sediment and soil in Skull Creek, and surface contamination in the process building continues.
The majority of contaminated soil excavated from these areas has been sorted by contamination level and retained onsite pending a decision as to the disposal method. Soil with higher contamination levels has been shipped to Barnwell for disposal, along with contaminated material resulting from shotblasting process building surfaces.
In a letter dated May 20, 1991, NRC infornied Kerr-McGee that the remediation activities at the Cushing site must be in accordance with NRC requirements under an NRC license.
In a follow-up meeting, held on -
A-119 NUREG-1444
June 7, 1991, Kerr-McGee agreed to apply, by September 15, 1991, for an fiRC license to possess the radioactive contamination at the Cushing site. fiRC provided Kerr-McGee with guidance on the preparation of the application on July 30, 1991. On October 17, 1991, the_ license appli-j cation was submitted to f4RC. On June 16, 1992 and July 10, 1992 f4RC requested additional information on the license application.
Due to the substantial content of the additional information requested, Kerr-McGee chose to revi.se the October 17, 1991 application in its entirety. On i
September 25, 1992, the revised application was submitted to f4RC.
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f4RC staff identified deficiencies in the licensee's decommissioning funding plan and financial assurance instrument proposed in the original snd revised license application.
After considerable correspondence l
between f4RC and Kerr-McGee, an acceptable decommissioning funding plan I
and financial assurance mechanism was received by tJRC on February 23, i
1993. On April 6,1993, a possession only license for the special l
nuclear material at the Cushing site was issued to Kerr-McGee.
7.
Other Involved Parties i
A consent order was entered into by the Oklahoma State Department of
)
Health and Kerr-McGee Corporation on May 4,1990.
The consent order required:
- 1) the characterization of the entire site, and if necessary, controls to prevent the removal or inadvertent spread of contamination to adjacent properties; 2) that contaminated soil around the process buildings be evaluated and excavated,.if necessary, to meet BTP Option 1 limits; 3) that the process building surfaces be decontaminated to meet current tiRC release criteria; and 4) that a feasibility study on remedial alternatives for the contamination in the northern portion of the site be submitted by May 1992.
A-120 fiUREG-1444 l
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l 8.
NRC/ licensee Actions and Schedule i
Kerr-McGee submits a license amendment request proposing the boundaries of areas on Cushing i
site that will be addressed as contaminated I
during remediation June 1993 j
NRC reviews proposed boundaries of contaminated areas l
and requests additional information (RAI)
June 1993 NRC approves designated boundaries of contaminated 30 days areas and issues amendment after Kerr-
"cGee response to RAI i
l I
Kerr-McGee submits license amendment request June 1993 proposing methods for controlling erosion from I
temporary on-site storage areas l'
NRC reviews proposed erosion control methods and requests additional information July 1993 NRC approves methods for controlling erosion 30 days and issues amendment after Kerr-McGee response 1
-to RAI Kerr-McGee submits license amendment request proposing decommissioning plan February 1994 NRC reviews decommissioning plan and requests additional information April 1994 NRC approves decommissioning plan and 60 days issues amendment after Kerr-McGee response to RAI A-121 NUREG-1444
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A-122 NUREG-1444 4
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t West Lake Landfill 1.
Site Identification l
West Lake Landfill Bridgeton, St. Louis County, M0 Docket Nos.:
040-08035 040-08801 License Status:
None l
Project Manager: J. Parrott
)
l 2.
ci'e and nraratione i
The West Lake landfill property, owned by Laidlaw and Rockroad, Inc. is a 81 hectare (200 acre) tract on the outskirts of the city of St. Louis.
Limestone was quarried there from 1939 to 1987, and an unregulated landfill was operated on part of the site from 1962 to 1974. 'About 3.9 7
x 10 kg (8.6 x 10' pounds) of contaminated soil, from Cotter Corpora-tion's Latty Avenue site, was placed in the landfill in 1973. A
)
concrete plant is operating on site, as well as a 8.9 hectare (22 acre) 1 demolition landfill and a 21 hectare (52 acre) sanitary landfill.
The property is on the border of the Missouri River Valley about 1.9 km-(1.2 miles) from the river.
The U.S. EPA Region VII office has the lead on the remediation of this site under the Superfund program.
EPA has identified four potentially-responsible parties (PRPs)'for the Superfund remediation of this site,.
these are Cotter Corporation, Laidlaw Waste Systems, Rock Road Indus-tries, and the U. S. Department of Energy.
3.
Radioactive Wastes
~
Two areas on the site have a layer of radiologically contaminated soil, mostly covered with 0.9 to 6.1 meters (3 to 20 feet) of other waste.-
The larger area in the northern site area comprises about-5.3 hectares 3
6 3
(13 acres) and contains about 99000 m (3.5 x 10 ft ) of soil contami-i A-240 NUREG-1444-
4 nated to at least 0.2 Bq/g (5 pCi/g) radium-226 (Ra-226). This contami-nated soil forms a more or less continuous layer from 0.6 to 4.6 meters i
l (2 to 15 feet) in thickness and lies above 4.9 to 6.1 meters (16 to 20 feet) of landfill debris.
The smaller area to the south covers 1.2 nectares (3 acres) and contains about 14,000 m (500,000 feet). This 3
oil body lies above a former quarry pit that was filled with debris.
The average Ra-226 concentration is about 3.3 Bq/g (90 pCi/g), uranium radioactivity concentrations average appreciably smaller, and the thorium-230 (Th-230) concentrations are 20 to 100 times those of Ra-226.'
The contamination originated with residues from extraction of uranium and radium from very rich uranium ores for the Atomic Energy Commission.
I 4
Description of Radiolooical Hazard This site poses no immediate threat to the public.
Radioactivity has been detected in groundwat'er monitoring wells on site, indicating slight contamination above background.
5.
Financial Assurance / Viable Respon;ible Orcanization As stated above, the U.S. EPA Region VII office has the lead on the remediation of this site under the Superfund program.
Under this program all remediation costs are provided by the PRPs or guaranteed l
through the fund.
6.
Status of Decommissionino Activities The Nuclear Regulatory Commission (NRC) had a radiological survey l
performed in 1981 and an environmental characterization of the site performed in 1983.
NRC previously informed Cotter Corporation that it is being held responsible for site remediation and asked for its plans for remedial action.
However, no site remedial action was done. The property owner has not allowed any more waste to be dumped in these
)
- areas, i
A-241 NUREG-1444
i t
t l
On August 30, 1990, the U.S. Environmental Protection Agency (EPA) listed the site on the Comprehensive Environmental Response, Compensa-tion, and Liability National Priorities List for Uncontrolled Hazardous.
Waste Sites and ranked it as site number 1003.(55 FR 35502).
In discussions between NRr, and Cotter Corporation in November 1990, it was acknowledged that EPA is taking the lead for site remediation. activi-ties. This arrangement was agreed to in a letter from NRC to EPA dated March 18, 1991.
7.
Other Involved Parties
(
EPA is currently working to establish a Scope of Work agreement with the j
cops to remediate the site. NRC will monitor EPA activities and I
i progress on this case.
NRC will ensure that there is a satisfactory cleanup arrangement and that the disposal of any removed waste material is in accordance with NRC requirements.
8.
NRC/ Licensee Actions and Schedule I
PRPs sign Scope of Work agreement March 1993 PRPs submit Work Plan to EPA May 1993 EPA requests NRC review of Work Plan September 1993 NRC completes review of Work Plan January 1994 9.
Problems / issues Because EPA is the lead agency, NRC does not exercise control over remediation activities.
1 A-242 NUREG-1444 1