ML20126C047
| ML20126C047 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 12/18/1992 |
| From: | Lux J KERR-MCGEE CORP. |
| To: | Fauver D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9212220334 | |
| Download: ML20126C047 (18) | |
Text
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7A3&3 KERR.Mr. GEE CENTER e OKLAHOMA CliY. ORL AHOMA 7Jl?S December 18,1992 Mr. David Fauver Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Commission Wahington, D. C. 20555 Re: Docket No. 70-3073
Dear Mr. Fauver:
Kerr-McGee Corporation (KMC) submitted an Application for Materials License to the NRC in September,1992. That application included a decommissioning funding plan generated for the purposes of financial assurance. In a telephone conversation subsequent to the submittal of the application, you indicated that staff responsible for reviewing the decommissioning funding plan had questions concerning how KMC estimated the costs. We believe the attached " Comments on the Cushing Decommissioning Funding Plan" explain why and how KMC arrived at the costs included in the plan.
In addition, we have made corrections to several pages in the license application.
The replacement pages are attached. Changes represent corrections of typographical errors and are not changes in substance.
If you have any further questions or comments concerning the cost estimates, please contact me at (405) 270-2694.
Sincerely,
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Jeff Lux Project Manager Kerr-McGe2 Corporation JL/jl cc:
R.R. Smith J.C. Stauter J.G. Ostmeyer 220080
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4 COMMENTS ON Tile CUSillNG DECOMMISSIONING FUNDING PLAN The following text outlines the rationale used in developing the cost estimate that pmvided the basis for financial assurance for the Kerr-McGee Corioration (KMC) Cushing facility license application. Areas of concern are addressed as discussed by Mr. David Fauver, in a telephone conveisation held November 17, 1992.
Costs Associated with the Use of the Cimarron Crew Mr. Fauver requested an explanation of the use of " crew-months" for estimating costs associatei with the following activities:
a) sorting and stockpiling mdioactive material, b) packaging and shipping radioactive material, c) radioactive material disposal and burial, and d) release surveying.
KMC believes the use of Cimarron " crew-months" is the most reasonable means of estimating these costs.
KMC has been utilizing a crew of four decontamination workers, one decontamination supervisor, and one health physics technician on a full time basis, as well as a radiation safety officer and accountability supervisor on a part time basis, for over two years.
Throughout that time, Cimarron Corporation charged KMC for all charges associated with the use of the Cimarron crew. These charges include the hourly wages of the employees for the hours they worked on the Cushing c!wp. However, these charges also inchide the cost of employee benefits, equipment and materbis consumed in the crew's decontamination activities, vehicle charges and fuel consumption, and other miscellaneous costs associated with monitoring and maintaining monitoring equipment.
l Over those two years, KMC has developed confidence in estimating the amount of work that can be accomplished over " calendar time" The amount of work that the Cimarron crew can complete in a month is much easier to visualize than the number of man-hours required to perform as significant a work effort as we face at Cushing. Since the exact quantity and 4
distribution of radioactive material at the Cushing site cannot be precisely predicted, based on current information, we have discovered that " crew-months" are a better means of estimating costs associated with radioactive materials work than the use of man-hours with estimated overhead.
Costs Associated with Contractor Charges A+ Welding and Construction (A+) has been serving as an earthmoving contractor for KMC at the Cushing site for the duration of the cleanup. According to the existing contract between A+ and KMC, the hourly rates for specified equipment (with operator) are:
4 4
16 cubic yard truck
$32.00 per hour John Deere 690B excavator
$60.00 per hour John Deere 650G dozer
$54.00 per hour John Deere 750B dozer
$70.00 per hour Caterpillar D9 dozer
$100.00 per hour JD 624E loader
$44.00 per hour Eteparation of Storage Areas-This estimate was based on what was required to prepare the first storage area, which is essentially complete. KMC estimated that it would require twenty working days running two trucks and one excavator to prepare the remaining two storage areas.
Construction of Disposal Cell-The radioactive material volume estimate performed for the license application yielded 2,650 cubic yards (71,550 cubic feet) of Option 2 material. Assuniing a pending disposal cell site evaluation yields an acceptable site, a disposal cell would be constructed for onsite disposal. In order to bury this volume of material, the disposal cell considered for this cost estimate would be constmeted with side slopes of 3:1, Hve feet of cover, and a maximum waste thickness of 10 feet. The cell thus constructed would be (assuming a square plan configuration) Otteen feet deep,55 feet long and wide at the base, and 145 feet wide and long at the surface.
Based on non-radiologic earthwork already performed at the site, such as _ excavation of a new Creek channel and construction of an oil interceptor trench, it was estimated that one dozer, two trucks, and one excavator would be employed for approximately four weeks to construct the disposal cell. Approximately two thirds of that time the Cat D9 would be used, and the John Deere 750B would be used the remaining third. This is why a $90.00 per hour rate was used.
Fill Disnosal Cril-Two tnicks, one loader, and one dozer were included in the cost estimate for placement of Option 2 material in the dispos / cell. The loader will hiad trucks at the storage areas, and the dozer will spread and compact.ae material as it is placed in the cell. Although it would only require approximately one week for the equipment specified to haul the 2,650 cubic yards of Option 2 material from the storage areas to the disposal cell, four weeks were estimated in the cost estimate because of inefficiencies associated with surveying the materials hauled as well as performing frequent exit surveys on the equipment.
Cover Placement-Two trucks, one loader, and one dozer were included in the cost estimate for cover placement. As with the filling of the disposal cell, KMC was very generous in the estimate of the time required to perform this task. Four weeks of use were estimated for all equipment at the above rates.
Hydrocarbon Extraction The radioactive material volume estimate performed for the license application yielded 670 tons of Option 4 material containing more oil and grease than the Chem-Nuclear disposal site is allowed to receive for burial. KMC determined the treatment cost for this " oily" Option 4 material based on communication with Waste Management, Inc. They quoted a "per ton" price plus substantial mobilization costs, which we translated to a "per ton" basis for the 670 tons of material requiring processing.
J I
4 Eack and Ship The cost estimate also included the packaging and shipping of 20 h> ads of Option 4 soil for disposal at Chem-Nuclear's Barnwell, South Carolina disposal site. - Since the submission of the license application, sixteen loads of Option 4 material have been shipped to Barnwell, KMC has already spent approximately $463,000 on the packaging and shipping of these materials, in accordance with the following breakdown:
Cimarron Crew charges (estimated)
$ 25,000 Freight
$ 18,000 Disposal Fees
$420,000 4
KMC believes that any errors concerning the time required for the above listed tasks will be more than compensated for by the more significant reduction in future expenditures represented by We packaging and shipping of this Option 4 material.
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O ITEM 10.
RADIATION SAFETY PROGRAM RJ Radiation safety measures are employed to protect workers rnd the general public against exposure to radiation levels exceeding permissible limits and to assure any exposures are maintained as low as reasonably achievable. The radiation safety program includes various monitoring and control measures.
Jill Personnel Monitoring Devices Film badges are used to monitor the external gamma radiation exposure of employees. The badges are furnished and processed by a supplier certified under The National Voluntary Laboratory Accreditation Program (NVLAP) as required under 10 CFR 20.202.C.1. Anyone AU entering a radioactive materials area is required to wear a film badge when within the radioactive materials area. Radiation workers wear film badges at all times while on site. Radiation I
workers' film badges are exchanged on 4 monthly basis. Film badges for visitors and others who do not routinely work with ruiwetive materials will be exchanged on a quarterly basis.
Records of exposure are kept on file.
JL2 Bioassays t
The licensed material remaining at the site has been exposed to the effects of the weather for many years. The radioactivity remaining is therefore chemically fixed within various matrices and are highly insoluble. Kerr-McGee considers the licensed material remaining on site as contamination to have a "Y" lung solubility classification.
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Q Dust suppression measures -will be employed where indicated on the basis of activity and measurements, as well as when there is visible evidence of dust suspension. Dust suppression measures will consist of water spray on loose particulate material until visual evidence ledicates that suspension of particulate matter has subsided.
If the result of any lapel or area air sample yields in excess of 0.5 MPC, an evaluation will be performed to determine what dust suppression measures were in effect and what additional I
measures should be implemented, if any. Work will not continue under the same conditions that produce air sample counts exceeding 1.0 MPC unless it is determined that the high count is an i
i artifact of the sampling device or the counter. This will assure that radioactive material intake will not exceed 40 MPC-hours within a work week.
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In-vivo lung counts will be performed every two years or each employee who routinely works l
with rtdioactive material. In-vivo lung count results will be used to compare the levels of 1
l uranium and thorium deposition in the lungs with the maximum permissible lung burdens.
l E
Surveys and Monitoring During Work With Radioactive Materials Health physics activities su1 porting site decontamination activity include definition of-l I
areas of radioactive contamination and monitoring of ambient-conditions.
Where indicated by monitoring results or observation of airborne particulates, protective I
clothing, respiratory protection, and personnel monitoring will be specified by the RSO '
O or health physics technician. As a minimum, where radioactive materials are being 13
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reviewed by corporate management, operations management, and the RSO. Operations management is responsible to respond to tne corporate audit, taking follow-up action and providing evidence of such action where indicated. A re-audit of compliance will be performed if deemed necessary by the Corporate Regulatory Compliance Auditor.
H. Standard Ooerating Procedugn The nature of the site and the decommissioning activities involved do not allow strict standard operating procedures (SOP) to be used effectively, because euch location with contamination is unique. Because features and circumstances vary between locations containing licensed materials, a Special Work Permit (SWP) Program will specify control activities related to site remediation and radiation protection. Special work permits (O3 specify the methodology used for completing a particular task and identify controls that must be implemented to perform the task safely. Supervisory staff generate special work permits, which are reviewed by health physics staff before work begins. Health physics staff review the SWP to assure that ALARA exposure levels are maintained.
l Employees r ssigned to an SWP-related activity review the SWP and follow the indicated precautions to perform the task safely.
All personnel responsible for either the preparation of the SWP or the performance of the task are required to sign the SWP, indicating awareness of the safety precautions associated with that task. A properly completed SWP is evidence that an upcoming job was reviewed for safety and exposure considerations. A special work permit is required and must be completed prior to
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beginning work whenever a safety hazard is suspected to exist or could be created, 24 l
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addition, approximately 500 cubic yards of Option 1,2, and 4 material has been excavated and stockpiled on site. Activities to date have been performed in accordance with 10 CFR Parts 20, 40, 70, and 71.
4 1L2 Material Excavation r
Micro-R meters are used to identify areas with surface gamma radiation levels-above background. A more sensitive radiation detection instrument equipped with a lead shielded 4
1 3" x 1/2" Nal instrument then defines the physical extent of the contaminated area. This area is flagged with surveyor flags.
Material samples are collected and analyzed with the t
1 computer-based multi-channel gamma analyzer to determine the radioactive concentration and l
isotopes present. Sampling with depth enables the volume of material and concentration within O
that volume to be approximately determined. The material may be excavated at that time or the
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location recorded and the area left for excavation at a future time. The 3" NaI detector is used to guide the excavation process until the detector indicates concentrations below Option 2 levels I
of the Branch Technical Position. Excavation equipment is selected based on the size and l
relative dimensions of the contaminated area.
When excavation is complete the area is gridded at appropriate intervals. Exposure levels and i
i gamma radiation levels are recorded at each node using a micro-R meter and a 3" detector. Soil.
samples are taken from the area showing the highest gamma radiation level as well a. w 1 an area with an " average" gamma reading. Samples are counted with the computer-based gamma.
spectrum analyzer to verify that the area has been cleaned to meet Option 1 unrestricted use O
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natural background, plus 20 pCi/g above natural background enriched uranium would be 1,467 times the maximum permissible contamination (MPC) for Option 1 material, because:
8 (Th activity) 20 (U activity)
= 1.467 FMPC 10 (Option 1 MPC) 30 (Option 1 MPQ Licensed materiai remaining as residual contamination will be sorted into either Option 1, 2, or 4 or greater concentration wges. Within these option ranges, the material will be further sorted on the basis of the matr:x or substrate containing the licensed material as identified below.
A. Non-Oily (<3% Oil & Grease.)
Contaminated material generated in the decontamination of the former processing Q
buildings and contaminated soil and sediments that contain less than 3% oil and grease V
comprise this category. Option 2 concentration range matecial will be stockpiled on site for subsequent disposal Option 4 material will be drummed and shipped to a licensed disposal facility, B. Pit 4 (Mixed) Wastes 3
Option 2 or 4 thorium-contaminated material in the western portion of Pit 4 will be neutralized to yield a pH of 7 or greater during excavation. The excavation and neutralization process is described below in the section entitled, " Pit 4 Excavation and Neutralization". After neutralization, the material will be sampled and sorted into Option 1, Option 2, and Option 4 categories. Option 1 material will be addressed as Non-hazardous Solid Industrial Waste, in accordance with OSDH regulations. Option 2 or 29
Q During excavation and neutralization activities, the sludge will be handled in accordance with V
requirements governing both hazardous and radioactive waste. The Waste Management Group of Kerr-McGee's Technology Division is performing a treatability study to determine the preferred method for efficiently and economically excavating and neutralizing the acidic oily i
wastes. After the contaminated waste sludge has been neutralized, the Option 1 material will be handled as State designated "Other Industrial Waste". Option 2 material will be stockpiled as discussed below. Option 4 material will be disposed of at a permitted disposal facility.
ILS Stockoiling and On Site Storace Three former petroleum stora;e tank pads are used as interim radiological material storage areas.
Figure 2 shows the locations of the three upgraded tank pads, identified as storage areas A, B, Q
and C. Option 2 waste containing > 3% oil and grease by laboratory analysis will be placed in storage area A. Contaminated material above Option 2 that also contains > 3% oil ar.d grease by laboratory analysis will be placed in storage area B. All other Option 2 material will l
l be placed in storage area C.
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Each storage area will consist of a three foot high earthen berm surrounding the storage area.
l Portions of the berm will be sloped gently to provide vehicular access to the storage area. A l
fence will be constructed around each berm to restrict access. Gates will be installed in the fence for access, and will be locked when not being used. The fence will be posted with signs reading, " CAUTION, RADIOACTIVE MATERIALS". Two thermoluminescent dosimeters (TLD's) will be posted on the fence in each cf the three storage areas to monitor the fence line O
extere i exposere ievet. T'o' -iii de se=t 'e the >> der tory ror #airsis o# = 9=>rteriy desi -
31
Q SAFEGUARD REQUIREMENIS v
The small amount of special nuclear material at the Cushing site exists solely as waste in the form of contaminated soil and sediment and on building surfaces. These materials are not suitable for recovery of either the special nuclear material or the source material content.
Significant effort has been expended to develop a method for removing the isotopes from the matrices in which they are contained to reduce the volume of material requiring disposal under 10 CFR Part 61 provisions. None of the approaches attempted, including soil washing and i
chemical extraction, have had any material effcet on making such a separation.. Moreover, i
i analyses of surface and s.ibsurface water failed to show the presence of contamination, further i
indicating the isotopes are bound on the soil and material and matrices and are not readily i O matiis.
l l-The matedals are acceptable for land disposal and will be handled in accordance with 10 CFR-l Part 61 provisions for Class A unstable waste. The waste does not contain any nuclides listed l
in Tables 1 or 2 of 10 CFR 61.55 and is therefore Class A waste (10 CFR 61.55(a)(6).
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In accordance with the Commission's position on safeguarding special nuclear material bearing-i waste, the Cushing site materials are not of a form or concentration that requires the protection as set forth in 10 CFR 73.
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ITEM 10.
RADIATION SAFETYPROGRAM Radiation safety measures are employed to protect workers and the general public against exposure to radiation levels exceeding permissible limitt and to assure any exposures are maintained as low as reasonably achievable. The radiation safety program includes various monitoring and control measures.
i a
M Personnel Monitoring Devices Film badges are used to monitor the external gamma radiation exposure of employees. The badges art, furnished and processed by a supplier certified under The National Voluntary Laboratory Accreditation Progrr.m (NVLAP) as required under 10 CFR 20,202.C.1. Anyone i
]
entering a radioactive materials area is required to wear a film badge when within the radioactive materials area. Radiation workers wear film badges at all times while on site. Radiation workers' film badges are exchanged on a monthly basis. Film badges for visitors and others who do not routinely work with radioactive materials will be exchanged on a quarterly basis.
1 Records of exposure are kept on file.
1 11h2 Bisssafs l
The licensed material remaining at the site has been exposed to the effects of the weather for many years. The radioactivity remaining is therefore chemically fixed within vativus matrices and are highly insoluble. Kerr-McGee considers the licensed material remaining on site as l
l contamination to have a "Y" lung solubility classification, i
11 1
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l Dust suppression measures will be employed where indicated on the basis of activity and i
measurements, as well as when there is visible evidence of dust suspension. Dust suppression measures will consist of water spray on loose particulate material until visual evidence indicates that suspension of particulate matter has subsided.
1 If the result of any lapel or area air sample yields in excess of 0.5 MPC, an evaluation will be performed to determine what dust suppression measures were in effect and what additional measures should be implemented, if any. Work will not continue under the same conditions that produce air sample counts exceeding 1.0 MPC tmless it is determined that the high count is an i
arti.act of the sampling device or the counter. This will assure that radioactive material intake v ih not exceed 40 MPC-hours within a work week.
O 1
In-vivo lung counts will be performed every two years on each employee who routinely works with radioactive material. In-vivo lung count results will be used to compare the levels of uranium and thorium deposition in the lungs with the maximum permissible lung burdens.
i i
l 1Q3 Surveys and Monitoring l
A. Dunng Work With Radioactive Materials Health physics activities supporting site decontamination activity ir.clude def' ition of m
areas of radioactive contamination and monitoring of ambient conditions.
Where l
indicated by monitoring results or observation of airborne particulates, prote,:tive l
clothing, respiratory protection, and personnel monitoring will be specified by the RSO I
O or health physics technician. As a minimum, where radioactive materials are being 13 l
,p reviewed by corporate management, operations management, and the RSO. Operations -
G management is responsible to respond to the corporate audit, taking follow-up action and providing evidence of such action where indicated. A re-audit of compliance will be performed if deemed necessary by the Corporate Regulatory Compliance Auditor.
H. Standard Operatine Presedures:
The nature of the site and the decommissioning activities involved do not allow strict standard operating procedures (SOP) to be used effectively, because each location with contamination is unique. Because features and circumstances vary between locations containing licensed materials, a Special Work Pemiit (SWP) Program will specify control activities related to site remediation and radiation protection. Special work permits
]
specify the methedology used for completing a particular task 'nd identify controls that must be implemented to perform the task safely. Supervisory staff generate special work permits, which are reviewed by health physics staff before work begins. Health physics staff review the SWP to assure that ALARA exposure levels are maintained.
Employees assigned to an SWP-related activity review the SWP and follow the indicated precautions to perform the task safely.
All personnel responsible for either the preparation of the SWP or the performance of the task are required to sign the SWP, indicating awarer. ss of the safety precautions associated with that task. A properly completed SWP is evidence that an upcoming job was reviewed for safety and exposwe considerations, A special work permit is required and must be completed prior to
()
beginning work whenever a safety hazard is suspected to exist or could be created.
m 24 e
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addition, approximately 500 cubic yards of Option 1,2, and 4 material has been excavated and stockpiled on site. Activities to date have been performed in accordance with 10 CFR PW 20, 40,70, and 71.
IL2 Material Excavation Micro-R meters are used to identify areas with surface gamma radiation levels above background. A more sensitive radiation detection instrument equipped with a lead shielded 3" x 1/2" Nal instrument then defines the physical extent of the contaminated area. This area is flagged with surveyor flags.
Material samples are collected and analyzed with the computer-based multi-channel gamma analyzer to determine the radioactive concentration and isotopes present. Sampling with depth enables the volume of material and soncentration within C
that volume to be approximately determined. The material may be excavated at that time or the location recorded and the area left for excavation at a future time. The 3" NaI detector is used to guide the excavation prms until the detector indicates concentrations below Option 2 levels of the Branch Technical Position. Excavation equipment is selected based on the size and relative dimensions of the contaminated area.
When excavation is complete, the area is gridded at appropriate intervals. Exposure levels and gamma ~dicion levels are recorded at each node using a micro-R meter and a 3" detector. Soil samples are taken from the area showing the highest gamma radiation level as well as from an area with an " average" gamma reading. Samples are counted with the computer-based gamma spectrum analyzer to verify that the area has been cleaned to meet Option 1 unrestricted use O
ieveis.
27 1
natural background, plus 20 pCi/g above natural background enriched uranium would be 1.467 times the maximum permissible contamination (MPC) for Option 1 material, because:
8 (Th activity) 20 (U activity)
,3,453 ygpg 10 (Option 1 NPC) 30 (Option 1 MPC)
Licensed material remaining as residual contamination will be sorted into either Option 1, 2, or 4 or greater concentration ranges. Within these option ranges, the material will be further sorted on the basis of the matrix or substrate containing the licensed material as identified below.
A. Non-Oily (< 3% Oil & Grease)
Contaminated material generated in the decontamination of the former processing Q
buildings and contaminated soil and sediments that contain less than 3% oil and grease comprise this category. Option 2 concentration range material will be stockpiled on site for subsequent disposal. Option 4 material will be drummed and shipped to a licensed disposal facility, f
B. Pit 4 (Mixed) Wastes Option 2 or 4 thorium-contaminated material in the western portion of Pit 4 will be neutralized to yield a pH of 7 or greater during excavation. The excavation and neutralization process is described below in the section entitled, " Pit 4 Excavation and Neutralization". After neutralization, the material will be sampled and sorted into Option 1, Option 2, and Option 4 categories. Option 1 material will be addressed as Non-
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hazardous Solid Industrial Waste, in accordance with OSDH regulations. Option 2 or 29
i During excavation and neutralization activities, the sludge will be handled in accordance with requirements governing both hazardous and radioactive waste. The Waste Management Group of Kerr McGee's Technology Division is performing a treatability study to determine the preferred method for efficiently and economically excavating and neutralizing the acidic oily wastes. After the contaminated waste sludge has been neutralized, the Option 1 material will be handled as State designated "Other Industrial Waste". Option 2 material will be stockpiled as discussed below. Option 4 material will be disposed of at a permitted disposal facility.
1L5 Stockniling and On Site Storage Three former petroleum storage tank pads are used as interim radiological material storage areas.
Figure 2 shows the locations of the three upgraded tank pads, identified as storage areas A, B, Q
and C. Option 2 waste containing > 3% oil and grease by laboratory analysis will be placed in storage area A.. Contaminated material above Option 2 that also contains > 3% oil and grease by laboratory analysis will be placed in storage area B. All other Option 2 material will be placed in storage area C.
Each storage area will consist of a three foot high earthen berm surrounding the storage area.
Portions of the berm will be sloped gently to provide vehicular access to the storage area. A fence will be constructed around each berm to restrict access. ' Gates will be installed in the j
fence for access, and will be locked when not being used. The fence will be posted with signs i
reading, " CAUTION, RADIOACTIVE MATERIALS". Two thermoluminescent dosimeters (TLD's) will be posted on the fence in each of the three storage areas to monitor the fence line O
extemal exposure level. TLD's will be sent to the laboratory for analysis on a quarterly basis.
l l-31 l
l l
Q SAFEGUARD REQUIREMENIS The small amount of special nuclear material at the Cushing site exists solely as waste in the form of contaminated soil and sediment and on building surfaces. These materials are not suitable for recovery of either the special nuclear material or the source material content.
Significant effort has been expended to develop a method for removing the isotopes from the matrices in which they are contained to reduce the volume of material requiring disposal under 10 CFR Part 61 provisions. None of the approaches attempted, including soil washing and chemical extraction, have had any material effect on making such a separation. Moreover, analyses of surface and subsurface water failed to show the presence of contamination, further indicating the isotopes are bound on the soil and material and matrices and are not readily O
mediiized.
4 6
The materials are acceptable for land disposal and will be handled in accordance with 10 CFR Part 61 provisions for Class A unstable waste. The waste does not contain any nuclides listed in Tables 1 or 2 of 10 CFR 61.55 and is therefore Class A waste (10 CFR 61.55(a)(6).
In accordance with the Commission's position on safeguarding special nuclear material bearing waste, the Cushing site materials are not of a form or concentration that requires the protection as set forth in 10 CFR 73.
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