ML20135A889

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Forwards Amend 6 to License SNM-1999,safety Evaluation & Categorical Exclusion.Amend Revises Conditions 11.K,11.F, 11.D & 11.C as Listed
ML20135A889
Person / Time
Site: 07003073
Issue date: 02/12/1997
From: Brown S
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Lux J
KERR-MCGEE CORP.
Shared Package
ML20135A891 List:
References
NUDOCS 9702280012
Download: ML20135A889 (7)


Text

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k UNITED' STATES 3

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. NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20664 0001 0

i February 12, 1997 f

g Mr.-Jeff Lux-Project Manager i

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, Kerr-McGee Corporation Kerr-McGee Center i

P.O. Box 25861

. Oklahoma City, OK 73125 i

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SUBJECT:

ISSUANCE OF AMENDMENT NO. 6 TO MATERIALS LICENSE NO. SIM-1999, i

CUSHING REFINERY SITE i

Dear Mr. Lux:

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The Commission has issued the enclosed Amendment No. 6 to Materials License No. SIM-1999 for the Cushing Refinery Site. This amendment is in response t'o Kerr-McGee's license amendment request, dated October 20, 1995, and is separated into four main sections. These sections are:

(1) the organization j

supporting the decommissioning of the Cushing site; (2) the approval i

requirements of radiation safety procedures; (3) the commitments of.the j

bioassay and-air sampling programs implemented under the radiation safety program; and (4) other miscellaneous items addressed in the license j

app'ication.

t The first section of the license amendment application requests that the j

licensee's organization be changed as shown on a chart it submitted as amended on February 9, 1996, and that Mr..Terence Moore be no longer designated by l

name as the radiation safety officer (RS0). NRC staff concludes that the i.

organization changes are adequate to ensure that licensed material will be l

used in accordance with NRC regulations. Accordingly, License No. SIM-1999 is j

amended as follows:

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lI.K. Except as specifically provided otherwise in this i-license, the licensee shall conduct its program in l

accordance with statements, representations, and conditions contained in a letter dated September 25, 1992, as supplemented on December 18, j

1992, January 14, 1993, February 23, 1993, August 26, 1993, January 5, 1994, and February 9, 4

1996.

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j NRC staff addressed the issue regarding the designation of the RSO in a letter dated November 14, 1995, in which NRC staff believes it is appropriate to i

~ specifically list the RSO on the license to ensure NRC will have an L

opportunity to review qualifications for the replacement of RS0's. The Ilconsee withdrew this amendment request in a letter dated February 15, 1996, i

.and said that it will continue to operate in accordance with this license-1 condition.-

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The second section of the licensee's request is to either delete approval requirements for the radiation safety plan and procedures or require approval of the radiation safety procedures by the RSO only and not by management. NRC staff agrees with the licensee that the licensee's managers do not need to f

approve the technical radiation protection program procedures.

In addition, j

the licensee said in a letter, dated February 15, 1996, that the revisions to-l-

the radiation safety plan would continue to be approved by the RSO, the Site Manager, the Project Manager, and the Project Leader. NRC staff believes that revisions to the radiation safety plan would be reviewed by the appropriate

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level of the licensee's managers. Accordingly, License No. SNM-1999 is j

amended as follows:

w 11.F. All radiation protection program procedures or revisions to these procedures shall be approved by the padiation Safety Officer. All revisions to the i

radiation safety plan shall be approved by the i

Radiation Safety Officer, Site Manager, Project j

Manager, and Project Leader.

The third section of the amendment request, regarding the commitments of the 4

bioassay and air sampling programs implemented under the radiation safety program, requests to be relieved from three comunitments. The commitments are to collect daily lapel and area air samples, provide 50 percent of all workers l

with lapel air samplers when working in radioactive materials areas, and provide bi-monthly urinalysis and bi-annual in-vivo lung count. The staff concludes that the. licensee's request to replace its commitments with revised air sampling and bioassay programs acceptable. However, NRC staff recommends that the revised programs = included-in the Cushing license as a license condition. Accordingly, License No. SM-1999 is amended as follows:

11.D. Lapel air samplars will be issued when required by a special work permit or at the direction of the health physics personnel. Lapel air samplers would be issued when there is a reasonable probability that personnel may be exposed to airborne radioactive material. -Lapel air samplers may be issued at a minimum of one per work crew, or a maximum of one per individual, depending on the work scope and the potential for worker exposure.

Downwind area air sampling would be performed when work activities are being performed that would cause the potential of producing airborne radioactivity, such as eartheoving.

Urine sampling and analysis for uranium isotopes will be performed for all workers in a crew, if either area air sample (s) or lapel air sample (s) indicate the following:

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>40 DAC-hrs for a single air sample result, j

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>100 DAC-hrs /yr accumulated exposure for any one j

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worker.

i Fecal analysis will be performed in cases where i

d thorium exposure is suspected and either area air e

sample (s) or lapel air sample (s) indicate chronic j

or acute exposures in excess of 100 DAC-hrs.

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The final section of the. license amendment request contains three t

miscellaneous items addressed in the license application. The requests are:

.l (1) NRC recognizes stipulated times of training programs are not appropriate i

as criteria for judging the adequacy of a radiation safety training program; 4

(2) all film badges for both workers and visitors to be submitted on a j

quarterly basis; and (3) all radiation monitoring instruments to be calibrated j

either by th; ='ufacturer or at the Cushing facility.

NRC staff addressed the issue regarding the radiation safety training program in a letter dated November 14,-1995, in which NRC staff agreed that the i

content of training courses, not the number of hours devoted to each course, j

is the germane issue. Thus, NRC staff requested alternate designations for the two training courses, and the licensee responded in a letter dated i.

February 15, 1996. Accordingly, License No. SNM-1999 is amended as follows:

l II.C. Both the Initial Radworker Training and the Annual l

Radworker Requalification Training, described in 4

Item 8 of the application, shall include all of the i

topics described in 10 CFR 19.12.

NRC staff acknowledges the modification for film badge submittal in the l

radiation safety program, as appropriate, based on the data submitted by the Itcensee.- NRC staff also acknowledges the modification for the location of instrument calibration as acceptable.

NRC staff has considered the potential for environmental impact of the license i

modifications and has determined that the amendment will not result in any i

significant environmental impact. Having made this determination, we have further concluded that the amendment does not substantially modify existing regulations and involves actions which are administrative, organizational, and procedural in nature and, as provided by the categorical exclusion of 10 CFR 51.22(c)(11), an environmental assessment need not be prepared in connection with the issuance of this amendment.

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J. Lux All other conditions of the license shall remain the same. The revised License No. SNM-1999, which incorporates Amendment No. 6, and the related Safety Evaluation are enclosed. Further, if you have any questions, please contact me at (301) 415-6605.

Sincerely,

[0riginal signed by]

i Stewart W. Brown, Prr

t Manager Low-Level Waste and ecommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No: 70-3073 License No: SNM-1999

Enclosures:

1.

Amendment No. 6 to License No. SNM-1999 2.

Safety Evaluation 3.

Categorical Exclusion cc w/encls: Kerr-McGee, Cushing dist. list l

DISTRIBUTION: [*w/ or **w/o encl or att)

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1/31/97 L //(//97 7/*I/97 f./b/97 J//)/97 0FFICIAL I!ECORD COPY i

ACNW: YES X

NO IG : YES N0 X

Delete file after distribution: Yes X No LSS : YES NO X

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All other conditions of the license shall remain the same. The revised License No. SNM-1999, which incorporates Amendment No. 6, and the related Safety Evaluation are enclosed.

Further, if you have any questions, please contact me at (301) 415-6605.

Sincerely, a -

Stewart W. Brown, Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management j

Office of Nuclear Material Safety and Safeguards 4

Docket No: 70-3073 License No: SNM-1999

Enclosures:

1.

Amendment No. 6 to License No. SNM-1999 2.

Safety Evaluation 3.

Categorical Exclusion cc w/encls: Kerr-McGee, Cushing dist. list l

1 J

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.c Kerr McGee Corporation, Cushing Plant Docket No. 70 3073, License No. SNM 1999 j

i Mr. Jess Larsen

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Project Leader 4:

Kerr McGee Corporation.

Kerr McGee Center P.O. Box 25861 Oklahoma City, OK 73125 1

Mr. Jeff Lux l

5 Project Manager Kerr McGee Corporation i

Kerr McGee Center P.O. Box 25861 Oklahoma City, OK 73125 i

Reponal Administrator j

j-USNR0 Region IV i

Louis C. Carson ll t

j' USNRC Region IV i

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Blair D. Spitzberg USNRC Region IV i-Michael Broderick Oklahoma Department of Environmental Quality 1000 NE 10th Street l

Oklahoma City, OK 73117 1212 Oklahoma State Department of Labor 4001 N. Lincoln Boulevard Oklahoma City, OK 73117 Richard Reiley j

Chairman, Citizen's Kerr McGee

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clo Cushmg Public Library Oversight Committee P.O. Box 551-Cushmg, OK 74023 4

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