ML20197C375
| ML20197C375 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 09/03/1998 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20197C367 | List: |
| References | |
| NUDOCS 9809110145 | |
| Download: ML20197C375 (5) | |
Text
- -
I '
pwa ye 4 UNITED STATES j
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055M001
% , ,o September 3, 1998 THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS SAFETY EVALUATION RELATED TO AMENDMENT NO. 8 TO MATERIALS LICENSE NO SNM-1999 KERR-McGEE CORPORATION j CUSHING REFINERY SITE '
I DOCKET NO. 70-3073
- 1. INTRODUCTION j The Kerr-McGee Corporation (the licensee) by letter dated November 26,1997, submitted an application requesting that its license for the Cushing refinery site located in Cushing, Oklahoma be amended to authorize remediation of Acid Sludge Pit 4 (Pit 4). The licensee 1
supplemented its application by letters dated February 5,1998, March 3,1998, and June 29, j 1998. Further, the licensee in its letter dated February 10,1998, and supplemented by letters '
dated May 1,1998, and May 28,1998, requested authorization to place radioactive contaminated materialinto the radioactive material storage area (RMSA). Operation of RMSA is necessary to allow removal of radiologically-contaminated material from Pit 4. This action will facilitate compliance with a Consent Order with the State of Oklahoma, and remediation of Pit 4 for release for unrestricted use, a necessary action for termination of Matorials License SNM-1999.
- 2. BACKGROUND On April 6,1993, the U.S. Nuclear Regulatory Commission (NRC) issued Materials License SNM 1999 to the Kerr-McGee Corporation for its Cushing site. This license authorized the licensee to possess contaminated soil, sludge, sediment, trash, building rubble, and any other contaminated material, at its Cushing site.
There are five acid sludge pits located on the Cushing site. These acid sludge pits contain acidic hydrocarbon sludge from an earlier lubricating oil manufacturing operation. The waste is primarily heavy hydrocarbon containing sulfuric acid (typically 15 to 20 percent). The northwest corner of Pit 4 also contains thorium-contaminated material. The other acid sludge pits do not I contain radiologically contaminated material. In Amendment No. 8, NRC staff is approving remediation of radioactive contamination in Pit 4.
- 3. EVALUATION 3.1 Method to Remediate Pit 4 License Condition 11.B.2 required the licensee to provide a description of the methods that would be used to neutralize acidic contaminated sludge. This information was to be provided before neutralization of this sludge.
9009110145 990903 PDR ADOCK 07003073 C. pon ,
e i 2
The licensee, by letters dated November 26,1997, February 5,1998, March 3,1998, and June 29,1998, submitted a proposed revision to its Cushing Refinery Site Decommissioning Plan (DP) Section 3.3.1, "RMA-3." In this revised section of the DP, the licensee provided the required information for the method that would be used to neutralize acidic contamnated sludge in Pit 4. In addition, the licensee provided proposed radiological criteria for remediation of Pit 4, and descriptions of both the Cushing Radiation Protection and the Quality Assurance programs.
The licensee requested approval of this section of the DP, to allow it to complete remediation of all the site acid sludge pits, including Pit 4, without disruption to the ongoing acid pit remediation effort. The licensee noted that a disruption could cause the possible loss of experienced contract workers before the acid pit remediation effort is completed.
The licensee proposed the following method for remediating Pit 4 based on the experience gained by remediating several of the other site acid sludge pits. The licensee would establish a 50-by-50-foot grid system over the surface of Pit 4, referenced to the site-wide grid system.
Next, a layer of a reagent (agriculturallime) would be placed over each grid block. The acidic sludge in each block would be neutralized to a pH level of approximately five to six by adding and mixing in the reagent to depth. This mixing process would produce a relatively homogeneous material. Next, the licensee plans to screen this material in 18-inch lifts with surface-scans to determine if the material exceeds NRC's Branch Technical Position (BTP)'
Disposal Option 1 (Option 1). The licensee will develop a surface scan reading correlation such that the licensee will be able, with a 95 percent level of confidence, to determine if the average radionuclide concentration of a 18-inch lift exceeds the Option 1 limit. Based on this screening process material found to exceed the Option 1 limit would be transported to the Radioactive Matenal Storage Area (RMSA). Once this materialis in the RMSA, the licensee plans to package this material for transportation to a licensed offsite disposal facility, the Envirocare Low-Level Radioactive Waste Disposal Site in Clive, Utah, for disposal.
The neutralized material from zones 1 and 2 of Pit 4 (the areas of Pit 4 with known radioactive contamination) found to be less than the Option 1 limit, based on the screening process, would be excavated in 18-inch lifts, stabilized by blending in cement kiln dust or similar reagent, and
- transported to the onsite Other Industrial Waste (OlW) disposal cell. The material will be placed in the OlW disposal cell in 8-inch lifts and compacted to approximately 6-inches. For each 6-inch layer the licensee will survey the material by performing surface scans of 100-percent of the area, collecting samples on a five-meter grid, and recording exposure rate measurements at each five-meter grid location. For neutralized material from zone 3 of Pit 4 (the area of Pit 4 not expected to contain radioactive contamination) the licensee will perform the same scanning and sampling of the material as the material from zones 1 and 2, except the surface scans will be approximate 50-percent of the area and samples and exposure rate measurements will be
< collected on a 10-meter grid. If survey and/or sampling results indicate material exceeding the decommissioning criteria, the material will be excavated and transported to the RMSA for offsite disposal.
I Disposal or Onsite Storage of Thorium or Uranium Waste from Past Operations (46 Federal Reaister 52061).
4
3 After the r$eutralized material is removed from Pit 4 the licensee will verify that the residual base j soil of Pit 4 in zones 1 and 2 do not exceed the decommissioning criteria. The licensee will j perform a surface scan of 100-percent of the area, collect samples on a five-meter grid, and perform exposure rate measurements at each five-meter gr d location. If survey or sampling ,
results indicate material exceeding the decommissioning criteria, the material will be excavated I and transported to the RMSA for offsite disposal. l l
The licensee proposes to use criteria and survey methods similar to those prescribed in
" Manual for Conducting Radiological Surveys in Support of License Termination,"
-C NUREG/CR-5649; NRC's BTP; and " Guidelines for Decontamination of Facilities and Equipment Prior e Relese for Unrestricted Use and Termination of Licenses for Byproduct, Source, or Special Nuclear Material," Policy and Guidance Directive 82-23. Therefore, NRC staff finds the licensee's proposed criteria and survey methods acceptable for remediation of I Pit 4. l The licensee has committed to use the site Radiation Safety Plan (RSP)2 for all decommissioning activities. The purpose of the RSP is to define the rules, standards, policies, engineering controls, and general radiological work practices that will be used at the Cushing site, to ensure the safety of both onsite personnel and members of the general public. NRC staff has reviewed the RSP and found that the RSP combined with inspections conducted by NRC staff during remediation activities, should provide reasonable assurance that the public health and safety would be protected during Pit 4 decommissioning activities. The limited approval of the RSP is for Pit 4 decommissioning activities only. The staff will conduct a more comprehensive review of the RSP when the licensee submits its decommissioning plan for the entire site and may modify the RSP based on the performance of the licensee during Pit 4 decommissioning activities. i The license has committed to perform site decommissioning and final survey activities using a combination of the American Society of Mechanical Engineers," Quality Assurance 1 Requirements for Nuclear Facility Applications" (NOA-1) and the American National Standards Institute /American Society for Quality ControlISO 9001 standard. NRC finds these standards acceptable for ensuring an adequate quality assurance program.
l Based on the above, NRC staff approves the proposed program for remediating radioactive contamination in Pit 4.
3.2 Liouid Effluen! Etonitorino Prooram License Condition 11.B.1 authorized construction of the RMSA but prohibited use of the RMSA until the licensee demonstrated that liquid effluent releases would be in compliance with the requirements of 10 CFR Part 20. The licensee in its letter dated February 10,1998, and supplemented by letter dated May 1,1998, requested License Condition 11.B.1 be amended to allow radioactive contaminated material to be placed into the RMSA.
2 Kerr-McGee Corporation Site Radiation Safety Plan, Cushing, Oklahoma, Refinery Site, Revision 2, April 30,1997.
- .J ,
4 The 10 CFR Part 20 liquid effluent release limits are based on a total effective dose equivalent of 50-mrem if the radionuclide were ingested continuously over the course of a year. The licensee's analysis indicates that the actual releases will likely be less than 1-percent of the effluent limits. The licensee has committed to maintain releases such that the annual cumulative average is less than 20 percent of the effluent limits stipulated in Appendix B of 10 CFR Part 20. The Cushing license will be conditioned to reflect this commitment.
The licensee's RMSA liquid effluent monitoring program will consist of a gross alpha analysis of the liquid effluent before and during discharge from the RMSA. Further, the licensee will obtain the results of isotopic analyses of pre-discharge and discharge samples to confirm compliance with release limits.
In addition to the RMSA the licensee plans to construct a Pit 4 stormwater retention pond (retention pond). The purpose of the retention pond is to collect surface water runoff caused by rainstm , events that may occur during the several week period while the licensee will be performhg Pit 4 remediation activities in known or potentially contaminated areas. Therefore, surface water runoff that may contain radiologically contaminated material from a rainstorm event would be collected and monitored prior to release from this area. The licensee plans to use the same liquid effluent monitoring procedures prior to release of liquid from the retention pond as it plans to use for monitoring RMSA liquid effluent releases. Finally, both the RMSA and the retention pond use a common discharge point in Skull Creek.
NRC staff finds that the licensee's proposed liquid monitoring program acceptable.
- 4. STATE CONSULTATION The Oklahoma State official was notified of the proposed issuance of Amendment No. 8. The State official had no comments.
- 5. CONCLUSIONS NRC has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with NRC regulations; and (3) the issuance of Amendment No. 8 will not be inimical to the common defense and security nor to public health and safety.
Principal Contributors: A. Huffert and S. Brown
A_.A a *-h.---.M.,_mJ .J.-,.A,C%84h am 4 A -aa A.mh%e-,J ._sa+_ _.3dse.e_m,mm .m ,-,4.4us__.a _ . _ . .,Aa.a.,.z.a.d4.Agm.p, ,m%w---- -.ww. . . _ - -m.i.,i _ a _.m w k O e I i e
' 4 q O h
E 1
1 d
t t . .
1 d
r r
i I
i d
W d
4 4'I f
d 4 Enclosure 3 2
d, a
T 4
4
~l 1
a 1
1 i
1 4
J 1
b d
4 e i 4
2 i
Y 2
i 4
N i i T
.I
., 1 i
t 1
M e
1 J
f 1
4 t
4 l
4, J
s l
J 9
.i
?
5
,