ML20198R567

Responds to 970828 & 0927 Ltrs Requesting Approval of Revised Section 3.2 & 3.3.1 of Cushing Decommissioning Plan & Provides Comments

ML20198R567
Person / Time
Site:	07003073
Issue date:	10/23/1997
From:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Lux J KERR-MCGEE CORP.
References
NUDOCS 9711130318
Download: ML20198R567 (5)

Text

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Mr. Jeff Lux October 23, 1997

, Project M: nager I ' 'f ,

Kerr McGee Corpor; tion i Kerr-McGee Centar P.O. Box 25861 Oklaho'ma City, OK 73125

Dear Mr. Lux:

This is in response to your letters dated August 28 and September 27,1997, requesting approval of ravised Section 3.2, Radiological Criteria for Decommissioning; and Section 3.3.1, RMA 3, of the Cushing Decommissioning Plan (DPlan), respectively. The staff has reviewed these requests and has the fc! lowing comments.

1. Review of Section 3.2 will be performed in the context of the complete DPlan review rnd not as part of a specific Pit 4 review. Therefore, if Kerr-McGee believes that approval of these criteria are needed in order to remediate Pit 4, Kerr-McGee should submit the specific criteria as part of a Section 3.3.1 revised submittal.

2. Requests for approval of portions of the DPlan, such as Section 3.3.1, should be in the form of a license amendment request. Kerr-McGee should submit a request to amend its license.

3. Provide or reference programs under which Pit 4 will be remediated that ensure public health and safety, such as a Radiation Protection and Quality Assurance Programs.

4. Additionalinformation is needed before the review of Section 3.3.1 can be completed.

The staff's comments are enclosed.

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

Sincerely,

[0riginalsignedby]

Stewart W. Brown, Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No.: 73-3073 License No.: SNM 1999

Enclosure:

As stated pfD n rn ~ -

cc w/encls.: Kerr-McGee, Cuching dist. list CD Ui E' UN-, P @77 IICKET NO JllDP;71717 DISTRIBUTION:

Central file LLDP r/f NMSS r/f RJohnson PUBLIC M L l] fli DOCUMENT NAME:s:\dwm\lldp\swb\cush.rdt OFC LLDP M LLDP RIV LLDP f LLDP b NAME 58ro[h W DFauver La y /4s Qo 4

n JH key 10/2797 10f/S07 10ntJ97 10/2f/97 JTE 10/J3497 OfflCIAL RECORD COPY ACNW: YES _ NO .1 l IG YES _ NO _ Delete file after distribution: Yes _ No ,__ l YES __. NO _

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I Mr. J;ff Lux October 23, 1997

. Pro lcct Manager j

• Kerr McGee Corporation Kerr McGee Center -

P.O. Box 25861 -

' Oklahoma City, OK 73125

Dear Mr. Lux:

This is in response to your letters dated August 28 ar'd September 27,1997, requesting approval of revised Section 3.2, Radiological Criteria for Decommissioning; and Section 3.3.1, RMA 3, of the Cushing Decommissioning Plan (DPlan), respectively, The staff has reviewed these requests and has the followir.g comments:

1. Review of Section 3.2 will be performed in the context of the complete DPlan review and not as part of a specific Pit 4 review. Therefore, if Kerr-McGee believes that approval of these criteria are needed in order to remediate Pit 4, Kerr-McGee should submit the specific criteria as part of a Section 3.3.1 revised submittal.

2. Requests for approval of portions of the DPlan, such as Section 3.3.1, should be in the form of a license amendment request. Kerr-McGee should submit a request to amend its license.

3. ProviJe or reference programs under which Pit 4 will be remediated that ensure public health and safety, such as a Radiation Protection and Quakty Assurance Programs. ,

4. Additionalinformation is needed before the review of Section 3.3.1 can be completed.

The staff's comments are enclosed.

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

Sincerely.

[0riginalsignedby]

Stewart W. Brown, Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No.: 70-3073 License No.: SNM-1999

Enclosure:

As stated cc w/encls.: Kerr-McGee, Cushing dist. list TICKET NO. LLDP-7171 DISTRIBUTION:

Central F;1e LLDP r/f NMSS r/f RJohnson PUBLIC DOCUMENT NAME:s:\dwm\1ldp\swb\cush.re OFC LLDP M LLDP RIV LLDP / LLDP II NAME SBro DFauver L a 50 g /4a T n JH key v

DATE 10/JA 97 10/2197 107S97 10n L/97 10/8/97 0FFICIAL RECORD COPY

'ACNW: YES _ NO L IG YES _ NO _ Delete file afte* distributton: Yes _ No _

LS5 YES _ NO _

__ _ _ . _ _. .~ _ .

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• cuq ** ,1 y *- k UNITED STATES '

j [ NUCLEAR REGULATORY COMMISSION '

WASHINGTON, D.c. 20 5 % 4001 o f

%*...+/ October 23.-1997 Mr. Jeff Lux'-

Project Manager ,

Kerr-McGee Corporation Kerr McGee Center .

P.O. Box 25861 l Oklahoma City, OK 73125

Dear Mr. Lux:

i This is in response to your letters dated August 28,1997, and September 27,1997, requesting f

approval of revised Section 3.2, Radiological Criteria for Decommissioning, and Section 3.3.1, RMA-3, of the Cushing Decommissior,ing Plan (DPlan), respectively. The staff has reviewed these requests and has the following comments:

1. Review of Section 3.2 will be performed in the context of the complete DPlan review and not as part of a specific Pit 4 review. Therefore, if Kerr McGee believes that approval of these criteria are needed ;n order to remediate Pit 4. Kerr-McGee should submit the specific criteria as part of a Section 3.3.1 revised submittal.

2. Requests for approval of portions of the DPlan, such as SectLn 3.3.1, should be in the form of a license amendment request. Kerr McGee should submit a request to amend its license.

3. Provide or reference programs under which Pit 4 will be remediated that ensure public health and safety, such as s Radiation Protection and Quality Assurance Programs.

4. Additionalinformation is needed before the review of Section 3.3.1 can be completed.

The staffs comments are enclosed.

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

Sincerely,

)/g;Y nrrz- -

Stew:nt W. Brown, Pruject Manager Low Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards

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

Enclosure:

As stated cc w/encts.: Kerr-McGee, Cushir, dist. list

'cc: Kerr-McGee Corporation, Cushing Plant - Letter dated October 23, 1997 Docket No. 70 3073, License No. SNM-1999 Mr. Jess Larsen Project Leader Kerr-McGee Corporation Kerr-McGee Center P.O. Box 25861 Oklahoma City, OK 73125 Ellis W. Merschoff USNPC, Region IV Louis C. Carson USNRC, Region IV Charles Cain USNRC, Region IV Michael Broderick Oklahoma Department of Environmental Quality 1000 NE 10th Street Oklahoma City, OK 73117-1212 Oklahoi:1a State Department of Labor 4001 N. Lincoln Boulevard Oklahoma City. OK 73117-1212 Richard Reiley Chairman, Citizen's Kerr-McGee Oversight Committee c/o Cushing Public Library P.O. Box 551 Cushing, OK 74023

f-NRC Comments Related to Kerr McGee's Letter Dated September 27,1997, Requesting .

Approval of Revised Section 3.3.1, RMA 3, of the Cushing Decommission Plan

1. Describe the procedures and QA/QC program that will ensure the Pit 4 remediation plan is implemented as wntten, and that reported data is of suffi: lent quality and validated.

2. - Zones 1 and 2 Decommissioning Activities, item 8 - Expand the discussion of this section to address the following: (1) uranium contamination, (2) exposure rate measurements, (3) samples to be taken at elevated scan points, and (4) action levels for sampling from elevated scan points.

3. Zones _1 and 2 Decommissioning Activities, item 10 - Will there be scan surveys of Pit 4 excavated surfaces once. the radioactive matenal has been?

4. Zones 1 and 2 Decornmissioning Activities - Descnba the statistical treatment that will he applied to the data obtained from these areas.

S. Zone 3 Decommissioning Activities - Describe the statistical treatment that will be applied to the data obtained from this area.

6. " Field Action Levels"-Include an action level for uranium.

7. Provide the final compliance criteria for the on-site cell.

Enclosure