ML20198S289
| ML20198S289 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 02/05/1998 |
| From: | Pounds R KERR-MCGEE CORP. |
| To: | Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20198S292 | List: |
| References | |
| NUDOCS 9901110244 | |
| Download: ML20198S289 (4) | |
Text
.
~..
~
. : u 4-KERR-WGEE CORPOR.QTION RT.4. BOX 2323
- CUSHING. OKLAHOMA 74023 SAFETY & ENVIRONMENTAL AFFAIRS Febmary 5,1998 Mr. Stewart Brown Low-level Waste & Decommissioning Projects Branch Division of Waste Management U. S. Nuclear Regulatory Comnussion Washington, D. C. 20555 Re:
Docket No. 70-3073 License No. SNM-1999
Dear Mr. Brown:
97 Kerr-McGee Corporation (KMC) submits herein replacement pages for the November 26,199fr submittal of Section 3.3.1 of the Site Decommissioning Plan, which concerns the remediation of Pit 4 at the Cushing site. The attached pages address comments received from NRC via teleconference on February 2,1998. Page 4 was revised to strike out references to paved surfaces - there are no paved surfaces associated with Pit 4, the Radioactive Materials Storage Area, or the landfill. Table 3.3 was revised to change " Internal Quality Records" to " Internal Quality Audits" to conform with both the ANSI standard and NQA-1.
Also attached is a copy of KMC's Radiation Safety Plan (RSP), submitted at your request, to enable NRC to evaluate KMC's capability to perform the Pit 4 decommissioning in accordance with NRC's standards for radiation protection. It is understood that license SNM-1999 authorizes changes to the RSP with the review and approval of the Radiation Safety Officer.
Such changes wili be documented. KMC will not make changes to its RSP without NRC approval if those changes allow exposures or releases exceeding limits stipulated in the plan.
If you have any questions or comments, please call me at (405) 270-2694.
Sincerely, obd Robert Pounds Site Manager
-xc:
C. L. Cain, NRC Region IV
)
Rick Reiley, Cushing Citizens' Oversight Committee h
Gene Smith, ODEQ Darrell Shults, ODEQ 9901110244 980205 '3 PDR ADOCK 07003073'
.C.
I 02/02/98 100 m2 area for soil radioactivity, s
100 m2 area for exposure rate on open land, and 100 m' 0r00 for paved cudace radicactivir/.
Area-weighted Radioactivity The average radioactivity concentration in soil must be < (100/A)1/2 times the stated limit, where A is the area of elevated radioactivity in m2 The maximum area for which this applies is 1u0 m2, a
Sudecc radicactivity or a paved cudace cut of decre that ic bettecen enc and e
three t:me: t50 ct !cd ""t ic accept b!c previded tSc arca vicighted average radicactivit/ vi:tNn a 100 m2 crea contcir5g the c!cvated activir/ c !ccc t50n the ctated "mit Maximum Radioactivity The maximum radioactivity in soil at any location may not exceed three times the stated limit above background.
The maximum exposure rate at any location indoors or out-of-doors may not exceed two times the stated limit above background.
For the purposes of this plan the Option 1 limit refers to the sum of the fraction result for an individual sample. The term criteria refe.rs to the area weighted result of a group of samples.
3.3.1.3 Pit 4 Decommissionina Activities Experience treating acidic hydrocarbon sludge in similar pits has shown that excavation without prior neutralization, generates sulfur dioxide emissions that exceed National Ambient Air Quality Standards at the property line. In addition, the sludge is very carrosive to equipment and dangerous to workers if not first neutralized.
Therefore, the sulfuric acid contained in the acidic hydrocarbon sludge requires neutralization prior to excavation.
Neutralized material that contains radionuclides in excess of Option 1 limits will be identified while still in Pit 4, excavated, and transported to a specially constructed radioactive materials storage area (section 3.4.4) for temporary storage prior to offsite dispcsal. Neutralized material that contains radionuclides in concentrations below the Option 1 limit will be excavated, treated and disposed of in accordance with a remediation plan approved by the Oklahoma Department of Environmental Quality Cushing site Decommissioning Plan Page 4 Revised Pit 4 Submittal
j j --
02/02/98 5
Table ?.3 Quality System Requirements Requirement ANSI Standard NQA-1 Basic Requirement Organization / Management Responsibility Section 4.1 1
Quality System /Ouality Assurance Program Section 4.2 2
Instructions, Procedures, and Drawings Section 4.2 & 4.3 5
Contract Review Section 4.3 Design Control Section 4.4 3
Document and Data Control Section 4.5 6
Purchasing / Procurement Document Control Section 4.6 4&7 Product identification and Traceability Section 4.8 8
Process Control Section 4.9 9
Inspection and Testing Section 4.10 10 & 11 Control of Inspection, Testing, and Measuring Equipment Section 4.11 12 Inspection and Test Status Section 4.12 14 Control of Nonconforming Product Section 4.13 15 Corrective and Preventative Action Section 4.14 16 Handling Storage Packaging, Preservation & Delivery Section 4.15 13 Control of Quality Records Stion 4.16 17 Intemal Quality Recor41e Audits Section 4.17 18 Training Section 4.18 2
Servicing Section 4.19 Statistical Techniques Section 4.20 Cushing S$e Decomrrussioning Plan -
Page 10 Revited Pit 4 Submittal t
e l.
t
+
I'hb KERRMcGEE CORPORAil0N s
RT. 4. BOX 2323 = CUSHING. OKLAHOMA 7C i SAFETY & ENVIRONMENTAL AFFAIRS Uncontrolled Document Acknowledgment of Receipt 1
To:
Stewart Brown From:
Terrie Ostmeyer i cy.,. 4 C -
'\\
Date:
Febmary 5,1998 Sabject:
Cushing Radiation Safety Plan Acknowledge receipt of the attachui Safety Plan by signing and returning this form to me at the address below.
If you have any questions, please call me at (918)225-7753.
j Acknowledgment:
Date:
This document is uncontrolled document cia controlled document.
Kerr-McGee Cushing Facility Attn: Document Control 2 Miles North of Hwy. 33 on Hwy.18 - % Mile East Route 4, Box 2323 Cushing, OK 74023 DO NOT DUPLICATE WITHOUT PERAUSSION!
cc: File l
l 1
!