ML20206J068

Forwards RAI in Order to Complete Review of Licensee 980817 Submittal of Revised Plan for Remediation of Cushing Refinery Site.Response Requested within 30 Days of Ltr Date

ML20206J068
Person / Time
Site:	07003073
Issue date:	05/06/1999
From:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Lux J KERR-MCGEE CORP.
References
NUDOCS 9905120103
Download: ML20206J068 (9)

Text

.. .

May 6, 1999

. Mr. Jeff Lux Kerr-McGee Corporation Kerr-McGee Center P.O. Box 25861 j

Oklahoma City, OK 73125 Dear Mr. Lux.

j l

By your letter dated August 17,1998, you submitted a revised plan for the remediation of the l Cushing Refinery site. We have reviewed your plan and find that additional information is i needed before we can complete our review. Our request for additionalinformation (RAI)is I enclosed. To ensure a determination can be made prior to the August 20,1999. date, in 10 CFR 20.1401 to be eligible to use the Site Decommissioning Management Plan Action Plan criteria, you are requested to provide your response to our RAI within 30 calendar days from a

the date of this letter.

Should you have any questions, please do not hesitate to contact me, at (301) 415-6605.

Sincerely,

. [ Original signed by:]

Stewart W. Brown, Project Manager Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards ,

i Docket No. 70-3073 l License No. SNM-1999

Enclosure:

As stated 1

cc w/encls: Kerr-McGee, Cushing distribution list TICKET: n/a DISTRIBUTION: Central File DCB r/f NMSS r/f RJohnson PUBLIC DOCUMENT NAME: S:\DWM\LLDP\SWB\QS.WPD *see previous concurrence.

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LSS: YES__ N O _ X_. L ACNW: YES_._ NO _X_

IG: YES___ NO_X_ Delete file after distribution YES ___ NO __._ I 1

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, Mr. Jeff Lux Kerr-McGee Corporation Kerr-McGee Center P.O. Box 25861 i Oklahoma City, OK 73125

Dear Mr. Lux:

l By your letter dated August 17,1998, you submitted a revised plan for the remediation f the

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Cushing Refinery site. We have reviewed your plan and find that additionalinformati n is needed before we can complete our review. Our request for additionalinformation Al) is enclosed. To ensure a determination can be made prior to the August 20,1999, te in 10 CFR 20.1401 to be eligible to use the Site Decommissioning Management P n Action Plan l

criteria, you are requested to provide your response to our RAI within 30 cale er days from I the date of this letter.

Should you have any questions, please do not hesitate to contact me, at '301) 415-6605. 1 Sincerely, 1

[ Original sig d by:]

Stewart W. rown, Project Manger Low-Level nd Decommissioning Project Branch j Divisio of Waste Management i Offic of Nuclear Material Safety i A Safeguards  !

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

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Enclosure:

Request for AdditionalInformation f

cc w/encis: Kerr-McGee, Cushing distributi n list l TICKET: n/a l I

DISTRIBUTION: Central File CB r/f NMSS r/f RJohnson PUBLIC DOCUMENT NAME: S:\DWM\LL \SBLB)OS.WPD *See previo.us concurrence.

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, DCB o // DCB NAME SBro [Mf! PS go 8 TCJohn on JHickey DATE 05/04 /99  ! 05/04/99 05/ ( /99 05/ /99 FICIAL RECORD COPY '

LSS: YES___ _X_

ACNW: YES / NO _X_

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1

, . Mr. Jeff Lux l Kerr-McGee. Corporation l

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

Dear Mr. Lux:

By your letter dated August 17,1998, you submitted a revised Ian for e remediation of the Cushing Refinery site. We have reviewed your plan and fin hat ad tionalinformation is needed before we can complete our review. Our request r addit' nalinformation (RAI) is '

enclosed. You are requested to provide your response our R within 30 calender days from .

the date of this letter. I Should you have any questions, please do not hes' ate to ontact me, at (301) 415-6605. j I

Si . cerely,

{

[ Original signed by:] i Stewart W. Brown, Project Manger  !

Low-Level and Decommissioning Projects Branch Division of Waste Management

.,/ Office of Nuclear Material Safety )

And Safeguards  ;

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

Enclosure:

Request for Ad itionaI'Information

/

cc w/encis: Kerr-McGee/ ,C uyh'ing distribution list TICKET: n/a

/

/ /

/

DISTRIBUTION: I,'entral File

/ j DCB r/f NMSS r/f RJohnson PUBLIC l

/ / i DOCUMENT NAME: St\DWM\LLDP\SWB\OS.WPD OFC DCB  ! DA F h s DCB DCB j NAME SBro ' TCJohnson JHickey DATE 05/ 05/ [ /99 05/ /99 05/ /99

/ j OFFICIAL RECORD COPY l /

LSS/ YES _ NO_X_

ACNW: 'YES __ NO _X_

IGi YES_._ NO_X_ Delete file after distribution YES ___. NO __

l l

l

4 +

i NRC's Request for Additional Information Related to Kerr-McGee's

' Cushing Refinery Site Decommissioning Plan Dated August 1998 The following represents areas where we need additional information in order for us to complete our review of your Cushing Refinery Site Decommissioning Plan.

General

1. Provide the schedule of planned decommissioning activities. If the time-line to complete decommissioning of the Cushing site is greater than 24-months from the date NRC approves the site decommissioning plan, provide justification for the delay in accordance with the requirements of 10 CFR 70.38(g)(4)(vii).

2. Provide a dose estimate (TEDE) for a member of the public (which includes non-radiation workers, truck drivers, and rail workers) that will result from the Cushing site remediation effort, including packing and transporting the greater than Option 1 radioactive waste to an offsite licensed disposal facility. Also, provide a dose estimate l TEDE for a radiation worker involved in tne Cushing site remediation effort. Finally, l provide a description of the worst-case postulated radiological accident scenario that could occur as a result of remediation activities. Transportation accidents should be included as part of the accident scenarios considered in this evaluation. This description i should be included in the estimated potential consequences (TEDE) of that postulated worst-case accident both site radiation workers and members of the public.

3. Provide a description of the physical security measures used to prevent the general

! public from intruding into either radiation areas and/or radioactive materials areas.

l 4. We recognize that situations could occur during the performance of a project that could l require certain changes to an approved decommissioning plan. Therefore, we would

! consider a license condition that would allow you to make certain changes to either the l approved decommissioning plan or procedures without our review or approval. If you want this type of f;exibility while remediating the Cushing site, provide a proposed l change process and license condition, including organizational oversight of this change process.

5. Provide a description of the specific method (s) that will be used to transport packaged radioactive waste greater than Option 1 for shipment from the Cushing site to a licensed offsite disposal facility. Provide the name and location of the licensed offsite disposal facility that Cushing radioactive waste will be shipped. Provide an estimate of the number of truck or rail car shipments that will be required to ship the Cushing waste to l the offsite licensed disposal facility. Provide the approximate o..e-way distance that will be traveled by either truck and/or rail.

ENCLOSURE

qQ REgy 4 -

pe t UNITED STATES g

't j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.c. 20555 <o01

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• • • • • May 6, 1999 Mr. Jeff Lux l

Kerr-McGee Corporation Kerr-McGee Center '

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

Dear Mr. Lux:

l By your letter dated August 17,1998, you submitted a revised plan for the remediation of the Cushing Refinery site. We have reviewed your plan and find that additional information is needed before we can complete our review. Our request for additionalinformation (RAl)is l enclosed. To ensure a determination can be made prior to the August 20,1999, date,in l

10 CFR 20.1401 to be eligible to use the Site Decommissioning Management Plan Action Plan criteria, you are requested to provide your response to our RAI within 30 calendar days from the date of this letter.

! Should you have any questions, please do not hesitate to contact me, at (301) 415-6605.

~

Sincerely, ,

l f W - ~

.a Stewart W. Brown, Project Manager Decommissioning Branch l Division of Waste Management ,

l Office of Nuclear Material Safety I and Safeguards Docket No. 70-3073 l License No. SNM-1999 l

Enclosure:

As stated cc w/encls: Kerr-McGee, Cushing distribution list

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, . If these buildinga or structures were not surveyed in accordance with this guidance, provide basis for not performing these surveys. Justify cutting structured steel building members before surveying them, as proposed during demolition of both Buildings 30

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and A6. Justification should include a discussion why you cannot survey these building j members before cutting and is this proposal considered ALARA? Confirm that the slab l

sectioning process will result in slab sections of sufficient size to allow surface surveying. Also, provide basis for not surveying the Building 30 first floor slab before l

sectioning the slab. Finally, clarify if the SNM Storage Building is part of Building 30 for decommissioning purposes. Noted in Section 2.3.4.3, there are still areas that need to i be cleaned to the unrestricted release limit. Yet the SNM Storage Building is not '

discussed in Section 3.3.5, Site Buildings. Was any radioactive material used or stored in Building 317 What buildings havp radioactive materials stored in them now?

i

7. Section 3.3.9 - In this section you provided a discussion of the proposed process that i will be used to remediate buried rubble. Provide location (s) where potentially radioactive contaminated rubble is buried, {

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8. Section 3.4.2 - NRC does not allow dilution of rcidioactive materialin lieu of decommissioning areas which do not meet clean-up criteria. Note that NUREG/CR-5849, Section 8.5.3 recommends that if the exposure rate exceeds two  :

times the guideline value, the area should be remediated and resurveyed. Also, provide a description of the methods that will be used to excavate and transport radioactive contaminated waste that will minimize the potential for spreading contamination.

9. Section 4,1.1 - Describe the audit performed by the independent corporate-based Environmental, Health, and Safety function. Also, prov;de the qualification of the people performing this audit, is the pJrpose of this audit compliance with10 CFR Part 20?

Also, provide a description of what actions would De taken by the Quality Assurance (QA) Coordinator if program deficiencies are found to exist.

10. Section 4.1.4 - Provide a statement that the RSO has authority and responsibilities to i stop ongoing work activities, should he or his staff observe, radiologically unsafe work l practices. Also, revise Figure 4.1 to show the RSO. The RSO should report to an i organizational manager at a level that will ensure independent safety reviews are I conducted.

11. Section 5.1.2 - Provide the basis for concluding that radioactivity is chemically fixeo within various matrices and is considered insoluble. Have any tests been conducted to demonstrate that the materials are insoluble? lf so, provide the results. For urine and ,

non-routine bioassay samples what laboratory will be used for bioassaying work? What j is the sample collection procedure recommended by the certified laboratory analyzing the samples? Is the recommended sample collection frequency monthly? Do you have I collection procedures? Is there a baseline analysis conducted for each individual before  ;

working in airborne activity areas? See, Regulatory Guide 8.9. Also, describe the I criteria for determining air sampling monitoring locations for monitoring worker intake i and airborne effluent around areas when decommissioning activities are in progress. l Also, confirm air sampling follows NUREG-1400 recommendations and Regulatory ,