ML20206P321

Informs That Kerr-McGee Corp Will Commit to Discharge from Rmsa Directly to Skull Creek,Divert Stormwater to Retention Pond & Implement Controls Implemented at Rmsa at Stormwater Retention Pond,Per 980520 Telcon

ML20206P321
Person / Time
Site:	07003073
Issue date:	05/28/1998
From:	Lux J KERR-MCGEE CORP.
To:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9901110198
Download: ML20206P321 (2)

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7 KERR-McGEECORPORATION K ERA-McGEE CENTER

• OKLAHOMA CITY, OKLAHOMA 73t25 May 28,1998 i

Mr. Stewart Brown Low-Level Waste & Dernmmiccioning Projects Branch l

Division of Waste Management N

Office of Nuclear Materials Safety & Safeguards N

U. S. Nuclear Regulatory Comnussion I

Washmgton, D. C. 20555 N,!

Re:

Docket No.' 70-3073 License No. SNM1999

Dear Mr. Brown:

In a May 20* telephone call, NRC provided Kerr-McGee Corporation (KMC) with feedback regarding recent submittals addressing liquid effluent monitoring for the Radioactive Materials Storage Area (RMSA) under construction. NRC believes it is not acceptable for liquid effluent i

from the RMSA to be discharged to the drainage path south of Pit 4. KMC will commit to discharre from the RMSA directiv to Simir Creek.

During the recent inspection by Region IV inspector Louis Carson, the stormwater retention pond that will be constructed near Pit 4 was discussed. Mr. Carson felt NRC ha*2=ters was j

unaware that this pond presents issues similar to the RMSA. 'Ibe pnmary source of water to the

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retention pond is rainwater that falls in the Pit 4 area. Obviously, ponded water makes the waste difficult to process, so KMC niant to divert stormwater to the retention cond.

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L Equipment will be surveyed upon exiting the RMA at the RMA bomvbry. This is the second i

area in which equipment may be decontammated. The first is at the exclusion zone boundary, well within the RMA. Although KMC does not anticipate a need to decontammate equipment or l

vehicles by washing, should this be necessary, a decontamination pad has been constructed at the RMA boundary. Decontammation water containing very low levels of contammation will be l

contained, and then pumped to Pit 4. If this small quantity of water doesn't soak in to Pit 4 material, it may collect with stormwater and be diverted to the stormwater retention pond.

One personal shower is located in the HP and QC trader at the RMA boundary. That shower is for radiological decontamination only, and KMC does not anticipate its use except potentially on rare occasions. This water will be collected and pumped to Pit 4. As with the decon water, if

' this 'small quantity of water doesn't soak in to Pit 4 material, it may collect with stormwater and [g be diverted to, the stormwater retention pond.

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.tsJ0.4 Finally, the QC laboratory measures the pH of untreated and neutralized waste. The small j

quantity of water the QC lab releases will be pumped to Pit 4. It will most likely soak irstA!WIWr j

ground. but, as with decon water, may collect with stormwater and be diverted into th stormwater retention pond.

JUN 011998 l~l Q 11{0 ] yo b 73 Doc Safety & Enwon Cusning i

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The*stormwater retention pond will contain significantly lower concentrations of licensed material than the RMSA for several reasons. First, the RMSA will contain only material near or above o

the Option 1 limit. This material will be removed from Pit 4 within a few weeks of the time it is exposed to rainwater. For the rest of the Pit 4 operation. stormwater will contact only waste with releasable concentrations oflicensed material. Since personnel and equipment will oniy be contactmg background concentrations of material for the vast majority of the Pit 4 work, it is unlikely that decontammation will be required, so essentially no contammated water is anticipated.

KMC submitted a Safety Evaluation Report (SER) demonstrating that the probable quantity of licensed material that could be discharged from the RMSA is less than one percent of the limit.

The potential for accumulation of licensed material in the stormwater retention pond is ' uch less m

than that for the RMSA. The combined quantity oflicensed material expected to be released to the environment is still less than one percent of the limit. Nevertheless, controls imolemented at the RMSA will also be imolemented at the stormwater retention vond. and the efiluent will be analyzed orior to and durine release in the same manner as for the RMSA. These analyses may be reduced based on evaluation of data as the work progresses and as KMC demonstrates that Zone 3 material contains background levels of thorium and uranium.

If you have any questions or comments, please call me at (405) 270-2694.

l Sincerely,

/

Jeff Lux Project Manager xc:

C. L. Cain, NRC Region IV Rick Reiley, Cushing Citizens' Oversight Committee Gene Smith, ODEQ Darrell Shults, ODEQ l

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