ML20206P368

Submits Listed Commitments to Satisfy NRC Concerns Related to Decommissioning of Pit 4

ML20206P368
Person / Time
Site:	07003073
Issue date:	06/29/1998
From:	Lux J KERR-MCGEE CORP.
To:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9901110236
Download: ML20206P368 (2)

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i h XERR-McGEECORPORAHON KERR.McGEE CENTliR e OKLAMOMA CITY, OKLAMOMA 73125 I

June 29,1998

- Mr. Stewart Brown -

Low-level Waste & Decomnussioning' Projects Branch Division of Waste Management Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1

Re:

Docket No. 70-3073 License No. SNM-1999 0

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Dear Mr. Brown:

In discussions regarding the decommissioning of Pit 4, NRC has stated that there are certain aspects of the work for which Kerr-McGee Corporation (KMC) has not provided adequate information to ensure appropriate regulatory and/or administrative control. Those aspects include analysis of film badges and thermolummescent dosimeters (TLDs), VFL Technology's (VFL's) respiratory protection program, and the monitoring of exposure rates surrounding areas j

- where licensed material will be handled during the performance of the work. KMC is willing to make the following commitments to satisfy NRC concerns related to decomnussioning Pit 4.

Eilm Badne and TLD Analysis i

All film badges and TLDs will be analyzed by a laboratory with NVLAP certification, yFL's Respiratory Protection Program NRC posed questions regarding the applicability of 10 CFR 20 Subpart H (NRC) regulations to ihe respiratory protection program implemented during Pit 4 remediation. KMC arrt VFL utilize respiratory protection during the remediation of all acid sludge pits to protect workers from chemical hazards. Respiratory protection will be implemented at Pit 4 for protection from chemical hazards. The Occupational Safety and Health Administration (OSHA) has promulgated regulations governing respiratory protection for such chemical hazards.

Respiratory protection will not be needed for the purpose of protection from radiological intakes.

If the chemical hazard were not present in Pit 4, KMC and VFL would not use respirators during Pit 4 decommissioning.

KMC acknowledges that NRC regulations address other aspects of respiratory protection thtm limiting the intake of licensed material, but these other non-radiological aspc :s are addressed by OSHA regulations. VFL's respiratory protection program complies with OSHA regulations g

governing respiratory protection. KMC will provide information demonstrating that VFL's j

program complies with applicable OSHA regulations at NRC's request.

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9901110236 920629 T PDR-ADOCK 07003073L C-PDR

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i Exposure Rate Monitorine

, NRC has expressed a desire for monitoring of the " radiation profile" of the site as work progresses. KMC is willing to perform periodic exposure rate surveys in the areas surrounding Pit 4, the Radioactive Materials Storage Area, and the disposal cell to monitor the potential spread oflicensed material via small, unnoticed spills, windblown dust, etc. Surveys will most likely consist of micro-R surveys performed on a periodic basis during the handling of Zone 1 and Zone 2 material, and on a less frequent basis during the handling of Zone 3 material. Survey information will be retained on site for NRC inspection.

. KMC is confident that these responses provide adequate assurance that these aspects of the Pit 4 decommissioning work will be performed with adequate regulatory and/or administrative control.

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

Sincerely, eff Lux Project Manager l

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C. L. Cain, NRC Region IV l

Rick Reiley, Cushing Citizens' Oversight Committee Gene Smith, ODEQ l

Darrell Shults, ODEQ t

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