ML20206P382

Forwards Replacement Pages for 971126 Submittal of Decommissioning Plan for Pit 4 at Cushing Site

ML20206P382
Person / Time
Site:	07003073
Issue date:	03/03/1998
From:	Lux J KERR-MCGEE CORP.
To:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9901110243
Download: ML20206P382 (3)

Text

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KERR-McGEE00RPORAT/0N 8

KEAR McGEE CENTER

• OKLAHOMA CITY, OKLAHOMA 73125 r

March 3,1998.

Mr. Stewart Brown Lcw-Level Waste & Decommissioning Projects Branch

- Division of Waste Management l

Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Commission l

Washington, D. C. 20555 l

Re:

Docket No. 70-3073

/

License No. SNM-1999 l-

Dear Mr. Brown:

i Kerr-McGee Corporation (KMC) submits herein replacement pages for the November 26,1997 l

submittal of a decommissioning plan for Pit 4 at the Cushing site. During recent plannmg l

meetings, an error was noted on Page 8. Point 2 under " Zone 3 Final Survey Activities" stated, L

"Each 6-inch layer of stabilized material from Zones 1 and 2...". Since this section deals with l

material coming from Zone 3, that sentence should have read, "Each 6-inch layer of stabilized l;

material from Zone 3...".

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Previous corrections were submitted to NRC in redline /stnkeout format. Because the revision of this sentence forced repagination of this and the subsequent page, KMC submits two replacement l_

' pages (pages 8 and 9) for the November 26 submittal If you have any questions or comments, please call me at (405) 270-2694.

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Sincerely, Jeff Lux Project Manager xc:

C. L. Cain, NRC Region IV

{

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

Darrell Shults, ODEQ f

41f 9901110243 900303 8

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03/03/98 b'-

l Zone 3 Final Survey Activities L

Stabilized Pit 4 material that is transported to the OlW disposal cell will be final surveyed as detailed below.

1. In the disposal cell the stabilized material will be placed in 8-inch lifts and compacted to approximately 6-inches.

2. Each 6-inch layer of stabilized material from Zence 1 :nd 2 Zone 3 placed in the disposal cell will be surveyed by scanning the area as shown in Figure 3.2, collecting samples on a ten meter grid, and recording exposure i

i rate measurements at each 10-meter grid location. Samples will be l

analyzed by the on-site gamma spectrometer for U-238, U-235, Th-232, i

and Ra-226.. U-234 activity will be calculated based on U-238 and U-235 values.

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3. Additional sampling will be conducted to delineate the area of elevated I

activity if scanning and/or sampling results indicate that material exceeding l

the Option 1 limits is present.

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4. Analytical results from the sampling specified above will be used to i

calculate the average and maximum activity of the survey unit, and the l

area-weighted average activity of areas of elevated activity. A statistical test such as a t-test will be used to demonstrate that criteria have been l

achieved at the 95% confidence level.

5. If survey and/or sampling results indicate that material exceeding the

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criteria specified Section 3.3.1.2 has been placed in the disposal cell, the material will be excavated and transported to the RMSA pending offsite disposal.

6. KMC will afford the NRO an opportunity to perform a confirmatory survey of treated material placed in the OlW cell before the final cap is installed.

l 3.3.1.4 Radiation Protection All decommissioning activities will be monitored by the site health physics department and will comply with the site Radiation Safety Plan (RSP). The RSP addresses both personnel and environmental monitoring to be implemented during decommissioning activities. The RSP has been established to ensure compliance with NRC's radiation exposure limits specified in 10 CFR 20.

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cushing Site Decommissioning Plan Page 8 Revised Pit 4 Submittel

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l 03/03/98 3.3.1.5 Quality Assurance Considerations In 1989, the American Society of Mechanical Engineers published " Quality Assurance Requirements for Nuclear Facility Applications" (NOA-1). This document, i

revised in 1994, sets forth quality assurance requirements for the decommissioning of nuclear facilities. NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination" references NOA-1 as an appropriate quality assurance standard. KMC established a site-specific quality system in accordance with NOA-1.

This quality system is now being modified to comply with the ANSI /ASQC ISO 9001 standard, 'Model for Quality As.surance in Design / Development, Production, installation, and Servicing", which includes all aspects of NQA-1.

Decommissioning and final survey activities will be performed under the Cushing quality system. Table 3.3 lists by category the quality assurance requirements of NQA-1 and the ISO 9001 standard. All are addressed within the Cushing quality system.

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l Cushing site Decommissioning Plan pag, g l

Revised Pit 4 submittal l

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