ML20207B538

Application for Amend to License SNM-1999,proposing Final Rev to Site Decommissioning Plan.Kmc Requests NRC Focus Attention on Sept 1997 Lar.Responses to NRC & DEQ Comments & Decommissioning Plan Are Encl

ML20207B538
Person / Time
Site:	07003073
Issue date:	08/17/1998
From:	Lux J KERR-MCGEE CORP.
To:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20207B544	List: ML20207B538 ML20207B552
References
NUDOCS 9903080159
Download: ML20207B538 (9)

Text

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D.[RR-GACGEE CENTf R e OKLAHOeAA CITY. OKLAHOMA 73125 August 17,1998 Mr. Stewart Brown low-level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Materials Jafety & Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re:

Docket No. 70-3073 License No. SNM-1999 Cushing, Oklahoma Facility

Dear Mr. Brown:

Kerr-McGee Corporation (KMC) submits herein as a license amendment reauest a final revision of the Site Decommissioning Plan for the Cushing, Oklahoma refm' ery site. The Plan was originally submitted in April,1994. The enclosed revision provides a " complete package" including:

1. The original Site Decommissioning Plan, submitted April 1994,

2. KMC's March,1996 responses to NRC comments on the site decommissioning plan, which KMC received in January,1996,

3. KMC's August,1996 commitment to ship all material exceeding decommissioning criteria (Branch Tecimical Position Option 1) to an off site licensed disposal facility,

4. The October,1996 radiological groundwater investigation work plan, endtled Worlwlan. Evaluation ofLicensed Materials Mieration via Groundnoter Pathuavs,

5. KMC's responses to NRC and DEQ comments on the groundwater investigation work plan (comments and responses are provided as an attaclunent to this letter,

6. The Tuilding Demolition Plan submitted March,1997,

7. Several revisions to the demolition phn addressing the Radioactive Materials Storage Area (RMSA) and the decommissicaing of Pit 4, from August 1997 through June 1998.

8. A cost estimate for decommi. sioring in accordance with the enclosed plan, and

9. Financial assurance documentation for the amount of the cost estimate.

In addition, over the past four years, KMC has presented several requests to split the decommissioning plan into two parts to expedite approval of certain aspects of the plan.

According to our understanding, NRC is in the process of providing approval for the operation of a Radioactive Materials Storage Area and the decommissioning of Pit 4. Those aspects of decommissioning have been addressed in this plan. Approval of these aspects of 9903090159 980817

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the enclosed plan will enable KMC to continue operations at the Cushing site without impedance.

The financial assurance package consists of two documents; a Standby Tmst Agreement executed between KMC and Bank One (successor to Liberty Bank), and an increase rider from Safeco Insurance, who provided the surety bond for the original f'mancia' assurance package.

It is KMC's believe that submittal of this decommissioning plan renders the following documents, currently contained in the license docket, no longer relevant to the decommissioning of the site:

1. April 27,1994 (KMC to NRC) Site Decommissioning Plan (SDP)

2. May 24,1994 (KMC to NRC) letter on the SDP

3. May 9,1995 (KMC to NRC) submittal identifying the SDP as a license amendment request

4. August 25,1995 (KMC to NRC) site characteriution report fer on site disposal cell

5. October 20,1995 (NRC to KMC) comments on the site characterization report

6. January 11,1996 (NRC to KMC) comments on the SDP 4

7. Match 29,1996 (KMC to NRC) response to comments on the SDP IN fr. August 22,1996 (KMC to NRC) notice that Op' ion 2 material will be shipped to a i

i k licensed disposal site

9. August 30,1996 (KMC to NRC) request to split the SDP into two parts to expedite approval

10. October 23,1996 (KMC to NRC) radiological groundwater investigation work plan

11. January 29,1997 (NRC to KMC) comments on the radiological groundwater investigation work plan

12. March 14,1997 (KMC to NRC) building demolition plan

13. May 15,1997 (NRC to DEC

quest for comments on the SDP

14. August 21,1997 (KMC to Nri) notes on meeting to address Pit 4 decommissioning plan

15. August 28,1997 (KMC to NRC) revision of section 3.2 of the SDP to clarify criteria

16. September 2,1997 (KMC to NRC) revision of section 3.4.10 of the SDP for Radioactive Materials Storage Area (RMSA)

17. September 27,1997 (KMC to NRC) revision of section 3.3.1 of the SDP

18. October 23,1997 (NRC to KMC) comments on 8/28 and 9/27 submittals

19. November 26,1997 (KMC to NRC) reviseo sections 3.2 (criteria) and 3.3.1 (Pit 4) of the SDP

20. Januay 15,1998 (NRC to KMC) request for radiation safety information for Pit 4 plans

21. Febmag 5,1998 (KMC to 14RC) replacement pages for 11/26 submittal. This document does not supercede the radiation safety plan.

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22. Febmary 10,1998 (KMC to NRC) evaluation of potential effluent release from RMSA

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23. February 26,1998 (KMC to NRC) information on RMSA. This document does not supercede the ALARA analysis submitted with this letter.

24. March 3,1998 (KMC to NRC) replacement pages for section 3.3.1 (Pit 4) of the SDP KMC requests that NRC also focus attention on the September 1997 license amendment request regarding the revision to the license application. However, approval of this decommissioning plan is considered most important by KMC.

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

Sincerely, Jeff Lux Project Manager xc:

C. L. Cain, NRC F..gion IV Rick Reiley, Cushing Citizens' Oversight Conunittee Earlon Shirley, ODEQ Darrell Shults, ODEQ f

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KERR-McGEE CORPORATION RESPONSES TO NRC AND DEQ COMMENTS ON RADIOLOGICAL GROUNDWATER INVESTIGATION l

CUSIIING, OKLAIIOMA REFINERY SITE In October,1996, Kerr-McGee Corporation (KMC) submitted _Workolan. Evaluation of Licensed l

Materials Micration Via Groundwater Pathways to the NRC and the Oklahoma Department of Environmental Quality (DEQ). KMC received NRC's comments on the work plan in January, r

1997, and DEQ's comments in Mech,1997. The following are NRC's and DEQ's comments atul KMC's response to those comments.

NRC Comment 1:

Section 4.3.2.1 RMA-3. Explain how sampling the unsaturated zone soilin RMA-3 willpro ide indication of thorium migration through the saturated zone.

KMC Response:

Section 3.5.3, which discusses sampling at RMA-3, has been modified to clarify that KMC will be investigating the potential for migration out of Pit 4 by sampling groundwater immediately downgradient of the pit. Sampling of unsaturated soil in the depression located downgradient of Pit 4 will be conducted to evaluate whether this feature is anc'her possible source area.

O("M NRC Comment 2:

Section 4.3.2.3 RMA-11. This section does not indicate that a new down-gradient well will be installed in RMA-11. However, Figure 14 shows that a down-gradient wellisproposedfor RMA-11, please clanfy.

KMC Response:

Section 3.5.2, discussing sampling at RMA-11, has been modified to include installation and sampling of one new shallow downgradient well.

NRC Comment 3:

Section 4.4.1.2 SoilLabomforv Analysis. Since enriched uranium can sometimes be contaminated withfission products, the soil samples should also be evaluatedfor beta / gamma emitting radionuclides. Also, Kerr-McGee should conduct distribution coefficient (Kd) testing using the generally accepted ASTM method rather than the Kerr-McGee specific method.

KMC Recponse:

Conversations with NRC personnel have indicated that the stated concern over fission products is related to the discovery of Technetium 99 at other fuel cycle facilities that processed enriched Uranium. Since Technetium 99 is highly soluble, it is inappropriate to analyze source material l

for its presence. Although process infonnation indicates that there is very little likelihood that Cushing ever received material for reprocessing (which could contain Tecimetium 99) KMC is I

willing to address this concern by including Technetium 99 in the list of analytes for the first h

round of groundwater sampling.

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i The text of the work plan has been modified to indicate that Kd testing will be conducted using l

ASTM Method D-4319. Reference to the Kerr-McGee specific method has been eliminated.

l NRC Comment 4:

Section 4.4.2.2 Monitorine WellInstallation. This section indicates that it' has already been I

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determined that groundnoter monitoring wells will be installed in RMA-3, RMA-10, and RMA-l 11, and that the proposed locations are presented in Figure 14. However, Figure 14 does not l

show a proposed well location in RMA-3, please clanfy.

KMC Response:

Section 3.5.5.2 shows there are two areas (RMA-10 and RMA-11) where monitoring wells are needed. Sampling at RMAs 1 through 9, and 12 through 16 also could indicate the need to install i

and sample additional down-gradient monitoring wells.

1 NRC Comment 5:

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&ction 4.4.2.4 Groundwaterisboratory Analysis. Will the of-site laboratory be independent of

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Kerr-McGee Corporation?

KMC Response:

KMC will contract with an independent outside laboratory to perform the radionuclide analyses.

DEQ Comment 1:

Paragraph 4, page 3-4, Section 3.3.1 states: " Consequently, radionuclide measurcments in l

undisturbed of-site "A " horizon surface soil might not be similar to the same measurements in i

the disturbed surface coilin on-site areas. " DEQ requests that KMC submit existing soil sampling analytical dc *a comparing on-site, disturbed background soils with of-site, undisturbed areas to venfy this stanment.

KMC Response:

The existing soil sampling analytical data was previously submitted in the Unaffected Area Report dated April,1995. A reference to that report has been incorporated into the revised discussion of existing analytical data.

DEQ Comment 2:

Paragraphs 3 and 6, page 3-5, Section 3.3.2 state: "Therefore, in background water quality, U-234: U-238 ratios of 4.4 or higher would not be unexpected, and alone, would not suggest the influence oflicensed materials... Ratios outside this range (i.e., ratios > 4.4) might be indications of thepresence oflicensed materials... " The two statements appear contradictory. Please clanfy i

the statements.

KMC Response:

Section 2.4.6.1 states, " Reported U : US ratios range from 0.7:32 in groundwater sampled S

from water supply wells in the United States, with an arithmetic mean of 4.4 and standard deviation of 5.2 (EPA,1985). Therefore, in drinking water, U*i U ratios of 4.4+2 standard S

deviations (or 0 - 14.8) would be expected. Ratios sigmficantly different from this range may be I

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D indications of the presence oflicensed materials, or of uncenainty in the concentration measurements.

DEQ Comment 3:

Paragrqph 1, page 3-6, Section 3.3.2 states: "In Site data, there are grounducter samples where l

thorium exceedr radium in samplesfrom several locations, including presumed background i

locations. " In Figure 3 and 4, allfour background wells (CMW 11.1, 21.1, 22.1, and 24.1) identify thorium concentrations less than radium levels. Please elaborate on the conclusion.

KMC Response:

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There is currently insufficient data to conclusively identify the cause of the observed variability in the concentrations of Radium-228 and Thorium-232 in groundwater. Out of twelve background wells sampled, seven showed concentrations of Radium greater Juin Thorium. The fact that l

elevated thorium was found in so many background sample points indicates that the relative concentrations of Radium-228 and Thorium-232 may not be reliable indicators of potential impacts from licensed materials.

DEQ Comment 4:

Paragraph 3, page 3-6, Section 3.3.2 states: " Wells screened in lesspermeable materials appear

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to have higher radionuclide concentrations, suggesting an association between natural radionuclide occurrence and thefine-grained material... " Please list which wells were utilized in drawing this conclusion.

KMC Response:

This statement is based on examination of the 1994 groundwater analytical results as well as j

boring logs and well constmetion diagrams from the sampled wells. Wells CMW 9.2, CMW j

14.2, CMW 16.3, and CMW 19.1 are predominantly' screened in fine grained materials

'(mudstones and shales) and contained somewhat elevated U-234 and U-238 concentrations relative to the other sampled wells.

DEQ Comment 5:

Paragraph 3, page 3-6, Section 3.3.2 states: "The water in utils in lowpermeability soil stays in il,i wellbore longer, and consequently unter chemistry might be a.Wected by contact with air... "

' Please indicate whether these wells werepurged with a minimum of three well volumesprior to sampling.

KMC Response:

The wells were purged prior to sampling. Section 2.4.6.3 now states " Water in low permeability materials stays in contact with the formation longer than water in more permeable materials. The longer contact time between groundwater and radionuclides in the soil or rock matrix in low permeability materials could contribute to increased leaching of radionuclides".

DEQ Comment 6:

Paragraph 3, page 3-6, Section 3.3.2 states: "Also, unter sampler from wells completed infine-J giained soil are moreprone to contamination byfine suspended soilparticles. " Please indicate

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i whether these well samples werepitered or unfiltered during the sampling event. Also, ifknown,

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please specify the size of thefilter.

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At the direction of the DEQ, unfiltered groundwater samples have been collected and analyzed.

Digestion of even small amounts of suspended solids during analysis can significantly overstate the apparent concentration of dissolved constituents.

l DEQ Comnent 7:

i Paragraph 5, page 3-6, Section 3.3.2, item 2 states: 'There does not appear to be a consistent relationship between welllocation and radionuclide concentrations. " Background concentrations of Uranium-234, 235, and 238 are higher than downgradient levels arou d Pit 4 in the lower Vanoss Group. The statement orprior statements need to be modsped or clanped.

i KMC Response:

The concentration of radionuclides detected in all of the wells around Pit +are extremely low and in the range of expected background values. Monitoring wells CMW-14.2,16.3, and 19.1 (located downgradient of Pit 4) are all screened across intervals dominated by mudstones and shales. The upgradient well(CMW-11.2)is screened in an interval with numerous sandstone stringers. We believe that the observed variation in uranium concentration represents natural geologic conditions. See response to Comment # 4.

i DEQ Comment 8:

Paragraph 4, page 4-5, Section 4.3.2.1, bullet 1 states: "If these wells show reducedpH and/or i

elemted thorium concentrations, then the next sampling step will be taken. " DEQ recommends that uranium as well as thorium concentrations be included in the analyticalprocess and l

emiuation ofRMA-3 (see Comment #7).

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- KMC Response:

During subsequent conversations with DEQ we have reached agreement that since uranium has not been detected in the potential source areas and previously detected concentrations are at or near background, uranium sampling will not be conducted in the investigation of RMA-3.

DEQ Comment 9:

Onpages 4-9 and 4-10, Section 4.4.2.2 discusses monitor wellinstallation and development procedures. DEQ recommends that a stas 1 be included to acknowledge that all wells will conply with Oklahoma Water Raources E wdstandard: (OWRB 785:35/ July 1996)for the drilling, completion, andplugging ofmonitor wells.

KMC Response:

Section 3.5.5.2 states, "Well installation and development will be conducted according to procedures in the SAP and will comply with Oklahoma Water Resources Board standards (OWRB,' 1996) for the drilling, completion, and plugging of monitor wells."

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DEQ Comment 10:

Appendix A records all existing water quality radiation datafrom previous groundwater sampling events at the Cushing site. Please reference which previous KMC document submitted the laboratory analyticaldata sheets.

IGIC Response:

Previous KMC documents have not included laboratory analytical data sheets for radionuclide analyses in previous submittals. Analytical data sheets are, available at the Cushing Site office if desired.

DEQ Comment 11 Table 1 lists existing groundnoter monitoring wells utilized et the Cushing site. Please reference i

the KMC document which illustrates the lithologic log and well completionfor thefollowing wells: CMW 25.1, 26.1, 27.1, 28.1, and 33.1. Also, Table 1 omits CMW 32.1 in the lower Vanoss Group column. This wellis listed in Table 3.

KMC Response:

Lith,,ogic logs and well constmetion diagrams for monitor wells CMW 25.1, CMW 26.1, CMW 27.1, and CMW-28.1 can be found in Volume II, Appendix C (Boring Logs and Monitoring Well Construction Diagrams), of the Phase 1 Remedial Investigation Report dated April 1,1993.

O Monitoring well CMW 33.1 was installed on the far nonhwest portion of the site to provide J

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clarification of the shallow lithology at one location being appraised as a possible site of the Other Industrial Waste cell. The lithologic log and well constmetion diagram have not been published in a report to the DEQ but are available at the Cushing Site office if desired.

Monitoring Well CMW 32.1 has been added to Table 1 as a lower Vanoss well.

DEQ Comment 12:

Table 2 lists sampled well locations and their relationship to any nearby wastepits and RMAs.

The table designates CMW 2.3 as upgradient to Pit 1. Using Figure 2, it is not apparent whether this wellis upgradient to thispit. The southward contour nose around Pit 2 may occur around Pit 1 as well. Ifso, CMW 2.3 could be downgradien: Plea-:e submit detailedpoten'i-tric data substantiating that CMW 2.3 is upgradient or revise the conunent to designate L 22.3 as adjacent to Pit 1.

KMC Response:

Table 2.2 indicates that CMb 2.3 is adjacent to Pit 1.

DEQ Comment 13:

Table 2 designates CMW 14.2 as upgradient to Pit 4. Figure 2 exhibits ths.vell as downgradient. Please revise the table.

KMC Response:

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Table 2.2 shows CMW 14.2 to be downgradient of Pit 4.

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1 Os DEQ Comment 14:

1 Table 3 lists locations used as background wells. CMW-23.1 and 23.2 are designated as l

hydraulically upgradient ofRMAs. Figure 2 discloses that these tne wells are separatedfrom l

RMAs by local discharge to Skull Creek. Please clanfy or revise the table.

t KMC Response:

Table 3.5 indicates that CMW 23.1 and 23.2 are separated from RMAs by local discharge to Skull Creek.

DEQ Comment 15:

Table 3 designates CMW 29.1 as hydraulically upgradient ofRMAs. Please reference any published study which documents Vamoosa-Ada groundnoter movement beneath the Cushing site as west to east or north to south thus venfying the welllocation as upgradient.

KMC Response:

Table 3.5 has been modified to designate CMW 29.1 as vertically separated from RMAs.

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