ML20210Q895

Environ Assessment & Finding of No Significant Impact Re Amend 10 to License SNM-1999 for Kerr Mcgee Corp Cushing Refinery Site

ML20210Q895
Person / Time
Site:	07003073
Issue date:	08/10/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20210Q886	List: ML20210Q881 ML20210Q895
References
NUDOCS 9908160149
Download: ML20210Q895 (16)

Text

E )

!( ..-(,*-

N:- p2 nt; p & UNITED STATES l g- j- NUCLEAR REGULATORY COMMISSION e- WASHINGTON, D.C. 20066-0001

?%> . . . . . ho r

i l THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS ENVIRONMENTAL ASSESSMENT. AND FINDING OF NO SIGNIFICANT IMPACT l: RELATED TO AMENDMENT NO.10 TO MATERIAL LICENSE NO. SNM-1999 q L - KERR-McGEE CORPORATION j CUSHING REFINERY SITE I DOCKET NO. 70-3073 i

j

1. INTRODUCTION l )

1.I' Backaround I

' The U. S. Nuclear Regulatory Commission (NRC) is considering the Kerr-McGee Corporation's (hereafter Kerr-McGee's'or the licensee's) request to approve the Cushing, Oklahoma, Refinery

' Site Decommissioning Plan. Kerr-McGee has environmental responsibility for a former refinery I site near the city of Cushing, Oklahoma.

l

! The refinery opened around 1912 and was purchased by Kerr-McGee in 1956. During the early 1960s, in addition to petroleum processing, Kerr-McGee processed uranium fuel and thorium

- metal in several buildings onsite under licenses issued by the Atomic Energy Commission (AEC). The uranium fuel and thorium processing area was decommissioned, the property and facilities were released for unrestricted use, and the license was terminated by the AEC. Kerr -

McGee continued to operate the refinery until 1972, at which time it was torn down. In May 1990, Kerr-McGee entered into a Consent Order' with the Oklahoma State Department of Health

- [now referred to as the State of Oklahoma, Department of Environmental Quality (DEQ)],

. addressing the investigation and remediation 'of the Cushing refinery site. The DEQ Consent Order divided the site work into radiological and non-radiological remediation efforts. The non-radiological remediation is being performed in a manner similar to the Federal Superfund Remedial Investigation / Feasibility Study process.

On April 6,' 1993, NRC issued Materials License SNM-1999 to the Kerr-McGee Corporation, for

- its Cushing site. This license authorized the licensee to possess radioactive contaminated soil, sludge, sediment, trash, building rubble, and any other contaminated material, at its Cushing site.

Title 10 of the U.S. Code of Federal Regulations'(10 CFR) 70.38 required the licensee to submit

a decommissioning plan for the Cushing site. Kerr-McGee, in its letter dated April 27,1994, submitted the required decommissioning plan for the Cushing site.

' ' Oklahoma versus Kerr-McGee Corporation, No. C-90-91-H (District Court of Payne County, Oklahoma, May 4,1990)(Consent Order).

9908160149 990810

+ PDR ADOCK 07003073 C PDR

p 1

Ikerr-McGee, in its letter dated November 26,1997, and supplemented by letters dated February 5,1998, March 3,1998, and June 29,1998, requested approval of part of the Site Deconunissioning Plan related to remediation of Acid Sludge Pit 4. Further, Kerr-McGee, in its letter dated February 10,1998, and supplemented by letters dated May 1,1998, and May 28, 1998, requested authorization to place radioactive contaminated material into the Radioactive Material Storage Area (RMSA). On September 3,1998, the staffissued License Amendment No. 8 to Materials License No. SNM-1999, which authorized both remediation of Acid Sludge Pit 4 and use of the RMSA.

Kerr-McGee, by letter dated August 17,,1998, submitted a revised Cushing site decommissioning plan. The licensee supplemented its plan by letters dated June 4, June 15, June 18, and July 29,1999.

1.2 Proposed Action This Environmental Assessment concerns the final remediation of the Cushing Refinery site.

The purpose of this decommissioning is to remove radioactive contamination to levels such that the site can be released for unrestricted use.

Kerr-McGee has performed a radiological characterization survey of the site. Those areas found to contain radioactive contamination were designated as radioactive material areas (RMAs). In this action Kerr-McGee is proposing to collect the radioactive contaminated material that exceeds NRC's Branch Technical Position (BTP)2 Disposal Option 1 (hereafter Option 1);

package this material; and ship this material to the Envirocare Low-Level Radioactive Waste Disposal Site in Clive, Utah, for disposal. The licensee will perform a final survey of the site to determine if the site has been remediated in accordance with the approved Cushing site decommissionieg plan and if the criteria for unrestricted release of the site have been achieved.

The results of this final site survey will be submitted to the NRC for its review. Based on the results provided in this final survey report and NRC confirmatory survey findings, NRC will terminate Materials License SNM-1999.

1.3 Need for Action The proposed action is necessary to remove the contamination that exists at the Cushing Refinery site. This action will facilitate remediation of this site to a condition suitable for unrestricted release and is one of the actions necessary for termination of Kerr-McGee's Cushing site Materials License SNM-1999.

l 2 " Disposal or Onsite Storage of Thorium or Uranium Waste from Past Operations" (46 Federal Recister 52061, October 23,1981), i

)

h u

,. . . . ' !,7-

2. - DESCRIPTION OF CUSHING SITE AND PROPOSED ACTIONS

' 2.1 General Site Description The Cushing Refinery site is comprised of 1.78 square kilometers'(km 2) (440 acres) in Payne County, Oklahoma.' The site is located 3.22 kilometers (km) (2 miles) north of the City of Cushing. The City of Cushing is located about midway between Tulsa and Oklahoma City on Highway 33. The Cushing site terrain is rolling pasture land. The elevation of the site ranges from 250 meters (m) (820 feet) to 280 m (920 feet) above mean sea level (MSL). Skull Creek

( runs through the Cushing site beforejoining the Cimarron River 6.44 km (4 miles) east-northeast -

l. of the site at an elevation of 232 m (760 feet) MSL.

L 1 .

L . 2.2 ' Site Operatine History i The Cushing site was operated as a refinery from approximately 1915 to 1972, when the refinery L was closed and dismantled. The licensee operated the refinery site from 1956 to 1972. The l . licensee also processed nuclear fuel material at the Cushing site from 1963 to 1966, under two AEC licenses.L AEC Source Material License SMB-664 authorized Kerr-McGee to possess unlimited quantities of natural uranium, depleted uranium, and thorium. AEC Special Nuclear Material License SNM-695 authorized Kerr-McGee to possess any enrichment of uranium, but l

limited it to 1,000 kilograms (2,205 pounds) of uranium-235. Kerr-McGee received, possessed, and processed these materials for the AEC. Both AEC licenses were terminated in 1966.

l 2.3' Current Radiolonical Coniitions ,

The licensee has identified 16 areas within which levels of radioactive contamination exist that may require decommissioning. The licensee's term for such an area is RMA. In addition to the

- 16 RMAs there are several other areas that may contain radioactive material which may

require decommissioning.

2.3.1 RMAs 1,4,6,7,9, and 12'through 16 (Small RMAs)

The licensee has determined, based on its characterization of the site, that these areas are contaminated with thorium that does not extend more than a fraction of a meter (several inches)

' below the ground surface. The licensee estimates that the concentration of thorium in these areas is about 0.74 Becquerel per gram (Bq/g) [20 picoCuries per gram (pCi/g)). The licensee plans to

. remove material that exceeds proposed release criteria. This material will either be packaged and  ;

shipped for offsite disposal directly from the RMA or transferred to the RMSA for subsequent l packaging and shipping for offsite ' disposal. The licensee will then perform a final survey of the remediated RMA.

l I

!l 4

, i

?

r. 1 t

2.3.2 RMAs 2,5, and 8 (Refinery Tank Benns)

The licensee has determined, based on its characterization of the site, that these tank bemt areas that contain tar-like layers of petroleum sludge are contaminated with thorium. The petroleum sludge is generally present at or near the ground surface in layers that range from less than 0.0254 m (1 inch) to approximately 0.61 m (2 feet) in thickness. The licensee has determined that the soil underlying the petroleum sludge does not contain thorium above background levels.

Also, the thorium is confined to the petroleum sludge and has not migrated to the surrounding material. The licensee estimates that concentrations of thorium in the petroleum sludge range between 0.37 and 1.11 Bq/g (10 and 30 pCi/g). The licensee plans to remove material that '

exceeds proposed release criteria. This material will be packaged and shipped for offsite disposal directly from the RMA or transferred to the RMSA for treatment and subsequent packaging and shipping for offsite disposal. The licensee will then perform a final survey of the remediated RMA. l l

2.3.3 RMA 3 (Acid Sludge Pit 4)

Acid Sludge Pit 4 is one of five acid sludge pits located on the Cushing site. However, Acid Sludge Pit 4 is the only one of the acid sludge pits that is radiologically contaminated with thorium. The licensee, by letter dated November 26,1997, requested NRC to amend the Cushing license to authorize remediation of Acid Sludge Pit 4. The licensee made this request to facilitate compliance with a Consent Order with the State of Oklahoma requiring remediation of five site acid sludge pits. On September 3,1998, the staffissued License Amendment No. 8 to Materials 1.icense No. SNM-1999, which authorized lyth remediation of Acid Sludge Pit 4 and use of the RMSA.

I 2.3.4 RMA 10 (Former Process Building Site)

There were three ditches between the process building and Skull Creek. Two of the ditches were dug during excavation of pipes leading from the buildings. The third ditch was a concrete-lined drainage ditch that extended from the southwest end of Building 31 to Skull Creek. It is possible that this area may still be contaminated. The licensee estimates that the concentrations of thorium in this area are about 1.11 Bq/g (30 pCi/g) and concentration of uranium are about 5.9 Bq/g (160 pCi/g). The licensee plans to perform additional soil b3 ring to better define the lateral boundaries and depth of the potential radioactive contamination. If radioactive contamination is found that exceeds the proposed release criteria, the licensee plans to remove that material. This material will either be packaged and shipped for offsite disposal directly from the RMA or transferred to the RMSA for subsequent packaging and shipping for offsite disposal.

The licensee will then perform a final survey of the remediated RMA.

r *

' 2.3.5 RMA 11 (Trash Dump)

' This RMA was a trash disposal area that was used to dispose of trash, refinery wastes, and some i licensed material. The licensee proposes'to perform soil boring on a 5-by-5 m (16.4-by-16.4 ft) l grid pattern. If the soil-like material contains licensed material above background limits, the L entire volume (including brick, steel, and other material) will be considered to exceed the L decommissioning criteria, and be excavated. This material will either be packaged and shipped L

for offsite disposal directly from the RMA or transferred to the RMSA for subsequent packaging and shipping for offsite disposal. The licensee will then perform a final survey of the remediated RMA.

l 2.3.6.- Disposal Trenches The licensee, during clean-up activities in 1978 through 1982, disposed of contaminated soil, sand, concrete, and waste. This material was disposed ofin trenches leait.d northeast of Acid Sludge Pit 4. The licensee proposes to perform additional soil boring to better define the lateral boundaries and depth of the potential radioactive contamination in each of the trenches. If

. radioactive contamination is found that exceeds the proposed release criteria, the licensee plans to remove that material.~ This material will either be packaged and shipped for offsite disposal directly from the area or transferred to the RMSA for subsequent packaging and shipping for offsite disposal. The licensee will then perform a final survey of the remediated area.

2.3.7 Skull Creek -

Skull Creek transverses the Cushing site. The portion of the creek that is southwest (upstream) of the nucl. ear material process buildings is considered an unaffected area. The licensee previously remediated the affected portion of the creek. Since that remediation effort was

. completed, a portion of the affected creek was rerouted to stop acid seepage into the creek from Acid Sludge Pit 5. The old creek channel was backfilled. A second portion of the creek had been rerouted before this remediation effort occurred. This rerouted portion of the creek is

' located between the railroad bridge and the site boundary. This old creek channel was also backfilled. The licensee will perform a final survey of Skull Creek, including boring samples from the old abandoned portion of the creek bed between the railroad bridge and the site boundary. If radioactive contamination is found that exceeds the proposed release criteria, the i

licensee plans to remove that material. This material will either be packaged and shipped for offsite disposal directly from the area or transferred to the RMSA for subsequent packaging and I shipping for offsite disposal. The licensee will then perform a final survey of the i

remediated area.

2.3.8 Site Buildings (Buildings 30 and A-6)

Radioactive material was processed in Building 31. This building was de.molished in 1966.

Buildings 30 and A-6 are the only remaining facilities that housed the nuclear material process L

N +

7, . , ; r, .

' 1 operations. The licensee proposed to dismantle these buildings. The dismantled building material will be surveyed to' determine compliance with the criteria provided in " Guidelines for Decommissioning of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of License for Byproduct, Source or Special Nuclear Material." The licensee plans to dispose of this building material either onsite or offsite.

Licensed material'is stored in Building A-9 and the Health Physics Laboratory. This material will be removed and these buildings surveyed and decontaminated, if necessary, before licence termination; 2.3.9 Rubble and O' ther Potentially Contaminated Areas l

There are several areas onsite that the licensee plans to investigate for possible radioactive

- contamination. These areas include debris located in site area Blocks 60,72, and 102, where

! ' contaminated doors and clothing may have been disposed of, from the 1966 thorium processing incident -- and a disposal trench located in an area east of RMA 1.1. If radioactive contamination is found that exceeds the proposed release criteria, the licensee plans to remove that material.

This material will either: (1) be packaged and shipped for offsite disposal directly from the area or transferred to the RMSA for subsequent packaging and shipping for offsite disposal; or (2) be segregated for further investigation, to decide on the best method to dispose of this material. The licensee will then perform a final survey of the remediated areas.

L 2.3.10 Ground-water Ground-water under the Cushing site can be found in one of three water-bearing zones. The water-bearing zones are the shallow water-bearing zones (unconsolidated soil and the upper portion of the Vanoss Group); the lower portion of the Vanoss Group; and the Vamoosa-Ada aquifer. - The Vamoosa-Ada aquifer is the regional ground-water aquifer. The licensee notes that it appears that there is not a significant ground-water flow between the shallow water-bearing

! zone arid the lower portion of the Vanoss Group. Further, the licensee notes that the

' Vamoosa-Ada aquifer is isolated from the uppermost water-bearing zone by low permeability l

strata within the Vanoss. Thus, the Vamoosa-Ada aquifer is unaffected by surface activities.

The licensee based this finding on an evaluation of environmental tritium. Tritium has been

' detectable in the surficial environment since the 1940s as a result of fallout from the detonation of thermal nuclear devices.

DEQS found the following: (1) the shallow ground-water unit yields low quantities of poor

_ quality water; (2) it is highly unlikely that future residential or commercial drinking water wells

will be established from the shallow ground-water at this site; and (3) no known drinking water 3 Letter to Jeff Lux, Kerr-McGee Corporation, from Darrell Shults, DEQ, September 19,

1997.

]

c i, .

wells are screened in the Vanoss within 1.6 km (1 mile) radius of the site. Further, DEQ stated that the Vanoss should not be considered a viable drinking water source for the area, and that DEQ would consider water quality standards other than maximum contamination levels, as set

. by the U.S. Environmental Protection Agency (EPA), as appropriate for the shallow ground-water at this site. Further, based on EPA guidance,' the Vanoss ground-water would be classified as a " Class 111 - Groundwater Not a Potential Source of Drinking Water and of Limited Beneficial Use."

Although, the licensee's ground-water characterization program is not yet complete, because the licensee plans to develop additional monitoring wells, the licensee has been sampling ground-water for various forms of contamination. The results of this ground-water sampling effort, to date, indicate the ground-water has not been contaminated by licensed radioactive material, t Further, the staff has determined that the activities associated with removing radioactive contaminated material from the Cushing site would not cause ground-water contamination, and that the removal of this material from the site will reduce the potential of future radioactive contamination of the local ground-water supply.

3. RADIATION PROTECTION PROGRAM 3.1 Ornanization and Responsibilities Kerr-McGee's Safety and Environmental Affairs Division has been delegated corporate responsibility for the decommissioning of the Cushing site and termination of the Cushing

- license. Corporate management is responsible for providing the resources and management oversight necessary to complete decommissioning of the Cushing site. Site operations management is responsible for directing the site decommissioning work activities such as the

' handling, transfer, storage, and disposal of radioactive materials. The Radiation Safety Officer (RSO) is responsible for the Cushing site health physics program and the radiological analysis ofsamples.

. The licensee's health physics program is described in the Cushing site " Radiation Safety Plan."

. This program is intended to ensure that all work activities involving licensed radioactive material are in compliance with the Cushing site radioactive material license (SNM-1999) and all applicable regulatory requirements. The licensee will ensure compliance by using approved radiation work procedures, standards, policies, practices, and engineering controls. The Radiation Safety Plan defines the rules, standards, policies, engineering controls, and general radiological work practices. Further, the as-low-as-is-reasonably-achievable (ALARA) principle is a fundamental principle of the Radiation Safety Plan. The Radiation Safety Plan is applicable

' to all site licensee employees, contractors, subcontractors, and visitors.

dEPA, Office of Water, " Guidelines for Ground-Water Classification under the EPA

. Ground-water Protection Strategy," Final Draft, November 1986.

s

m _

Q.4

.g.

~ a The RSO is responsible for ensuring that the provisions of the Radiation Safety Plan are in full compliance with radioactive' material license SNM-1999 and all applicable regulatory requirements. Also, the RSO is responsible for ensuring that the provisions of the Radiation

Safety Plan are incorporated into individual Health Physics Operating Procedures. Finally the RSO is responsible for conducting site inspections on a regular basis to verify that the Radiation Safety Plan is' implemented and to evaluate the effectiveness of the plan.

' The general radiation safety policies the Radiation Safety Plan requires that a qualified health physics staff member be on duty whenever work is being performed in a radiologically restricted area or RMA. ~Also, work performed in a radiologically restricted area or RMA will be covered by either a valid operating procedure or a special work permit (SWP). Finally, no individual is allowed into an area of unknown dose rates or contamination status within a radiologically restricted area or an RMA without being accompanied by a member of the health physics staff.

Safety areas specifically covered by the Radiation Safety Plan are the following: external exposure protection; internal exposure protection; respiratory protection; declared pregnant-woman exposure control; visitor exposure control; radiological area control; radiological surveys; environmental monitoring; waste management and disposal; release of material or equipment for unrestricted use; and radiation safety training. j 3.2 Trainine As stated in the Cushing Site Decommissioning Plan, all individuals working in radiologically restricted areas will be given radiation safety training commensurate with the potential radiological health hazard in the restricted areas. The RSO, or designated alternate, will determine the potential radiological health hazard for individuals who work in these restricted areas and the level of training required. Workers classified as " radiation workers" in accordance with the site Radiation Safety Plan shall receive initial radworker training and annual radworker requalification as appropriate. All radworker training shall include, at a minimum, the topics listed in 10 CFR 19.12.

)

The staff concludes that the Cushing site training meets the requirements of 10 CFR Part 19, in

_ that training will ensure that site personnel involved in radioactive materials remediation are knowledgeable of radiation protection requirements and procedures, and all training will be l

appropriately documented.

3.3 Ouality Assurance The licensee's Cushing site quality assurance (QA) program is based on a combination of the American Society of Mechanical Engineers," Quality Assurance Requirements for Nuclear Facility Applications"(NQA-1) and the American National Standards Institute /American Society of Quality Control ISO 9001 standard. The QA program at the Cushing site provides for both

. quality control (QC) and quality assessment. The objective of QC is to ensure reproducible

y, . '..

measurements or execution ofintended actions. The objective of QA is to evaluate performance and determine whether desired quality is achieved.

The QA Coordinator reports directly to the Cushing Project Manager. The QA Coordinator is responsible for the development, implementation, and auditing of the Cushing Quality System.

At least one QA audit will focus on the radiation safety program each year.

The staff concludes that the program is acceptable and will provide reasonable assurance that the proposed remediation activities will be conducted in a controlled and acceptable manner.

Further, the staff concludes the QA Coordinator will have sufficient independence and authority to correct deficiencies that could affect public and worker health and safety.

l I

3.4 Financial Assurance The licensee, by letter dated August 17,1998, provided an undated site decommissioning funding plan to NRC, along with the revised Site Decommissioning Plan, to meet the requirements of 10 CFR 70.25. The revised decommissioning funding plan consisted of a decommissioning cost estimate of $18,500,000, and a bond from Sefeco Insurance Company of j America, for that amount. The licensee also provided a standby trust from Bank One Trust Company. Staff reviewed both the language of the bond and the standby trust agreement, to ensure that they were consistent with NRC's guidance for decommissioning financial assurance  ;

i instruments, in Regulatory Guide 3.66. NRC concluded that the licensee's financial assurance instruments meet the requirements of 10 CFR 70.25: that the instruments use language consistent with Regulatory Guide 3.66; and that NRC's rights to draw on the guarantee, if necessary, would {

not be adversely affected by the instrument language. Further, the staff reviewed the revised decommissioning cost estimate. This review included the unit cost factors, the estimated quantities of materials, and the labor costs, using Mean's cost estimating guides.

3.5 Radiolonical Controls Radiological controls to be implemented include controls limiting effluent releases to the environment and radiation exposure to workers and the public. An environmental monitoring program has been established as an additional safeguard. The radiation controls are subject to the Cushing Site Radiation Safety Plan and the Cushing QA program.

The radiation protection program was established and implemented by qualified Cushing staff under the direction of the RSO. The goals of the radiation protection program are to ensure that remediation activities are conducted in full compliance with all NRC regulations, and that all occupational radiation exposures are within the limits of 10 CFR Part 20 and are reduced to ALARA levels. The radiation protection program is described in the Cushing Radiation Safety Plan and will be implemented through written procedures.

?. ,

I

' To control occupational exposures, restricted areas are identified and posted--and access to them i

~ is controlled. An SWP program is used to ensure that workers understand: (1) the tasks they are

- assigned; (2) the radiation hazards in the work area; (3) and the monitoring and personnel protection requirements for the task. Personne.1 external monitoring will be accomplished through the use of personnel dosimetry, using thermoluminescence dosimeters, and radiation surveys. Respiratory protection equipment will be available and will be used in compliance with 10 CFR 20.1703.

A contamination control program has been established to minimize the spread of contamination.

All personnel and equipment leaving an RMA will be surveyed. The acceptance criterion for personnel is no detectable radioactivity on hands and feet above background. For equipment the criteria are provided in " Guidelines for Decommissioning of Facilities and Equipment Prior to Release for Unrestricted Use or Temiination of License for Byproduct, Source or Special Nuclear Material."

An ALARA program has been established to ensure that exposures are reduced to ALARA

~

levels. This program encompasses work task planning, control and monitoring of personnel and operations, radiation work permits, training, and tracking exposures. l 3.6 Unrestricted-Use Criteria The licensee has proposed to use the unrestricted-use criteria listed in " Guidelines for l Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or j

. Termination of License for Byproduct, Source, or Special Nuclear Material" for surfaces of l buildings and equipment;" Method for Surveying and Averaging Concentrations of Thorium in Contaminated Subsurface Soil" for. subsurface contaminated soil; and the BTP, " Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations," for soils. Specific values are given below:

' Soils: Uranium 1.11 Bq/g (30 pCi/g) l Thorium 0.37 Bq/g (10 pCi/g)  !

_ Subsurface soil: _ The licensee shall survey in accordance with NRC's guidance paper, " Method for Surveying and Averaging Concentrations of Thorium In Contaminated Subsurface Soil", as a minimum, but may collect samples on a smaller grid or at more frequent depth intervals. The subsurface soil concentration limits are the same as the soil  :

concen'tration for uranium and thorium, above.

When multiple radionuclides are present, the sum of the ratios of the concentration of each radionuclide to its respective limit must not exceed 1.

Surfaces: Uranium 5,000 disintegrations per minute (dpm)/100 square centimeter (cm 2) average 15,000 dpm/100 cm2 maximum 1,000 dpm/100 cm2 removable Thorium 1,000 dpm/100 cm2average 3,000 dpm/100 cm2 maximum 200 dpm/100 cm2 removable Exposure rate: Soils 2.6 nanocoulombs per kilogram per hour (nC/kg/hr)

[10 microroentgen per hour ( IUhr)] above background at 1 m Buildings 1.3 nC/kg/hr (5 IUhr) above background at I m Staff concludes that the above proposed unrestricted use limits are acceptable and consistent with the criteria approved by the Commission in the " Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites."

3.7 Waste Manacement and Disposal 3.7.1 Waste Generation I

i Remediation activities are expected to generate the following volumes of waste:

RMA3 7,646 m3 [10,000 cubic yards (yd3)] ,

RMAs 2,5, and 8 1,529 m3 (2,000 yd))

RMAi1 1,529 m3 (2,000 yd3) j RMAs 10 Buildings 76 m3 (100 yd3)

RMAs 10 Soils 344 m3 (450 yd3)

Small RMA 15 m3 (20 yd))

All waste that exceeds release criteria limits will be shipped offsite to Envirocare for disposal.

3.7.2 Waste Handling and Packaging The licensee has stated that if radioactive contamination is found that exceeds the proposed release criteria it plans to remove that material. This material will either be packaged in intermodal containers and shipped for offsite disposal directly from the RMA or transferred to the RMSA for subsequent packaging in intermodal containers and shipping for offsite disposal.

3.7.3 Waste Transportation The licensee plans to transport the intermodal containers containing the radioactive contaminated waste by truck to a rail station in Sand Springs, Oklahoma, where the containers will be loaded onto railcars. The containers will then be transported by railcar to the Envirocare facility in Clive, Utah. Each intermodal container will contain approximately 11.5 m) (15 yd)) of soil-like material and/or debris. Each intermodal container will represent one truck shipment to the rail facility, which is located approximately 80.5 km (50 miles) from the Cushing site. Typically, three intermodal containers are loaded onto a flatbed rail car. The distance from Sand Springs to Clive is approximately 2,253 km (1,400 miles).

4. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 4.1 Radiolocical Impacts on the Public and Workers Radiological impacts on members of the public may result from inhalation and ingestion of releases of radioactivity in air and in water during the remediation operations, direct exposure to i I

radiation from radioactive material at the site during remediation operations, and transport for disposal. Decommissioning workers may receive dose primarily by ingestion, inhalation, and direct exposure during the remediation activities. In addition to impacts from routine operations, the potential radiological consequences of accidents are considered.

4.1.1 Radiological Impacts on the Public The licensee has evaluated the potential for exposure to a member of the public that would result from remediation of the Cushing site. The results of the licensee's analyses indicate that the upper-bound doses resulting from remediation activities would be 0.18 millisievert (mSv) [18 milliroentgen-equivalent-man (mrem)] total effective dose equivalent (TEDE). Thus, the radiological consequences of remediating the Cushing site are insignificant for members of the j I

public and are well within the regulatory limits as specified in Part 20.

4.1.2 RadiologicalImpacts on Workers The licensee has evaluated the potential for exposure to a radiation worker that would result from remediation of the Cushing site. The licensee evaluated the exposure that would result from remediation of the two major areas that need to be remediated. The licensee evaluated remediation of RMA 11 and Sludge Acid Pit 4. The results of the licensee's analyses indicate that the upper-bound doses resulting from these remediation activities would be 1.4 mSv (140 mrem) TEDE and 0.62 mSv (62 mrem) TEDE, respectively. Thus, the radiological consequences of remediating the Cushing site are a small portion of the Part 20 occupational limit for a radiation worker and are well within the regulatory limits as specified in Part 20.

s 4.1.3 Impacts of Potential Accidents The licensee has evaluated the potential for exposure from conditions that would result from several postulated accident scenarios. The licensee considered accident scenarios for both onsite and offsite accident. The licensee found that the worst-case credible accidents were the results of contaminated wastes being spilled.' The offsite worst-case credible accident was a single intermodal container holding 12.6 m2 (450 ft)) of contaminated waste soil being spilled in transit.

The resulting dose to the worker cleaning up the spilled material was 0.35 mSv (35 mrem)

TEDE, and for a member of the public the resulting dose was 0.0015 mSv (0.15 mrem). The onsite worst-case credible accident was a singlec ' ontainers, holding 0.2 m) (7.5 ft') of contaminated waste soils, being spilled. The resulting dose to the worker cleaning up the spilled material was 0.11 mSv (11 mrem) TEDE.-

The results of the licensee's analyses were considered estimates of upper-bound doses resulting

' from worst-case, but credible, potential accidents. The results indicate that the radiological consequences of the potential accidents involving radioactive waste spillage are insignificant for

. the radiation worker cleaning up the spilled . waste and would result in doses to that worker which are well within the regulatory limits as specified in Part 20.

4.1.4 ~ Impacts on Low-Level Waste Disposal Site Operations The licensee has estimated the amount of radioactive contaminated waste to be shipped to the l Envirocare facility to be about 11,000 m3 (14,570 yd)). This represents a relatively small  !

i percentage of the total volume of wastes disposed of at the Envirocare facility. Radiological impacts'on workers and the public from waste disposal operations are. considered in the approval for low-level waste disposal site licenses and will be consistent with the performance objectives in 10 CFR Part 61, Subpart C, and the applicable State regulations.

4.2 . Nonradiological imoacts y 4.2.1- Demography Socioeconomic Impacts

- Between 1980 and 1990, the population of Payne County dropped from 62,435 to 61,507--a l decrease of 1.4 percent per year. The population estimate for Payne County for 1998 was 65,109, which constitutes an increase of approximately 0.75 percent per year. The estimated l

1998 population of the State of Oklahoma is 3,346,713. The 1990 population of Oklahoma was 3,145,585.

Over 11 percent of Payne County's 1990 population of 65,507 lived in Cushing, the second

. largest town, and 60 percent lived in Stillwater, the largest town. The remaining towns located within Payne County had populations that totaled 7 percent of the County's population. The

' remainder of the County's population,22 percent, lived in rural areas outside of towns. There were a total of 27,381 housing units located in the County in 1990. Most subdivisions are small, L

e

. .~ ,

with small lot sizes and average roads. Sales of existing homes and the rate of new construction are slow. Payne County does not have a zoning ordinances or a land-use plan, but does have subdivision regulations.

Much of the economy of the county is derived from government activities and higher education (Oklahoma State University). Payne County has approximately 1,100 farms, averaging 1,145,300 m2 (283 acres)in size. The vast majority of the farms produce hay or wheat, and graze cattle between plantings. Also,4,614 businesses registered in Payne County in 1992, not including self-employed persons, such as farmers. The Cushing site remediation effort is expected to involve an average of 60 workers. Therefore, this remediation effort should have a minimal socioeconomic impact on the local community.

4.2.2 Air-Quality Impacts Air-quality impacts will result from dust and equipment exhaust from excavation of waste, demolition of buildings, and transport of waste. These impacts will be of short duration and are expected to be minor, j 4.2.3 Land and Water Use A portion of the Cushing site is dedicated to crude oil storage and pipeline operations. The licensee sold these operations to the Notti Gathering Corporation, Inc. (now Dynergy) in 1995.

As part of that sale, the no'rth tank fann, south tank farm, and a small area containing the site office building (Building A-9) will be transferred to Dynergy after NRC has terminated license SNM-1999 and DEQ has approved the final clean-up of the refimery site. The south tank farm is contained within Unaffected Area 2, but the remaining areas Dynergy will acquire are in areas that require surveys or remediation for release.

The remainder of the Cushing site will remain under the licensee's ownership. Portions of this property will be noted in the deed as containing industrial waste (such as the acid sludgq disposal cell). The licensee has stated that it l'as no phns to develop or sell the remaining property and expects the property to remain fallow.

l 4.2.4 Environmental Justice l The conclusion of this Environmental Assessment is that the remediation of the Cushing site represents an insignificant risk to the public health and safety and the human environment.

Therefore, NRC concludes that there are no environmental justice issues related to the remediation of the Cushing site.

m ..

4.2.5 Transportation Transportation in Payne County is primarily by road, although there is one rail line that passes through the county. The Cushing site is serviced by State Highway 18. The site is located near the intersection of State Highway 18, which runs north and south. and Deep Rock Road, which runs east and west. The average daily traffic at this intersection is about 1,500 to 2,000 vehicles per day using State Highway 18, and about 200 to 300 vehicles per day using Deep Rock Road.

The licensee estimates that it will require 1,000 truck shipments to remove the expected )

radioactive contaminated wastes for offsite disposal. Further, the licensee estimates that the Cushing remediation effort will take about 1,000 days to complete. Therefore, the average i additional truck traffic from the Cushing remediation effort will be less than two truck shipments per day. Consequently, the impact of the additional truck traffic and noise due from this additional truck traffic should be insignificant.

4.2.6 Endangered Species I

The licensee has indicated that there are no rare, threatened, or endangered species on the Cushing site. In addition, staff checked U.S. Fish and Wildlife Service (FWS) data to determine whether any threatened or endangered species reside in the area. The data indicated the possibility of three endangered species (interior least tern, peregrine falcon, and whooping crane) and one threatened species (piping plover) in Payne County. On June 16,1999, FWS staff stated that only the interior least tern was found in the vicinity of the Cushing site. FWS staff also noted that decommissioning actions at the Cushing site were unlikely to affect this endangered species or its nesting areas which are commonly located on sand bars in rivers.

Therefore, it is unlikely that the Cushing remediation effort will have any impact on any rare, ,

threatened, or endangered species. i 4.2.7 Historic or Archeological Sites  ;

The only registered historic or archeological site located in or around the City of Cushing is the Cushing Armory, located at 218 South Little Avenue, over 3.2 km (2 miles) from the Cushing site. The Cu_shing Armory is listed with the National Register of Historic Places and with the Oklahoma State Historical Preservation Ofiice. The remediation efforts at the Cushing site should have no impact on the Cushing Annory, since it is some distance away.

5. ALTERNATIVE TO THE PROPOSED ACTION The staff considered the no-action alternative to the licensee's proposed action of collecting the radioactive waste material and shipping this material to the Envirocare facility for disposal. The no-action alternative would mean that the Cushing site would not be remediated at this time.

This conflicts with NRC's requirement, in 10 CFR 70.38, of timely remediation at sites that have i

r .

7h

• I ceased operations. Although there is no immediate threat to the public health and safety from this site as long as the licensee maintains appropriate controls over the radioactive material, not undertaking remediation, at this time, does not resolve the regulatory and potential long-term l

health and safety problems involved in storing this waste. No action now would delay remediation until some time in the future, when costs could be much higher than they are today.  !

I It is even possible that no disposal option will be available in the future if the current low-level radioactive waste disposal facilities are closed and no new ones are opened.

6. CONCLUSIONS i The staff believes that the proposed decommissioning of the Cushing site will not cause any significant impacts on the human environment and is acceptable. The proposed action would result in the irreversible use of energy resources in the conduct of removal activities and the transportation of waste material for disposal. A portion of the Envirocare facility will be irreversibly committed for the disposal of Cushing site waste. There is no reasonable alternative to these resource uses, and the proposed action does not involve any unreviewed conflicts )

concerning use of available resources.

7. AGENCIES AND PERSONS CONSULTED, AND SOURCES USED Only NRC staff prepared this Environmental Assessment. No other sources were used beyond ,

those referenced in this Environmental Assessment. NRC staff provided a draft of this J Environmental Assessment to DEQ for review. DEQ in its letter dated July 12,1999, stated that they had no comments.

t i

8. FINDING OF NO SIGNIFICANT IMPACT l l

NRC has prepared an Environmental Assessment related to the issuance of a license amendment l to Materials License SNM-1999, authorizing remediation of the Cushing Refinery site. On the basis of this Environmental Assessment, NRC has concluded that this licensing action would not adversely affect the environment and does not warrant the preparation of an Environmental l Impact Statement. Accordingly, it has been determined that a Finding of No Significant Impact is appropriate.

The aforementioned documents related to this proposed action are available for public inspection and copying at NRC's Public Document Room at the Gelman Building,2120 L Street NW, Washington, DC 20555-0001.