ML20211D602
| ML20211D602 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 08/23/1999 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20211D589 | List: |
| References | |
| NUDOCS 9908270098 | |
| Download: ML20211D602 (18) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 20066-0001 g
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TiiE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS SAFETY EVALUATION RELATED TO AMENDMENT NO.10 TO MATERIAL LICENSE NO. SNM-1999 I
KERR-McGEE CORPORATION f
CUSHING REFINERY SITE DOCKET NO. 70-3073
]
1 INTRODUCTION This Safety Evaluation Report (SER) was prepared by staff of the U.S. Nuclear Regulatory Commission (NRC) (hereafter referred to as "the staff"), Office of Nuclear Material Safety and Safeguards. This SER concerns a license amendment proposed by Kerr-McGee Corporation (Kerr-McGee or the licensee) to authorize remediation of radioactive contamination at Kerr-McGee's Cushing Refinery Site (Cushing site), located in Cushing, Oklahoma. The purpose of this SER is to evaluate how consistent the licensee's proposal is with applicable NRC regulations and regulatory guidance, and to recommend appropriate licensing actions.
1.1 Backcround On April 6,1993, NRC issued Materials License SNM-1999 to Kerr-McGee for its Cushing site.
This license authorized the licensee to possess contaminated soil, sludge, sediment, trash, I
building rubble, and any other contaminated material, at its Cushing site. Title 10 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 Site Decommissioning Plan for its Cushing site. By letter dated August 17,1998, Kerr-McGee submitted a revised Site Decommissioning Plan. The licensee supplemented its plan by letters dated June 4 and June 18,1999.
i Kerr-McGee, in its letter dated November 26,1997, and supplemented by letters dated February 5,1998, March 3,1997, and June 29,1998, requested approval of part of the Site Decommissioning 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 i
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.
l 9908270098 990823 PDR ADOCK 07003073 C
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. 1.2 Proposed Action This SER 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) (Reference 10) Disposal Option 1 (Option 1),
package this material, and ship this material to the Envirocare Low-Level Radioactive Waste Disposal Site in Clive, Utah, for disposal.
2 ADMINISTRATIVE CO~NTROLS 2.1 Oreanization and Resnonsibilities The Safety and Environmental Affairs Division (SEAD) is the organization within the Kerr-McGee Corporation responsible for the decommissioning of the Cushing site. The corporate portion of the SEAD organization responsible for the Cushing site decommissioning consists of:
the Vice President, Hydrology, Geology, and Remediation; Program Manager; and Project Manager. The key Cushing site personnel are the Plant Manager and Radiation Safety Officer (RSO).
The staff has reviewed the organizational structure and the qualifications of the individuals who hold the key SEAD Cushing decommissioning positions. Based on that review the staff has determined that the SEAD Cushing decommissioning project organization provides sufficient experience and expertise to conduct the remediation in a manner that will protect the health and safety of both the public and site workers.
2.2 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 radiation worker training and annual radiation worker requalification as appropriate. All radiation worker training will include, at a minimum, the topics listed in 10 CFR 19.12.
l The staff concludes that the Cushing site training program 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. Further, all training will be appropriately documented.
2.3 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 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 stafTconcludes 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 that the QA Coordinator will have sufficient independence and authority to correct deficiencies that could affect public and worker health and safety.
2.4 Licensee Flexibility The licensee has proposed that it be authorized to make certain changes to the NRC-approved decommissioning plan, the Radiation Safety Plan, and associated procedures without NRC approval if these changes are consistent with the as low as is reasonably achievable (ALARA) principle and the decommissioning process. All changes would be approved by the Cushing ALARA Review Committee (ARC). The staff concludes that authorizing the licensee to make certain changes, during the site remediation, is acceptable, subject to the following license condition:
The licensee is authorized to make changes to the NRC-approved decommissioning plan and the Radiation Safety Plan without NRC's approval, if these changes are consistent with the ALARA principle and the decommissioning process. All changes shall be approved by the Cushing ALARA Review Committee (ARC), subject to the following:
A.
The licensee may, without prior NRC approval, and subject to the requirements specified in Parts B and C of this condition:
i.
Make changes in facility or process, as presented in the approved Site Decommissioning Plan and Radiation Safety Plan;
. ii.
Conduct tests or experiments not present in the approved Site Decommissioning Plan or applicable license conditions.
B.
The licensee shall not be required to file an application for an amendment to the license when the following conditions are satisfied; i.
The change, test, or experiment does not conflict with requirements specifically stated in the license (excluding those aspects addressed in Part A of this condition), or impair the licensee's ability to meet all applicable NRC regulations; ii.
There is no degradation in safety or environmental commitments addressed in the Site Decommissioning Plan or Radiation Safety Plan, or have a significant adverse efTect on the quality of the of the work, the remediation objectives, or health and safety; and iii.
The change, test, or experiment is consistent with the conclusions of actions analyzed in the Environmental Assessment (EA) dated August 1999.
C.
The licensee's determination shall be made by the Cushing ARC. The ARC shall consist of a minimum of three individuals employed by the licensee, of whom one shall be designated as the ARC chairman. One member of the ARC shall represent corporate (Oklahoma City office) management and shall be responsible for approval of managerial and financial changes. One member shall represent site operations and shall have responsibility for implementing any changes. One member shall be i
the site RSO or equivalent, with responsibility for assuring that changes conform to j
radiation safety requirements. Additional members may be included in the ARC, as appropriate, to address technical aspects, such as health physics, ground-water hydrology, surface-water hydrology, specific earth sciences, and other technical disciplines. Temporary or permanent members, other than three individuals who are required to be Kerr-McGee Corporation employees, may be consultants. The licensee's determinations as to whether the above conditions are met will be made by the ARC. The licensee shall provide in an annual report to NRC describing all such determinations made pursuant to this condition, including a summary of the safety and environmental evaluations of each such action. As part of this annual report, the licensee shall include any Site Decommissioning Plan and Radiation Safety Plan pages revised pursuant to this condition. The records of each determination shall be retained until license termination. The retained records shall include the written safety and environmental evaluations, made by the ARC, that provide the basis for determining whether the above conditions are met.
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. 3 RADIATION HEALTH AND SAFETY The staff reviewed the proposed health physics program to be used during remediation of the Cushing site. Using the guidance provided in 10 CFR Part 20 and Regulatory Guides 8.7,8.8, 8.9,8.25,8.34,8.36, and 8.37 (References 12 through I8), the staff evaluated the proposed health physics program by examining procedures, equipment, instruments, training, and personnel dosimetry.
3.1 Health Physics and Safety Manacement The Cushing decommissioning project organization is headed by the Project Manager, who is responsible for overall project control. The Project Manager is also responsible for meeting environmental, health and safety, QA, and technical requirements. The Site Manager, who has on-site management responsibility for remediation and decommissioning of the Cushing site, reports to the Project Manager. The Staff Health Physicist who is the Cushing site RSO, reports to the Site Manager.
The RSO is directly responsible for the Cushing site radiation safety program, the radiological analysis of samples, and monitoring decommissioning activities. The RSO has sufficient authority and independence to stop work and correct radiologically unsafe practices. The RSO is responsible for supervising radiation safety operations, ensuring that project personnel receive i
radiological training, providing technical expertise to radiation safety personnel, conducting audits of the Radiation Safety Plan, reviewing radiation survey reports, and developing and i
implementing the necessary project radiation safety procedures.
The staff finds that the Cushing site project health physics management organization is appropriate for the proposed decommissioning effort.
3.2 Sources of Radiation The licensee has identified 16 areas where 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.
3.2.1 RMAs 1,4,6,7,9, and 12 Throughl6 (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 (m)(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 packaging and shipping for offsite disposal. The licensee will then perform a final survey of the remediated RMA.
The staff finds the licensee proposed remediation methods for these RMAs acceptable.
3.2.2 RMAs 2,5, and 8 (Refinery Tank Berms)
The licensee has determined, based on its characterization of the site, that these tank berm 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). be 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.
The staff finds the licensee proposed remediation methods for these RMAs acceptable.
3.2.3 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 License No. SNM-1999, which authorized both remediation of Acid Sludge Pit 4 and use of I
the RMSA.
3.2.4 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 thatyxtended from the southwest end of Building 31 to Skull Creek. It is possible that this area may stih be contaminated. The licensee estimates that the concentrations of thorium in this area are about 1.11 Bq/g (30 pCi/g) and concentrations of uranium are about 5.9 Bq/g (160 pCi/g). The licensee plans to perform additional soil boring 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 L
. 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.
The staff finds the licensee proposed remediation method for this RMA acceptable.
3.2.5 RMA-11 (Trash Dump)
This RMA was a trash disposal area that was used to dispose of trash, refinery wastes, and some licensed material. The licensee proposes to perform soil boring on a 5-by-5-m [16.4-by-16.4-foot (ft)] grid pattern. If the soil-like material contains licensed material above background limits, the entire volume (including brick, steel, and other material) will be considered to exceed the decommissioning criteria, and be excavated. 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.
The staff finds the licensee proposed remediation method for this RMA acceptable.
3.2.6 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 located 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.
The staff finds the licensee proposed remediation method for this area acceptable.
3.2.7 Skull Creek Skull Creek transverses the Cushing site. The portion of the creek that is southwest (upstream) of the nuclear 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
.g.
boundary. If radicactive 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.
The staff finds the licensee proposed remediation method for this area acceptable.
3.2.8 Site Buildings (Buildings 30 and A-6)
Radioactive material was processed in Building 31. This building was demolished in 1966.
Buildings 30 and A-6 are the only remaining facilities that housed the nuclear material process 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 license termination.
The staff finds the licensee proposed remediation method for the site buildings acceptable.
3.2.9 Rubble and Other Potentially Contaminated Areas 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 cast of RMA 11. 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.
The staff finds the licensee proposed remediation method for this RMA acceptable.
3.3 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
d 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 and 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 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.
DEQ' 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 g
will be established from the shallow ground-water at this site; and (3) no known drinking water
]
wells are screened in the Vanoss within 1.6 km (1 mile) radius of the site. Further, DEQ stated J
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,2 he Vanoss ground-water would be t
classified as a " Class Ill - 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.
Further, the staff has determined that the activities associated with removing radioactive contaninated 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.
3.4 Dose Commitment 3.4.1 Radiation Exposure to 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
' Letter to JefTI.ux, Kerr-McGee Corporation, from Darrell Shults, DEQ, September 19,
' EPA, Office of Water," Guidelines for Ground-Water Classification under the EPA Ground-water Protection Strategy," Final Draft, November 1986.
l
i,
{
milliroentgen-equivalent-man (mrem)] total effective dose equivalent (TEDE). Thus, the radiological consequences of remediating the Cushing site are insignificant for members of the public and are well within the regulatory limits as specified in Part 20.
{
3.4.2 Occupational Exposure i
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 a
limit for a radiation worker and are well within the regulatory limits as specified in Part 20.
3.5 Health Physics Procram 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 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.
j The RSO is responsible for ensuring that the provisions of the Radiation Safety Plan are in full compliance with radioactive materials 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 of 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 an 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 an RMA or a radioactive restricted area without being accompanied by health physics staff. Safety areas specifically covered by the Radiation Safety Plan are the following: extemal exposure protection; intemal 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.
The staff concludes that the health physics program is acceptable, and is capable of effectively measuring worker and public exposure and effluent releases, controlling contamination, training 1
workers, and ensuring that 10 CFR Part 20 requirements are met.
3.6 IIealth Physics Instruments. Eauinment. and Facilities Portable alpha, beta, and gamma radiation monitoring instruments will be used to monitor radiation exposure and activity levels. These instruments will be calibrated in accordance with manufacture's recon mendations and established site procedures. In the onsite laboratory there is a multi-channel gamma spectrum analyzer that is available for determining the concentration of licensed material in soil and environmental samples. Instruments will be properly stored and maintained, and regularly tested within the IIcalth Physics Laboratory. Portable instruments are maintained in designated storage areas, depending on their operational status (i.e., calibrated instruments are stored separately from uncalibrated and/or out-of-service instruments).
Monitoring and surveying instruments are calibrated with sources traceable to National Institute of Standards and Technology standards. Gamma scanning instruments are energy-calibrated with a non-traceable cesium-137 source; traceability is not required because the source is not relevant to the energy calibration.
The staff concludes that appropriate controls will be established to ensure the proper storage, maintenance, and use of health physics instruments, equipment, and facilities.
3.7 11ealth Physics Procedures The licensee will control work activities through the use of operating procedures or special work permits. A special work permit is a work permit reviewed by licalth Physics personnel, all personnel assigned to perform a task, and all personnel affected by the task, before beginning work. Further, special work permits will be prepared to identify precautions to be taken to maintain exposures ALARA. All radiation workers are required to wear their film badges at all times in any undesignated area, RMA, or any radiologically restricted area. liowever, radiation workers are not required to wear film badges in Building A-9, Trailer A, or Trailer B, unless they are working with radioactive material. Non-radiation workers will be required to wear film badges if they are working with radioactive material or entering a radiologically restricted area or RMA. All radiation exposure information will be obtained, processed, and recorded in accordance with Part 20.
The staff concludes that the proposed program for using operating procedures or SWP to control work activities involving radioactive materials is acceptable.
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. 4 RADIOACTIVE WASTE MANAGEMENT 4.1 Waste Packacine and Shipnine 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 off-site disposal directly from the RMA, or transferred to the RMSA, for subsequent packaging in intermodal containers and shipping for offsite disposal.
i 4.2 Offsite Waste Disposal Remediation activities are expected to generate the following volumes of waste:
RMA3 7,646 m' [10,000 cubic yards (yd')]
2 RMAs 2,5, and 8 1,529 m (2,000 yd')
RMA11 1,529 m) (2,000 yd))
3 RMAs 10 Buildings 76 m (100 yd')
RMAs 10 Soils 344 m (450 yd')
2 3
Small RMA 15 m (20 yd))
All waste that exceeds release criteria limits will be shipped ofTsite to Envirocare for disposal.
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 Ilighway 18. The site is located near the intersection of State Ilighway 18, which runs north and south, and Deep Rock Road, which runs east and west. 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 licensee estimates that it will require 1,000 truck shipments to remove the expected radioactive contaminated wastes for offsite disposal. 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 yd3) of soil-like material and/or 2
debris. Each intermodal container will represent one truck shipment to the rail facility, which is located approximately 80.5 kilometers (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).
Wastes disposed of offsite shall be classified and meet waste form requirements of 10 CFR Part 61, meet applicable disposal site license conditions, and meet Department of Transportation and 10 CFR Part 71 transportation requirements.
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. 5 UNRESTRICTED USE REQUIREMENTS 5.1 Unrestricted Use Criteria The licensee has proposed to use the unrestricted use criteria listed in " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of License for Byproduct, Source, or Special Nuclear Material" for surfaces of buildings and equipment; " Method for Surveying and Averaging Concentrations of Thorium in Contaminated Subsurface Soil" for subsurface contaminated soil in RMA 3 RMA 11, Skull Creek, RMA 10, Block 102, Block 60 or 72, and potential trench east of RMA-11; 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)(total uranium)
Thorium 0.37 Bq/g (10 pCi/g)(total thorium)
Subsurface soil (in The licensee shall survey in accordance with NRC's above listed areas):
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 i
concentration limits are the same as the soil concentration 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.
Equipment and Uranium 5,000 disintegrations per minute (dpm)/100 Building Surfaces:
square centimeter (cm ) average 2
2 15,000 dpm/100 cm maximum 2
1,000 dpm/100 cm removable 2
Thorium 1,000 dpm/100 cm average 2
3,000 dpm/100 cm maximum 2
200 dpm/100 cm removable l
Exposure rate:
Soils 2.6 nanocoulombs per kilogram per hour (nC/kg/hr)
[10 microroentgen per hour (pR/hr)] above background at I m Buildings 1.3 nC/kg/hr (5 pR/hr) above background at 1 m Equipment 0.05 pC/kg/hr (0.2 mR/hr) at 1 cm for beta radiation 0.26 pC/kg/hr (1.0 mR/hr) at I cm for gamma radiation
. 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."
5.2 Final Radiation Survey Plan The licensee will perform a final site radiation survey once decontamination and decommissioning are completed in accordance with NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination" and staff's paper, " Method for Surveying and Averaging Concentrations of Thorium in Contaminated Subsurface Soil." The object of this survey is to demonstrate, with a 95-percent confidence level, that there are no radioactive hot spots having levels that exceed the averaging criteria in NUREG/CR-5849--
except for subsurface contaminated soil in RMA 11 and the Disposal Trench areas, and no radioactive hot spots having levels that exceed the averaging criteria in " Method for Surveying and Averaging Concentrations of Thorium in Contaminated Subsurface Soil."
NRC will perform a confirmatory survey to ensure that the licensee's final survey reflects the actual radiological conditions at the site.
Staff concludes that the final survey plan meets the requirements of 10 CFR 70.38(g) and the recommendations in NUREG/CR-5849. Therefore, the survey plan is acceptable.
6 PHYSICAL SECURITY All RMAs are enclosed with a three-strand barbed wire fence with locked gates. Portions of two RMAs (RMA -11 and RMA 3) are also enclosed by a 6-ft chain link fence. All fences surrounding RMAs are appropriately posted with signs indicating " Restricted Area, Authorized Personnel Only" and " Caution, Radioactive Materials."
Staff concludes that the Cushing Refinery site physical security plan meets the requirements of Part 20 and is acceptable.
7 POSTULATED 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 accidents. The licensee found that the worst-case credible accidents were the result of contaminated wastes being spilled. The offsite worst-case credible accident was a single 3
intermodal container holding 12.6 m (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 3
3 worst-case credible accident was a single container, holding 0.2 m (7.5 ft ) of contaminated
. waste soil, 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.
8 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 Safeco Insurance Company of America, for that amount. The licensee also provided a standby trust from Bank One Trust Company. StafTreviewed 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 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 (Reference 11), 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 the Site Decommissioning Plan and Mean's cost estimating guides. The staff concluded that the cost estimates were reasonable for the proposed decommissioning activities, and no changes are necessary in the decommissioning financial assurance instruments.
9 MAJOR DECOMMISSIONING ACTIVITIES, TASKS, AND SCllEDULES The licensee has proposed a schedule to complete remediation of the Cushing site. The general work activities necessary to meet the unrestricted release criteria included the following activities and tasks: radiological operations; Pit 4 decommissioning; undesignated area surveys; decommissioning structures; decommissioning RMAs 1,4,6-9, and 12-16; decommissioning RMAs 2 and 5; Process Building demolition; decommissioning RMA 3; decommissioning RMA 10; decommissioning RMA 11; ground-water assessment; decommissioning Skull Creek; decommissioning offsite areas; and decommissioning the RMSA. Remediation activities will be accomplished using common construction equipment. The licensee estimates that it will take approximately 4 years to complete remediation of the Cushing site. Because the schedule to complete the Cushing site remediation exceeds the requirement, specified in 10 CFR 70.38(h)(2)(i), to complete site remediation within 24 months after the initiation of.
decommissioning, the licensee, in accordance with the provisions of 10 CFR 70.38(h)(2)(i)(5),
has requested an alternate schedule. The licensee has indicated that it is not technically feasible 1
1
. to complete all proposed decommissioning within 24 months based on the scope of the effort.
Further, the licensee noted that the decommissioning plan includes various non-routine activities that increase the likelihood of accidents. The licensee will also need to coordinate with the State j
of Oklahoma on areas of the site requiring remediation of hazardous chemical wastes. Therefore, the licensee proposed a schedule so that no more than five different decommissioning activities will be in process at a given time. This would allow sufficient time for training and supervision.
NRC finds the proposed altemated schedule acceptable based on the licensee's justification.
j 10 CONCLUSIONS The staff evaluated the licensee's proposed site remediation plan for the Cushing Refinery site for consistency with NRC's regulations and regulatory guidance. The staff concludes that the licensee's plan is acceptable.
11 REFERENCES 1.
Cushing, Oklahoma, Refinery Site, Site Decommissioning Plan, April 1994, Kerr-McGee Corporation.
2.
Cushing, Oklahoma, Refinery Site, Site Decommissioning Plan, August 1998, Kerr-McGee Corporation.
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3.
Letter to S. Brown (NRC) from J. Lux (Kerr-McGee), dated June 30,1998.
4.
Letter to S. Brown (NRC) from J. Lux (Kerr-McGee), dated January 15,1999.
5 Letter to S. Brown (NRC) from J. Lux (Kerr-McGee), dated June 4,1999..
6.
Letter to S. Brown (NRC) from J. Lux (Kerr-McGee), dated June 15,1999.
7.
Letter to S. Brown (NRC) from J. Lux (Kerr-McGee), dated June 18,1999.
8.
Letter to M. Broderick (DEQ), from S. Brown (NRC), dated June 22,1999.
9.
Letter to S. Brown (NRC) from H. Caves (DEQ), dated July 12,1999.
- 10. U.S. Nuclear Regulatory Commission, Branch Technical Position, " Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations," Federal Register, Vol 46, No. 205, October 23,1981, p. 52061.
I1. U.S. Nuclear Regulatory Commission, Regulatory Guide 3.66 (Task DG-3002),
" Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30,40,70, and 72," June 1990.
. 12. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.7," Instructions for Recording and Reporting Occupational Radiation Exposure Data," Revision 1, June 1992.
- 13. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.8,"Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As i
Low As is Reasonably Achievable," Revision 3, June 1992.
- 14. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program," Revision 1 July 1993.
- 15. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.25," Air Sampling in the Workplace," Revision 1, June 1992.
- 16. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.34," Monitoring Criteria and Methods to Calculate Occupational Radiation Doses," July 1992.
- 17. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.36," Radiation Dose to the Embryo / Fetus," August 1992.
- 18. U.S. Nuclear Regulatory Commission, Regulatory Guide 8.37,"ALARA Levels for Efiluents from Material Facilities," July 1993.
- 19. U.S. Nuclear Regulatory Commission, Regulatory Guide 10.4, Guide for the Preparation of Application for Licenses to Process Source Material," Revision 2, December 1987.
- 20. U.S. Nuclear Regulatory Commission," Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites," Federal Recister, Vol. 57, No. 74, April 16, 1992,p.13389.
- 21. U.S. Nuclear Regulatory Commission, " Manual for Conducting Radiological Surveys in Support of License Termination," NUREG/CR-5849, June 1992.
- 22. U.S. Nuclear Regulatory Commission," Guidelines for Decontamination of Facilities and i
Equipment Prior to Release for Unrestricted Use or Termination of License for Byproduct, Source, or Special Nuclear Material," August 1987.
- 23. U.S. Environmental Protection Agency," Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," EPA 400-R-92-001, Revised 1991.
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