ML20211D618

Application for Amend to License SNM-1999,to Authorize Remediation of Cushing,Ok,Refinery Site

ML20211D618
Person / Time
Site:	07003073
Issue date:	08/17/1999
From:	Lux J KERR-MCGEE CORP.
To:	Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20211D589	List: ML20211D584 ML20211D590 ML20211D596 ML20211D602 ML20211D609 ML20211D618
References
NUDOCS 9908270101
Download: ML20211D618 (3)

Text

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KERR-McGEE CORPORMION u a.usace cmea. o uscui cm. onusou4 nm

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August 17,1998 l

Mr. Stewart Brown Low-Level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Materials Safety & 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 request a final j

revision of the, Site Decommissioning Plan for the Cushing, Oklahoma refinery site. The l

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 Technical Position Option 1) to an off site licensed disposal facility,

4. The October,1996 radiological groundwater investigation work plan, entitled Workplan. Evaluation of Licensed Materials Mieration via Groundwater Pathways,

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

6. The Building Demolition Plan submitted March,1997,

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

8. A cost estimate for decommissioning 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 j

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 I

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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 Trust 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 financial assurance package.

It is KMC's beliese 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 characterization report for 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

7. March 29,1996 (KMC to NRC) response to comments on the SDP

8. August 22,1996 (KMC to NRC) notice that Option 2 material will be shipped to a 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 DEQ) request for comments on the SDP

14. August 21,1997 (KMC to NRC) 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) revised sections 3.2 (criteria) and 3.3.1 (Pit 4) of the SDP

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

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

22. February 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.

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

Sincerely, Jeff Lux Project Manager l

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C. L. Cain, NRC Region IV Rick Reiley, Cushing Citizens' Oversight Committee Earlon Shirley, ODEQ Darrell Shults, ODEQ l

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• BOX 2323 CUSHNG OKLAHOMA 74023 SAFETY 4 ENVIRONMENTAL AFFAIRS j

June 4,1999 Mr. Stewart Bauwn Low-level Waste & Decomminioning Projects Branch j

Division of Waste Management Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regal *wy Conunission W.rJJrpi, D. C. 20555 Re:

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

Dear Mr. Brown:

Kerr-McGee Corporation (KMC) herein submits respomes to NRC's Request for Additional Information Related to Kerr-McGee's Omhing Refinery Site Dmwnminioning Plan. KMC has provided each request for information by NRC (in italicized font), followed by KMC's response.

KMC has also included responses to Oldahoma Department of Environmental Quality (DEQ) enmmenta on the.f+ -

2=':.bg plan in the same format.

NRC Genemi Raguest II: Pnmide the sduade ofplanned decommissiomng activities. If the time- ?,

line to amqpiere i+t-. '"%ing of the Ckshing site is greater than 24-monthsfrom the date NRC Appnwes the site l-

.. **d -l.g plan, provedejustrpanionfor the delay in accordance with the requirements of10 CFR 70.38(g)(4)(vii).

KMC Response: KMC has projected a d==nmid=ing eharkle based upon appiuvat of the Site I'+---- " 2-g Plan (SDP) by August 20,1999. 'Ibe projected schedule is provided as Anschmew A to this iener. 'Ihe eharkle indicates that d=wnn'ia*ianing will extend over more than two years. ' Ibis eharkle is yih as a planning document only. 'Ibe actual sequence or duration of activities may vary based on field and/or weather conditions, available resources, technical pinblems encountered, etc.

10 CFR 70.38(hX2)(i) states that NRC may approve a request for an alternate schedule for completion of dana==i= inning if, among other rmarum, it is not iM.bHy feasible to cumplac -

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• 2-g activities within the allotted 24-month period. In light of the scope of the project, it is not echnicany feelhle to g...; '-7-: all proposed damuniaianing activities within 24 months.

In addition the section allows consideration of other site-specific factors. Id. At 70.38(hX2XiX5).

KMC believen safay will be enhancad by cunni eing different proposed e>-.

a=k-.he activities over a period ---di. beyond 24 mone=. 'the decommissioning pian includes various non-9\\Y

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Responses to Request for Additional Information KMC Cushing Site Ihmmminianing Plan routine activities, which increases the likehbood of accidents. KMC has therefore scheduled the drenmmiminning effort so no more than five different d==nmM=ing activities will be in process at any given time, thereby facilitating training and supervision. NRC approval of this altemate aclable is r-~I along with approval of the SDP.

~p NRC Gmemi Reguest #2: Provide a dase estimate (IEDE)for a member ofthepublic (Mddr indades mm-mdiation unters, truck driwrs, and mil wrters) that Mil resultfmm the Ckshing site renwHarime epbrt, including packing and tmnsporting the greater than Option 1 r~Nausiw mste to an ofsite licensed dkpasalfadlity. Also, pmvide a dose estimate TEDEfora mdsation wrterinmtmiin the Ckshing site wrmliarias efort. Fmally, provide a desaiption of the wrst-arsepostulated radnological accident scenario that could ocaer as a result ofrenwfiation activities.

Daruportation accidents should be included aspart of the accident scenarias considered in this enlaation. This description should be included in the estimatedpotential consequences (1EDE) of that pn~Med wist-case accident both site ivutuntinn wrters and members of thepublic.

KMC Response: Attachment B contains dose evaluations for on-site and off-site accident scenarios, as well as the dose to woiters and the public from normal operations. 'Ibe evaluations utilize conservative assumptions and thus are expected to overestimate significantly any actual dose that would be realized durmg de.i..iinioning activities. The calculated doses deii==uate that full comphance with the regulations will be achieved even under the worst anticipated scenarios.

O=hing is committed to ALARA in all activities associated with f+ iiasinioning of the facility.

i NRC General Reguest #3: Pmvide a description of the physical security measures used to prewnt

,g the genemipublicfrom intrudmg into either mdiation areas and/or imH~" sin materials areas.

KMC Response: All radioactive materials areas (RMAs) are enclosed with a 3-strand barbed wire fence with locked gates. Portions of two RMAs (RMA-11 and a portion of RMA-3) are also enclosed by a six-foot chain link fence. All fences surmunding RMAs are appropriately posted with signs bearing the legends " Restricted Area Authorized Penannel Only" and " Caution Radioactive Materials".

NRC Genemi Reguest N: We recognize that situations could ocaer during the performance ofa project that could require certain daanges to an pppromt decommissioning plan. :Therefore, we l

madd consider a lianse andntion that would allow you to make certain damges to either the Appnmd M.. *==i--.;,.g plan orprocedures without our review or qpproml. Ifyou want this type offlexibility while remediating the Osshing site, provide a proposed dsange process and license condution, includung w w.l4xtional owrsight of this dungeprocess.

s KMC Response: A licenae condition allowing artain d cip to be made to the NRC-approved l

SDP, the Radiatina Safety Plan (RSP), and associated procedures without NRC approval is nnnaisser with AIARA and the dmnmmiminning process. ' Ibis would allow appropriate d.icip to be made to these dcmnanta as site health and safety requirmneres change. All changes would be preceded by the Cushing ALARA Review Committee (ARC) review and written documentation of the justification and approval process. KMC therefore proposes the following license condition:

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Page 2 of 21

R& to Request for Additional Information KMC Oething Site Dannmmtatiomng Plan A.

The licensee snay, without prior NRC approval, and subject to the requirements specified in Parts B and C of this condition:

1.

Make changes in facility or process, as piaritmi in the approved Site Decomrnissioning Plan and Radiation Safety Plan; 2.

Make d.iii.gs in the procedures presented in the approved Site Dmx-<.i. i" inning r -: A e

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Plan, Radiation Safety Plan, or applicable license conditions; and 3.

Conduct tests or experiments not pir.ed in the approved Site Dacammiecianing 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:

1.

The change, test, or experiment does not conflict with any requirement specifically

-r stated in this license (excluding those aspects addressed in Part A of this condition),/

or impair the licensee's ability to meet all applicable NRC regulations; 2.

There is no degradation in safety or envicuuni, ental commitments addressed in the Site Decommissioning Plan or Radiation Safety Plaa; and 3.

The change, test, or expenment is consistent with the conclusions of actions analyzed in the Enviruini uial Assessment (EA) dated (insert month and year when

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the EA for the Site Decommissioning Plan is appmved).

C.

The licensee's determinations shall be made by the Oi=hing ALARA Review Committee (ARC). The ARC shall consist of a minimum of three individuals employed by the licenwe, of whom one shall be designated as the ARC diriku.ss. One member of the ARC shall i+m wir.ic (Oklahoma City office) management and shall be responsible for approval of managerial and financial d r.gs. One member shall i+m site operations and shall have responsibilitylor 'M any changes. One member shall be the site 3

Radiariani Safety Officerkequivalent,'with responsitulity for assuring that d-.gs conform to radiatinn safety requirements. Additional members may be included in the ARC, as appropriate, to address technical aspects, such as health physics, groundwater hydrology, surface-water hydrology, specific earth sciences, and other technical disciplines.

Temporary or permanent members, other than three individuals who are required to be KMC employees, may be consultants.

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Pe to Request for AddinonalInfuo hon

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KMC Onehmg Site Decommissioning Plan P

NRC Gmemi Repest 15: Pnnide a desaiptim ofthe speapc method (s) that will be used to tmmportpackaged radsoodiw waste greater than Option 1forshipmentfmm the Otshing site to a liamsed ofsite dispasalJhdlity. Pnmide the name and location of the licensed ofsite duposal faciety that Oahing mdioaatw unste usu be shipped. Pnnide an estimate of the number oftruct or mil car shipments that will be required to ship the Otshing waste to the ofsite licensed dicnm!

facility. Pnnide the pppmximate one-nay distance that will be smuled by either truct and/or mil.

KMC Response: Material that is %nJ=-i with licensed material above hiinihioning criteria will be packaged in intermodal cormniners. 'Ibe curmnt plan is for these containers to be transported by truck to a rail station in Sand Springs, Oklahoma, where they will be loaded onto railcars. 'Ibey will then be transported by radcar to a licensed disposal facility operated by Envimcare of Utah (Envirocare) in Clive, Utah. Each intennodal container will contain approximately 15 cubic yards of soil-like material and/or debris.

If KMC ships a total volume of 15,000 cubic yards of waste to Envirocare (Table 3.4 of the SDP),

this will require the use of approximately 1,000 intermodal containers. Each contamer will (qnsat one truck shipment to the rail facility, which is letM approximately 50 miles from the O=hing site. Typically, three intermodal containers are loaded onto each flatbed railcar, so approximately 340 railcars will transport waste fiom Sand Springs to Envirocare, a distance of approximately I,400 miles.

NRC Site Dmunmissionine Plan Reauest #1: Section 1.3 - We do not agree that the activities that you areproposing quahfyfor a categorical erclusion pursuant to the provisions of10 CFR Part 51.22(c)(11). Therefore, to allow us to assess the enviw.,,ar:alionpact ofyourproposed activities provide thefollowing: (a) provide a dicmccim on the socioeconomic irnpaas the Dahing renwsnim efort will haw on the local commumty; (b) provide a Ab~ccim on thefuture land and unter use of the site once site remediation is cornplete and the NRC license is terminated; (c) pmvide a dnsmuinn ofary historical or ardwological sites on the Otshing site or in the local area and how site renwbrim aanities will irnpact them; and (e) pnnide the last three annual reports doc 1--g the rmits of the Oahing envinmmental monitoring progmm.

KMC Response: (a) - Between 1980 and 1990, the population of Payne County dropped from 62,435 to 61,507, a decrease of 1.49 percent per year (Charlet,1992). 'Ibe population arimare for Payne County for 1998 was 65,109 which conwinna an increase of approximately 0.75 percent per year. Ihe merimarad 1998 population of the state of Oklahoma is 3,346,713. 'Ihe 1990 population of Oklahnma was 3,147,088.

l Over 11 pescent of Payne County's 1990 population of 61,507 livul in O=hing, the second largest town, and 60 percent lived in Stillwater, the largest town. 'Ihe remaining towns located within Payne County had populatinns that totaled 7 percent of the county % pel=*ian The vernainder of the County's pop l. dos,22 percent, lived in rural areas outside of towns. 'Ibere were a total of 27,381 housing units located in the county in 1990. Most subdivisions are small, with small lot sizes and average roads. Sales of existing homes are slow and the rate of new construction is slow.

Payne County does not have a zoning ordinance or a land-use plan, but does have subdivision regulations.

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Pa=nm== to Request for Additional Infonnanon KMC Cushing Site D w-hiomng Plan Much of the economy of the county is derived from govemment activities and higher education (Oklahoma State University). Payne County has approximately 1,110 farms, averaging 283 acres in size. The vast majority of these farms produce hay or wheat, and graze cattle between plantings. 4,614 businesses were registemd in Payne County in 1992, not including self-employed persons, such as farmers. The Cushing facility remediation effort involves,an average of 60 workers and is therefore expected to have minimal socioeconomic impact on the local community.

Transportation in Payne County is primarily by road, although there is I rail line that passes through the county. The Oi=hing facility is served by State Highway 18. 'Ibe site is located near the intersection of State Highway 18, which runs north and south, and Deep Rock Road, which runs east and west. Avenge daily traffic counts at this intenection reveal that about 1,500 to 2,000 vehicles use State Highway 18 per day, and about 200 to 300 vehicles per day use Deep Rock Road.

Health care facilities in Payne County include a hospital in Oishing and 2 hospitals in Stillwater.

One airport in Oiching serves small airplanes and the Stillwater Municipal Airport in Stillwater serves commuter airplanes. 'Ihe county does not have any military reservations, but does have a state prison.

(b) - A portion of the Oimhing site is dedicated to crude oil storage and pipeline operations. KMC sold these operations to Notti Gathering Corporation, Inc. (now Dynergy, Inc.) in 1995. As part of that sale, the north tank farm, south tank farm, and a small area enntaining the site office buddmg (Building A-9) will be transferred to Dynergy after NRC has terminawl license SNM-1999 arvi DEQ has approved the final cleanup of the refinery site. 'Ihese areas are shown on M-h #= C.

'Ihe south tank farm is conrained within Unaffected Area 2, but the remaining areas Dynergy will acquire are in areas that require survey and/or dannmminciomng for release.

The rernaindar of the site will remain under KMC ownership. Portions of this property will be noted in the deed as containing industrial waste (such as the acid sludge disposal cell). KMC has no plans to develop or sell the remaining property and expects it to remain fallow.

Shallow groundwater is not and will not be used for drmking water. DEQ has agreed with this position in a leuer to KMC dated knaamher 19,1997. Dynergy and future mapants of the pipeline properties shown in Attachment C, as well as surroundmg neighbors, will continue to have drinking water supplied by public water systems.

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1. s' (c)I e Phase I Rangeshal Investigation Report. submitted to DEQ in Apni,1993, states, " Rare, lh threatened, or endangered species are nehber documented nor anticipated on the Site (Butler,

,1990)". 'this is stiu the case.

(d) 'Ihe only @M historic and/or archeological site ima M in or around the city of Cushing is the O=hiag Armory, located at 218 South Uttle Avenue, over two miles from the Omahing remndiarinn. site. 'Ibe O=hia: Armory is listed with the National Register of Historic Plams and Page 5 of 21

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Re to Request for Additional Information KMC Cushing Site Decomminaioning Plan with the Oldahoma State Historical Preservation Office. Dammmimmioning activities will have no affect on this facility.

(e)- Armual envimamental results fmm 1996,1997, and 1998 are included in Attachment D.

Results for gmwde, anface water, vegetation, and soil samples, which are collected on an annual basis, are provided as Anschment D-1. Envimnmental air samples are collected on a weeldy basis, and envimurneraal air iranJE=4 data for the three year penod are provided as Anachment D-2. Environmental TLDs are analymd on a quartedy basis, and quartedy data for the three year period are p.44 as Attachment D-3.

NRC Sute Decommissioning Pier Reguest #2: Section 2.2.3.3 - In this seaion, you indicate that rqfinate may haw been disdarged into a unstepond. Provide site location of this unste pond.,&'

Was this unstepond 6araderized? Ifso, pmvide a discussion ofresults. Ifnot, pmvide justipoationfor not damcterizing this area. In addstson, pmvide the site location ofany unste or retention ponds that uere in aistencefrom 1963 to present. Were theseponds orpreviouspond locations chamcterized? Ifso, provide a discussion ofresults. Ifnot, pmvidejustipcationfor not chamderizing these areas.

KMC. Response: Section 2.2.3.3 states that historical desmenen provide conflicting accounts of raffinate disposal. One Atomic Energy Cammi= ion (AEC) document states that raffinate was discharged into Skull Creek, and another AEC dmiment states that raffinate was discharged into a waste pond. Several former employees were questioned about this disusy.iicy, and they believe the,4.

ce to disposal of raffinate to a waste pond is incorrect. 'Ibe former employees recall that the only waste water discharged 'o a waste pond (Pit 4) came from the thorium pmcess, and that raffinsee from the ura Gum process was discharged duectly to Skull Creek.

Attachment E is a site map showing the locations of all impoundments that were present on the site between 1%3 and the time the refinery closed in 1972. 'Ihe drawing shows the locations of former tank dikes, since they coukt have formed imamadmaata. All property underlicense will be surveyed in accordance with the du--.....M *.g plan. The only impoundments created since the refinery closed were constructed in unaffected areas for acidie water treatment and dird rge.

'Ibese areas were released fmm license in Arrendment #9, dated May 5,1999.

NRC Site Deaommissioning Pier Reguest #3: Section 2.2.4.3 - In this section, you indicate that routine dusdargesfmm holding tanks occurred and thoriwn low-level unste uns buried north of W Deep Rod Road. Pmvide site block locationsfor these areas. Also, pmvide a dismssinn related to the disposition of the holding tanks, incimimg the locations of these tanks.

KMC Regponse: Historical air photos of the O=hiag site show several small tanks located in the nonh of Skull Creek and appros;... cly 100 feet east of the thorium process building (Building 31).

' Ibis area is arrently mumminnd within RMA-10. These tanks were removed sometime between the time the refinery closed in 1972 and Apn!,1979, when an air photo shows the tanks were no longer there.

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U Responses to Request for AdditionalInformation KMC Cushmg Sire D==missionmg Plan

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'Ibe low-level waste buried south of Pit 4 and north of Deep Rock Road (Blocks 60 and 72) is addressed in the second bullet item in Section 3.3.8 of the SDP.

NRC Site Deu..-. 'camnine Plan Fam*ct #4: Sedian 3.2.2.3 - Sqpplement the discussion provided under the topic headmg Maximan Radioaaivsty with the background mnges you identifedfor the nxvious indimwiw materials in soil and exposure mies.

i KMC Response: The site background numbers for soil activity concentration and exposure rate are 1

tabulated below.

Soil Volumetnc Activity U-235 pCi/g U-238 pCi/g U-234 pCi/g Th-232 pCi/g Maximum value 0.16 2.39 3.90 1.43 Minimum value 0.00 0.73 0.00 0.60 Average 0.06 1.59 1.30 1.13 Ntimher of namnies 54 54 54 54 Nose: U-234 is c=MarM based on the meaniral ratio of U-238 to U-235. Source of data is Appendix C to " Final Pad =mn Survey of Four Unaffected Areas of the Cushmg Refinery Site -

April,1995".

Exposure Rate 12xilum 19 (pR/hr)

PIC (pR/hr)

Max value 9.0 9.4 Muumum Value 6.0 7.6 Average 7.3 8.5 Number of Measurements 33 33 Nose: exposure rases was meessed at 33 locanons using both a Landium Model 19 and a Reuser h*rm Model RSS 112 pressunand ion chamher. Source of data is Table B2 of Appendix B to " Final Radi= sum Survey of Four Unesecsed Anus of then=hmy par==y Site - April.1995".

NRC site Dn.__ 'cchurine Plan P==*ct #5: Sedion 3.2.2.5 - In this sedion, you proposed rasocaive limits)br debris and rubble. For material that will be surwyed eitherfor swface antaminadan oras debris andrubble: (a) provide the minimum size of the matenal specimen n-below uhids surface maxsurements would be considered impmaiaal and the material would be treatal as debris or rubble; (b) indioxte whether the potential antamination isfrom alpha, beta, or gamma type sources; (c) justify why direct exposure measurementfor gamma mdiation with a pR meter is suitable instead of volumetric and surface adivity limits: (d) provide volumetn'c amantmtionsfor licensai material that will be correlatai to the proposed debris and mbble limit of theproposai enposure mte limit of two times the maximum background; (e) provide the tedsnical basis)br this correladon; and y) enpand the hwcchm to srgpport the exposure-only pathnay assunp*m.

KMC Response: (a) - When debris and/or rubble has flat surfaces for which surface contamination wks, surface contamination measurements will be utilized. However, the mesmrements are r decision to utilim surface mremminatinn memmiements for debris and rubble is not based strictly on Page 7 of 21

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Responses to Request for Additional Infonnation KMC Cushmg Sire Deconunissxxung Plan l

the size of the material specimen. Partially crushed and hk=6g dnuns, coils of barbed wire, contorted metal in which voids are fdled with asphaltic hydrocarbon, pieces of brick, and other debris which KMC will encounter at several locations do not provide the " broad" flat surfaces for which surface contarninstion rrmanements are appropriate.

l Field conditions also affect the appropriateness of c Mag surface contamination measurements.

If one 18" X 18" piece of brick wall were discovered in a pile of broken brick, it would be sensible l

to deal with it in the same manner as the rest of the pile. However, if the same size piece of brick f

wall were discovered whde excavating soil, it would probably be practical to use surface nnntaminatinn memmuernenen to survey this piece of wall. KMC believes it is reasonable to both material hanrfling and nantaminant measurement methods on a case-by-case basis. 'Ihis is i

reasonable hacanae this debris will not be used in the future in accordard with the exposure f

i scenario for which surface contamination limits were derived, and the application of surface d

contamination limits to this material is questionable.

(b) - The potential contamination on this rubble / debris could be any combination of uranium and thorium, depending on its location on the site. Therefore the emitted radiations will be alpha, beta, and gamma.

(c)-(f) - KMC anamnead to develop a methodology for segregating material haeeri on micro-R mensimnenen when volumetric or surface contaminarma measurements are not appropriate or technically defensible. Using MicroShield, KMC was able to provide technical justification for l

such a method when the only contaminant is thorium. However, the method is not feasible for uranium. KMC therefore submits as Attachment F revised pages from Section 3 of the SDP.

L Section 3.2.2.5, which y,d the proposed nmairement method, has been deleted. hanan 3.3.3.1 and 3.3.9, which addressed the decommissioning of matenals using the proposed method, have been revised.

j In RMA-11, where a large quantity of solid waste is mixed with contarninsted soil-like material, KMC will sample the soil-like material captained within the debris and rubble addressed in these sections. In a May 20,1999 meeting with NRC, KMC agreed that if the soil-like material contains licensed material, the entire vohnne (including brick, steel, and other matenal) will be considered to exaed the dammminainning criteria, and will be excavated and shipped to a licenaerl disposal facility. Should KMC develop a better method for Ldag the vohnnetric activity of such i

maserial, KMC will propose this alternate measurement method as a license amendment request.

NRC Site Decommissioning Plan Request #6: Section 3.3.5 - Corfrm that buildings whether TV "q(eded" or not that are going to be demolished or will remain onsite will be surwyed in acooniance with the gsddance pnmided in NUREGICR 586, and the results will be included in the jfnel surwy report. Vthese besidings or strudures were not sunwp. in accordance with this 1

guidance, pvAdc basis)br not per)brming these surwys. JustVy cutting strudured steel building members bejbre surwying them, asproposed during demohtion of both Buildings 30 and A-6.

Just$aaaion should include a discussion why you cannot surwy these building,2,kis before cutting and is this proposal cornsidered ALARA ? Cor$rm that the slab seasoning process will result in slab sections ofsufident size to allow surface surwying. Also, provide basisfor not surwying in Page 8 of 21 l

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Responses to Request for Additional Informanon KMC Cushing Sire Decomnussionmg Plan buiMing 30)Irstpoor slab before sectioning the slab. Finauy, darVy if the SNM Stomge Building is part ofBuildiq 30for decommissioning purposer. Nord in Seaion 2.3.4.3, there are still areas dsat need to be deaned to the unrestrictd release limit. Yet the SNM Storage Building is not disassd in Section 3.3.5, Site Buildings. Was any radicadive material used or stored in Building 317 What buildings haw raducadive materials storalin them now?

KMC Response: All final status nuveys for any buildings or agai==nt that will remain at the Odian Facility aAer license tennination will be cordered in ac ner.cc with protocols described in DraA NUREG/CR-5849. Survey records relating to haildiaga or a=ipment that will remam at the Oding facility after license termination will be included in the final status survey report.

Building rubble r hian from demohtion, as well as a=ipment and other material that will not remain at the site, will be surveyed in accordance with NRC's " Guidelines for Dmammus.aion of

? ament Prior to Release for Unrestricted Use or Termination of Uwamas for i

Facilirian and E Byproduct, Source, or Special Nuclear Material" (1987) (Guidance Directive FC 83-23). Such survey records will be maintainsi in site files, but will not be included in the final stann survey report. 'Ihis is in au.vidence with a letter from NRC to Kerr-McGee Corporation dated April 23, 1999.

Surveys were previously performed on accessible building surfaces and areas in accordance with NUREG 2082. As proposed in Section 3.3.5 of the Oiching Facility Deramminioning Plan, Odiag personnel plan to cut structural steel members and section concrete slabs located in Buildmgs 30 and A6 prior to performing final surveys. This is due to the fact that contamination could potentially be located on portions of the stmetural steel members that are inaccruible in their current configuration and in cracks and crevices located on the concrete floors.

'Ibe cutting and removal of structural steel members and the aaetianing of the concrete floors into slabs will be performed in accordance with approved Special Work Permits (incorporating ALARA principles) and will ensure that all structural steel member surfaces are surveyed and/or dannnemminased in accordance with proposed dacammi alaaing criteria. 'Ibe concrete floors will be eartinnad into slabs (pieces) amall enough to ensure that such concrete slabs can be safely handled and/or manipitarad to support. -pt and thorough characterizarinn. The size of the concrete slabs (pieces) will be sufficient to allow KMC to survey the surfaces to demonstrate compliance with proposed dacammianinning enteria.

- Ibe SNM storage huilding is part of huiding 30 for dacamminaioning purposes. It was surveyed in accordance with NUREG 2082, as were the other buildings. As with hiilding 30, this building will be surveyed in accordance with FC 83-23 as it is dismantled, and the records of these surveys' will be maintainad on site for NRC inspection.

Radinactive material was pm, d in Buildmg 31, which was demolished in 1966. Iicensed material is s..Jy being stored in Buikhng A-6, Building 30, Building A-9, and the HP lab.

NRC Site Deamamissioning Plan Regpat 17: Seaion 3.3.9 - In this sesion you provided a diseuceinn oftheproposedprocess dsat will be used to ranediate burid rubble. Provide location (s) nerepotentiauy indi=4ve contaminated rubble is buried.

Pag:9 of 21

E i

Pe to Request for Additional Information KMC Cushing Site Decomnussioning Plan KMC Response: 'Ihe process for -unrni=ianing buried rubble will vary based on the nature of a

the rubble. Buried rubble may be found during subsurface investigations in areas identified in Sections 3.3.1.6 (burial trenches), 3.3.3 (trash dump), 3.3.6 (former process buildings site), and t

3.3.8 (miarellanenne areas) of the SDP, 'Ihe method for determining whether that material complies with de=amianianing criteria is W upon the nature of the material, as diernaaed l in the response to Request #5. For example, if the " rubble" consists of bmken chunks of brick, M concrete block, and soil, the most appropriate method of survey may be to crush the maternal and mamane the degree of contamination volumetrically. If the " rubble" consists oflarger pieces of material with relatively flat, accessible surfaces, the most appropriate method of survey may be to measure potential surface contamination.

NRC Site %.... '"h=xine Plan Reauest #8: Section 3.4.2 - NRCdoes not allow dilution of

\\

r Mw materialin lieu ofdecommissioning arats which do not meet clean-yp aiteria. Note that NUREG/G.5849, Senion 8.5.3 rea,,,..x.ds that Vthe exposure rate acceds tw times the guideline value, the area should be remahated and resurwyed. Also, pmside a description of the methods that will be used to eranate and transport radioactive contaminated waste that will f

minimize the potentialfor spreading contamination.

ry',g jQy KMC Rema; KMC anticipates that exposure rate measurements will exceed 10 pR/hr above

. j /p.

o background (h-....i= inning criterion for exposure rate) only when the underlying soil exceeds volumetric decommissioning criteria. If extemal gamma measurements exceed the exposure rate i'

criterion, an investigation will be performed to identify the source. Gamma scans will be q

performed to identify areas in which additional sampling will be required.

l:

KMC will neilire engineering controls to minimize the potential for spreadmg contamination during transport. &=mnian of engineering controls include wetting dusty material, stabilizing oily maserial, or using covers or other forms of contamment while transporting ori site. Intermodal enneminers will be covered so as to prevent loss of licensed material during transport to the disposal site.

NRC Site M._. *=L a--= Plan R="mr #9: Sectum 4.1.1 - Describe the e antit performed by the v,;(

independent corporate-based Envimnmernal, Health, and Sqfetyfunaion. Also, prmide the qualffaation of thepeople to pdforming this audet. Is the purpose of this audit conpliance with 10 CPR Part 20? Also. provide a description ofwhat actions wuld be taken by the Quality Assurance (QA) Coordinator ifprogram de)Iciencies arefound to exist.

KMC Response: A curpvue auditor audits the O=hing facihty on an annual basis. 'Ibe scope of the corporate audit will meet the requirements of 10 CFR 20.1101, but may include other topics at the direction of corporate management. Currently, the corporate auditor is a Certified Professional Envirnamental Auditor experienced in audning envimamenemi, health & safety, and radiation safety programs at a variety of company facilities. 'Ibe corporate avhrar retains appmpd.e. y qualified rechnical professionals when technical aspects of a program are audited.

Page 10 of 21

Pr to Request for Addninnal Infonnsdon

}

KMC Custung Site Decnmmiazioning Plan

'Ibe animal corporate radistion safety program is only one of numerous audits perfonned at the Cushing site on an annual basis. The site Quality Assurance Coordinarnr (QAC) participates in the rweintinn safety program audit with the corporate auditor and receives a copy of the audit report.

'Ibe QAC initiates Non-Conformance Reports and/or Corrective Action Requests as appropnate as a result of audit findings and tracks action items through camala+ inn 'Ihe QAC provides monthly reports on progress by responsible personnel who are addressing action items to the project manager and site manager.

NRC Site IW._ %i--, <4 Plan Ranuct #10: Seaion 4.1.4. - Provide a statement that the RSO has authonty and raponsibilities to stop ongoing wrt adivities, should he or his stqtfobserw rascicgically sougfe workpractices. Also, revise Figure 4.1 to show the RSO. The RSO should f report to an organizational manager at a lewl that will insure independent safety reviews are conducted.

KMC Response: 'Ibe RSO has responsibility to ensure that work is performed safely and has mahnnty to stop work. Figure 4.1, the " Cushing Project Gis Jsmiion", makes a reference to a

" Staff Health Physicist". Mr. Terence M. Moore is the Ruharion Safety Officer as listed on the NRC license and canies the title of Staff Health Physicist. The RSO (Staff Health Physicist) reports to the site manager, who is responsible for all health and safety, radiation safety, environmental operations, environmental compliance, and quality perfonnance on site. Awhment F includes a revised Figure 4.1 with the titic, " Radiation Safety Officer".

NRC Site Dw--

"==!--.,q Plan R=="ct Ill: Sedian 5.1.2. - Provide the basisfor concluding f that radiocaMty is chemically)lxed within narious matrices and considered insoluble. _ Haw any f

tests bem corwheral to demonstrate that the materials are iruoluble? lfso, provide the results.

yI%g.-

For urine and non-routine bkwnscay sanples what laboratory will be usedfor bioassaying work?

What is the sanple colleaion procedure recommended by the certified laboratory analyzing the sanples? Is the i+-

2'='sanple cMmfrequency monthly? Do you haw colleaion proceduras? Is there a baseline analysis conductedJbr ends individ arl before working in airborne adinity areas? See Regulatory Guide 8.9. Also, describe the criteriafordetermining air sanpling monitoring locationsfor monitoring worter intake and airborne q0!uent around areas when decommissioning activities are in progress. Also, cor$rm air sanpingfollows NUREG-1400 rw:'A=3 and Regulatory Guide 8.25. What is thepwposed trigger or anion Lewl? Also, is there a trigger lent orprocessfor determining uhen an individual is required to wear Personal Procedin Equ& ment? Ifso, what is the trigger lew! orprocess? Ifnot, providejustificationfor not having a triggerlewlorprocess.

KMC Response: For the three uranium isotopes, the Class Y All is the most conservative of those listed in 10 CFR 20; i.e., if KMC tested these wastes and was able to justify Class W or Class D, the calculasal exposures would decrease. For thorium (both 'th-232 & 'Ih-228) Class W is the most ennamvative. KMC will either collect the appropriste samples of waste materials to determine the actual solubility class, or cxmservatively assign exposures for uranium assuming Class Y, and for thorium assuming Class W.

Page 11 of 21 i

Re to Request for AdditionalInformation i

KMC Cushmg Site Decomnussioning Plan KMC cunently plans to use Thermo NUtech in Albuquerque, New Mexico for the analysis of bionssay samples. KMC has contracts with several other internally approved labs and may change labs at KMC's discretion. We r~=Wai input fnun Thermo NUtech on the eniMian of bioassay samples, and were advised of two pnmary requirements: a minimum sample volume, and the absence of sample preservative. These two requirements were irunen.eM into the site procedure for binammy sample collection.

The collection frequency is neither monthly nor periodic, but is driven by action levels stipulated in NRC Iiwnne Condition 11 D. The license requires urine analysis for uranium isotopes when air samples yield >40 DAC-hrs for a single air sample or > 100 DAC-hrs accumulated exposure for any one worker. It requires fecal analysis for thorium isotopes when either acute or chronic exposures exceed 100 DAC-hrs.

The KMC Oneit site does not cunently have any Airborne Radioactive Areas. KMC does not routinely perform baseline bioassays prior to an individual's initial entry into a Radioactive Materials Area.

Regulatory Guide 8.9 "Acc@bk Concepts, Models, Equations, and Assumptions for a Bioassay Prop.iu" states the following:

"Bionssay services should be available if the types and quantities of radioactive material licensed for use at the facility could, under normal operational occurrences, result in airbome levels in normally occupied areas exc=iig DACs. Provisions should be made for the collection of appropriate samples, analysis of bionssay samples, and evaluation of the results of these analyses to determine intakes."

i "Binanny measurements used for der===. dug compliance with the W nnat done limirs should be conducted often enough to identify and quantify potential exposures and resultant intakes that, during any year, are likely to collectively exceed 0.1 times the ALI."

"An individual's baseline measurement of radioactive matenal within the body should be corrhartM prior to initial work activities that involve exposure to radiation or radioactive materials, for which monitoring is required".

The KMC Oiaig site does not cunertly have (and does not anticipate) any nonnally occupied i

areas with airbome levels in excess of 1.0 DAC and does not anticipate potential exposures 5 1 tunes the All. KMC does not anticipate that decommissioning activities will trigger e==~ii 0

the 10 CFR 20.1502 requirement for monitoring. Based on 10 CFR 20.1502, in conjunction with Reg. Guide 8.9, KMC thus does not perform routine bioassay measurements or baseline bionssays.

KMC generased an intemal Technical Evaluation evaluating the potential for generating airbome radioactive maserials during projected work activities at Pit 4. The evaluation inviica M that this aren should not be considered an ARA and that respiratory prrwe would not be required for i

those work activides evaluated. KMC plans to update this Technical Evaluation prior to Page 12 of 21 N

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Ra==== to Request for Additional Informanon KMC Cushing Sire Decomnussioning Plan l

cornmencing work in other areas. KMC will continue to perform wublia air sampling in accordance with Ilrenna Candaian D, and to validate this technical evaluation. Air sampling will ennrinne to be the primary methodology for measuranent ofinsemal exposures. KMC will rnmintain binamany services, as necessary, to implement the nxtuirements of License Condition 11 i

D. However, as long as anenpatinnal exposures are below the monitoring requuements of 10 CFR 20.1502 and Reg. Guide 8.9, KMC will not perform any baseline, periodic, or termination bionssays.

KMC maintains three envimnmental air samplers that collect samples over an appmximate seven-day period. 'Ibese are currently located near the Dynergy petroleum tanks north of Deep Rock Road, at the northeast corner of the site, and in the southeast portion of the site. 'Ihese locations may be d.sc41 as appropriate.

In addition, KMC will place area air samplers downwind of daenmmiccioning activities in accordance with license Coadi*ian D. 'Ibese area air samplers will be placed downwind of the work and will be located as close as practical without interfering with the work. Lapel samplers will also be used in imendars with license Condition D. Lapel samplers will be issued to the potentially maximum exposed individual and to others as deemed appropriate.

Regulatory Guide 8.25, Table 1, " Air Sampling RacnmmeMatiana Based on Estimmed Intakes and Airborne ennnantrations" recommends that for work areas where the estimated intake is less than 0.1 ALI, and the enrimarad airbome concentration is greater than 0.01 DAC:

"Some air sampling is appropriate. Intermittent or grab samples are appmpriate near the lower end of the range. Continuous sampling is appropriate if concentrations are likely to exceed 0.1 DAC averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or longer."

KMC expects workplace cannantrations to stay below 10% DAC averaged over forty hours, and KMC expects mar==1 worker intakes to remain below 0.1 All. KMC will comply with the specific recommandarian above and other racammendariana within Table 1 of Rega'*wy Guide 8.25, should workplace nandwinna change. As stated on page iii of NUREG-1400, "NUREG-1400 is not and should not be used as a regulatory compliance document... NUREG-1400 is a technical resourm for the liremar to use to obtain technical information when 'mformation is wantad." In keeping with the irsent of NUREG-1400, KMC intends to use NUREG-1400 as a resource i

anemnant.

1 KMC currently uses the serian levels of 0.5 and 1.0 DAC. At 0.5 DAC, KMC will perform an

]

evalumrian to determine what dust suppression measures were in effect and what additional measures should be implementad, if any. At 1.0 DAC work will be stopped until conditions are changed to prevent a reoccurrence.

J KMC issues respiratory prn*~*ian ~=ipmaat (RPE) at the trigger levels established in 10 CFR 20.

Aher engineering and administrative controls, RPE is required when entering Airborne Radioactivity Areas, defined as areas with concentrations greater than 1.0 DAC, or where intemal exposure could exceed 12 DAC-brs in a week (30% DAC). As emp'd =d in Response 11 (b) l Page 13 of 21 U

c Responses to Request for Additional Information

(

KMC Cushing Site Decomnussioning Plan

)

above, KMC does not expect to use RPE for radiological prwetian during Pit 4 dammminionmg activities, and will update the Technical Evaluation as nece===ry prior to working in other areas where the work and radinarrive source terms are substantially different fium those in Pit 4 dwou.uissiv ug.

1 NRC Site Deaommissioning Plan Request #12: Section 5.1.3.3. - Describe theprocessfor dt.,,,:,.l,ig Vtheproposed aaion limit of 0.5 DACis readunifor a speapc isotope when

,j; ud, g

A+x... cd--,'.g work is beingperformed. How will this ensure an individual's exposure will not ~

exceed TEDElimits?.

gC KMC Response: KMC analyzes both lapel and area air samples approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 14 days after sample calletian= ne first analysis is performed to check for any non-routine or I

unexpected sesult. De second analysis is performed to dacument final sample activity after l

allowing for naturally occurring endon daughter decay. De first analysis could easily exceed 0.5 l

DAC (even 1.0 DAC), if activity fmm the radon daughters were aanmed to be fmm D-232.

Nonetheless, based on past expenence as to the expected contribution of radon daughters to the 12-hour analysis, KMC finds this first analysis useful as a screenmg tool; i.e., to indicate when radiation exposures may be high relative to normal variability. Only the second analysis is needed to comply with the provisions of Regulatory Guide 8.25. KMC may place an air sampler upwind of work activities to use as an informal radon "hackgmund" when reviewing results fmm downwind sampiers.

De TEDE limit will not be erceeded due to the expected airborne concentration levels. KMC l

expects workplace levels to remain below 10% DAC when averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. Regn1*ary Guide 8.25 " Air Sampling in the Workplace" renmmande that in situations where there is a potential for intakes to exceed 40 DAC-hrs in a week, air samples should be analyzed promptly on a daily basis. Dere is essentially no potential for intakes to exceed 40 DAC-hrs in a week at the work site. KMC does not expect this to change when decornmissioning activities begin, based on the limited radioactive sousee term and the types of work activities involved. KMC will continue to monitor the workplace using air sampling and will change the pmgram accordingly if there is a si,A.E change in workplace concentration levels; i.e., e-ling 10% DAC averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. KMC will conrirmie to analyze lapel and area air samples using the tehniana described l

above.

NRC Site Decommissioning Pian Request #13: Seaion 5.1.4. - Provide thefollowsng irgformation related to dse calibmtion ofmonitoring/ survey instruments: (a) conprm that calibmtion of these instruments will be pw,jM;.;i with standards traceable to the National Institutefor Standards and

• f,, ;

Testing; (b) provide a disassion on howportable instruments will be stored and maintained: (c) V f

these instruments are oahbmted onsite by Kerr-McGeepersonnel or contmctors, provide the qual $0eaion requirements)brpwiw.,,el to perform this task, a list of the tmining required to be qual $ed to per)brm this task, and a list ofsources and quantities used: (d) provide a &cd'=s on the servicer ofofste lahomtories to be usedfor either normal sanple analysis, orforproviding l

quakty assummor cross 4aecks; and (e)for instrument daeds perfwz.;i on a daily basis, duscuss Maat aadons will be taken Van adverse trend is observed; e.g., is the instrument taken out of service ygreater than plus or mhsus 20 percent deviationfrom a "repmduable soume. " You Page 14 of 21

1 Responses to Request for Additional Infonnation I

KMC Cushmg Sire Decommissioning Plan hadicate in Table 5.1 that the MDA for the Nal multidennel analyzer is being enlaated, pmvide the results ofthis enluadon. Corgffrm that the report Milinclude dri-squared tests and data.

KMC Response: (a) - Monitoring / surveying instruments are calilxated using NIST traceable mandards. Gamma scanning instruments are energy calibrated with a non-traceable Cs-137 source

'g~

(traceabihty is not required because the source strength is not relevant to the enerEy calibration).

De gamma scanning instruments to be used at Pit 4 and at the disposal cell are also source calibrated with NIST traceable %-232 slab sources cuni Mig appmximately 10 pCi/g of h-232.

y) {#

(b) - Portable instruments are stored within the health physics lab, and are maintained in designated storage areas, depending on their operability status, i.e. calibrated instruments are stored separately og fmm uncalibrated and/or out-of-service instruments.

(c) - Individuals must arceufully qualify using the site Qualification Matrix system for the calibration of these instmments. De individual must penonally demannrate his/her ability to calibrate the instruments in resord.ru with established procedures to either the RSO or the H_

Physics Specialist. His involves actually calibratmg the instrument, completing the data records,

'arut answering questions fmrn the reviewer. Qualifications are then ncomerwad in the individual's a

qualification file, and are available on-site for inspection. De portable instruments and their sources are as follows:

Instiwnent Source (c)

IJudhnn Model 2224 w/ mo. 43-89 NIST traceable Alpha source-3-230,184.6 alpha / beta sciritillation probe Bq. NIST traceable Beta source-Sr-90/Y-rahhrated on-site 90,788.1 Bq IJudium model 2221 w/ mo. 44-10 NaI 2x2 Non-traceable Cs-137 source used for the crystal, and mo. 44-82 NaI 3xl/2 energy cabbration; NIST traceable B-232

]

Calibrated on-site slab sources,10 pCi/g, used to calibrate for field response for the 2x2; the 3x1/2 detector is calibrated for gross count rate.

Ludlum Model 19 nucm R meter Calibrated off-site at Imdlum, using their Cah'hrated off-site standard pmcedures and NIST traceable i

mandards.

Reuter-Stokes pressurued ion chamber Cahbrated annually at Reuter-Stokes using Calibrated off-site their standard procedures and NIST traceable standards.

(d) - Dermo NUsech in Albuquerque, New Mexico is KMC's primary off-site lab. It analyzes KMC's annual envirnnmeraal surface water, ground water, vegetation, soils, and bianuay samples. KMC is not curraitly using any off-site lab for quality assurance cross-checks.

T i

(e) - If an instrument is outside of the acwpiare range of +/- 10%, the calibration sticker is removed and the instrumant is taken out of service. When a anticeshle trend is discovered, but the instmment is still within +/- 10%, the technician notifies the RSO or his 4W so an evaluation can be performed. If the trend is==aW or une='M he instmment may be taken out of t

Page 15 of 21

Responses to Request for Additxmal Information KMC Cushing Site Decomnussioning Plan service. The MDAs for the onsite MINAXI soil counter utilizing CUTRANL software have been determined and are as follows for 5 minute and 20 minute count times:

l MDA,5 minute count MDA,20 minute count Isotope pCi/g pCug U-235 0.6 0.2 U-238 6.7 3.5 7

Th-232 1.0 0.4 Ra-226 1.4 0.4 KMC does perform chi-squared tests. The results of all QA/QC tests will be mainaineri on site for inan~ rian by NRC, but will not be submitted in the final status survey report. All final status data will be included in the final status survey report.

NRC Site Decomminh=rine Plan Pmmt #14: Section 6.4.3.4. - Pmvide thepercentage of /)[

j surfaces that will be samnedfor waafected areas.

~

KMC Response: There are no more land areas designated as unaffected areas. Consequently, the only " unaffected areas" that remain on site are those portions of buildings that will be used after j

license termination that have not received licensed material. Section 4.2.3 of NUREG/CR-5849 i

states that scanning of unaffected stmetures should cover at least 10% the floor and bottom 2 meters j

of walls. KMC will perform scans covering at least 10% of these areas.

KMC has classified land areas remaining as either affected antas or undesignated areas. In May, 1996, KMC submitted a final survey report for the haul road corridor. In its August 8,1996 crun==en on the final survey report, NRC noted that the survey of this area was not consistent with either the unaffected area survey nor the affected area survey methods r==n* in NUREG/CR-5849, and requested the rationale behind the survey rnethod uned. In an August 30, 1996 response, KMC described the rationale behind this type of survey, noting that 100% of undraignarert areas are scanned. In a letter dated October 22,1996, NRC approved the survey report KMC plans to survey undesignated areas in the same manner as the haul road corridor, i-W 100% coverage with scanning instruments.

i MC Site L'-

'"Ir inz Pfan Pw==: #15: Section 6.6. - Provide a discussion of what is meant by the wonigenerally in the statement, "Reportformat and content will " generally" follow the f'"

via..:%n contained in NUREGICR 5849. " Confirm that the Ckshingfinal survey report will include inkrmation in Okqpter 9 ofNUREG/GR-5849.

KMC Response: A,'=adiv D to NUREG/CR-5849 provides an eramale of a sample final survey report. This sample report does not include discussion of all the topics listed in Chapter 9 of NUREG/CR-5849. Aww&#y, KMC will " generally" follow NUREG/CR-5849 by providmg information on all the topics listed in Chapter 9 that are r=dert to verify that the site complies with the demnunisminning criteria.

Page 16 of 21

Responses to Request for Additional Infonnation KMC Onhing Site Decommissioning Plan Chapter 9 of NUREG/CR-5849 states, "... sufficient information and data should be provided to enable an independent re-creation and evaluation at some future date of both the survey activities and the derived results. Much of the information in the fmal status report will be available from the 4x-i.iiissioning plan; the written survey plan..." It also states that, "certain suppon or related informadon related to the decommissioning pmcess,... are pmvided as part of the 4x-iiinioning plan..." Chapter 9 then presents a list of topics that, "... the licensee may also incorporate... into the final status survey repon". Several of these topics have already been reported at length, and some are not relevant to the final status of the site. For instance, KMC has already reponed on:

1. the processes performed and waste disposal practices employed while under AEC licenses,

2. the results of a site-wide characterization survey (which are not relevant to the final status survey), and

3. the results of final status meys of the unaffected areas and the haul road corridor.

Including this information in the final status survey repon would make it needlessly voluminous and confusing. This infonnation will be incorporated in the final status survey repon by reference.

Reporting only that information that relates to the final status of the site and which has not already been reviewed multiple tunes will not only make the report more understandable to NRC arxl the public, but also should expedite the review of the repon. For example, discussed in the KMC Response to NRC Decommissioning Plan Request #6 (above), the results of surveys performed on buildings that are dimuntled during decommissioning will be retained on site, but will not be_

included in the final survey repon.

/

m,,oc

./

v 7

KMC intends to repon the background, site description, decomnussioning activities, fmal sur,,vey procedures, survey fuxhngs, and a sumndry in accordance with the outline pmvided in Chapter 9 of NUREG/CR-5840 'Ihis will pmvide the information needed to recreate the fmal survey and evaluate the survey results.

NRC Fwlinrinn Safety Plan Reauest #1: Section 2.4. - For unrestricted areas, you stated the dose

, )/ " 'f will not etceed 2 mrem /hr. Do you also establish a trigger level at any lower dose rate if the typical measurements are 0.002 mR/hr in unrestrided areas, or how do you ensure that an individual is not presentfor more than 25 houn in a year at the 2 mrem /hr dose rate (10 CFR f

20.1302), so that they do not receive 0.05 rem in a year?

Y KMC Resoonse: KMC has performed extensive characterization surveys in the past in both restricted and unrestricted areas. Unrestricted areas of the site were surveyed using a Model 19 micro-R/hr meter at ten-meter grid nodes; most of these areas have also been scanned using gamma field survey instruments. Areas of the site that do not appear to meet Ax-iiniiuioning criteria are fenced as Radioactive Material Areas and Restricted Areas. There are currently no locations on-site (includmg RMAs) that approach the 2 miem/hr criteria of 10 CFR 20. Exposure rates in unrestncted areas are consistently at background levels. KMC has no work activities planned that would move licensed material into these areas that could potentially change the exposure rates. 'Ihe unrestricted areas are also contmiled as KMC site pmpeny, and only incidental unauthorized access is possible.

Page 17 of 21

p r

Responses to Request for Adchtional Informanon KMC Cushing Site Decomnussionmg Plan

'Ibe RSO reviews the results of the environmental TLDs each quarter for changes or anomalies.

KMC uses the trigger level of 2 miem/ hour from 10 CFR 20.1302. Environmental TLD results are included in Anachment D3. KMC has perfonned calculations to estimate public dose, and these are available on-site for i@ 'Ihese calculations show that the dose in tunsieted areas is far less than 0.05 rem per year.

NRC Purimr Safety Plan R==mr #2: Section 12.3 - Describe the radiation wrter tmining, &

length oftime, and topics. Also, describe the annual requalflaxtion tmining topics, length of /

t tmining, and how records are maintained.

KMC Response: Radiation worker training is perfonned once each year for those individuals who are designarad as radiation workers. The requalification training utilizes the same course and is aduGi;_.d each year after initial qualification. License Condition C requires that both the initial and the requalification course must contain the topics described in 10 CFR 19.12. The lesson plan encompasses these topics and is available for inspection on site. Training an= lance rusters,

@~I exams, blank exams, lesson plans, and student handouts are maintained in the QA file system at the site.

The actual length of the course is approximately one day; but varies from class to class. NRC's February,1997 cover letter acw.rpisying License SNM-1999 Amendment #6 stated that course content (not length) was the key factor injudging the %=ey of the racharion worker traming. An NRC L +9 report dated May 19,1997 stated that the scope of the radiation safety training is i

adequate.

DEQ Comment 1: KMC responded to DEQ's Comment #7 on the Gmundnoter Pathwys Wor 11 plan byproposing that the qgmdient wil (OfW-11.2) uns scmned in an intermt with numemus sandstone stringers uhile the donngmdient wits were all screened acmss intermis dominated by mudstones and shales. Disfaa accountedfor the obserwd wriation in umnium concentmtion betwen the y and donngmdient wils. Per wnwrsation with Sten Lawr, DiC Regional Hydrologist, the pgradient Lowr Vanoss wil should han been reported as CKW-11.3.

Howwr, 04W-11.3 reported mudstone andfossikferous mudstone with shellfmgments owr its scmned interml. Please elabomte or revise the text.

KMC Response: CMW 11.2 is screened in the upper Vanoss formation. 'Ihe screened interval includes several thin mandmane lenses. Most of the water obtained during sampling would have been supplied to the well by these mandonne lenses, since the mudstones have very low go.#1.ity. CMW 11.3 is wd in a deeper interval within the lower Vanoss. The screened interval is ammantially all rnmienne. Any water supplied to this well would be commg from navisinnen. KMC maintains that most of the variation in radionuclide concentration of groundwater samples is due to the formation in which the well is m.swd and the presence of sediment in the water sample. Formations with a higher clay content would be expected to provide more sedunent (with higher background concentrations of naturally occumng radionuclides) than more permeable (sandy) formations.

Page 18 of 21

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Responses to Request for Additional Information KMC Cushing Sire Decommissoning Plan KMC has revised the groundwater assessment secton (Section 3.5) of the Site Decommissioning Plan, and includes it in Attachment F of this submittal. 'Ihese pages should replace the corresponding pages in the Site D=wnmissioning Plan. This revision does not change the work proposed, but clarifies sampling activities associated with determinir g the range of naturally occurring radioactive nuterial in the groundwater, as well as those associated with identifying releases from source areas.

DEO Comment 2: Pumgraph 6, Seaion 2.4.6.1, pate N0 states: " Reported U234:U238 meios mngefmm 0.7:32 in gramdwater sanpiedfrom unter sqpply wells in the United States, with an arithmetic meer of 4.4 and standant deviation of5.2 (EPA,1985). " Please reference the page and pamgrqph monber uhere this conclusion is reached.

KMC Response: The citation is from EPA, Natinnwide Ocmrence of Pan and Other Natural Pdaetivity in Puhlic Water hnalies (1985). Table 3.13, on page 55 of the cited report, shows an arithmetic mean of 4.4 for the U-234/U-238 ratio, taken from samples collected from 2% public water supply wells. Figure 3.31, on page 56, lists a minimum U-234/U-238 ratio of 0.7 and a maximum U-234/U-238 ratio of 32.0.

DEO Comment 3: Pamgrqph 2, Section 2.4.6.1, page 2-20 states: " dferencesin the solubilities j

' of these tw nuclides (1h 232 and Ra 228) should yieldfar greater amounts of radium in the groundnoter than thorium. Typiaally, this dgerence is on the order of100 to 1,000 tunes more mdian than thorian (HEM,1985). " DEQ has reviewed the referenced document, USGS Water-Sypply Pqper 2254, andfa!!ed to locate the assertion. Please reference thepage andpamgrqph number where this conclusion is reached.

KMC Reqponse: KMC was also unable to locate the referenced statement in USGS Water Supply Paper 2254. 'Ibe armamment ermneously reversed the words "radnun" and " thorium" in the discussk,n regarding their ratios. In fact, on an activity basis, there are typl:: ally 100 to 1,000 times more thorium than radann in background groundwater, as explained on pages 148 and 149 of the paper, This is not inunadiately apparent hennae typical concersistions of radium are evid in picoCuries per liter, and typical concentrations of thorium are expressed in micrograms per liter.

'Ihe discussion of ratios of U-234 : U-238 and 'Ih-232 : Ra-226 presented in Section 2.4.6.1 was targeted at historical data and is not relevant to the propoeed gmundwater investigation. The referenced paragraph was deleted (page enclosed in Anehment F) and does not change the appropriatenens of the proposed groundwater sampling and data evaluation.

DEQ Comment 4: Season 3.5.2.1, page 3-30 discusses the seleaion of background wilsfor radiologiaalanalysis. These wells are illustmted in Figure 3.5. In addition,fourproposed backgrowed wells are dqpicted in thisfgure with a red triangle. Three of these wells are M "*j donagmdientfrom RMA-10 while an additional wilis downgradientfrom RMA-11.

Please clarVy the Apparent contmdiction or revise the text.

Page 19 of 21

o Rw to Request for AdditionalInfonnation KMC Cushing Sire Deconunissiomng Plan i

KMC Respanne: 'Ibe enclosed revised Section 3.5 of the SDP clarifies which monitoring wells will be sampled to develop a range for background groura:ws. and which will be sampled as upgradient and downgradient monitoring wells for each of the three RMAs.

DEQ Caament 5: Pdingraph 1, Section 3.5.5.4, page 3-38 states: ' Filters usedin this brmgigation will be stad to remow suspended materials Msile allowing dissolved and colloidal material to pass. " DEQ requires that a 5-micrwpiter be utilized in grwndwater sarrpie colledion. It has been 40c.=.x.:ed that a 5-micronfiter will screen most suspendedparticles while allowing mast colloidalparticles to pass through thefiter.

KMC Response: KMC will use a 5 micron filter to remove suspended material from groundwater samples.

AdditionalInformadon During review of the SDP, KMC recogmzed the need to revise Section 3.2.2.4, " Application of Radioactivity Umits to Subsurface Material". 'Ihis section was revised and is included in this submittal with the other changes to Section 3 in An-i.. w.: F. Changes to the original are shown in redline-stnkeout format. KMC's example of the application of radioactivity limits to subsurface matenal was not in accordance with the guidance cited in the section, so the example is deleted.

KMC has sought to be prompt and thorough in responding to NRC's ;W nns and comments on i

the Site D==nmi=ianine Plan (SDP). As the August 20,1999 deadline for appmval of dammmiminning plans under the Site Denmminioning Management Pre ii u nears, KMC s

emphnim the urgency of NRC's review and approval of the SDP. KMC requests a we ^ g with NRC during the week of June 14 through 18,1999, to discuss these r-ar=. If you have any questions or comments, please call me at (405) 270-2694.

Sincerely,-

JeffImx Project Manager xc:

C. L. Cain, Chief, Nuclear Materials Licensing Branch, NRC Region IV Blair Spitzberg, Chief, Fuel Cycle and Decomirdssioning B'anch, NRC Region IV l

Cushing Citizens' Cui.ight Committee Eadon Shidey, ODEQ Danell Shuhs, ODEQ l

1 Page 20 of 21

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Responses to Request for Additional Information l

KMC Cushing Site D-- - asionmg Plan Refer

• aces l

Charlet, B., M. Woods, C. Allen, and D. McVey, A Summary of Economic Conditions in Payne County. Oldahoma. Rural Development, Cooperative Extension Service, Oklahoma State University, April 1992.

The U.S. Department of Commerce Bureau of Census,

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I l

Page 21 of 21

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KERR-McGEE CORPORMION KERR-McGE E CENTER e OKL AHOMA CITY, OKLAHOMA 7312$

June 15,1999 Mr. Stewart Brown Imw-Level Waste & Decommissioning Projects Branch Division of Waste Management

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Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l

Re:

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

Dear Mr. Brown:

l Amendment # 8 to license SNM-1999 provides for the decommissioning of Pit 4 at the Cushing l

refinery site. At the time the Pit 4 decommissioning plan was submitted in November,1998, Kerr-McGee Corporation (KMC) was remediating the acid sludge in accordance with a DEQ-approved remedial design. The approved design included the disposal of treated wastes in an on site disposal celi located in Unaffected Area 3. It has become clear that, although the design allowed for as much as 20% growth in the total quantity of waste, the actual quantity of waste generated in Pits 1,2, 3, and 5 is much greater than this. The original disposal cell will not provide adequate capacity for the treated waste generated from all five acid sludge pits.

l KMC is amending the remedial design to include the construction of a second disposal cell in Unaffected Area 4. Both unaffected areas occupy property released from license SNM-1999.

KMC will begin construction of this cell after DEQ has approved the design.

KMC would like to amend license SNM-1999 to allow placement of waste from Pit 4 in either the existing disposal cell or in the planned disposal cell. Treatment criteria and final survey procedures will not change as a result of the construction of this second disposal cell. KMC requests NRC concurrence, prior to or along with site decommissioning plan approval, that all references to a disposal cell in license documents apply to either disposal cell. If you have any questions or comments, please call me at (405) 270-2694.

Sincerely, Jeff Lux Project Manager xc:

C. L. Cain, NRC Region IV Cushing Citizens' Oversight Committee Earlon Shirley, ODEQ Darrell Shults, ODEQ h ?lyk q.

LS SHc

@ 001 00<18/99 FRI 14:43 FA1 405 270 6039 KrRR-VcGEC SEA DIEISION 4-"

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• (m KERRMcGEECORPORAHON ktRR#cOEk CEN'ER e OnAMCWA On y, 04AHouA mn June 18,1999 Mr. Stewart Brown Low-level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re:

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

Dear Mr. Brown:

Kerr-McGee Corporation (KMC) met with NRC on June 16,1999, to review KMC responses to NRC's Request for Additional Infonnation dated May 6,1999. KMC provides the following clarification requested by NRC. The requests are italicized. NRC did not provide these requests in writing, and the requests are stated as understood by KMC.

1. Provide assurance that the estimated dose to a transportation worker (as presentedin Appendh B) hauling radioactively con:aminated soilis less than that estimatedfor a radiation worker.

Calculated doses to transponation personnel would be less than calculated doses to radiation workers due to the fact that the drivers will be transporting sealed containers - the most likely route of exposure would be direct exposure in the cab of the vehicle. 'Iherefore, the worker scenarios presented in Attachment B of the June 4,1999 letter include and exceed the range of potential exposures that might result from waste transportation.

2. Clarify that the estimated dose to a radiation worker (as presented in Appendh B) was calculatedforfuture decommissioning operations.

The estimate was based upon work to be performed in the future and utilized upper ranges for radioactive materials in air and soils /sladges at the facility. It is therefore considered to be an upper bound estimate for potential doses to workers during the deconunissioning project.

3. Providejusti6cationfor the cited 9.6 m'/ day of air that a member of the public would inhale or recalculate the dose based on an air intake of1.2 m'/hr.

The value cited is for a typical radiation worker breathing at a rate of 1.2 m'/hr for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and should reflect the time of exposure for a member of the public, which is assumed to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Corrected pages B-7, B-8, B-12 are submitted as an attachment to this letter with the appropriate values and calculations. The modifications yield an estimate of 0.15 mrem to a member of the public for the off site transportation accident scenario. The corrections do not affect the conclusions of the evaluation in that this estimated dose is insignificant.

f j k' d

- 08/18/99 FR1 14:44 FAI 40s 270 6039 KERR-McGEE SEA DIVISION ~~ L S SRC

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4. Please clanfy KMC'sposition regarding debris and/or rubble outside of AWA-ll.

I KMC will perform surface contamination incasurements on "large" debris and/or rubble, I

such as brick, sheet steel, etc. All material that exceeds surface contanunation limits

. specified in Section 3.2.3.2 of the Site Decommissioning Plan will be shipped to an off site licensed disposal facility. KMC may not be able to justify the use of surface contamination measurements for some debris and/or rubble (e.g., pieces are too small or irregular). Such debris and/or rubble will be segregated in a separate area until KMC and NRC agree on an appropnate measurement rnethod and criteria for this material.

5. Provide additional information regarding analyses of air samples and acrions taken as a result of those analyses.

Air samples are typically analyzed at approximately twelve hours and two weeks after sample collection. Air samples are classified as "Open" or " Closed". Air samples are not considered " Closed" until the second or final count is performed, the results_ are loaded into the dosimetry database, the data record is printed, and the record is reviewed /sigrul by the HP I2ad Technician (HP Iead).

Each day air samples are analyzed, an air sample repon is generated from the dosimetry database. This report has two par:s. The firs: lists results from all "Open" air samples. The second lists year-to-da:e DAC-hrs for each individual. The second pan includes exposures based on both " Closed" air samples and any "Open" air samples assigned to that individual.

The HP lead compares workplace concentration levels listed in the first part of the report j

with concentration-based action levels, and then compares year-to-date exposures listed in the j

second part with bionssay action levels. If an "Open" air sample has a significant impact on any specific individual, the HP lead may pursue funher action, such as re-counting the air sample to quantify naturally occurring short lived radon daughters. Air samples may therefore be counted at additional intervals besides 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 14 days after sampling. As long as the anticipated radon decay appears to be the cause of clevated concentrations, no work-islated actions are triggered.

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

Sincerely, Jeff Lux Project Manager -

xc:

C. L. Cain, NRC Region IV Blair Spitzberg, NRC Region IV Ci=Wg Citizens' Oversight Committee Earlon Shirley, ODEQ Darrell Shults, ODEQ

06/18/99 FRI 14:45 FA1 405 270 6030 KERR-McGEE SEA DIVISION ~ l's.N R c

'G u 0 4 significantly overestimate the actual doses that would be received, due to the l

conservative assumptions utilized and the fact that no credits were assumed for the use of personal protective gear during the cleanup effort Off-Site Radiological Accident Scenario-Member of the Public The member of the public is assumed to be at a distance of 1 km from the spill, and is constantly in the plume centerline in the downwind direction. The atmospheric stability will be assumed as extremely stable, Class F. The spill will be modeled as a point source, whh emission rates as defined for the cleanup worker scenario.

The basic atmospheric dispersion equation for a ground level source at die plume l

centerline is:

X = Q + (2nXo,)(o,)(u).

~

Sigma y and sigma z were picked from Figures 3-2 and 3-3 in Reference 5, using Class F atmospheric stability curves. The wind speed is assumed to be 1 m/s.

The concentration of airborne total uranium, x, is calculated:

x = 7.1 E-12 Ci/s + (2n)(34 m)(14 m)(1 m/s) = 2.4 E-15 Ci/m' The effective dose can be calculated using the dose conversion factors from EPA Federal Radiation Guidance Report No.11 (Reference 3). The dose conversion factors for U-234, U-235, and U-238 are similar. Therefore, simplification of the problem can be achieved through the use of the dose conversion factor for U-234, which is the most conservative.

Inhalation Class Y is assumed for the resuspended material.

The 3

breathing rate is assumed to be 9.6 m / day.

Effective Dose to the Member of the Public from total U

= (2.4 E-15 Ci/m ) (1.2 m'ihr) (24 hr) (3.58 E-05 Sv/Bq) 3 (3.7 E+09 mrem' Ci per Sv/Bq)(10' Ci/Ci)

= 9 E-03 mrem CEDE l

l Cushing Decommissioning Plan B7 Responic to General Comrnent #2

L S.4C

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. 06f18/99 FRI.14:45 FAI 405 270 6030 KERR-McGLE SEA DI\\ lSIO.\\

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~4-Effective Dose to the Member of the Public from Th-232 3

3

= (2.4 E 15 Ci/m ) (1.2 m /hr) (24 hr) (4.43 E-04 Sv/Bq)

(3.7 E+09 mrem /pCi per Sv/Bq) (10' Ci/Ci)

= 0.113 mrem CEDE Effective Dose to the Member of the Public from total Th-228

= (2.4 E-15 Ci/m') (1.2 m'/hr) (24 hr) (9.23 E-05 Sv/Bq)

(3.7 E +09 mrem / Ci per Sv/Bq) (10' pCi/Cl)

= 0.023 mrem CEDE Total CEDE to the Member of the Public from all nuclides I

= 0.15 mrem Note that the TEDE is equivalent to the CEDE as there is no anticipated direct exposure to a member of the public resulting from the accident scenario.

f The upper estimate of dose to the member of the public Is 0.15 mrem, which is insignificant. This estimate utilized conservative assumptions of wind speed and stability class and placed the individual in the plume centerline for the entire duration of the cleanup. In addition, no shielding or dilution effects were considered as is normally done to account for shelter of the individual.

On-Site Padialonical Accident Scenarlo R2alation Worker This scenario assumes that a single container holding 7.5 ft' of waste soils is spilled.

The concentrations of total U, Th-232, and Th-228 within the spilled material are each 2

200 pCi/g. The spill covers an area of 15 ft to a depth of 6 inches (15 cm). The calculations can be performed utilizing the same methodology as for the Off-Site Scenario-Cleanup Worker. The cleanup is assumed to take 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Emission Rate (E) = 0.01 [a A K C L' V'] based upon Reference 1.

= (0.01)(0.41)(52)(1.0)(20)(0.7)(1.0) = 2.98 tons / acre-y Cushing Decommissioning Plan B-8 Response to Gencrul Comment #2 i

LS NRC 06/16/99 FH1 14:46 FAI 40s ::70 6039 KERR McGEE SEA DIVISION 44 of spilled radioactive material. Conservative assumptions were utilized to generate

- estimated doses for the three scenarios, as follows:

ON-site Radiological Accident Scenarlo-Worker:35 mrem TEDE ON-site Radiological Accident Scenario-Public: 0.15 mrem TEDE On-site Radiological Accident Scenario-Worker: 11 mrem TEDE These dose estimates are considered to represent upper bounds of dose.

The calculations demonstrate that the radiological consequences of accidents involving radioactive waste spillage are insignificant for members of the public, and will result in doses to cleanup workers that are well within the regulatory requirenents.

References

1. Colorado Department of Health, Interoffice Communication, Fugitive Dust Emissions, September 30,1981.

2. Radiological Health Handbook,- U.S. Department of Health, Education, and Welfare, Public Health Service, Revised 1970.

3. Environmental Protection Agency, " Limiting Values of Radionuclide intake and Air Concentration and Dose Conversion Factors-for Inhalation, Submersion, and Ingestion," EPA-520/1-88-020. Federal Guidance Report No.11, September,1988.

4. U.S. NRC, NUREG/CR-5512, PNL-7994, Residual Radioactive Contamination from Decommissioning", Volume 1, Reprinted June,1994.

5. Turner, D.

B.,. " Workbook of Atmospheric Dispersion Estimates," U. S.

Dq west of Health, Education, and Welfare, Cincinnati, OH,1%9.

J Cushing Decommissioning Pier.

B 12 Renponseto General Comment #2