ML20211P213

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Responds to Requesting NRC to Confirm Understanding of Adequacy of Matl Control & Accounting Program for Cushing,Ok Refinery Site
ML20211P213
Person / Time
Site: 07003073
Issue date: 09/09/1999
From: Brown S
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Lux J
KERR-MCGEE CORP.
Shared Package
ML20211P217 List:
References
NUDOCS 9909130165
Download: ML20211P213 (3)


Text

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O-kA MEO p 24 UNITED STATES j

g NUCLEAR REGULATORY COMMISSION

's WASHINGTON, D.C 20555-4HM u p. . # . September 9, 1999 j l

Mr. Jeff Lux Kerr-McGee Corporation Kerr-McGee Center P.O. Box 25861 -

Oklahoma City, OK 73125

SUBJECT:

ADEQUACY OF THE MATERIAL CONTROL AND ACCOUNTING PROGRAM FOR THE CUSHING, OKLAHOMA, REFINERY SITE

Dear Mr. Lux:

I am responding to your letter dated June 15,1999, in which you requested Nuclear Regulatory Commission (NRC) to confirm your understanding of the following. I l

1. The Kerr-McGee Corporation (KMC) needs only account for speciai nuclear material (SNM) as this materialis generated by excavation of contaminated material; and

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2. The material control and accounting (MC&A) measures as proposed in KMC's September 25,1992, license application continue to be adequate based on the assumed dilution of any SNM expected to be excavated as a result of site remediation.

We have reviewed your request and agree with your understanding. However, there are several points made in your attachments that merit additional discussion. As noted in your Attachment 2, NRC d:d not grant exemptions to MC&A related regulations. Thus, unless NRC specifically grants an exemption to a specific regulation, licensees such as KMC, are obligated to comply with the requirements of the specific regulation. On August 23,1999, NRC authorized KMC to begin remediation of the Cushing site. Once excavation begins and materialis accumulated, the issue is whether KMC will possess at ar9 one time and location SNM in a -

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~ totaling more than 350 grams, or more than one effective kilogram of SNM. If so, NRC expects KMC to be in compliance with the MC&A regulations.

If you have any questions, please contact me at (301) 415-6605.

Sincerely, Stewart W. Brown, Project Manger Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety ,

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

Enclosure:

As stated cc w/ encl: Kerr-McGee, Cushing distribution list This document should / / should not / / be made available to the PUBL / 19 9,

, Using this format will require the originator / supervisor to scratch one or le other, and initial. l TICKET NO. LLDP-9105 DISTRIBUTION:

Fila Center J. Holonich NMSS r/f CB r/f LCarson RNelson DOCUMENT NAME: S:\DWM\DCB\SWB\Cusheal.wp 1

%FC DCB ,, RIV  ! LIB m DCB OGC DCB I NAME SB BSpitzberg/ TPham TCJohnson JLieberman LCamper DATE 8/h99 8/ /99/ 8/J//99 8/ /99 8/ /99 8/ /99 FICIAL RECORD COPY ACNW: YES NO Delete Sie after distribution: Yes _ No _

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