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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F5041999-10-0101 October 1999 Notifies NRC That T Moore Has Left Employment of Keer-McGee. K Morgan Who Has Been Serving as RSO for Cimarron Corp Facility in Crescent,Ok Has Agreed to Take Role of RSO for Cushing Site ML20211P2131999-09-0909 September 1999 Responds to Requesting NRC to Confirm Understanding of Adequacy of Matl Control & Accounting Program for Cushing,Ok Refinery Site ML20211D5841999-08-23023 August 1999 Forwards Amend 10 to License SNM-1999,safety Evaluation & Environ Assessment,In Response to 980817 Application & Supplemented by 990604,15,18 & 0729 Ltrs,Requesting NRC to Authorize Remediation of Cushing,Ok,Refinery Site ML20210N1481999-08-0505 August 1999 Informs That Staff Is Completing Review of License Amend Request Re Authorization of Cushing,Ok Refinery Site.Nrc Is Considering Revising License SNM-1999,as Listed ML20210G6381999-07-30030 July 1999 Forwards Insp Rept 70-3073/99-01 on 990706-07.No Violations Noted ML20210V4871999-07-29029 July 1999 Submits Clarification Re Design of Second Disposal Cell in Unaffected Area 4,as Requested During Subsequent Communication to ML20210B4291999-07-13013 July 1999 Informs That During Annual Insp Last Week It Was Noted That There Were No Form 4s in Three Individuals Folders. Forms Have Been Taken Care of & Placed in Proper Folders ML20210K0951999-07-12012 July 1999 Informs That State of Ok Reviewed EA Re Decommissioning Plans at Cushing Refinery Site.No Comments Offered ML20209B3221999-06-18018 June 1999 Provides Listed Clarification Requested by NRC During 990616 Meeting Re Responses to 990506 RAI ML20209B3821999-06-15015 June 1999 Forwards Summary & Detailed Analysis of Review of 10CFR70.32 Re Audit Finding Addressing Apparent Lack of Control & Accounting Program for SNM at Site ML20195E5491999-06-0404 June 1999 Submits Responses to NRC RAI Related to Kerr-McGee Cushing Refinery Site Decommissioning Plan.With Responses to Ok Dept of Environ Quality Comments on Decommissioning Plan in Same Format ML20206J0681999-05-0606 May 1999 Forwards RAI in Order to Complete Review of Licensee 980817 Submittal of Revised Plan for Remediation of Cushing Refinery Site.Response Requested within 30 Days of Ltr Date ML20206G1551999-05-0505 May 1999 Forwards Ea,Fonsi & Notice of Opportunity for Hearing - Release of Portion of Cushing Refinery Site for Unrestricted Use & Amend 9 to License SNM-1999,in Response to 960830 & 1024 Ltrs ML20205C2051999-03-26026 March 1999 Informs That NRC Considering Kerr-McGee Corp Request to Have Property Released for Unrestricted Use,From Cushing Refinery Site License SNM-1999.NRC EA Encl for Records ML20207B4701999-03-0202 March 1999 Informs That Ok Dept of Environ Quality Has No Comments on Assessment or Suggestions on Kerr-McGee Proposed Action for Release of Unaffected Areas & Haul Road Corridor from License Re Cushing Site ML20198L3121998-12-0101 December 1998 Provides Addl Info Requested in Re Transfer of Two Depleted U Bullets from Cimarron Site to State of Wa Dept of Health.State of Wa License & Shipping Records of Transfer Encl ML20207B4611998-11-13013 November 1998 Forwards Data Sheets for Concrete Slab from Former Thorium Processing Bldg (Bldg 31) at Cushing Refinery Site in Accordance with NRC Request.Data Shows That Concrete Floor Was Surveyed in 1991.Attached Pages of Data Present Results ML20207B5731998-11-0606 November 1998 Requests Release of Only Portions of Unaffected Areas & Haul Road Corridor from License SNM-1999.Map Showing in White Portions of Site NRC Is Willing to Release,Submitted. Historical Data Encl,Per Request ML20197C3621998-09-0303 September 1998 Forwards Amend 8 to License SNM-1999,approving of Plan to Remediate Acid Sludge Pit 4 & Authorizing Placement of Radioactive Contaminated Matl Into Radioactive Matl Storage Area.Se,Ea & Fonsi,Encl ML20154P3901998-08-12012 August 1998 Forwards Two Copies of Aerial Photographs of Cushing Site That Were Taken 980515.Photos Have No Direct Association with Map Submitted,But Are Just Updated Photos for Use or Files ML20206P3681998-06-29029 June 1998 Submits Listed Commitments to Satisfy NRC Concerns Related to Decommissioning of Pit 4 ML20249C5291998-06-19019 June 1998 Submits Comments on Draft EIS & Fonsi Re License Amend 8 for Kerr-McGee Cushing,Ok,Site.Strike & Underline Utilized to Identify Suggested Changes ML20248J9401998-06-0202 June 1998 Forwards Insp Rept 70-3073/98-01 on 980511-13.No Violations Noted.Purpose of Insp Was to Determine Whether Activities Authorized by NRC Special Nuclear Matls License SNM-1999 Were Conducted Safely & in Accordance W/Nrc Requirements ML20206P3211998-05-28028 May 1998 Informs That Kerr-McGee Corp Will Commit to Discharge from Rmsa Directly to Skull Creek,Divert Stormwater to Retention Pond & Implement Controls Implemented at Rmsa at Stormwater Retention Pond,Per 980520 Telcon ML20206P3241998-05-0101 May 1998 Provides Addl Info Requested by NRC to Show That Radioactive Matl Storage Area (Rmsa) Will Be Operated in Manner That Releases Are Small Fraction of Regulatory Limit.Revised SER, Based on Conservative Yet More Realistic Conditions,Encl ML20217Q6871998-04-0303 April 1998 Requests That Kerr-McGee Submit Listed Info Re Radioactive Matl Storage Area Liquid Effluent Monitoring Program,In Response to ML20206P3821998-03-0303 March 1998 Forwards Replacement Pages for 971126 Submittal of Decommissioning Plan for Pit 4 at Cushing Site ML20206P3411998-02-10010 February 1998 Forwards Ser,Presenting Potential for Release of Radioactive Matl Via Surface Water Effluents from Radioactive Matl Storage Area.Rept Concludes That Concentration of Radioactive Matl at Effluent Point Is Less than Limits ML20198S2891998-02-0505 February 1998 Forwards Replacement Pages for 971126 Submittal of Section 3.3.1 of Site Decommissioning Plan,Concerning Remediation of Pit 4 at Cushing Site.Radiation Safety Plan,Also Encl,As Requested ML20199J1031998-01-29029 January 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-3073/97-02 on 971205.Finds Reply Responsive to Concerns Raised in Nov. Will Review Implementation of C/As in Future Insp ML20198J1811998-01-0606 January 1998 Responds to NRC Ltr Re Violations Noted in Insp Rept 70-3073/97-02.Corrective Actions:Modified Form to List Groundwater & Suface Water Samples Separately ML20203G8671997-12-10010 December 1997 Forwards Amend 7 to SNM-1999 & Ser.Amend Is Responding to Application Dtd 970902,requesting Approval of Proposed Radioactive Matl Storage Area Design ML20198F0611997-12-0505 December 1997 Forwards Insp Rept 70-3073/97-02 on 971014-21 & Nov. Violation Re Failure to Collect & Analyze Soil & Groundwater Environ Samples for Radioactivity ML20206P3181997-11-26026 November 1997 Submits Responses to NRC 970828,0927 & 1023 Requests for Addl Info on Cushing Site Decommissioning Plan.Revised Portion of Section 3 of Subj Plan Encl ML20198R5671997-10-23023 October 1997 Responds to 970828 & 0927 Ltrs Requesting Approval of Revised Section 3.2 & 3.3.1 of Cushing Decommissioning Plan & Provides Comments ML20211G0601997-09-25025 September 1997 Notifies NRC Re Plans to Submit Revised Cushing Decommissioning Plan for NRC Review by End of Oct 1997,so NRC Can Reschedule Resources to Ensure Timely Review of Licensee Submittal ML20207B4861997-09-19019 September 1997 Requests That Ok Dept of Environ Quality Waste Mgt Div Comment on Potential of Shallow Groundwater as Drinking Water Source at Former Kerr-McGee Cushing Refinery Site ML20141G9171997-05-19019 May 1997 Forwards Insp Rept 70-3073/97-01 on 970422-24.No Violations or Deviations Identified.One Unresolved Item Was Identified Re Licensee Failure to Have Exemption from Submitting Semiannual Effluent Reports Per 10CFR70.59 ML20148D5201997-05-15015 May 1997 Requests That Comments on Decommissioning Plan for Kerr-McGee Corp'S Former Refinery Facility at Cushing,Ok Be Provided by 970612 ML20135A8891997-02-12012 February 1997 Forwards Amend 6 to License SNM-1999,safety Evaluation & Categorical Exclusion.Amend Revises Conditions 11.K,11.F, 11.D & 11.C as Listed ML20134C2171997-01-29029 January 1997 Forwards Comments on Workplan,Evaluation of Licensed Matls Migration Via Groundwater Pathways ML20133J2341997-01-10010 January 1997 Informs of Expectation to Continue to Comply W/Terms of Matl License SNM-1999 as Amended Until NRC Notifies Kerr-McGee Corp in Writing That License Is Terminated ML20134B2871997-01-0707 January 1997 Issues Amend 5 to Matls License SNM-1999 for Cushing Refinery Site,In Response to Kerr-McGee Corp Identifying Need to Construct All Weather Haul Road ML20135B7991996-11-25025 November 1996 Discusses Concerns Re Final Radiation Survey of Haul Road Corridor, Submittal ML20134K6841996-11-0808 November 1996 Forwards Comments on Draft Rept Confirmatory Survey of Haul Road Corridor Kerr Mcgee Corp Cushing Site ML20129J7261996-10-31031 October 1996 Forwards Amend 4 to License SNM-1999 & Safety Evaluation, Deleting Condition 11.D ML20134F7891996-10-24024 October 1996 Requests That Four Unaffected Areas Be Released from License SNM-1999 ML20134K6791996-10-23023 October 1996 Forwards Rev 0 to Draft Work Plan,Evaluation of Licensed Matls Migration Via Groundwater Pathways Cushing,Ok Refinery Site ML20129J6861996-10-22022 October 1996 Informs That Activities May Be Conducted at Cushing Refinery Site Haul Road Corridor.Addl Info,Requested Re Buried Matl, Potential Groundwater Contamination & Procedures to Prevent Recontamination ML20129A6731996-10-11011 October 1996 Forwards Amend 3 to Materials License SNM-1999 for Cushing Refinery Site,Authorizing Possession & Use of Sources Containing U-235 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20211P2131999-09-0909 September 1999 Responds to Requesting NRC to Confirm Understanding of Adequacy of Matl Control & Accounting Program for Cushing,Ok Refinery Site ML20211D5841999-08-23023 August 1999 Forwards Amend 10 to License SNM-1999,safety Evaluation & Environ Assessment,In Response to 980817 Application & Supplemented by 990604,15,18 & 0729 Ltrs,Requesting NRC to Authorize Remediation of Cushing,Ok,Refinery Site ML20210N1481999-08-0505 August 1999 Informs That Staff Is Completing Review of License Amend Request Re Authorization of Cushing,Ok Refinery Site.Nrc Is Considering Revising License SNM-1999,as Listed ML20210G6381999-07-30030 July 1999 Forwards Insp Rept 70-3073/99-01 on 990706-07.No Violations Noted ML20206J0681999-05-0606 May 1999 Forwards RAI in Order to Complete Review of Licensee 980817 Submittal of Revised Plan for Remediation of Cushing Refinery Site.Response Requested within 30 Days of Ltr Date ML20206G1551999-05-0505 May 1999 Forwards Ea,Fonsi & Notice of Opportunity for Hearing - Release of Portion of Cushing Refinery Site for Unrestricted Use & Amend 9 to License SNM-1999,in Response to 960830 & 1024 Ltrs ML20205C2051999-03-26026 March 1999 Informs That NRC Considering Kerr-McGee Corp Request to Have Property Released for Unrestricted Use,From Cushing Refinery Site License SNM-1999.NRC EA Encl for Records ML20197C3621998-09-0303 September 1998 Forwards Amend 8 to License SNM-1999,approving of Plan to Remediate Acid Sludge Pit 4 & Authorizing Placement of Radioactive Contaminated Matl Into Radioactive Matl Storage Area.Se,Ea & Fonsi,Encl ML20248J9401998-06-0202 June 1998 Forwards Insp Rept 70-3073/98-01 on 980511-13.No Violations Noted.Purpose of Insp Was to Determine Whether Activities Authorized by NRC Special Nuclear Matls License SNM-1999 Were Conducted Safely & in Accordance W/Nrc Requirements ML20217Q6871998-04-0303 April 1998 Requests That Kerr-McGee Submit Listed Info Re Radioactive Matl Storage Area Liquid Effluent Monitoring Program,In Response to ML20199J1031998-01-29029 January 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-3073/97-02 on 971205.Finds Reply Responsive to Concerns Raised in Nov. Will Review Implementation of C/As in Future Insp ML20203G8671997-12-10010 December 1997 Forwards Amend 7 to SNM-1999 & Ser.Amend Is Responding to Application Dtd 970902,requesting Approval of Proposed Radioactive Matl Storage Area Design ML20198F0611997-12-0505 December 1997 Forwards Insp Rept 70-3073/97-02 on 971014-21 & Nov. Violation Re Failure to Collect & Analyze Soil & Groundwater Environ Samples for Radioactivity ML20198R5671997-10-23023 October 1997 Responds to 970828 & 0927 Ltrs Requesting Approval of Revised Section 3.2 & 3.3.1 of Cushing Decommissioning Plan & Provides Comments ML20211G0601997-09-25025 September 1997 Notifies NRC Re Plans to Submit Revised Cushing Decommissioning Plan for NRC Review by End of Oct 1997,so NRC Can Reschedule Resources to Ensure Timely Review of Licensee Submittal ML20141G9171997-05-19019 May 1997 Forwards Insp Rept 70-3073/97-01 on 970422-24.No Violations or Deviations Identified.One Unresolved Item Was Identified Re Licensee Failure to Have Exemption from Submitting Semiannual Effluent Reports Per 10CFR70.59 ML20148D5201997-05-15015 May 1997 Requests That Comments on Decommissioning Plan for Kerr-McGee Corp'S Former Refinery Facility at Cushing,Ok Be Provided by 970612 ML20135A8891997-02-12012 February 1997 Forwards Amend 6 to License SNM-1999,safety Evaluation & Categorical Exclusion.Amend Revises Conditions 11.K,11.F, 11.D & 11.C as Listed ML20134C2171997-01-29029 January 1997 Forwards Comments on Workplan,Evaluation of Licensed Matls Migration Via Groundwater Pathways ML20133J2341997-01-10010 January 1997 Informs of Expectation to Continue to Comply W/Terms of Matl License SNM-1999 as Amended Until NRC Notifies Kerr-McGee Corp in Writing That License Is Terminated ML20134B2871997-01-0707 January 1997 Issues Amend 5 to Matls License SNM-1999 for Cushing Refinery Site,In Response to Kerr-McGee Corp Identifying Need to Construct All Weather Haul Road ML20134K6841996-11-0808 November 1996 Forwards Comments on Draft Rept Confirmatory Survey of Haul Road Corridor Kerr Mcgee Corp Cushing Site ML20129J7261996-10-31031 October 1996 Forwards Amend 4 to License SNM-1999 & Safety Evaluation, Deleting Condition 11.D ML20129J6861996-10-22022 October 1996 Informs That Activities May Be Conducted at Cushing Refinery Site Haul Road Corridor.Addl Info,Requested Re Buried Matl, Potential Groundwater Contamination & Procedures to Prevent Recontamination ML20129A6731996-10-11011 October 1996 Forwards Amend 3 to Materials License SNM-1999 for Cushing Refinery Site,Authorizing Possession & Use of Sources Containing U-235 ML20058M9631993-09-23023 September 1993 Forwards Amend 1 to License SNM-1999,designating T Moore Rso,Per 930826 Amend Request ML20057B0311993-09-10010 September 1993 Forwards Insp Rept 70-3073/93-01 on 930818-19.No Violations Noted ML20126G9381992-12-22022 December 1992 Forwards Comments Based on Review of Revised Matls License Application for Possession of radioactively-contaminated Matl at Cushing,Ok Refinery Site,Transmitted Via 920925 Containing Decommissioning Funding Plan & Surety Bond ML20086D7351991-11-18018 November 1991 Responds to Re Shipment of Radwaste from Cushing Oil Refinery Site Containing SNM Enriched to Average of 7.6% U-235.NRC Raises No Objection to Shipment of SNM Bearing Waste to Land Disposal Facility 1999-09-09
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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
. 1
- 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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j[Mk %[ i C
, hC. M L3
4 . J. Lux. , T
~ 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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