ML20214E662
| ML20214E662 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 02/19/1987 |
| From: | Stauter J SEQUOYAH FUELS CORP. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20214E599 | List: |
| References | |
| 82976, NUDOCS 8705220185 | |
| Download: ML20214E662 (13) | |
Text
F s
SEQU0YAH FUELS CORPORATION POST OFFsCE BOR h861
- Out AHOMA CifY OILL AHOMA 73Q$
February 19, 1987 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. A. Bert Davis, Acting Regional Administrator United States Nuclear Regulatory Comission 9
E; m
Region III y"
a 499 Roosevelt Road 8
Glen Ellyn, IL 60137 so RE: License SNM-928 Docket 70-925 Condition No. 20 i
Dear Mr. Davis Sequoyah Fuels Corporation requests revision of Condition No. 20 of License SNM-928 for the Cimarron Uranium Plant to extend the decontamination conpletion l
date.
Condition No. 20 requires completion of all decontamination activities at the plant and submittal of the final close-out report by March 31, 1987.
While substantial progress has been made, all decommissioning activites will not be completed by that date and accordingly, Sequoyah Fuels requests l
Condition No. 20 be revised as follows:
- 20. By December,1988, the licensee shall decontaminate the facilities and grounds for unrestricted release.
Any residual concentration of uranium on-site will not exceed the criteria contained in the October 23, 1981 NRC Branch Technical Position Paper, titled Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations, option #2.
J.
1
,, E By December 31, 1988, the licenseo shall submit a report that g
0-identifies all facilities where radioactive materials were used and o
stored, or disposed on-site.
The report shall briefly describe operations conducted and radioactive materials used in the facilities and shall assess the results of the decontamination activities. The g
report shall provide the basis for unrestricted release of the
.gN M
facilities and the site, including a description of sampling a
$ni survey methods and instrumentation
- used, and shall include o
contamination survey data for the facilities and grounds.
NtuE 05 In support of this request for extension, a complete summary of the status of the decommissignin u ctivities underway at the Cimarron site is provided in the q%=nt............... 85 C E I V E D ca:a.. o.t.on '
ey m c%=.46-2.hEB 231987 CONTROLNpg,$3[,7 0, O A i/r tm.... nu/tf.'.'.'.'.hEGIon IRk
Page 2 Feb. 19, 1987 B..Davi2
,?
C attachment.
These activities cover not only' the - uranium plant but the; plutonium plant, lagoons and various disposal areas as well.
Decomissioning and decontamination work is approximately 80 percent couplete, with. the remainder projected to be finished by December,1988 to include submittal of a final report.
1-Because this projected completion date will extend beyond the current license period of March 31, 1988, Sequoyah Fuels also requests that the current license:
be extended to December 31, 1988 plus whatever additional time NRC will require for its review leading to release of the site.
'Ihis will enable all decomissioning activites to be completed and the unrestricted release of 'the -
entire site at that time.
In order to further facilitate this release review process, SFC requests that NRC begin its survey release program in the spring of 1987.
Attached is SFC check number 101053 for $150.00 to inititate this amendment review process.
If you have any questions concerning this request, please contact me at your earliest convenience.
Sincerely,e t
(2,u John C. Starter, Director Nuclear Licensing &
Regulation )
JCS:ms Enclosure as stated (two copies) xc:
W. T. 2 row, NMSS Distribution:
I s
CONTROLNO. 8 o 9 7 6 u
L
~h0 -
m
'i SEQUOYAH FUELS CORPORATION CIMARRON FACILITY STATUS OF FACILITY DECOMMISSIONING FEBRUARY, 1987 l
Sequoyah Fuels Corporation submits this facility l
decommissioning summary in support of an extension of the
- Condition 120 completion date of March 31,'1987 for the uranium l
facility.
This extension is justified and appropriate for the 3,
following reasons:
/
- 1. The Cimarron Facility is actively engaged in a
decommicsioning program'that wili result in release of the entire site for future unrestricted use and termination of all NRC licenses.
The decommissioning activities include total decontamination of the Cimarron Plutonium Plant as l
Well as the Uranium Plant and all outside areas, including the lagoons and an old 10 CPR 20.302 disposal area.
This work is being done with a dedicated team of well trained and experienced operating, health physics and management personnel knowledgable of the health and safety requirements for handling plutonium and enriched uranium materials.
L m..
.,,, ir-Site activity has focused on the Plutonium Plant decommissioning over other sit'e activities, including decontamination of the Uranium Plant, so as to facilitate
+-
removal of'all TRU materials.
In mid-1983, the Department of Energy, through DOE's Richland office,~ agreed to accept e
Cimarron's plutonium wastes and SFC agreed to prepare seven specific'-
lessons-learned reports covering the plutonium facility decontaminatior activities.
The agreement established a fixed time period within which DOE would authorize disposal of the facility plutonium waste..
Thus, pluton [um plant activities necessarily have priority to meet those contracted receipt requirements..
l-Sequoyah Fuels' current schedule will result in shipment to DOE's repository of" all transuranic quantities of plutonium by April, 1987, and the final task of ' cleaning s
the building surfaces for unrestricted release will be completed by December-31, 1987..
Completion. of the
, transuranic quantity shipments will. enable SFC-to place more manpower on the other site decontamination activities.
at the Uranium Plant, lagoons and buria.t site.
- 2.. Uranium Plant decommissioning includes. decontaminating th'e plant and any other contaminated areas on the site.- SFC.
currently has three projects underway related to this-
, ci Ic -
f'
,A t.-
g
=-.,
i -.
- a.:
.f.
A
,Lactivity.
These projects a're'. -(a); decontaminating-the:
LUranium Plant-- and' grounds-immediately surrounding.- the
- plant, (b) decontaminating. the Jtwo.
remaining-un1Ined-lag'oons
-and-recovery and. -decontamination of any:.
underground piping, and (c) excavation, repackaging,., and disposal.at a' -commercial-low-level radioactive ~ waste
. disposal. site o'f materials-previously _ disposed -on-site under l'0 CFR Part 20.302.
'These activities are detailed below:
. building is r
currently 85%
complete.
As. shown on the attached Figure 1,
both the laboratory and pellet. areas have been decontaminated, surveyed.
.and
-rele'ased..
All-equipment ~ has been removed ~f rom the -ceramic area and preparation is underway for cleaning-and. detailed-J econtaminstion-surveying to determine
' additional:
d needs.- Since wet' chemical process'ing wasLdoneiin this
~
area,- SPC anticipates 'some flooring and possibly 'some; wall _ structures will require : removal.
The' storage area east of the ceramic area isinow~ dedicated ~asLa. cleaning-and release area'for stored? junk.~ yard l equipment..
The bulk.of the l stored -processing (. equipment shas-been'-,
e, e
b m
removed.
The high-line and scrap
- areas, including-Building's No.
2 and SX,
'are also being decontaminated.
.Most of the equipment has been
- removed, except for the ion exchange unit',
which is-used in the decontamination activities.
Additonal current activities 'includa removal of pla r.t prteess pipes and conduit located above the process f.loor.
SFC's goal is to clean and release the junk yard equipment to enable the excavation of elevated uranium concentration areas in the p3 ant' yard.
SFC currently 3
anticipates approximately 30,000 ft of low level contaminated soils will be removed and packaged for shipment to a commercial low Je/el r dioactive wastu disposal site.
In addition to the activities above, SPC has ~ completed drilling approximately 300 ' survey holes on-site, each of which has been gamma probed at one-foot intervals to characterize the site.
Core samples have been taken to correlate the gamma probe readings with concentrations.
- b. Sanitary Lagoons and Underground Piping The underground piping, except for 'the existing sewage treatment, certain process drains and lines connected l?
J
to the new lined lagoon, has been-removed an'd-areas decontaminated where required.
The east unlined lagoon contents have been totally excavated,
- packaged, and-shippdd to a
commercial low-level radioactive ' waste disposal site.
Excavation of the west unlined. lagoon is approximately 60%
complete.
Removal of.
the.
contaminated clay liner (approximately 12") is nearing completion, at which time the area will be surveyed. to determine. whether additional excavation is required.
These materials will be shipped for disposal ac a commercial low-level radioactive waste disposal site.
Excavation of the lagocas has been proceeding behind-schedule due to the exceedingly wet conditions s
experienced since this activity was ir.itiated approximately two years ago.
Normal rainfall 'in. the area historically averages 31"/ year; however, in 1985 and 1986 this a.verage was exceeded by. 27" and 14".,
respectively.
Based on ' the remaining
- soils, SFC estimates task completion to be.approximately 80%
complete; under normal weather conditions, completion of this task is anticipated during the - March to = May, 1987 time frame. 4 4
v.
4 e
n
c.
10 CFR 20.302 Disposed Materials.
In the fourth quarter of 1985, SFC decided to complete decommissioning of the_ site by exhuming'the 10 CFR Part.
20.302 disposal location, repackaging the' wastes, and -
shipping the packaged waste ' off-site to a commercial low-level radioactive waste disposal site,-
This _,:'. i o n -
will parmit unrestricted release of tPu catir 31 6.
Records indicate the site contains about-1.5' Ci, corprised of an assortment
-of depleted
..nve u r 19,
- 385, a
request for authoriza' ion to p r tum s
was submitted to NRC for the purpose of com?D t; this removal activity.
The application was. approved by NRC on April 16, 1986, at which time SFC.was authorized to-open the disposal trenches.
c SFC estimates this excavation project is - 15% complete.
The necessary work area facilities have been constructed and are in place, the exact locations of-the four trenches have been' identifed, and approximately 1000' drums have been packaged and shipped..
4 a
~
'w-g e
4 -
At this time, the disposal trench excavation activity-presents the largest unknown because only ' one : trench.
has been opened.
Records - indicate, and SFC expects'to encounter, material which'may require further treatment.
(i.e.,
oxidc. tion-cr st'abilization).
A' controlled ventilated' glovebox located d n the Uranium Plant will L
be utilized for safely performing-any required l
additional treatments.
Snis contaminated materials treatment area in the Uranium Plant will also-be used for equipment decontamination from the outside activities.
SFC plans to continue decontamination activities in all the above areas with a dedicated - site decommissioning crew.-
The first priority is, and will continue to-be, the Plutonium Plant-effort.
As the weather permits, the second priority will be to complete the outside act.ivities-and
- finally, the Uranium Plant.
The Uranium Plan; logically will be the last' area, as it' will be used-for cleaning and repairing equipment and for treating materials removed from the burial ground that~ require the use of the' hooded enclosure.
SFC has scheduled completion of all decontamination _ activities by the end of
- 1987, including the Uranium Plant.
- However, i
adverse weather conditions, encountering significantly more volume of contamination than currently estimated,'or the need l i
to treat some wastes further may delay
-completion significantly.
Because such events cannot be
- foreseen, the extension of the completion date to December 1988 should a'llow
~
sufficient contingency to provide for completing. all tasks efficiently and safely.
A final report describing the decommissioning activities will be prepared and submitted by December, 1988.
SFC has evaluated, and will continue to te riev, de possibility of using additional temporary persomlel.
- However, the decontamination activity is a
specialized activity and experienced personnel trained in health physics practices are required.
SFC will not compromise' the success it has experienced to date in maintaining-exposures ALARA, receiving positive inspection reports, and operating safely-in all areas associated with the decommissioning activity.
In
- summary, SFC has made substantial progress toward decommissioning the entire Cimarron site.
Ove r'all, SFC estimates that more than 80%
of the work involving the buildings has been completed.
Approximately 50% of the waste volume removal has been completed;
- however, the bulk of the remaining volume as currently ~ estimated is lagoon, disposal ground and soil excavation and removal should proceed rapidly as weather permits.
SFC's experience in final close-out L
4*-
)
surveys'(i.e., building surfaces) suggests this activity can be
-variable and difficult to estimate in some instances.
Consequently, 3FC believes an extension of the Uranium Plant decommissioning deadline through December, 1988 for completing SNM-928 decontamination activiti s will be sufficient to accomplish all currently identi *ieci ' as, a and un; t, seeable potential added tasks.
SFC realizes the License Condition 20 SYtension tequest exceeds the current expiration date of the license.
Therefore, SFC requests at this time that NRC consider an -extension ~ of the license expiration date to accomplish this remaining closeout.
- Finally, SPC believes the extension as requested does not affect the licensed activities, will not degrade health 'and safety and does not require preparation of an additional environmental impact. statement
.in.
accordance - with 10 CFR 51.22.
The following points are made in regard to these items:
- 1. The action sought is procedural in -nature and only-authorizes the licensee to continue current. licensed activities to make the site releasable for unrestricted use; 1.
- 2. The action sougnt does not represent a change in the types or amounts of effluents that may be released off-site and,
-indeed, the decommissioning actions-have lessened the opportunities for future releases;
- 3. The action sought does not increase individual' or cuaulative occupational radiation exposures above previous-
'ecrease can licensing actions and,'_in fact, a significant d be anticipated as the radionuclide inventory continues _ to be decreased;-
- 4. The action sought does not include any new construction impact; and l
5..The action sought will not increase the potential for-or l
l consequences from a radiological release accident.
l
_10_
4,.
FIGURE 1 N4 URANluM PLANT
- t 9
MAIMTENAAICE y WATER TREATMEMT 224W :s*4 :
17-J P
..m.
us::
4 Q
- sx
- :
1.3,
',', 1; / O',
- ; - ; g;;
W; 3.
'1 i=
i DR.0M A M k [7 N/f
'~
LDAbluG AREA h31' jg p ::).
., g y:vg,
+* n * ' N > :$
l lp-
.. ;' Lll c
nr<
_ _ _d.Q gd)q
- fh, g.Jx
. p:
occg gg it DECONTAMINATED & RELEASED o...
6'@y,,.
EQUIPMENT & OVERHEADS REMOVED OFFICES 64 Aub
~,-
- ? -%
1722+E1] CURRENT DECONTAMINATION ACTIVIi'"I 51oRAGE ans
- . Jhdb m
..w r
j y; % %i'
, 9 *SS;&'R
.. lip y-cu ".
f 4y,9 ;j -
PELLET castAMic '
(1,
~
l
[4 f AM ;
]g ARF.A
._' i 1
D i
i;6,
o-,
t O
t~
2 LABORATORi P
OFFICES-d b.
.CO w
to
- Q CD i
i
(
t 4
g 4
i i t
n m.
%