ML20249C529
| ML20249C529 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 06/19/1998 |
| From: | Jim Larsen KERR-MCGEE CORP. |
| To: | Brown S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9806300259 | |
| Download: ML20249C529 (3) | |
Text
7
.o 6
h) KERRMcGEECORPORMION N
KERR McGEt CENTER e OML AHOMA CITV. ORL AHOM A 7312$
June 19,1998 1
Mr. Stewart W. Brown, Project Manager Facilities Decommissioning Section l
Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, DC 20555-0001 l
l Re:
Docket No. 70-3073; License No. SNM-1999 i
Kerr-McGee Corporation Cushing Site Comments on Draft Environmental Assessment for License Amendment #8 l
Dear Mr. Brown:
I Kerr-McGee Corporation takes this opportunity to comment on the draft Environmental Assessment and Finding of No Significant Impact related to License Amendment No. 8 for the Kerr-McGee Cushing, Oklahoma site. I utilize strike and underline to identify suggested changes.
COMMENT #1 In the title block reference to License No. SNM-199 should be corrected to SNM-1999.
COMMENT #2 Kerr-McGee recommends changes to section 2. INTRODUCTION, as follows:
(First sentence) Kerr-McGee owns has environmental responsibility for a former l
refinery site near the city of Cushing, Oklahoma.
l (Second sentence) During the early 1960's, in addition to petroleum processing, Kerr-McGee processed uranium fuel and thorium metal in several buildings onsite under licenses issued by the Atomic Enerav Commission (AEC).
,jo (Third sentence)
The uranium fuel and thorium processing area was
[
decommissioned and the property and facilities were released for unrestricted use by AEC license releases.
1S lki v\\
h-9806300259 980619 PDR ADOCK 07003073 (ed C
l (Last full sentence of page 1) On April 6,1993, NRC issued Materials License
$NM-1999 to the Kerr-McGee corporation Corporation, for the radiological decommissioning of its Cushing site.
COMMENT #3 Kerr-McGee recommends changes to section 3. PROPOSED ACTION as follows:
(Add new first two sentences)
One of the refinery acid sludae oits beina remediated under the Oklahoma Department of Environmental Quality (ODEO)
Consent Order contains Thorium contamination in one corner of the oit. This affected pit is desianated as Pit 4.
l l
(First sentence of draft) The licensee proposed to remediate Acid Sludge Pit 4 based on the experience gained from remediating ecvera! cf the non radic!cgica!
n_on-radiologically contaminated acid sludge pits.
l COMMENT #4 We recommend changes to section 4. "The Need for Proposed Action" as follows:
)
(Heading title) Put in all caps for consistency with remainder of document.
(Paragraph 1, penultimate sentence) The Rl!FS process was completed and reviewed by the Ok! honatepc'tment oLEnvironmente! Qua!!!y (ODEQ) ODEQ and local citizens.
(Paragraph 2, first sentence)
NRC Materials License SNM-1999, License Condition 11.B.2, required reauires the licensee to provide a description of the l
methods that would will be used to neutralize acidic contaminated sludge contaminated with radioactive materials.
(Paragraph 4, first sentence) In addition to the RMSA the licensee plans to j
construct an Acid Sludge Pit 4 stormwater retention pond (retention pond).
(Paragraph 4, second sentence) The purpose of the retention pond is to collect surface water runoff caused by precipitation from rainstorm events that may occur during the several week period while the licensee will be performing Acid Sludge Pit 4 remediation activities in zones 1 and 2 (known contaminated or possibly contaminated areas. respectively).
COMMENT #5 Kerr-McGee recommends changes to section 6. ENVIRONMENTAL IMPACTS OF PROPOSED ACTION as follows:
(Paragraph 3, first sentence) The licensee has committed that all of these a'ctivitie's would be monitored by the Cushing facility Health Physics Department and will comply with the site Radiation Safety Plan (RSP).
(Paragraph 3, fourth sentence) In addition, the direct exposure, inhalation and ingestion hazards to workers and the public will be kept as low as is reasonably achievable (Al. ARA), during the proposed activities, and within NRC guidelines, as discussed in the licensee's submittals.
(Paragraph 6, second sentence) The licensee has committed to maintain annual cumulative averaging less than 20 percent of the effluent limits stipulated in Appendix B of 10 CFR Part 20.
(Paragraph 6, fourth sentence) The licensee's analysis indicates that the actual releases will likely be less than one percent of the effluent limits.
(Paragraph 6, add two sentences at the end of the paragraph)
Therefore.
effluent releases from the RMSA will be limited to an annual averaae of not more than 20% of the 10 CFR Part 20 limit and that in accordance with ALARA, any discharae above 20% of the limit will be investigated and corrective measures will be taken and documented. This condition will ensure that the maximum potential dose to a member of the public is 10 mrem /vear.
(Paragraph 7, fifth sentence)
The Oklahoma Water Resources Board determined that Skull Creek water dose does not meet water quality standards for drinking water or for beneficial uses ranked hiaher than industrial use.
l We hope that our comments are helpful and conducive to NRC's timely issuance of License Amendment No. 8 to SNM-1999. If further clarity or explanation is desired, please do not hesitate to contact me or Jeff Lux.
i Sincerely, V
yU Jess Larsen l
Program Manager l
cc:'
Mike Broderick - ODEO Jeff Lux John Stauter jl061998let
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