ML20197C383

Environ Assessment & Finding of No Significant Impact Re Amend 8 to License SNM-1999 for Kerr-McGee Cushing Refinery Site

ML20197C383
Person / Time
Site:	07003073
Issue date:	09/03/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20197C367	List: ML20197C362 ML20197C370 ML20197C375 ML20197C383 ML20197C390
References
NUDOCS 9809110146
Download: ML20197C383 (8)

Text

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', ,, M ato O k UNITED STATES g g NUCLEAR REGULATORY COMMISSION o 2 WASHINGTON, D.C. 20666-0001

. . . . . ,o September 3, 1998 THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS ENVIRONMENTAL ASSESSMENT. AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO AMENDMENT NO. 8 TO MATERIALS LICENSE NO. SNM-1999 KERR-McGEE CORPORATION CUSHING REFINERY SITE DOCKET NO. 70-3073 The U.S. Nuclear Regulatory Commission (hereafter referred to as NRC staff, Office of Nuclear Material Safety and Safeguards) is considering a license amendment request, submitted by the Kerr-McGee Corporation (Kerr-McGee or the licensee) in its November 26,1997, letter, and supplemented by letters dated February 5,1998, March 3,1998, and June 29,1998, to authorize remediation of Pit 4 located on its Cushing refinery site (Cushing site located in Cushing, Oklahoma). The licensee is obligated to remediate Pit 4 by both NRC regulations and an Oklahoma State Consent Order. Further, the licensee in its letters dated February 10,1998, and supplemented by letters dated May 1,1998, and May 28,1998, requested authorization to place radioactive contaminated material into the radioactive material storage area (RMSA).

1.

SUMMARY

AND CONCLUSIONS:

Based on NRC staffs evaluation of the licensee's Pit 4 remediation plan and placement of radioactive contaminated materialinto the RMSA, NRC staff has determined that u,, proposed plan and use of the RMSA complies with NRC's public and occupational dose and effluent limits, and that authorizing the proposed activities by license amendment would not be a major Federal action significantly affecting the quality of the human environment. NRC staff concludes that a Finding of No Significant Impact is justified and appropriate, and that an environmentalimpact statement is not required. In accordance with the requirements of Subpart L of 10_Qpsie of Federal Reaulations (CFR) Part 2, an Opportunity for a Hearing was offered.'

2. INTRODUCTION Kerr-McGee has environmental responsibility for a former refinery site near Cushing, Oklahoma. The refinery opened around 1912 and was purchased by Kerr-McGee in 1956.

During the early 1960s, in addition to petroleum processing, Kerr-McGee processed uranium fuel and thorium metal in several buildings onsite under licenses issued by the Atomic Energy Commission (AEC). The uranium fuel and thorium processing area was decommissioned, the property and facilities were released for unrestricted use, and the license was terminated by the AEC. Kerr-McGee continued to operate the refinery until 1972, at which time it v,:s torn down.

In May 1990, Kerr-McGee entered into a Consent Order with the Oklahoma State Department of Health, addressing the investigation and remediation of the Cushing refinery site. The 1

60 Federal Reaister 46318 (September 6,1995).

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Consent Order divided the site work into radiological and non-radiological remediation efforts.

The non-radiological remediation is being performed in a manner similar to the Federal Superfund Remedial Investigation / Feasibility Study (Rl/FS) process. On April 6,1993, NRC issued Materials License SNM-1999 to Kerr-McGee Corporation, for the radiological decommissioning of its Cushing site. This license authorized the licensee to possess radioactive contaminated soil, sludge, sediment, trash, building rubble, and any other contaminated material, at its Cushing site.

3. PROPOSED ACTION One of the refinery acid sludge pits being remediated under the Oklahoma Department of Environmental Quality (ODEQ) Consent Order contains thorium contamination in one corner of the pit. This affected pit is designated as Pit 4. The licensee proposed to remediate Pit 4 based on the experience gained from remediating non-radiologically contaminated acid sludge pits. The licensee would establish a 50-by-50-foot grid system over the surface of Pit 4, referenced to the site-wide grid system. A layer of reagent (agricultural lime) would be placed over each grid block. The acidic sludge in each block would be neutralized to a pH of approximately five to six by adding and mixing in the reagent to depth. The mixing process should produce a relatively homogeneous material. The licensee plans to surface-scan this material in 18-inch lifts, to determine if material exceeds NRC's " Branch Technical Position on Disposal or Onsite Storage of Thorium or Uranium Waste from Previous Operations" (BTP) (46 Federal Reaister 52061) Disposal Option 1 for thorium concentrations. Material that exceeds this Option 1 limit would be transported to the RMSA. Once this material is in the RMSA the licensee plans to package and transport this material to a licensed offsite disposal facility, the Envirocare Low-Level Radioactive Waste Disposal Site in Clive, Utah, for disposal. Material that meets the Option 1 limit would be excavated, stabilized by blending in cement kiln dust or similar reagent, and transported to the onsite Other Industrial Waste (OlW) disposal cell. The licensee plans to perform a final survey of the material once it is placed in the OlW disposal cell to confirm that the material meets NRC's release criteria in the BTP (Option 1 limit).

4. THE NEED FOR PROPOSED ACTION There are five acid sludge pits located on the Cushing site. These acid sludge pits contain acidic hydrocarbon sludge from an earlier lubricating oil manufacturing operation. The waste is primarily heavy hydrocarbon containing sulfuric acid (typically 15 to 20 percent). The northwest corner of Pit 4 also contains thorium-contaminated material in concentrations that exceed current remediation criteria and pose a long-term risk to the environment. The other acid sludge pits do not contain radiologically contaminated material. Phase One of the non-radiological effort is remediation of the five acid sludge pits. The Rl/FS process was completed and reviewed by the ODEO and local citizens. The ODEO issued a record of decision for the acidic sludge pits requiring neutrali1.ation, excavation, and placement in an onsite engineered disposal cell.

NRC Materials License SNM-1999, License Condition 11.B.2, requires the licensee to provide a description of the methods that will be used to neutralize acidic sludge contaminated with radioactive materials. This information was to be provided before neutralization of this sludge.

The licensee, by letters dated November 26,1997, and supplemented by letters dated l

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3 February 5,1998, and March 3,1998, submitted a proposed revision to its Cushing Refinery Site Decommissioning Plan (DP) Section 3.3.1, "RMA-3." In this revised section of the DP, the licensee provided the required information related to the method that would be used to neutralize acidic-contaminated sludge in Pit 4. The licensee requested approval of this section of the DP and authorization to remediate Pit 4.

Further, License Condition 11.B.1 authorized construction of the RMSA but prohibited use of the RMSA until the licensee demonstrated that liquid effluent releases would be in compliance with the requirements of 10 CFR Part 20. The licensee in its letter dated February 10,1998, and supplemented by letter dated May 1,1998, requested License Condition 11.B.1 be amended to allow radioactive contaminated material to be placed into the RMSA. The licensee also provided its proposed RMSA liquid effluent monitoring program.

In addition to the RMSA the licensee plans to construct a Pit 4 stormwater retention pond (retention pond). The purpose of the retention pond is to collect surface water runoff caused by rainstorm events that may occur during the several week period while the licensee will be performing Pit 4 remediation activities in Zones 1 and 2 (known contaminated or potentially contaminated areas, respectively). Therefore, surface water runoff that may contain radiologically contaminated material from a rainstorm event would be collected and monitored prior to release from this area. The licensee plans to use the same liquid effluent monitoring procedures prior to release of liquid from the retention pond as it plans to use for monitoring RMSA liquid effluent releases. Finally, both the RMSA and the retention pond use a common discharge point in Skull Creek.

This proposed action is necessary to remove radiologically-contaminated material from Pit 4.

This action will facilitate compliance with the Consent Order, and remediation of Pit 4 for release for unrestricted use, a necessary action for termination of Materials License SNM-1999.

5. ALTERNATIVE TO PROPOSED ACTION An alternative to the proposed action is a no-action alternative. No action would mean that Pit 4 would not be remediated now. This would prevent the licensee from complying with the Oklahoma State Consent order. Also, this conflicts with NRC's requirement, in 10 CFR 40.42, of timely remediation at sites that have ceased operation. Although there is no immediate threat to the public health and safety from this site, not undertaking remediation at this time does not solve the regulatory and potential long-term health and safety problems associated with storing this waste. No action now would delay remediation until some time in the future, when costs could be much higher than they are today. It is even possible that no disposal option will be available in the future if the current low-level radioactive waste disposal facilities are closed and no new ones are opened. Therefore, the no-action alternative is not acceptable.

6. ENVIRONMENTAL IMPACTS OF PROPOSED ACTION Remediation of Pit 4 could result in both radiological and non-radiological environmental impacts.

4 Ra'diological environmental impacts that could result from remediation of Pit 4 are direct exposure, inhalation, and ingestion hazards to workers and the public. These hazards would occur during the in situ neutralization; excavation of this material for transportation to the RMSA; transport of material to the RMSA; and packaging the material for shipment to the Envirocare Low-Level Radioactive Waste Disposal Site, in Clive, Utah, for disposal.

Additionally, radiological environmental impacts could result from either RMSA or retention pond liquid effluent releases.

The licensee has committed that all of these activities would be monitored by the Cushing facility Health Physics Department and will comply with the site Radiation Safety Plan (RSP).

The purpose of the RSP is to define the rules, standards, policies, engineering controls, and general radiological work practices that will be used at the Cushing site, to ensure the safety of both onsite personnel and members of the general public. The RSP addresses contamination controls; effluent monitoring and controls; worker training; and worker dosimetry. In addition, the direct exposure, inhalation, and ingestion hazards to workers and the public will be kept as low as is reasonably achievable (ALARA), during the proposed activities, and within NRC guidelines, as discussed in the licensee's submittals. NRC staff has reviewed the RSP2 and found that the RSP combined with licensee's commitments provided by letter dated May 28, 1998, provide reasonable assurance that the public health and safety would be protected during Pit 4 decommissioning activities by the radiation safety program based the RSP.

An additional potential environmental impact could be the effluent released while contaminated materialis being stored in the RMSA. On December 12,1997, NRC amended Materials License SNM-1999 to allow construction of the RMSA. Notwithstanding this approval, NRC, in License Condition 11.B.1, has prohibited the licensee from transferring contaminated material into the RMSA until NRC has approved the RMSA liquid effluent monitoring program.

NRC wanted the licensee to demonstrate that there is reasonable assurance that before the licensee releases liquid effluent from the RMSA and the retention pond, the amount of radioactive material contained in the liquid effluent would be less than the 10 CFR Part 20 release limits. The licensee has provided a proposed RMSA liquid effluent monitoring program which provides reasonable assurance of compliance with the requirements of 10 CFR Part 20.

The 10 CFR Part 20 liquid effluent release limits are based on a total effective dose equivalent of 50 mrem if the radionuclide were ingested continuously over the course of a year. 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. The Cushing license will be conditioned to reflect this commitment. The licensee's analysis indicates that the actual releases will likely be less than one percent of the effluent limits. If the licensee did release liquid effluents at one percent of the 10 CFR Part 20 release limits and if a member of the public were able to directly consume this contaminated liquid effluent, that member of the public would receive a total effective dose of less than 0.5 mrem / year. Further, if the licensee released liquid effluents at 20 percent of the 10 CFR Part 20 release limits and if a member of the public were able to directly consume this contaminated liquid effluent, that member of the public would 2

Kerr-McGee Corporation Site Radiation Safety Plan, Cushing, Oklahoma, Refinery Site, Revision 2, April 30,1997.

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5 receive a total effective dose of less than 10 mrem / year. Therefore, effluent releases from the RMSA wW be limited to an annual average of not more than 20 percent of the 10 CFR Part 20 limit and, in accordance with ALARA, any discharge above 20 percent 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 less than 10 mrem / year.

It is very unlikely that a member of the public would consume the total annual discharge from the RMSA and retention pond. This liquid effluent will be discharged into Skull Creek. The creek water flow will dilute the liquid effluent as it is discharged into the creek. Further, the licensee has noted that Skull Creek contains both organic and inorganic contamination from industrial and refinery sites in the Cushing area. The Oklahoma Water Resources Board determined that Skull Creek water does not meet water quality standards for drinking water or for beneficial uses ranked higher than industrial use. This further reduces the possibility of a member of the public consuming a large portion of the liquid effluent discharged into Skull Creek. Therefore, the impact on the human environment due to the release of potentially radioactive contaminated liquid effluent from either the RMSA or the retention pond is insignificant.

Non-radiological environmental impacts that could result ' rom the acid sludge remediation process are dust, sulfur-dioxide (SO2 ) emissions, and hydrocarbon vapors. Dust can be generated when reagent is applied to the surface of Pit 4 for use in in-situ neutralization and when reagent dust is pneumatically loaded into silos located at the treatment plant. Both SO2 and hydrocarbon vapors may be released during the neutralization process. ODEQ has stipulated the limits for both the dust and SO, emissions, and ODEQ will be monitoring the three possible emissions during the remediation process to ensure compliance.

Packaging of radioactive material for shipment and the shipment of radioactive material from the Cushing site to the Envirocare facility will be made in accordance with both NRC and the Department of Transportation regulations. Disposal of the wastes at the Envirocare facility will be made in accordance with State of Utah requirements. Therefore, any impacts to the public health and safety, or the environment will be minimal.

In addition to the above, this proposed action would result in the irreversible use of energy resources in the conduct of removal activities and the transportation of waste material for disposal. A portion of the Envirocare facility will be irreversibly committed for the disposal of this Cushing low-level radioactive waste. There are no reasonable alternatives to these resource uses, and the proposed action does not involve any unresolved conflicts concerning use of available resources.

7. AGENCIES AND INDIVIDUALS CONSULTED This environmental assessment was prepared entirely by NRC staff. No other sources were used beyond those referenced in this environmental assessment. NRC staff provided a draft of this environmental assessment to ODEQ for review. ODEO had no comments.

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, 8. ' CONC'LUSIONS i

. Radiological exposures to workers and the public will be in accordance with the 10 CFR Part 20 l limits. Radiologically contaminated effluents released from the site due to either the i remediation of Pit 4 or use of the RMSA or the retention pond will also be within 10 CFR Part 20  ;

limits. _Therefore, the environmental impacts from the proposed action are expected to be insignificant. Further, the low-level waste disposal facility, Envirocare, eligible to receive this waste, is regulated under State of Utah rules for land disposal of radioactive wastes, which provide for long-term institutional control and minimize the potential for human intrusion and l other environmentalimpacts. Therefore, NRC staff believes that disposing of the Pit 4 radiologically contaminated wastes at the Envirocare facility will not cause any significant j impacts on the human environment and is acceptable. The conditions and restrictions placed on the Envirocare facility, combined with the facility design provisions and its location, provide l an acceptable level of protection of human health and safety and the environment. '

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9. FINDING OF NO SIGNIFICANT IMPACT- )

Pursuant to 10 CFR Part 51, NRC has prepared this environmental assessment related to the issuance of a license amendment to Materials License SNM-1999, authorizing remediation of

Pit 4 and placement of radioactive contaminated materialinto the RMSA. On the basis of this environmental assessment, NRC has concluded that this licensing action would not have any significant affect on the quality of the human environment and does not warrant the preparation i of an environmental impact statement. Accordingly, it has been determined that a Finding of No Significant Impact is appropriate.

The aforementioned documents related to this proposed action are available for public inspection and copying at NRC's Public Document Room at the Gelman Building,2120 L Street NW., Washington, DC. l i

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,l 6 . . ; 5 5 SNM-1999 70-3073 Amendment No. 8 Equipment and surfaces:

1.000 dpm alpha /100 cm 2

average contamination level over 1 m 2 or smaller area 2

1.000 dpm beta gamma /100 cm  : average contamination level over 1 m or smaller area 2

3.000 dpm alpha /100 cm 2: maximum over 100 cm2 3.000 dpm beta-gamma /100 cm2 : maximum over 100 cm2 200 dpm alpha /100 cm2 : removable 2

200 dpm beta-gamma /100 cm  : removable Exposure rate:

Soils 2.6 nC/kg/hr (10 uR/hr) average above background at 1 meter Equipment and buildings:  !

1.3 nC/kg/hr (SuR/hr) above background at 1 meter N. Except as specifically provided otherwise in this license, the licensee shall conduct its program in accordance with statements, representations, and conditions contained in a letter dated September 25, 1992, as supplemented on  !

December 18, 1992. January 14, 1993. February 23, 1993. August 26, 1993. January 2 5, 1994, and February 9. 1996.

FOR THE NUCLEAR REGULATORY COMMISSION Date: September 3, 1998 By:

John W. N. Hickey Chief y Low-Level Waste and Decommissioning Projects Branch jf0

1. g' Division of Waste Management Office of Nuclear Material Safety g '

p \o and Safeguards y

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DISTRIBUTION:

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LLDP RIV k , , , LLDP\ LL[yf)) Vi NAME- Skoh AHufht JCopeland* LCarson* SIwh TJ N n Mkey DATE 7/N/98 (/il/98 7/30/98 8/04/98 g /2f/98 T/lT98 h//h98 l S:\dwm\lldp\swb\cush8.lic 0FFICIAL RECORD COPY /

-ACNW: YES NO Category: Proprietary or CF Only l IG : YES NO LSS : YES NO Delete file after distribution: Yes No

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2 Exposure rate: [

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Soils 2.6 pC/kg/hr (10 uR/hr) avera .above background at 1 meter /

Equipment and buildings:  !

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1.3 pC/kg/hr (SuR/hr) [

above background at meter 7

N. Except as specifically provided otherwise innse, this the1,ce/

licensee shall tepresentations, and conduct conditionsits program contained in in accordance a letter with statements dated Septembe / 1992, as,5, supplemented on December 18, 1992. January 14, 1993. February 3. 1993. August 26, 1993, January i 5, 1994, and February 9, 1996. , i

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FOR THE NU IARREGULATORYCOMMISSION

[0 iginal signed by] l Date: By:

Joh W. N. Hickey. Chief L -Level Waste and Decommissioning 1 Projects Branch j Division of Waste Management  !

Office of Nuclear Material Safety and Safeguards 1

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DISTRIBUTION: [*w/ o /**w/o encl or att]

Central File PUBLIC /LLDP r/f NHSS r/f RJohnson BSpitzberg/RIV 0FC LLDPg LDP LLDP d RIV OGC LLDP LLDP f V/JP /*T= PM NAME AHuffert JCopdfand 2/LW TJohnson JHickey DATE M8 /' / -/98 7/40/98 f/d/98 / /98 / /98 / /98 S:\dwm\1 p b\cush8.lic 0FFICIAL RECORD COPY ACNW: Y NO Category: Proprietary or CF Only IG .: ES NO LSS : YES NO Delete file after distribution: Yes No I

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