ML20195E549

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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
ML20195E549
Person / Time
Site: 07003073
Issue date: 06/04/1999
From: Lux J
KERR-MCGEE CORP.
To:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20195E555 List:
References
NUDOCS 9906110211
Download: ML20195E549 (23)


Text

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<= KERRMcGEE CURPORMION RT. 4

  • BOX 2323. CUSHING. OK1.AHOMA 74023 r

SAFETY & ENVIRONMENTAL nFFAIRS June 4,1999 Mr. Stewart Brown low-level Waste & Decommissiop53 r@cu Branch P

Division of Waste Management Omce of Nuclear Materials Safety & Safeguards U. S. Nuclear Regulatory Cnmmiazion Washington, D. C. 20555 7

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Re:

Docket fo. 703073

's License No..SNM-1999 O=hing, Olda65ma' Facility

Dear Mr. Brown:

Kerr-McGee Corporation (KMC) herein subrnits inapan= to NRC's Request for Additional Infonnation Related to Kerr-McGee's O=hing Refinery Site Decommissioning Plan. KMC has provided each request for inftmnation by NRC (in italicized font), followed by KMC's respchue.

KMC has also included resprmses to Oldahoma Department of Environmental Quality (DEQ) comments on the decommissioning plan in the same format.

NRC Gmeral Raguest 11: Provide the schedule ofplanned decommissioning adivities. If the time-line to conqplate decommisdoning ofthe Ckshing site is greater than 24-monthsfmm the date NRC Appnner the site -i- -. Wi-=2.gplan, providejustifaxtionfor the delay in accontance with the requirements of10 CFR m.38(g)(4)(vii).

KMC Response: KMC has projected a decommissioning schedule based upon approval of the Site narneminainning Plan (SDP) by August 20,1999. 'Ihe projected schedule is pmvided as Anachment A to this letter. 'Ibe schedule indicates that tw<-..si:amioning will extend over more k

than two years. This schedule is pre:ented as a planning doeurr.cnt only. 'Ihe actual sequence or f

duration of activities may vary based on field and/or weather conditions, available resources, technical problems encountered, etc.

10 CFR 70.38(hX2Xi) states that NRC may approve a request for an alternate schedule for compiction of decornminainning if, among other reasons, it is not technically feasible to complete

(+>--- " - :- activities within the allotted 24-month period. In light of the scope of the project, it is not technically feasible to w ;h all proposed decommissioning activities within 24 months.

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In mMainn, the eartian allows consMeration of other site-specific factors. Id. At 70.38(hX2XiX5).

V KMC believes safety will be enhanced by mmab*ing different proposed twe i.s.hioning activities over a period extending beyond 24 months. 'Ihe (+x-.inihioning plan includes various non-9906110211 990604" PDR ADOCK 07003073 3

PDR

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l lupviss to Request for Additional Information KMC Cushing Site Demmmissioning Plan routine activities, which increases the likelihood of accidents. KMC has therefore scheduled the decommissioning effort so no more than five different damnminioning activities will be in process at any given time, thereby facilitating training and supervision. NRC approval of this alternate schedule is r=*i along with approval of the SDP.

NRC Gmem! Repest #2: Pnnide a dose estimate (TEDE) for a member of the public (uddch includes non-ndation norkers, truck drivers, and rail uorkers) that uill resultfmm the Chshing

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site renediation efort, including packing and tmnsporting the greater than Option 1 mdioactive unste to an ofsite licensed dimn=1 facility. Also, pmvide a dose estimate TEDEfor a mdiation

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unrker innhed in the Ckshing site remediation efort. Finally, provide a descrip: ion of the uo:st-casepostulated mdiological accident scenario that could occur as a result ofremediation activities.

Dansportation accidents should be inclwid as part of the accident scenarios considered in this enluation. This description should be included in the estimatedpotential consequences (IEDE) of

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that postulated norst-case accident both site mdtatnon norters and members of thepublic.

KMC Response: Attsdorst B contains dose evaluations for on-site and off-site accident scenarios, as well as the dose to workers and the public from normal operations. The evaluations utilize conservative assumptions and thus are expected to overestimate significantly any actual dose that would be realized during h+<.iissioning activities. The calculated doses demonstrate that full compliance with the regulations will be achieved even under the worst anticipated scenarios.

Oding is committed to ALARA in all activities associated with damnminioning of the facility.

NRC Genemi Repest #3: Provide a description of thephysical security measures used to prevent the genemipublicfmm intruding into either radiation areas and/or radioaalve materials areas.

KMC Response: All radioactive materials areas (RMAs) are enclosed with a 3-strand barbed wire fence with locked gates. Portions of two RMAs (RMA-11 and a portion of RMA-3) are also enclosed by a six-foot chain link fence. All fences surroundmg RMAs are appropriately posted with signs bearing the legends " Restricted Area Authorized Personnel Only" and " Caution Radioactive Materials".

NRC Genemi Request #4: We recognize that situations could occur during theperformance ofa pmjed that could repire certain changes to an appmved decommissioningplan. Therefore, ne uvuld consider a license condstion that uvuld allow you to make certain changes to either the Appmved decommissioning plan orpmcedures without our review or appmmi. Ifyou unnt this type offlaibility while remediating the Cushing site, prmide a proposed changeprocess and license condution, includmg organizational oversight of this changepmcess.

KMC Response: A license condition allowing certain changes to be made to the NRC-approved SDP, the Radisian Safety Plan (RSP), and associated pmcedures without NRC approval is mnainent with ALARA and the hm. i=L.: g pmcess. 'Ihis would allow appropriate changes to be made to these documents as site health and safety requirements change. All changes would be rh by the Onian ALARA Review Committee (ARC) review and written dcmnentation of thejustification and appmval process. KMC therefore proposes the following license condition:

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Responses to Request for Additional Infonnsoon KMC Cushing Sire Decomnussioning Plan A.

The licensee may, without prior NRC approval, and subject to the requirements specified in Parts B and C of this condition:

1.

Make changes in facility or process, as gh in the approved Site nannmmiminning Plan and Radiatine Safety Plan; 2.

Make changes in the procedures p --- A in the approved Site Decomminioning Plan, Radiation Safety Plan, or applicable license conditions; and 3.

Conduct tests or experiments not presented in the approved Site D-ami taning Plan or applicable license conditions.

B.

The licensee shall not be required to file an wlication for an amendment to the license when the following conditions are satisfied:

1 1.

The change, test, or experiment does not conflict with any requirement specifically stated in this license (excludirg those aspects addressed in Part A of this condition),

or impair the licensee's ability to meet all applicable NRC rpa'inam; 2.

There is no degradation in safety or envim. J commitments addressed in the Site Decommissioning Plan or Rahation Safety Plan; and 3.

The change, test, or expenment is consistent with the conclusions of actions analyzed in the Envimnmental Assessment (EA) dated (insert month and year when the EA for the Site Decommissioning Plan is approved).

C.

'Ihe licensee's determinations shall be made by the Omahing ALARA Review Cnmmim (ARC). The ARC shall consist of a minimum of three individuals employed by the licensee, of whom one shall be designated as the ARC chainnan. One member of the ARC shall.5m corporate (Oklahnma City office) management and shall be responsible for approval of managerial and financial changes. One rnamher shall sem site operations and shall have responsibility for i=alamantiag any changes. One member shall be the site Radiarian Safety Officer or equivalent, with responsibihty for assuring that changes conform to radation safety requirements. Additional members may be included in the ARC, as appmpriate, to address technical aspects, such as health physics, groundwater hydrology, surface-water hydrology, specific earth sciences, and other technical disciplines.

Temporary or permanent memben, other than three individuals who are required to be KMC employees, may be consultants.

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Responses to Request for Additional Informeon KMC Cushing Sire Decommissioning Plan MC Genemi Reguest #5; Pmvide a descriptim ofthe specQlc method (s) that will be used to tmruportpodcaged r~"% waste greater than Option 1)br shipmentfmm the Ckshing site to a ucensat afsite diaposalJhcility. Pmvide the name and location of the ucensed ogsite mens Jkcility that Ckshing mdioactive miste wiu be shipped Provide an estimate ofthe number oftruck or mil car sh{pments that MU be requirai to ship the Ckshing mute to the ofsite licensed A"mmi Jkcinty. Pmvide the qpproximate one-way distance that wiH be tmveled by either truck and/or mil.

KMC Respanc; Material that is contaminated with licensed marerial above decommissioning criteria will be packaged in intermodal containers. The current plan is for these containers to be s g.ai by tmek to a rail erarian in Sand Springs, Oklahnma, where they will be loaded onto railcars.1 hey will then be transported by railcar to a licensed disposal facihty q=.64 by Ewimcare of Utah (Envirocare) in Clive, Utah. Each intermodal container will contain approximately 15 cubic yards of soil-like material and/or debris.

If KMC ships a total volume of 15,000 cubic yards of waste to Envirocare (Table 3.4 of the SDP),

this will require the use of appmximately 1,000 intermodal containers. Each container will

%& one tmck shipment to the rail facility, which is located appmximately 50 miles fmm the Oding site. Typically, three intermodal containers are loaded onto each flatbed railcar, so approximately 340 railcars will E r-pan waste fmm Sand Springs to Envimcare, a diarance of approximately 1,400 miles.

MC Site Decommissioning Plan Reguest #1: Section 1.3 - We do not agree that the activities that you areprspasing qual $yJbr a categorical exclusion pursuant to the pmvisions of10 CFR Ptirt 51.22(c)(11). Therefore, to aHow us to assess the environmentalinpact ofyourproposed activities pmvide the)buoMng: (a) pmvide a discussion on the socioeconomic inpads the Ckshing renadiation epbrt wiu have on the local w..-.*ty; (b) provide a discussion on thejidure land and mater use ofthe site once site ranediation is conplete and the NRC license is terminated; (c) pmvide a discussion ofarry historical or ardreological sites on the Ckshing site or in the local area and how site remahrunr activities MH inpact them; and (e) pmvide the last three annual reports w1.g the results ofthe Cushing envimnmental monitoring pmgmm.

KMC Response: (a) - Between 1980 and 1990, the population of Payne County dmpped fmm 62,435 to 61,507, a decrease of 1.49 percent per year (Charlet,1992). The population enrimate for Payne County for 1998 was 65,109 which constitutes an increase of approximately 0.75 percent per year. The estimated 1998 population of the state of Oklahoma is 3,346,713. The 1990 population of Oklahnma was 3,147,088.

Over 11 percent of Payne County's 1990 population of 61,507 lived in Cushing, the second largest town, and 60 percent lived in Stillwater, the largest town. The remaining towns located within Payne County had popularians that totaled 7 percent of the county's population. The remainder of the County's popdatinn, 22 percent, lived in rural areas outside of towns. There were a total of 27,381 housing units located in the county in 1990. Most subdivisions are small, with small lot sizes and average roads. Sales'of existing homes are slow and the rate of new construction is slow.

Payne County does not have a zoning ordmance or a land-use plan, but does have subdivision regulariana.

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Responses to Request for Additional Infonnation KMC Oning Site Decornmissioning Plan

- Much of the economy of the county is derived from government activities and higher education (Oklahama State University). Payne County has approximately 1,110 farms, averaging 283 acres in size. The vast majority of these farms produce hay or wheat, and graze (,attle between plantings. 4,614 businesses were registered in Payne County in 1992, not including self-employed persons, such as farmers. The Cushing facility remediation t:rTort involves an average of 60 workers and is therefore expected to have minimal socioeconomic impact on the local community.

Transportation in Payne County is primarily by road, although there is I rail line that passes through the county. The O=hia= facility is served by State Highway 18. The site is located near the intersection of State Highway 18, which runs north and south, and Deep Rock Road, which runs east and west. Average daily traffic counts at this intersection reveal that about 1,500 to 2,000 vehicles use State Highway 18 per day, and about 200 to 300 vehicles per day use Deep Rock Road.

Health care facilities in Payne County include a hospital in Cushing and 2 Imspitals in Stillwater.

One airport in O=hing serves small airplanes and the Stillwater Municipal Airport in Stillwater serves commuter airplanes. The county does not have any military reservations, but does have a state prison.

(b) - A portion of the O=hing site is dedicated to crude oil storage and pipeline operations. KMC sold these operations to Notti Gathering Corporation, Inc. (now Dynergy, Inc.) in 1995. As part of 1

that sale, the north tank farm, south tank farm, and a small area 9 A:r.:.g the site office Milding

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(Building A-9) will be transferred to Dynergy after NRC has terminated license SNM-1999 and DEQ has approved the final cleanup of the refinery site. These areas are shown'on Attachment C.

The south tank farm is contained within Unaffected Area 2, but the remaining areas Dynergy will acquire are in areas that require survey and/or decommissioning for release.

The remainrier of the site will remain under KMC ownership. Portions of this property will be noted in the deed as ennraining inchwrial waste (such as the acid sludge disposal cell). KMC has no plans to develop or sell the remaining property and expects it to remain fallow.

Shallow groundwater is not and will not be used for drinking water. DEQ has agreed with this position in a letter to KMC dated September 19,1997. Dynergy and future mpana of the pipeline properties shown in Anehnent C, as well as surrounding neighbors, will continue to have drinking water supplied by public water systems.

(c) - The Phase I Remedial Investigation Report. submitted to DEQ in April,1993, states, " Rare, threatened, or u "- -gxi species are neither documented nor anticipated on the Site (Butler, 1990)". This is still the case.-

(d) - 1he only re '

J historic and/or archeological site located in or around the city of O=hing s

is the Cushing Annory, located at 218 South Little Avenue, over two miles from the Cushing remediation site. The O=hing Annory is listed with the National Register of Historic Places and Page 5 of 21 1

Responses to Request for AMaianal Informadon KMC Cushing Sire Decommissioning Plan with the Oldahnma State Historical Preservation Officz. Decommissioning activities will have no affect on this facility.

(e) - Annual environmental results from 1996,1997, and 1998 are included in Attachment D.

Results for groundwater, surface water, vagd*ina, and soil samples, which are collected on an 1

' annual basis, are provided as Anschment D-1. Environmental air aamples are collected on a weekly basis, and environmental air monitoring data for the three year period are provided as Attachment D-2. Envimernental TLDs are analyzed on a quarterly basis, and quartedy data for de a as Arracinnent D-3.

three year period are r MC Site Deaommisdoning Plan Jteguest #2: Sedian 2.2.3.3 -In this seaion, you indicate that rq0fnate may han been disdaarged into a unstepond. Pmvide site location of this unstepond.

Was this unstepond chamcterized? Vso, pmvide a &~dar ofresidts. Ifnot, pmvide J=%=darfor not daaracterizing this area. In addition, pmvide the site location ofany unste or i

retention ponds that nere in existencefrom 1963 topresent. Were theseponds orprevious pond locations daaracterized? Ifso, pmvide a discussion of results. Ifnot, providejustifcationfor not daaracterizing these areas.

KMC Response: Section 2.2.3.3 states that historical dmimaart provide conflicting accounts of raffinate disposal. One Atomic Energy Commission (AEC) document states that raffinate was discharged into Skull Creek, and another AEC document states that ramnate was discharged into a waste pond. Several fonner QF were questioned about this discrepancy, and they believe the reference to disposal of raffinate to a waste pond is incorrect. The former employees recall that the only waste water discharged to a waste pond (Pit 4) came frorn the thorium process, and that raffinate fium the uranium process was discharged duecdy to Skull Creek.

Anachment E is a site map showing the locations of all impoundments that were present on the site between 1963 and the time the refinery closed in 1972. The drawing shows the locations of former tank dikes, since they could have formed impranvimenta. All property under license will be surveyed in accordance with the darnmmianinning plan. The only impoundments created sirwe the refinery closed were constructed in unaffected areas for acidic water treatment and diacharge.

These areas were released from licznse in Amendment #9, dated May 5,1999.

MC Srte Decomme.uioning Plan Jteguest #3.' Seaion 2.2.4.3 - In this section, you indicate that routine dsdaargesfrom holding tanks occurred and thorium low-leut unste uns buried north of Deep Jtock Jtaad. Provide site block locationsfor these areas. Also, pmvide a discussion related to the dhpasition of the holding tanks, induding the locations of these tanks.

KMC Response: Historical air photos of the O=hia= site show several small trdics located in the north of Skull Creek and approi

e.
y 100 feet east of the thorium process building (Building 31).

This area is s..Jy contained within RMA-10. These tanks were runoved sometime between the time the refinery closed in 1972 and April,1979, when an air photo shows the tanks were no longer there.

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Responses to Request for Additiona11aformation KMC Cushing Siw Demmaussioning Plan ne low-level waste buried south of Pit 4 and north of Deep Rock Road (Blocks 60 and 72) is andressed in the wand bullet item in Section 3.3.8 of the SDP.

NRC Site Daaommissoning Plan Reguest #4: Section 3.2.2.3 - Sypplement the dic~camprovidal under the topic heading Maximwn Radioactivity with the background ranges you identifiedfor the i

wrrious radioaaive materials in soil and apasure rates.

KMC Response: De site bmi,vand numben for soil activity concentation scOxposure rate are tahdatad below.

l Soil Volumetric Activity U-235 pCi/g U-238 pCi/g U-234 pCi/g B-232 pCi/g Maximum value 0.16 2.39 3.90 1.43 Minmmm value 0.00 0.73 0.00 0.60 Average 0.06 1.59 1.30 1.13 Number of samples 54 54 54 54 Note: U-234 is calad=ad based on the maammi ratio of U-238 to U-235. Source of data is Appedix C eo " Final Pad *v= Suivey of Four Unaffected Areas of the Cushmg Refinery Sie -

April,1995".

F=~=== Rate Imdlum 19 (pR/hr)

PIC (pR/hr)

Max value 9.0 9.4 Mmmmm Value 6.0 7.6 Average 7.3 8.5 Number of Measurements 33 33 Note: exposure ruses wuc measured at 33 locasions using bola a I ndhan Model 19 and a Reuter Stokes Model RSS 112 pressuriand iond===har. Source of dass is Table B2 of Appsodix B to " Final Rad *vm Survey of Four Uns5scend Ames of the Cushing Redinssy Sise - April,1995".

NRC Site Decommissioning Plan Reguest #5: Seaion 3.2.2.5 - In this seaion, you proposal in&w*ive limitsfor debris and rubble. For material that will be surveyed eitherfor surface contamination or as debris and rubble: (a) provide the minimum size ofthe material specimen below which surface measurements would be considered inpractical and the material uvuld be treated as debris or rubble; (b) indicate whether thepotential contamination isfrom alpha, beta, or gamma type sources; (c) Justify shy direct apasure measurementfor gamma radiation with a pR meter is suitable instead of mlumetric and surface activity limits: (d) provide wdumetric concentradons)br licensed material that will be correlated to theproposed debris and rubble limit oftheproposed aposure rate Ibnit of two times the maximum background; (e) provide the tedmical basis)>r this correlation; and g) apand the $s~ cam to sqpport the apasure-only pathnay assu"Flimt.

KMC Response: (a) - When debris and/or rubble has flat surfaces for which surface contamination measuremmma are psicel, surface nnnaamiration meneurements will be utilized. However, the daniaina to utiliae surface cornaminssian rnamann manen for detuis and rubble is not based strictly on Page 7 of 21 j

Responses to Request for Addninnal Infonnanon

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KMC Cushing Sile twmmininnmg Plan 1

the size of the material specimen. Partially crushed and 4-6 ming dnuns, coils of barbed wire, consoned metal in which voids are filled with asphaltic hydsfocu, pieces of brick, and other debris which KMC will encounter at several locations do not provide the "bmad" flat surfaces for 1

which surface contarninstion me==rernants are appropriate.

Field conditions also affect the appropriateness of conducting surface contamination measurements.

l If one 18" X 18" piece of brick wall were discovered in a pile of broken brick, it would be sensible so deal with it in the same manner as the rest of the pile. However, if the same size piece of brick wall were discovered while excavating soil, it would probably be proical to use surface

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cantaminatinn measurements to survey this piece of wall. KMC believes k is reasonable to develop both material handling and enntaminant menenement methods on a case-by case basis. 'Ihis is j

reasonable because this debris will not be used in the future in ac 4-w with the exposure scenario for which surface contamination limits were derived, and the application of surface contamination limits to this material is questionable.

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(b) - The potential contamination on this rubble /debrim guld be any combination of uranium and thorium, dmending on its location on the site. 'Iherefore the emitted radiations will be alpha, beta, and gamma.

(c) - (f) - KMC attempted to develop a methodology for segregating material based on micro-R measurements when volumetric or surface cantaminatinn measurements are not appropriate or j

technically defensible. Using MicroShield, KMC was able to provide technicaljustification for i

such a method when the only contaminant is thorium. However, the method is not feasible for uranium.- KMC therefore submits as Attachment F revised pages fmm Section 3 of the SDP.

herian 3.2.2.5, which y..- ed he proposed maannement method, has been deleted. hetinam t

3.3.3.1 and 3.3.9, which addressed the decommissioning of materials using the proposed method, have been swined.

In RMA-11, where a large quantity of solid waste is mixed with cnnenminatal soil-like material, KMC will sample the soil-like material enntainad within the debris and rubble addressed in these aantinna. In a May 20,1999 meeting with NRC, KMC agreed that if the soil-like material contains licensed material, the entire volume (including brick, steel, and other material) will be considered to exceed the darnmmissinning criteria, and will be excavated and shipped to a licensed disposal facility. Should KMC develop a better method for determining the volumetric activity of such material, KMC will pmpose this alternate measurement method as a license amendment request.

NRC Site Decommissioning Pier Reguest #6: Sedion 3.3.5 - Cor$me that buildings whether

'q0ectext" or not that are going to be demolished or will remain onsite will be surwyed in acoondance with he guidana provided in NUREG/CR 5849, ami the rendts will be included in the final survey report. ]these buildings or strudures wie not surwyed in aamdar,ce with this guidance, prtmide basis)br notperjbrming these surwys. Justgy atting strudured steel building members b4bre surwying hem, as proposed during demolition ofboth Buildings 30 and A-6.

Justfinarime should incimie a discussion why you cannot surwy these k!: Jing members before canting amt is thisproposal considered AlARA ? Cor$rm that the slab sectioning process will result in stab secaions ofsqfleient site to allow surface surwying. Also, provide basisfor not surwying in Page E of 21

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@ 10 Rec luest for Additional Informanon KMC Custiing Site Dooommissioning Plan building 30)listfloor slab be)bre sedioning he slab. Finally, clarVy ifhe SNM Stomge Building ispart ofBuildung 30)brL. -. '='- _'mpurpases. Notedin Sedian 2.3.4.3, there are stillareas dat need to be cleaned to the arrestrided release limit. Yet de SNM komge Building is not dsruccad in Sedian 3.3.3, Site Ruildings. Was any indimerin material wed or stored in Building

. 317 What buildings haw indimnive materials stored in them now?

l KMC Response: All final status anveys for any buiklings or ~=iian-ne that will remain at the 043== Facility aAer license tennination will be conducted in accordance with protocols described in DraA NUREG/CR-5849. Survey records relating to buikhngs or equipment that will remain at the Cushing facdity aRer limnae terminatinn will be included in the final status survey report.

Building rubble resulting from demolition, as well as equipment and other material that will not remain at the site, will be surveyed in accordance with NRC's " Guidelines for Decontamination of Facilities and F=ianent Prior to Release for Unrestricted Use or Termination of I h for Bypmduct, Source, or Special Nuclear Material" (1987) (Guidance Directive FC 83-23). Such survey records will be mairmainad in site files, but will not be included in the final status survey repoit. 'Ihis is in tsurd a with a letter from NRC to Kerr-McGee Corporation dated April 23, 1999.

Surveys were previously perfonned on accessible building surfaces and areas in tsvidi-a with NUREG 2082. As proposed in Section 3.3.5 of the Oding Facility D==nmi-i=ing Plan, 1

Odia permannal plan to cut stmetural steel members and section concrete slabs located in BuiMings 30 and A6 prior to performing final surveys. ' Ibis is due to the fact that contamination could pneantially be located on portions of the stmetural steel members that are immible in their cunent configuration and in cracks and crevices located on the concrete floors.

'Ibe cutting' and mnoval of stmetural steel members and the sectioning of the' concrete floors into slabs will be performed in accordance with approved Special Work Pennits (incorporating ALARA principles) and will ensure that all stmetural steel member surfaces are surveyed and/or damnraminnend in accordance with pmposed deconanissioning criteria. 'Ihe concrete floors will be sectioned into slabs (pieces) small enough to ensure that such concrete slabs can be safely handled and/or manig=d=*ad o support 9. - '-r and thorough characterizarinn. 'Ihe size of the concrete t

slabs (pieces) will be sufficient to allow KMC to survey the surfaces to demonstrate compliance with proposed decornmissioning criteria.

'Ibe SNM stomge tailding is part of Building 30 for decommissioning purposes. It was surveyed in accordance with NUREG 2082, as were the other buildings. As with Wilding 30, this building will be surveyed in accordance with FC 83-23 as it is dismantled, and the records of these surveys' will be rnmintainad on site for NRC inspection.

J Radioactive mararial was W in Buikhng 31, which was demolished in 1966. Ucaa d maaerial is cunently being stored in Buikling A-6, Buikhng 30, Building A-9, and the HP lab.

i NRC Sire M. __ '"le-}-= Plan R*=*ct #7: Section 3.3.9 - In this sedion you pmvided a dsrucciar ofheproposedprocess nat will be used to renediate buried rubble. Provide location (s)

Aere anto a-ny indimnin contaminated rubble is buried.

Page 9 of 21 l

Respomes to Request for AdditionalInfonnation KMC Cushing Site Decornminaioning Plan KMC Response: The process for decommissioning buried rubble will vary hanM on the nanne of the rubble. Buried rubble may be found during subsurface investigations in areas idenufied in Sections 3.3.1.6 (burial nench m), 3.3.3 (tash dump), 3.3.6 (former process buildings site), and 3.3.8 (miacellaneous areas) ofihe SDP. 'Ihe method for A-1 -% whether that material complies with decommissioning criteria is W upon the nature of the material, as diacneerd in the response to Request #5.- For example, if the " rubble" consists of bmken chunks of brick, concrete block, and soil, the m at appropriate method of survey may be to crush the material and measure the degree of contansation volumetrically. If the " rubble" consists oflarger pieces of material with relatively flat, rmenaihie surfaces, the most appmpriate method of survey may be to meanne potential surface contarnination.

NRC Site Decommissionbrg Plan Request #8: Section 3.4.2 - NRCdoes not allow dilution of mdioactiw materialin lieu ofdecommissioning areas whids do not meet clean-sp afteria. Note that NUREG/CR-5849, Section 8.5.3 rew....:.ds that if the exposure mte erceeds tw times the guideline nxlue, the area should be remeduated and resurwyed. Also, pmvide a description of the methods that will be used to ercamte and tmnsport r=Ilmwive contaminated waste that will minimize thepotentialfor spreading contamination.

KMC Response: KMC anticipates that exposure rate measurements will exceed 10 pR/hr above

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i background (h :--4 criterion for exposure rate) only when the undedying soil neards volumetric dacamminainning cnteria. If external amma measurements exceed the exposure rate F

criterion, an investisation will be performed to identify the source. Gamma scans will be perfonned to identify areas in which additional sampling will be required.

KMC will valim engineering contmis to minimize the potential for spreading cantaminatinn during transport. E=P of engineering controls include wetting dusty materiad, stabilizing oily material, or using covers or other fonns of enntainment whde transporting on site. Intermodal enntainers will be cmJ so as to prevent loss oflicensed material during transport to the disposal site.

NRC Site Decommissioning Plan Reguest #9: Section 4.1.1 - Describe the auditperfonned by the independent wq,m.; chased Envimnmental, Health, and Sqfety)haction. Also, in&Ast the ymra f thepeople toperforming this audit. is the purpose of this audut conpliance with 10 ro CPR Purt 207 Also. pmvide a description of what actions would be taken by the Quality Assumnce (QA) Coordinatorifpmgmm defciencies arefound to crist.

KMC Response: A corporate auditor axhts the Cushing facility on an annual basis. 'Ihe scope of the corporate audit will meet the requirements of 10 CFR 20.1101, but may include other topics at the direction of corporate management. Currently, the corporate mutirnr is a Certified Professional FJwinnnmental Auditor experienced in auditing environmental, benith & safety, and rachation safety pmgrams at a variety of company facilities. The corporate mulient retains appropriately qualified eachnical professionals when technical aspects of a program are audited.

Page 10 of 21

Responses to Request for Additional Information KMC Cushing Site Decommissioning Plan 1he annual cuipui.E radiation safety program is only one of annerous audits perfonned at the Cushing site on an annual basis. The site Quality Assurance Coordinator (QAC) participates in the rudimian safety program audit with the corporate auditor and receives a copy of the audit report.

The QAC iriitima Non-Confonnance Reports and/or Corrective Action R~=de as appropriate as a result of audit findings and tacks action items through completion. The QAC provides monthly reports on progress by responsible personnel who are skhessing action items to the project manager and site manager.

NRC Site Decanunissioning Plan Reguest #10; Sedion 4.1.4. - Pmvide a statement that the RSO has authority and responsibilities to stop ongoing nort activities, should he or his stq(obserw nadnologiaally unsqfe nortpmaices. Also, revise Figure 4.1 to show the RSO. The RSO should nport to an organizational manager at a lewl that willinsure independent sqfety reviews are conducted.

i KMC Respome: 1he RSO has responsibility to ensure that work is performed safely and has l

authority to stop work. Figure 4.1, the "Oiahing Project Gis Ladon", makes a reference to a

" Staff Health Physicist". Mr. Teience M. Moore is the Radiation Safety Officer as listed on the NRC liceme and carries the title of Staff Hea'th Physicist. The RSO (Staff Health Physicist) reports to the site manager, who is responsible for all health and safety, radiation safety, environmental operations, envimnmental compliance, and quality performance on site. Attachment F includes a revised Figure 4.1 with the title, "Rmhmion Safety Officer".

NRC Site Decc~~iccianine Plan R~nmt ill: Section 5.1.2. - Pmvide the basisfor amcluding that radioactivity is chemiaallyfrxed within nrrious matrices and considered insoluble. Haw any tests been conducted to demonstrate that the materials are insoluble? Ifso, pmvide the results.

For urine and non-routine bioassay sanples what laboratory will be usedfor bioassaying nort?

What is the sarnple colledian pmcedure recommended by the certffed laboratory analyzing the sanpler? Is the rcu....::.ded sanple collectionfrequency monthly? Doyou haw collection pmcedures? Is there a baseline analysis conductedfor eads individual before working in airborne activity areas? See Regulatory Guide 8.9. Also, describe the criteriafordetermining airsanpling monitoring locationsJbr monitoring worker intake and airborne 40fuent around areas uhen b. M-ing aaivities are in pmgress. Also, oorfinn airsanplingfollows NUREG-1400 recommendations and Regulatory Guide 8.25. What is theproposed trigger or action lewl? Also,

]

is there a trigger lewl orprocessfor determining uhen an individual is required to wear Personal Protectin Equipment? Ifso, uhat is the trigger level orpmcess? Ifnot, providejustflaxtionfor not having a triggerlew!orprocess.

KMC Response: For the three uranium isotopes, the Class Y ALI is the most conservative of those listed in 10 CFR 20; i.e., if KMC tested these wastes and was'able tojustify Class W or Class D, the cahdmai exposures would decrease. For thorium (both Th-232 & Th-228) Class W is the most enanervative. KMC will either collect the appropriate samples of waste materials to deterinine the actual solubility class, or conservatively assign exposures for uranium assuming Class Y, and for thorium assuming Class W.

Page 11 of 21

pp to Pp for Additional hJwouds KMC Custung Site Decomnussioning Plan KMC currently plans to use 'Ihenno NUtech in Albuquerque, New Mexico for the analysis of bionssay samples. KMC has contracts with several ot'cr internally approved labs and may change labs at KMC's discretion. We r-M input from 'Ihermo NUtech on the collection of bioassay samples, and were advised of two primary requirements: a minimum sample volume, and the absence of sample preservative. 'Ihese two requirements were incorporated into the site prnreaue for bionssay sample collection.

'Ibe collectina frequency is neither monthly nor periodic, but is driven by action levels ari 8-*M in NRC I Lwnne Cnndition 11 D. The license requires urine analysis for uranium isotopes when air samples yield >40 DAC-his for a single air sample or > 100 DAC-brs accumulated exposure for any one worker. It requires fecal analysis for thorium isotopes when either acute or chronic exposures exceed 100 DAC-hrs.

' 'Ibe KMC O=hing site does not currently have any Airbome Radioactive Areas. KMC does not routinely perform baseline binamanys prior to an individual's initial entry into a Radioactive Materials Area.

Regulatory Guide 8.9 " Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program" states the following:

"Binaanny services should be available if the types and =aatities of radioactive material licensed for use at the facility could, under normal operational occurrences, result in airborne levels in normally occupied areas e= Ming DACs. Pmvisions should be made for the collection of pymyristc samples, analysis of binamany samples, and evaluation of the results of these analyses to determine intakes."

"Bionssay unnamuements used for demonstrating compliance with the occupational dose limits should be conducted oRen enougti to identify and quantify potential exposures and resultant intakes that, during any year, are likely to collectively exceed 0.1 times the ALI."

"An individual's baseline measurennt of radioactive material within the body should be conducted prior to initial work activities that involve exposure to radiation or radioactive materials, for which monitoring is required".

'Ihe KMC Oiahing site does not currently have (and does not anticipate) any nonnally occupied areas with airborne levels in excess of 1.0 DAC and does not anticipate potential exposures e=Miag 0.1 times the All. KMC does not anticipate that d==arnia=ianing activities will trigger the 10 CFR 20.1502 requirement for monitoring. ' lased on 10 CFR 20.1502, in conjunction with Reg. Guide 8.9, KMC thus does not perform mutine bioassay measurements or baseline binnaanys.

KMC pcw an intemal Technical Evaluation evaluating the potential for generating airbome mdioactive materials during pmjected work activities at Pit 4. 'Ihe evaluation irvlicateri that this area should not be considered an ARA and that respiratory pr**ian would not be required for those work activities evaluated. KMC plans to update this Technial Evaluation prior to Page 12 of 21 I :

Responses to Request for Additional Information KMC Cushing Sire Decornmissioning Plan commencing work in other areas. KMC will continue to perform workplace air sampling in acconlanz with I hane Condition D, and to validate this technical evaluation. Air sampling will continua to be the primary methodology for measurement of internal exposures. KMC will maintain biamanay services, as nacenaary, to implement the requirements of License Condition 11 D. However, as long as occupational exposures are below the monitoring requirements of 10 CFR 20.1502 and Reg. Guide 8.9, KMC will not perform any baseline, periodic, or tennination bionssays.

KMC rnaintains three environmental air samplers that collect samples over an appmximate seven-day period. 'Ibese are currergly located near the Dynergy petroleum tanks north of Deep Rock Road, at the northeast corner of the site, and in the southeast portion of the site. 'Ibese locations may be changed as appmpriate.

In addition, KMC will place area air samplers downwind of h+u L=4 r.1 ig activities in accordance with liceme Condition D. 'Ihese area air samplers will be placed downwind of the work and will be located as close as practical without interfering with the work. Lapel samplers will also be used in accordiac with license Condition D. Iapel samplers will be issued to the potentially maximum exposed individual and to others as deemed appropriate.

Regulatory Guide 8.25, Table 1, " Air Sampling Recommervlarinna Based on Estimated Intakes and Airborne Concentrations" recommends that for work areas where the estimated intake is less than 0.1 AIJ, and the estimated airbome concentration is greater than 0.01 DAC:

"Some air sampling is appropriate. Intermittent or grab samples are appropriate near the lower end of the range Continuous sampling is appropriate if -

concentratici 4 are likely to exceed 0.1 DAC averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or longer."

KMC expects workplace enncentrations to stay below 10% DAC averaged over forty hours, and KMC expects annual worker intakes to remain below 0.1 All. KMC will comply with the specific recomamistinn above and other rewnhians within Table 1 of Reg *ary Guide 8.25, should workplace ennditinna change. As stated on page lii of NUREG-1400, "NURFB-1400 is not and should not be used as a regulatory corupliance document... NUREG-1400 is a technical resource for the licensee to use to obtain technical information when information is wanted." In hadag with the intent of NUREG-1400, KMC intends to use NUREG-1400 as a resource document.

KMC cunently uses the action levels of 0.5 and 1.0 DAC. At 0.5 DAC, KMC will perform an '

evatustion to determine what dust suppkm measures were in effect and what additional measures should be Wad, if any. At 1.0 DAC work will be stopped until conditions are changed to prevent a reoccurrence.

KMC issues respiratory prnea*ian ~=>in nant (RPE) at the trigger levels established in 10 CFR 20.

After engineering and administrative controls, RPE is required when entering Airborne Radianceivity Areas, defined as areas with concentrations greater than 1.0 DAC, or where intemal exposure could exceed 12 DAC-brs in a week (30% DAC). As explained in Pa-w=a 11 (b)

Page 13 of 21

Responses to Request for Akhtional Infonnarion KMC Cushing Site Decommissioning Plan above, KMC does not expect to use RPE for radiological protection during Pit 4 dwTdd.rdig activities, and will update the Technical Evaluation as necessary prior to working in other areas where the work and radioactive source terms are schstantially different horn those in Pit 4 deconunissioning.

NRC Site Decommissioning Plan Reguest #12: Season 5.1.3.3. - Describe theprocessfor d;L...Li.g if theproposed adion limit of 0.5 DAC is nadmifor a spec @c isotope when decommissioning nort is being perfonned. How will this ensure an individual's exposure will not i

exceed TEDElimits?

KMC Response: KMC analyzes both lapel and area air samples approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 14 days after sample collection. De first analysis is performed to check for any non-routine or ur-va-M result. The arrand analysis is performed to document final sample activity after allowing for naturally occurring radon d==_*ar decay. De first analysis could easily exceed 0.5 DAC (even 1.0 DAC), if activity from the radon daughters were assumed to be from n-232.

Nonetheless, based on past experience as to the expected contrilustion of radon d==.*ars to the 12-hour analysis, KMC finds this first analysis useful as a screening tool; i.e., to iruhcate when radiation exposures may be high relative to normal variability. Only the second analysis is needed to comply with the provisions of Regulatory Guide 8.25. KMC may place an air sampler upwind of work activities to use as an informal radon " background" when reviewing results from donwind sampiers.

The TEDE limit will not be exceaded due to the expected airborne concentration levels. KMC expects wMdi.x levels to remain below 10% DAC when aver ged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. Regulatory Guide 8.25 " Air Sampling in the Workplace" recomrnands that in situations where there is a parential for intakes to exceed 40 DAC-brs in a week, air samples should be analyzed promptly on a daily basis. Dere is emnantially no parantini for intakes to exceed 40 DAC-hrs in a week at the work site. KMC does not expect this to change when h -.....Mi...:..g activities begin, based on the limiend radioactive source term and the types of work activities involved. KMC will contirme to monitor the workplace using air sampling and will change the pmgram aw&rg'y if there is a significant change in workplace nnnrentration levels; i.e., e=adia: 10% DAC averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. KMC will canti== to analyze lapel and area air samples using the t~**= described above.

NRC Site Decommissioning Plan Reguest #13: Section 5.1.4. - Provide thefollowing irtformation

' related to the calibmtion ofmonitoring/ survey instruments: (a) cor$nn that calibmtion of these instruments will be perfmned with standants tmceable to the NationalInstitutefor Standards and '

Testing; (b) provide a disem&us on howportable instruments will be stored and maintained: (c) if

. these instruments are cabbmtad onsite by Kerr-McGeepeiw..:' or contmctors, provide the qual @caaion requirenentsforpersonnel to perform this task, a list of the tmining required to be qual @ed to perjbrm this task, and a list ofsources and quantities used: (d) provide a discussion on

the services ofofsite labomtories to be usedfor either normal sample analysis, orforproviding

- quality assumnce cross-cheds; and (e)for instrument checkspaifwz.:s on a daily basis, discuss uhat acdons will be takes if an adverse trend is observed; e.g.,' is the instrument taken out of service ifgreater than plus or minus 20 percent deviationfrom a "nproducsble sourte. " You Page 14 of 21

Responses to Request for Additional Informahon KMC Cushing Site Decommissioning Plan indicate in Tame 5.1 that the MDA)br the Nat multidaannel analyzer is being enluated, pnmide the nmdts of this enluation. Cor$1nn that the report willinclude chi-squared tests and data.

KMC Response: (a) - Monitoring / surveying instruments are calibrated using NIST traceable standards. Gamma meannirig insertanenen are energy calibrated with a non-traceable Cs-137 source (traceability is not required because the source strength is not relevant to the energy calibration).

De gamma scanning instannents to be used at Pit 4 and at the disposal cell are also source calibrated with NIST traceable D-232 slab sources containing approximately 10 pCi/g of n-232.

(b) - Portable instnanents are stored within the health physics lab, and are maintained in designated storage areas, danaMia= on their operability status, i.e. calibrated instruments are stored separately from uncalibrated and/or out-of-service instruments.

(c) - Individuals must successfully qualify using the site Qualification Matrix system for the calibration of these instruments. The individual must pemonally demonstrate his/her ability to calibrate the instruments in mwid-w. with established prncMures to either the RSO or the Health Physics Specialist. His involves actually calibrating the instrument, completirig the data records, and answering quentians fmm the reviewer. Qualifications are then documented in the individual's quahfication file, and are available on-site for ia-ian. The portable instmments and their sources are as follows:

lastnrment Source (s)

Imdhan Model 2224 w/ mo. 43-89 NIST traceable Alpha source-D-230,184.6 alpha / beta scintillarion probe Bq. NIST traceable Beta source-Sr-90/Y-Calibrated on-site 90,788.1 Bq Imdhan madel 2221 w/ mo. 44-10 Nal 2x2 Non-traceable Cs-137 source used for the crystal, and mo. 44-82 Nal 3x1/2 energy calibration; NIST traceable D-232 Calibrated on-site slab sources,10 pCi/g, used to cahbrate for field response for the 2x2; the 3x1/2 detector is cahbrated for gmss count rate.

Imdhan Model 19 micro-R meter Calibrated off-site at Imdlum, using their Calibrated off-site standard procedures and NIST traceable standards.

Reuter-Stokes p.-isai ion chamber Calibrated annually at Reuter-Stokes using Calibrated off-site their standard pmcedures and NIST traceable standards.

(d) - Hermo NUtech in Albuquerque, New Mexico is KMC's primary off-site lab. It analyzas KMC' anrmal environmental surface water, ground water, v4 w% soils, and bioassay samples. KMC is not cunently using any off-site lab for quality assurance cross <: hecks.

(e) - If an instrument is outside of the maare range of +/- 10%, the calibration sticker is

... sed and the instrument is taken out of service. When a noticeable trend is discovered, but the.

instmment is still within +/- 10%, the technician notifies the RSO or hit, hignae so an evaluation can be pufu...d. If the trend is naPad or uneWaad he instrument irr~ be taken out of t

Page 15 of 21 L..

i nespomes no nequem for A&inional intonnaion I

KMC Cushing Sise Decommissioning Plan

)

service. The MDAs for the onsite MINAXI soil courser wilMag CUTRANL software have been deterrnined and are as follows for 5 minute and 20 minute count times:

MDA,5 minute count MDA,20 minute count Isotope pCi/g pCi/g U-235 0.6 0.2 U-238 6.7 3.5 Th-232 1.0 0.4 Ra-226 1.4 0.4 KMC does perform chi-squared tests. The results of all QA/QC tests will be mairmained on site for inspection by NRC, but will not be submitted in the final status survey report. All final status data will be included in the final status survey report.

NRC Site Decommissioning Plan Reguest #14: Section 6.4.3.4. - Pmvide thepercentage of surfaces that will be samnedfor unq(ected areas.

KMC Respome: 'Ihere are no more land areas designated as unaffected areas. Cna==~ly, the only " unaffected areas" that remain on site are those portions of buildings that will be used after license terminarian that have not received licensed material. Section 4.2.3 of NUREG/CR-5849 states that scanning of unaffected structures should cover at least 10% the floor and bottom 2 meters of walls. KMC will perform scans covering at least 10% of these areas.

t KMC has classified land areas remaining as either affected areas or undesignated areas. In May, 1996, KMC submitted a final survey report for the haul road cun; dor. In its August 8,1996 commenits on the final survey report, NRC noted that the survey of this area was not consistent with either the unaffected area survey nor the affected area survey methods recommended in j NUREG/CR-5849, and. requested the rationale behind the survey method used. In an August 30,

' 1996 response, KMC described the rationale behind this type of survey, noting that 100% of undesignated areas are scanned. In a letter dated October 22,1996, NRC approved the survey report. KMC plans to survey undesignated areas in the same manner as the haul road curridor, including 100% coverage with scanning istruments.

NRC Site Decommissioning Plan Reguest #15: Section 6.6. - Pmvide a discussion of what is meant by the woni genemity in the statement, "Reportformat and content will "genemlly" follow the tw..: M-=s contained in NUREGICR 5849. " Corgttrm that the Osshingfinal survey report will

- include hgbrmation in Oaqpter 9 ofNUREGICR-5849.

KMC Response: AMir D to NUREG/CR-5849 provides an example of a sample final survey neport. ' Ibis sample report does not include discussion of all the topics listed in Chapter 9 of NUREG/CR-5849. Am=4y, KMC will " generally" follow NUREG/CR-5849 by pmvidag information on all the topics listed in Chapter 9 that are needed to verify that the site complies with the ' -- --- ' ' * ; criteria.

Page 16 of 21

-1

r Responses to Request for Additional Information 1

KMC Cushing Sire Deconunissioning Plan Chapter 9 of NUREG/CR-5849 states, "... sufficient ' formation and data should be provided to m

enable an iP ns:reation and evaluation at some future date of both the survey activities and the derived results. Much of the information in the final status report will be available fmm the decommissioning plan; the written survey plan..." It also states that, "certain support or related information related to the decommissioning process,... are provided as part of the decommissioning plan..." Chapter 9 then r4 a list of topics that, "... the licensee may also incorponte... into the final status survey report". Several of these topics have already been reported at length, and some are not relevant to the final status of the site. For instance, KMC has already reported on:

1. the processes performed and waste disposal practices employed while under AEC licenses,
2. the results of a site-wide characterization survey (which are not relevant to the final status survey), and
3. the results of final status surveys of the unaffected areas and the haul road corridor.

Including this information in the final status survey report would make it needlessly voluminous and confusing. 'Ihis infonnation will be incorporated in the final status survey report by reference.

Reporting only that infonnation that relates to the final status of the site and which has not already been reviewed multiple times will not only make the report more understandable to NRC and the public, but also should expedite the review of the report. For example, discussed in the KMC Response to NRC Decommissioning Plan Request #6 (above), the results of surveys performed on buildings that are dismanded during dammminaioning will be retained on site, but will not be included in the final survey report.

KMC irmends to report the background, site description, decommissioning activities, final survey pmcodures, survey findings, and a summary in aand-w with the outline provided in Chapter 9 of NUREG/CR-5849. 'Ihis will provide the infonnation needed to recreate the final survey and evaluate the survey results.

NRC Radiation Sqfety Plan Request #1: Section 2.4. - For unrestricted areas, you.nated the dose will not aceal 2 mrem /hr. Do you also establish a trigger Lew! at any loner dose rate if the typical measurements are 0.002 mR/hr in unrestricted areas, or how do you ensure that an individual is not presentJbr more than 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> in a year at the 2 miem/hr dose rate (10 CFR 20.1302), so that they do not recein 0.05 rem in a year?

KMC Response: KMC has performed extensive characterization surveys in the past in both restricted and wuestricted areas. Unrestricted areas of the site were surveyed using a Model 19 micr&R/hr meter at ten-meter grid nodes; most of these areas have also been scanned using gamma field survey instruments. Areas of the site that do not appear to meet h....;issioning criteria are fenced as Radioactive Material Areas and Restricted Areas. 'Ihere are cunently no locations on-site (including RMAs) that approach the 2 mrem /hr criteria of 10 CFR 20. Erpa==e rates in unrestricted areas are conmianeritly at background levels. KMC has no work activities planned that would move licensed material into these areas that could potentially change the exposure rates. 'Ihe unrestricted areas are also controlled as KMC site property, and only incidental unauthorized access is possible.

Page 17 of 21

4 1

Responses to Request for AMkinnal Informninn KMC Cushmg Site Decommissionmg Plan

'Ihe RSO reviews the results of the environmental TLDs each quarter for changes or anomalies.

KMC uses the trigger level of 2 miem/ hour from 10 CFR 20.1302. Environmental TID results me included in Attachment D3. KMC has performed aimlatiana to estimate public dose, and ~

these are available on-site for inspection. 'Ihese emientations slaw that the dose in unrestricted

)

areas is far less than 0.05 rem per year.

NRC Aadiadon Sqferv Pier Request #2: Sectim 12.3 - Describe the mdnation uonter tmining, length of time, ami topia. Also, desenbe the annual requaycation tmining topia, length of emining, and how rards are maintained.

EdC. Response: Rmlistinn worker training is performed once each year for those individuals who are M as rmliarian worteni. The requalification training utilim the same course and is adeninistered each year after initial qualification. T ivaae Condition C requires that both the initial and the requalification course must contain the topics described in 10 CFR 19.12. 'Ihe lesson plan encompasses these topics and is available for inspection on site. Training attendance rosters, j

@ exams, blank exams, lesson plans, and student handouts are maintained in the QA file l

_ system at the site.

Ibe actual length of the course is appmximately one day, but varies from class to class. NRC's Fehmary,1997 cover letter accompanying I Lvnne SNM-1999 Amendment #6 stated that course ennannt (not length) was the key factor in judging the adequacy of the radiation worker training. An NRC inspection report dated May 19,1997 stated that the scope of the radiation safety training is adequate.

DEQ Comment 1: KMC r" to DEQ's Comment #7on the Groundwater Pkahnays Woriplan byproposhg that the apgmdient wil (QWW-11.2) uns screened in an intenal with nonerous sandstone. wringers uhile the downgmdient wits wre all screened acmss intenals dominated by mudnones and shales. ThisJhet accountedfor the obserwd wrriation in umnian concentmtion between the ap and domsgmdient wils. Per comersation with Stew Lower, JGWCRegional Hydrologist, the spgmdient inwr Vanoss wil should how been reported as QWW-11.3.

Howeur. OwW-11.3 reported mudstone andfossilifemus mudstone with shell$cp-^.4 owr its x,z;.:.iintenal. Please elabomte or renise the text.

13dC Response: CMW 11.2 is screened in the upper Vanoss formation. 'Ihe screened interval includes several thin sandstone lenses. Most of the water obtained during sampling would have been supplied to the well by these sandstone lenses, since the numlarnoes have very low permeability. CMW 11.3 is screened in a deeper interval within the lower Vanoss. 'Ibe screened interval is emanntially all nautenne. Any water supplied to this well would be coming fran numfasanna. KMC maintaina that most of the variarian in radionuclide concentration of grourdec samples is due to the formation in which the well is screened and the presence of sediment in the water sample. Formarinna with a higher clay content would be eW to provide more sediment

- (with higher background concentrations of naturally occurring radionuclides) than more peeble (sandy) formarinna.

Page 18 of 21

Responses to Request for Additional Information KMC Custung Sire Decommissioning Plan KMC has revised the groundwater assessment =actina (Section 3.5) of the Site Decommissioning Plan, and includes it in Anschment F of this submittal. Dese pages should replace the corresponding pages in the Site Decommissioning Plan. His revision does not change the work proposed, but clarifies sampling activities associated with CivJcis the range of naturally occurring radianctive material in the grourdw.;.r, as well as those associated with identifying releases frorn source areas.

DEO Comment 2: Pksmgraph 6, Sedian 2.4.6.1, pate 2-19 states: " Reported U234:U238 ratios mngefrom 0.7:32 in groundnoter sangpledfrom unter sqpply wils in the United States, unith an aridumeric mean of 4.4 and standant deviatin of5.2 (EPA,1985). ' Please reference the page and pamgngph nanber where this conclusion is reached.

KMC Response: The citation is fmm EPA, Nationwide Occunence of Radon and Other Natural Radioactivity in Public Water Supplies (1989. Table 3.13, on page 55 of the cited report, shows an arithmetic mean of 4.4 for the U-234/U-238 ratio, taken from samples collected fmm 2% public water supply wells. Figure 3.31, on page 56, lists a minimum U-234/U-238 ratio of 0.7 and a maximum U-234/U-238 ratio of 32.0.

DEQ Carment 3: Paragraph 2, Section 2.4.6.1, page 2-20 states: " dferencesin thesolubilities of these two nuclides (1h 232 and Ra 228) shouldyieldfar greater amounts of mdiurn in the gicit-er than thorium. Typically, this dgerence is on the order of100 to 1,000 times more mdian than thorian (HhM,1985). " DEQ has reviewed the referenced document, USGS Water-Sqpply Paper 2254, andfailed to locate the assertion. Please reference thepage andpamgrpph nanber where this conclusion is reached.

KMC Response: KMC was also unable to locate the referenced statement in USGS Water Supply Paper 2254. De statement ermneously revened the words " radium" and " thorium" in the dancineminn reganhag their ratios. In fact, on an activity basis, there are typically 100 to 1,000 times more thorium than radium in bk.iganmd gmundwater, as eg8-M on pages 148 and 149 of the paper. His is not imrnadintely' apparent because typical concentrations of radium are earM in picoCuries per liter, and typical concentrations of thorium are card in micmgrams per liter.

De discussion of ratios of U-234 : U-238 and n-232 : Ra-226 ra in Section 2.4.6.1 was t,Li at historical data and is not relevant to the proposed gmundwater investigation. The referenced paragraph was deleted (page enclosed in Attachment F) and does not change the appropriateness of the proposed groundwater sampling and data evaluation.

I DEQ Comment 4: Section 3.5.2.1, page 3-30 discusses the seledian ofbackground witsfor mdiologicalanalysis. These wells are illustmted in Figure 3.5. In addttion, fourproposed badground wils are depicted in thisJigure with a red triangle. Three of these wils are hydhadically downgmdientfrom RMA-10 uhile an additional wil is dragmdientfrorn RMA-11.

Please clarVy the ppparent contmdiction or revise the text.

Page 19 of 21

Responses to Request for Additional Information

. KMC Cushing Site Decommissiomng Plan KMC Response: The enclosed revised betino 3.5 of the SDP clarifies which monitoring wells will be sampled to develop a range for bra,ipuund groundwater and which will be sampled as upgradient and downgradient monitoring wells for each of the three RMAs.

DEO Conenent 5: Pamgraph 1, Sectim 3.5.5.4, page 3-38 states: ' Filters usdin this inmtigation will be sizd to remove.napendd materials while allowing &ssohwi and colloidal material to pass. " ' DEQ requires that a 5-micarpher be utilizd in groundmater sanple tvilection. It has been documentd that a 5-micronfiter will screen most suspenddparticles while allowing most colloidalparticles to pass through thefiter.

KMC Reqponse: KMC will use a 5 micron filter to remove suspended material from groundwater samples.

AdditionalInformation During review of the SDP, KMC rengairai the need to revise Section 3.2.2.4, " Application of Radioactivity Limits to Subsurface Material". 'Ihis section was revised and is included in this submittal with the other dwp to Section 3 in Attachment F. Changes to the original are shown in redline-strikeout format. - KMC's example of the application of radioactivity limits to subsurface material was not in whu with the g*= ace cited in the section, so the example is deleted.

KMC has sought to be prompt and thorough in rapaading to NRC's questions and comments on the Site Decommissioning Plan (SDP). As the August 20,1999 deadline for approval of dannmmissioning plans under the Site Decommissioning h8===gement Program nears, KMC emphasizes the myency of NRC's review and approval of the SDP. KMC requests a meeting with NRC during the week of June 14 through 18,1999, to discuss these responses. If you have any questions or comments, please call me at :}105) 270-2694.

Sincerely, AW JeffLux Project Manager xc:

C. L. Cain, Chief, Nuclear Materials Licensing Branch, NRC Region IV Blair hitwherg, Chief, Fuel Cycle and Decommissioning Branch, NRC Region IV r%s Citizens' Oversight Cammit*~

Earlon Shidey, ODEQ Darrell Shults, ODEQ Page 20 of 21

Responses to Request for Additional Information KMC Cushing Site Decommissioning Plan References Chadet, B., M. Woods, C. Allen, and D. McVey, A 9=nmarv of Ernaamic Carviitions in Payne County. Oldahoma. Rural Development, Cooperative Extension Service, Oklahoma State University, Apnl1992.

De U.S. Dwsc of Commen:e Bureau of Census.

I Page 21 of 21

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