Cimarron Proposed Revision to License 6/30/1997
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KERR-MCGEE CORPORATION Proposed Revisions to the Cimarron SNM License License No. SNM-928 Docket No. 70-925 June 30, 1997 CIMARRON CORPORATION CIMARRON CORPORATION P. 0. BOX 25861 • OKLAHOMA CITY. OKLAHOMA 73125 S. JESS LARSEN VICE PRESIDENT June 30, 1997 Mr. Kenneth L. Kalman, Project Manager Facilities Decommissioning Section Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re: Docket No. 70-925; License No. SNM-928 Cimarron Corporation Proposed Revisions to the Cimarron SNM License Dear Mr. Kalman: As requested during our conference call on June 17, 1997, the following information is being provided to address all outstanding issues related to the NRC staff's comments concerning Cimarron License SNM-928 and the Radiation Protection Plan (Annex A). The following comments and responses address the verbal comments made by the NRC staff during previous telephone conversations. As requested by NRC staff, Cimarron Corporation has also reviewed the current license conditions and is proposing the following additional modifications and clarifications. Comment: NRC staff commented that Annex A contains specific references to a quality assurance program, but that no reference appeared to be present in Annex A to an overall quality assurance program which would apply to the entire Annex A (Radiation Protection Plan). Response: ( 'Annex A (Radiation Protection Plan) was developed to conform with the requirements contained in the Cimarron Quality Assurance Program. The Cimarron Quality Assurance Program was designed to assure compliance with the applicable requirements of ASME NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities." Cimarron Corporation proposes to revise Section 3.3 of Annex A to include the Cimarron Quality Assurance Program (see Attachment #1). A SUBSIDIARY OF KERR-MCGEE CORPORA/ION Comment: NRC staff expressed concern that Section 6.3 of Annex A, as contained in Attachment #3 of the May 16, 1997 Cimarron Corporation submittal to NRC, did not include the criteria for dose limits for individual members of the public. Response: Attachment #3 of the May 16, 1997 Cimarron Corporation submittal contains a new section 6.3 that is to be inserted into Annex A, and does not replace the previous Section 6.3 titled "Dose Limits for Individual Members of the Public" (original Annex A submittal to NRC dated September 20, 1996). Sections 6.3 through 6.11 of the original submittal will be re-numbered as Sections 6.4 through 6.12. The inserted Section 6.3, titled "Administrative Dose Limits for Occupationally Exposed Individuals", was also revised to incorporate NRC staff comments. Specifically, two sentences were added to the first paragraph of the re-numbered Section 6.3 stating that the Cimarron administrative dose limits for occupationally exposed adults and minors have been established at 80% of the occupational dose limits listed in 10 CFR 20. The administrative dose limits for the embryo/fetus are the same as those listed in 10 CFR 20, as provided in Section 6.2.3. Attachment #2 incorporates all revisions to Section 6.0 of Annex A and presents Section 6.0 in its entirety. Comment: NRC staff expressed concern that a justification for the proposed action level of 11.5 pCi/g total uranium in soil needed to be added to Section 15.5 of Annex A. Response: The average concentration of total uranium in background soils, as determined by the } Cimarron soil counter when calibrated for 2.7 weight percent enriched uranium, is approximately 4 pCi/g. The total uranium concentration corresponding to 25 percent of the BTP Option #1 guideline value of 30 pCi/g is 7.5 pCi/g. This fraction of the guideline value is then added to the average total uranium background concentration at the Cimarron site to derive the corresponding action level for soils of 11.5 pCi/g total uranium (i.e. 7.5 pCi/g + 4.0 pCi/g). Attachment #3 incorporates this clarification into Section 15.5 of Annex A. Comment: NRC staff expressed concern that the wording contained in License Condition #18 of License SNM-928 was unclear and subject to misinterpretation. 2 Response: NRC staff and Cimarron staff discussed possible wording changes to improve License Condition #18. The existing License Condition #18 and the proposed revision are listed below: Existing License Condition #18 18. The licensee shall dispose of the radioactive contaminated solid waste generated by licensed activities at a licensed low-level waste disposal site. Pr ()posed License Condition #18 18. BTP Option #1 soils are acceptable for unrestricted release/use and thus may be left in place as described in the 1981 Branch Technical Position (BTP), "Disposal or On-site Storage of Thorium or Uranium Wastes from Past Operations". BTP Option #2 soils can be disposed of on-site in accordance with License Condition #23. Soils with elevated activities between one and three times the BTP Option #1 & #2 guideline values shall be: 1) tested to assure that the average concentration of surface soil is less than (100/A)1"2 times the guideline values, where A is the area of the elevated activity in m2 as described in Draft NUREG/CR-5849, or 2) tested to assure that the average concentration of subsurface soil is less than the guideline values after application of the NRC "Method for Surveying and Averaging Concentrations of Thorium in Contaminated Subsurface Soil", dated February 13, 1997. Radioactive waste generated by licensed activities, including soils with BTP concentrations exceeding the criteria described above, shall be disposed at a licensed low-level waste disposal site. In addition to the above NRC staff comments, discussions were also held with NRC staff regarding the following additional revisions that are required to provide additional clarification both within License SNM-928 and Annex A. 1. Revision to Table 15-1 of Annex A. Table 15-1 contains the Cimarron Facility Environmental Sampling Schedule. Well #1319 was not originally intended for use as an environmental monitoring well and was incorrectly added to Table 15-1 of Annex A. Well #1319 has therefore been removed from Table 15-1 as can be seen in Attachment #4. Section 15.4 (see Attachment #13 of the May 16, 1997 submittal) was also revised to reflect the removal of Well # 13 19 from Table 15-1. Attachment #3 provides the revised Section 15.4. 2. Deletion of the requirement for 50% of workers in restricted areas to wear lapel samplers. The previous Appendix A to the Cimarron license contained a requirement for lapel sampling. Page 3-7 of Appendix A, dated August 30, 1976 states: 3 "During decontamination and maintenance of the building and equipment, lapel air samplers shall be worn by a minimum of 50% of the personnel involved." In addition, Cimarron Corporation letter dated November 3, 1994 from Dr. John Stauter to Mr. John Austin (NRC) committed to monitoring 50% of workers within the restricted area for internal exposure through the use of lapel sampling. This letter dealt specifically with the potential internal exposure to workers during the disposal of BTP Option #2 soils in the on-site disposal cell. Cimarron Corporation is now proposing that the requirement for 50% of workers to wear lapel samplers within restricted areas be deleted for the following reasons: * Doses due to internal exposures are low at the Cimarron site. For calendar year 1996, the maximum exposed worker was assigned a committed effective dose equivalent (CEDE) of 97.5 mrem due to the intake of uranium. The collective total effective dose equivalent (TEDE) for 1996 for all site workers was 352 mrem. For 1997, the worker with the highest intake had received a CEDE of 20 mrem for the January through May time period. The collective CEDE for all site workers was 99 mrem during the same time period. * Cimarron has an established radiation protection program and utilizes Special Work Permits to assess all hazards associated with all site work. Monitoring requirements shall be specified for each job involving the potential for exposure to radioactive materials. Lapel sampling shall be prescribed for those tasks which have the potential for airborne contamination levels in excess of 10% of the Derived Air Concentration (DAC). " As stated in Annex A, Section 10.2, "Cimarron shall incorporate the guidance contained in U.S. NRC Regulatory Guide 8.25, 'Air Sampling in the Workplace' as an acceptable method for meeting certain survey and dose assessment requirements contained in 10 CFR 20." " Cimarron has an established ALARA program, and is committed to the maintaining worker exposure ALARA utilizing engineering and administrative controls (Section 14.3 of Annex A). * Much of the remaining work to be performed at the Cimarron site should not require the use of lapel samplers as the potential for exposure due to intake is very low. No changes and/or revisions are required to be made to Annex A in order to incorporate this change. 4 3. Deletion of the requirement for permanently mounted air sampling equipment used to determine the concentration of radioactive material in the workers' breathing zone. This requirement is currently addressed in License SNM-928, Condition #11. Cimarron has previously proposed that Condition #11 be deleted from License SNM-928, and incorporated into Section 10.2 of Annex A. The permanently mounted air sampling equipment was previously located within the Uranium Building. However, most of the Uranium Building has now been dismantled. Deletion of the requirement for permanently mounted air sampling equipment is necessary to allow for completion of all decontamination and decommissioning efforts in the general area of the Uranium Building. A recent evaluation of the three remaining permanently mounted air samplers indicated that they were no longer representative of the workers breathing zone.