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WASHINGTON. D. C. 205$6% February 25, 1991

.....

Docket No. 40-2061 Board Notification 91-04

MEMORANDUM FOR: Atomic Safety and Licensing Appeal Boardand All Parties '

FROM: Charles J. Haughney, ChiefFuel Cycle Safety BranchDivision of Industrial and

Medical Nuclear SafetyOffice of Nuclear Material Safety

and Safeguards|

SilBJECT:NEW INFORMATION POTENTIALLY RELEVANT AND MATERIALTO BOARD PROCEEDING IN THE MATTER OF KERR-MCGEECHEMICAL CORPORATION, WEST CHICAS0 RARE EARTHS FACILITY,DOCKET 40-2061-ML

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In conformance with the Co:nmission's policy on notification of LicensingBoards, Appeal Boards, or Commission of new, relevant, and materialinformation, this memorandum calls attention to the documents listad below.

The documents being brought to the attention of the Board as information whichmay be relevant and inaterial to issues pending before the Board are:

Letter to Thomas W. Ortciger, Director, Illinois Department of Nuclear Safety,from Carlton Kammerer Director, State Programs, Office of Governmental andPublic Aff airs, dated February 13, 1991. (Incoming letter to Mr. Kammerer wasforwarded to the Board by Board Notification 90-15, dated December 7, 1990.)

Letter to Tracy Shackelford from Robert M. Bernero, Director, Office ofNuclear Material Safety and Safeguards, dated February 13, 1991, with incomingletter to Chairman Carr from Tracy Shackelford, dated January 10, 1991.

News Release from the Illinois Department of Nuclear Safety, dated F ebruary 14,' 1991, with its enclosures:

1. Letter to Joseph G. Klinger, Head, Licensing Section, Department ofNuclear Safety, State of Illinois, from John C. Stauter, Kerr-McGeeChemical Corporation, dated February 8,1991.-

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2 February 25, 1991

2. Letter to John C. Stouter, Kerr-McGee Chemical Corporation, fromJoseph G. Klinger, Head, Licensing Section, Department of NuclearSafety State of Illinois, dated February 14, 1991,

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Charles J. Hau ey, Chief IFuel Cycle Safety Branch i

Division of Industrial and-

Medical Nuclear SafetyOffice of Nuclear Material Safety

and Safeguards

Enclosures:As stated

icc: Attached List

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2 February 25, 1991 j

2. Letter to John C. Stauter, Kerr-McGee Chemical Corporation, from-Joseph G. Klinger, Head, Licensing Section, Department of NuclearSafety, State of Illinois, dated February 14, 1991.

ORIGINAL SIGNED BY

Charles J. Haughney, ChiefFuel Cycle Safety BranchDivision of Industrial and

Medical Nuclear Safety.Office of Nuclear Material Safety

and Safeguards

Enclosures:"As stated

cc: Attached List,

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DistributionNRC File Center Docket No. 40-20611 PDR/LPDR NMSS R/F INSB R/FCJHaughney JJSwift PJehle. AHodgdon

| B0'Connell MCDaniel FBrown

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FEB 131991

Mr. Thomas W. Ortciger, DirectorIllinois Department of Nuclear Safety1035 Outer Park DriveSpringfield, IL 62704

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Dear Mr. Ortciger:,

This letter is in response to your December 5,1990 letter which informedthe Nuclear Regulatory Cornission (NRC) that the Illinois Departsent ofNuclear Safety (IDNS) had implemented 32 Ill. Adm. Code Section 332.30(c)and notified Kerr-McGee Chemical Corporation (Kerr-McGee) that its currentlicense will expire in 90 days. Your letter also stated that this servedas notification to enable the NRC to carry out its responsibilities underSection 2740 of the Atomic Energy Act, as amended (AEA), as discussed in

: Chairman Carr's letter to Governor Thompson.'

We disagree that implementation of Section 332.30(c) of the Illinois .

regulations serves to invoke the provisions of Section 274o of the AEAapplicable to State alternatives to requirements adopted and enforced by-

NRC, 9ather, we believe that, since Section 2740 is to be invoked whena st.bstantive alternative can be evaluated for its safety and

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environmental effects under the Section 2740 standard, and no suchsubstantive alternative is provided in Section 332.30(c), it ispremature at this time to invoke the provisions of- Section 2740..

Therefore, no further documentation or submittals are required with;

i regard to application of Section 332.30(c) of the Illinois regulations| to the Kerr-McGee license. On December 18, 1990, this was discussedj between Mr. Kerr, IONS, and Mr. Sollenberger, State Programs.!

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Weap(2) material.preciate your prompt notification of the IDNS action involving! 11e. If further clarification is needed, please contact( Vandy Miller (301-492-0236) or Dennis Sollenberger (301-492-0819).:

! Sincerely,1

MIINJIDA.d.O@0A MMNI

i. Carlton-Kasserer Director,

State Programs; Office of Governmental and Public Affairs

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Tracy Shackelford |'

"*S35 E. York StreetWest Chicago, IL 60185 gg 131991*

Dear Ms. Shackelford;

I as responding to your letter of January 10, 1991, to Chairman Carr; expressingconcerns about potential hazards associated with unprotected waste material l

at Kerr-McGee's site in West Chicago Illinois. As the matters about L::hy>u express concern are related to IItigation that may come before the Commissionfor a judicial-type decision in which Chairman Carr will-particibe improper for him to connent outside of the formal proceeding.pate, it would

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In addressing your concern regarding hazards to the environment caused by thesite's not being protected from external elements, two points should be noted.First protective covers consisting of a synthetic asphalt / fiber layer havebeen a,pplied to the top of piles of contaminated material although not to theentire 43-acre site. Additional protection has been provIded by a layer ofsoil applied to dried-up ponds and other specific areas containing concentrationsof contamination. These measures were taken by Kerr-McGee in the early 1980sto minimize spread of contamination.- Second, continuous monitoring stationsare located arcuad the site's perimeter to ensure that offsite contaminationand exposure leve?s stay within acceptable limits. These stations measurecontamination levels in the air as well as direct radiation exposure. Substantialmonitoring of the groundwater has been done at the site and in its vicinity,showing tant the groundwater pollution existing from earlier site operationshas been improving in recent years. Nevertheless, Kerr-McGee's plan for onsitedisposal or any of the alternative offsite disposal methods evaluated by theNRC Staff in its Supplement to the Final Environmental Statement would-appreciably ,enhance environmental protection.

Regarding the oral argument presented before the Appeal Board on January 16,1991, the Appeal Board has not yet issued its decision on the issues that wereargued. The Appeal Board's decision, once issued, will be subject to review

j by the Commission and to an appeal to the United States Court of Appeals.

| The resolution of these and other legal issues will determine the terms and.conditions of the cleanup. _i

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! Thank you for your interest in these matters.

! TG| [Jtobert M. Barnero, Directori 0 Office of- Nuclear Material ~ Safety-i

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lilinois Department of Nucler" Safety ;

1035 Outer Park Drlw Springfield, Illinois 62704 Q17) 785-98681

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KERR HCGEE SUBMITS February 14, 1991

LETTER TO IDNS FOR IMME0! ATE RELEASE

SPRINGFIELD, IL.....Kerr McGee Chemical Corporation recently responded

to a letter from the Illinois Department of Nuclear Safety (INNS) notifying

the company its license for the West Chicago facility would expire in March.

However, Kerr-McGee did not submit an application for a 6ew license.

On Oc: ember 5,1990, IDNS, which has regulatory authority over the 13,

million cubic feet of radioactive thorium mill tailings at the West Chicago

facility, notified Kerr McGee that its license would expire 90 days fromi

receipt of the letter. The expiration was allowed under IDNS regulations forthorium mill tailings.

"We had expected Kerr McGee to submit a license application, since we

notified.them that their itcense would expire on March 10, 1991," said ThomasW. Orteiger, IONS Director. "We are disappointed that they chose instead to

! simply send a letter taking issue with the regulations."

On Thursday, IONS responded to Kerr-McGee's letter to address issues

raised by the company. The letter explained that any authority Kerr McGee has

under its current license to dispose of thorium mill tailings will expire onHarch 10, 1991. After that date, the company will need to apply for and

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obtain a license from IONS.

The Department emphasized that even if Kerr-HcGee allows the license to,

expire, it will still be responsible for site reclamation, decontamination,

stabilization and closure, observation and maintenance and transfer of the

license to the ultimate governmental owner.!

(Lettersattached)!

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KEMMc0EE i'HF.nimal CMPORMICN, ... ou cae . ee.ow om. ow.o= ==

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February 8, 1991

CERTIFtBD MAILRETURN RECE!PT REQUESTED

'Joseph G. Klinger, Head \

1.icensing Sect,on i

111tnois Department of -Nuclear Sa fety |

1035 Outer Park Drive i

Springfield, IL 62704i Dear $4r. Klinger:

* On December 10, 1990, I raceived letter notif ying -Kerr McGee-Chemical Corporation ("Kerr-McGee") yourthat, in accordance with section

4,

332.30(c) of the State of tilinois (" State") regulations,,

Kerr McGee's NRC License Number STA 583 will expire 90 days from |: receipt of the letter. Letter by Joseph G. Klinger to John' C.: Stauter (Dec. 5 1990). The Fact 11ty NRC license has an expirationdate of February, 28, 2000.

1 In Kerr-McGee's view, IDNS' decision to truncate the expiration date.

i of the license without any cause or opportunity to be heard vlotatesi due process of law. Moreover, the State regulation which purports toj authortte IDMS to take this action is inconsistent with both existingi NRC guidelines on Section 274(b) regulatory . t rA ns fers and thei parallel State regulation that governs other non-section -118(1)nuclear material. NRC, Criteria f or Guidance of States and NRC inDiscontinuance of NRC Regulatory Authority and Assuspeton Thereof bV;

States Throuch Agreement, 4o Fed. Reg. 7,540, 7,543 (para. M),

!(1981); 3z I t ,. Admin, code 330.360

| Further, steps to bring about expiration of tho existing itcensei

would -also be improper in light of certain aatters now pending beforej the courts and the NRC. As you know,- a petition challenging. the!

propriety of the transfer of regulatory juttsdiction over sectioni ne:2) byproduct material to the ' State i s now pending before the'

United States- Court of Appeals. Kerr-McGee Chemical Corp. v. NRC,No. 90-1534 Cir.). Kerr-McGee also has pendtng betore the"WC;

! / ,

Appeal Board (D.C.:a action for a protective order directtng the State tovacate its notice of license expiration. Motion for a Protective;

order, Kerr McGee Chemical Corp. (West Chicago Rare Earths Facility).Dkt. No. 40-2001 ML tDec. u, 1990). And, IDNS Director Thomas W.Ortciger. has informed the NRC that IDNS will submit an explanationand an analysis of the level of protection thati

Itcense expiration in order to allow the- Commission to complete thewill be afforded by|'

evaluation required by Section 274(o) of the Atomic Energy Act.Thomas W. Ortciger to Carlton Kammerer (Dec. 5, 1990). To ouri

knowledge, the Commission has not yet acted on the matter..

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Votwithstanding the above, we understand there (s' no need f o t'Kerr-McGee to apply f or a new license. Your letter states that "theexpiration dato applies only to the receipt and processing of oresand enplacemene o f- byproduct material." Accordingly, c i~osu reactivities would not be adfected. We see no reason for Kerr McGee toapply f or a new 11 cense which your letter suggests we may considerbecause Kerr-McGee does not currently receive or process ores or !produce byproduct materials for emplacement by way of such processingat the West Chicago fa'cility. Moreover,'the processing factitties

|have been dismantled snd KMCC has no plans to construct a new millingf acility or to receive ores for processing at the site, of course,as part of its closurecrelated activities, Kerr McGee may returnmaterials to the site that have been removed to off-site areas.

Your letter speaks to our responsibility for implementing finalclosure of the f actit ty. Kerr-McGee has always fully recognized thisresponsibility and to that end, Kerr-McGee submitted a closure planfor the f actitty to the NRC staf f in 1978. In accord with evolvingregulations, technology and analytical techniques, Kerr-McGeeincorporated appropriate revisions in the ensuing years. A copy of

i the Kerr McGee closure plan is included in the NRC license docket forthe NRC proceeding in which IDNS participated and we know that theIDNS is fully familiar with it. The NRC approved the plan and issued

; a license authorizing decommissioning and final on-site stabilization! of the f acility related materials in accordance with the Kerr-McGee| plan. NRC Materials License STA-583 (Feb. 23, 1990). The appeal of

the NE decision . authorizing on-site stabilization is now pendingi before the NRC Atomic Safety and Licensing Appeal Board (" Appeal

Board"). Kerr McGee Chemical Corp. (West Chicago Rare Earths'

Facility). DKt. No. 40 2001-ML. Oral argument was held on January16, 1991.

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It is apparent f rora the foregoing that there is substantialuncertainty surrounding thu disposition of the West Chicago wastes.The _ IDNS jutts' diction is subject to challenge and, in any event, theef fectiveness of the proposed application of section 332.30(c) 15-subject to significant doubt. Moreover, as discussed above, the NRCAppeal Board's review of the IDNS challenge to Kerr-Mehe's finalclosure plan has not yet been resolved. Until some of thisuncertainty is dispelled, Kerr-McGee does not intend to undertake

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activities at the facility to implement its closure plan. We willnotify IDNS before any such activities are commenced.

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Although by submission of this letter Kerr McGee does not waive itschallenge to any exercise of authority over the f acility by the IONS,Kerr.McGee understands that it has adequately satisfied anyobligations that might be seen to arise from the IDNS regulations.Please contact me if I can provide any further information.

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Sincerely,

.

John C. Stauter, Vice PresidentEnvironmental Services j

Ke rr-+IcGen Corpora tion '

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STATE OF |LLINOIS

DEPARTMENT OF NUCLEAR SAFETY1035 OUTER PARK DRIVESPRINGFIELD,IL 62704 .

(217)785 9900 ;'

Tnome W. Omicosa JedEcon'

february 14, 1991

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CERT!f!E0 MAIL

Or. John C. Stauter, Vice PresidentEnvironmental ServicesKerr-McGes Chemical Corp.Kerr-McGee Center

,

Oklahoma City, OK 73125,

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Dear Dr. Stauter:

On February 8,1991, I received a letter from you regarding theexpiration of Kerr-McGee Chemical Corporation's (Xerr-McGee) license No STA-583. Your letter, which was sent in response to a letter that. I sent to youon December 5, 1990, raised several issues that I would like to address atthis time.

In my letter of December 5,1990, I stated that "the expiration dateapplies only to the receipt and processing of ores And the emplacement ofbyproduct material" (emphasis added). Thus, any authority that Kerr-McGee mayhave under license No. STA-583 to dispose of lle.(2) byproduct material willexpire upon expiration of that license, if, after the expiration date,March 10, 1991, Kerr-McGee wishes to dispose of byproduct material at the WestChicago facility, it will be necessary for Kerr-McGee to apply for and obtaina license from the Illinois Department of Nuclear Safety (Department). Thisis true for byproduct material currently located at the West Chicago facilityas well as for such material brought to the facility from off-site areas.

;

into conduc.your letter you stated that you were unaware of any Cosmiission actiont a hearing, under Section 274(o) of the Atomic Energy Act, to i,,

f consider Section 332.30(c) of the Department's rules. We have been-informed-'

by HRC staff that such a hearing will not be conducted with regard to the. implementation of Section 332.30(c). Upon direction of the NRC staff, the

Department will not be preparing any further submittals to NRC on this issue.L

| Finally, as the Department has not received an application for renewalof license flo. STA-583, that license will expire at midnight- on March 10"

1991. As stated previously, upon * expiration of the license Kerr McGee will Iremain responsible for site reclamation, decontamination, stabilization andclosure, observation and maintenance, and transfer of the license to theultimate governmental owner.

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Mr. John C. StauterPage 2February 14T 1991

I appreciate Kerr-McGee's comf tment to notify the Illinois Departmentof Nuclear Safety before comencing any closure activities at the facility,and the Departmerit awaits the receipt of your application.

.

Sincerely,

b. f'

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Jo ph .Klinger,HeIJi Li nsing Section

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cc:

Administrative JudgeThoma3 S. Moore, Chair an Administrative JudgeAtomic Safety and Licensing A oeal Christine N. Kohl -

D

Board Atomic Safety and Ocensing AeoealBoardU.S. Nuclear Regulatory C:m ission

Wasington, OC 20555 U.S. Nuclear Regulatory Comssionwashington. OC 20555

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Administrative JudgeHoward A, Wilber, chairman Administrative Judge

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Atomic Safety and Licensign Appeal John H. Frye, !!!, ChairmanBoard Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Commission; Washington DC 20555 Washington, DC 20555

Administrative Judge' Jerry R. Kline Administrative Judge,

Atomic Safety and Licensing Board James H. Carpenteri U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board

Washington, DC 20555 U.S. Nuclear Regulatory Cosutission,

Washington, DC 20555

Datricia Jehlv. Esq.Counsel for NRC Staff Richard A. Meserve, Esq.Office of the General Counsel Covington & BurlingU.S. Nuclear Regulatory Comission P.O., Box 7566Washington, DC 20555 Washington, DC 20044

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Robert D. Greenwalt, Esq.City of West Chicago Joseph V. Karacanis, Esq.100 Main Street Xaraganis & Whict Ltd.West Chicago, IL 60185 414 North Orleans Street, suite 810

Chicago, R 60610

Joseph A. Young, Jr., Esq.Kerr-McGee Cheetcal Corporation Stephen J. England, Eso.123 Robert S. Kerr Avenue Departmeit of Nuclear SafetyOklanoma City, OK 73125 1035 Out)r Park Drive

Springfiild, IL 62704'

Douglas A Rathe. Esq.Assistant Attorney General Mark M. Randall, Esq.Office of the Attorney General Assistant Regional Counsel100 West Randolph Street-12th Floor U.S. EPA Region V

SCS.TUS-3Chicago, IL 60601 .

230 South Dearborn StreetChicago, 11. 60604

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Jeffrey B. Renton, Esc. Carl Bausch, Esc.Office of the General Counsel Assistant General CounselU.S. EPA Executive Office cf the Dresident

LE-132A Council Environmental.0ualtiy401 M. Street, S.W. '22 Jackson Place, N.W.dashington, OC 2Ca60 aashington, OC 20503

Occteting and Service secti:- ^]),

Office of the Secretary |V.S. Nuclear Regulatory Comm'ssice |Washington, OC 20555

Adjudicatory FileAtor.;ic Safety and Licensing ScardU.S. Nuclear Regulatory CommissionWashington, OC 20555, .

Atomic Safety and Licensing :::ealPanel (5)

U.S. Nuclei.r Regulatory CommissionWashington, DC 20555

Atomic Safety and LicensingBoard Panel (1)*

U.S. Nuclear Regulatory CommissionWashington, O C 2'0555

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Board Notification 91- 04 dated February 25, 1991cc: i

J. Taylor, EDOH. Thompson, DEDSR. Bernero, NMSS

I G. Arlotto, NMSSI W. Parler, OGC

L Chandler, 0GCR. Cunningham, IMNSG. Sjoblom, IMNSA. B. Davis, Reg IIISECY (3) |

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J. Lieberman, OE

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