ML20135F495

Insp Rept 70-0925/96-02 on 961104-07.No Violations Noted. Major Areas Inspected:Review of Site Status,Management, Organization & Controls,Radiation Protection Program, Environmental Program & Followup of Previous Insp Issues

ML20135F495
Person / Time
Site:	07000925
Issue date:	12/10/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135F445	List: ML20135F442 ML20135F495
References
70-0925-96-02, 70-925-96-2, NUDOCS 9612130084
Download: ML20135F495 (8)

Text

-

l ENCLOSURE U. S. NUCLEAR REGULATORY COMMISSION REGION IV ,

i Docket No.: 70-925 License No.: SNM-928 l Report No.: 70-925/96-02 Licensee: Cimarron Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 l'acility: Cimarron Site Location: Crescent, Oklahoma Dates: November 4-7,1996 Inspector: Louis C. Carson ll, Health Physicist Nuclear Materials Licensing Branch Approved By: D. Blair Spit: berg, Ph. D., Chief Nuclear Material Licensing Branch 9612130004 961210 PDR ADOCK 07000925 C PDR

l EXECUTIVE

SUMMARY

Cimarron Corporation, Cimarron Site i NRC Inspection Report 70-925/96-02 This special inspection included a review of the site status, management organization and controls, radiation protection program, environmental program, and followup of previous 4

inspection issues.

Manaaement Oraanization and Controls The licensee had maintained its management organization and controls program consistent with the license requirements (Section 2).

Radiation Protection The licensee had performed operational checks on the soil counting system in l accordance with applicable procedures. A mid-range bias in the counting system '

was determined not to be significant (Section 3).

An inspection followup item was closed concerning bioassay results exceeding action levels (Section 5).

4 Environmental Protection Prior to the inspection, the licensee had notified the NRC of the presence of Tc-99 in groundwater samples. An inspection followup item was opened to review the licensee's future followup of radiological occurrences to ensure that issues similar to l the Tc-99 finding will be promptly identified and investigated (Section 4).

1 i

I i

Report Details 1 SITE STATUS AND CLOSEOUT INSPECTION AND SURVEY (83890) l Portions of the radiation protection and environmental protection programs were inspected  ;

to determine if the licensee was implementing the programs in accordance with the license. i The licensee's Decommissioning Plan had been submitted to the NRC in April 1995; however, the plan had not been approved. The licensee's current activities included soil l

sampling and surveys, characterization of radioactive material areas, and facility maintenance. Remediation at the Cimarron site was more than 90 percent complete. The licensee continued to implement the Decommissioning Plan despite it not having received NRC approval. ,

l 2 MANAGEMENT ORGANIZATION AND CONTROLS (88005) l l

a. Inspection Scope The inspector reviewed License Condition (LC) No.10 to determine compliance with the referenced correspondence, supplements, and appendices to the license. l

b. Observations and Findinas The inspector examined severallicensee submittats to determine if the licensee was implementing described programs and procedures. The inspector found that the licensee's programs, as implemented, adequately met the intent of the submittals. The inspector noted that a letter from the NRC Region 111 office dated September 14,1990, was not incorporated into the license. This letter authorized the licensee to discontinue the submittal of 10 CFR 70.79 semiannual effluent reports. On November 12,1996, the licensee requested amendment of the license to include reference of this letter in this license.

c. Conclusions The licensee appeared to be maintaining its programs consistent with the license submittals referenced in LC No.10.

3 RADIATION PROTECTION (83822)

a. Inspection Scope An inspection of radiation detection instruments used in radiation protection and decommissioning activities was performed to ascertain whether the licensee had compliec' with regulatory requirements established in the license and 10 CFR Part 20.

4 l

b. Observations and Findinas l

The inspector observed health physics technicians (HPTs) perform quality assurance i (QA)/ quality control (OC) operational checks on the soil counter. Cimarron's soil counter is a sodium iodide multi-channel analyzer radiation detection system. Radiation Protection Procedure KM-Cl-RP-47, "Cimarron Soil Counter Operation," was the procedure used for the soil counter. The inspector observed HPTs perform the operational checks in accordance with the procedure. Three reference standards were used in the checks. The inspector found the measurements of the low and high range standards to be in close agreement with their respective reference activities. The reference uranium activity in the mid-range sample standard DP-2 was 134.6 picocuries/ gram (pCi/g). The soil counter operational check sheet entries from October 18 to November 6,1996, revealed that the DP-2 standard on average measured 119 pCi/g, which was 12 percent loss than the j reference activity; however, the NRC determined that the magnitude and region of bias i was not a significant concern.

c. Conclusions

The licensee had performed operational checks on the soil counting system in accordance with applicable procedures. A mid-range bias in the counting system was determined not to be significant.

4 ENVIRONMENTAL PROTECTION (88045)

a. inspection Scope The inspector reviewed part of tha !!censee's environmental protection activities to determine compliance with license and regulatory requirements. Areas reviewed included the licensee's groundwater monitoring program, which recently detected Tc-99.

b. Findinas and Observations On October 9,1996, the licensee notified the NRC that Tc-99 had been identified as a groundwater contaminant on the site. The licensee measured 4760 pCill in well No.1208.

The NRC effluent limit for Tc-99 is 60,000 pCi/l, but the Environmental Protection Agency proposed drinking water standard is 3790 pCi/l. The inspector's review of the licensee's activities regarding the Tc-99 matter revealed that the licensee had not developed a plan of i action in light of this constituent exceeding the EPA standard. The licensee had contacted various government agencies and other companies that have experience with Tc-99 contamination.

The inspector reviewed the licensee's Procedure KM-CI-RP-43, " Environmental Monitoring." The inspector also reviewed the Cimarron 1995 environmental sampling report that was generated in accordance with the environmental monitoring procedure.

According to the environmental monitoring procedure, environmental action levels (EALs) were established for water samples that measured more than 15 pCi/l gross alpha radiation

v and greater than 20 pCi/l gross beta radiation. The 1995 environmental data revealed that various monitoring well sample results exceeded the licensee's EALs. Licensee personnel showed the inspector environmental data for samples collected prior to 1995, which also indicated that well samples routinely exceeded the site EALs.

Section 5.7 of Procedure KM-Cl-RP-43 identified several actions that the radiation safety officer was to perform when responding to and investigating EALs that have been exceeded. One such action was to analyze and review probable causes. The inspector noted that the licensee had not initiated followup pursuant to Procedure KM-CI-RP-5,

" Radiological Occurrence Reports (RORs)" to investigate the action level exceedances.

Licensee management explained that the Tc-99 finding resulted from an ongoing investigation of EALs being exceeded in groundwater measurements. Licensee management further explained that a groundwater characterization report would be submitted to the NRC in December 1996 and would result in the NRC establishing site specific cleanup requirements. Therefore, the licensee was not planning to fully implement corrective actions until after the characterization report was reviewed by the NRC.

Licensee management was aware that possession of Tc-99 may require a license amendment: however, Cimarron would need to fully investigate the source and origin of the Tc-99. Despite the licensee's current actions to address the presence of Tc-99 in samples, had the licensee followed up on environmental action level exceedances more formally, the identification of Tc-99 would likely have occurred much sooner than it did.

At the time of the inspection, licensee procedures for followup and investigation of radiological occurrences were not binding; however, they will become NRC requirements

.when a pending amendment is approved. An inspection followup item was opened to review the licensee's future followup of radiological occurrences according to procedural guidance (Inspection Followup item (IFil 70-925/9602-01).

c. Conclusions The licensee had notified NRC of the presence of Tc-99 in groundwater samples. An inspection followup item was opened to review the licensee's future followup of radiological occurrences to ensure that issues similar to the Tc-99 finding will be promptly identified and investigated.

5 FOLLOWUP (92701) 5.1 (Closed) IFl (70-925/9601-01): Bioassav investiaation Cimarron's in-vitro bioassay action level was 3.0 pCill. The inspector had noted that one worker's bioassay results measured 3.05 f_ O.13 picoCuries/ liter (pCi/l) in April 1995.

Several other workers' bioassay results were in excess of 3.0 pCi/l when the margin of error was added into the measurement. According to the Radiation Safety Officer (RSO), a NCR 95-002 was written against their contract laboratory concerning analytical problems in June 1995. However, the RSO had not completed any bioassay action level dose investigation and NCR concerning the 3.05 pCi/l measurement or similar elevated bioassay results in 1995. Cimarron used the NCR to conduct ROR investigations and other types of

a

(

6-1 1

1

, inspections. The RSO stated that they would provide the results of their NCR investigation 4 when it was complete.

On March 13,1996, the licensee issued NCR 96-008, " Bioassay Exceeding Action Levels."

During this inspection, the RSO provided NCR 96-008 and Cimarron internal memoranda

} concerning the disposition and closure of the elevated bioassay results. The licensee found I that the contract laboratory procedures were incomplete which caused the bioassay results I

to be elevated. All previously elevated bioassay results were reanalyzed, and the results were less than the bioassay action level value. Based on the inspector's review of the

licensee's completed NCRs and bioassay investigation reports, the inspector determined that the elevated bioassay results were erroneous.

j The inspector also concluded that the licensee's NCR process was an effective tool for j investigating and documenting radiological concerns.

6 EXIT MEETING

SUMMARY

! The inspector presented the inspection results to the representatives of the licensee at the conclusion of the on-site inspection on November 6,1996, and during a telephone conversation on November 7,1996. Licensee representatives acknowledged the findings i as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.

I 1

4 I

5 .

l 4

I l

i i

_ _ . _ - - . _ . _ _ .. . _ _ _ _ . . _ .._ _._, _ _ _ . . _ _ _ . _ . _ ~ _ . . . _ _ . _ . _ _ _ _ _ _ _ _ _ _ .__

4 .

I ..

l PARTIAL LIST OF PERSONS CONTACTED

' icensee 1

} Cimarron Corooration M. Hodo, Qua'lity Assurance Manager 1

J. Kegin, Site Manager J. Larsen, Vice President K. Morgan, Radiation Safety Officer i

l Contractor Personnel S. Marshall, Principal, Chase Environmental Group, Inc.

4 R. Sauer, President, Chase Environmental Group, Inc.

1- W. Rogers, Technical Consultant State of Oklahoma l M. Broderick, Director, Oklahoma Department of Environmental Quality (ODEO),

l. Radiation Management Section 1 M. Calvey, Staff Epidemiologist, ODEO 4 E. Shirley, Environmental Engineer, ODEQ j G. Smith, Senior Environmental Specialist, ODEO NRC Personnel 1

L. Carson 11, Health Physicist, Region IV i

j INSPECTION PROCEDURES USED IP 83822 Radiation Protection j IP 83890 Closeout inspection and Survey i IP 88005 Management Organization and Controls i IP 88045 Environmental Protection ITEMS OPENED, CLOSED AND DISCUSSED l

Ooened i

70-925/9602-01 IFl Licensee followup of radiological occurrences, i

Closed j ,

i 70-925/9601-01 IFl Bioassay Investigation i

i Discussed a

i None ]

, l 4

, _ __ y _ ,

7 LIST OF ACRONYMS USED IFl Inspection Followup item EAL Environmental Action Level HPT Health Physics Technician LC License Condition NCR - Non-Conformance Report PDR Public Document Room ROR' Radiological Occurrence Report QA Quality Assurance QC Quality Control RSO Radiation Safety Officer Tc-99 Technetium-99 4

s i

c i I  !

i i i

i i i i

! J k i i

t l'

j 1

4 k

j 4

4

. ~ , . - - - , . , , - - . _ _ . - - s. , m ,______ _ .. ,