ML20149E290
| ML20149E290 | |
| Person / Time | |
|---|---|
| Site: | 07000925, 07001193 |
| Issue date: | 01/07/1988 |
| From: | France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20149E282 | List: |
| References | |
| 70-0925-87-02, 70-1193-87-03, 70-1193-87-3, 70-925-87-2, NUDOCS 8801130289 | |
| Download: ML20149E290 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 70-925/87002(DRSS); 70-1193/87003(DRSS)
Docket Nos.70-925; 70-1193 Licenses No. SNM-928; SNM-1174 Licensee:
Sequoyah Fuels Corporation
), err-McGee Center Oklahoma City, OK 73125 Facility Name:
Cimarron Facility Inspection At:
Cimarron Facility, Crescent, Oklahoma Inspection Conuucted:
Decemter 7-9, 1987 Q
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g Inspector:
Georg h France, III
[' "7 - E' Date Gy.i 3
Approved bv-
'ober Greger, Chief
/~ 7 ~d3d3 Fac1'ities Radiation Protection Date Secticn Inspection Summary Inspection on December 7-9, 1987 ' Reports No. 70-925/87002(DRSS);
No. 70-1193/87003(DRSS))
Areas Inspected:
Routine, unannounced safety inspection including organization; radiation protection program; operation review; transportation and radioactive waste; audits and procedures; and nuclear criticality safety.
Results:
For the areas inspected, no violations or deviations were identified.
I 8801130289 880107 REG 3 LIC70 SNM-0928 DCD
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en DET41_ LS 1.
Personi Contagted
- R. J. AdKisson, Director, :%tra' t Menagerdent and Cimarron Operation
- R. L. Fine, Supervisor, Health Physics and Industrial Safety M. W. tiodo, Accounting Supervisor
- J. Kegin, Utilities and Decontamination Superviscr
- A. W. Norwood, facility llanager
- W. J. Rhodes, Uranium Dacontamination Supervisor
- V. Ricnards, Plutonium Decor.tamination Supervisu
- W A. Rogers, Decontamination Supervisor W. Spencer, Senior Project Engineer
- C. H, Thc:npson, Health Physics Specialist USNnC NHSS
- G. Comfort, Nuclear Process Engineer
- D. Sly, Senior HeElth Physicist
- Denotes those present at the exit meeting on December 9,. 1987.
2.
General The inspection of onsite activities, which beaan at 8:30 a.m. un December 7,1987, was conducted to examine decommissio'ning activities at Sequoyah Fuels Cimarron site under Materials License No. CNM-928 and SNM-1174.
Representatives of NRC HQ NHSS were also onsite to reticw the i
status of decommissioning activities and the licensee's. amendment epplication.
3.
Licensee Action on Previously Identified Items I
The inspector reviewed the progress the licer:see had made in correcting j
open items and or observations identified during a previous inspection.
(Closed) Observatien No. 70-925/87001-01; No. 70-1193/87001-01(DRSS)):
Review and update certain procedures in accordance with the approved annual schedule.
The procedure for disposing of radioactively contaminated asbestos material was reviewed and updated to meet the current asbestos threshold levels.
Procedures that described the use of special equipment which is no longer used or has been decommissioned, such as x-ray instrumentation and process glove boxes, have been deleted.
(0 pen) Open Item No. 70-1193/87001-02(DRSS)):
A 165-millicurie cesium source is listed on both the SNM license (SNU,-1174) and byproduct License No. 35-12636-02.
A license amendment application has been filed to retain the source under the byproduct license.
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l (Closed) Observation No. 70-928/87001-03 (DRSS)):
Alpha i:ontamination i
levels shall be maintained below 5000 dpm/100cm2 in controlled areas of the uranium plant.
There doesn't appear.to be any notation that corrective a."ion _was tsken to maintain contamination levels below the 5000 dpm/100i.' ' restriction.
In response, the HP Supervisce initiated an action memo to remind HP technicians to record close out survey data on survey maps after excessive contamination ~ levels have been reduced.
(Closed) Open Item No. 70-1193/87001-04(DRSS)): - Contamination on a plutonium worker's lapel sampler disclosed contamination levels equivalent to 63 MPC-hours.
A review of the bioassay data indicated plutonium levels of less than 0.1 dpm/1, which is indicat.ive of an insignificant intake at most.
The worker was equipped with a bubble hood and supplied air.
Results of three samples indicated that there was no apparent intake of plutonium.
(Closed) Open Itw '>. 70-1193/87001-05 (DRSS)): A lapel air sampler worn by a plutonium worker who was cutting up contaminated flexible ventilation lines with an air saw showed an equivalent exposure level of 44 MPC-hours.
However, the worker was wearing protective respiratory equipment and the corresponding bioassay data indicated 0.1 dpm/1, which is indicative of an insignificant intake at most.
(0 pen) Open Item No. 70-1193/87001-06(DRSS));
Two 6,000 gallon tanks used for plutonium process operations have been cleared of radioactive waste sladge.
Final disposition of these tanks rer.iains under review.
4.
Management 10rganization and Controls, The inspector reviewed the licensee's management organization and-controls for radiation protection and operations, including changes in t
the organizational structure, a.
Organization The licensee has hired four workers since the previous inspection (70-928/07001).
These workers have been assigned to perform r:tivities associated with the nandling, packaging, and shipping of radioactive contaminated soil.
Sequoyah Fuels Cimarron Operation now employes 54 persons in security, health and safety, and decommissioning operations.
No prcDiems ware identified.
j b.
Special Work Permits (SWP) i The inspector determined that special work permits (SWP) appeared adequate for the various tasks observed.
SWP# 0180 which covers the removal of asbestos fiber from pipe joints and SWP# 0176 which requires the use of a portable ventilation sys'.em in conjunction l
with a sand blaster (vac-u-blast) are two of eleven SWP's implemented since the previous inspection.
See Inspection Reports (No. 70-925/87001; No. 70-1193/87001).
The inspector noted that the l
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..e disposal of asbestos fiber, and removal of contamination from concrete walls and floors by vacuum blasting, are co/ered by similar work permits for both the plutonium and uranium facilities.
No problems were noted.
No violations or deviations were identified, 5.
Radiation protection The inspector reviewed the licensee's internal and external exposura control programs, including required records, reports, and notifications.
a.
Internal Exposure Control The inspector interviewed the Health Physics Supervisor conceriing the uranium and plutonium bioassay program.
In addition, a discussion was held with licensee representatives about the use of good practices and guidance provided in Regulatory Guide 8.15 concerning the medical approval of workers selected to wear respiratory equipment.
A review of the bioassay reccrds for the second and third quarte-disclosed that the 40 MPC-hours intake limit for uranium /plutoni.a was not exceeded.
The licensee maintains a file showing physician approval for selected workers to wear respiratory equipment.
Based on licensee records and interviews with licensee workers, the it,spector concluded that there had been no significant internal exposure to workerc engaged in uranium and/or plutonium decommissioning activities since the previous inspection.
See Inspection Reports (No. 70-925/87001; No. 70-1193/87001).
b.
External Exposure The licensee has determined by nondestructive analysis that the plant plutonium inventory is about two grams.
Because of this small quantity of plutoninm the average reported exposure for third quarter operations was 10 mrem.
There wr.. no exposure velec abova 300 mrem reported to any individual during June through Novemoer 1987.
c.
Surveys and Contamination Control The inspector reviewed the licensee's program for radiological surveys to verify compliance with the regulations and license requirements including the schedule for periodic surveys, effectiveness of surveys, and adequacy of instrumentation.
Air sample surveys (conducted in the plutonium plant) disclosed airborne concentrations of 2.7 MPC in the pipe cutting operations area.
Subsequent sampling showed an increase in concentration (after operations had ceased) to 7.75 MPC.
6e exposure was assigned to worker, because of credit taken for the ptotection factor for the full face respirators worn by the workers.
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At the uranium facility air sample data ranged from 1 to 5 MPC-hours, while airborne concentrations measured at the onsitu burial ground were less than 0.5 MPC-hours.
Monthly unannounced personal surveys (conducted by the licensee health nhysics technicians at both the plutonium and uranium facilities) disclosed no contamination levels in excess of action levels.
Nasal smears continue to be self-administered by each worker leaving the restricted area of the plutonium plant.
Because of low levels of contamination detected, the licensee has no plans to implement a routine nasal sampling ;;rogram at the uranium plant.
Nevertheless, an alert HP technician requested nasal smears for two uranium plant workers who were moving equipment from storage areas above the office.
A high smear of 18 dpm on one worker prompted the HP technician to have both operators don respiratory protection equipment.
The follow-up urinalysis was less than 10 dpm/ liter.
In order to support additional radioactive surveys for the release of i
decontaminated equipment and plant locations, the licensee increased its instrument inventory by purchasing four new survey instruments (Scaler Rate Meter Ludlow 2220).
It appears that the licensee has sufficient supplies of survey instrumentation and respiratory i
equipment to perform health physics routines during decommissior'ng activities.
d.
Radiological Event Report (Incident) i The inspector reviewed several incidents which involved higli airborne radioactive concentrations.
In each instance the exposure was mitigated by applying appropriate protective factors for respiratory protection followed by bioassay sample analysis.
No violations or deviations were identified.
6.
Criticality Safety There is no longer a fissile quantity of special nuclear material remaining onsite.
Hence, no facility modifications or changes the.t require nuclear criticality safety analyses were submitted.
Monthly l
criticality safety audits were conducted (January 1987 through November 1987) as required by Appendix A, Paragraph 5, of the license application, j
The inspector confirmed that management of the licensee's nuclear safety I
program is :ommencarate with the license application.
Since the remaining l
SNM amounts to less than 4 grams of Pu, (significantly less than the quantity specified in 10 CFR 70.24 for a criticality monitoring system) the licensee has filed an amendment application to remove the criticality monitoring requireinents from the license.
l No violations or deviations were identified,
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7.
Transportation of Radioactive Matericis The inspector ~ reviewed the licensee's transportation of radioactive materials' program", including:
determination whether shipments are in.
compliance with NRC and DOT regulations; determination if there were any transportation incidents involving licensee shipments; and experience concerning identification and correction of progranmatic weaknesses.
On June 8,-1987, the license shipped a TRU waste saipment.to the Richland, Washington-burial site that included 39 grams of plutonium contained in nearly 285 cubic feet of waste.
With this shipment, about 4 grams of plutonium remains onsite as shown on the material balance account (MBA).
While no incidents occurred in the licensee's radioactive waste transportation program that _resulted in a violation of regulatory requirements, the inspector did determine that the licensed waste disposal site neglected to return a signed-copy of shipping form (741) to Sequoyah Fueis acknostedging acceptance of the shipment.
During the course of this inspection the licensee attempted to make telephonic contact with the burial site to eliminate this discrepancy._ This was discussed during the exit meeting and will be reviewed during a future
-inspection (0 pen Item No. 70-1193 87003-01).
Additionally, three drums of waste sludge which emanated from wo 6,000 gallon plutonium process waste i
tanks were returned to the licen'ee for solidification and rapackaging.
According to licensee personnel, the burial site had previously accepted dewatered sludge when packaged with absorbing material.
The licensee plans to repackage the drums by solidifying the sludge with cement.
8.
Radioactive Waste Management The inspector reviewed the facility effluent control process to determine whether the licensee is complying with regulations and license i
requirements related to the release and disposal of liquid and solid radioactive waste.
a.
Liquid Waste (Plutonium Facility)
Liquid effluent discharged to the sanitary lagoon was discussed in the previous report.
See Inspection Report (No. 70-1193/87001).
A review of the waste water (effluent) data indicated that two planned releases of plutonium plant laundry water (less than 0.1 MPC) were sampled, NDA counted for grots alpha, and released to the sanitary lagoon.
At the uranium plant IX treated waste water was analyzed i
for uranium content prior to release to the sanitary lagoon.
The inspector determined that the licensee's program for waste water discharge complies with the decommissioning plan as indicated in the license application.
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b.
Solid Waste During the course of this inspection, the licensee identified areas where radioactive contaminated asbestos insulation was removeo from overhead piping.
The licensee constructed a hazardous work facility for workers handling material ladened with asbestos.
The hazardous work facility consisted of a work area for handling asbestos insulation, a change room, and a shower.
The ventilated building was constructed of plastic. sheeting and wood and was designed to meet requirements for handling asbestos as outlined in the Federal t
Register, Volume 51, No, 119,. June 20, 1986, Page 22780.
The plastic glove bag method of handling asbestos material (such as insulated piping) enables the' workers to transport the package to the onsite hazardous work facility and prepare the material for shipment to a licensed waste disposal site.
The licensee noted that the material was removed from the restricted area and treated as radioactive waste with emphasis on meeting the handling i
characteristics of asbestos ladened material.
The licensee also noted that over 43,000 cubic feet of waste (mostly soil) had been exhumed from the onsite burial ground and shipped to waste disposal.
No violations or deviations were identified.
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Training The inspector reviewed the licensee's provisions for training new employees and periodic retraining of senior employees assigned to work with insulating material that is contaminated with radioactivity and ladened with asbestos.
Four new employees received about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of 4
instruction and/or demonstration in industrial safety and basic radiation protection requirements.
Senior workers received special training in the removal of insulating material ladened with asbestos.
Additionally, the Health Physics and Industrial Safety Supervisor completed an offsite contractors' course in asbestos abatement.
During a tour of the facility the inspector noted that glove bags had been placed around pipe r
connections in preparation for removal of asbestos ladened pipe insulation.
It was apparent that the licensee had demonstrated special training and handling techniques in order to meet current threshold limits for asbestos as mandated by OSHA requiu 'ents.
No violations or deviations were identified.
10.
Operations Review (Decommissioning / Decontamination (D/0) Activities) l The Standby Facility Manager discussed the status of decommissioning activities at the Cimarron Facility.
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a.
Plutonium Plant The licensee's current major effort in plutonium plant activities'is the removal of contaminated building surfaces and decontamination of the exhaust fan room.
A vacuum-sandblaster is used to remove layers of concrete from the building surfaces.
Radiological surveys are conducted in order to identify and remove contaminated surfaces.
The vacuum system used in conjunction with sandblasting wall surfaces is designed to capture any re-suspended concrete dust.
During a tour of the exhaust fan room'the licensee stated that-ventilation of the plutonium building is now conducted with one major fan unit.
One fan unit is sufficient to. provide four air changes per hour.
It was also noted that a second air unit is on standby and a third unit was available for use during production operations.
The decrease in air handling units (three to one) is in accordance with Appendix A of the license.
Since all equipment has been removed from the building, there appears to be no loss of control over radioactive material.
This also holds true during decontamination when radioactive dust re-suspended-by sandblasting is captured by vacuum suction.
The licensee also demonstrated that the air balance was adequate to maintain a differential pressure of approximately 0.1 inches of water with one air handling-unit.
The inspector observed the manometer reading.
b.
Uranium Plant The licensee has demolished the uranium plant SX building.
Only the plant's concrete floor end foundation remain.
Major efforts to '
remove asbestos insulation from overhead piping and the ammonia still and to completely remove the uranium plant incinerator are ongoing.
The inspector observed that vacuum-blasting of concrete wall surfaces and floor surfaces were also ongoing.
The inspector also observed that exhumation of burial waste was being conducted during two work shifts.
Small generator / lighting equipment had been installed in order to illuminate the soil packaging and counting location for the second shift. Waste recovery operations is now ongoing in four trenches.
To date, none of the thorium metal purportedly buried in 1966 has been identified and recovered.
The trenches were excavated and or shaped into a rectangular parallel pattern.
In one trench the shape was branched from a parallel pattern to a "Y" formation in order to continue exhumation of the original waste material.
Apparently, the original pattern of the burial ground is quite difficult to duplicate.
Further discussion was held during the exit meeting.
No deviations or violations were identified.
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Maintenance Surveillance The-licensee maintains emergency power equipment to assure _that there is' no interruption of ventilation in the event of a loss of power.
The emergency generator is tested weekly.
The licensee also conducts weekly surveillance checks and or differential pressuro_ measurements on final filters.
During a recent power. loss the emergency unit responded as required.
The inspector determined that the licensee performed surveillance operations on plant systems pertinent to safety in accordance with Appendix A of the license application.
'No violatior.s or deviations were identified.
12.
Exit Meeting The inspector along with representatives from NRC NMSS met with-the licensee's staff (denoted in Section 1) at the conclusion of the onsite-inspection _on December 9, 1987.
The licensee indicated that all drums of thorium and uranium metal will be set aside/ isolated as they are exhumed from the burial site.
There was no indication that a map or diagram was aVailable to pinpoint the exact location of the buried thorium and or uranium metal.
NHSS recommended that the licensee develop a plan that would describe the order of completion of'each campaign.
By this arrangement, NMSS could scnedule a confirmation inspection as each campaign is completed.
The licensee acknowledged that it would be desirable to have a copy of shipping form 741 signed by the waste disposal licensee to confirm acceptance of waste shipments.
During the course of the inspection and the exit meeting, the licen,ee did not identify any documents or inspector comments and references to specific processes as proprietary.
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