ML20155H787
| ML20155H787 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 11/03/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20155H760 | List: |
| References | |
| 70-0925-98-02, 70-925-98-2, NUDOCS 9811100280 | |
| Download: ML20155H787 (9) | |
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ENCLOSURE U. S. NUCLEAR REGULATORY COMMISSION REGION IV 1
Docket No.:
70-925 License No.:
SNM-928 Report No.:
70-925/98-02 Licensee:
Cimarron Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 Facility:
Cimarron Site Location:
Crescent, Oklahoma Dates:
September 22 through October 22,1998 Inspector:
Louis C. Carson 11, Health Physicist Fuel Cyc:e & Decommissioning Branch Division of Nuclear Materials Safety Approved By:
D. Blair Spitzberg, PhD., Chief Fuel Cycle & Decommissioning Branch Division of Nuclear Materials Safety
Attachment:
SupplementalInformation l
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9811100280 981103 PDR ADOCK 07000925 C
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. EXECUTIVE SUMM ARY Cimarron Corporation, Cimarron Site NRC inspection Report 70 925/98-02 Cimarron is conducting site remediation activities in preparation for the termination of license i
SNM-928. Several radiologicalinspections and surveys have been conducted at Cimarron as part of the overall NRC confirmatory survey process. This inspection is a continuation of this process. The licensee is authorized to release for unrestricted use Cimarron site property and material with residual amounts of low-enriched uranium and thorium if the property meets:
(1) criteria in the NRC Branch Technical Position (BTP) for Option 1 soil and (2) criteria in Table 1 of " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use of the Termination of Licenses for Byproduct, Source or Special Nuclear Material." This inspection involved reviewing Sub-Area J Final Status Survey records and collecting soil and sediment samples from Sub-Area J to confirm compliance with the license and the BTP Option 1 limits. This inspection also included a review of the licensee's program for control of equipment and concrete that had been released from a restricted area (Phase til, Sub-Area K) and placed in an unrestricted area (Phase !!, Sub Area G).
Decommissionino. Closeout Survev. and Site Status Site decommissioning activities reviewed had been conducted in accordance with applicable license conditions and regulatory requirements. Site fences were in good condition, and perimeter postings were appropriate. No health or safety hazards were identified (Section 1).
Survey data indicated that the concrete slabs that were removed from Sub-Area K and placed in Sub Area G met the NRC's release criteria for unrestricted use. Training records indicated that qualified personnel conducted Sub-Area G release surveys. Sub-Area G release surveys and work instructions were consistent with the Phase lli Final Survey Plan (Section 1).
Radiation survey instruments used during the Sub-Area G release surveys and Sub-Area J surveys had been calibrated in accordance with, licensee procedures and the recommendations of NUREG 5849 and ANSI N 323-1978," Radiation Protection Instrumentation Test and Calibration" (Section 1).
Twelve soil and sediment samples were collected from Sub-Area J by both the NRC and l
the licensee as part of the NRC confirmatory survey program (Section 1).
NRC measurements confirmed that residual radioactivity in Sub-Area J soil and sediment had less than 30 picocuries/ gram of soluble uranium remaining and thus met the BTP criteria. No significant bias or statistical errors between the licensee's soil and sediment results and the NRC's results were identified (Section 1).
Radiation exposure levels at Sub Area J were less than 10 pR/hr above background levels (Section 1).
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Report Details 1
Decommissioning inspection Procedure for Fuel Cycle Facilities, Closeout inspection and Survey, Site Status (83890/88104) 1.1 boection Scoco Tne site status and decommissioning activities were reviewed to determine if activities were being conducted in accordance with the license, regulatory requirements, Phase 11 and Phase lil Final Status Survey Plans, and the proposed Cimarron Decommissioning Plan. The licensee's proposed Cimarron Decommissioning Plan commits the licensee to follow the recommendations in NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination" and " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use of Termination of Licenses for Byproduct, Source or Special Nuclear Material." This inspection included a review of release surveys, final status survey data, instrument calibration records, and the performance of confirmatory sumeys of Phase 11 Sub-Area J.
This inspection included a review of the site's release program regarding equipment and concrete that had been released from a restricted area (Phase Ill, Sub Area K) and placed in an unrestricted area (Phase ll, Sub-Area G). The inspector had to verify that radiation survey instruments used during the release surveys were calibrated and functional.
As part of the NRC confirmatory sumey process, the inspector collected soil and sediment samples from Sub-Area J to determine if these samples met the criteria of BTP Option 1 and were consistent with the licensee's measurements at these locations.
The concentration of residual uranium in soil must be less than the BTP Option 1 concentration limit, which is 30 picocuries/ gram (,-Cl/g) uranium.
1.2 Observation and Findinas a.
Site Status Cimarron is in the final stages of site remediation in preparation for termination of its nuclear materials license. The licensee's Decommissicning Plan was submitted to the NRC in April 1995 and io under review. The licensee has continued to implement decommissioning activities in accordance with the Decommissioning Plan and Final Status Survey Plans, although the Decommissioning Plan has not received NRC approval. However, the licensee's activities continue to be coordinated with the cognizant project manager in the Office of Nuclear Materials Safety and Safeguards.
l The licensee's current activities included soil sampling, performing radiation surveys, groundwater remediation planning, and facility maintenance. Remediation at the Cimarron site was more than 95 percent complete. Sub-Area J included 16 acres and i
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represented the only remediation effort by Cimarron of property located outside the main site boundary. Final survey activities for the site were in progress. This inspection was a continuation of the NRC's confirmatory survey program for the Cimarron site.
b.
Site Tour A site tour was performed to verify that site activities were being conducted in accordance with applicable regulations and the conditions of the license to ensure that controls were adequate to protect the health and safety of the workers and the public.
During the tour, buildings, fences, gates, construction, and operating equipment were observed. The inspector noted that security was maintained by site security personnel l
who prevented unauthorized access to the site. The licensee maintained locked gates i
at entrances to site property, and visitors were required to check in at the main office when accessing the site property. The inspector determined that licensed material was secure within the site property as required by 10 CFR 20.1801. Additionally, fences were posted with radioactive material signs as required by 10 CFR 20.1902.
c.
Phase ill Final Status Survey Plan and the Uranium Process buildina On September 11,1998, the NRC approved the licensee's " Phase lli Final Status Survey Plan." The proposed "Cimarron Decommissioning Plan" was still undergoing NRC review. Both of the licensee's plans addressed the manner in which the Uranium Process building and equipment would be decontaminated, dismantled, and surveyed l
for release. Specifically, the licensee's plans stated that equipment, walls, floors, and i
concrete had been removed, decontaminated, and disposed of in accordance with the release limits specified by the license. Prior to this inspection, the licensee had cut up the Uranium Process building concrete floor into 80 sections and surveyed the slabs for release from the restricted area (Phase ill, Sub Area K) to an unrestricted area (Phase II, Sub Area G).
The inspector reviewed the licensee's radiation survey procedures for release surveys, examined the records for the 80 slabs of concrete, and conducted confirmatory radiation l
surveys of selected concrete slabs located in Sub-Area G. The inspector reviewed Cimarron Procedures KM-CI-RP 39," Performance of Radiation, Contamination, and Airborne Radioactivity Surveys"; and KM-Cl RP 40," Survey Documentation and Review." Additionally, the inspector reviewed the licensee's "Cimarron Radiation Protection Plan," the license, and the NRC's Safety Evaluation Report dated July 7,1997, which allowed the licensee to routinely release items from the restricted area during decommissioning. Release survey records revealed that the licensee had I
conducted more radiation surveys on tha concrete slabs than was required by the NRC.
l The licensee had conducted systematic, scan, exposure rate, and fixed and loose contamination radiation surveys on each slab of concrete. Radiation instruments used by the licensee included sodium iodide (Nal) microRoentgen meters, Nal scintillation scanners, alpha-beta counters, beta-gamma gas-proportional counters, and Geiger-Mueller probes.
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5-According to the survey data reviewed, residual (alpha, beta, and gamma) contamination remaining on each concrete slab was less than 5,000 disintegrations per minute (dpm)/100 square centimeters (100 cm ) fixed contamination and less than 1,000 2
dpm/100 cm loose contamination. Additionally, the licensee's exposure rate surveys did not reveal any variations in the ambient background radiation levels in Sub-Area G due to the presence of the 80 concrete slabs. The inspector conducted independent exposure rate and contamination surveys on 40 or the concrete slabs..The inspector determined that residual (alpha, beta, and gamma) contamination remaining on the concrete slabs was below the NRC's release criteria. Additionally, the ambient background radiation level in Sub-Area G was not affected by the presence of the con.: rete slabs from the Uranium Process building.
The inspector compared the exposure rate survey data, gross alpha activity, and gross beta-gamma activity data from the Sub-Area F report to the actual radiation survey data record collected by the licensee's health physics technicians (HPTs). The inspector found that the HPTs' survey data had been accurately transferred to the final status survey report. The inspector noted that survey data collected by HPTs as reviewed by i
the radiation safety officer and the quality assurance manager. The inspector reviewed training records which qualified the HPTs to conduct release surveys. The inspector found that the training records and worn instructions were adequate.
Based on the inspector's reviews of the licensee's concrete slab survey records, license requirements, and confirmatory surveys, the inspector concluded that the licensee had released the concrete from the Uranium Process building to Sub-Area G in accordance with Cimarron's license, d.
Instrument Calibrations The inspector reviewed calibration records of instruments used to conduct the Sub-Area J Final Status Survey and the Sub-Area G concrete slabs. Inctrument calibration and functional check records were reviewed for alpha radiation survey instruments and beta / gamma radiation survey instruments used. The inspector's review of these records revealed that the instruments had been calibrated and functionally checked in accordance with the following licensee procedures:
KM-Cl-RP-50, "Ludlum 2220/2221 Alpha Probe 43-68/43-4" KM-CI RP-57,"Ludlum 2220/2221 Beta Probe 43-68' KM-CI-RP-59,"Eberline PRM-6/N-15 Detector"
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KM-Cl-RP-62, "Cimarron Soil Count #2 Operation" Additionally, the calibrations were consistent with the recommendations of NUREG-5849 and ANSI N 323-1978," Radiation Protection Instrumentation Test and Calibration."
The licensee used a Nal detector to conduct soil analysis for uranium. Radiation Protection Procedure KM-CI-RP-62 was used for soil counter operations. This 4
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6-procedure contained instructions for operational checks, calibration checks, cesium-137 energy and efficiency checkr, background determinations, and sample counting. Total uranium was determined by. sing a scaling factor applied to the uranium-235 value.
During this inspection, the Cimarron site lost all offsite power. The licensee had to recalibrate the soil counter prior to analyzing Sub-Area J split soil and sediment samples. Based on the licensee's results presented in this report, the inspector determined that the licensee's recalibration of the soil counter was satisfactory.
e.
Confirmatory Radiation Soil and Sediment Samolina The inspector reviewed the licensee's procedures for collecting and preparing soil and sediment sampies. The inspector observed licensee technicians collect, prepare, and split samples for analysis by the NRC as part of the confirmatory survey process. The samples were expected to contain uranium that was less than the BTP Option 1 concentration limits.
Before shipping the soil samples to the NRC for analysis, the licensee analyzed samples for uranium using a Nal soil counter as a quality assurance measure. The licensee counted the samples at 15 minute intervals. The inspector's objective was to determine if the licensee's results were reproducible. The licensee counted the samples in the same containers that NRC uses during its analyses. The inspector found that the licensee's soil counting data was reproducible in that the licensee's September 1998 results were similar to the March 1997 of Sub-Area J results. Licensee results indicated that the samples met BTP Option 1 release limits for uranium.
Twelve samples were sent to the NRC Region lil laboratory for analysis by the Oak Ridge Institute for Science and Education on September 22,1998. NRC sample results were compared with the licensee's results to confirm that uranium levels met the license limits and were consistent with the corresponding licensee measurements. The comparison of the analytical results were discussed with licensee representatives telephonically on October 22,1998. Samples collected at location No. 2 measured 41 pCi/g and 38.8 pCi/g by the licensee and 46.14 pCi/g by the NRC. The inspector confirmed that the licensee appropriately applied the hot-spot averaging criteria to the area surrounding Sample No. 2. Additionally, the NRC Sample No. 3 result measured 30.15 pCi/g. However, the net residual contamination remaining in this soil sample, considering natural background and instrument error, met the 30 pCi/g limit for uranium.
The licensee's hot-spot average evaluation of the area surrounding location No. 2 also encompassed location No. 3. The average residual contamination remaining in the vicinity of locations Nos. 2 and 3 based on the licensee's hot-spot averaging was 16.12 pCi/g. The following table represents the results of the confirmatory soil and sediment samples at and around Sub-Area J. Overall, the NRC measurements confirmed that Sub-Area J soil and sediment had less than 30 pCi/g uranium. No significant bias or statistical errors between the licensee's soil and sediment sample results and the NRC's results were identified. Licensee measurement methods and counting times were found to be acceptable.
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l Confirmatory Soil and Sediment Sample Results For Sub-Area J l
Location Licensee March 97 Licensee September 98 NRC October 98 (Sample #)'
pCl/g pCl/g pCi/g 1
14 6.3 2.14 3.39 1.79 80N\\140W l
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41 38.8 2.23 46.14 3.23 70N\\220W 3
26 24.8 2.12 30.15 2.96 70N\\218W 4
19 12.7_ 1.87 15.19 2.77 70N\\210W 5
18 6.3 1.8 3.33 1.17 70N\\195W 6
11 9.0 1.75 6.77 1.46 78N\\205W 7
14 16.5 2.35 18.70 2.60 190N\\370W 8
16 21.4 2.53 21.01 2.88 190N\\330W 9
16 19.9 2.64 16.25 2.61 110N\\290W 10 7.1 4.8 1.90 1.89 1.16 278S\\373W 11 N/A 8.1 2.04 2.51 1.32 85S\\79W 12 N/A 6.0 2.24 3.53 2.0 118N\\146W i
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Confirmatory Exposure Rate Survev Results Sub-Area J exposure rates had been evaluated by the licensee using a portable Nal detector. Background radiation levels around the ate averaged 7 microRoentgen/ hour (pR/hr). Sub-Area J radiation levels measured by the licensee averaged 8 pR/hr.
Confirmatory exposure rate surveys were performed by the inspector using a portable Nal detector at the Sub-Area J soil and sediment sample locations. Site background readings measured by the inspector averaged 8 pR/hr. The inspector's Sub-Area J measure,ments were 8-12 pR/hr, and no hot-spots were found during the inspector's survey. The inspector concluded that radiation exposure levels at Sub-Area J were less than 10 pR/hr above background levels.
1.3 Conclusion Site decommissioning activities reviewed during the inspection had been conducted in accordance with the applicable license conditions and regulatory requirements. Site fences were in good condition, and perimeter postings were appropriate. No health or safety hazards were identified.
NRC measurements confirmed that Sub-Area J soil and sediment had less than 30 pCi/g uranium. No significant bias or statistical errors between the licensee's soil and sediment sample results and the NRC's results were identified. Licensee measurement methods and counting times were found to be acceptable. Radiation exposure levels at Sub-Area J were less than 10 pR/hr above background levels.
The inspector concluded that the alpha and beta / gamma survey instruments used during the Sub-Area G release survey and Sub-Area J final and confirmatory surveys had been calibrated in accordance with license procedures and the recommendations of NUREG-5849 and ANSI N 323-1978," Radiation Protection Instrumentation Test and Calibration."
2 Exit Meeting Summary The inspector presented the inspection results to the licensee representatives at the conclusion of the onsite inspection on September 22,1998, and during a telephone conversation on October 22,1998. Licensee representatives acknowledged the findings as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.
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1 ATTACHMENT 1
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Cimarron Corooration K. Downing, Director of Regulatory Compliance M. Hodo, Quality Assurance Manager J. Larsen, Site Manager and Vice President, Cimarron K. Morgan, Radiation Safety Officer Contractor Personnel S. Marshall, Nextep Environmental W. Rogers, Technical Consultant INSPECTION PROCEDURES USED IP 83890 Ciosecut inspection and Survey IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities ITEMS OPENED. CLOSED AND DISCUSSED i
Closed I
None Opened i
None Discussed None LIST OF ACRONYMS ANSI American National Standards institute BTP branch technical position CFR Code of Federal Regulations l
dpm disintegrations per minute HPT health physics technician l.
Nal Sodium lodide pR/hr microRoentgen/ hour pCi/g picocuries/ gram PDR public document room
'RSO-radiation safety officer SNM special nuclear material l
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