ML20155K297

Insp Repts 70-0925/88-01 & 70-1193/88-01 on 880509-12,19,24 & 0602 & 06.No Violations Noted.Major Areas Inspected:Mgt & Organization Controls,Radiation Protection Program, Operations Review & Waste Generator Requirements

ML20155K297
Person / Time
Site:	07000925, 07001193
Issue date:	06/14/1988
From:	France G, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155K226	List: ML20155K221 ML20155K297
References
70-0925-88-01, 70-1193-88-01, 70-1193-88-1, 70-925-88-1, NUDOCS 8806210165
Download: ML20155K297 (8)

Text

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t U.S. NUCLEAR REGULATORY- COMMISSION REGION III i

Reports No. 70-925/88001(DRSS); 70-1193/88001(ORSS)

Docket Nos. 07000925; 07001193 Licenses No. SNM-928; SNM-1174 Licensee Name: Sequoyah Fuels Corporation Facility Name: Cimarron Facility Inspection At: Crescent, Oklahoma Inspection Conducted: May 9-12, 1988 (Onsite) '

May 19 and 24 and June 2 and 6, 1988 (Telephone) ,

M 4%t 0 Inspector: G. M. France, III Date

I W G//yh' c

, Approved By: M. C. Schumacher, Chief l Radiological Effluents and Date Chemistry Section 3

Inspection Summary Inspection on May 9-12, 1988 (Reports No. 70-925/88001(DRSS); 70-1193/88001(DRSS))

Areas Inspected: Routine, unannounced safety inspection, including:

management and organization controls (IP 88005); radiation protection program

, (IP 83822); operations review (IP 88020); waste generator requirements (IP 84850); transportation activities (IP 86740); environmental protection (IP 88045); and criticality safety (IP 88015).

Results: The licensee was found to be in compliance with NRC requirements

. within the areas examined. The licensee documented a closeout survey for the loading dock (Plutonium Plant) and expects tc complete closeout surveys for room 143 (Plutonium mass spectrometer laboratory) the liquid waste drainage system (Plutonium Plant) and the burial trenches, by July 1988.

l 6806210165 880614 PDR ADOCK 07000925 C DCD

DETAILS

1. Persons Contacted

• R. J. Adkisson, Director, Contract Management and Cimarron Operation

• R. L. Fine, Supervisor, Health Physics and Industrial Safety

• J. Kegin, Utilities and Decontamination Supervisor

• S. C. Munson, Senior Staff Environmental Specialist

• A. W. Norwood, Facility Manager

• Denotes the principal managers interviewed during the inspection and who also attended the exit meeting on May 12, 1988.

2. General This inspection of onsite activities, which began at 1:30 p.m. on May 9, 1988, was conducted to examine decommissioning activities at Sequoyah Fuels Cimarron site under Special Nuclear Materials Licenses No. SNM-928 and No. SNM-1174. During this inspection, the licensee identified areas ready for confirmatory surveys and areas that will be resurveyed with new (large areas) instrument probes (515 cm2 probe gas proportional counter).

On May 19 and 24, and June 2 and 6, 1988, telephone discussions were held with the licensee concerning the initiation of confirmatory measurements at the Cimarron Facility.

3. Licensee Action on Previously Identified Items The inspector reviewed the progress the licensee had made in correcting open itens and or observations identified during a previous inspection.

(Closed) Open Item No. 70-1193/87001-02(DRSS): A 165-millicurie cesium source is listed on both the SNM license (SNM-1174) and Byproduct License N:. 35-12636-02. An amendment was granted to delete possession of the sealed source from the plutonium license (SNM-1174).

(0 pen) Open Item No. 70-1193/87001-06(DRSS)): Two 6,000 gallon tanks used for radioactive waste sludge await final disposition. The sludge has been removed from the tanks. The licensee is reviewing the alternatives of decontaminating the tanks or excavating and preparing the tanks for shipment to a licensed burial facility. This item will be reviewed during a future inspection.

4. Management Organization and Controls (IP 88005)

The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organizational structure,

a. Organization Sequoyah Fuels Cimarron Corporation now employs 51 persons in security, health and safety, and decommissioning operations. With approval of a recent amendment request that deleted the requirement 2

for materials and plant protection, Plutonium plant utility operators were relieved of performing auxiliary security duties.

The utility operators were reassigned to decommissioning crews.

There were no. organizational changes that affected radiological safety. No problems were identified.

b. Special Work Permits (SWP)

Special work permits were issued to cover the following activities:

SWP No. 0401 - 8aghouse Dismantling; No. 0171 Cement LSA Liquids; and No. 0186 Removal of High Pressure Airline. The inspector observed the licensee's removal / relocation of e three story incinerator baghouse in preparation for dismantling and disposal.

The inspector concluded that SWP No. 0401 specified the necessary safety controls for respiratory protection, fire protection, and health physic.s coverage of the workers assigned to relocate the baghouse.

No violations or deviations were identified.

5. Radiation Protection (IP 83822)

The inspector reviewed the licensee's internal and external exposure ,

control programs including the required records, reports, and notifications.

a. Internal Exposure Control The inspector interviewed the Supervisor, Health Physics, and Industrial Safety concerning whole body count results, bioassay records and air sampling data for the December 1987 through May 1988 operating period. In vivo counts by Helgeson Nuclear Service were conducted May 2-5, 1988 for lung depositions of uranium-235 in 24 workers, lung depositions'of thorium in 13 workers, and lung depositions of plutonium-239 and americium-241 in 19 plutonium plant  :

workers. The maximum reported uranium-235 level was 63146 pg which l is near the instrument detection range of 30-60 pg. The highest reported americium-241 level was 0.3610.16 nCi which is less than 1%

of the maximum permissible body burden. The highest reported level of plutonium-239 was 0.17 nCi which is also less than 1% of the l

, maximum permissible body burden. Since the sensitivity for natural '

thorium is about 6-8 mg, the levels shown for one worker (513 mg thorium) appear to be not statistically significant. One employee continues to show uranium counts from enriched UALX (uranium metal) exposure prior to 1976. His last whole body count (1987) showed 71136 pg U-235 with previous levels of 103 pg in 1981 and 138 pg U-235 in 1977. Bioassay records disclosed that the 40 MPC-hour intake limit for uranium and plutonium had not been e<.ceeded. I l

Area air sample surveys (conducted at the uranium plant) indicated air concentrations of less than 1.0 MPC. The highest individual i

exposure in a work week reported based on a lapel air sampler was 3

22.9 MPC-hours. Although the workers were wearing ~ respirators, the 22.9 HPC-hours was calculated with~out the use of a protection factor. At the plutonium facility air sample data reviewed for first quarter 1988 activities indicated exposures well below 40 MPC-hours.

The inspector concluded that there had been no significant internal exposure to workers engaged in decommissioning activities for the December 1987 through May 1968 operating period.

b. External Exposure The licensee's records indicated that whole body radiation exposures from external penetrating radiation are not significantly different than background radiation. The data disclosed some thorium waste packages with surface readings of about 15 mrem / hour. Other than several stored drums of uranium and thorium metal (2-35 mrem /hr) and an encapsulated cesium-137 source (165 mci) contained in a lead shield there were no other materials located onsite that represented a significant source of penetrating radiation.

c. Radiological Surveys and Contamination Control Records of radiological surveys conducted for the December 1987 through April 1988 operating period disclosed no significant contamination or exposure problems. Smear results on six items (laboratory equipment) released from the Cimarron site were less than 200 dpm/100 cm2, which is less than the licensee's releasable limits (1000 dpm/100 cm2 removable contamination). The reported fixed radioactivity levels also met the licensee limits (15,000 dpm/

100 cm2) for release,

d. Instrument Calibration and Leak Detection The licensee's Instrument Maintenance Specialist (IMS) services and calibrates instruments used at the Cimarron Facility. At the request of the inspector, the IMS demonstrated calibration of air monitoring equipment, provided leak detection data for radioactive sources, and demonstrated handling and storage techniques used to protect the licensee's sources. The inspector concluded that the licensee's instrument calibration and leak detection procedures adequately support the licensee's radiation protection program.

No problems were observed in the licensee's handling and Storage of radioactive sources.

No violations or deviations were identified.

6. Operations Review (IP 88020) ,

l The Facility Manager discussed the status of decommissioning activities '

at the Cimarron Facility.  ;

a. Plutonium Plant Guided by radiation survey results, the licensee made several furrows in concrete surfaces to remove subsurface contamination. Vacuum sandblasting of painted surfaces to remove surface contamination is still a major decommissioning activity. The licensee obtained a more sensitive detector with a larger area probe (gas proportional counter with a 515 cm2 probe) and resurveyed the mass spectrometer laboratory and the facility loading dock. The licensee considers both locations ready for NRC close out surveys. The licensee stated that radiation surveys had also been performed on concrete and sand removed while excavating the building (laboratory and laundry waste) drainage system. This material was reported to be at background level.

The lines run from the plant laboratory and laundry rooms to two 10,000 gallon waste tanks located below grade about 25 yards north of the plant. The inspector observed the excavated area and was informed that one of the drain lines was leaking and that excavation and survey efforts will continue until the leak is discovered and repaired. This will be reviewed during a future inspection (0 pen Item No. 70-1193/88001-01). The licensee has yet to address the final disposition of the underground waste tanks.

On May 19, 1988 (via telephone), the inspector discussed with the Facility Manager the requirements in Annex C, "Guidelines for Decontamination of Facilities and Equipment," which is referenced in the license. In a followup telephone discussion on May 24, 1988, Region III informed the licensee that before NRC closeout surveys i could commence, the licensee would need to provide reports of his completed surveys of areas ready for closecut. On June 2, 1988, a telephone conference was held with a licensee representative and a representative of Oak Ridge Associated University (0RAU) concerning methods followed by ORAU in performing confirmatory ,

taasurements. The licensee acknowledged the information provided 1 in the various t(lephone discussions and indicated that selected '

areas of the Cimarron Facility (burial trenches; Pu building, drain excavation Room 143 and the Pu building loading dock) were being prepared for closeout surveys by late July 1988.

b. Uranium Plant Dismantling of the SX building and foundation has been completed.

The soil that was located beneath the SX building foundation will be surveyed for disposal under Option No. 2., as described in NRC's Branch Technical Position Paper (BTP). The inspector observed that contaminated wall and floor surfaces have been removed in most areas of the Uranium Plant. Several furrows were made in the walls and floors to remove subsurface contamination.

Contaminated waste has been removed from the four trenches of the old burial site. Further surveys of the trenches will be performed to complete characterization of the contamination.

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O The licensee would like permission to meet Option 2 of the NRC Branch Technical Position for contaminated soil to be left in these trenches. By telephone on June 6, 1988, the facility manager was informed that permission to meet Option 2 would have to be requested in accordance with 10 CFR 20.302. The licensee estimated the burial trenches could be ready for NRC closeout survey by late July 1998.

Still awaiting final disposition are several barrels of uranium l and thorium metal. These will be repackaged in accordance with '

standards acceptable to a licensed disposal facility.

No violations or deviations were identified.

7. Inspection of Waste Generator Requirements of 10 CFR 20 and 10 CFR 61 (IP 84850)

The inspector reviewed the licensee's program for waste generation in accordance with requirenents of 10 CFR 20 and 10 CFR 61 applicable to low level radwaste form, classification, stabilization, and shipment manifests.

In accordance with 10 CFR 20.311, the licensee maintains a manifest for all waste shipments. Records reviewed for 1986 through 1987 operations indicated no violations of regulatory requirements.

In accordance with 10 CFR 61.56 and Region III concerns, potentially pyrophoric materials, exhumed from the burial site, such as uranium and thorium metal, have been contained and packaged to be nonflammable.

Further treatment may be necessary in order to meet requirements imposed by a licensed burial site.

'he inspector concluded that the licensee has established and maintains an adequate qA program to assure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 61.56.

No violations or deviations were identified.

8, Transportation Activities (IP 8C740)

The inspector reviewed the licensee's program for assuring that radioactive waste shipments were adequately surveyed prior to shipping.

According to records of 23 waste shipments made in 1988, there were no significant levels of removable or fixed contamination detected during preshipment surveys. Most shipments were comprised of contaminated soil removed from burial trenches which previously held uranium and thorium waste. In preparing contaminated soil for offsite shipment to a licensed burial site, powdered cement was added to the drums to absorb any excess moisture that remained in the soil. Among surveys of individual waste drums, 15 mR/ hour appeared to be the highest contact reading. Shipping trailer / cab exposures were less than 0.6 mR/ hour.

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O In addition to the waste shipments, the licensee shipped a 30A cylinder containing about 1000 kgs of depleted UF8 to its Sequoyah Fuels (UF 8 + UF 4 ) facility located in Gore, Oklahoma. This material was a carry over from'a previous operation conducted under a' different license.

No violations or deviations were identified.

9. Environmental Protection (IP 88045)

Liquid Waste Containment a.

Domestic and process waste liquids are transported from the Plutonium Plant via two underground drain lines. These lines are connected either directly or via a header pipe to an underground tank. Liquid waste is analyzed and upon meeting 0.1 MPC levels for plutonium is discharged from the tank to the new sanitary lagoon.

Liquid waste that exceeds the 0.1 MPC level for plutonium is either passed through an ion exchange (IX) resin for plutonium removal or formed into a stable monolith with cement for offsite disposal, Liquid waste generated at the uranium plant is similarly treated before discharge to the new lagoon.

The inspector observed that the drain lines from the plutonium plant

were exposed via excavation efforts for ultimate determination of contamination on the interior surface of the drain lines and the surrounding soil. The licensee plans to remove part of these lines ,

and eventually reroute the piping directly to the new lagoon.

The licensee monitors the level of radioactivity in sanitary waste <

ponds that are nearly decommissioned. Recent radiochemical analysis ,

(1987 samples) of rainwater collected in the ponds indicate that the  !

uranium, plutonium, and radium levels are similar to data reported  ;

for upntream river samples. The inspector and the licensee collected two liquid samples from each pond. Results of these samples will be i reported during a future inspection.

b. License Condition No. 11 (Environmental Report)

In accordance with License Condition No. 11 (Plutonium License

No. SNM-1174) the licensee submitted an annual environmental report j for 1987 summarizing the results of soil, vegetation, and water i

samples that may be affected by decommissioning activities. The s inspector noted that the data for two of the wells that monitor l

. the burial site show elevated levels of gross alpha and uranium concentrations. On May 24, 1988, Region III indicated to the

licensee that it would be desirable to increase the sampling

)' frequency of the wells. The licensee acknowledged the discussion and noted that the well most affected was actually between the ,

trenches where it was probably affected by ongoing excavation j operations. The need for developing a better understanding of l l

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O ground water conditions was again mentioned in telephone discussion on June 2 and 6, 1988. The wells are scheduled for routine sampling during June 1988.

No violations or deviations were identified.

'10. Criticality Safety (IP 88015)

On March 18, 1988, Region III deleted the licensing requirement for nuclear criticality control of special nuclear material under Special Nuclear Material License No. SNM-1174, the licensee's plutonium license.

It was also noted that the possession limits were amended to 5 grams of plutonium. No problems were noted.

11. Exit Meeting The scope and findings of the inspection were discussed with licensee representatives (Section 1) at the close of the onsite inspection on May 12, 1988. The inspector stated that licensee programs in the areas of exposure control, decommissioning operations, waste generator requirements, transportation activities, and environmental protection met regulatory requirements. By telephone on May 19 and 24 and June 2 and 6, 1988, the inspector and other NRC representatives discussed the licensee's responsibility to complete decontamination and surveys prior to NRC closeout surveys. The licensee acknowledged the discussion.

During the inspection and exit meeting, the licensee did not identify any documents or inspector statements and references to specific processes as proprietary.

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