ML20210G654
| ML20210G654 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 07/30/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20210G644 | List: |
| References | |
| 70-3073-99-01, NUDOCS 9908030170 | |
| Download: ML20210G654 (9) | |
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ENCLOSURE i
U. S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-3073 License No.: SNM-1999 Report No.: 70-3073/99-01 Licensee: Kerr-McGee Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 Facility: Cushing Site Location: Cushing, Oklahoma inspection Dates: July 6-7,1999 Inspector: Louis C. Carson 11, Health Physicist Fuel Cycle & Decommissioning Branch Approved by: D. Blair Spitzberg, Chief Fuel Cycle & Decommissioning Branch
Attachment:
Supplemental Information 1
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9900030170 990730 PDR C ADOCK 07003073 pg
EXECUTIVE
SUMMARY
Kerr-McGee Corporation, Cushing Site NRC Inspection Report 70-3073/99-01 This inspection included a review of the site status, decommissioning, management organization, quality assurance program, radiation protection, environmental protection, and radioactive waste management.
Site Status and Dccommissionina of Fuel Cycle Facilities Full-scale remediation and decontamination of contaminated areas will not begin until the NRC approves the licensee's decommissioning plan in August 1999 (Section 1).
The licensee's current remediation and decontamination activities included the Pit 4 pilot program, soil sampling and surveys, non-radiological remediation, and site maintenance (Section 1).
Manaaement Oraanization and Controls The licensee's management organization for the Pit 4 remediation was found to be in accordance with license requirements. The audits conducted by quality assurance staff were found to be comprehensive and satisfactorily conducted (Section 2).
Radiation Protection The licensee had implemented a radiation protection program that met requirements established in 10 CFR Part 20 and the license. Personnel exposures were low, and equipment releases had been conducted as required by the license (Section 3).
Environmental Protection and Radioactive Waste Manaaement The liquid environmental and effluent monitoring program was adequate (Section 5).
Report Details 1 Site Status and Decommissioning inspection Procedure for Fuel Cycle Facilities (88104) 1.1 Scope The site status and decommissioning activities were reviewed to determine if activities were being conducted in accordance with the license, regulatory requirements, and the proposed Cushing Site Decommissioning Plan.
1.2 ObservaUons and Findinas
- a. Site Status The NRC granted Special Nuclear Material License No. SNM-1999 to Kerr-McGee Corporation for the Cushing site on April 6,1993. The license authorizes possession of uranium and thorium onsite in concentrations above background levels. The license enables Kerr-McGee to possess contaminated soil, sludge, sediment, trash, building rubble, structures, and any other contaminated material at the Cushing . site during remediation and disposal activities. Licensed activities to date have included soil sampling and surveys, characterization of radioactive material storage areas, characterization of affected areas, and facility maintenance. Nonradiological remediation is ongoing at the site. Full-scale radiological remediation and decontamination of contaminated areas will begin after NRC approval of the licensee's decommissioning plan in August 1999. In Septcmber 1998 the NRC approved the Pit 4 remediation plan. However, the licensee had not began Pit-4 remediation due in part to (1) further testing of the Pit-4 remediation process and (2) a reaccurring pungent odor that has been affecting members of the public during the non-radiological remediation pit cleanups.
- 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 personnel preventing unauthorized access to the site. All visitors were required to stop at the main office before 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. The inspector observed that the licensee was collecting soil samples in support of the Pit 4 remediation project. No problems were identified during the tour.
1.3 Conclusions Site decommissioning activities were reviewed and found to have 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.
2 Management Organization and Controls (88005) 2.1 Insoection Scope The licensee's management organization and quality assurance (OA) program were reviewed by the inspector to ensure compliance with license conditions, regulatory requirements, and commitments to NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination."
2.2 Observations and Findinas
- a. Manaaement Oraanization The inspector reviewed organization changes since the last inspection. The Department of Hydrology, Geology, and Remediation was responsible for the corporate oversight of site decommissioning. The onsite organization structure had not changed. The inspector noted that the licensee had enhanced the OA organization by assigning corporate and contract GA auditors to onsite staff. The inspector reviewed the licensee's organization and assignment of personnel responsible for implementing the Pit 4 Remediation Plan. At the time of this inspection, the licensee's staff consisted of 92 personnel,12 Kerr-McGee employees and 80 contractors. The contract staff included health physics technicians, engineers, construction equipment operators, and clerical staff. The inspector found that the licensee's organization for implemen'ing the Pit 4 Remediation Plan was consistent with the license and NUREG/CR-5849.
- b. Quality Assurance Audits and Reports The inspector reviewed the 1999 Cushing Site Quality System Manual which stated that the onsite OA coordinator assures that periodic audits are conducted, and that audits are sufficient to verify that site plans and procedures are being fully implemented. The inspector reviewed six audits that had been conducted b' tensee corporate OA staff, site OA, and contract personnel since the last inspection. The audits addressed the following areas:
Licensee Radiation Protection a
Contractor Radiation Protection a
Health Physics Laboratory Regulatory Compliance: 10 CFR Parts 19,20,21, and 70 The regulatory compliance audits had been conducted by corporate QA ctaff, and they
i identified 60 program deficiencies and observations. The licensee's Project Manager and QA Coordinator assigned individuals responsibility for resolving specific audit deficiencies and observations within 30 days of the date of the report . The inspector determined that the licensee's audits were comprehensive.
The inspector reviewed the licensee's Non-Compliance Report (NCR) and Corrective Action Report (CAR) programs. During 1998 the licensee had written 39 NCRs, and 12 NCRs had been written during 1999. At the time of this inspection all the NCRs that had been written in 1998 were closed, and only two of the 1999 NCRs remained open. The licensee had written nine CARS during 1999, and five of the CARS remained open. The inspector determined that the licensee's self-assessments were comprehensive, had appropriate management oversight, and were adequately dispositioned.
2.3 Conclusions The licensee's management organization for the Pit 4 remediation was found to be in accordance with license requirements The licensee's audit and self-assessment programs were found to be comprehensive and conducted satisfactorily.
3 Radiation Protection (83822) 3.1 Inspection Scoce An inspection of the radiation protection program was performed to ascertain whether the licensee was complying with regulatory requirements established in the license and 10 CFR Part 20. Areas inspected included program implementation for special work permits (SWP), radioactive material area controls, external and internal exposure controls, training and posting of notices to workers, and radiation detection surveys.
3.2 Observations and Findinas The inspector reviewed the licensee's SWP program. The licensee used SWPs to describe the details of tasks being performed, to provide maintenance instructions to workers, and radiation safety and industrial hazard instructions to workers. The licensee had maintained at least 20 open and active SWPs during 1998 and so far in 1999. The inspector reviewed several SWPs that involved work with and around licensed material.
The inspector noted that each SWP had been appropriately approved by the site manager, the radiation safety officer (RSO), and the health & safety officer prior to implementation. The inspector found that the licensee's SWP program continued to be adequate.
Bulletin board postings required by 10 CFR 19.11, " Posting of Notices to Workers," were found to be up-to-date and adequate. License Condition (LC) 11 requires that the licensee provide workers radiation safety training as described in the license application and 10 CFR 19.12. The inspector reviewed licensee personnel training records for 1998 I and 1999. Records maintained by the licensee adequately documented worker training attendance, test results, and that radiation safety training had occurred annually.
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r License Condition 11(E) requires that equipment being released from restricted areas or radioactive material areas be surveyed for radioactive contamination prior to release in j accordance with " Guidelines for Decontamination of Facilities and Equipment Prior to '
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated August 1987. According to the RSO and licensee records, very few pieces were released from contaminated areas during 1998 and 1999. The licensee's records indicated that equipment released from the site met free release criteria.
I The external and internal exposure monitoring programs were reviewed. No site personnel had received external radiation exposure in 1998 or so far in 1999. The licensee continued to process film badges in accordance with procedure KM-HP-104,
" Film Badge issuance / Collection." Air samples had been collected in accordance with procedures KM-HP-117, " Airborne Surveys" and KM-HP-118, " Internal Exposure Monitoring." The results of personnel air samples collected in 1998 and in 1999 indicated that internal exposures were essentially zero. Ninety-three lapel and area air '
samples had been collected during 1998. During 1998 the licensee had monitored 92 persons for internal and external radiation. The licensee used procedure KM-HP-125
" Review of Bioassay Sample Results" to collect urine samples. Records indicated that the licensee continued to collect urine samples from workers on a bimonthly basis.
Bioassay analysis indicated that radioactive uptakes were nonexistent during 1998 and 1999 which validated the personnel air sampling program.
During a licensee sponsored meeting on March 4,1999, the licensee explained to members of the public that they were investigating whether a barrel and soil located on the north property line of their site was contaminated with radioactivity. The inspector requested that the licensee provide the NRC with the details of their investigation including radiological survey data The licensee provided the following information concerning the suspected contaminated barrel and area:
A chronology of the events leading to the removal of the barrel from the property;
- the results of chemical and radiologicalinvestigations of the barrel; e a description o* the contents of the barrel and the immediate surroundings;
- health physics shift logs and radiation survey records.
Based on the licensee's chemical and radiological analysis results of the barrel and soils :
samples, the inspector concluded that neither the barrel nor the soil in the vicinity of the barrel had been contaminated with licensed material.
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7-3.3 Conclusion The licensee had implemented a radiation protection program that met requirements established in 10 CFR Part 20 and the license. Personnel exposures were low, and equipment releases had been conducted as required by the license.
4 Environmental Protection (88035)
Radioactive Waste Management (88045) 4.1 Insoection Scope The inspector reviewed the licensee's environmental and radioactive waste programs to ensure that controls were adequate to protect health and safety of the workers and the general public.
4.2 Observations and Findinas The environmental and effluent liquid sampling program included periodic groundwater sampling and surface water sampling and analysis. The inspector reviewed the groundwater and surface water sample results for 1998 for the various locations around the site. The licensee had appropriately analyzed samples for thorium-228,230, and 232 and uranium-234,235, and 238. The level of radioactivity in the groundwater and surface water were found to be well below 10 CFR Part 20, Appendix B, release limits.
4.3 Conclusion The liquid environmental and effluent monitoring program was adequate.
5 Exit Meeting Summary The inspector presented the inspection results on July 7,1999, to the representatives of
'the licensee at the conclusion of the inspection. Licensee representatives acknowledged the findings as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.
ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee j l
J. Lux, Project Manager T. Moore, Radiation Safety Officer S. Nelson, Principal Engineer T. Ostmeyer, Administrative Supervisor S. Pekarak, Quality Assurance Coordinator R. Pounds, Site Manager Oklahoma Department of Environmental Quality E. Shirley, inspector, Radiation Management Section INSPEC' DON PROCEDURES USED IP 83822 Radiation Protection IP 88005 Management Organization Controls IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities ITEMS OPENED, CLOSED AND DISCUSSED Opened None Closed None Discussed None l
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2-LIST OF ACRONYMS CFR Code of Federal Regulations LC license condition PDR Public Document Room QA Quality Assurance RSO Radiation Safety Officer SNM Special Nuclear Material SWP special work permit l
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