ML20210H338

Safety Insp Repts 70-0925/86-02 & 70-1193/86-02 on 860818-22.Violation Noted:Failure to Make Timely Submittal of Effluent Monitoring Rept

ML20210H338
Person / Time
Site:	07000925, 07001193
Issue date:	09/22/1986
From:	France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210H314	List: ML20210H309 ML20210H327 ML20210H338
References
70-0925-86-02, 70-1193-86-02, 70-1193-86-2, 70-925-86-2, NUDOCS 8609260141
Download: ML20210H338 (13)

Text

-

U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 70-925/86002(DRSS); 70-1193/86002(DRSS)

Docket Nos.70-925; 70-1193 License No. SNM-928; SNM-1174 Licensee: Sequoyah Fuels Corporation Kerr McGee Center Oklahoma City, OK 73125 Facility Name: .Cimarron Facility Inspection At: Cimarron Facility, Crescent, OK Inspection Conducted: August 18-22, 1986

1. E Inspector: G. M. France, III ~D Date Approved By: L. . eger, Chief 9~89 -86 Facilities Radiation Date Protection Section Inspection Summary Inspection on August 18-22, 1986 (Reports No. 70-925/86002(DRSS);

70-1193/86002(DRSS))

Areas Inspected: Routine, unannounced safety inspection including:

organization; radiation protection program; training; operations review; transportation and radioactive waste; audits and procedures; maintenance surveillance; and environmental monitoring, including a review of environmental sample data collected as part of a previously conducted investigation of an allegation. The inspection involved one NRC inspector

- and one observer from NMSS.

Results: One violation of NRC requirements was identified (failure to make timely submittal of an effluent monitoring report - Section 5.c).

l l

3 9609260141 860922 PDR j

C ADOCK 07000925 PDR

DETAILS

1. Persons Contacted

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

• R. L. Fine, Supervisor, Health Physics and Industrial Safety M. W. Hodo, Accounting and Administrative Analyst

• R. M. Jones, Administrative Clerk

• D. Majors, Regulatory Compliance Auditor, Kerr McGee Corporation W. Momsen, Decontamination Operator

• A. W. Norwood, Standby Operations Manager L. Price, Decontamination Operator

• D. W. Rall, Supervisor Burial Ground Decontamination

• W. J. Rhodes, Decontamination Supervisor

• k. A. Richards, Plutonium Decontamination Supervisor

• W. A. Rogers, Plutonium Decontamination Supervisor W. Spencer, Senior Project Engineer

• C. M. Thompson, Health Physics Specialist

• G. C. Comfort, Jr. NRC/NMSS

• Denotes those present at the exit meeting conducted August 22, 1986.

2. General This inspection, which began at 1:30 p.m. on August 18, 1986, was conducted to examine activities at the Cimarron site under Materials Licenses No. SNM-928 and SNM-1174. The inspector toured the Plutonium and Uranium Fuel Fabrication Plants, the onsite contaminated soil removal programs, and the thorium / uranium waste burial location. A representative of NRC/NMSS also observed facility activities and met with the Standby Operations Manager and selected members of his staff.

3. Licensee Action on Previous Inspection Findings (Closed) Allegation (RIII-84-A-0155): Cattle Grazing over Th/U Waste Burial Site. A list of concerns regarding irregularities and deficiencies in safety performance at Sequoyah Fuels Plutonium Plant was received at Region III on October 24, 1984. Region III met with the alleger (former employee) on November 13, 1984. Inspection Report No. 70-925/84002; No. 70-1193/84002(DRSS) provides the initial allegation review. A followup review, conducted on June 24, 1985, is discussed in Inspection Report No. 79-925/85001; No. 70-1193/85001(DRSS).

As noted in Inspection Report No. 70-925/85001; No. 70-1193/85001, environmental samples collected by NRC personnel and analyzed by RESL/USDOE Idaho Operation Office did not show the presence of plutonium or abnormal amounts of uranium except for one vegetation sample. Inasmuch as the vegetation results for uranium were higher than anticipated based on previous vegetation analyses, two additional vegetation samples were collected over the licensee's burial / disposal site and a reference (background) sample was collected from an offsite location. The 2

samples were split with the licensee. The NRC samples were submitted to the RESL/USDOE Idaho Operations Office for uranium analysis. The analysis results, for samples analyzed by the licensee and by the independent laboratory, indicated that there was no statistical difference between the analysis results of the vegetation atop the burial site and of the reference sample; nor was statistically significant radioactivity found above that found in other environmental samples.

Tte allegation was not substantiated.

4. Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organizational structure, procedure revising and updating, and utilization of audit systems.

a. Organization Sequoyah Fuels Cimarron Operation employs 52 persons in security, health and safety, and decommissioning operations of the plutonium and uranium fuel facilities.

The onsite radiation protection organization consists of ten persons including the Supervisor, Health Physics and Industrial Safety.

One Junior Health Physics Technician was added to the radiation protection program since the last NRC inspection. On a routine basis, technicians provide coverage during the day and evening shifts, and upon request all shifts are covered by radiation protection personnel.

b. Procedure Revising and Updating The inspector reviewed the licensee's transuranic and low level radioactive waste packaging and shipping programs and confirmed that operating procedures pertaining to these activities are periodically reviewed and/or approved by the Standby Operations Manager, Health and Safety Supervisor, Director, Nuclear Licensing and Regulation and the Director, Contract Management and Cimmarron Operations.

Recent reviews and approvals of operating procedures conducted by the staff include:

KM-NC-10-19, Revision 7, March 19, 1986, Low Level Radioactive Waste Packaging and Shipping.

KM-NP-10-82, Revision 8, March 24, 1986, Transuranic Waste Packaging, Storage and Shipping.

3

The inspector determined that changes made to operating procedures appear to be consistent with regulations and license requirements.

c. Special Work Permits l

The inspector examined the licensee's special work permit (SWP) file and discussed the operational aspects of jobs performed in conjunction with SWP provisions.

The inspector reviewed specific SWP's which corresponded to the following operations:

• Removal of Wall Tank Cover Plates

• Cut-up and Removal of Stainless Steel Wall Storage Tanks Each SWP required workers to follow prescribed safety precautions.

The inspector' observed two operators using a cutting saw (Wach's Guillotine Saw) to sever stainless steel tanks. In accordance with the SWP, the operators used the following safety precautions:

• The guillotine cutting saw is adapted for glovebox use. The box is under negative pressure and an additional exhaust line is located beneath the box. Each wall tank is 30 feet in length and 5 inches in diameter. The operator's must make 26 cuts in order to remove each tank for subsequent waste packaging and disposal. A selected length of the 5-inch pipe (slightly more than one foot) is passed upward through the bottom of the box and placed in cutting position. An exhaust hose is positioned near the bottom of the box in order to provide ventilation for the workers to perform the cutting operation without respiratory protective masks. The airborne radioactive concentration associated with the wall tank cutting operation was less than 10 CFR 20 limits established for plutonium.

• A survey meter was present for monitoring contamination icvel during glovebox bagout.

• An operator was equipped with a lapel air sampler.

• An air sampler was located near the cutting box.

The inspector determined that the operators were performing their assigned tasks using the precautions addressed by the SWP.

Additionally, the licensee employed engineering controls that enabled the operators to perform wall tank removal in a manner that mitigated contamination levels (ALARA).

The licensee also discussed precautions taken to mitigate personal injuries due to industrial accidents. The Senior Project Engineer noted that the hydraulics / associated oil pressure required to drive 4

. l the Wach cutting saw was equipped with relief valves / mechanical devices to limit blow-back and or the escape of oil under high pressure that may cause personal injury. A ladder and scaffold / platform (30 feet high) had been erected to accommodate personnel engaged in wall tank removal.

d. Internal Reviews and Audits The inspector verified that the licensee utilizes independent and inhouse audits as a means of identifying deficiencies. The following items were discussed in recent audits:

• Self contained breathing apparatus were inspected for damage and or usability.

• It was recommended that records of the operating condition of portable instrument response prior to and after calibration be maintained.

Fire guards are used during welding operations and no fires have been reported during decommissioning operations.

An internal OSHA review is conducted by the Corporate Compliance Inspector. No deficiencies were identified.

e. Safety Committee The inspector noted that a safety meeting was held during the course of this inspection. The licensee continues to emphasize safety topics related to equipment required for decommissioning activities.

Topics recently discussed are as follows:

• Portable power saw safety.

• Eye / hand safety (goggles, gloves).

• Safe response to accident or fire.

• Emergency escape route.

5. Radiation Protection The inspector reviewed the licensee's internal and external exposure control programs including the required records, reports, and the licensee's program for maintaining occupational expcsures ALARA.

a. Internal Exposure Control The inspector reviewed licensee records of internal exposure evaluations including: bioassay and air sampling results; whole body count data; and MPC-hour detccminations.

5

The inspector reviewed the results of routine urinalyses performed on plant personnel since the last inspection (70-1193/86001(DRSS)).

Urinalysis results for plutonium and. uranium plant workers for the January through June 1986 operating period were below investigation levels. In-vivo counts for persons assigned to the Th/U waste disposal site disclosed values less than the sensitivity values for thorium and natural uranium. Only two workers showed whole body counts detectable above the sensitivity for U-235. Since the sensitivity for WBC/U-235 is about 30-60 ug, the levels shown for the two workers (72 1 48 and 52 1 36) appear to be not statistically significant. All plutonium values were below the detection sensitivity.

The licensee's data on nasal smears disclosed that one Uranium Plant worker showed activity ranging up to 102 dpm. The operator was receiving packaged items from workers inside a plastic enclosure who were engaged in dismantling a UALX hood. (UALX-U235 is a uranium aluminum oxide matrix, insoluble Class Y material.) The operator was working outside of the plastic enclosure placing packages in the drums. Apparently, one of the packages either ruptured or was damaged causing an aerosol of UALX particles. The operator was not wearing respirator protection. Since the material was thought to be highly enriched U-235, all personnel performing the task were requested to submit nasal smears for uranium determination. While nasal sr.aar collection is a routine end of shift activity at the Pu plant, it is not a normal practice at the U plant. Nonetheless, the initial determination that the operator may have experienced an inhalation of airborne radioactive particulate matter was discovered-by counting nasal smaars. The licensee conducted a follow up insnection including a contamination incident report. The worker was placed on restricted duty, and sample kits were issued to the worker for both fecal and urine voidings. Fecal excrements disclosed about 5393 dpm over seven days, while urine voidings totaled about 19 dpm. A lung count was made in July 1986 and the results were less than the detection sensitivity for uranium. The licensee's assessment of the operator's exposure was 40.5 MPC-hours.

The inspector concurred with the licensee's assessment.

4

b. External Exposure Control The inspector reviewed the licensee's expcsure control program including adequacy of procedures used to evaluate, control, and minimize exposures and required records, reports, and notifications.

Film badge data for the first and second auarter 1986 disclosed that individual doses did not exceed the quarterly limit of 1.25 rem.

c. Air Sampling The inspector reviewed the licensee's program for determining exposure to personnel from airborne radioactivity detected by lapel samplers, and reports on the release of SNM effluents in the gaseous and particulate states.

6

The licensee's Plutonium Plant lapel sample data disclosed that operators in full face and/or supplied air respiratory protective devices were assessed'MPC levels of 5.1 to 34.8 MPC-hours. No significant levels of contamination were found in nasal smears (less than.15 dpm).

In accordance with 10 CFR 70.59, effluent monitoring reporting requirements, the licensee is required to submit a report to the Regional Office specifying the quantity of each of the principle radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous six months; 70.59 requires timely submittal within 60 days after January 1 and July 1 of each year.

Reports of this nature are supportive to the Commission in estimating maximum potential annual radiation doses to the public resulting from effluent releases.

The inspector determined that the licensee's report dated March 3, 1986, representing the last half of 1985 operations was submitted to Region III later than the time allowed by 10 CFR 70.59. This appears to be a violation of regulatory requirements. The inspector noted that the effluent monitoring report for the first half of 1986 was submitted to Region III in a timely manner. The promptness shown is considered adequate for corrective action and no further reply from the licensee is required.

d. Surveys The inspector reviewed the licensee's program for radiological survey to verify compliance with the regulations and with license requirements, including schedules for periodic surveys, effectiveness of surveys, and adequacy of instrumentation.

Nonroutine, unannounced surveys of work areas by health physics technicians have been very effective in alerting workers to the importance of personal surveys. Workers performing decommissioning tasks inside the plutonium plant also perforr.

personal surveys with four different instrument / detection systems prior to exiting the plant.

In response to the inspectors inquiries, the licensee agreed that it is desirable to expand the surprise surveillance to include wall lockers and privately owned automobiles.

The licensee also maintains records to show data on skin contamination, wound counting results, and unannounced or surprise surveys, discussed above.

Data for skin contamination included contamination to the ears, back of the neck, forearms, and the wrist and chest of various workers.

Corresponding contamination levels r;nged from 200 to 8,000 dpm; in all cases the levels were reduced to less than 100 dpm after a soapy water wash or shower. A puncture to the ring finger of one worker 7

resulted in contamination levels of 400 dpm as determined by a wound counter; contamination levels were less than 100 dpm after washing the punctured area with soapy water. The inspector reviewed the licensee's internal exposure results and determined that routine bioassays of these workers have not shown significant intakes.

e. Instruments and Calibration The inspector reviewed the licensee's program for calibration of instruments including effectiveness of the system used to identify instruments due for calibration.

The licensee is considering removal of the BF3 neutron counter from service because of the lack of neutron activity to monitor. This instrument was not calibrated during the routine schedule. This matter will be further reviewed. (0 pen Item No. 70-1193/86002-01)

Selective review of records of calibration of portable survey instruments, constant air monitors, and plutonium stack monitors disclosed that calibrations were performed as required.

The inspector concluded that instrument calibrations are performed at required frequencies, and that License Condition No.10, Authorized Place of Use for licensed sources, has been complied with.

One violation was identified.

6. Nuclear Safety During the operating period of January 1, 1986 through August 22, 1986, there were no facility modifications or changes that required the licensee to perform nuclear criticality safety analyses.

The licensee maintained compliance with requirements of 10 CFR 70.24, criticality accident requirements, which states: a monitoring system using gamma or neutron sensitive radiation detectors with audible alarm signals shall be maintained in each area in which SNM material is stored.

Article 70.24 used 450 grams of plutonium as a limited quantity for criticality monitoring.

During a recent decommissioning campaign, the licensee discovered that a tank containing Raschig rings, which are used to absorb neutrons, contained about 290 grams of plutonium; the 290 grams of plutonium represented a quantity that far exceeded the quantity previously determined by NDA measurements. The ratio of plutonium to previous NDA measurements (made outside of the tank) was about 8 to 1. The shielding provided by the Raschig ring tank, plus limitations of the NDA detector to accurately quantify values greater than 10 grams of plutonium apparently contributed to the error ratio. Deionized water was added to the tank, mixed with the solids, and vacuum transferred as a slurry through a tubular filter. The tubular filter (a geometrically nuclear safe container) retained the plutonium residue. This process was repeated until all of the visible material was transferred and collected.

8

~_ _-

Each filtered batch was dried and NDA counted. According to the data, the largest single batch contained slightly more than 9 grams of plutonium. Individual Raschig rings were collected in cardboard tubes and NDA counted for plutonium content. The tank was severed into small

. pieces, packaged and also NDA counted for plutonium content. The sum total of plutonium as determined by NDA measurement for each package was about 290 grams.

No violations or deviations were identified.

7. Training The inspector reviewed the licensee's provisions for training and periodic retraining of employees assigned to work with radioactive materials.

During decommissioning operations, the employee receives training in radiation safety, plant operations, equipment operation. emergency procedures, and selected topics in industrial safety. Workers from other Corporate divisions are engaged in equipment / sample storage operations at the Cimarron Uranium Plant. For these workers, the Health Physics Department conducted basic orier.tation in radiation protection including discussions of Regulatory Guide 8.13. " Instructions concerning Prenatal Radiation Exposure."

Two Health Physics Technicians (one Senior) attended a course in Radiation Safety Specialist Training conducted offsite by personnel from the Oklahoma State University Department of Physics. The Health Physicist / Industrial Safety Supervisor attended the midyear topical symposium-in Health Physics concerning decontamination and decommissioning activities. The inspector determined that the licensee is complying with regulations and license requirements related to the training of licensee employees.

No violations or deviations were idsntified.

8. Operations Review The inspector interviewed the Standby Operations Manager concerning the status of decommissioning activities at the Cimarron operations. During facility tours, the inspector observed licensee performance in accordance with statements, representations, and conditions contained in Appendix A of the licensee's application.

a. Plutonium Plant Plant laboratory facilities and rooms have been decontaminated and rearranged to accommodate waste storage. Operations have commenced and the licensee has removed 12 of the 60 plutonium liquid storage wall tanks. Each tank was cut into 26 individual pieces, NDA l

9 w - -- n e - ~ -m ,-

counted for plutonium content, and packaged for waste disposal.

The tanks had been previously rinsed with hot nitric acid which removed most of the plutonium residue. Ts date, airborne radioactivity detected during wall tank cutting was near background levels.

Decontaaination efforts have commenced on the three 5000 gallon tanks used as waste tanks during plant production operations. The Decon Operations Supervisor noted that the residue on the bottom of the tanks contained only about eight grams of plutonium. The residue was slurried with water and vacuum transferred to favorable criticality geometry.

b. Uranium Plant The UFs cylinder concrete storage pad was broken into small chunks for NDA evaluation. The soil beneath the pad will also be tested for uranium content. Decontamination Operations are nearly complete in the uranium oxide pellet area; the floor was stripped and new concrete poured after equipment removal. The walls adjacent to the pellet plant were shot blasted to remove any contaminated outer surface; the inspector noted that floor monitoring surveys were being conducted to release the area for a storage location. In other activities, the licensee started excavation procedures at the onsite burial site. The first swath excavated at the burial site was done to determine the extent of the waste. Material that was discovered intact in 55 gallon drums was placed on a drum conveyor and moved to the counting chamber for NDA determination of U/Th content. A counting room was constructed into the hill side adjacent to the U/Th burial site in a manner that allowed the natural contour of the hill to form three walls of earth to act as shielding to lower the counting background. Each wall of the counting room was reinforced with railroad timbers and lead lined.

The drum conveyor extended from the counting chamber through an access doorway to'reveral yards outside of the counting room.

The radiation detection equipment consists of two (5-inch by 9-inch)

NaI crystals packaged with hardware for isotopic analyses and printout. The licensee noted that the background of the counting system in this arrangement is about 10 pCi/ gram. The licensee noted that a small quantity of source material, as discussed in Inspection Report No.70-925/86001(DRSS), had arrived and had been prepared as a standard for measuring the thorium content in excavated thorium waste.

Final preparations have been made to dredge the bottom of two sanitary lagoons. Lab analyses were being conducted by two different laboratories for uranium isotopic content of samples dredged from the two sanitary lagoons. Confirmatory measurements, including samples for regulatory verification, are being planned in the near future. Samples are currently being analyzed by a corporate laboratory and an outside vendor.

10

The inspector concluded that the licensee's decommissioning program is being conducted in accordance with the regulations and the license.

No violations or deviations were identified.

9. Transportation Radioactive Waste Management The inspector reviewed transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt, packaging, and delivery of licensed radioactive materials. No discrepancies were found in the licensee's shipping records. About 2500 drums of dredged bottoms from the sanitary lagoon have been packaged for waste disposal.

The licensee noted that most of the radioactive waste generated for waste disposal is comprised of contaminated soil. Contaminated soil was removed from.the following locations:

• Dredged bottoms from two sanitary lagoons

• Soil surrounding a leaking process line routed to the waste ponds.

• Excavated soil from the Th/U burial site.

Excavation and contamination assessment have not commenced on land contiguous to the Uranium Plant.

The licensee also noted that liquid waste generated from decontamination activities is chemically treated and processed'through ion exchange columns for' uranium and plutonium recovery. The liquids are analyzed for isotopic content and released to the sanitary lagoon.

No violations or deviations were identified.

10. Maintenance Surveillance The inspector examined the licensee's maintenance operations to determine if records are maintained on plant systems pertinent to safety. The following subjects were reviewed:

• Pressure readings for ventilation flow in glovebox and slot box operations. Fans and dampers for operability.

• Manual starting emergency generator.

• Maintenance of Type B overpack container integrity to prevent loss of material during waste shipments.

11

• American Nuclear Insurers inspection of facility boiler operation.

No recommendations resulted.

Other activities performed by the maintenance department in support of decommissioning activities include:

• Installation of a counting room for counting waste drums at the burial site.

• Fabrication'of a cutting box hood for use in wall tank removal at the Pu Plant.

• Installation of a new chain link fence-erected around the burial ground (Includes Three-strand barbed wire).

The inspector concluded that the emergency generator is inspected weekly and that a record of repairs ~is maintained.

For criticality monitoring, gamma sensitive detectors are maintained in the areas as required. The detectors are checked monthly for calibration and alarm function. A spare system is maintained as a replacement unit.

No violations or deviations were identified.

11. Environmental Monitoring The inspector reviewed the licensee's environmental monitoring program with emphasis on the concentration of radioactivity in waste water released to the sanitary lagoon. Stack sample results were also reviewed.

a. Waste Water The two sanitary lagoons that were used during production are being decommissioned. Recently, the licensee constructed a new sanitary lagoon to take care of current needs for waste water containment and evaporation and to meet any new requirements for construction of a sanitary lagoon required by the State ~of Oklahoma. Waste water generated during decommissioning activities is passed through an ion exchange column for plutonium removal, collected in a batch tank, and subsequently sampled for release to the sanitary lagoon. The licensee recently pumped about 6,600 gallons of waste water (at less than 0.1 MPC for plutonium) to the lagoon. An additional batch of about 13,450 gallons (at 0.06 MPC) was also released to the sanitary lagoon. Heavy rains in early August, coupled with pumped rainwater from the excavated ponds to the new lagoon, had almost filled the lagoon. Normally the volume of water in the lagoon is controlled through evaporation. Plant generated waste water that exceeds the 0.1 MPC releasable limit for plutonium and or uranium is periodically recycled through ion exchange or solidified with cement for final waste disposal.

12

Stack sampling data for the U and Pu Plants disclosed levels.of airborne radioactive particulate matter at 0.04 and 0.02 MPC, respectively. ,

1 No violations or deviations were identified.

12. Exit Meeting The inspector met with licensee representatives (denoted in Section 1)-

at the conclusion of the onsite inspection on August 22, 1986. The inspector summarized the scope and findings of the inspection. In response to certain items discussed by the inspector, the licensee:

a. Acknowledged the inspector's comments concerning' locker room and parking lot (privately owned automobile) surveys.

~b. Stated that documentation of decommissioning activities for DOE publication will include a discussion on the decommissioning of a Raschig ring tank.

- c. Stated that emphasis on proper surveillance by individual workers will continue.

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

i l .

t i

! 13 I

i