ML20216H375

Insp Rept 70-0925/97-03 on 971117-980302.No Violations Noted.Major Areas Inspected:Decommissioning,Closeout Survey & Site Status

ML20216H375
Person / Time
Site:	07000925
Issue date:	03/18/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216H367	List: ML20216H362 ML20216H375
References
70-0925-97-03, 70-925-97-3, NUDOCS 9803200263
Download: ML20216H375 (8)

Text

. i ENCLOSURE i l

U. S. NUCLEAR REGULATORY COMMISSION REGION IV i l Docket No.: 70-925 i

- License No.: SNM-928 l

l Report No.: 70-925/97-03  ;

l Licensee: Cimarron Corporation i Kerr-McGee Center {

Oklahoma City, Oklahoma 73125 i

i Facility: Cimarron Site Location: Crescent, Oklahoma i

Dates: November 17,1997, through March 2,1998 Inspector. Louis C. Carson ll, Health Physicist Nuclear Materials Safety Branch - 1 I

Approved By: Charles L. Cain, Chief Nuclear Materials Safety Branch - 1

Attachment:

Supplemental Information l

l 9903200263 900318 PDR ADOCK 07000925 C pm

2-l EXECUTIVE

SUMMARY

Cimarron Corporation, Cimarron Site NRC Inspection Report 70-925/97-03 i

Decommissionina Closecut Survev. and Site Status Cimarron is conducting site remediation activities in preparation for the termination of license SNM-928. Several radiological inspections and surveys have been conducted at Cimarron as part of the overall NRC confirmatory survey process. This inspection was a continuation of this process. This inspection report contains the results of confirmatory soil samples and exposure rate surveys analyzed by the NRC. The licensee is authorized to bury soil at the Cimarron site i contaminated with enriched uranium if the soil meets the uiteria of the NRC Branch Technical Position (BTP) for Option 2 soil. This inspection involved the sampling of soil placed in Pit 3 j Lift 2 to confirm compliance with the license and the BTP Option 2 soillimits. '

Exposure rate surveys were conducted on the soil in Pit 3 by the NRC inspector using a Nel detector. No new hot spots were identifiexf using the NRC's detector (Section 1).

Collection of soil samples from Pit 3 was performed during this inspection. Soil samples were collected from the same nine locations by both the NRC and the licensee. This i sampling is part of the NRC confirmatory survey program to support the eventual termination of the license (Section 1). t The NRC confirmed that licensee soil being placed in Pit 3 Lift 2 had less than 100 picocuries/ gram of uranium. No significant bias or statistical errors between the licensee's soil results and the NRC's results were identified (Section 1).

Followuo to Previous Insoection Findinas The inspector determined the adequacy of 49 CFR 172.704 waste processing and shipment training based on availability of records. This matter, previously identified as an unresolved item, has been resolved and closed (Section 2).

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3-Report Details  !

1 1 Decommissioning inspection Procedure for Fuel Cycle Facilities, Closeout 1 inspection and Survey, Site Status (83890/88104) l 1.1 Inspection Scope The proposed Cimarron Decommissioning Plan requires the licensee to follow the recommendations in NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination." Section 3.1(B) of NUREG/CR-5849 establishes i cr;terion for hoi-spot averaging in contaminated soil and requires that exposure rates do not exceed 10 microRoentgen/ hour (pR/hr) above background radiation. In the licensee's Phase-2 final status survey plan for areas like Pit 3, the licensee committed to applying a hot-spot averaging criteria in accordance with Section 3.1(B) of NUREG/CR-5849 for contaminated soil that exceeded the BTP Option 2 criteria.  ;

1 License Condition 23 authorizes onsite burial of up to 14,000 cubic meters of soil contaminated with low-enriched uranium. The concentration of residual uranium in soil i must be less than the BTP Option 2 concentration limits which are 100 pCilg soluble uranium and 250 pCi/g insoluble uranium. The inspector reviewed the licensee's  ;

compliance with License Condition 23 for soil placed in Pit 3 Lift 2. '

The primary objective of this portion of the inspection was to confirm that the licensee i placed soil into Pit 3 that met the BTP Option 2, NUREG/CR-5849, and License l Condition 23.

1.2 Observation and Findinas Sde Status The licensee's Decommissioning Plan was submitted to the NRC in April 1995 and is under review. The licensee continued to implement the Decommissioning Plan, although j the plan had not received NRC approval. The licensee's current activities included soil '

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sampling and radiation surveying, characterization of radioactive material areas, and facility maintenance. The Cimarron site has been undergoing final remediation activities  !

for termination of its NRC license. Remediation at the Cimarron site was more than 90 percent complete. The work activity at Pit 3 represents the final soil remediation effort underway by Cimarron and is planned for completion in 1999. Final survey activities for the site are underway. This inspection was a continuation of the NRC's confirmatory q survey program for the Cimarron site.  !

j Geotechnical Review of Pit 3 '

License Condition 23(d) established requirements for soil compaction tests. The soil was

' required to be compacted to 95 percent of maximum dry density. The inspector noted l that the licensee had completed the placement of Lift 2 soil in Pit 3, compacted the soil, and conducted compaction and density measurements. Soil compaction tests were l

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4 completed by a licensee contractor on September 9,1997, for Lift 2 soil in Pit 3. Based on the inspector's review of records and discussions with the licensee's contractor, it was concluded that the 95 percent compaction requirement had been met in Pit 3.

Confirmatorv Exoosure Rate Survev Results Pit 3 Lift 2 exposure rates were evaluated by the licensee using a portable Nal detector.

Background radiation levels around the site averaged 7 pR/hr. Radiation levels inside Pit 3 measured by the licensee were 13 pR/hr. Confirmatory exposure rate surveys were  :

performed by the inspector using a portable Nal detector at nine soil sample collection I locations in Pit 3 on top of Lift 2. Background readings measured by the inspector were 7-8 pR/hr. Readings inside Pit 3 were 11-14 pR/hr, and no new hot-spots were found during the inspector's survey. The inspector concluded that radiation exposure levels as a result of Pit 3 Lift 2 soil were less than 10 pR/hr above background levels.

Confirmatorv Radiation Soil Samolinojcooe and Results The inspector observed licensee sampling activities of Pit 3 Lift 2. A licensee technician collected and prepared nine soil samples for split-sample analysis by the NRC as part of the confirmatory survey process. Eight of the samples were expected to contain uranium that was less than the BTP Option 2 concentration limits. Soil Sample 140 was expected to exceed the limit and had been evaluated under the licensee's NRC approved hot-spot averaging criteria. The inspector collected the hot-spot soil sample to further evaluate the licensee's ability to detect and analyze higher levels of soil contamination in accordance with the approved criteria.

The licensee used a Nal detector to conduct soil analysis for uranium. The software and computer system had been upgraded in 1997. The inspector reviewed Radiation Protection Procedure KM-CI-RP-47 for soil counter operations. This procedure contained instructions for operational checks, calibration checks, Cs-137 energy and efficiency checks, background determinations, and sample counting. The U-235 concentration in the soil samples was determined based on the 0.186 million electron voit peak. Total uranium was determined by using a scaling factor applied to the U-235 value.

Before shipping the nine soil samples to the NRC for analysis, the licensee analyzed samples for uranium using the Nal soil counter. As a quality assurance measure, the licensee recounted some soil samples that were previously counted during the Lift 2 activities in October 1997. The licensee counted the samples at 5 minute and 15 minute intervals. The inspector's objective was to determine if the licensee's measurement system was reproducible. Finally, the licensee counted the samples in the same containers that the NRC Region 111 laboratory uses during its analyses. The inspector found that the licensee's soil counting data was reproducible.

Nine samples were sent to the NRC Region ill laboratory for analysis on November 18, 1997. The results were compared with the Cimarron results to confirm that uranium /

levels met the license limits. The results of the comparison of the analytical results were i

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' discussed with a licensee representative telephonically on March 2,1998. Except for Sample 140, a hot-spot sample, the residual contamination in each soil sample l contained less than 100 pCi/g of uranium. The inspector confirmed that the licensee

. appropriately applied the hot-spot averaging criteria to the area surrounding Sample 140.

The table on the next page represents the results of the confirmatory soil samples and l exposure rate surveys at nine locations in Pit 3 Lift 2.

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Soil Sample and NRC Survey Results For Pit No. 3 Location isotope Cimarron Sample Size NRC NRC (Sample #) pCilg grams pCilg pR/hr 1 U-234 10.2 +/- 3.06 5.86 +/- 1.5 285NW10E U-235 0.5 +/- 0.14 0.27 +/- 0.08 13 (137) U-238 1.3 +/- 0.23 2.63 +/ - 0.7 Total U 11.9 +/- 3.44 661 8.8 +/ -2.2 2 U-234 170 +/- 4.66 168.3 +/- 12.12 370NW10E U-235 8.0 +/- 0.22 7.58 +/- 0.63 12 (140) U-238 54.0 +/- 0.45 60.76 +/- 4.47 Total U 232.3 +/- 5.33 684 233.12 +/- 16.59 3 U-234 60.7 +/- 3.45 45.65 +/- 4.78 340NW28E U-235 2.8 +/- 0.16 2.1 +/- 0.19 14 (157) U-238 17.5 +/- 0.3 16.95 +/- 1.78 l

Total U 81.1 +/- 3.91 691 62.6 +/- 6.57 4 U-234 54.1 +/- 3.18 39.59 +/- 5.76 296NW25E U-235 2.5+/- 0.15 1.82 +/- 0.18 12 (178) U-238 15.5 +/- 0.27 11.74 +/- 1.71 Total U 72.1 +/- 3.6 737 51.3 +/- 7.47 5 U-234 26.1 +/- 2.64 19.35 +/- 4.15 295N\526E U-235 1.2 +/- 0.12 0.9 +/- 0.09 13 (180) U-238 4.8 +/- 0.21 5.59 +/- 1.2 Total U 32.6 +/- 2.97 773 25.82 +/- 5.35 6 U-234 44.6 +/- 2.99 33.26 +/- 4.08 335N\520E U-235 2.1 +/- 0.14 1.53 +/- 1.53 11 (182) U-238 12.6 +/- 0.25 12.31 +/- 1.54 Total U 59.2 +/- 3.28 735 47.08 +/- 5.69 1

7 U-234 36.9+/-2.73 24.35 +/- 4.05 370NW10E U-235 1.7 +/- 0.13 1.12 +/- 0.13 13 (183) U-238 12.2 +/- 0.23 8.36 +/- 1.39 Total U 50.8 +/- 3.09 807 33.83 +/- 5.44 8 U-234 53.1 +/- 3.05 45.43 +/- 5.64 295NW25E U-235 2.5 +/- 0.14 2.09 +/- 0.19 12 (184) U-238 17.6 +/- 0.26 15.88 +/- 1.97 Total U 73.2 +/- 4.36 798 61.31 +/- 7.61 9 U-234 42.5 +/- 2.69 30.25 +/- 3.48 355N\520E U-235 1.9 +/- 0.13 1.39 +/- 0.14 12 (185) U-238 11.4 +/- 0.23 12.10 +/- 1.39 Total U 53.5 +/- 3.05 888 43.74 +/- 4.47

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1.3 . Conclusion The NRC confirmed that soil placed in Pit 3 Lift 2 had less than 100 pCi/g uranium. The exception to the 100 pCi/g acceptance criteria were the hot-spots allowed by the NRC.

Therefore, the licensee met Cimarron License Condition 23. No significant bias or statistical errors between the licensee's soil results and the NRC's results were identified.

Licensee soil measurement methods and counting times were acceptable.

2 FOLLOWUP (92701) q 2.1 (Closed) Unresolved item 70-925/9702-01: Weste Generator and Shinnina Trainino B.equirements During the previous inspection, the licensee did not have onsite detailed training plans, training materials, and had not conducted proficiency tests. According to the licensee,-

training covered each relevant Department of Transportation (DOT) and NRC regulation and Procedure KM-Cl-RP-23,

• Low-Level Radioactive Waste Packaging and Shipping."

However, the licensee could neither provide the details of all waste training nor the test results for employees pursuant to 49 CFR 172.704(4)(d). The DOT requires the .

. licensee's records to include a description, copy, or location of the hazardous material training material used to meet the requirements, and a certification that the employees had been trained and tested. The licensee stated that it needed more time to gather all  !

- the required records. The inspector concluded that the adequacy of the licensee's waste i

processing and shipment training could not be determined. Therefore, this matter was determined to be an unresolved item.

During the current inspection, the licensee provided all the necessary records. The l inspector ascertained that the licensee met DOT training requirements pursuant to i 49 CFR 172.704(4)(d). This matter is closed.

3. Exit Meeting Summary

. The inspector presented the inspection results to the licensee representatives at the conclusion of the onsite inspection on November 19,1997, and during a telephone i conversation on March 2,1998. 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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ATTACHMENT 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 J. Stauter, Vice President, Kerr-McGee Contractor Personnel H. Newman, Nextep Environmental W. Rogers, Technical Consultant INSPECTION PROCEDURES USED )

IP 33890 Closeout inspection and Survey i IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities IP 83822 Radiation Protection IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Followup ITEMS OPENED. CLOSED AND DISCUSSED Closed 70-925/9702-01 URI DOT training and test records not available Opened l None l

Discussed l None LIST OF ACRONYMS BTP Branch Technical Position DOT U. S. Department of Transportation Nal Sodium lodide pR/hr microRoentgen/ hour URI Unresolved item i i

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