ML20236G881

Safety Insp Repts 70-0925/87-01 & 70-1193/87-01 on 870609-12 & 0724.Violation Noted.Major Areas Inspected:Nuclear Criticality Safety,Mgt Organization & Control,Radiation Protection & Radwaste Mgt

ML20236G881
Person / Time
Site:	07000925, 07001193
Issue date:	07/29/1987
From:	France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236G847	List: ML20236G845 ML20236G870 ML20236G881
References
70-0925-87-01, 70-1193-87-01, 70-1193-87-1, 70-925-87-1, NUDOCS 8708040410
Download: ML20236G881 (11)

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U.S. NUCLEAR REGULATORY COMMISSION' REGION III Reports No. 70-925/87001(DRSS);70-1193/87001(DRSS)

Docket Nos.70-925; 70-1193 Licenses No. SNM-928; $NM-1174 Licensee: Sequoyah Fuels Corporation Kerr-McGee Center Oklahoma City, OK 73125 Facility Name: Cimarron Facility Inspection At: Cimarron Facility CresQnt, Oklahoma Inspection Conducted: ~ June 9-12 and July 24, 1987 Inspector: .M F ne I M4 JZ/9f*7 Date #

. Approved By: L. R. Gregor, Chief 9-2.S -B 7 Facilities Radiation Date Protection'Section Inspection Summary Inspection on June 9-12 and July 24,1987(ReportsNo. 70-925/87001(DRSS);

No. /O-1193/6/001(DR55))

Areas Inspected: Houtine, announced safety inspection includinq: nuclear criticality safety; management organization and control; radiation protection, including training, exposure control surveys, and reports radioactive waste management, including transportation, activities; and discus;sions with licensee, NRC, and ORAU representatives concerned with confirmatory measurements for the decontamination / decommissioning program.

Results: The licensee was found to be in compliance with NRC requirements within the areas examined, except for the following itein: SNM-928, uranium

. plant - failed to perform radiological surveys in controlled. areas.

kE3 fffh870729 SNM-0928 pg

F DETAILS 1.- Persons' Contacted

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

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

• M.lW. Hodo, Accounting Supervisor

• A. W. Norwood, Facility Manager

• D. Rall, Decontamination-Supervisor

'*W.~J. Uranium Decontamination Supervisor Rhodes, Plutonium Decontamination Supervisor

~*V.Richards, Senior'ProjectEngineer W.. Spencer, E. Still, V ice PresidentEnvironmental and Health Management Division

• C,M. Thompson,HealthPliysicsSpecialist Oak Ridge Associated Universities J. Berger Oak. Ridge Office A. Luck,doloradoOffice

'* Denotes tho'se present at the exit meeting on June 12, 1987.

one Health The Physics inspector alsoand technician, interviewed theatlicensee's two operators the onsite medical waste burial consultant, location,.

~and one; operator at the uranium plant.

2. ' General. ,

The inspection of onsite activities, which began at 8:30 a.m. on June 9, 1987, was conducted to examine-decommissioning activities at the Cimarron site under Materials License Nos. SNM-928 and SNM-1174. Representatives of.

Kerr-McGee NRC Region III, and ORAU were also onsite to review the status of decommis,sioning activities and to determine a starting point for-initiating a confirmatory measurements program. A subsequent meeting involvinglicenseeandNRC(RegionIIIandNMSS)representativeswasheld 3 in the Region III Office on July 24, 1987, to discuss decontamination and decommissioning activities. ,

Licensee Actions on Previously Identified Items )

3.

(Closed)ObservationNo. 70-1193/86003-01(DRSS): Postin on using respiratory equipment. A copy of the licensee'g of plant policys policy the use of respirators is now posted on the plant bulletin board.

4. Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in l

'the organizational structure, procedure revising and updating, and l utilization of audit systems.

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a. Organization Sequoyah Fuels Cimarron Operation employs 50 persons in security, health and safety, and decommissioning operations of the plutonium and uranium fuel facilities. The licensee noted that two o have resigned from the facility since the last inspection. perators(Re) ort No. 70-925/86003; 70-1193/86003(DRSS)). The licensee plans to aire additional personnel to su) port those activities associated with handling, packaging, and slipping of radioactive contaminated soil.

There were no personnel changes in the licensee's radiation protection program.

b. Procedure Revising and Updating Many of the requirements adopted by operational procedures no longer a) ply to the licensee's decommissioning activities. In response to tie inspector's inquiry, the licensee plans to review and update procedures in accordance with the approved annual schedule. Progress in this area will be reviewed during a future inspection. (Observation No. 70-925/87001-01; 70-1193/87001-01(DRSS))

c. Special Work Permits (SWP)

SWP No. 0058 covers licensee activities for the non-destructive analysis and repackaging of waste material recovered from the onsite burial ground. An observation of work crew performances and interviews with theprojectsupervisor,twoworkmen,andthehealthphysicstechnician assignedtothejobdemonstratedthatthetaskwasbeingconductedin accordance with the SWP.

d. Internal Reviews and Audits The licensee utilizes independent audits and inhouse audits as a means ,

of identifying deficiencies. The following recommendation was made by  !

American Nuclear Insurers (ANI) during the conduct of an onsite audit:

• A method of documentation should be established to assure that a direct correlation exists between radiological instrument usage, measurement result obtained, and instrument calibration records.

• Nasal smears should be collected for uranium plant workers.

• The licensee noted that nasal smears are only recuested for uranium plant workers when airborne leveis exceec 10 CFR 20 limits and contamination has taken place. However, nasal smears are routinely taken at the end of the shift by workers engaged in plutonium activities.

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.The inspector noted that smear / fixed survey forms show entries-i for instrument calibration, serial number and identification of L instrument used.. The licensee demonstrated that' audit findings are promptly reviewed and evaluated for corrective action.

No violations'or' deviations were identified.

5. Radioactive Source Inventory - Cesium-137 The licensee is-licensed to use four Cs-137 sources under this existing license (No. 3512636-02) which expires February 28, 1990. In accordance the sources were checked for leaks and met the criteria with the license,ioactivity for removable rad or contamination level of 0.005 pCi'.

Hence,

'there was no problem identified.

TheinspectordidnotethatoneCs-137 source (165 mci)wasinadvertently listedonboththeSNMlicense(No.SNM-1174)ardtheby)roduct' license No 35-12636-02. Thus giving the impression.that two suc1 sources are in.

the licensee's possession, instead of one. The licensee plans to correct this. discrepancy by filing a licensing amendment application to retain the source under the byproduct license.

This will be reviewed in a future inspection. (0 pen Ite:n No.70-1193/87001-02)

6. Radiation Protection The' inspector reviewed the licensee's internal and external exposure control programs, including required records, reports, and notifications.

-a.- Internal Exposure Control Whole body count results for decontamination / decommissioning were below the maximum permissible body burden thorium, for uranium,g wo plutonium and americium-241 1soto)es.

the first quarter 238,239(JanuarythroughMarch1937)disclosedthattheBioa 40 MPC-hour intake limit for uranium / plutonium was not exceeded.

b. External Exposure Because of limited quantities of SNM materials available, the highest exposure to any employee was less than 200 millirem for current (1987) operations.

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

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In accordance with Materials License No. SNM-928 License Condition I No. 16 removablealphacontaminationlevelsshallbemaintained below$000dpm/100cm 2 in controlled areas of the uranium plant.  !

Although survey forms are used to document plant locations with high l 2

alphasmears(6000 dam /100cm;, April 13,1987) there doesn't appear I to be any notation tlat corrective action was taken to maintain t 2

contamination levels below the 5000 dpm/100 cm restriction, as required i by L. C. No. 16. This lack of documentation was discussed with the HP  !

Su)ervisor and will be reviewed during a future inspection.

(0)servationNo. 70-928/87001-03)

According to radiation survey records for the months of March and A)ril 1987, the licensee failed to perform required surveys in the clange rooms. Failure to perform a monthly survey in the controlled areas is an apparent violation of Materials License No. SNM-928, license condition No. 16, and Paragraph 7.E of Health Physics procedure KM-NC-10-63, Revision 6, which respectively state:

The licensee shall conduct a routine surface radiological survey of the facility on a monthly basis. The surface contamination i levels in the controlled areas shall be maintained below 5000  !

dpm/100 cm2 (removable alpha).

• KM-NC-10-63, Revision 6, Floor and Equipment Surveys and Limits. Floor and equipment in the radiation control areas andtheadjacentcleanareasshallbesurveyedweeklyand results recorded in HP survey log book. ,

No significant contamination levels were identified on coffee pots, j microwave oven, drinking water, fountain, or door knobs in the lunch 1 room and/or the guard station.

d. Incident Report Contaminationlevelsonthelapelsamplerfilterofoneworker(dressed inabubblehoodwithsuppliedair)wasequivalentto63MPC-hoursfor a 3.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> exposure. In practice, the lapel sampler filter head is worn beneath the respiratory hood in order to sample the environment inside the hood. Analysis of the workers' nasal smear samples resulted in only background levels of contamination. This suggested that contamination to the lapel samaler may have occurred inadvertently while the worker was removing lis anti "C" clothing. As a arecaution, the worker was required to submit a bioassay sample under tie licensee's delayed sampling schedule. Under the delayed sampling plan urinalysis is performed within one month after a worker is exposed to airborne radioactivity in excess of 40 MPC, but less than 99 MPC-hours. The bioassay data was not available for review during this inspect'.n.

This data will be reviewed during a future inspection. (0penItem No. 70-1193/87001-04) l l

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In another incident involving a plutonium )lant worker an' airborne Twoworker'swerecuttin)gupcontaminatedflexibleventilationexposure..(to lines with an air. saw while wearing full face protective masks.

Subsequent lapel air s, ampler data was equivalent to nearly 44 MPC-hours for one worker and less than 10 MPC-hours for the second worker.

-Theworkerwho.wasassessedthehigherMPCvalue(44MPC-hour) submitted a bioassay sample under the licensee's delayed sampling plan. This data will be reviewed during a future inspection. (0 pen Item No.- 70-1193/87001-05)

One violation was identified.

7. 'OperationsReview(Decommissioning / Decontamination'(D/D) Activities)

The Standby Facility Manager discussed the status of decommissioning activities at the Cimarron Facility.

a. Plutonium Plant.

The only ' remaining glovebox is the solidification box which is equipped-to dispense concrete-mix to drums of liquid waste.

Ventilation lines and/or duct work from all other glove boxes have been. removed and packaged for shipment to burial.

Thelicensee'scurrentmajoreffortinplutoniumplantactivities is to identify and remove contaminated concrete flooring and walls.

Excavation of concrete floors beneath the wall cells has already begun.

b. Uranium Plant Contaminated process equipment / scrap material has been removed from yard storage to the uranium plant for final D/D disposition. The flow of contaminated process equipment was observed in the following D/D modes:

• . Steam cleaning of the metal equipment is the final decontamination step. Collected condensate from the steam cleaning operation is processedthroughanionexchangeprocess(IX)foruraniumremoval.

~* where Steam a plasmacleaned materials arc cutting areissubmitted device to the used to size the cut-up material shop,for waste drum packaging. The ins)ector observed an operator i serving as a fire guard when tie plasma are cutter was in use.

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Y c. ' Contaminated Soil Most recent waste shi)ments were comprised of contaminated material-from' the licensee's.tlorium-uranium waste deposit site. ' Four tretiches c have been excavated and contaminated soil, paper,, plastics, and metal drums are being removed, assayed for uranium-thorium content and repackaged for offsite burial. . Cement dust is added to each drum of

. damp soil to absorb the moisture.

No violations or deviations were identified.

8. Criticality Safety There is no longer.a fissile quantity of special nuclear material i remaining onsite. Hence, no facility modifications or chan reguire nuclear criticality safety analyses were submitted.ges thatMonthly criticalitysafetyauditswereconducted(January 1987throughMay1$87) as required by Appendix A, Paragraph 5, of the license application.

The inspector confirmed that management of the licensee's nuclear safety program is commensurate with the license application. Since the remair>1ng SNM material amounts to-less than 450 grams of Pu, (less than the quantity

• specified in:10 CFR 70.24 for a criticality monitoring system) the licensee plans to file an amendment application to remove the criticality monitoring.

requirement'from.the license.

No violations or deviations were identified.

'9. Emergency Building The licensee's medical consultant disclosed that no health and safety incidents major enough for emergency treatment had occurred in recent months. At the time of-this inspection, the physician was in the process

.of submitting a users report to the ORAU registry documenting the use of trisodiumcalciumpentamil(DTPA). DTPA has been used in the past for treatment of workers who have suffered' internal plutonium depositions.

According to the licensee's DTPA users re) ort there was no exposure incident between June 1986 to June 1987 t1at required workers to be-treated with'DTPA. The inspector made the following observations while inspecting the licensee's emergency building:

• The HP Supervisor demonstrated operability of the Mark 7 respirator which is used in administering DTPA treatments.

• The'HP Supervisor demonstrated operability of the wound counter with a 0.17 pCi Am-241 source.

• Weekly checks of the wound counter were documented for the Janu'ary to June-10, 1987 operating-)eriod. A statistical check of

.the data showed good agreement, wit 1in the counting statistics, for an Am-241 source.

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• Survey instruments which are kept in a standby mode showed I semi-annual calibration stickers. l

• In accordance with the licensee's requirement the metal locator for detecting ferrous and/or non ferrous material in wounds / eyes had ,

been periodically inspected for operability. J

• The licensee's surgical instrument tray had been sterilized and returned to the emergency building in accordance with the consulting  !

physicians recommendation.

• A supply of DTPA is stored in the emergency building refrigerator.

Equipment located in the emergency building was being maintained in an operable standby mode.

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

The licensee continues to provide employees with periodic retraining in radiation safety, plant operations, equipment operation, emergency ,

procedures, and selected topics in industrial safety. New employees are reguired to take 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of instruction and/or demonstration in radiation health and safety.

Two Health Physics Technicians attended a 32-hour course in Radiation Safety Specialist Training conducted offsite by personnel from the Oklahoma State University College of Engineering Architecture and Technology. The Health Physicist / Industrial Safety Supervisor passed the examination for registration in the National Registry of Radiation ProtectionTechnologists(NRRPT).

The inspector cencluded that the licensee is complying with regulations i and license requirements related to the training of licensee employees.  ;

No violations or deviations were identified.

11. Transportation The inspector reviewed transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt and delivery of licensee radioactive materials.

Licensee shipping records disclosed that the licensee performed adequate program requirements that covered: 3 8

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• Monitoring for radiation and contamination of radwaste packages and transport vehicles.

• Shipping paper documentation in accordance with licensee and burial site procedures.

• Finalshipment(:3 drums)ofTRUwastematerial. (Theinspector observed the Accounting Supervisor confirming arrival and acceptance of the last TRU waste shipment from Sequoyah Fuels via telephone with US Ecology).

Under the licensee's packaging requirements, closure of a filled waste dr= =t include the application of a minimum torque pressure on the drum cover ring bolt-nut of 40 foot pounds. A corporate transportation audit disclosed that a representative from offsite burial ground notified the licensee that a ring bolt-nut on one drum was not fully torqued.

The Facility Manager instructed the Decontamination Supervisor to perform a supplementary check on all drum covers. In addition, the Accountability Supervisor was instructed to provide a pre-shipment check on drum lid covers.

The burial ground representative accepted the licensee's commitment /

corrective action via telephone. It appeared that the licensee's corrective actions were appropriate and an adequate response was made to the burial ground representative. The inspector discussed this issue during the exit meeting.

No violations or deviations were identified by the inspector.

12. Radioactive Waste Management The inspector toured the facility effluent control process to determine whether the licensee is complying with regulations and license requirements related to the release and disposal of liquid and solid radioactive waste.

a. Liquid Waste (Plutonium Facility)

In the plutonium plant, waste water streams that originate from lavatory stools is directed to a septic tank, while shower water, potable water devices, and discharge from the laundry operation are collected in one of two 10,000 gallon tanks. The collected effluent is sampled and NDA counted for gross al)ha, evaluated for 0.1 MPC release criteria, and if acceptable disclarged to the sanitary lagoon. Radioactive contaminated liquid waste that exceeds the 0.1MPC concentration is processed for solidification with cement and shipped to a waste disposal site. Accumulated '

sludge has been removed from each of the two 6,000 gallon waste process tanks. During the plant tour, the licensee noted that rinse water was being recirculated and filtered between the tanks to remove residual matter. Final disposition of the process tanks will be reviewed during a future inspection. (0penItem i No. 70-1193/87001-06) 9

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b. GaseousWastes(PlutoniumFacility)

Practically all ventilation duct work has been removed from glove  :

boxes previously located in the plutonium building. However, the system of HEPA filters remains intact to filter air exiting the building.

c. Solid Waste (Plutonium Plant)

During the course of this inspection the licensee identified areas where contaminated concrete flooring,was removed from beneath the wall tank cells. Other radiation surveys indicate that-contamination levels in the concrete wall bordering the solvent extraction room may also reguire excavation and waste disposal.

Most solid waste generated in the plutonium plant now consists of contaminated concrete.

.- d. Uranium Plant Radioactive contaminated solid waste generated from uranium operations is now comprised of cut up process eguipment and soil which is being exhumed from the uranium-thorium burial ground.

Collections from lavatory showers, potable water devices, and laundry discharge stream are piped directly to the sanitary lagoon.

Contaminated waste water is processed / treated through the IX clean up system. Effluent from the IX system having less than 1-MPC (via alpha couaing analysis) for uranium concentration is discharged to the sar.itary lagoon.

13. Exit Meeting Theinsp2ctormetwithlicenseer-preventatives (denotedinSection1)at the conclusion of the onsite inspection on June 9-12, 1987. Tne inspector summarized the scope and findings of the inspection. In response to certain items discussed by the inspector, the licensee:

a. Indicated that a list was being prepared for submittal to NRC via license amendment application to reduce criticality requirements and to assign the Cs-137 source to the byproduct license.

b. Indicated that a more comprehensive check would be made on waste packages pr:or to shipping offsite.

During the course of the inspection and the exit meeting, the licenst not identify any documents or inspector comments and references to speciric processes as proprietary.

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14. Confirmatory Measurements / Contaminated Soil Disposal i On. June 11, 1987 representatives of US'NRC Region III and Oak Ridge Associated Univer,sities conducted an onsite review of the decontamination status of the Cimarron Facility and the associated contaminated soil locations. A' follow-up meeting was held in-the Region III office on '

July 24, 1987. Personnel attending the July 24 meeting included: .

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'Mr. E. Still, Vice President, Environmental Health and Health Management

. Division, representing Kerr-McGet Corporation; Mr. R. Adkisson, Director, Contract Management Mr. W. Shafer and.Cimarron Operation,ief, Emergency Preparedn Corporation;ical and Radiolog Protection,-US Branch, NRC RIII,-Ch and members of their respective

.staf.fs, and Mr. P. Loysen, US NRC, NMSS. >

I During-the course of the meeting the. licensee and.the NRC staff discussed  !

the possible mechanisms for disposing of contaminated soil and subsequent j termination of the license. Based on these and subsequent telephone  !

discussions it was agreed that the licensee would submit a request-to amend their license to allow onsite decontamination in accordance with' the Option 1 and 2 criteria specified in the NMSS Branch Technical Position for Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations.  ;

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