ML20236R081
| ML20236R081 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 07/15/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236R075 | List: |
| References | |
| 70-0925-98-01, 70-925-98-1, NUDOCS 9807210228 | |
| Download: ML20236R081 (13) | |
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1 ENCLOSURE 1
U. S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-925 License No.: SNM-928 Report No.: 70-925/98-01 Licensee: Cimarron Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 Facility: Cimarron Site Location: Crescent, Oklahoma Dates: May 13 through June 25,1998 Inspector: Louis C. Carson 11, Health Physicist Nuclear Materials Safety Branch 1 Approved By: Charles L. Cain, Chief Nuclear Materials Safety Branch 1
Attachment:
Supplemental Information 9807210228 DR 980715 ADOCK 07000925 PDR
EXECUTIVE
SUMMARY
Cimarron Corporation, Cimarron Site NRC Inspection Report 70-925/98-01 Cimarron is conducting site remediation activities in preparation for the termination of license SNM-928. Several radiologicalinspections and surveys have been conducted at Cimarron as part of the overall NRC confirmatory survey process. This inspection was a continuation of this process. The licensee is authorized to bury soil contaminated with low-enriched uranium at the Cimarron site if the soil meets the criteria of the NRC branch technical position (BTP) for Option 2 soil. This inspection involved reviewing final status survey records and collecting soil samples from Pit 3 Lift 3 to confirm compliance with the license and the BTP Option 2 soil limits.
This inspection also included a review of the site's decommissioning status, management organization and controls, radiation protection program, and environmental monitoring program.
Decommissioning. Closecut Survev. and Site Status Site decommissioning activities were conducted in accordance with applicable license conditions and regu!%xy requirements. Site fences were in good condition, and perimeter postings were appropriate. No health or safety hazards were identified (Section 1).
Sub-Area F final status suivey data were included in a licensee final status survey report.
Sub-Area F final surveys and the training recorcis indicated that qualified personnel conducted Sub-Area F final surveys, and work instructions were consistent with the Phase 11 Final Survey Plan (Section 1).
The inspector concluded that the alpha and beta / gamma survey instruments used during the Sub-Area F final surveys had been calibrated in accordance with the recommendations of NUREG-5849 and ANSI N 323-1978,
- Radiation Protection Instrumentation Test and Calibration" (Section 1).
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Four soil samples were collected from Pit 3 Lift 3 during this inspection. The samples were collected from the same locations by both the NRC and the licensee as part of the NRC confirmatory survey program (Section 1).
. The NRC confirmed that licensee soil being placed in Pit 3 Lift 3 had less than 100 picocuries/ gram of soluble uranium and thus met the BTP criteria. No significant bias or statistical errors between the licensee's soil results and the NRC's results were identified (Section 1).
Manaaement Organization and Controls The licensee's management organization in support of decommissioning and radiation protection was in accordance with license requirements. The NUREG/CR-5849 compliance audit was comprehensive and satisfactorily conducted (Section 2).
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3-Radiation Protection The licensee had implemented a radiation protectico program that met ALARA goals and was in accordance with license conditions and 10 CFR Part 20. Internal and external personnel exposures were well below 10 CFR Part 20 limits (Section 3).
Environmental Protection Environmental protection and monitoring had been conducted in accordance with license '
requirements (Section 4).
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Egport Details 1 Decommissioning inspection Procedure for Fuel Cycle Facilities, Closeout inspection and Survey, Site Status (83890/88104) 1.1 Insoection Scooe 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 Cimarron Decommissioning Plan. The licensee's proposed Cimarron Decommissioning Plan commits the licensee to follow the recommendations in NUREG/CR-5849,
- Manual for Conducting Radiological Surveys in Support of License Termination." This routine inspection included a review of the site status, waste management, environmental monitoring, final status survey data, instrument calibration records, and quality assurance (QA) audit reports.
An objective of this inspection was to compare the quality of the licensee's original Sub-Area F final status survey data to the data the licensee submitted for NRC approval and to verify that radiation survey instruments used during the Sub-Area F final status survey were calibrated and functional.
As part of the NRC confirmatory surveys process, the inspector collected soil samples from Pit 3 Lift 3 to determine if the licensee met the BTP Option 2, NUREG/CR-5849, and License Condition 23. 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 must be less than the BTP Option 2 concentration limits which are 100 picocuries/ gram (pCi/g) soluble uranium and 250 pCi/g insoluble uranium.
1.2 Observation and Findinas
- a. Site Status Cimarron is in the final stages of site remediation in preparation for termination of its nuclear materials license. The licensee's Decommissioning Plan was submitted to the NRC in April 1995 and is under review. The licensee has continued to implement decommissioning activities in accordance with the Decommissioning Plan, although the plan has not received NRC approval. However, the licensee's activities have been coordinated with the cognizant project manager in the Office of Nucelar Materials Safety and Safeguards. The licensee's current activities included soil sampling, radiation surveying, groundwater remediation planning, characterization of radioactive material areas, and facility maintenance. Remediation at the Cimarron site was more than 95 percent complete. The work activity at Pit 3 represents the final soil remediation effort underway by Cimarron and is planned for completion in 1998. Final survey activities for the site are in progress. This inspection was a continuation of the NRC's confirmatory survey program for the Cimarron site.
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- b. Site Tour i 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 security personnel who prevented unauthorized access to the site. The license,e maintained locked gates at l entrances to site property, and visitors were required to chtsck in at the main office when accessing the site property. The inspector determined that licensed material was secure within the site property as required by 10 CFR 20.1801. A iditionally, fences were posted with radioactive material signs as required by 10 CFR 20.1002.
- c. Final Status Survey Sub-Area F Qata_ Quality Review On March 10,1998, the licensee submitted the
- Final Status Survey Report for Concrete Rubble in Sub-Area F" for NRC review and approval. The Sub-Area F final status survey package contained data from 134 grid locations. Sub-Area F was part of Cimarron's Phase 11 Final Status Survey Plan which was being implemented under special work permit (SWP) 96004. During this inspection, the inspector reviewed the original survey records from Grid 83,91, and 111. Final survey results for Sub-Area F included the following types of measurements: ambient radiation levels using thermoluminescent j dosimeters (TLD), exposure rate surveys using microRoentgen meters, soil and l sediment gamma spectral analyses, gross alpha surface radioactivity using alpha )
radiation survey instruments, and gross beta / gamma surface radioactivity using I beta / gamma radiation survey instruments. For Grid Nos. 83,91, and 111, the inspector compared the exposure rate survey data, gross alpha activity, and gross beta-gamma activity data from the Sub-Area F report to the actual radiation survey data record collected by the licensee's health physics technicians (HPT). The inspector found that the HPTs' survey data had been accurately transferred to the final status survey report.
The inspector noted that survey data collected by HPTs were reviewed by the RSO, the Sub-Area F project manager, and the QA manager. The inspector reviewed the SWP 96004 and training records which qualified the HPTs to conduct Sub-Area F final surveys. The inspector found that the training records and SWP 96004 instructions were adequate.
Instrument Calibrations j The NRC's final review of instruments used to conduct the Sub-Area F Final Status Survey was completed during the inspection of survey data collected by the HPTs.
Instrument calibration and functional check records were reviewed for alpha radiation survey instruments and beta / gamma radiation survey instruments used between May 5,1996, and August 28,1997. The inspector's review of these records revealed that the instruments had been calibrated and functionally checked in accordance with licensee procedures KM-CI-RP-57 and KM-CI-RP-59 and was consistent with the
6-recommendations of NUREG-5849 and ANSI N 323-1978, " Radiation Protection Instrumentation Test and Calibration."
- d. Confirmatory Radiation Soil Samolino The inspector reviewed the licensee's compliance with License Condition 23 for soil placed in Pit 3 Lift 3. The inspector observed the sample storage area. A licensee technician collected and prepared four soil samples for split-sample analysis by the NRC as part of the confirmatory survey process. The samples were expected to contain uranium that was less than the BTP Option 2 concentration limits.
The licensee used a sodium iodide detector to conduct soil analysis for uranium.
Radiation Protection Procedure KM-Cl-RP-47 was used for soil counter operations. This procedure contained instructions for operational checks, calibration checks, cesium-137 energy and efficiency checks, background determinations, and sample counting. Total uranium was determined by using a scaling factor applied to the uranium-235 value.
Before shipping the four soil samples to the NRC for analysis, the licensee analyzed samples for uranium using the sodium iodide soil counter. As a QA measure, the licensee recounted some soil samples that were previously counted during the Lift 3 activities in February 1998. The licensee counted the samples at 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 til laboratory uses during its analyses. The inspector found that the licensee's soil counting data was reproducible.
Four samples were sent to the NRC Region til laboratory for analysis on May 15,1998.
Licensee results indicated that the samples met limits for uranium in Pit 3. NRC sample results were compared with the Cimarron results to confirm that uranium levels met the license limits. The comparison of the analytical results were discussed with licensee representatives telephonically on June 25,1998. The residual contamination in each soil sample contained less than 100 pCi/g of uranium. The table on the next page represents the results of the confirmatory soil samples and exposure rate surveys at four locations in Pit 3 Lift 3.
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I 7-Confirmatory Soil Sample Results For Pit No. 3 Lift No. 3 NRC ,
Cimmaron Sample j Location isotope Cimarron Sample Size NRC Size (Sample #) pCilg grams pCilg grams 1 U-234 10.7 +/- 2.19 9.75 +/- 3.63 30N\510E U-235 0.5 +/- 0.1 0.43 +/- 0.09 (136) U-238 4.4 +/- 0.17 3.51 +/ - 1.31 Total U 15.6 +/- 2.47 895 19.44 +/ -4.28 765.2 1 2 U-234 19.3 +/- 2.4 11.05 +/- 3.47 290N\515E U-235 0.9 +/- 0.11 0.52 +/- 0.07 (141) U-238 4.0 +/- 0.19 3.98 +/- 1.25 Total U 24.1 +/- 2.7 871 15.55 +/- 3.68 707.2 3 U-234 15.0 +/- 2.29 15.16 +/- 4.16 305N\520E U-235 0.7 +/- 0.11 0.64 +/- 0.15 (149) U-238 5.0 +/- 0.18 3.64 +/- 1.01 Total U 20.7 +/- 2.58 879 19.44 +/- 4.28 722.7 4 U-234 36.2 +/- 2.51 34.13 +/- 6.72 375N\S25E U-235 1.7+/- 0.12 1.67 +/- 0.18 (178) U-238 11.8 +/- 0.22 12.29 +/- 2.42 Total U 49.7 +/- 2.85 l 1001 48.09 +/- 7.14 747.8 1.3 Conclusion Site decommissioning activities were 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.
1 The NRC confirmed that soil placed in Pit 3 Lift 3 had less than 100 pCi/g uranium. No significant bias or st3tistical errors between the licensee's soil results and the NRC's results were identified. Licensee soil measurement methods and counting times were found to be acceptable.
2 Management Organization and Controls (88005) 2.1 Insoection Scoog l
l The licensee's management organization and QA 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." The proposed Cimarron Decommissioning Plan commits the licensee to the recommendations of NUREG/CR-5849, Subsection 4.1.1 l
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"Ouality Assurance." This inspection involved an assessment of audits conducted by a corporate auditor regarding tra Cimarron site's compliance with NUREG/CR-5849.
2.2 Observations and Findinos
- a. Manaaement Organization The Cimarron Radiation Protection Plan describes the corporate and site organization.
The inspector reviewed organization changes since the last inspection. In July 1997 a license amendment request was approved by the NRC which authorized Kerr-McGee Corporation's Department of Assessment and Remediation to be respc nsible for corporate oversight of site decommissioning. On May 11,1998, the Dapartment of Assessment and Remediation was renamed to the Department of Hydrelogy, Geology, and Remediation. The onsite organization structure had also changed. The Cimarron vice president is also the site manager and is ultimately responsible for the completion of the decommissioning project. The inspector reviewed the licensee's organization and assignment of personnel responsible for implementing the proposed decommissioning plan. At the time of this inspection, the licensee's staff consisted of 24 personnel that included 2 Kerr-McGee employees,14 Cimarron employees,4 security contractors, and 4 consultant contractors. The Cimarron staM included HPTs, a health physicist, a decontamination specialist, contractor engineers, a OA manager, and clerical staff. The inspector found that the licensee's decommissioning organization was consistent with the license, NUREG/CR-5849, and the proposed decommissioning plan.
- b. Decommissioning Audit During Deceraber 1997, the licensee's corporate auditors began an extensive audit to verify the extent to which Cimarron's decommissioning program was in compliance with NUREG-5849. The licensee's audit team consisted of the Kerr-McGee corporate auditor, a contractor health physicist, and a contractor environmental engineer. The inspector determined that the qualifications of the audit team were consistent with NUREG/CR-5849. Program areas discussed in following chapters of NUREG/CR-5849 were audited:
- Chapter 2: The Decommissioning Process
. Chapter 3: Assessing the Radiological Status of the Site
. Chapter 4: Planning and Designing the Final Status Survey
. Chapter 7: Sample Analysis
. Chapter 8: Interpretation of Survey Results
. Chapter 9: Survey Documentation and Results At the time of this * *)ection, only Chapter 5 (RadiologicalInstrumentation) and Chapter 6 (Survey s echniques) were yet to be audited.
The audit plan covered 87 topical items from NUREG/CR-5849 and included 280 !
acceptance criteria. The audit team identified 79 criteria that were found to be i unacceptable (findings) and acceptable with comment (observations for improvement).
At the time of this inspection, Cimarron staff had taken corrective actions to prevent recurrence on 21 findings and 12 observations. Licensee staff had identified the l
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9 underlying root cause in most of the 21 findings. Corrective actions included training personnel, revising procedures and documents, and re-evaluation of final survey data by site staff. The site QA manager issued Corrective Action Report 97-12004 for corporate I management to assess the role of the site QA manager in reviewing final status survey data and calculations. The inspector noted that site staff, corporate management, and the As low As is Reasonably Achievable (ALARA) committee were continu;ng to develop corrective actions for many of the audit findings and observations. The inspector determined that the Cimarron staff's response to the audits and proposed corrective actions was generally adequate. The inspector further determined that the NUREG/CR-5849 audits were comprehensive.
2.3 Conclusion The licensee's management organization for site decommissioning and radiation protection was found to be in accordance with license requirements. The licensee's NUREG/CR-5849 decommissioning audit was comprehensive and had been conducted satisfactorily.
3 Radiation Protection (83822) 3.1 Inspention Scooe An inspection of radiation protection and decommissioning activities was performed to ascertain whether the licensee had complied with regulatory requirements established in the license and 10 CFR Part 20.
3.2 Qhservations and Findinas i i
The inspector reviewed the licensee's dosimetry records for doses received from '
January 1997 through April 1998. The licensee used film badges for external radiation dose determinations. Out of 29 workers monitored during 1997,'wo t workers had extemal radiation doses of 10 millirems. All other workers had no measurable extemal {
doses detected. The inspector reviewed the licensce's internal exposure records. The licensee analyzed breathing zone air lapel samples to determine intemal exposures.
During 1997,15 out of 29 workers were assigned intemal exposures. The internal exposures assigned ranged from 2 to 24 millirems.
The licensee's ALARA goals for 1997 veere less than 100 millirem per individual and a site collective dose of less than 300 millirem. The site collective dose for 1997 was )
155 millirem. The inspector determined that the licensee met its ALARA goals. J Additionally, the licensee conducts personnel urinalyses (bioassays) on a monthly basis.
The licensee's action level is 3 picoeuries/ liter (pCi/l), and no worker had exceeded the action level since 1995.
3.3 Conclusion The licensee had implemented a radiation protection program that had met ALARA goals and was found to be in accordance with license conditions and 10 CFR Part 20. Intemal
, and external personnel exposures were well below 10 CFR Part 20 limits.
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4 Radioactive Waste Management and Environment: Protection (88035/88045) 4.1 Insoection Scoce The inspector reviewed part of the licensee's environmental protection activ'ities to determine compliance with license and regulatory requirements. Areas reviewed included the licensee's groundwater monitoring program and environmental TLD monitoring program. l 4.2 Observation and Findinos i
Groundwater Contamination l Section 15 of the Cimarron Radiation Protection Plan requires the licensee to implement an environmental monitoring program that includes groundwater monitoring. The inspector reviewed the licensee's 1997 environmental monitoring report that was j generated in accordance with Procedure KM-Cl-RP-43, " Environmental Monitoring."
Groundwater monitoring results detected technetium-99 contamination between 874 pCill and 3960 pCill in monitoring wells (MW) 1208,1312,1313, and 1336A during 1997. Additionally, MWs 1313,1315,1316,1317 and 1331 measured uranium contamination between 111 pCi/l and 3044 pCi/l during 1997. The inspector noted that the licensee was continuing to investigate groundwater contamination and was planning to issue a groundwater corrective action plan to the NRC in June 1998 as part of the decommissioning plan that is currently under NRC review. The inspector determined that the licensee was adequately pursuing resolution of groundwater contamination matters in accordance with Procedure KM-CI-RP-43 and NRC requirements.
Ambient Radiation Section 15 of the Cimarron Radiation Protection Plan requires the licensee to implement an ambient radiation environmental monitoring program. The inspector reviewed the licensee's 1997 environmental TLD monitoring report that was generated in accordance with Procedure KM-Cl-RP-43. The licensee has 20 environmental TLD monitoring stations around the site. Environmental TLD Station 14 represented the site's background measurement and was located in the southwest section of the site. During 1997, TLD Station 14 measured 79 millirem. The highest ambient radiation was located at TLD Station 7 (Uranium Yard) which measured 106 millirem or 27 millirem above background radiation. Based on the inspector's review of the remaining TLD stations onsite and at the site boundary, the inspector determined that potential radiation dose to any member of the public from licensed material would have been well below the 100 millirem per year limit.
4.3 Conclusion
! Environmental protection and rnonitoring were found to be conducted in accordance with j license requirements.
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l 5 Exit Meeting Summary The inspector presented the inspection results to the licensee representatives at the conclusion of the onsite inspection on May 15,1998, and during a telephons conversation on June 25,1998. 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 l
PARTIAL LIST OF PERSONS CONTACTED Cimarron Corporation l
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K. Downing, Director of Regulatory Compliance M. Hodo, Quality Assurance Manager J. Larsen, Site Manager and Vice President, Cimarron K. Morgan, Radiation Safety Officer l J. Stauter, Vice President, Kerr-McGee Contractor Personnel S. Marshall, Nextep Environmental W. Rogers, Technical Consultant INSPECTION PROCEDURES USED l lP 83822 Radiation Protection IP 83890 Closeout inspection and Survey IP 88005 Management Organization and Controls IP 88104 Decommissioning inspection Procedure for Fuel Cycle Facilities IP 88035 Radioactive Waste Management IP 88045 Environmental Protection
( ITEMS OPENED, CLOSED AND DISCUSSED i
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Ooened l None Discussed l None
LIST OF ACRONYMS ALARA as low as is reasonably achievable ANSI American National Standards Institute BTP branch technical position CFR Code of Federal Regulations HPT health physics technician MW monitoring wells
- pCi/g picocurie / gram
- - pCi/l picoeurie/ liter PDR public document room QA quality assurance RSO radiation safety officer SNM special nuclear material SWP special work permit TLD thermoluminescent dosimeter l
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