ML20248J959
| ML20248J959 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 06/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20248J942 | List: |
| References | |
| 70-3073-98-01, 70-3073-98-1, NUDOCS 9806090375 | |
| Download: ML20248J959 (8) | |
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ERGLOSURE U. S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:
70-3073 License No.:
SNM-1999 Report No.:
70-3073/98-01 Licensee:
Kerr-McGee Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 Facility:
Cushing Site J
Location:
Cushing, Oklahoma inspection Dates:
May 11-13,1998 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 l
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9906090375 990602 PDR ADOCK 07003073 C
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EXECUTIVE
SUMMARY
Kerr-McGee Corporation, Cushing Site NRC Inspection Report 70-3073/98-01 This inspection included a review of the site status, decommissioning, management organization, quality assurance program, and inspection followup.
Site Status and Decommissioning of Fuel Cvele Facilities Full-scale remediation and decontamination of contaminated areas will not begin until the NRC approves the licensee's decommissioning plan submitted in April 1994 (Section 1).
The licensee's current remediation and decontamination activities included the Pit 4 pilot program, soil sampling and surveys, construction of a radioactive material storage area, non-radiological remediation, and site maintenance (Section 1).
1 Management Organization and Controls l
l The licensse's management organization for the Pit 4 remediation was found to be in accordance with license requirements. The audit conducted by the quality assurance staff was found to be comprehensive and satisfactorily conducted (Section 2).
Insoection Follow-up In 1996, the licensee failed to collect and analyze soil samples at eight locations and failed to analyze groundwater samples at five groundwater monitoring wells. These two failures were identified as a violation of License Condition 11(K) which incorporated I
Section 10.3(E) of the license application dated September 25,1992. The inspector determined that the licensee's corrective actions were adequate to preclude recurrence of a similar violation in the future. The inspector concluded that this matter should be closed (Section 3).
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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 Observations and Findinos 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. Although nonradiological remediation is ongoing at the site, full-scale radiological remediation and decontamination of contaminated areas has not begun pending NRC approval of the licensee's decommissioning plan submitted in April 1994 and separate approval of the Pit 4 remediation plan.
During this inspection, the licensee was planning for the remediation of Pit 4 which contains 1900 cubic yards of sulfuric acid and hydrocarbon sludge mixed with thorium cor.taminated waste. The average thorium concentration in Pit 4 is 20 picocuries/ gram.
The licensee's proposed Pit 4 Remediation Plan consist of the following three phase process:
Phase I: Mixing and neutralizing the acidic sludge to a pH of 9 with 20,000 tons of an aglime reagent.
Phase 11:- Excavation of radioactive material, sorting radioactive waste from the non-radioactive waste by conducting radiological scan surveys and placing radioactive waste into a radioactive material storage area (RMSA).
Phase 111: Stabilization of Pit 4 by backfilling the pit with radiologically clean soit and performing the final status survey.
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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 had began constructing the RMSA in support of the Pit 4 remediation project. No problems were identified during the
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Pit 4 Remediation Proiect Planning License Condition 11(B)(2) requires that the licensee submit to the NRC a description of the methods to be used to neutralize the acidic contaminated sludge in Pit 4.
Additionally, License Condition 11(B)(1) authorizes the licensee to construct the RMSA in support of the Pit 4 remediation project. However, the NRC must approve the licensee's effluent monitoring program and Pit 4Remediation Plan before the licensee can transfer radioactive material to the RMSA. During this inspection, the inspector held discussions with licensee staff and examined Pit 4 job planning which included: construction, special work permit (SWP) development, radiation protection training, a pilot demonstration of the acid sludge neutralization process, and quality assurance requirements. Overall, the inspector determined that the licensee's Pit 4 planning efforts were adequate. Licensee staff explained that SWPs would ultimately contain detailed instructions concerning the implementation of the Pit 4 project. However, the inspector determined that details associated with radiation protection and acid sludge neutralization processing were incomplete. For example, the licensee's Pit 4 Remediation Plan did not address radioactive waste shipments to an offsite disposal facility. The licensee planned to address the handling and shipment of radioactive waste from the RMSA at a later date.
The licensee plans to start the Pit 4 Remediation Project in August 1998.
d.
Respirators Used for Radiological Protection To date, the licensee's respiratory protective equipment had been used only for nonradiological remediation activities at the Cushing site. Therefore, the licensee's usage of respiratory protective program for radiological protection had not been of regulatory concern. The Pit 4 project represents the first Cushing site decommissioning project with a potential of exposing workers to airborne radioactivity. Therefore, the inspector reviewed the licensee's Radiation Protection Plan, Section 4.0, " Respiratory.
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. Protection "and Procedure KM-HP-122, " Issuance, Control, Usage, and Maintenance of Air Purifying Respirators Used for Radiological Protection."
3-Discussions with the licensee's radiation safety officer (RSO) and contractor technical staff revea!ed that the licensee's program for the issuance of respiratory protective equipment did not adequately address contractor use. According to the RSO, Kerr-McGee did not supply respiratory protection equipment to contractors. This was the responsibility of the contractor's employer. Individual contractors were responsible for cleaning and maintaining respirators that the contractor's employer had issued to its workers. According to the Radiation Protection Plan, the RSO is resporaible for maintaining Kerr-McGee employee's respiratory protection qualifications for radiation protection and for the issuance and maintenance of respirators. However, the inspector determined that the licensee had not evaluated whether its contractors had a respiratory protection program for radiological protection that was consistent with Procedure KM-HP-122 and the Radiation Protection Plan. The RSO stated that he and the occupational health and safety officer would review the contractor's respirator protection program for consistency with Kerr-McGee's program and 10 CFR Part 20.
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
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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 Scoce The licensee's management organization and quality assurance (CA) program were reviewed by the inspector to ensure compliance with license conditions, regulatory requirements, and commitments to NUREGICR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination."
2.2 Observations and Findinas a.
Manaaement Organization The inspector reviewed organization changes since the last inspection. The Department of Assessment and Remediation that was responsible for the corporate oversight of site decommissioning had been reorganized as the Department of Hydrology, Geology, and Remediation. The onsite organization structure had not changed. The inspector noted that the licensee had enhanced the QA organization by assigning a full-time QA engineer
> to the 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 86 personnel,9 Kerr-McGee employees and 77 contractors. The contract staff included health physics technicians, engineers, construction equipment operators, and clerical staff. The inspector found that the licensee's organization for implementing the Pit 4 Remediation Plan was consistent with the license and NUREG/CR-5849.
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Quality Assurance Audits The inspector reviewed the Cushing Site Quality System Manual which stated that the onsite QA coordinator assures that periodic audits are conducted, and that audits are sufficient to verify that site plans and procedures are being ful!y implemented. The inspector reviewed the QA audit report (AR) 98-1 dated April 14,1998, which addressed the following areas:
NUREG/CR-5849, Section 4.1.1, " Quality Assurance" l
Noncompliance Repcrt Trending Procedure Compliance Audit Ait 98-1 had been conducted by the site QA staff, and they identified 24 program deficiencies and observatiers. "Ihe licensee's Project Manager and O.A Coordinator assigned individuals responsibility for resolving specific audit deficiencies and observations within 30 days of the date of the report, a period which had not elapsed at the end of the inspection. The inspector determined that the licensee's audit was comprehensive.
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 was found to have been comprehensive and conducted satisfactorily.
3 Follow-up (92701) l 3.1 (Closed) Violation (70-3073/9702-01r Failure to collect and analyze environmental soil and groundwater samoles in accordance with the license In 19%, the licensee failed to collect soil samples at eight locations to determine the concentration of licensed material in soil and failed to analyze groundwater samples at l
five groundwater monitoring wells to determine the concentration of licensed material.
These two examples were identified as a violation of License Condition 11(K) which incorporated Section 10.3(E) of the license application dated September 25,1992.
In response to the inspector's findings, the licensee promptly initiated an investigation, collected and analyzed the missed soil and groundwater samples, and modified the appropriate procedures to reduce the likelihood of missing such requirements in the future. During this inspection, the inspector reviewed the licensee's corrective actions and the latest results of the soil and groundwater analysis. The inspector reviewed licensee procedures KM-HP-133, " Routines Procedure" and KM-HP-135,
- Quality Control Inspections." The inspector noted that both procedures contained checklists to validate that requirements will be met..The inspector determined that the licensee's corrective actions were adequate to preclude recurrence of a similar violation in the future. The inspector concluded that this matter should be closed.
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_ Exit Meeting Summary l
The inspector prasented the inspection results on May 13,1998, to the representatives of the licensee at the conclusion of the inspection. Licensee representatives acknowledged the findings as presen.ted. 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 Licensee R. Jones, Health Physics Specialist 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 INSPECTION PROCEDURES USED IP 88005 Management Organization Controls IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities IP 92701 Follow-up ITEMS OPENED, CLOSED AND DISCUSSED Ooened None Closed 70-3073/9702-01 VIO Failure to collect and analyze environmental soil and groundwater samples in accordance with the license.
L Discussed None LIST OF ACRONYMS AR audit report CFR Code of Federal Regulations PDR Public Document Room QA Quality Assurance RMSA radioactive material storage area RSO Radiation Safety Officer SNM
- SWP special work permit I
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