ML23119A005

Letter to Mrothschild, NRC from Dshandy, Cimarron Corporation Dated September 21, 2005 Regarding Decommissioning Under Sdmp List

ML23119A005
Person / Time
Site:	07000925 (SNM-0928)
Issue date:	09/21/2005
From:	Shandy D Cimarron Corp
To:	Office of Nuclear Material Safety and Safeguards
Smith J
References
Download: ML23119A005 (72)

Text

CIMARRON CORPORATION Donald K. Shandy Senior Counsel Law Department Ms. Marjorie Rothschild U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 15 D21 11555 Rockville Pike Rockville, Maryland 20852-2738 RE: Cimarron Corporation

Dear Ms. Rothschild:

P.O. BOX 315

• CRESCENT, OK 73028 September 21, 2005 Telephone 405-270-2791 Facsimile 405-270-4101 E-Mail: dshandy@kmg.com It is Cimarron Corporation's (Company) desire to seek a timely license release of its Cimarron facility pursuant to the existing Site Decommissioning Management Plan (SDMP). Decommissioning of any remaining groundwater contamination under the SDMP is reasonable, using methods other than monitored natural attenuation (MNA). Also, it would be counter-productive to require remaining decommissioning to be performed under the License Termination Rule (LTR)1 (other than the SDMP grandfathering provisions).

Furthermore, the Cimarron Decommissioning Plan (DP) is clear in providing for alternate remedial methods such as pump and treat or exhumation for the remaining groundwater above the license criteria. This letter addresses concerns that the Nuclear Regulatory Commission (NRC) has brought to our attention regarding potential applicability of the LTR at Cimarron in the event that active remediation is chosen over MNA.

The Company has identified several areas with groundwater above the release criteria for total uranium of 180 pCi/L total uranium. These were reported in recent submittals such as the Site Wide Assessment Review (SW AR)2 and Conceptual Site Model (CSM)3.

The release criteria for total uranium in groundwater at Cimarron was established via Amendment #15 to License SNM-9284*

Overview of NRC Position In recent meetings, NRC indicated that the use of methods other than MNA at Cimarron would require the approval of a decommissioning plan compliant with the LTR. Further, NRC maintained 1 10 CFR 20 Subpart E.

2 Site Wide Groundwater Assessment Review for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, OK August 2005 3 Conceptual Site Model for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, OK August 2005 4 Issued via letter dated August 20, 1999 from Larry Camper, NRC.

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that Cimarron could not proceed with groundwater remediation without such a plan. The basis for NRC's argument was 10 CFR 70.38 (g) (1), and (g) (3) which state:

10 CFR 70.38(g)(l)

"A decommissioning plan must be submitted if required by license condition or if the procedures and activities necessary to carry out decommissioning of the site or separate building or outdoor area have not been previously approved by the Commission and these procedures could increase potential health and safety impacts to workers or to the public, such as in any of the following cases:

i) Procedures would involve techniques not applied routinely during cleanup or maintenance operations; ii) Workers would be entering areas not normally occupied where surface contamination and radiation levels are significantly higher than routinely encountered during operation; iii) Procedures could result in significantly greater airborne concentrations of radioactive materials than are present during operation; or iv) Procedures could result in significantly greater releases of radioactive material to the environment than those associated with operation. "

10 CFR 70.38(g)(3)

"The procedures listed in paragraph (g)(J) of this section may not be carried out prior to approval of the decommissioning plan. "

NRC asserts that MNA was specifically identified in the DP as the preferred method for achieving compliance with the license release criteria. NRC recently took the position that Cimarron must justify the use of groundwater remedial processes other than MNA, and "that any technology other than natural attenuation will require a revised decommissioning plan and would fall under the LTR5."

The above citations have been interpreted by NRC in NUREG-1757 (see attachment 1). This interpretation appears to be the basis for NRC's assertion that a revised DP would have to be submitted for processes other than MNA.

We have prepared a brief historical background, followed by information supporting our position that a revised DP is not required for work proposed at the site.

History of Cimarron Facility Remedial work at the Cimarron facility has undergone several conceptual changes throughout the license termination process, beginning with site decommissioning during the era of NUREG/CR-2082, and continuing through the SDMP process and NUREG/CR-5849. Today, the facility also faces conformance issues related to the application of the LTR, even though it will undergo license termination under the SDMP.6 The Cimarron facility has performed decommissioning operations since 1975 using many remedial methods and processes to achieve compliance with license criteria. Due to the complexity of 5 Summary of November 10, 2004 NRC/Cimarron Meeting Regarding Groundwater Remediation at the Cimarron Facility, transmittal fromK. Kalman, NRC NMSS to J. Lux, Kerr-McGee, February 28, 2005.

6 For example, NRC has indicated that even when all license criteria are met, the site must undergo an "all environmental pathways" dose assessment to determine its status relative to the LTR criterion of 25 rnrem/y Total Effective Dose Equivalent (TEDE) for the average member of the critical group. See 10 CFR 20.1402.

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the site, as well as the lack of specific regulatory guidance regarding cleanup methods, Cimarron has been a leader in the development of remedial processes, employing As ;Low ~s is Reasonable Achievable (ALARA) concepts throughout site decommissioning. The processes and procedures used at Cimarron have been performed with full NRC oversight and concurrence.

Procedures for remediation of groundwater will be consistent with these processes and procedures, and therefore should not trigger LTR requirements.

In addition to the SW AR and CSM, Cimarron has performed numerous studies of the groundwater conditions, and has reported these to NRC7* These documents identify certain areas of the Cimarron site containing groundwater exceeding the release criteria8*

In addition, Cimarron submitted annual environmental reports in accordance with its license, as well as supplementary data documenting the measured concentrations of radiological parameters. NRC considered this data when it approved the Decommissioning Plan.

Reports and communications to NRC throughout the years identified natural attenuation as well as the option of using other methods as means to achieve compliance with the groundwater release criteria9* NRC has recently taken the position that Cimarron must justify the use of groundwater remedial processes other than natural attenuation (e.g., plume excavation or water treatment) 10, and "that any technology other than natural attenuation will require a revised decommissioning plan and would fall under the LTR"11. In the interest of timeliness and compliance with our historical position with respect to groundwater remediation, as stated repeatedly in communications with NRC, Cimarron asserts that other methods ( e.g., 'pump and treat' and/or excavation) are acceptable methods under the SDMP for groundwater remediation, in addition to MNA.

Cimarron's positions related to the acceptability of various technologies are summarized below, followed by a discussion of each position:

MNA was NOT specified in the DP as the ONLY method authorized for groundwater remediation; the potential utilization of other methods was provided for in the DP and Decommissioning Plan Groundwater Evaluation Report (DPGW). Restriction of groundwater remediation to MNA was neither required nor specified in either the Environmental 7 Historical examples include:

• Cimarron Radiological Characterization Report, October 1994.

• Cimarron Decommissioning Plan, April 1995.

• Groundwater and Surface Water Assessment for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma, December 1996.

• Recharge and Groundwater Quality Study for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma, December 1996.

• Cimarron Corporation Responses to NRC Staff Comments dated March 13, 1997, on "Groundwater and Surface Water Assessment" and "Recharge and Groundwater Quality Study", May 1997.

• Work Plan for a Risk Assessment for Groundwater, August 1997.

• Risk Assessment for Groundwater, June 1998.

• Cimarron Decommissioning Plan Groundwater Evaluation Report, July 1998.

• Burial Area #1 Groundwater Assessment Report for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, OK, January, 2003.

• Assessment Report for Well 1319 Area for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, OK, December, 2003.

8 See SNM-928 License Condition 27(b).

9 e.g., Cimarron Progress Report - Burial Area 1 Groundwater Evaluation, Section 6, pages 5-6, 1/20/2000.

10 Telephone Record, Cimarron Conference Call with K. Kalman, NRC Headquarters and B. Evans, NRC Region IV, March 17, 2005.

11 Summary of November 10, 2004 NRC/Cimarron Meeting Regarding Groundwater Remediation at the Cimarron Facility, transmittal from K. Kalman, NRC NMSS to J. Lux, Kerr-McGee, February 28, 2005.

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Assessment (EA) or the Safety Evaluation Report (SER). In other words, all remedial methods were left in play.

Decommissioning work was performed concurrent with Decommissioning Plan (DP) development and with full NRC oversight and approval. NRC has granted wide latitude with respect to decommissioning methods both before and after approval of the DP.

Groundwater extraction, ion exchange, and excavation have already been used at Cimarron under NRC oversight for decommissioning activities.

Other methods Cimarron would propose would not increase potential health and safety impacts to workers or to the public.

CIMARRON POSITIONS REGARDING GROUNDWATER REMEDIATION OPTIONS Position #1 - MNA was NOT specified in the DP as the ONLY method authorized for groundwater remediation; the potential utilization of other methods was provided for in the DP and DPGW. Restriction of groundwater remediation to MNA was neither required nor specified in either the EA or the SER. In other words, all remedial methods were left in play.

MNA was not specified in the DP or in the groundwater related correspondence referenced in License Condition 27(a) as the only method to be used for bringing the ground water into compliance with the license decommissioning criteria.

In approving the DP, NRC agreed with Cimarron's stated intention to pursue alternative methods for accelerating cleanup in order to achieve an expeditious license termination. Cimarron's intentions were clearly stated in the March 4, 1999 letter referenced in License Condition 27(a).

"... should this investigation and modeling effort determine that relying upon natural attenuation to achieve the 180 pCi/1 total uranium concentration is not in the best interest of Cimarron for achieving its goal of expedient license termination, then other means of accelerating the clean up will be considered. "12 There have been numerous letters from NRC since the approval of License Condition 27(b) indicating that either additional characterization or comprehensive site planning for groundwater remediation was required. As further evidence of this assertion, the Environmental Assessment (EA) for License Amendment #1513 does not specify that MNA is the only method which is to be used for achieving compliance.

Position #2 - Decommissioning work was performed concurrent with Decommissioning Plan (DP) development and with full NRC oversight and approval. NRC has granted wide latitude with respect to decommissioning methods both before and after approval of the DP.

Cimarron began D&D activities during the era of NUREG/CR-2082, and proceeded through the issuance of NUREG/CR-5849, D&D activities were performed with NRC oversight and concurrence prior to issuance of License Amendment 15 which approved the DP. During this time, which stretched from 1975 to the present, NRC provided wide latitude to Cimarron in the selection and use of methods and techniques for remediation of the site.

12 Cimarron letter dated 3/4/99, Response to NRC's January 19, 1999 comments to Cimarron's July 30, 1998, "Decommissioning Plan Groundwater Evaluation Report", Docket No.70-925; License No. SNM-928.

13 Environmental Assessment by the Office of Nuclear Material Safety and Safeguards of the Proposed Decommissioning Plan and Other Proposals Related to the Cimarron Corporation Former Fuel Fabrication Facility, Docket No. 70-0925, July 29, 1999.

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That Cimarron and NRC have conducted almost 30 years of D&D activities in this way is an indisputable matter of record regarding the numerous methods and techniques which have been utilized in varied and innovative ways over the years.

This concept is reflected in License Conditions 27(e)(l) and 27(e)(2) which state:

"The licensee may, without prior NRC approval,... make changes in the facility or process,...

make changes in the procedures presented in the NRC-approved DP... conduct tests or experiments not present in the NRC-approved DP or applicable license conditions.

The licensee shall not be required to file an application for an amendment to the license when the following conditions are satisfied; The change, test, or experiment does not conflict with requirements specifically stated in the license (excluding those aspects addressed in Part 1 of this condition), or impair the licensee's ability to meet all applicable NRC regulations; There is no degradation in safety or environmental commitments addressed in the NRC-approved DP or RPP, or have a significant adverse effect on the quality of the work, the remediation objectives, or health and safety; and The change, test, or experiment is consistent with the conclusions of actions analyzed in the Environmental Assessment (dated July 29, 1999) and Safety Evaluation Report (dated August 20, 1999)."

One of the most important aspects regarding the use of methods other than MNA is that they would be "consistent with the conclusions of actions analyzed in the EA and SER". NRC has widely interpreted this as meaning that the result of remedial activities (i.e., health and safety aspects) are not significantly different from those concluded in the EA and SER14.

Remediation of groundwater contamination was recently completed in the Well 1319 area using a

'pump and treat' method.

The treatment process was discharge to the ground surface and adsorption onto soils. NRC was fully aware of the remedial activities and commented on the results of the remediation 15. The groundwater removal and treatment methods were not challenged at any time by NRC.

Position #3 - Groundwater extraction, ion exchange, and excavation have already been used at Cimarron under NRC oversight for decommissioning activities. 16 Several methods currently under consideration ('pump and treat' and excavation) by Cimarron for the acceleration of groundwater remediation rates are by no means new to the project but have been employed since early in the D&D process.

Ion exchange methods for reduction of both plutonium and uranium in waters were employed at Cimarron from 1981 through 1990. The use of ion exchange is documented in numerous NRC inspection reports and other correspondence.

The excavation of contaminated soils to eliminate source materials which could impact groundwater quality has been extensively reported and documented in the Characterization Report, ORAU/ORISE and NRC Confirmatory Survey Reports, Final Status Survey Reports, NRC inspection reports, and correspondence between the licensee and NRC.

As stated in the Cimarron Progress Report - Burial Area 1 Groundwater Evaluation:

14 See NUREG-0386, Section 6.

15 Letter from K. Kalman, NRC to J. Lux, Kerr-McGee dated May 2, 2005.

16 See Attachment 2, Tabs 3-8, 10, 12-25, 28, 31, 33, 35, 36, 40, 44, and 47.

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"Cimarron Corporation feels confident that all discrete sources have been removed from BG-1.

The only remaining item to be addressed is achieving the 180 pCi/1 total uranium concentration in groundwater required for license termination. As discussed in Cimarron 's March 4, 1999, letter to NRC, natural attenuation was considered a viable option for achieving the goal of expedient license termination because of the diminishing uranium concentrations in Well #1315. However, because of new information gathered during this recent investigation, Cimarron intends to expeditiously study the options for accelerating the cleanup of the groundwater near BG-1. The methods under study include:

Groundwater withdrawal and treatment followed by reinjection or appropriate discharge. Any sludge generated would be shipped off site for disposal or stabilized and placed into the on-site disposal cell.

Insitu chemical stabilization of the soluble uranium within the plume through the injection of a chemical slurry formulated for the subsurface hydrogeological conditions.

Insitu chemical stabilization of the entire shallow groundwater formation through the mixing of soils and groundwater with a formulated chemical constituent. The method would stabilize the soluble uranium and bind it to the surrounding soils. "

The DPGW, which has been incorporated into the SDP via License Condition 27(a), states:

"... groundwater radionuclide impacts have continued their decreasing trends from the levels presented in the 1989 Grant report.

With additional sources removed in these areas... these recorded decreasing trends will continue. "

However, the DPGW also states that Cimarron will monitor Burial Area #1 (BA #1) groundwater while conducting studies and performing other activities that include:

"... Any undiscovered waste... will be removed,... any suspect... soils that are revealed... will be evaluated utilizing the NRC's Branch Technical Position and volumetric averaging guidance.

These activities will serve to assure that any identifiable source of lingering groundwater contamination is identified and removed. "

Position #4 - Other methods Cimarron would propose would not increase potential health and safety impacts to workers or to the public.

10 CFR 70.38(g)(l) requires that two conditions both be met before a new DP is required under the LTR. Those conditions are:

The procedures or activities used were not previously approved, and There must be a potential health and safety impact to workers or the public as a result of implementing those procedures or activities.

The first bullet has been addressed in previous discussion. Procedures and activities that would be proposed for groundwater remediation have been implemented at the Cimarron site under NRC oversight and inspection, and in accordance with the ALARA principle. Those procedures and activities have been evaluated in Safety Evaluation Reports prepared by NRC for previous license amendments, and none of those reports have identified potential health and safety impacts to workers or the public. Consequently, neither of the two conditions that would require a new DP under the LTR, both of which should be present, will be triggered in plans to remediate groundwater by excavation or pump-and-treat technologies.

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Summary Cimarron has reviewed the License, DP, DPGW, and relevant associated documents and maintains that none of these state that MNA was intended as the sole method applicable to the achievement of compliance with the groundwater concentration criteria in SNM-928 License Condition 27(b).

NRC' s proposal to replace the current DP, submitted and grandfathered under SDMP, with a revised DP under the LTR is contrary to the spirit and intent of the timeliness rule and exposes both Cimarron and NRC to major delays and increases costs, with no corresponding environmental or safety benefit.

Active methods for groundwater remediation (such as 'pump and treat' or excavation) are consistent with the DP and the license. Cimarron proposes to utilize one or both of these individually or in combination under the existing DP and under the SDMP Action Plan. Cimarron will submit a groundwater remediation plan for areas of concern within 90 days of:

NRC concurrence with this position, and NRC and State concurrence with the Conceptual Site Model and Site-Wide Groundwater Assessment Review.

I would like to meet with you to discuss our position and to address any questions. In the meantime, if there is anything I can do to provide additional information or clarification, please call me at 405-270-2391.

cc:

Stuart A. Treby Jeff Lux Sincerely, 7)~t~

Donald K. Shandy 7

Figure 5-3 from NUREG-1757 8

THE.DECOMMISSIONING PROCESS Figure 5.3 fa a Decommissiimmg Pin Requil'ed?

Notts:

1 "Release limits" are* defined m 10 CFR 20, Subjmt E.

2 "NEW !icens.ed 111cmty"' meam my acti.1.ity &t thee facility m.10lvillg Illd:i.o3cm-e material, that is. IIO'I: anlhoiizea. ill tbe license prior m deamuuissiOlllllg. Eump1es; of Kmties llOt 1ypic11lly ml:horized mr1ml.e ~

demaitklm. ml e~

ofblll:isl areas.

3 "'.S~cmtly i:ocrease" mems. my mcru;e that illft:iates or c:lmJges a:ny report to !\'!RC.

5-11 NUREG-1757, Vol 1, Rev. 1 9

Key Position Supporting Documentation 10

Support Documentation List Kev Position TAB Date Document Title Refloc Reference Title 1

2 3

4 1

6/27/1979 NRC Inspection Report IP, 5 Additional plant cleanuo not initiated; Na2CO3 solution containina U still in storaae, to be blended X

X 2

6/23/1980 NRC Inspection Report IP, 6 Blendinq of waste solution continuinq - shipped to Sequovah for conversion X

X 3

2/20/1981 NRC Inspection Report IP, 5 Ion exchanqe system implemented soon, dismantlinq and decon continuinq X

X 4

IP, 7 Ion exchanqe will help eliminate larqe accumulation of waste containers X

X 5

ID, 10 Liauid waste cleanuo material on hand will be used for feed material in new ion exchanae svstem X

X 6

6/17/1981 NRC lnsoection Reoort ID. 3 Ion exchanae used on Pu moo water; ion exchanae svstem ooeratina for U Plant decon X

X 7

11/19/1981 NRC Inspection Report IP, 2-3 Ion exchanae svstem - aaueous waste within limit for disoosal X

X 8

3/18/1983 NRC Inspection Report IP, 3-4 Lie. Amend. 6 authorizes ion exchanqe system for reducina volume of liauid wastes X

X 9

3/31/1983 NRC Letter - Lie Renew p, 5 att. Liquid wastes qenerated: sanitary water and decon waste /fax note to K. Kalman 8/26/1998\

X X

10 5/17/1983 NRC Inspection Report p,4 Equipment beinq decon'd and shipped except ion exchanqe eauioment used for decon X

X 11 p,6 U inventory: solids, soda ash solution, drummed waste, and standards X

X 12 4/27/1984 NRC Inspection Report p,4 Ion exchanqe system in use for reducinq volume of liquid waste aenerated bv cleanuo X

X 13 7/26/1985 NRC Inspection Report p,8 U Plant dismantlinq activities - equipment and underqround pipinq X

X 14 2/11/1986 NRC Inspection Report p,4 Ion exchanqe system for decon solutions; review of SWP for ion exchanqe system X

X 15 p,9 Contaminated soil removal from U Plant X

X 16 p, 10 Inspector review of ion exchanqe for criticality safety-favorable and in compliance X

X 17 9/22/1986 NRC Inspection Report p, 10 U Plant decon, burial area excavation, laqoon dredqinq preparation X

X p, 11 Transportation safety reviewed, contaminated soil removed from 3 source areas, ion exchange 18 treatment X

X 19 D. 12 Sanitarv laaoons decom, waste water ion exchanae treatment X

X 20 1/14/1987 NRC lnsoection Reoort ID. 6 Sanitarv laaoons decom and excavation of Th/U burial site X

X

p. 7-8 Decom of Pu Plant and U Plant, screening & transporting Th/U waste (BTP accordance) &

21 excavation X

X 22 5/10/1989 NRC lnsoection Reoort ID. 2-3 U-ar sludae tanks oackaaed for burial, u-ar waste tanks oackaaed for off-site disoosal X

X 23 ID. 5 Characterization of soil for final disoosition /BTP\

X X

24 9/18/2002 NRC lnsoection Reoort ID. 7 Buildina demo, eauioment dismantlina, soil excavation X

X 25 12/29/1987 Resoonse to NRC RAI ID. 4 U Plant liauid wastes orocess throuah ion exchanae X

X 26 12/7/1988 NRC Letter w/ORAU Reoort ID. 1-2 GW contamination associated with former burial area X

27 2/23/1990 NRC Reoort Review ID. 2 GW contamination areas identified in 1980 Grant reoort X

28 3/13/1990 NRC Letter ID. 1 Reauest for descriotion of soil excavation, samolina and sortina X

X 29 9/14/1990 NRC Letter ID. 1 No obiection to discontinuation of effluent release reoorts X

30 12/9/1991 NRC Commission Policv lss.

ID. 1 License termination - orooosed to not imoose condition of reinstatement on license termination X

31 ID. 4 U contamination in soil and GW, decon under BTP Ootion 1 X

X 32 ID. 9 Need for oromot cleanuo mav outweiah reooener clause X

33 7/15/1992 NRC Commission Policv lss.

ID.3 GW imoacts of orooosed burial overlao with ootential imoacts of former oonds X

34 10/30/1992 NRC Commission Memo D. 1 Aooroved oroceedina with license termination w/o reooener clause X

35 5/31/1995 NRC Letter D. 1 ORISE borehole samole exceeded U limit, resamolina bv KM recommended X

3/29/1996 NRC Inspection Report

p. 7 Site activities included building surveys and dismantling, general cleanup, and remediation of burial 36 around #2 X

X 4/11/1996 Federal Register Docket

p. 1-3 EA, FONSI & Notice of Opp. For a Hearing; Release of Parts of Cimarron Site - 1979 scoping survey 37 and soil samolina referenced X

X 38 4/17/1996 NRC Letter D. 1 Review of 3/6/1996 submittal: concerned GW remediation not addressed in D Plan X

X 39 4/17/1996 NRC Letter D. 1 License conditions, althouah exoired, continue in effect until license termination X

40 4/23/1996 NRG Letter ID. 1 Aoril 1992 "SDMP Action Plan" instructed the use of 1981 BTP auidelines and ALARA X

X X

11

Kev Position TAB Date Document Title Ref Loe Reference Title 1

2 3

4 41 4/23/1996 NRC Letter ID. 2 Phase I areas released and removed from license X

11/12/1996 Cimarron Letter to NRC

p. 1 Request to include 9/14/1990 NRC Letter in license Condition #10 (discontinuation of effluent release 42 reports)

X 43 1/20/2000 Cim ProQess Report - BA #1 GW Evaluation cov ltr ProDoses Dian to continue GW studv then submit a DroDosed remedial Dian X

X

p. 5-6 Feels sources removed from BA #1, natural attenuation viable option, studying other methods due to new data (GW pump and treat, insitu chem stabilization of U in plume area, insitu chem stabilization 44 of entire shallow GW formation\

X X

6/19/2000 Cim Response to NRC Comments on Progress p.10 Cimarron is evaluating different methods for GW remediation - proposed remedial plan to be 45 Report for BA #1 GW Evaluation submitted to NRC for review and approval X

X 47 July-98 Cim D Plan GW Eval Report p, 10-4 Corrective action proQram will be prepared if U concentrations do not decline sufficiently X

X 3/4/1999 Cim Response to NRC Comments on D Plan p.4 If investigation and modeling determine natural attenuation not expedient, other means of 48 GW acceleratinQ cleanup will be considered X

X 49 11/7/1983 NRC Inspection Report p.4 U plant decommissioninQ - ion exchanQe used to recover enriched U X

X 3/18/1998 NRC Inspection Report p.3 Proposed D Plan requires following NUREG 5849; licensee implemented D Plan although it hasn't 50 been approved X

12

Tab 1 -NRC Inspection Report, 6/27179 p5 Found also in the same c~rdboard box with this fuel rod 1.i;ere sev~ral plastic bot:::les containing a total of 3.4 uo2 pellets.

These wera first weighed, then identified f~om code letcers imprinted on the flat end Sll~face of che pellets and fu:rther by reco:rd checks plus NDA measurements.

The UO~ pellets were dete=-:1ined co range from ~nrich.ments of 2.f6% U-235 up to 4.65% U-235.

Ite1:1ized listings with related values we.re e..xamined by the inspector as documented by the licensee en JEV i/959 issued on May 10, 1979, one* day after the pellets were found.

No discrepancies u1.. the gram c;.uantities assigned by the licensee we:re detected by the inspector.

Additional plant cleanup has not been initiated to any extent since the previous inspection in March, 1979.

Most of the scrap recovery area, pellet presses, furnace lines and other operating areas have not yet been subjected to thorough internal and dismantling type cleanup.

No new blending operations have been completed in several months.

~~~i

,~~~:i~l~::~*lY positioJ U"t8:r.!itlm

-- :'.:i-"

worthwhlale>:*sd.

.ceia procee;sad must be d~O:e "f-.:-~;<9£e~a.°d~aieas::.fo~

~~ill ~ *iii.a~ '

\.P the n~t,:p~~g:apera::ifon~ 'i:r,e. -'firris;J.iid solu,tion ~.l,end will then be sriip;ied to 1:he li.censea 's Se.qu:oy~ F.icilitj:* for.

conversiOn -t..o UF :> ~,

0

6.

Measurement and Statistical Controls - 85206B No items of noncompliance were noted.

Measurements perforned by the licensee since this inspection module was last addressed (Ref. IE Inspection 70-925/78-01) in March, 1978 consisted of periodic gamma counting using the single channel, Ludlum analyzer.

This NDA measurement method was utilized on nonline trash, solid wastes, dried mop water sludge, and bottles of pellets (see Paragraph 5 description on these pellets) since the inspector's previous measurement review.

Since then th~ea new raeasurement working stfu,dards have been developed for use with the Ludlum analyzer.

These are uo2 pellet samples. pulveri~ed, and put in a matri..~ of inert solid non-radioactive filler, each in a cardboard box (approxi:nacely 8" x 8 11 x 2") to :nake,up a gross weight of one kilogram per box-sta::idard.

Quantitative analytical measurement 13

Tab 2 - NRC Inspection Report, 6/23/80 p6 32..e!:::.:.::g o_--n-a..........._..

• a::ce._.,..,,_. ~--'L-... 5 as vol-r..x:.2.s v£ *,..*asca ~vl~:..~vrr i:ic-:-ea.se e::.c ug~... to j u..s :.i£:; the ~ l::.::ci.ing o £ lu:.,; e.::.::i:.:'-.-=C sc.*.:...u:ic~.:..5 ;..*i :h d2.~ ::..e::ed

~!6i~oc~:k;a~~ :~::~u:~t~~~~~!~=~o:!~::;Js~fp;~~=~:.i~:~atrc~;.:~~;sr-235.

The NRC ~1.a~e:-.!..al Coc.:-:-ol. a::::d Acco~~::a.bili..t:; I.i,:e.~sing B!"ia.t.-Ch i:: a letter d.ac-::::d. J~--:e 2: iS6 1J 1 s:.aced ::~-:.2.: ~he licer:.32,;:: *..;.:z.:ld r.. o longer :,a :-e.q-:..:.i::2.~

t.o issue ~or1c'.1ly loss repor-ts £-or Coth the ur2.r:i:.:= plane.a:-~,:! t::-'..c plutoniu.=1 plan:..

Co:1.sequen:.ly t:he. ~lay, 1380, loss repcrt which *was cos.p.letcd by t:he: A &.A Clerk du.ri:ig ch..i.s inspeccion. will Oe c:J.e: final one isst:ed.

7.

Measurem.e:it ~!ld Sta::istical Con:rols -

(852063):

No items of :ioncompli.ance were. noted..

The i;1spe.cticn results ~e:ce obtained. through re.view of NDA method. wi:...1-licer.. se.e pers*:;-::.n.el., int.er~al p:-oc.ed.u:ces, revie..-r..: aud rii:icussiun.

,,;ith key i?=rsoc;~el on zneas.urc

=:.t:!lt values 0Dr::a:.::2d ior ac::.01.Z.cabil.:..t:.y purposes.

The three measurement working standarCs for the single channel Ludlum Analyze.r devaloped prior co t.he: previous ins-p-=.cc.ion are still being u:ilize,.: by the lice.::.see. in cor:.]"t.!.."1.Ccion :.;ith N~-A m..easu::rements.

T:1.e.

u:-anit.:m. anC. U-235 con.tent cf th.esi= :hre.e s-ca:n.daxd.s £lave. Oee.n. veri.Ei-ad quant.itat.ive.ly by outside. laboratories..

They are best used for com.-

parz.ti ve ga.~a c.our_t:ing.values on low level~ noc.-line solid. ~,.;asta ::.ate::i.al.

A,.:::.~l working ste.ps involved iil t:hese ~4DA :ne.asure:mec.t:s were specifically obset:\.red b:,..* the inspe.ccor during gamma cauc.t:iI!g of non-lir!.e t:;:asD.. by a Health Physics Tec1:u::ician.

From the n:.ethod r..:sed the L-i_spec.tor con-cluded. ch.at ti1esa NDA mess,.. r.rements including backiround and instrumer:.i::

standards checks were being followed according t.O the licensee.

1 s 09er~ting

?.roce.d;:.::::=.s..

T... ~.e v'..:11~d.:.... y,...,;.

• ~a~~ based wr: rl"'Le. ::1..eaa:..:.rament:£ obse::-ve..d wv2s cc......C.:....::::.e.:: b/ ::.he in;;pecr::or.

The -~....:..::-__.,a::-... _ v.:: 1::0, 55 ga.llcu drt:ms a£ ur.:.n.i:i::. waste and one wooden box of.radioac:t:.*vel:"~ contaminated room ceiling cil~ was basad on me.asu:-e.d.

values a.s ve::-:..fie.,:i by :he ins?e-.:tcr:-.

~\.2.so a -iimit cf e.:.:::-::r r.,;as es:abl.iseC.

and _;;,Js::~ci. or: che :.;RC-7..:. l c.rsn.s.Eer doc...u:::::.r:t:, Y'SC:-\~:.:A-67" based 0:1. p.:-io::

measured. values obt:ai:1.e.d by use of the Ludlum single. channel. analyzer as reviewed by :.he inspec:or~

T11.e 66 line it:e..:::s cm:n:~:r:-isi:rg the pb.ysical inve.n:.ary ca.ken on Ju..rie 12~

1980 1 had uracium ar.d U-235 gram. quan~ities lisced cc the invencory tag ~hich wera all based on measured values as req~ired by the Sa£e-g1.:.a.:rcis A.mencim.ent of License Ccndi,;ion 3~ l, L.:.~e.nse.:ic~ s:NM-?28 and che lice:!':.see 1 s ow-:-:. ac.c.ount:abilit"'; Ptocedu::-es w I:--iis fact: was also verified

':>y ~he i.nspec:or t:!'".. rcugh revii:::w of back-1.!? me.asureme.r:.t d.a:.a 1nci. d.iscussicrr r,.;i:h th;)s2. licensee ?ersonr;,el responsil:ile for :::cbt.aining :.hese SNM values.

6 14

Tab 3 - NRC Inspection Report, 2/20/81 p5

5.

Facility Operation (85204 B)

No items of noncdmpl.iance were noted.

The inspection results were attained through a walk-through of plant areas, review and observa-tion of new uranium processing method for waste*cleanup solutions, review and observation of plutonium plant operations, review of internal procedures and interviews with key operating personnel.

Uranium Plant Dismantling and decontamination of process equipment is continuing at a somewhat erratic pace due to occasional other priority jobs in both this plant and the plutonium plant.

Areas and equipment still not dismantled and cleaned include tb.e "Big Shot" work hood, a series of gloveboxes which were used to make high enriched (93% U-235) buttons, drying ovens, and th.e process lines used for UAl which contains glove-boxes enclosing crushing and milling equipment and other process para-phernalia. All these areas inclu.ded processing of enriched uranium to over 5% U-235.

Any accountable amounts of SN!1 found here and verified by analysis to contain uranium enriched to over 5% U-235 will result, again in the licensee being found in noncompliance with its authorized possession limits under SN!-1-928.

The inspecto; discussed with the Standby Oper,itions l1anager the 1<oon to be implemented ion exchange system..

This. ~:r;~~!;!;,SS. will be ui;Jlizetl to reduce thevoJume of the, 1£.q,~id ~aste solut;i;~JI$a<;cUJllulated from deci>:rita.minatio-~ "and clean tip operations of plant surfaces, piping and dismantled eqµip111)!nt..Arr.ll.nion excliange resin wHT he used* to adsorb

,\ll.:/,,pr1::f:i::omplexes.ft:ii;.i;~nfum in ~~2

~olution... wf!,.1J.;l!:1Jd. f:lff1:1e,;its, rei;u1;ting from the 1~;1 exchange sys.******. will !lleet, NR.C rel~ase hmits to un_resf.dcted areas acc:o,~.4lp.g.. to the.Uc:eg~f!.*... Solids and solutions j,;ill be pretreated with Na*cq;.,rof the ion iiclla.i;rge p;rocess.

The systeia includes four ion excfian.ge columns which receive the filtrate from.t.he decontaminated solution treatment tanks and extract the uranium from the filtrate.

Uranium Accountability Procedure No. KM-~'ll-15-100 is being drafted now by licensee plant management and will include a description of sampling procedures, size of samples, frequency of sampling, and types of analyses which will be made to comply with a.ccountability requirements.

Suspended weigh scales will weigh one of two sets of four vertical, five inch diameter (I.D.) tanks at a time.

The limit of uranium concentration will be 60 grams of uranium per liter of solution of less than 5% enriched U-235 material.

The new ion exchange system should be operational by February 15, 1981.

6.

Plutonium Plant The inspector observed a test demonstration of the plasma arc torch as performed in a glove box in the uranium plant.

A piece of Section 80 stainless steel pipe was cut, and the safety controls were activated PART 2.790(d) INFORMATION 5 -

15

Tab 4 - NRC Inspection Report, 2120/81 p7 i.e., to be used with the proper matrix for NDA standards if required.

In this context, the calibration curve should be updated using more points, up to a level of 10 or 15 gr.ams U-235 to include the range of quantities anticipated in further NOA measurements.

Uranium measurements on liquid waste solutions are still b~ing m~de by the hcensee'5,.S~qH<3:)::ilh Pl,mt.

Isotopic ill1il1is.~s for perceiit.U-235 are contracted out* ~to Isotopic Analysis, Inc6r]?of;ted of Tulia, -Oklahoma.

The oi;ierati<;n of the fon ex.change system for separati11g>9:ut ~raniurn.{[2111 inputted liquid and solid faSj:-es will. h:elp elimir1ate large accumulatfon of waste containers during an.~nventory period and ge.t measurement values in less time.

Being a Groups V licensee with less than one effective kilogram of SNJ-!,

the licensee has limited measurement control requirements, however, limits of error (1.E.'s) are calculated for SNM items prior to shipment to waste burial sites. These 1.E.'s have been calculated and reported on the NRC-741 as determined by the inspector for the two waste shipemnts made since June 11, 1980.

Plutonium Plant New license conditions have been imposed on the licensee by the Material Control and Accountability Licensing Branch of the Division of Safeguards NRC Headquarters in a letter dated Septmber 22, 1980.

Three of these license conditions relate to measurement control.

One of these three, License Condition 4.2 has not been adhered to by the licensee as determined by the inspector *. The licensee has failed to measure any plutonium standards at the same time measure-ments were made on plutonium waste items as removed from the solvent extraction glovebox No. 27A.

These NDA measurements are being made by the Health and Safety (H&S)

Supervisor using a Ludlum Scintillation Counter with a Hodel 25 ratemeter and a cesium-137 transmission source. Earlier plans were for a SAM-II single channel, scintillation counter with a NaI crystal.

Tha11ium activiated, to be used when the pouched iteins were to be measured in a portable glovebox in a room adjacent to the SX Glovebox area.

Instead the pouched items were to be measured for plutonium have been transferred to Room 123 for gamma counting prior to pack-aging in 55 gallon drums in MBA-121, The SAM-II counter is available and operable, however, if needed.

The inspector had the H&S Supervisor go through the operation of the Ludlum instrument in measuring some plutonium standards.

Thus; the inspector was more assured of the operability of the instrument and the transmission source as well as the capability of the operator.

The NDA measurement system is beini calibrated over the range of operations with standards containing plutonium in matrices and geometries similiar to that encountered in operations.

The in-spector noted that this information could be better defined in PART 2.790(d) INFO&"iATION 16

9.

Tab 5 - NRC Inspection Report, 2/20/81 pl 0 Inventory (85212 B)

No items of noncompliance ~ere noted.

The ins?ection results were attained. through a review of internal inventory procedures, a piece count inventory of the uranium plant, a complete physical inventory of the items in the plutonium vau1t., observations of the inspector and discussion with key person.'lel.

Uranium Plant Physical inventories are being performed every six months as required by the licensee's internal procedure, No. Kl1-NU-15-8, and verified by the inspector.

A piece count inventory was taken by the inspector as-sisted by the Administration and Accountability Clerk.

No discrepancies were detected.

Several milk cans of liquid waste cleanup were on hand, unmeasured at this time.

These were generated since the previous in-ventory in June 1980, and must be measured and tamper-safe sealed before the next physical inventory.

The licensee informed the inspector that these plus others generated in the next month will be feed material for the new ion exchange system (previously described in Paragraph 5).

l'feasurements will then be a made on the uranium separated by the ion exchange columns.

Plutonium Plant A complete physical inventory of all items in the plutonium vault, HBA 12 was taken by the inspector assisted by the MBA custodian.

No discrepancies were detected.

A piece count of 121 drums of plutonium waste made up the inventory in tlBA 121.

The paper seals on the valves, plant operating equipment and gloveboxes were not inspected during this inspection.

The upper level area of the SX system for Glovebox 27A was observed by the inspector to reveal only the Section 80 stainless steel tanks remaining in the system.

The plasma arc torch was to be installed later that day to begin cutti11g the pipe into two foot sections prior to being pouched in polyvinyl and measured for plutonium content by NDA afte1 removal from the system.

The inspector reviewed inventory records and concluded they were being made bi-monthly and properly documented as required.

Also a piece count inventory is being taken and recorded in a log in the vault each time the vault is entered as the licensee's internal procedure requires.

10.

Records and Reports (85216 B)

One item of noncompliance was noted.

The inspection results were attained through review of license authorization, licensee ledgers, licensee offsite burials and agreement with Forms NRC-742 for the inspection period.

The licensee was found in noncompliance for possessing high enriched uranium (93%) as a result of uranium plant clean up.

The Uranium License lfo. SNM-928 authorizes the licensee to possess enriched uranium PART 2.790(d) INFOR.i'1ATION 17

Tab 6 -NRC Inspection Report, 6/17181 p3 to the uranium plant, primarily because packaging and burial site regulations prevent disposal of plutonium - contaminated waste generated during decontamination.

4.

Review of Operations

a.

Plutonium Plant License No. SNM-1174 for the plutonium plant does not permit any process operations.

Amendment No. 3 to the license authorized the removai of the solvent extraction (SX) system, a task that was the principal wo.rk activity during 1980.

At the time of this inspection, all SX equipment had been remov~d from the single large glovebox and packaged in 55-gallon drums for eventual burial.

A plasma arc torch was used to reduce the long stainless steel columns to shorter segments for packaging.

Work remaining is removal of steel equipment supports, and disassembly and volume reduction of the glovebox.

The glovebox ventilation system remains in operation.

In early 1981, work on SX system removal was discontinued temporarily to repackage the accumulated waste (Section 10).

Amendment No. 4 to.the license authorizes decommissioning of the remaining systems and equipment in the plutonium plant.

The work

.i()t begun.

The report for the inspection conducted in September 1980 (In-spection Reports No. 70-925/80-03; 70-1193/80-05) described an accumulation of several 55-gallon drums partially filled with mop water slightly contaminated with plutonium.

The licensee subsequently assembled a small ion exchange column about four inche~ in diameter, and removed the plutonium from the water.

The cleaned water was released to the sanitary lagoon.

b.

Uranium Plant Equipment decontamination activities in the uranium plant have been accelerated.

Since the inspection in September 1980, a decontamination system consisting of a stean1 cleaning unit and ion exchange columns was installed for the cleaning of larger pieces of equipment that cannot easily be cleaned by hand.

The steam cleaning_unit is located in a plastic tent.

Condensate is collected in a sump, then passed through an ion exchange colwnn to remove the uranium.

The water is sampled and analyzed for radioactivity, then discarded to the sanitary lagoon.

The eluate from the ion exchange column is normally concentrated about 7 g/1 in uranium enriched about 2.6% in uranium-235.

This material is blended with depleted uranium to obtain natural uranium oxide for shipment to. the company's conversion plant.

The inspector observed that two criticality monitors near the ion exchange columns and in the blending area, had been reac-tivated and were in operation. 18

Tab 7 -NRC Inspection Report, 11/19/81 p 2-3 DETAILS

1.

Persons Contacted

• A. W. Norwood, Cimarron Facility Manager

• R. L. Fine, Health and Safety Supervisor

• V. D. Richards, Uranium Plant Decontamination Supervisor

• J. L. Kegin, Maintenance and Utilities Supervisor

,;.-,,<G. J. Sinke, Corporate Staff Health Physicist

• ";;,E, R. Gqltra, M.D., Corporate l'led.ical Director The inspector also interviewed two uranium plant operators during the inspection.

• Present at exit interview at Cimarron facility.

• "kPresent at exit interview at corporate office.

2.

General This special, announced inspection began at 1:00 p.m. on July.15, 1981, and was concluded the following day.

The purpose of the inspection was to follow-up on a licensee report of the possible exposures of two uranium plant employees to more than 40 MPG-hours of soluble uranium in one week.

3.

Background

During a routine inspection on Hay 5-8, 1981 (Report No. 70-925/81-02),

the licensee's Technical Center, which analyzes biweekly urine samples submitted by uranium plant employees, reported uran.ium concentrations significantly above the licensee's action point of 65 dpm/1 in samples submitted by t1;0 employees.

The samples were submitted in early and mid - April.

The licensee began an investigation of the cause of ttie high concentrations and an evaluation of the personal exposures, as required by 10 CFR 20.103(b)(2).

The workers were restricted from work with uranium until their urine samples contained no significant uranium and the probable cause of the incident was determined.

The incident was classified as an unresolved item in Inspection Report No. 70-925/81-02 pending completion of the licensee's evaluation, including determination of MPG-hours exposure.

This information was provided to Region III in a report dated May 29, 1981.

The report indicated that the exposures to two employees may have exceeded 40 MPG-hours of soluble uranium in a seven day P,~rie>d.

4.

Cause of Exposures Cleanup and decontamination of the plant and equipment is currently the major activity in the uranium facility.

Solids and solutions containing uraniu,~ are generated in the process.

These are pretreated chemically to produce an alkaline carbonate solution which =is pumped through an ion exchange column to remove the uranium.

The aqueous waste from the column, after analysis to assure that its concentration 2 -

19

Tab 7 -NRC Inspection Report, 11119/81 p 2-3 is within the limit for disposal, is pumped to the sanitary lagoon.

The uranium eluted from the column, usually enriched about 2.5 percent, is transferred to an adjacent building for blending with depleted uranium to produce uranium with the enrichment of natural uranium, The principal components of the cleanup system are:

A steam cleaning unit enclosed in a plastic tent.

Several solution pre-treatment and storage tanks.

Ion exchange columns.

Ovens for drying solids.

An open-faced ventilated hood for handling dry solids.

recently replaced with a ventilated glovebox.

This was The two exposed workers were engaged in cleanup work during the period in which they submitted samples with elevated uranium concentrations.

Routine air samples collected at six locations in the restricted area showed no concentrations indicating significant air activity, nor did lapel sample data provide any evidence of airbo.rne activity.

Lapel air samplers were worn occasionally by each of the employees in accordance with a license condition which requires use of a lapel sampler during certain decontamination work.

The licensee concluded that excessive airborne radioactivity could have existed near the open-faced hood where the employees worked with open trays of uranium in the soluble carbonate form.

The employees did not wear lapel samplers during thi.s operation.

A st.ationary air sampler located at the bank of ion exchange columns, about ten feet away, was apparently too distant to detect air-borne activity near the hood.

The inspector discussed the exposures with the two employees involved.

Both were familiar with the licensee's evaluation.

Although neither could recall any specific occurrence that could have caused them to inhale airborne uranium, they agreed that inhalation of uranium while handling dry solids in or near the hood could have occurred.

They knew of no other possible cause.

The inspector concurs with the licensee's statement in the report of tfay 29, 1981, that inadequate air sampling failed to detect the incidents of apparent overexposure.

Inadequate air sampling is a violation of 10 CFR 20.103(a) (3) which requires that the licensee use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity.

Use of lapel samplers or an air sampler near the open-faced hood should have detected excessive airborne radioactivity.

5.

Corrective Action In the report of May 29, 1981, the licensee described several corrective actions, itemized below, that had been taken to improve det*ection and prevention of further exposures to airborne radioactivity. :

3 -

20

Tab 8 - NRC Inspection Report, 3/18/83 p 3-4 The larger job of dismantling the remaining equipment in the plant, authorized by Amendment 4 began in late 1981.

The licensee's Termination ?lan incorporated into the license by the amend.~ent divided the work into several tasks.

The status of the work.by task is described below.

Task No. 1 Task No. 2 Task No. 3 Task No. 4 Task No. 5 Task No. 6 Task No. 7 Task No. 8 Dismantling of solvent extraction system.

Work is completed except for the ventilation system.

Dismantling of gloveboxes and equipment in_ the wet ceramic area, rooms B-02 and 128.

The eight solution tanks in box 4, the internals of a calciner, and glovebox 6A have been re~oved.

The work is estimated to be about 35 percent completed.

Dismantling of equipment in the scrap area, rooms B-01 and 127.

This task was begun recently.

The completion estimate is 6 percent.

Dismantling of the dry process areas, rooms 123 and 124.

Gloveboxes in 123 have been removed and the room is in use as a storage area for packaged waste.

Equipment has been removed from gloveboxes in room 124.

Completion is estimated at 80 percent.

Dismantling of the laboratory. _Work has not begun.

This is a la.rge area containing much equipment.

Decommissioning should be easier than in process areas, however, because conta~ination levels are low or non-existent.

Removal of ducts and intermediate filters.

Work has not begun.

Removal of final filter system.

Work has not begun.

Decontamination of building surfaces and ventilation system.

Work has not begun.

'.rhe licensee "'in:.:i.m?"tted.;;:hat.completion of tasks 1 through 5 would require about three more years, assuming the work force remains at its current level.

Amendme."lt No. 6 to the license, issued in April 1982, authorizes operation of existing ion exchange equipment for the purpose of reducing the volume of liquid was~es generated in the plant during cleanup.

Plutonium in cleanup sohitions will be absorbed in ior:

exch&"lge resins.

The raffinate solutions will be collected, analyzed for plutonium, and di.scharged to the sanitary lagoon when 3

21

Tab 8-NRC Inspection Report, 3/18/83 p 3-4 concentrations are less than 10 percent of MPC for disposal to an unrestricted area~

The a-nendr.11int requ.ired prepa.ration of cpe:--atin.g procedures and a Safety Analysis Report before startup of the system.

The licensee has completed these requirements and the ion exchange, systems are being prepared for use.

b.

Uranium Plant Dismantling and decontamination work continues at a reduced rate because of the reduction in force.

The operation of air samplers and criticality monitors, ar:d the use of respiratory protection equipment observed during the tour were in accordance with applic-able regulations and license conditions.

5.

Radiation Protection

a.

External E:)..-oosure Film badge records for 1982 disclosed no problems.

Exposures to two workers exceeded one rem.

Tne average for all employees was about 0.5 rem.

b.

Urinalysis

c.

Uranium pla:.~t employees submit biweekly samples for analysis at the corporation's technical center.

Records for 1982 indicated no concentrations that significantly_exceeded the detection limit of 10 dpm/1.

Plutonium plant employees submit quarterly samples to a contractor laboratory.

Tne detection limit is 0.1 dpm/sample, usually a

-liter or more.

More frequent sampling is required when air sample results indicate possible exposure to more than 40 M?C-hours.

No samples in 1982 exceeded the detection limit.

Injuries involving skin penetration in the plutonium plant are subjected to a wound count if there is a possibility of contam-ination.

Urinalyses are required whether or no't the counter discloses a contaminated wound.

Four minor hand injuries were coU.'lted in 1982, one of which proved to be contaminated and required excision by the licensee's medical consultant.

None of the urinalyses following these injuries or following possible exposures to high airborne activity exceeded O.1 dpm/ml:

In Vivo Counting Annual cot:nts by a mobile contractor service were conducted in June 1982.

Three of 14 counts for uraniurn show'2'.d traces of uranium, all well below the restriction level of 200 micrograms of uranium-235.

No plutonium was detected in any of the 18 individuals cou.~ted.

Seve.~ of this group showed traces of arnericium-241.

The highest americium count was 0.36 nanocuries.

4 22

Tab 9 - NRC ltr for License Renewal dtd 3/31/83 p5 att.

5 Condition 14.

The licensee shall not a1low an individual whose skin or personal clothing is found contaminated above background radiation level to exit a controlled area without prior approval of the Standby Operation Manager or Health Physics and Safety Supervisor.

Condition 15.

Notwithstanding the statements in subsection 3.3.l, page 3-7, and Section 3.4 of page 3-14 in Appendix A of the application, release of facilities, equipment, and material from the plant to offsite for unrestricted use or from a controlled area to an uncontrolled area onsite shall be in accordance with the attached Annex A dated July 1982.

Record of the contamination survey and final disposition of any equipment shall be kept for inspection by NRC.

Condition 16.

The licensee shall conduct a routine surface radiological survey of the facility on a monthly basis.

The surface contami-nation levels in the controlled areas shall be maintained below 5000 dpm/100 cm2 (removable alpha).

3.

Training:

All personnel receive radiological safety training prior to starting work.

A refresher meeting on safety topics is also given periodically to all personnel.

4.

Management of Radioactive Effluents

a.

b.

Gaseous.

Since the exhaust fans are not in operation while the Cimarron Plant is in standby, no significant amount of radio-activity is expected to be released through the gaseous effluents.

of liquid waste are.. geper'tl:tei! atthe Cimafron.

wastes fr~m the 1 atintlcy and r~strooms, and/

ni:>ri~r;ftf*d as a result of.. the deconhm);~at.ion operatfon.

23

Tab 10 - NRC Inspection Report dtd 5/17/83 p4 shipment as indicatec!*in_the SNt-1-1174 Termination Plan.

Except for equipment being used in the ion exchange system for removal of plutonium from decontamination solutions, all equipment is beTng decontaminated and prepared for shipment.

Licenses No. SNM.1.1174 and SNt-1-928 expire Marc-h 31, 1988.

Due to requests from DOE for research to be done by the. lic_ensee., there is no projected date for completing tl:ie Termination Plan.

The inspection results were attained through revi~w of uranium and plutonium procedure;s, and discussions with: l_icensee personnel.

The inspectors determined that the procedures -are peing followed and a:ppear to be adequate.

5.

Neasurement a11d St'atisti'cal Controls No items o.£ noncompliance were noted.

The in~pection results were attained through a review of non-destruct:iye analysis (:NDA) methods used in both the uranium and plutonium _plants., review of internal records and discussions witli. individuals who have -measurement responsibilities for NDA in both facilities.

a.

Uranium Plant Uranium measurements are done by gamma count (Ludlll.lll Model 25 Scaler),

and when neces*sary, isotopic analyses for percent U-235 are contracted out to an independent contractor (Isotopic Analysis Incorporated of Tulsa, Oklahoma).

Duri."lg plant cleanup, *an}'. ti.ran:ium found which is enriched greater than five percent is. immediately mixed with depleted uranium and degraded to below fiv,e percent.

This method is authorized if the licensee does not exceed its present authorization (after degradation) of 1.2 kilograms U-235 enr~ched to less than five percent in the isotope U-235.

Good material degraded to natural (liquid) is shipped to the Kerr McGee Sequoyah Plant as "feed."

Nonusable m?te:i;ial resulting from plant cleanup is picked up as an inventory gain and removed as a measured discard (offsite burial).

During this in~pection period, 62,798. grams.of uranium and 1,725 grams U-235 were removed to offsite burial and 43, 292 grams of uranium and 309 grams U-235 were degraded to natural and shipped offsite. The inspectors also reviewed the licensee's method to calculate Limits of Error (L.E.'s), The inspectors verified that licensee figures (noted above) were accurately presented on the NRC-7 42 's_ for* this inspection period.

b.

Plutonium Plant Gram determination in the plutonium facility is by NDA using a Ludlum }lodel 25 Scaler.

Standards for operation are sampled 20

~imes each month to establish upper and lower limits.

These limits are then used to establish control charts. Each* standard is counted

five times on both Monday and Wedl\esday of-each week.

Part 2.790(d) Information 4

24

8.

Tab 11-NRC Inspection Report dtd 5117/83 p6 Tamper-safe seals in the plutonium plant are controlled by the Health and Safety Supervisor and storage custodians. All 1eals applied to containers are cross referenced on the internal transfer form and the drum is assigned the same number as the.applied seal.

Signature on the int.er1,1al transfer form signify proper applicatiol'.! of the seal and.witness by the shipper and receiyer signatures.

Type E seals are used in the Plutonium Plant.

. j..',

!1aterial resulti'tlg from d:t'smant!ing in !'IBA 50 (Holdup.Plutonium and General Laboratory) and',tiansferred to MBA 12, (Vault) is transferred on waste cards -whi~h accompany the drums:

When the d.rum is packaged each waste card reprasenting::_items is inserted. intp the drum.

In addition, a listing of was.t~ car.d material is maintained 'in the NDA Log by the Heal th and Safety. Supe:P.,isor _which allows for* t,:,aceab.ility of each item in the drums for subsequent shipment.

Movement of -Sm.I 'into and;.::ut oi MBA' s is based on :!!'DA measurement.

Losses can be 16.calized and dis'crete item control is on an MBA basis.

The inspect~rs determined' through interviews, observation, and records review that procedures are being followed and appear to be adequate.

Inventory No items of noncompliance were identified.

Physical inventories at the Uranium Plant are being performed every six months as required by 10 CFR 70.51 and licensee procedure, KH-NU-15-8.

SNM Inventory Reports are submitted to N:ltC Region III within 30 days after the start of each ending physical inventory as required.

The licensee presently has two cans of solids, 20 d;rums of drummed waste, and eight* standards in storage at the Uranium Plant, The'uranium inventory a~ of December 15, 1982 was 14,190 grams* uranium and 390 grams U-235 described as fo,llows:

a.

Solids

b.

Soda Ash Solution

c.

• Drummed Waste

d.

Standards Total u

4,556 2,613 4,224 2,79i' 14,190 Physical.inventories 'at the Plutonium being performed every 60 days as required by both 10 CFR 70.51 and licensee procedures.

Reports of each inventory are submitted to the NRC_Region III as required.

Except for the plutonium in 1'1BA 50 (G,loveb;x Holdup Plutonium), all SNM is stored in the Vault (MBA 12) and Roam 121 and 123 consists of SN!-!

packaged for shipment to burial.

The vault inventory: was comprised of four standards, and one Pu-238 neutron source.

The contents of Rooms 121 and 123 consisted of 457 drums of transuranic waste and 7 drums of non-

transuranic waste.

The plutonium inventory as of April 29, 1983 was

• ~ * '.10, 486 grams of plutonium broken down by MBA as follows:

Part 2. 790 (d) Information 6

25

Tab 12 - NRC Inspection Report dtd 4127184 p4 Task No. 5 Task No. 6 Task No. 7 Task No. 8

• 98 percent (some pieces remain in preparation for volume reduction and waste has not been shipped to burial).

Dismantling of the 1aboratory.

Work has not begun.

The 1icensee plans to begin this activity in June or Ju1y: For this activity the licensee plans to add two operators who wi11 be supervised by one of the two existing supervisors for the other crews.

The labora-tory is a large area containing much equipment most of which has no contamintion, or 1ow levels of contami-nation.

Therefore, decommissioning should be easier than in the process areas.

Removal of ducts and intermediate filters.

Work has begun. by removal of glovebox exhaust ducting and inter-mediate filters in Rooms 123 and 124.

The comoletion estimate_ is 5 percent.

Removal of final filter system.

Work has not yet begun.

Decontamination of building surfaces and ventilation system.

Work has not begun.

Licensee personnel stated plans were to complete all tasks by the end of 1986.

The licensee uses existing ion exchange equipment for the purpose of reducing the volume of liquid waste generated in boxes*, etc. resulting from the cleanup of equipment and systems.

The processed liquid is ana1yzed and if the concentration is less than 4.0 x E-7 uCi/ml a1oha (0.1 MPC for release to an unrestricted area) it is released to the sanitary lagoon:

When release limits can not be met, the licensee solidifies the liquid with cement in drums while limiting the concen-tration such that the solidified waste may be placed in licensed dis-posal sites.

The licensee has recently set up a new ion exchange column to be used exclusively for processing low concentration mop water.

This equip-m-ent is discussed in Section 10, "Facility ModHications and Changes".

b.

Uranium Plant The inspectors toured the Uranium Plant to observe decommissioning activities and licensee programs in accordance with statements, representations, and conditions contained in Appendix A of the licensee's application, and to review the license requirement for survey instrument calibration.

Work continues in the size reduction and removal of concrete neutron shields (donuts) for drum waste disposal. The calciner has been decontaminated and removed, while the ca1ciner's concrete support base is undergoing size reduction and contamination surveys for waste disposal.

4 26

Tab 13 -NRC Inspection Report dtd 7126/85 p8

a.

Plutonium ?lant Decom:nission.b::g of plant 1aborat:ory facilities is nearly complete.

Several laboratory rooms are scheduled for radiation surveys for subsequent release and use as storage areas.

In the scrap recovery area several gloveboxes were disma:1tled and the lower flight staircase was moved 90 degrees to accommodate additional working space.

The licensee noted that as a result of decontamination activities about 60 percent 0£ the plutonium is being recovered, compared to predetermi."l.ed (1't1)A) plutonium hold-up values.

Several glcveboxes previously used i., scrap recovery operations were placarded ~i~~

• radia.t:ion exposure levels.

These levels will be considered when special work permits are issued to dismantle the gloveboxes.

b.

Uraniu:m Plant

c.

Processing and ancillary equipment continue to be stockpiled in the rear of ~he plant.

Tne licensee is also conduc~ing ac~ivities to remove u.-iderground overflow pipes routed from the sanitary lagoon t:o the river, to remove underground piping routed between evaporation ponds, a.,d to remove underground piping rcut:ed between evaporation ponds and the river.

Recovered underground pip::.:ig and ether stockpiled equipmen~ will be surveyed for radioactive con~amination) and*

decontaminated to levels consistent with regulatory requirements.

Dismantling activities within the uranium operations building are about 85 percent complete, while the percent.age of clea..,up for i:he overall project completion at the plutonium facility is about 50 percent.

Housekeeping During the course of this inspection, the inspectors observed that equipment and waste material contaminated with SNl1 material was s~ored in designat:ed storage areas.

The inspection also disclosed that exits and evacuation pathways were clear, and based on quantitive recovery data the potential fer accumulating fissle materials in critical quantities and or in unauthorized locations was minimized.

The inspectors concluded that the licensee's decommissioning activit:ies are being conducted in a ma.n..~er that is commensurate to practices that appear adequate to protect the health and safety of facility workers and members of the general public.

No violations or deviations were ident:ified.

8 27

c.

Tab 14 -NRC Inspection Report dtd 2/11/86 p4 inspector noted that a1l personnel are cautioned to never exceed safe operating limits for accumulation of fissionab1e material.

KM-NC-10-83 1 Revision 1, July 30, 1985, Plutonium Plant LSA Waste Drum Counter The drum counter enables the licensee to restrict contamination Jevels i.n combustible LSA waste.

KM-NP-36-18, Revision 4, July 26 1 1985, Operation of Glovebox (GB) 40 Ion Exchange System Along with filtration, the ion exchange system is used to reduce the radioactivity level of the decontamination solutions to a level that can be solidified and disposed of as C1ass A LSA w~~te, Since both the vacuum pump exhaust and air supply in GB 40 have the potential of pressurizing the GB, the GB low negative pressure alarm switch has been wired to shut off the vacuum pump and to close the air supply solenoid valve when the GB negative pressure gets above 0.25 11 of water.

The operator is also cautioned that constant attendance is required quring op,eration.

This procedure also addresses nuclear safety a.ssociated with positioning the tanks, IX columns, and filter canisters.

The geometric configuration and location of these vessels is favorable to nuclear safety practices.

The inspector verified that changes made to operating and radio1ogical protection procedures since the last inspection appear to be consis-tent with regulations and license requirements.

Special Work Permits The inspector reviewed the licensee's special work permit (SWP) file and discussed the operational aspects of jobs performed in sonjunction "'ith SWP provisions.

The inspector revie~ed *swP No. 0042.

This SWP was specific to Procedure KM-NP-36-18, Revision 4, "Operation of GB 40 for Exchange System" discussed in Section 3(b), "Procedure Revising and Updating."

Under SWP No. 0042, a process 1ine is connected between an existing tank farm, which consists of 8 individual 5-inch diameter tanks, and the ion exchange operation in GB 40.

The tanks hold waste solutions schedu1ed for transfer to GB 40 for filtration, ion exchange, and volume reduction by solidification with cement.

The SWP requires use of respiratory protective devices.

4 28

6.

Tab 15 - NRC Inspection Report dtd 2/11/86 p9 skirts can be fitted around the skid frame to comp1ete the enclosure.

Exhaust ventilation includes filters and airflow measuring equipment.

Workers will be further protected by donning protective clothing, including respiratory protection if needed.

Construction of a loading dock (compacted dirt reinforced with a wall constructed of railroad ties). The height of the dock wi11 accommodate the height of a trailer bed for ease of loading containers of excavated radioactive material.

b.

Uranium P1ant

c.

The major activity noted was a contaminated soil removal project.

The licensee estimated that over 600 cubic feet of contaminated soil (over 30 pCi/gram) was removed, radiometrically surveyed, and put into barrels for waste disposa1.

The licensee has excavated the process piping and made radiometric measurements to identify soi1 contaminated by line Teaks.

To date, several thousand cubic feet of soil have been excavated and put in piles for closer survey and disposal.

The inspector observed this operation and noted that contaminated dirt is handled with a front end loader or scoop.

The dirt is placed on a conveyer and transported to a prepared container (55-gallon drum).

The inspector noted that a similar conveyor was constructed to transport the dirt through dual hoppers; this conveyor will only be used.d4ring.dry weather.

Small Quantities of Source Material According to 10 CFR 40.22 the licensee is authorized to receive fifteen (15) pounds of source material for operational purposes.

A 55-gallon drum of ore containing up to 15 pounds of thorium is being prepared as a standard for measuring thorium content of excavated thorium waste.

The inspector concurred that the licensee can legal1y receive up to 15 pounds of source material at any one time and.up to 150 pounds of source material in any one calendar year under a general license.

The inspector concluded that the licensee's decommissioning activities appear adequate to protect the health and safety of facility workers and members of the general public.

No violations or deviations were identified.

Nuclear Safety The inspector examined records of audits performed by the licensee in order to determine if any breach of procedures had occurred since the previous inspection.

9 29

Tab 16 - NRC Inspection Report dtd 2/11/86 pl 0 During a tour of the plutonium plant vault the inspector verified that the quantity of plutonium stored was less th.an the postedJ.imits.

The inspector reviewed the licensee's documentation of facility changes requiring criticality considerations, including determination of whether the licensee has the appropriate expertise to establish criticality-safety limits for facility operations, and determination of whether the licensee has positive management controls to assure that facil'ity operations are conducted within nuclear criticality safety limits. A process line connecting the ion exchange (IX) operations in Box 40 to an existing tank farm, consisting of 8 five-inch diameter tanks, was reviewed for criticality safety. The inspector concurred that both systems, the IX system and the 8-tank liquid storage array were previously reviewed for criticality control and that the connecting line was nuc1ear1y favorable by diameter (less than 2 inches) and acted only as a*conduit to transfer 1 i quid.

The inspector noted that month 1y safety audits were performed in compliance with license requirements.

Results of the December audit had not been received, and the inspector considered this an open item (70-1193/86001-0l(DRSS]).

No violations or deviations were identified.

7.

Maintenance Surveillance The inspector examined the licensee's maintenance operations to determine if records are maintafned on plant systems pertinent to safety.

Maintenance inspection and performance records were reviewed for the following safety oriented systems:

Load test - diesel generator Hoist and crane assembly - waste operations Standby fans - redundant blowers ventilation system Final filter - DOP annual test Stack monitor calibration The inspector noted that the annual emergency generator load test was completed in December 1985. and no major items of repair were needed.

No violations or deviations were identified.

8.

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

10 30

Tab 17 - NRC Inspection Report dtd 9/22/86 pl 0 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.

To date, airborne radioactivity detected during wall tank cutting was near background levels.

Decontamination 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 UF6 cylinder concrete storage pad was broken into small chunks for NOA 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 NOA 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 a11owed the natural contour of the hi11 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 d,i:1or,.;a,t to several 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 1 i censee noted that the background of the counting system in this arrangement is about 10 pCi/gram.

The 1icensee noted that a sma11 quantity of source material, as discussed in Inspection Report No.70-925/8600l(ORSS), had arrived and had been prepared as a standard for rneasur*i ng the thol"i um content in excavated.thorium waste.

Final preparations have been made *to drJdge the bottom of two sanitary 1agoons.

Lab analyses were being conducted by two different laboratories for uranium isotopic content of samples dredged from the two sanitary lagoons. _Confirmatory measurements,

• including samp 1 es for regulatory verification, are. being planned in the near future.

Samples are currently being ana*lyzed by a corporate laboratory and an outside vendor.

10 31

Tab 18-NRC Inspection Report dtd 9/22/86 pll 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 isotopk content and released to the sanitary lagoon.

No v fol afi6ns' of 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 fo 11 owing subjects were reviewed:

Pressure readings for ventilation f1ow in glovebox and slot box operations.

Fans and dampers for op<e**:;bi1ity.

Manua1 starting emergency generator.

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

11 32

Tab 19 -NRC Inspection Report dtd 9/22/86 p12 American Nuclear Insurers inspection of facility boiler operation.

No recommendations resulted.

Other activities performed by_the maintenanse 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 month1y 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 mon1~oring program with emphasis on the concentration of radfoactivity fo waste water re1eased to the sanitary lagoon.

Stack sample resu1ts 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 contro11ed 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 fina1 waste disposal.

12 33

Tab 20-NRC Inspection Report dtd 1/14/87 p6 Shipping papers were examined for about 35 shipments of radioactive waste material.

No problems were identified.

However, the disposal site licensee (US Ecology) did caution the licensee about the following minor infractions:

Use only one vent clip per drum.

Inadvertently, the licensee inserted two vent clips on one drum.

The closing ring bolt/nut assembly was not tightened to the fu11 measure of exposed bolt thread on one drum cover lid.

These minor infractions were not considered violations, but the licensee has improved the drum inspection program to prevent recurrence.

No deviations or violations were identified.

8.

Operations Review The Standby Operations Manager discussed the status of decommissioning activities at the Cimarron Facility. Ouring facility tours, the inspector observed that licensee performance was in accordance with statements, representations, and conditions contained in Appendix A of the.licensee's application.

a.

Environmental Activities Record rainfalls {58 inches by October, compared to 30 inches annually) have seve.re ly restricted the 1 i censee' s progress on decommissioning the sanitary lagoons and the thorium-uranium (Th/U) waste buriai site. The two sanitary lagoons are currently filled with rain water.

However, soil samples were obtained from lagoon dredging during the dry months.

These samp 1 e.s were split and submitted to US testing and the licensee's corporate laboratory for independent analyses. Weather permitting, along with timely confirmatory measurements, the licensee plans to close the lagoons by the 3rd quarter of 1987.

Meanwhile, four trenches have been excavated at the Th/U burial site in preparation for screening contaminated and non-contaminated soil.

The licensee noted that the Th/U waste will be uncovered by expanding each of the four trenches.

To date, neither excavation operations conducted at the Th/U burial site or the. sanitary lagoons have led to any detection of airborne radioactivity above background.

Furthermore, survey records disclosed that the workers change room located at the burial site, had removable contamination levels of less than 200 dpm/100 cm2 alpha.

No problems were noted.

6 34

Tab 21 -NRC Inspection Report dtd 1114/87 p7-8 Box-40-IX-system tanks and associated equipment.

Solidification box-glovebox:

should be only slightly contaminated.

Box 4; cut-up box.

Associated ventilation/duct lines.

There is also a potential major project at the Th/U disposal site concerning the handling of pyrophoric thorium metal.

If excavating operations uncover pyrophoric radioactive metal, the licensee will have to develop and implement special handling procedures.

No deviations or violations were identified.

c:c~,

9.

Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the onsite inspection on December 18, 1986.

The inspector summarized the scope and findings of the inspection.

In response to certain items discussed by the inspector, the licensee:

acknowledged the inspector's comments concerning the posting of the licensee's respiratory policy statement.

stated that continuing surveys are scheduled to identify radioactive contamination in personnel lockers and automobiles.

In addition to the above discussion, the licensee requested that timeliness of confirmatory measurement be determined by the NRC as soon as feasible.

The licensee is also concerned whether or not waste disposal options for low level radioactive waste will continue under present guidelines as discussed in Section 8, or will NRC change the requirements.

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

8 35

Tab 22 - NRC Inspection Report dtd 5/10/89 p2-3 Cfmarr1n C:lrporation... Joy Smi:.h, ?'resident wayne NorHood, Cimarron Faci1ity Manager Ronald Fine, Superv1sor, Hea1t:-i Physics and ;ndustrial Safety i(;\f Caroorata - 'Hil:iam Ganus, Carpente i-lydro1ogfst John St.:;.uter, Dfrector, Envi rornnenta; ?rograms Scott Munson, Sr., Staff Environmental Specialist Ed Sti11, Director, Environment and Health Management Division State of Oklahoma - Dale McHard Qepart.~ent of Healt:-i - ?aul Brown ORAU -

Jlm Jerger, Hea}th ?hys"cist 3nd C:-a.:.ty, Hyctro1ogist NRC*NMS5 - Lee qouse Davis Hurt Jer~~./ Swi *ft NRC-Regi0n III - George France, III iJona,d Sreniawski

,..;iose in attendance reoresenr. ::.:ie orincina1- ;J1anagers and/:Jr s-caff of t:-ie 1 ice.nsee :md :he './ari,1us cont,-actors and regu1-,r:::.:ir:1 agencies.

This inspection,)f onsi:e ac:ivit~e:s ;.,as ;:ier"0rmed in,::onjunction witn

,. :neetfog,,e 1 d oy :ne 1 \ censa<e t.;J d'i scuss the 0pt ~ ons ::i 1 'owea by NRC' s 3nnch Te,::.nic::,.} ?0s i:fon :iaper i;-i CJisoos'.ng 'JT C:Jntanrinatad soi 1.

-:,e me'"t1,m was :-ie'ct,Jn Aori* -1_ :_939_

-'lose in :1:t-:nciance inciuned h~nresern:-1::: *1es,if **me_ Sta-c?,1f }k 1-inoma. NRC,::::m:;>1ct.:ir JRAU. :,nd

-*~!:::H... esern:.1r/t1es :J-f :he ~:-fmar-on 1nct ;{i:::rr* ~cGt:e Gur,or*1-c::on.

":"'he f ns:wect ~an.::.Jrts *: s*:2a t.rf -i ;-"~V~-2:\rt ;Jf ::he 1 ~ 1:ans2:e

• 5 t:-1:nspor*~at:i on~

-'1uiat7*on 0ri.:rcec:.'iun, -ind ~nvi~onmeni:.::1 pr0gr~ms.

-:-:1e

~ nsnec:.Jr ;"ev-: ei."'ea ::.ne :rr"Jgr":ss the ; fc.:nsae hact 11aae 1 n corr~ct i :10

pen i-

ems 2:nu *Jr.;bs2r'1arA1ons identif*:ect dl!r:1

,'?:

~nsnect~onA

• :*,.is.:;11 Joen ~-::.em 'lo_ 70-:i:::::,-'370Ul-%(JRSS):

H,e :-.. o,muergr?una

3. 'JOO J -1Jn

., uage t.1nKs :iave 0e~n "'<:movea 3.nd :Jac:<:.igea f 1Jr bur*f a~.

36

Tab 22 - NRC Inspection Report dtd 5/10/89 p2-3 (Cicsed) Ooen Item Ne. 70-1193,/88001-0l(DRSS):

Two undergr'Jund 10 1 000 gafic:1 wast2 tanks were :"8moved and ;,ackaged for sn~pment tc a

]icensect disposa1 site.

The 1ev~l of radioactiv~ soil contamination

-:iet.ec:.ed,;1.f':e: e-xcavat~on ~-as net significant1y r:1if:er-ent :han

""aai oac

:.,, i -;_y -1ss0ci

• ,.f'i th backgr:Jund.

The insae,::tJ r re'/ i ewed the 1 i cens ee' s :nanagement organization and control~ for rad1ation orotection and operations, including changes in the,:,:rgani:.atfona1 structure.

a.

Jrgani :at ion

b.

C.

C:marron Ccrporat~on now emp1ays 39 persons in sec~r~ty, hearth and safety, and decommissioning operations.

At least 12 workers have retired, changed jobs or trans~arred to or.:her company operations since the previous inspect.ion.

These argani.rat.iona1 changes do not appear -.:a affect the radiological safety pr<Jgram.

No prob]ems '<tere noted.

he 1 ic?.nsee' s coma 1 i ance ;nsoec::fon o-f C~rnarron operatfons indicated that t:,e 1 i c2nsee :':riled to perform a periodic 1 eak test on a cesfom-:37 source.

Thf:; omission,,;as cor':"ected by performing a leak test.

The source was found to be not 1eaking, since the level of radioactjvfty dei::ected was significantly be]ow the manufacturers suggested 1imit of 0.005 uCi.

The inspector determined that correct1ve actions were taken and that an audit system exists for reporting deficiencies to management.

~WP No~ 0092 -

~~~par2 ;oom ~xhaust duct *.ror'< to remove.'isbestos

"" ber.

CJt up 24.< 211 ;-1E?A '::: 1-r.::rs that 'Her":: -..1sed for asbes~os T*fbe~ ::nt-.~01_

';'wP :'lo..JciJO - 3:a.nK,yf':' :=1 *,.,~r ::iank No. 10 cr0m o1cwer 1na :'":move iOSU ": :.it2 -=~ '. ::2:rs.

7 ;1e

~ :iswet.:::1Jr

..... ~*-1"' eW'e.d :he : i cansee: s ; ;ycer~a; anc 8::c:.cr~1c ~ 2xuosur1:

• 3ntr1 Jr~qrJms 1nc 1uding :~e ~~au:~ect r~cor1s. ~epcr~s. 1na

'h~"t--: ;:.. C3.T~ ~ ons.

37 I

Tab 23 - NRC Inspection Report dtd 5/10/89 p5 Environmentai Protection (IP 88045)

n ac:crdance *,1itn License Condition No. 11 (DJutonium Plant License No. SNM-1174) the l~cgnsae submit~ed an annual environmental report f:Jr ::388 sammarizing :he r~suJts of ;:u11,,eget.ation~ ana :.-.-ater-samp:es

-iat "nay :e -1ff~ct~d by dec.Jmm1ss:on':ng ac-:ivit:es.

The.;amoi~1g f:,--~aLenc*-, *-vas fnc:--2:-3,s~d ~r<Jm annua~ 1v to 01.1ar:a:--iv f:;r one 1f t:1e

""e~i*s *.is~d t.J m.oni:0r ~:1e -irea,1cr-:h-- of tne four burial pit.s.

Similar to orevious data reoorted ii, the 1985 through 1987 sampling years, the 1988 data for the same l es continues to show e 1 evatsd 1 eve 1 s

Jf gros:; a 1pha and,.ir1nfom concent,at ions.

The 1 icensee i noi cated that

., hydrg;ogfc-11 ~eview of ttie Cfmarron site is being performed 'Jy a

mtrac:::or.

Sixteen new we1 ls,1ere insta.1 led at aepths s;gnificant,y greater than the *1;1e 1 is presently samp; ea by the 1 icensee.

A"i ong ',ii th groum:i\ltater analyses through deep '"en sampling, the contractor is also shoring up s:te characteriza.:fon by developing a transport model of the groundwater and a meas,Jre of the ranae of ::1isso1*1ed solids.

Results of these efforts should be avai1ab1e in-July 1989.

No v~o1ations or dev'atfons.,era identified.

3.

sJoer1tions Rev4ew (IP a8020)

The Super*,~ sor, Hea 1th P!'lys: cs disc:issad t!:'le status af decommissioning ac-:-f~1lties.~t t:ie Cimar~on -;ite.

The major cleanup effort has been dfv~ded ':letween the plm:onium plant and the '3ita charactc:rization of son for final disoositfon under NRC' s 3r:inch P<JSitfon Paper BTP-i:Jisposal on Onsite Storag~ of Thorium or

Jrani um 'Hastes F:-om Pasr. Operations -

FR VOL 46 No. 205, October 23, l98l, Pages 52061-63.

Juring this ins.:iec::ion t,'1e 1 \censee held a *neet:ina with reoresem:atives

~rom the-State -:;f Gk1anoma. 'JR.O.U, :lMSS, and '<egfo;, ~Ir NRC t0 dis,::uss t:ie

)pt-:ons a' 1owed under 1:.-ie -move NRC 31?.

iMS.S i ncti cated t:1a"C t;1e 1 i cansae -snou ':d deve 1 no ja~.::. :a jus:. i Ty re 1 ocat i tJn of ::on'tam-i"na"t:dd e:xcava.-cect so:*;, devi::: l 0p -:l summa.r:1 of 5Ur'1ey data en ~ne

i~uton~um ::iu~'.,1ing, :'i narr2:t 1,,e,n,my,;;ie faci1::y is ::1e:in,,md a r-9:quest. i*Jr c:;nf*:*,..ma:.Jr:1 ;neaswr-emen-c5.

Af*~er c:>nsi11e!"'*ation.::nd rev,,;ew

-he *)CJOe '.3:nd. ;1nd~!1GS of ~:-:e ~nspE-:c:.--on Here ::i1si::.1ss.ed \v..,th the 5uoervi~or) ~ea7th ?~ysic~ d~ :~e ~Iase Jf the i~spec:i~n 0n Apri~ +/-

989.

The inspec::~r s~at~a t.1a-c ! ic2ns.ae Jrocr;.ms *-n tne 1Y-~as of

~xposur8- :,::Jn-t.-:*o'. 1

r-:-:.nspor":".J.t:*on 3.c*:~-ri::1es, je~::mm~s.-=.:,,oing ;J9era-c,f0ns.

ina -2nvi,..onmenta! ;Jr-Jtcc~ion :net r--~guiator:1 r-equ~r-emeflts.

-he TnsiJeC'~Jr 11 so 57~3t.cd :.:iar: -Hn ~: e ::1e. ii censee: s 1u it sys 7.2m -1...: a ::omp; i a nee

~nsnec~~Dns r!pO~~ea l ~ef~c~~ncy in :as ing ~euuir~mentE ~or!

.""1u~c,7:ctive source it **s ::-le t-:~::nonsibfl :_y or :Jcerar..fons :a ;)e:~orm

~.. ~me: y :::H:r:,Jai i: -:cs:. "'et1u i ~emen c.s.

38

Tab 24 - NRC Inspection Report dtd 9/18/02 p7 2001, Cimarron's response to the NRC Notice of Violation dated December 19, 2001, and any additional actions that the ALARA Committee deemed warrar;ted to assure that full compliance with iicense conditions are achieved at al! times. The minutes of this ALARA Committee meeting appeared to adequately address measures to prevent recurrence.

g.

Wioe Survevs Surveys (wipes) are conducted weekly at 15 locations for alpha contamination.

Building U, which has been released by NRC, is wiped at the driveway where trucks enter and exit the facility buifding. The men's and women's change rooms, offices, count and instrument rooms, soil count room, guard station and laundry room are included in the 15 Wipe locations.

2.3 Conclusions Radiation survey instruments were operable and within their calibration interval. No occupational exposure was received in 2001 or the first quarter of 2002. Radioactive sources were stored in a locked and properly labeled cabinet The ALARA Committee had met quarterly in 2001 and the first quarter of 2002, with one additional Special ALARA Committee meeting on June 26, 2002.

3 Transportation Activities (86740)

Radioactive Waste Management and Waste Generator Requirements (84850) 3.. 1 Inspection Scone 3-2 The inspectors interviewed the cognizant licensee representatives; toured the site; and reviewed applicable records related to radioactive waste management to determine if the licensee had established and maintained an effective program, and to determine whether transportatlon of licensed materials was in compliance with the applicable NRC and US Department of Transportation regulations.

Observations and Findings There were no temporary storageistaging areas for radioactive wastes from building demolition, equipment dismantlement, or soil excavation. The onsite waste disposal ceil was properly posted. The licensee had placed cairns on each comer of the disposal cell that indicate the cell's location. The onsite disposal cell was adequately protected by fencing around the entire site, onsit~. security, and a 4-foot ca;:J of sieapsoil.

There has been no oftsite nor onsite disposal of decommissioning wastes since the last inspection.

There were no radioactive waste shipments made since the last inspection. The last sr,ipment of radioactive waste was on October of 2000 involving one shipment of radioactive waste to an oftsite facility.

39

Tab 25 - Response to NRC RAJ p4 from the enriched ura1"lium fuels production facility which involved the following general process steps:

1)

Enriched UF6 gas was contacted with an ammonia solution to produce solid arrmonium diuranate (ADU),

2)

ADU was calcined to produce uranium oxide (003) powder,

3)

Uranium oxide powder was mechanically pressed into pellets, and

4)

The pellets were converted into ceramic grade uo2 in reduction furnaces.

~.n ancillary solvent extraction process was useq to recover uranium from dissolved processing scrap and nonspecification material.

Uranilllll pl$nt. prdce&,s l~guid* wast.es were.. passed thr;.ou§h :ag ion-exchange system to recover uranium and then discharged under permit

• to the Cimarron River.

This treated process effluent was released along with the overflow from the facility sanita.ry lagoons from 1965 to 1971.

Beginning in 1971 and continuing through 1975 the treated liq.:id effluent was routed to process waste evaporation ponds.

Sludges that accumulated in the process evaporation pends were excavated, solidified and shipped to an offsite commercial low-level disposal facility. This sludge disposal activity occurred in 1976 and 1977 after which the ponds were reclaimed, surveyed and released for unrestricted use.

Previous license submi ttals for both the U plant ( SNI-1-928) and Pu plant (SNM-1174) contain detailed information relating to the facility process operations and waste handling techniques.

Please refer to those docuuents for additional information.

Solid wastes generated from the uranium facility activities were buried onsite at a designated burial ground from 1966 to 1970.

After 1970, all solid wastes were shiooed to an offsite commercial low-level radioactive disposal site.

Th;* onsite waste burial ground is currently being excavated and its entire contents shipped offsite.

P-.lthough not processed at the Cima._..-ron Facility, some thorium-bearins materials were 9laced in the site burial ground from decomuissioning of the Cushing nuclear facilities in 1966.

As noted above, this burial area material, including the thorium, is being packaged and shipped to an off.site commercial low-level radioactive disposal facility.

There was nc onsite disposal of plutonium wastes.

3.

N"RC Request:

Are there any radioactive materials buried onsite from past operations?

If so, provide the records on the volUir.es, locations, and average radioactivity concentrations.

(June 1988/Rev. 1) 40

Tab 26 -NRC ltr dtd 12/7188 w/ ORAU Report pl-2 Docket No.70-925 Ci111arron Corporation UNITED STATES f\'

'LEAR REGULATORY COMMISSION W.A911NGTON, 0. C. 206ISl5 OEC 01 1911 ATTN:

Dr. J.C. Stauter, Director Nuclear Licensing and Regu1ation P. O. Box 25861 Kerr-McGee Center Oklahoma City, OK 73125 Gentlemen:

In August 1988 our contractor, Oak Ridge Associated Universities (ORAU),

collected soil and water saqiles from 19 boreholes in potentially contaminated areas around the Cimarron facility. A copy of their findings is enclosed for your infonnation. Although samples were taken at only a limited number of locations, there appears to be little evidence of subsurface radioactive contamination. The ORAU water samples showed some uranium contamination of ground water immediately north of the old burial trench area.

We are uncertain how to reconcile these findings with the large estimates of contaminated soil volumes in your June 29, 1988 request for license amendment.

After you have had time to review the enclosed report, perhaps we should meet to discuss your sampling and analytical methods, and to attempt to resolve these discrepancies.

Enclosure:

ORAU Survey Report sincerely,

~-L Leland C. Rouse, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS cc:

Dale McHard, Oklahoma State Department of Hea>lth 41

Tab 26 -NRC ltr dtd 12/7188 wl ORAU Report pl-2 Oak Ridge Associated Post Offir"' Box 11 7 Universities Oak Rid;.~. Tennessee 37831-0117 Nov**b*r 11, 1988 Dr. Ed Shu Division of Juel Cycl* and Katcrials Safety Nuclear Regulatory co-isaion NKSS-396 Washington, DC 20555

Subject:

RADIOLOGICAL DATA - SEQUOYAH FUELS FACILITY BOREHOLES

Dear Mr. Sh1111:

Enclbsed are the analytical results for soil and water samples collected in August 1988 from 19 boreholes at Sequoyah Fuels in Crescent, Oklahoma.

All soil samples were analyzed by gamma spectrometry; composites fro* borehole groupings were also analyzed for plutonium.

Samples of water were analy:z:ed for gross alpha and gross beta, and those exceeding 15 pCi/1, gross alpha, or 50 pCi/1, gross beta, were also analy:z:ed for plutonium anq isotopic uranium.

As you can see from this data, we found little evidence of subsurface uranium, thorium, or plutonium contamination in the soil at any of the sampled locations.

Elevated concentrations of gross alpha and gross beta contamination were, however, noted in the water samples from most of the boreholes, where water could be obtained.

Of particular note are the concentrations in boreholes 5, 6, 7, and 8, which are all down-gradient from the former burial areas.

Further analyses indicated, that the contaminant in the water samples is slightly enriched uranium.

Contact me at F'l'S 626-3305 or Scott wical at FTS 626-5073, if there are any questions about this information.

Sincerely, ftf:-~er Radiological Site Assessment Program JDB:jle cc:

S. ~ical, OR.AU 1/4': Rouse, NR.C/NMSS G. France, NR.C/Region III D. Tiktinsky, NRC/NMSS 42

Tab 27 _ NRC Report review dtd 2/23/90 p2 ENCLOSURE Groundwater Impact Analysi~

The Grant report has provided an incomplete groundwater imoact analysis. only one point on the groundwater pathline was analyzed, however one could argue that the shallow aquifer anywhere onsite could be used as a source of drinking or irrigation water at some future time.

Section 4.3 of the Grant report states that the principal source of groundwater in the area of the Cimarron facility is the Garber/Wellington formation and that the Cimarron River and Cimarron River alluvium are too salty for use as drinking water.

From the groundwater chemical analysis results given in table 3.4 and 4.2 of the Grant report it appears that the upper aquifer of the Garber Formation, identified as sandstone A in the Grant report, may have the best water quality of any of the other aquifers of the Garber formation.

If this is the case the peak concentration of urani~ through time in a well tapping the shallow aquifer groundwater directly adjacent

• to and down gradient from the option 2 burial area should determined.

Also if groundwater containing leachate from the option 2 burial area would flow through the shallow groundwater and into any site surface

water, then the peak uraniwn concentration through time in that water should be determined. If it is unlikely that the shallow groundwater or surface water impacted from the option 2 burial will be used then a demonstration of that needs to be given.

Areas of Known Groundwater contamination repo.rt.i r contalllina Form4!r Waste rsurtal~rea Each of these areas was only briefly described in the Grant report.

Because these areas may have to be subjected to a groundwater impact analysis before the site can be decommissioned they should be fully characterized.

The characterization of t.~.ese areas should include determining if any residual soil contamination above the water table still exists.

Next, the contaminant plume at each of these areas should be defined in terms of concentration and distribution of contamination. Statements 111ade in the Grant report about a change in aquifer geochemistry down gradient from some of these areas should be validated.

Finally, impacts for water use pathways should be c.onsidered including contaminated groundwater discharge to site surface water.

43

Tab 28 -NRC ltr dtd 3/13/90 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 Docket No.70-925 Cimarron Corporation ATTN:

J.C. Stauter, Director Environmental Affairs P.O. Box 25861 Kerr-McGee Center Oklahoma City, OK 73125

Dear Dr. Stauter:

RECEIVED MAR 19 1990 ENVIRONMENTAL AFFAIRS Enclosed for your information is our review of the information contained in your submittal of February 1, 1990, concerning the gamma-spectrometry system you are using to determine the extent of uranium contamination in soil on the Cimarron site. The data in the February l submittal show that the gamma-spectrometry system.is suitable for purposes of surveying the site, although we recommend that you take steps to improve the system's performance in the 30-50 pCi/g concentration range.

Our discussions of March 1, 1990, on the occasion of your visit to our office to discuss the Site Investigation Report, indicated that such improvements may already have been made.

You also told us that you wi11 submit a new estimate of the total volume of soi1 on the site contaminated to the Branch Technical Position Option Two level or above.

The description in your submittals of procedures for excavating and sorting the contaminated soil also needs to be revised. The description in the October 1989 submittal was based on the assumption that the borehole gamma-logging method would provide a meaningful measure of uranium contamination. That assumption was apparently invalid, and we understand that you will not be using the borehole gamma-logging method for future surveying or soil sorting work.

Plegs:e,pro.v,,i de us an 11pdated description of y()ur.ex.t;c1vatiom~.,so'i 1 samp1in~~ and soi 1 sorting proce,dr;1rJ?~.f'

Enclosure:

NRC Staff Review of Revised Cimarron Survey Program cc:

Dale McHard Oklahoma State Department of Health James Berger Oak Ridge Associated Universities 44

Tab 29 - NRC Ltr dtd 9/14/90 pl 11/07 '96 09:44 FAX:405-270-3504 PAGE 4

UNIUP S:iATES NUCLEAR REGULATORY COMMISSION REGION HI 1** RQO$£VI.\.. T ROAD G\.ltN ltl.L.VN, 11.1.INOIS 501>7 SEP 1, 1990 RECEIVED SEP 1 7 1990 ENVIRONMENTAL AFFAIRS Docket No.70-925 Docket No. 70-i193 Kerr-McGee Corporation ATTN:

~r. John C. Stauter, Vice President Environmental Services Post Office Box 25861 Oklahoma City, OK 73125 Gentlemen:

This.re.fers to your 1etter datedAu~us.1... ?.?t.l.~90, informing Re lllof_your totirn~ton'to di ~continue fi1 fog rt~;t:fon th.~ reJea~~iof:,r

.. *1~r *~

ma tE:~1a1 {St,tM). rn.... ~ff1.u.en;ts... t.0:... urn:,;estncted a;rea s~ for,the, ci i ty plutonium and urariifiltm~plarrts.

Si nee the reports are required for erfsees authorized possession and use of SNM for processing and fuel fanrication and your 1 icense authorizes possession or use of SNM subsequent to decontamination and deco!l1llissioning only. ;we~,.h.av.e..... ~oooj~ct~n;,tRi,10J:1r tlfacorJ.tinuat'lon ot tbe

~ffluent release r.eJ.l~f~~*/ "*

We will continue to perform routine inspections at the Cimarron Facility to review your records of surveys which monitor for release of SNM resulting from decontamination and decommissioning efforts. lf you have any questions, please contact Don Sreniawski of my staff at (708/790-5611).

cc w/ltr dtd 08/22/90; George B. Rice, S~nior Vice President, Engineering and Environmental Systems, Kerr-McGee Chemica1 Corp.

D<;D/DCB (RIDS) 45 Sincerely, Charles E. Norelius. Director Division of Radiation Safety and Safeguards

Tab 30-NRC Commission Policy Issue dtd 12/9/91 pl December 9, 1991 From: -

Purpose:

• ~umary:

Contact:

J. Swift, NMSS X20609 TEL:301-415-5398 Jun 11'96 1s:02 No.oos P.02 POLICY fSSUE (Notation Vote)

The Corrmissioners James M. Taylor Executive Director for Operations SECY-91-398 LICENSE TERMINATIONS FOR CIMARRON CORPORATION FACILITIES.

CRESCENT, OKLAHOMA To obtain Conmission appl"Oval of the actions and the approach t:ha.t the staff plans tc take to tenninate the licEnses at the Cimarron site, and of omission of a license reopener clause.

As part of the process for deco11J11issioning the Cimarron site. staff proposes to terminate the license for the former mixed oxide fue1 faci1it.Y. and as a step toward temination of the uranium fuel facility 1icenset authorize an onsite burial of soil contaminated with small concentrations of enriched uraniu~. This paper notifies the Co11111iss1oners of these proposed actions ar.d requests Comission approval of the sequence of actions the staff proposes for termination of the licenses at the Cimarron site, in accordance with item 3 of the staff requirements memorandum (SRM) of January 31, 1990.

This paper also addresses the issue of conditioning license terminations to peraiit the Nuc1ear Regulatory Connission {HRC} to reins.tate licenses if NRC promulgates residUa1 radioactivity standards thilt i.n~kat,e, a need for additional decontamination; s Itri seJicl:il*not 1 ** ose

'eo,k'--~

NOTE:

SENSITIVE INFORMATION - LIMITED TO NRC UNLESS TEE C<>>-~1ISSION DETERMINES O'l'HERW!SE 46

Tab 31 -NRC Commission Policy Issue dtd 12/9/91 p4 NRC/NMSS/DWM The Connissioners TEL:301-415-5398 Jun 11'96 15:03 No.008 P.05 4

license to facilitate c1eanup of uranium contamination in conjunction with the uranium license tel'lllination.

Any areas previous1y re1eased wi11 be checked for possible cross contamination. The mixed oxide facility 1fcense 11ight be terminated as early as February 1992.

i!n ~9~~<<i

. a 1 s,~ began deeo~~s:ifill'i~9

• its 1.1perat~*o itim lfcense.

• The t

the site contalllinat ionall;y/gr8 cf the sit&

niL to be cont Further characterization work has recently ound what is apparent1y another 10 CFR 20.304 buria1, the ~nown burial having been exhumed earlier and wastes shipped for disposaJ *.... Ibe.... Mt had pr9.v t~ed, 9.ufde lei nes f.Qr decontami;ria'tYfoit ?or the uranium fad i ity ~9'di.~!lr;cctcQ!l!J~g~ c.91'9!.ll'ldS;. in.... thJ.foqi:i of T;ncl9$ure 2 of Po Hoy ~

~flfii*

• 83-23 and the 'l.

• Technica 1 Poift ;yn

,Sf llraniu:n and.

wa,te"S" (BTP)

• f.f6 l,13 tl:!.e scite is being ciiane.d

tif:

Option 1 guidance provides soi1 conuminat1on levels judged sufficiently sma11 for release for unrestricted use.

Option 2, also for release for unrestricted use. provides for burial (under prescribed conditions and under at least 4 feet of c1ean cover) of higher? but limited, concentrations of contaminated soil. See Enciosure l for further details.

Ci1;1arron Corporation has requested a 10 CFR 20.302 onsite buria1, discussed below, of contaminated soil under Option 2 of the BTP. because of the lar~e quantities of contaminated soil found at the site. The staff has prepared a draft EA

{

Enclosure:

2) based on this request. The licensee is continuing its characterization and decontamination. and plans to submit survey results and a license termination request upon COlll?letion.

The uranium process building 1s undergoing a decontamination process similar to that used on the mixed oxide building.

In addition to determining the extent of contamination under the uranium µrecess building. the 1icensee !IIUSt also address the site's pr1wious waste:-water treatment lagoons before the entire site will be ready for release for unrestricted use.

The stilff has been coordinating with the OklahOlllil State Departlnent of Health with regard to sOfl'.e chemical c<>ntamination on the site (primarily nitrates. especially at fon=er waste-water treatlnent lagoons} and groundwater contamination.

When a11 fssues have been addressed. the staff wi11 confinr.

the adequacy of the decontmination of the buildings and 47

Tab 32 -NRC Commission Policy Issue dtd 12/9/91 p9 NRCINMSSIDWM The Colllilissfoners Recoa.ienct,1t1on:

TEL:301-415-5398 Jun 11 '96 15:06 No.008 P.10 9

standards would lead to a significant1y different result.

OGC emphasizes that such a reopener clause should be.coniidered, not necessarily required in a11 such cases. l:iiir "ff' app Tication of: lle!.. ~B,~... standiirds might 1ad..

fi.'F8nt)y differen:f.:ri!i~:J~;-;iyh, l'.l~d.

for prOl!lpt cTea.l'.)1,1g,. -1.partkular case maJ'd:>i.£:5telgh the benefits of fnsistfog on a reopener clause in the face of objection.

The staff requests Connission approva1 of the plan and sequence of actions *the staff proposes to follow to term-inate the licenses at the Cimrron site. in particular, the pend1ng termination of the mixed oxtde facility license and 10 CFR 20.302 soil disposal.

With regard to the reopener clause, the OGC recoll'lllendation is given in the CCllli"di.natioc paragraph above.

The staff, however, requests Co11111iss10n approval of proceeding with ltcense terminations on the basis of exfsting guidance and regulations, without a license reopener clause.

or ns

Enclosures:

- Commissioners. SECY, OGC on1y.

1. Decontamination and Disposal Guidance Applied at the Cimarron Site

2.

Environmenta 1 Assessment of a Proposed Disposal of Uranium-,Contaminated Soil at the Cimarron Uranium Plant

3. Proposed Notice Regarding License Terminations 48

Tab 33 - NRC Commission Policy Issue dtd 715/92 p 3 The Corrrnissioners 3

screening level for enriched uranium contaminated soi1s has yet been developed by EPA.

However, the reported levels are generally iess than the screening level for plutonium with a few exceeding by a factor of 2 to 3. Kerr-McGee's plan calls fer discing unlined ponds, bul ]dozing berms over the bottoms to level all the ponds to the surrounding topography.

This*

will blend the levels of higher activity with the much more abundant low activity soil, further reducing or eliminating the spots that exceed the screening level.

In conclusion, the method outlined by Kerr-McGee appears to be appropriate to return the pond areas to a condition suitable for safe unrestricted use.*

The closure process authorized by License Amendment Ho. 2 involved folding sheet liners up in the pond-center and burying them with fill. Unlined pends were to be tilled to blend the contaminated layer into deeper soil, and then the pond berms leveled and the ponds filled to match the surround\ng ground surface. The finished surfaces were revegetated.

Al'~ough Uranium Waste Ponds 1 and 2, in particular. may have concentrations of uranium contamlnatto~ which exceed current guidelines for release for unrestricted use, the ponds appear to have been closed ln accordance with all procedures and requirements in effect in 1978.

Even though the license itself was not terminated in 1978, it would conform to the principles of the policy on finality expressed in the Action Plan enclosed with SECY-92-106 to not reopen this issue.

On the other hand, the staff has an opportunity now to review the case, before the license is terminated.

Of particular interest is the issue of whether the former ponds in their present condition are contributing to groundwater contamination, radiological or chemical (e.g., nitrates).

Therefore, staff is including the former ponds In its evaluation of the decomdss1oning to be performed on the remainder of the site before termination of the uranium facility license, No. SNH-928.

The:-'" staff ha S a1:s o,-con, t:41,'fo,r,,}.he:sro;~nd

~alt.er impacts of th"ff Q"*S

~~ ~~riau>:-:sescr,ibed "tin SECY-91-398 to o~er!ap~

il!iP~~t sflb f~*lthe*'l former ponds.

Although the propci'se

.J02 6uria1 she is not much more than 100 feet horizontally from the former Uranium Waste Pond No. 2, it Is both uphill and up the ground water gradient.

As mentioned in SECY-91-398 (and documented in the 10 CFR 20.302 Environmental Assessment), based.on measurement~

by the 1 icensee, staff performed an evaluation of uranium migration from the burial via pret1pitation infi1tration and 49

S£CRETAFfY Tab 34 -NRC Commission Memo dtd 10/30/92 pl

• • tct':J J.O ::,o UNflt;U:>'rAT!.11 NUCLCAn m:cuLATORV COMMl~i!ON W.o.£:1 llNCTON, 0.C. lOiii MEMORANDUM FOR:

James M. Taylor Executive Director for!,

ations FROM:

Samuel J. Chilk, Secre 1

SECY-~1-3~8 U.:=EN~%

INATIOU'G !'OR CIMARRON CORPORATION FA I ITIES, CRESCENT, OKLAHOMA The Co!!lmission {with all commis$ioners agreeing) has a:pproved.the staff plan (in that thQ rgaommgnagd action~ ara consistent with t.11.e commission-approved policy as set for-...h in the site Decommissioning Action Plan dated April 6, 1992) and sequence of actions to follow to ter.11inate the licenses at the Cimarron site including the pending te-""!llination of the mixed oxide facility license and 10 cm 20.302 soil disposal.

In this regard, the staff should:

1.

Ensure that all technical requirements are satisfied.

2.

Determine that all site-specific standards to be applied are ALAR.A, consistent with the Action Plan.

3.

Treat in t.~e swne manner and apply the same criteria to buried contamination in the area of the former waste ponds as will be applied to....:was.te..materials in other locations on the site.

This would mean that additional cleanup of this contamination 111ay be necessary or that the staff may have to impose greater restrictions, depending on the levels of contamination found in the area of the former waste ponds, such as those contemplated under Option 3 of the Branch Technical F0siti0n, 0n any future use 0f t.ha ~~r.ility.

(EDO)

(SECY Suspense:

12/21/92)

'.li'.~e'e-1'-tt;ssion (W,ith au Co:m:tissiohet-s ~gr~e:i::l'lg~ Iias,'approved prgceeding wit.l:a t~e *lic.ense.ta..a'"':llillatiqns w.ithout a.licens.e,",

re.opener cla!;ls.e:,

SECY NOTE:

THIS SRM AND SECY-91-398 CONTAIN SENSITIVE INFORMATION AND WILL BE LIMIT-ED TO TEE--NRC UNU:SS THE COMMISSION DETERMINES OT?.ERWISE 50

Tab 35 - NRC ltr dtd 5131/95 pl UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555,-0001 31, 1995

Dear Mr. Larson:

On April 24 and 25, 1995, representatives from the Oak Ridge Institute for Science and Education (ORI SE), u6der contract to the U.S. Nuclear Regulatory Commission, performed a confirmatory survey of the south yard area on the Cimarron site. The interim report from ORISE, dated May 18, 1995, raised two issues that should be resolved before NRC approves the backfill of the south yard.

First, the ORISE borehole sample from location #1 (see Enclosure 1), at the 0-15 cm depth, indicated a total uranium concentration of 38.4 pCi/g.

Since 38.4 pCi/g exceeds the enriched uranium limit of 30 pCi/g, additional samples should be collected to determine compliance with the hot-spot limit using the procedure that was ap.p lied in the _November 1994 "Report on the South Yard Remediation at the Cimarron Facility," (South Yard Report).

NRC believes that it would be more efficient for Kerr-McGee to collect and analyze the additional samples as opposed to sending GRISE back to the Cimarron site to perform the work.

The results of the additional samples should be submitted to NRC.

Second, during the confirmatory survey, GRISE collected six samples from the vicinity of the Cimarron site to assess background uranium concentrations.

The GRISE results for background concentrations of total uranium range from 0.80 to 1.86 pCi/g. These values differ from the background concentration of 6 pCi/g total uranium reported in the South Yard Report (page 4).

Please provide an explanation for this apparent discrepancy.

If you have any ~uestions, please contact David N. Fauver on 301-415-6625.

Docket No.70-925 cc: Attac~ed Mailing List

Enclosure:

• • • As st a tee;

'T' 51 Sincerely,

~

~cU ~~

lfh'V Michael F. Weber, Chief Low-Level Was::'-: and Decommissioning Projects Bra1..-h Divi**~0n of ~aste Management Office of Nuclear Material Safety and Sa feguar?s

Tab 36 - NRC Inspection Report dtd 3/29/96 p7 schedu1ing, and personnel) and provided little substance relating to the decommissioning licensed activities. Discussions with licensee management revealed that they thought the Yankee Atomic assessment would completely assess decommissioning activities, but it did not.

The inspector determined that the Yankee Atomic assessment was not a useful management tool for evaluating the quality of the decommissioning program.

Cimarron Quality Assurance Procedure KM-CI-QA-2.1, Revision 1, "QA Program Assessment," required each site project manager to prepare a summary assessment on the adequacy and effectiveness of the Quality Assurance Program as it applied to each department.

Procedure KM-CI-QA-2.1 stated that the

• quality assurance manager was to develop a Management Assessment Report for each project manager.

The inspector reviewed the assessments that were conducted for 1995 and found the following:

0 The radiation safety department had not completed its assessment for 1995.

The assessments as submitted were not detailed or thorough in that none of the project managers described whether or not the Quality Assurance Program was working for their decommissioning activities.

Procedure KM-CI-QA-2.1 did not provide detailed instructions on what the project manager was to include in the assessments.

Discussions with the quality assurance manager revealed that neither he nor the Cimarron site management provided clear expectations regarding the implementation of the Quality Assessment Program assessment.

The inspector determined that the assessments for 1995 were not useful management tools for identifying quality assurance concerns.

2.4.3 Conclusions The inspector concluded that the licensee's Quality Assurance Program in the areas of audits and assessments was an area for potential improvement.

However, the inspector noted that the licensee was providing extensive NQA-1 training to appropriate personnel in order to enhance the Quality Assurance Program.

3 RADIOACTIVE WASTE MANAGEMENT AND ENVIRONMENTAL MONITORING (88035 AND 88045) 3.1 Site Tour The inspector conducted a site tour of Phase I, 11, and III areas.

Licensee personpel identified areas that )'ler:e 1,1pderg9jngrerni,9,iation.activities.< Some v.ll;,t\e.s... being copd~cti;;f.l f11cl,~d~d ~!J,:1i,1 i~t~lIY-\1JaYs'i;.disrn1iJ;ltlioo.the

• ld'.1nsL genera*1 site 6)eanu~; and]r,:.em~cj.;j;~ti;bb.:o*-1':Purt~l}grO:u~a*

During the tour inside the licensee's Restricted Area, the radiation officer (RSO) identified several piles of trash and rubble that had 52

Tab 37-Federal register Docket dtd 4/11/96 pl-2 C,4/l.8 '96 11:43 ID:KE,~-MCGEE FAX:4052703787 Search of the Federal Registcrto Find i Document...

In FR V(ll. 6!, 1996 Published on 04/11/96 AND With Reference in the Text to 'CIMARRON' AND Selected from preview list

. 04/! 1/96 fL-S document 554879, 61 FR 16127, 207 lines]

fDockct No. 70-0925]

. nJ~i t\ssessipent1 Fi riding of No SignificantJ:n1pact,and.No~~~ of for a H

• • *,i\leleaseo!'Pai1s of Cimarron Sitr.: for Uht*cstricfod

!)sti;GJinarron Co/:p<'ir' The U.S. Nuclear Regulatory Commission is considering thr.: release for unre$U-icted use of approximately 695 acres of the 840 acre Cimarron site cummtly under NRC License SNM-928. There is O(l history oflictinsed activities within this 695 acre area. The licensee has performed systematic measurements in the area to confirm that the concentration oflicensed material in the soil is below NRC's guidelines for unrestricted use.

Introduction The Cimarron Corporation, a subsidiary of Kerr-McGee Corporation, operated two plants, near Crescent, Oklahoma, for the manufacture of enriched uranium and mixed oxide reactor fuels. Fuel manufacturing operations ceased in 1975, at which time decommissioning activities were initiated. The ultimate goal of the decommissioning effort is to release thi;: entire 840 acre site for unrestricted use. To facilitate remediating and releasing the site., the licensee has divided the 840 acre Cimarron site into three areas, designated as Phase I, Phase TI, and Phase Ill areas.

Aller any necessary remediation is complete in each of these three areas, the licensee will perform final status surveys in the area. Assuming that the surveys demonstrate that any residual contamination moots NRC guidelines. the licensee intends to request NRC to release the area for unrestricted use, and remove the area from the license. The release of the 695 acre Phase 1 area for unrestricted use is the proposed licensing action addressed in this environmental assessment.

53 PAGE

.J.

Tab 37-Federal register Docket dtd 4/11/96 pl-2 QJ/i.8 '96 11 : 44 iD:KERR-MCGEE FRX:4052703787 Proposed Action The proposed action is the release for unrestricted use, and the removal from License SNM-928, of approximately 695 acres of land. This area has been designated by the license as the "Phase I" area. The boundaries of the Phase I area are defined in Drawing No. 95MOST--RF3 in the licensee's November B, 1995, letter to 1'.TRC.

The Need for Proposed Action The licensee seeks to release property that is currently under license for unrestlfot.cd use, This action is requested in order to remove the current

!imitations on the future u~e oflhc property.

Alternatives to Proposed Action The only alternative to the proposed ac..1ion is to not release the Phase I area for unrestricted use and keep the area under license. Maintaining an NRC license for the Phase [ area would provide negligible, if any, environmental benefit, but would significantly reduce options for future use of the property.

Environmental Justice There are no environmental justice issues associated with this proposed action.

Environmental Impacts of Prnposed Action Based upon a review of the Cimarron site history, the lken~~':: c.!:'/UCl\,lged that the Phase I ~~a

.. "".~~p~~L!~~fmJicense4 actiyittes. 1P !!tifi~ifl:;t4te **

hi storieal site*.assessmenr1conclusions, the licensee references the results

()f_ its.1971-? SCQJ)t!lf~ry'ey ot1fiij*Ctt&Sron*site: This scoping SUf\/~)' fitcllidcd.

exposure fate;mel!s1Jren1ent,<isysfilm'.atil;irllymade qvet the site. Tne exposure rates measured within the Phase T area ~,ere within the range of natural

-bafKgf{:l]Jjn(i,Jl'.l<addition, in I 99Q,. tn~ iicililsee tibnducteo. a iuil sampling program in tho areas surrounding the uranium building tn further define the extent of contamination on the site. No areas identified as contaminated during the 1990 survey are included in the Phase I area. The results ofhoth the l CJ79 and 1990 charactcri7.ation surveys are included in the licensee's "Radiolof_,>1cal Characterization Report for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma," October 1994 (Cimarron Charactruization Report),

Based on the historical site assessment and characterization results, the licensee classified the Phase I area as unaffected. An unaffected area, as defined in NUREGiCR-5849, "Manual for Conducting Radiological Surveys in 54 D"'_,.._.,..

, hbt:

2

Tab 37-Federal register Docket dtd 4/11/96 pl-2 FAX:4052703787 Support ofLicense Termination," is an area not expected to contain residual radioactivity from licensed operations.l{!~heJicense submitted.the Final Surv.:y Plan for Urliiflecr~d.~rea~,'!.in~t~r-1,994 (Final sur~ey Plan).

Following theguidartce fo NtlREGiCR~5849,Ih~r)JJal. s;uryeyPl!:U!_Pro\<'ide<i the methods to be.ll¥t!d*l0 conduct the firlal iurvey and provide uocuriientation that the Phase l ar,eirneets N1lC unrestricted use criteria p.rtcf the licensee respnnde11' satisfactorily to NRC comments on th;*Final Survey Plan, the plan "VaS.aj!Jproveli on May.T, l<J.95 The licensee completed the final surley of the Phase I area, in accordance

':'-'Jt.~,the approved pla.i;;.;iw,d;5~rriitted1:here_sults to NRC in the "Final Status Stiivt:y Report, Phase*i:/4'reas at the Cimarron Facility... July 1995 (final Survey Report).,\~~r l~t!licensee acceptitqiyr~sp<1nded to NRC's September 5, 1995, comments, thii Final Survey Report was deemed acceptable by NRC to demonstrate that the Phase I areas meet NRC's guidelines for unrestricted use. A confirmatory survey was performed by an NRC contractor, the Oak Ridge Institute for Science and Education (ORISE), during the period October 17 through 19, 1995. ORISE conducted independent, random, measurements in the Phase 1 area The ORlSE results were consistent with the licensee's results and support the conclusion that the Phase 1 area meets NRC guidelines.

The unrestricted use guidelines for enriched uranium and thorium for the Cimarron Phase I area were the Option 1 guidelines in the 1981 Branch Technical Position on "Disposal or Onsite Storage ofThorium or Uranium Waste~ From Past Operations" (46 FR 52061) (1981 BTP). The Option I guidelines are 30 pCi/g for enriched uranium and 10 pCi/g for thorium. In the April 1992 "SDMP Action Plan" (57 FR l'.l38CJ), the Commission instructed the staff to use the 1981 BTP guidelines, and ALARA, as the unrestricted release criteria for decommissioning pending the final rule on radiological criteria for decommissioning. Although thorium was never processed at the Cimarron site, thorium concentrations in soil were also evaluated during final survey.

The average enriched uranium activity measured in soil samples collected during the final survey 11f the Cimarron Phase J area, as reported in the Pinal Survey Report, was 4.9 pCi/g. After subtracting the Cimarron enriched uranium background value of 4.0 pCi/g, the net average total uranium activity measured was 0. 9 pCi/g. Note that the 4.0 pCi/g background value includes a correction factor to estimate total uranium assuming 2,7 percent enrichment, by weight, ofU-235, The licensee uses the cvrrected background since all of the sample results also contain the correction factor. The licensee estimates lhat the natural uranium background at the Cimarron site, not including the c<mection factor, is 1,8 pCi/g. Less than L3 percent of the indiv1dual sample results were statistically greater than background. The maximum individual net concentration of enriched uranium identified in the final survey samples was 8,4 pCi/g. The area containing this sample was separated from the Phase I area and will be further evaluated during the Phase 11 final status survey. Although it is unlikely that the 0.9 pCi/g net concentration represents a statistically significant concentration above background, the staff conservatively assumed that the 0. 9 pCi/g did repre.~ent a concentration 55 PAGE 3

Tab38-NRC Letter dtd 4117/96 pl UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-000'1 Mr. Jess Larsen, Vice President Cimarron Corporation P.O. Box 25861 Oklahoma City, OK 73125 Deir Mr. Larsen:

,April 1 1996 The NRC staff has reviewed your submittal of March 6, 1996, which presents the most recent groundwater monitoring data from the Cimarron facility.

The data indicates that there are areas of groundwater contaminaterl above the EPA drinking water limits for gross alpha, the EPA drinking water screening limit for gross beta, and the proposed EPA drinking water limit for uranium.

The NRC's "Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites* (57 FR 13389, April 16, 1992} lists the EPA's drinking water criteria as reference standards for protection of groundwater resources.

The staff is concerned that the levels indicated by this data may preclude the unrestricted release of the Cimarron property.

In addition, the data also indicates that there are areas of groundwater contaminated above the EPA drinking water limits for fluoride and nitr,ates. This will most likely be of concern to the State of Oklahoma.

• Wittare ** a 1 so coricElnn*erl?ttha;t ;grounqwa;ter remedi*at(-0.n. *fl as. not been,*a,dl1jressed. i n the. "Decollll)d0$:SC'iJming Pl an for Rim.[1:r;ro~ ~o..rpJ?,fa;tjo.9!,s: ~o~}':.J;L14t:le.[ir FueJ F.~b.rJ.sit4it*~n,.Facility (in) Crescent, Okl a:noma, "'dated ~pril 1995. The staff

• believes that the absense of this information may delay the ultimate release

~f the property, and that an addendum to the decommissioning plan should be submitted to address groundwater contamination.

Please contact me at (301) 415-6664 if you have any questions about this matter.

Docket No.70-925 License No. SNM-928 cc:

Cimarron distribution list 56 Sincsrely,

/

/~/'/.:'?' :-'.. _/,c-;;j;.-,1<'-

Kenneth L. Kalman, Project Manager Low-level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards

Tab 39-NRC Ltr dtd 4/17/96 pl UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Jess Larsen, Vice President Cimarron Corporation P.O. Box 25861 Oklahoma City, OK 73125

Dear Mr. Larsen:

April 17, 1996 In a te1ephone conversation with Joe Kegin on March 28, 1996, Mr. Kegin requested a written explanation of why the expiration date of the Cimarron Corporation license (SNM-928) was not extended. The expiration date of this license was June 30, 1995.

The app1icab1e rule for expiration and termination of licenses and decommissioning of site and separate buildings or outdoor areas is in 10 CFR 70.38.

As noted in 10 CFR 70.38{c), *each specific license continues in effect, beyond the expiration date if necessary, with respect to possession of special nuclear materia1 until the Commission notifies the licensee in writing that the license is terminated." This section goes on to specify what actions the licensee sha11 take.

likewise, 10 CFR 70.38(k) states that, "specific licenses, including expired licenses, will be terminated by written notice to the licensee... " and then goes on to state what determinations the Co11111ission must make before it can terminate the license. Therefot:e, the con j,,il'~:,set...f~rthjn 1/4ic.~n$

9,Z8,3tlthd.ugh e

l(pfr~~" jfhntjnuein 1

• !.ln:ti1 the license is t~..... *.. *.*...... the.Commission, ano*.. fo:'.r:... '.'fnat:reason,

¥.e~!!"JSTl:0 needtoextend tne,exp'fraf'1011*'aa'te<.

I believe that you will find this explanation satisfactory. If you have any further questions, please contact me at (301) 415-6664.

Docket No.70-925 license No. SNM-928 cc:

Cimarron distribution list 57 Sincerely,

.I

/'.s '~,/.7,1/.,

Kenneth L. Kalman Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguaras

Mr. Jess Cimarron P.O. *Box Oklahoma Tab 40 - NRC Ltr dtd 4/23/96 pl UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 Larsen, Vice President Corporation 25861 City, OK 73125

.C.pril 23, 1996

Dear Mr. Larsen:

In a letter dated November 13, 1995, Cimarron Corporation (Cimarron) requested the Nuclear Regulatory Commission to amend License SNM-928 to release certain areas of the Cimarron site, designated as the "Phase I" areas, for unrestricted use, and to remove the Phase I areas from License SNM-928.

To demonstrate that the residual contamination in the Phase I areas is below NRC unrestricted use guidelines, Cimarron submitted the "Final Status Survey Report, Phase I Areas, at the Cimarron Facility," (Final Survey Report) in a letter dated August 9, 1995.

In response to NRC comments on the Final Survey Report, Cimarron submitted supplemental information on November 13, 1995.

The staff reviewed the Final Survey Report, as supplemented, and determined that it provides adequate documentation to demonstrate that the Phase I areas meet NRC unrestricted use guidelines.

The unrestricted use guidelines applicable to the Cimarron Phase I areas are the Option 1 guidelines in the 1981 Branch Technical Position on "Disposal or Onsite Storage of Thorium or Uranium 14astes From Past Operations" (46 FR 52061) (1981 BTP).

The 1981 BTP Option 1 guidelines are 30 pCi/g for enriched uranium and 10 pCi/g for thorium.

In the April 1992 "SDMP Action Plan" (57 FR 13389), the Commission instructed the staff to use the 1981 BTP guidelines, and ALARA, as the unrestricted use guidelines for decommissioning pending the final rule on radiological criteria for decommissioning.

Independent confirmatory measurements were conducted in the Phase I areas by an NRC contractor, the Oak Ridge Institute for Science and Education (ORISE).

During the period October 17 through 19, 1995, ORISE performed random measurements in the Phase I areas.

The ORISE results are contained in the March 1996 report, "Confirmatory Survey of the Phase I Unaffected Areas, Kerr-McGee Corporation, Cimarron Facility, Crescent, Oklahoma."

These results were consistent with the licensee's Final Survey Report results, and support the conclusion that the Phase I area meets the 1981 BTP guidelines.

The ORISE report is enclosed (Enclosure l).

In addition, the staff performed an environmental assessment of the proposed unrestricted release of the Phase I areas and made a "Finding of No Si nificant Impact." contains the "Environmental Assessment.

Fi ding of No Significant Impact, and Notice of Opportunity for a Hearing, Re ease of Parts of Cimarron Site for Unrestricted Use, Docket No. 70-0925" (6

FR 16127).

58

Tab 41 - NRC Ltr dtd 4/23/96 p2 J, Larsen 2

Based on the above documentation, NRC is issuing Amendment No. 13 to License SNM-928 (Enclosure 3).

Amendment No. 13 adds License Condition No. 25 as follows:

J~~,.areas

• • • Hi.~1m.~ e 11'

. /'.uorestr1**

lt~**** ~ij-ii0£l:.,.RF3jr,; *~<J.*lll*th}l aiitie.. ~eleaswf... f.iJcJt~; *,>

m.JM..:9'28.

The Phase I Although the staff found Cimarron's November 13, 1996, response to NRC comments acceptable to support the conclusion that the Phase I areas meet the 1981 BlP Option 1 guidelines, the staff requests additional information.on the equation for "critical value* on page 2 of the response.

Please provide a dertvation of the equation to the NRC for review.

Please.careful1y review th*e enclosed license,. inc1uding the revision to License.Condition 10, and new License Ccmdittori 25.

If you have any questions, immediately notify me on (301) 415-7298.

Docket No.:

70-925 License No.,

SNM-928

Enclosures:

As stated Sincerely, R. A. Nelson, Acting Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nucr ear Ma teri a 1 Safety and Safeguards cc: Cimarron distribution list w/enclosures 59

Tab 42-Cimarron Ltr to NRC dtd 11/12/96 p3 JOHN C. $TAUTER VtCE PRESIDENT November 12, 1996 Mr. Ken Kalman Project Manager CIMARRON CORPORATION Low-Level Waste and Decommissioning Project Branch Division of Waste Management U.S. Nuclear Regulatory Commission Ref:

Docket No.70-925 License No. SNM-928

Dear Mr. Kalman:

The purpose of this letter is to request that the nvo attached letters be included in existing Condition #10 of License SNM-928. This license is currently under review for amendment to reflect the final decommissioning actions underway. During the NRC Region [V audit performed during the week of November 4, 1996, the inspector noted that he could not find any documentation wherein Cimarron Corporation was released from the requirements contained in l 0 CFR 70.59 (reports describing the release of SNM in effluents to unrestricted areas). The referenced letters document this action and approval.

Cimarron Corporation notified theNRC i):1.at. they would be discontinuing filing these reports by* letter dated August 22, l 990 due to the fact that Cimarron Corporation was no longer.utilizing SNM for processing and fuel fabrication. 'foe NRG notified Cimarron Corporation by letter September I 4, 1990 that they had no objection to the discontinuation of the etl1uent release reports.

Please contact me if there are any additional questions or concerns, or if Cimarron Corporation can be of any further assistance.

Sincereiy,

-LC~~

(/ John C. Stauter Enclosed Letters dated August 22, 1990 J. C. Stauter to C. E. Norelius September 14, 1990 C. E. Norelius to J.C. Stauter cc:

Mr. Louis Carson (NRC Region IV)

ASUSSIDIARY OF KEJ11MfCGEECOIIPORAllON 60

y Tab 43 - Cimarron Progress Report - BAJ GW Evaluation Cover ltr dtd 1120/00 S,,ESS LARSEN VICE PRESIDENT January 20, 2000 CIMARRON CORPORATION

?.O. 50X25!!:61 OKLAHOMACtTY,OKLAHOMA 73i25 Mr. Ken Kalman, Project Manager Facilities Decommissioning Section Low-Level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re:

Docket No.70-925; License No. S1"'M-928 Cimarron Corporation Progress Report-Burial Area #1 Groundwater Evaluation

Dear Mr. Kalman:

This letter transmits to you an interim report of the ongoing investigation of groundwater quality, hydrology, and soil activity in the vicinity of former Burial Area #1 (BG-1) at the Cimarron site.

The report presents a status summary on shallow soil sampling, deeper soil coring, and groundwater delineation efforts over the last sev~.ral:months. It also states Cimarron's plan to further study the,~ttitable remedy during the first half of year 2000 and then submit to NRC a proposed rerhedi~~plan.

Please feel free to contact me if you require clarification of the interim report that is attached.

Sincerely,

~~

Jess Larsen Vice President Attachment jlO I 2000.lel A S'JBSIDIARY OF KERR*MCGE£CORPORJITJON 61

Tab 44 - Cimarron Progress Report - BAJ GW Evaluation dtd 1/20/00 p5-6 The excavations were open from 1986 through 1992. During that time, the buried waste was removed, final status surveys were completed, confirmation surveys by ORA.U were performed, and the final report was issued. License Amendment #9, allo,ving backfilling of the area was issued by the NRC on December 28, 1992.

By July 1993, clean soil had been transported to BG-1 and placed into the excavated area for final contouring.

Monitoring Well #1315 *was installed in 1985 and the well sampling that immediately followed the installation indicated the presence of elevated uranium in groundwater at a concentration of over 8,000 pCi/1. As discussed above, the extended period of time the excavations were open may have contributed to the uranium concentrations in the shallow groundwater. Drawing No. 99BGI-TR, included as Attachment E, sho,vs the former trenches and the open excavation in relation to the groundwater contamination. Indications are that the transmissivity characteristics of the alluvium in the vicinity of the alluvium/bedrock contact may have mitigated the migration of the plume in the alluvial material.

The soil samples collected from each boring during this most recent work provide additional evidence that all sources have been removed.

Hov.,ever, the soil sampling did confirm the presence of residual activity in the subsurface resulting from the slow migration of a groundwater plume toward the northwest. The average total uranium soil concentration was calculated for the TMW soil borings for the area that represents the center of the groundwater contamination and for the other areas investigated by these borings. The center of the groundwater contamination, which are represented by TMW-#3, #9, #10, #11, and #12, shows an average total uranium concentration in soil of 12.1 pCi/g. T\VM--#1, #2, #4,

1. 5, #6, #7, and #8, which represents other areas of investigation, shows an average total uranium concentration in soil of 5.8 pCiig. This level is indicative of site background. The concentrations in the soils ranged from 2.1 pCi/g to 32.4 pCi/g. All analytical results were below the BTP #1 guiddine value of 30 pCi/g total uranium above background (i.e., equivalent to 34 pCi/g).

6.0 CONTINUING INVESTIGATION Cimarron Corporation feels confident that all discrete sources have been removed from BG-1. The only remaining item to be addressed is achieving the 180 pCi/1 total uranium concentration in groundwater required for license termination. As discussed in Cimarron's March 4, 1999, letter to the NRC, natural attenuation was considered a viable option for achieving the goal of expedient license termination because of the diminishing uranium concentrations in Well #1315.

However, because of new information gathered during this recent investigation, 5

62

Tab 44 - Cimarron Progress Report - BAJ GW Evaluation dtd 1/20/00 p5-6 Cimarron intends to expeditiously study the options for accelerating the cleanup of the groundwater near BG-1. The methods under study include:

Groundwater withdrawal and treatment followed by reinjection or appropriate discharge.

Any sludge generated would be shipped off site for disposal or stabilized and placed into the on-site disposal cell.

Insitu chemical stabilization of the soluble uranium within the plume through the injection of a chemical slurry formulated for the subsurface hydrogeologic conditions.

Insitu chemical stabilization of the entire shallow groundwater formation through the mixing of the soils and groundwater with a formulated chemical constituent.

The method would stabilize the soluble uranium and bind it to the surrounding soils.

Prior to implementation of Cimarron' s proposed remedial plan, additional studies will be conducted to further define the local geology, water chemistry, plume geometry, costs, and estimated times for achieving the guideline value. These studies are to be performed during the first quarter of year 2000 in hopes of formulating a remediation work plan for submittal to the NRC in the June 2000 timeframe.

6 63

Tab 45 - Response to NRC Comments on Progress Rpt for BAJ GW Eval pl 0 NRCComment

b. The hydraulic characteristics (hydraulic conductivity and specific yield) of the alluvial and Garber sandstone units that are or may be impacted by uranium concentmtions in the groundwater should be determined.

Cimarron Response Cimarron is continuing investigations to determine the hydraulic characteristics of the alluvial and Garber sandstone units in the vicinity of former Burial Area #1. The results of these investigations,vill be provided to the NRC in the Final Investigation Report.

NRCComment

c. An analysis that simulates and models the measured uranium concentrations in the

[ground-water] should be performed.

The simulated uranium concentrations can be generated from analytical or numerical models using data from 4a and 4b.

Cimarron Response This analysis is being developed and will be provided in the Proposed Remedial Plan to be submitted to the N"'RC.

N"'RC Comment

d. Based on the results of 4a, 4b, and 4c, the licensee should evaluate its proposed remedial procedures by using existing pilots, full-scale studies, and analytical or numerical modeling.

Cimarron Response Cimarron is evaluating different methods for remediation of the groundwater in the vicinity of BG-1. This evaluation includes natural attenuation and other options for accelerating t.li.e cleanup. The selection process for determining which remediation alternative is acceptable to Cim:mon will include input from the ongoing characterization study, bench scale pilot tests, and/or ground,vater modeling. The data evaluation and the reasons for recommending a remediation procedure will be presented in the Proposed Remedial Plan to be submitted to the NRC for review and approval.

10 64

Tab 46 - Intentionally left blank 65

Tab 47 - Cim D Plan GW Evaluation Report dtd 7/30/98 pl 0-4 The three reservoirs located on site are monitored under the sitewide environmental monitoring program.

These reservoirs are recharged by a combination of surface run-off and shallow groundwater. Surface water location #1204 monitors Reservoir #1 which also is designated the West Lake. Monitoring location #1205 is for Reservoir #2, and location #1209 is for Reservoir #3. The 1997 analytical data for total uranium was 4.0 pCi/L for #1204; 0.8 pCiiL for #1205; and 2.9 pCi/L for #1209. These results show no effects from prior site operations.

5. 7 Deep Monitoring Well As discussed in Section 3.2.1, the monitoring wells located on site that monitor the deeper groundwater zones have shown total uranium concentrations ranging from 11 to 44 pCi/L. These concentrations are considered within background variances for these deeper sandstone layers.

Historical data for uranium and other constituents monitored indicated that these deeper zones have not been impacted by prior site operations.

5.8 Summary The historical and more recent groundwater and surface water investigations clearly.. show. that :§,~~~~rt~t~r'):a,~~~¢1i1~ ~!mpa?ts >have continuetl,fheir*decresi-sirjg Jr=enci'~:~; the **.;~~Is t;.;s~~te<l in the. 1989 Grant reeort:. With additional sources rer:riove:d in these areas and tA;e site in the :{i1;aJ phase ofdecommisslonrng, these recorded decreasing trenas will continue.

5.9 References Chase Environmental Group, Inc, 1996.

Groundwater and Surface Water Assessment for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma, December, 1996.

5-20 Ground-Nater Evaluation Report 66

Tab 47 - Cim D Plan GW Evaluation Report dtd 7/30/98 pl 0-4 close proximity to former Burial Area #1 at the Cimarron site exceeds the proposed uranium criterion. Former Burial Area #1 is within the Cimarron River flood plain and is prone to inundation on a regular basis, thereby minimizing the likelihood of a downgradient residence or well.

In order to address the fact that groundwater in the vicinity of former Burial Area

1. 1 does not meet the proposed criterion, Cimarron is moving forward with a further evaluation of former Burial Area #1 utilizing the protocols described below:

A. c;~fron... wm continue. to monitor Former BurialArea #1 mroundwater

.on,<1.quarterly bas is. Even though Ci!JlEtn;pn, b~J~y~~ a~',g roundwater c.q11~ntrations will contlnve to decr~a:s~, it will cooouct additional

. stiii\j,tes for the purpose of understandJiigtheatti:?f)uation mechanisms.

These studies will include additional hydrogeologic evaluations of the general area.

B.. forh)er Burial Area #1 is.being sulileyep 0:ang mapped using both conductivity and magnetometer non-intrusive subsurface investigation techniques. In ar:icefforttoassur~thatn!3lotbier§olidwast~s remain:

1. Any areas that are suspect due to the above studies will be investigated.

2, Any d~~~-v~fed'wi:iste:,e:~., cthirns; s~rap~. etc.) will be removed; pr?'p~rly,t;).gCK?9es:i and:shrppeaio*a.11 appropriate disposal ~ite.

3. A~;r<~~p~qhtc::tpalizeti are,r soils t.hat are. revealed as acesult of wciste..;vemd\lal ~~t1wties will be evaluated utilizing the NRC's Branqil cf~dl;Jnical.PosTtiol3! and volumetric averaging guidance.

,;c,,

10-3 Groundwater Evaluation Report 67

Tab 47 - Cim D Plan GW Evaluation Report dtd 7130/98 pl 0-4 These acwftles will serve to assure that any identifiable source of Hngering,groundwater contamination is identified and remov!i:d.

C. Cimarron, through its parent Kerr-McGee Corporation, will retain and control the property areas formerly licensed under SNM-928 until the proposed groundwater criteria are met In the unlikely event that the uranium concentrations do not decline sufficiently during the monitoring period, Cimarron will prepare a corrective action program.

The main plant site area will continue to be used by the Chemical Division, KMCLLC., for pilot plant studies related to titanium dioxide pigment activities.

These research activities do not require the use or application of radioactive materials. With the submission of this report, Cimarron believes that it is now appropriate to approve the Cimarron Decommissioning Plan.

10-4 Groundwater Evaluation Report 68

Tab 48 - Cim Response to NRC Comments on GW Report dtd 3/4/99 p4-5 piezometers or wells. The data collected will be used to further characterize the local groundwater near the former Burial.t\rea and to model the mobility of the uranium in the subsurface. Cimarron has assumed that four locations will be completed as two inch monitoring wells for short-term (i.e., four to six months) sampling. With the completion of the data gathering activities, all corings not completed as wells will be grouted.

The information gathered from this additional characterization effort will be summarized in a report to the N"RC. Should a discrete source be found during the investigation, then further evaluation may be required, possibly followed by source removal.

~o; shq-ulct tl;lis.

• gation odeling effort determine that relyiijguporrna

• on to.achieve

• Ci/1

.* anium concentration is not in the ~fst fntey:esJ.*

.for. achie;,".ing

• lts!~oaI bf e nt license termination, then other mi~ans oraccelet

• , eclean 11p ':"',ill*.

l'h¢ic~rtsidered:*

Although specific locations, sampling frequencies and general coring depths are specified with this plan, site conditions may require modifications in the field.

Any required modifications will be discussed in the report submitted to the NRC.

2. NRC Comment:

Cimarron should provide a plan describing what it will do to investigate any areas where uranium concentrations in monitoring well levels exceed the proposed groundwater criteria.

Cimarron Response:

The most recent groundwater monitoring well environmental data are included as an attachment to this response (i.e., Table 1.0). This data represents the latest 1998 sampling event for all wells on site included under the Site's environmental monitoring program. This recent data was not available for inclusion in the Groundwater Report. As the NRC is aware, these wells are sampled annually with seven wells also included under a quarterly sampling program. The quarterly sampling represents those wells monitoring areas on site \Vith the greater impact from prior site operations. This data set shows that only Well #1315 detects groundwater exceeding the approved total uranium concentration of 180 pCi/1. The proposed plan for addressing the groundwater monitored by Well #1315 is discussed in the response to the first NRC comment.

Since site-v,,ide source removal is essentially complete, Cimarron is confident that the average total uranium concentrations presently reflected by the environmental data will continue to trend dov.nward.

The next annual sampling event for all wells 'Nithin the monitoring program is scheduled for June 1999. Once this analytical data is received and compared to the past environmental data, Cimarron intends to request removal of numerous wells from the monitoring program. The wells that will be included for removal from the monitoring program would represent only those areas where ongoing analyses have shov,,n that within the last 3 years the groundwater criteria (i.e., 180 pCi/1 total uranium) has not been exceeded.

Presently, under this criteria only three wells would continue to be monitored; they are Wells #1315, #1317 and #1331. These three wells would continue to be 4

69

Tab 48 - Cim Response to NRC Comments on GW Report dtd 3/4/99 p4-5 monitored* on a quarterly basis until one year of subsequent data shows residual concentrations of total uranium are below the 180 pCi/1 criteria for each sampling event.

Individual wells would be removed as this goal is achieved. Cimarron believes that Well

1. 1315 will be the only well remaining under this monitoring program after the third quarter of 1999.

In the unlikely event that another well beside Well # 1315 exceeds the 180 pCi/1 total uranium criteria, then Cimarron will implement a characterization plan tl1at includes resampling of the well to verify the original result. Next, quarterly sampling will be continued for one year to determine whether or not the elevated concentration continues or is simply a.one-time spike for that well. Should the elevated concentration continue as verified by the one year of quarterly sampling for total uranium, then Cimarron will implement a plan for potential source identification. The source identification program *will include possible soil borings or

~eH installations in the potential areas of C~P,-Ce *** "

.. rear j:1],e.11,~mitl fJl'~~equent r:em "' tion if neceiisar,y, \l\19qld:i ~;si~iil:

for

• • #33 ts as cliscussed in2\the; onse to NRC Co1nmefit#t,**.f Please advise if you have further questions or we can further clarify any matters for you. We trust that this response and its commitments will satisfy the needs of NRC to then expeditiously approve the Cimarron Decommissioning Plan.

Sincerely,

/1,:,~ ~~?"/

~sLarsen Vice President Attachments jl030499.lel 5

70

Tab 49 - NRC Inspection Report dtd 11/7/83 p4 The licensee estimated that completion oi Tasks 1 through 5 would require about ~we more years, assuming the work force remains at its cur::ent level.

The renewed license~ issued in !-!arch 1983, authorizes operat.ion of exist.i.ng ion exchange e.quipment ior t.he purpose cf reducing t.he volume cf liguid wast.es generated in t..h.e plant duri:1g cleanup.

Plutonium in cleanup solutions is abso=~ed on ion exchange resins.

T.he ra:f:fir..at.e solu~ior:s ;;,;ill be collec~ed and analyzed f:i::- plut..onium..

The licensee hopes to reduce ~he p~uLoniu..~ content so ~hat the solution @ay be fixed in coccrete and placed\in licensed low level land dis?osal sites.

Decommiss*io~in::g oi the Uranium ?lant con:-i.nu~s under :.he r~newed license, -dated :iarc:h 31, 1983.:

Decont..arninat.ed-releasable equipment is being utilized at the coal-liquifac~ion plant at Cimarron as well as.at-otb.e:: Rerr-McGee :facilities.

Other cleaned and released equipment is being sold or held in a designated area as clean scrap.

Six surplus Denison pelle~ presses have been sold.

Three have been de::or..tarnin.ated and sh:i.ppe.d.

The licensee estimates the decom.l!iissio:c.ing is about CS percent complete.

d i.s ~o l u~ i.ou r~ ?_~;~:~;;;;~H-:f ~~i:: ~ ~!~!~i:;;~~i: !iH:f ~;!:;ii:::or.s _,

tecc,ye:-ec--,u=aniu_tn-sclutions -ar.e, blended do1/4'n t.o na-:.u:::-c.J u,ranium and ?~i:p~~d,to t.he S.::.q*,o:~ar Facili-:.y £0:; r:e.~ove~y* _

A ne-:;..~ sanCblast:ing bood ":as bei:1g developed to remove paint. and corrosion produ.cts :from decontaminat.ed equipment.

This facilit.y is still under development and no safe~y an2lysis had been made nor had operating procedures been developed.

The licensee committed to cor::iplet:e t.hese befo::e routine 1:se of the equipment.

5.

Radiation Prote~tion

a.

Ixterr..al Exposure Revie;;; cf monthly *oeta-gam.:Tia film badge records for January through August. 2983 disclosed no problems.

Th:-ee of the 27 badged ~orke:-s have received exposures during the period exceeding one rem, t.he maximu.~ being about 1.7 rem.

b.

T..:rinalvsis Lranium plant employees submi~ biweekly samples for analysis at the corporation's technical cen~er.

Review of records from January 1 through September 5~ 1983, showed that most concentrations were below the de~ection limit of 10 dpm/1.

The highest measured concentration was 21 dprnil, well below the first action level of 65 to 160 ciprn/1 for partially soluble (inhalation Class~) material whicb would require (by procedu:::-es) con£irma1:icn of result.s and identification of ca_use.

4 71

1 1.1 Report Details Decommissioning Inspection Procedure for Fuel Cycle Facilities, Closeout Inspection and Survey, Site Status (83890/88104) lnspection Scope Th ~;B,fi:iposi;~ \;;lt;rl~fr9s11 Q~cofri m issioningJ'.

c~qUife§ -tl]e licensee to-follow the recom'mendatio~sin ~UREG!CR-5849, "Ma I for Conducting Radiological Surveys in Support of License Termination." Section 3.1 (B) of NUREG/CR-5849 establishes criterion for hot-spot averaging in contaminated soil and requires that exposure rates do not exceed 10 microRoentgen/hour (µR/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::.8,JP Option 2 criteria.

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 pCi/g 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 placed soil into Pit 3 that met the BTP Option 2, NUREG/CR-5849, and License Condition 23.

1.2 Observation and Findings Site Status The licensee's Decommissioning Plan was submitted to the NRC in April 1995 and is under review. The licensee continl:!e,<;Jtg,i;

_ e,.11t:the_pecommi~§!~nJQg Plan, although the plaQ_tJad0not received NRC app_(qvij[,-

. ensee's current activities included soil "samplin*/fandradiation surveying:cfia'racterization 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 p_lanned for completion in 1998. Final survey activities for the site are underway. This inspection was a continuation of the NRC's confirmatory survey program for the Cimarron site.

Geotechnicai 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 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 TM05-l 0 Support Document for Cim/NRC Discussion of Permissible GW Treatment Methods Revision 0 NEXTEP Environmental, Inc.

72 June 2005