ML24138A072

FOIA-2023-000184 - Released Set

ML24138A072
Person / Time
Issue date:	05/10/2024
From:	NRC/OCIO
To:
References
FOIA-2023-000184
Download: ML24138A072 (1)

Text

UNITEDSTATES NUCLEAR REGULATORY COMt11SSION fH:GIOl'-l II/

s, 1 RY I\\N PLAZA OF\\IVE. SUITE 1000 ARLI/IIGTON, TE.* AS 76011 License ro. SUB-1010 Kerr-~cGee Nuclear Corporacion ATTN:

Mr. W. J. Shelley, Director Regulation and Control Kerr-~cGee Building Oklahoma City, Oklahoma 73102 Gentlemen:

August 31, 197B This refers to the inspection conducted by Messrs. R. J. Everett and C. L. Cain of this office on August 10-11; 1978, of tne activities authorized by t!RC Source Material License No. SUB-1010, and to tne discussion eif our findings held by Messrs. Everett and Cain with Messrs. B. E. Brown and C. E. ~rossclaude on August 11, 1978, The inspect-ion was,an examination of the activities conducted under the license as they relate to radiation safety and compliance with the Co, ission's rules and regulations. and the conditions of the 1icen:;e.

The inspection consfsted of se1ect1ve e~aminations of procedures and representative records, interviews of personnel, independent meas~renents and observations by the ins?ec~or.

The fnspectors also reviewed the action you hud ta~en with respect to two (2) items of noncompliance observed during our previous inspec~ion, whicn was condu.. ed June 15-17, 1977.

They verified that the corrective action with ret;pect to these items was implemented as stated in your reply of July 20, 1977, to ~ur !et~er dated July 6, 1977.

Based on the r~sults of this inspection, it appears that certain of you-activities were not conducted in f*Jll compliance 't1ith ~lRC requirements, as set forth in the tlotice of Violation. enclosed here\\*d~h.

This notice is sent to you pursuant to the provisions of Section 2.201 of the me "Rules of Practice," Part?., Title 10, Code of Feder'il1 Regulations.

Sec.tion 2.201 requires you to submit to this office, withrn t*(lenty (20) days of your receipt of this notice. a written statement or explanation in reply 1ncludi:,g (1) corrective actions \\vhich have oeen taten by you and the results achie1ed; (2) correctiv~ actions w~ich wi11 oe ta~en :o a'.'oid furtner 1:.ems of r.oncomoliance; and ('.3) the da':.e wnen full compli~nce will be achieved.

781121(/.J /

Kerr-*~cGee nuclear Corporation August 31, 19i8 In accordance with Section 2.790 of the 'lRC "~ules of Prac~ice, 11 Part 2, Title 10, Code of fed~r~l Regulation~. a copy of th1s letter and the enclosed inspection report w11l be placed in the ilRC's Public Document Room.

If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within twenty (20) days to this office to withhold such information from public disclosure.

Any such application must include a full statement of the reasons it is claimed that the infonnation is proprietary. It should be prepared so that proprietary infonnation identified is contained in a separate part of the document, since th~ application, excluding this separate part, will also be ~laced in the Public Document Room.

If we do not hear from you in this regard within the specif'led period, the report wilJ be placed in the Public Document Room.

Should you have any questions concerning this letter, please let ne know.

Sincerely,

,,{ "JV C

ll

1. t ~.L I

/h Glen O. Brown, Chief Fuel Facility and Material Sa fcty Branch Enc 1 osu res:

1. Notice of Violation

2.

IE Inspect:ion Report ico. 40-8027/78-01

License i{o.

SUB-1010 tlotice of Violation Based on the results of the r;Rc insoection conducted on August l0-11, 1978, certain acti'lit1es appear to be in noncompliance \\itt1 tlRC regulations and the conditions of your License No. SUB-1010 as indicated below:

1.

Contrary co 10 CFR 20.103(c), use of respiratory protective equipment was not in accord with Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection" in that;

a.

At tne time of the inspection, tv,elve workers had not compl~ted a respirator fitting and training ~rcgram prior to the use of respiratory equipment as r*equired by Section C of Regulatory Gui de 8.15.

b.

Half-mask respirators are not being tested for fit with irritant sooxe, prior to use, each tir.te such equipment is donned as required by Table 1. Footnote f, of Regulatory Guide 8.15.

c.

Half-mask respjrators are used with head straps over the hard hat which prevents straps from lying in their nor~41 position next to the head as required by Section 13.5 of NUREG-0041, which is referenced in Section C.8.n of Regulatory Guide 8. 15.

This is an infraction.

2.

Contrary to 10 CFR 20.'203(c)(2). the ash recei'ler enclosure, a high radiation urea in the fluorination area~ was not equipped with entrance or access control devices or maintained locked when access was not required.

This fs an infraction.

3.

Contraty to 10 CFR 21.21(a), aopropriate procedures have not been adooted that would provide for the evaluation and re~orting of defects in basic components as defined in Section 21.3 of 10 CFR 21.

This is an infraction.

rt, License Condition 9 requires that license~ JCMi,ities be conducted in accordance ~ith statements, repre~entations, procedures and conditions stated in tne License Application, Appendix A. and Section 2.0 of Appendix B.

781121 1 //;*

f.nntrary to this requirement:

a.

During the period October 1977 to August 1978, surface contamina-tion levels in the operating areas of the plant eAce!ded and remained above the control

'alue of 2,000 dpr:t/100 cm srrearable activity as specified in Section 3.4.3 o Appendix A.

b.

Annua 1 oral or wri tlen tests ha*:e not b~en gi'len to mi 11 "'-Orkers to detennine their understanding of rad1ation protection and uranium loss prevention as specified in Section 2.0 of Appendix B.

This is an infraction.

5.

L1cense Condition 12 requires, in part, that soil samples be collected at 6000 foot distdnce::; from tne plant in the cardinal comoass directions and analyzed for uranium and fluoride. Contr~ry to this requirement:

S011 samples have not been collected at 6000 foot distances from the plant in the cardinal co~pass directions, since the renewed license was issued.

This is an 1nfraction.

6.

License Condition 1S requires that samples of bottom sediments be obtained at n~aningful upstream and downstream points o the plant outf311 into the Robert S.. ~rr reser*,o~r and analyzed as a means of evaluating the effect of the liquid plant effluent on aquatic biota.

Contrary to this requirement:

Bottom sediment samples have not be~n obtainPd and analyzed, since the renewed license was issued.

This fs an infraction.

LI.$. UUC!_fAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION I'!

Report Ho.

40-8027/78-01 Licensee:

Kerr-McGee Nuc1eur Corporation Kerr-McGee Center License No. SUB-1010 Docket No.

40-8027 Oklahoma City, Oklahoma 73125 Facility:

Sequoyah Uranium Hexafluoride Conversion Facility Inspectior. at: Gore, Oklahoma In~pection conducted: August l0-11, 1978 Inspectors; Approved by:

C. [. Ca1n, Radiation Specialist R. J. Everett, Rad1at\\on Specialist G. O. Brown, Chief, Fuel.Facility and Material Safety Branch rnspection Surnary g/z'1 /1s Dat e Inspection on August 10 and 11, 1973 (Report No. 40-03027/78-01)

Areas Inspected: Routine, unannounced inspE":.. tion of uranium con*1ersion facility operacfons and radiation protection program including organization

.and administration; facilities and equipment; internal exposure control; ex~ernal exposure control; environmen~al monitoring, auaits and training; emergency planning and fire protection; posting, labeling, and reports; and independent measurements.

The inspection involved sixteen (16) hours on site by two inspectors.

Results:

Of the nine (9) areas insoect~d, no i:ems of noncompliance or deviat1ons were identified in four (4) areas; six (6) apparent items of noncompliance were identifiad in five (5) areas (Infraction - deficiencies in respfratory protection prconm, s~e p~,r:igraoh 5; infraction - failure to provide proper access contMl to a h'ign radiation area, see paragrapn 6; infraction - failure to obtain soil samples, see paragrdph li infraction -

failure to obtain bottom sediment samples, see paragraph 7; infraction -

failure to perform personnel ~esting and to control contamination, para-graphs 5 and a. infraction - failure to establish procedures to report defects, paragraph 10).

OETAILS

l.

Persons Contacted

• 8. E. Brown, General Manc1ger, Nuclear Manufacturing

• C. E. Grossclaude. Manager, Health Physics & Industrial Safety L. H. Harrison, Manager> Administration & Accounting

~Members present at exit interview.

In addition the inspectors interviewed one member of the plant operating force.

2.

License Action on Previous Inspection Findings

a.

(Closed) Moncompliance (40-8027/77-0l):

This item involved failure to conduct monthly audits of health physics programs by facility management required by License Condition 8 of SUB-1010.

This license condition was modified in the renew~rl license issued October 1977.

b.

(Closed) Noncompliance (40-8027/77-01): This item involved failure to post radiation areas.

The inspectors verified proper oosting of radiation areas during the plant tour.

c.

(Closed) Unresolved Item (77-01/1): This item involved the use of a compliance certificate issued to Union Carbide (AEC-ORO 6273-48/ AF) as authority to ship type B quantities of UF5 in a container described as OR0-651, Model 48x. The l1censee Ms now rPceived comp1 iance certi f1cc1te #6273, issued by the rtRC on July 2q, 1977, and now fully complies hfth 10 CFR 71.12.

3.

Organ i :::c.1 ti on and AdIJli n f dra tion Discussions with licensee management established the following corporate and facility organiz3tion on the dates of the inspection:

Corporate Morgan ~'.oore, Pres I dent, Kerr-McGee 'luc l en r Corporation R. P. L1Jke, 'lice President, t*ltlnu~acturing & Marketing C. J. Sinke, Corpora~e Health & Safety Coordinator W. J. Shelley, Director, ::uclear Reou:ation & Control 78112101 5 v

4. Sequoyah Facility

8. E. Brown, General r**anager, tluclear ~anufact1.:ring C. E. Grossclaude, Manager, Heal th Physics ~ Industrial sa;ety J. W. Craig, ~anager, Conversion Engineering L. H. Harrison, Manager, Administration & Accounting The licen~ee stated that the facility staff is comprised of about 148 employees, which includes about 78 1n production, 40 in maintenance and 30 salaried workers.

Facilities and Equipment The inspectors toured the plant and the liquid effluent retention ~reas on August 10, 1978, to observe operations in progress and verify that equipment and facilities were in accordance with app1icable license requirements.

The l ice11see stated that the plant capacity had been doubled to 10,000 tons pe:-- year cof'11'11enc i ng April 1978, as authorized by a renewed license dated October 1977.

The licensee stated that the plant operating <<.chedule was twent:;-fou?* (24) hours per day, seven (7) days per week. During the plant tour tne inspectors verified thot correcti~e aLtion had been maintained regarding the posting of radiation areas, a~ item of noncompliance from the June 15, 1977, inspection.

The plant was observed to be operating and housekeeping was noted as being poor.

The license2 stated that this condition was due in large degree to the recent plant modifications necessary to increase production capacity.

A tour of the waste ponding areas revealed that a pit had been dug for burial of fluoride sludge at the south side of the exclusion area.

The licensee indicated that an additional liquid effluent retention pond was being planned for construction south of the exclusion area fence.

5.

Internal Exoosure Control The licensee's air sampling rogram is described in the license Application. Aµpendix A.

Licensee records lisled 46 air sampling locations in war~ locations within the plant. -~ ~se samples are collected s~ch 8-hcur shift and analyzed radiomftrically for tolal alpha emission after a 4-hour delay.

Each worker is recuired to tabulate his work time in each area.

The ~PC-hoer exposure is then calculatdd on a seven-day exposure perioc. The licensee s~ated that air sampling in the solvent extraction buildin~ had been terminated,

since results obtained o*,er man,y Y"'ars of opera:ion had shOwn air activities in this area to be l~ss tnat 25w of 10 CFR 20, ~ppendic B, Table I, limits.

A review of uir sampling data revealed many areas in the plant where airborne radioactivity concentrations exceeded Part 20, Appendix B1 Tabler, limits. Exposure records indicated no evidence of overexposure to personnel. This was achieved by limiting occupancy and/or utilizing respiratory protection equiprner1t.

Daily Radiological Status Reports listing air sample results greater than 0.5 MPC were reviewed.

These reports were noted to be distributed to various plant and corporate management personnel.

Process engineering controls had been implemented to reduce airborne radioactivity concentrations 1 but concentrations were still recorded above those that would delimit an airborne radioactivity area. A rotary valve had been installed on the re-drum hopper in the sampling plant and additional ventilation had been installed.

The licensee stated that several other measures had been studi~d, but none of these had yet been implemented.

The inspectors were unable to clearly determine whether the licensee's effor*c; to provide engineering and process controls were sufficient to comply with 10 CFR 20.lOJ(b)(l). The item wa~ left unresolved pending discussion with NRC Licensing.

The licensee stated that a respiratory protection program has been established in accordance with Regulatory Guide 8.15.

Internal exposure records were found to apply protection factors for those p~rsonnel wearing respirators. A polydisrerse OOP man-test system with a fitting chamber has been used in conjunction w1th the pr~gram.

Records indicated that personnel had received medical examinations including lung dynamics tests as a part of the program.

Copies of written examindtions relating to respiratory protection were contained in employee record files. Comprehensive written procedures were found descr~bing the program.

During the plant tour, i~~pectors observed that half-mask ~espirators were worn with head strap~ over hard hat helmets and that irritant smoke testing was not performed, prior to use, each time respirators w~re donned.

The licensee also indicated that twelve (12) workersr who received allowance for respirator use, had not completed the respirator fitting and t~sting program.

The inspectors seated that these 1tems constituted noncompliance with 10 CFR 20.103(c).

The 1 *c~nsee's bioassay program is described in Section 3.4.2.,

App~*dix A of the application.

The inspectors' discussions with the lic~nsee and a review of pertinent records estJblished that the program being conducted 1tas as described in the app1 ication.

The bi-roonthly urinalysis sched~le for plant workers is designed to ~onitor the controls implem~nted for routine worker expos11re.

The ~nspector.s noted some data in exce,s of 20 micrograms per liter action lev&l and inquired as J the 1 icensee's evaluation.

n1e licensee sta"ed that in ec1ch case the workar was restricted from further exposure until tile next bioaSiaY indica:ed normal levels. ihe licensee stated f~rther that

6.

7. some of the high samples may have been contaminated.

The inspectors noted that the bioassay laboratory did not, in two instances, report levels in excess of the action level in e timely manner, sufficient to allow resampling to confirm the result from an acute exposure standpoint. Powever. once the licensee was informed, samples were collected and t1*.~se samples yielded nonnul values.

The licensee stated that acute exposures should be readily identified so that more fref'!~~nt,";ampling can be conducted, and discussions would be held with the Lioa~say laboratory in order to expedite the reporting of data.

L'icensee records ind,cated that in vivo lung counting is perforr.ied by a vendor as described in the License Application. Appendix A.

A review of current data revealed no result in excess of 10 CFR 20.lOJ(a) limits.

fhe inspectors noted that th~ licensee documented alpha contamination survey data for approximately 100 points within the plant. Surveys were documented as being perfonned wee~*y. Section 3.4.3 of Appendix A specifies that operating areas will t =- cleaned so as to remain below 2,000 dpm/100 cm2 smearQble octi, ity. Surveys of the operating areas were noted to exceed this limit during the period October 1977 to August 1978. The inspectors stated that failure to maintain contamination levels below this limit constituted noncompliance with License Condition 9.

External Exposure Control Licensee records i ndi ca ted tr,a t film badges are provided to a 11 workers on a monthly exchange.

External exposure data was reviewed and no exposures were noted in excess of 20.101 limits.

The inspectors confirmed t external radiation surveys have been made monthly at nineteen (L~) designated locations. Measurements as high as llOO mR/hr (contact) 1n the ash receiver enclosure were noted.

The whole body dose rate within this area was higher than 100 mR/hr, and the area v,as appropriately posted as a high radiation area.

The licen,ee stated that the area was not equipped with entrance or access control devices or maintained locked when access was not required. The inspectors sc5ted that failur~ to provide control devices or control ~ccess constituted noncompliance wi~h 10 CFR 20.203(c)(2}.

Envi ronmental ri~oni toring The 1 icensee's environmental monitoring program is described in license appl1cation references specified in License Condi tion

12.

The liquid effluent stream from the plan~ is continuously sampled at the site bounda,*y.

Daily grab samples are analyzed for uranium.

fluoride, nitrate, pH, and temperature. Monthly co,:iposites are analyzed for uranium, gross alpha, gross beta. nitrate, and fluoride.

Quarterly nalyses ~re performed ior Ra-226 Jnd Th-230.

All radio-logical data were less than tne applicable Part 20, Appendix B, Table tt, values. A review of nonradiological parameters revealed no upward trending. ~nalyses for fluoride, uranium, and nitrate are performed at the SeQuoyah Facility. Analyses for gross alpha, gross beta, radium, and thorium are performed at the Kerr-McGee Technical ~enter, Oklahoma City.

Surface water is collected and analyzed from the Arkonsas, Illinois~

and Salt Fork rivers and three nearby porids as described in ~he lic~nse application. Ground water is collected from four (4) settling basin monitor wells, one (1) residence well, and thirty-nine (39) raffinate pond monitor wells. Concentrations were found to be below applicable MPC's for um*estricted areas.

The licensee stated that submerged combustion burning had been suspended at the raffinate ponds and that the raffinate w~s no longer used to fertilize test plots, since increa~ 0 d nitrat~ levels had been detected at monitor well. The licensee~* a siated that there had been no burials of wastes since the last inspection.

Air sampling is performed at plant stacks, hatches, and vents; at four (4) locations within the boundary fence; and at five (5) locations off-site. Samples are analyzed for gross alpha and fluoride.

Two boundary samples are analyzed for uranium, Th-210, and Ra-226.

Data for these boundary sampl~s were noted to be we11 below applicable MPC's for unrestricted areas. These data are used by the licensee to determine release quantities to unrestricted areas for compl *ance with 10 CFR 40.65.

The method entails ratioing of gross alpha concentrations between the stacks and the boundary samplers in order to determine total discharge of uranium. Ra-226.

and Th-230 at the stacks. Although License Condition 14 seemed to imply tnat principal radionuclide analyses at the stack5 should be performed to,erify the licensee's method, th1s condition was not clearly stated; therefore. the item was left unresol~ed pending discussion with NRC Licensing.

Engineering data ~as reviewed in order to confirm that the plant bu i 1 ding underwent ten ( 10) air changes per hour as requireo by License Condition 12.

License Condition 12 requires that soil and vegetation samples be collected at 1000 foot a11d oOOO foot distances from the plant in the ~ardinal compa~s point directions and that they be analyzed for uranium and nuoride.

The inspector stated that contrary to this requirement soil samples had not been obtained at the 6000 foot distances, since the renewed license had been issued.

The inspectors stated that failure to obtain such samples constituted noncompliance with License Condition 12.

License Condition l S requires obtaining ano analyzing samples of bottom sediments at meaningful upstream and downstream points of the plant outfa11 into :he Robert S. Kerr reservoir, as a means of evaluating the effect of the liquid plant effluent on Jquatic biota.

The licensee stated that this sampling program had not been initiated since the renewed license was issued.

The inspectors responded that failure to obtain such samples constituted noncompli~nce with License Condition 15.

8.

Audits and Training Reports of weekly, monthly, and ~uarterly audits were reviewed and found to be performed as required by Appendix A.

Documented mi nut es of safety meetirigs were also reviewed.

Licensee training activities are detailed in appendices of the License Application.

New employees receive two hours of safety training and a safety handbook at time of hire.

A second training session of two hours dur~tion is provided within several weeks of hire, The licensee stated that female employees are Instructed in the contents of Regulatory Guide 8.13 and that signatory verification of this instruction is required.

Section 2.0 of Aopend*ix B states that workers will be tested annually to determine their understanding of radiation protection and uraniwn loss prevention.

The licensee stated that such testing had not begn performed.

The licensee was informed by the inspectors that failure to a~ninister such testing constituted noncompliance with License Condition 9. The inspectors intervic,-1ed one \\*1orv.er and detennined that her un<lerstanding of the radiological hazards was sufficient to comply with 10 CFR 19.12.

9.

Emergency Planning & Fire Protection The 11censee's emergen~!' planning :ind fire protection programs are described in Appendix A.

Tr~ fire protection program includes t~mpeN-+:trre activated foam spray heads in the SX 81Jildin9, sprinkler systems 1n cable trays, temp~r~cure activated nitrogen purge in the fluoride cell room, and manual fire extinguishers throughout the

., I

10. plant.

The licensee's insurance underwriter i1,spection \\~as last performed during the second quarter of 1978.

The fire horn and emergency generator are tested monthly.

Nine hose stations are supplied by a 150,000 gallon holding tank and are fed by diesel and electrical pumping equipment which is also checked monthly. Observa-tion of approximatelJ 10 manuul extinguishers revealed that these were inspected monthly.

Emergency teams on each shift have had instruction in the use of self-contained breathing apparatus. Several individual!

on each team have had first aid training.

The licensee stated that there had been neither simulated fire exercis~s nor fire drills since the the last inspection.

The 1 icensee was found to have several documented procedures pertaining to f1re response and to systems operations and inspection.

Posting. Labeling and Reports The inspectors noted that inc:.iming and outgoing shipping containers were labeled as LSA and radioactilie.

Forms tlRC-741, completed upon receipt and transfer of source material~ \\-iere reviewed; and cumpl iance with 10 CFR -l0.64(a) was verified.

The 1nventory report required by 40.64(b) was reviewed.

The inspe~tors noted that documents were posted as requ1red by 10 CFR 19.11, but that no regulations or procedures were posted relating to Part 21. The licensee stated that there were no procedures relating to the reporting of defects. The ~nspect~rs stated that failure to establish such procedures consti~uted noncompliance with 10 CFR 21.Zl(a).

The inspectors noted continuous fencing of the restricted area and access control at the main gate.

1he plane entrance was posted with the information that all areas within the mill may contain radioactive material.

11.

Independent M~asurements A Yiater sample was obtained from tne combined effluent stream at the boundary fence.

The sample will be,,nal"zed for uranium, gross alpha, gross beta, Ra-226, and Th-230.

The analytical results from Idaho Health Services Laboratory will be later compared to the: licensee's results of samples taken at the same location.

12.

Unrs~o1ved items Unresolved items are matters about 'Hhich more infonnation is re~uired in order to determine ~,hether they are acceptable items, items of noncompliance 1 or dev1i.:1tions.

Two unresolved items were identified duri n~ the insper.t icn These items are discussed in paragraphs 5 and 7.

78112~

13.

Exit Interview The inspectors met with licensee management (See paragraph 1) at the conclusion of the inspection on August 11, 1978.

The inspectors su:1111arized the purpose and scope of the inspection and sunmarized the findings.

KERR-MCGEE NUCLEAR t70RP/JPt ~t.

CERT1FlED XA!L - REitR.~ ~ECElP: R.E.QUF.STEO

~r. Cl~n D. Brown, Chi~~

Fuel r1cility 6 Material Safety Branch -

Lf.S. "Suclear Rcgula:.ory Commission Region tv 611 Ryan Pl~za Drivet Suite 1000 Arlington, r~xas 70011 RE:

Llcense No. SUB-1010 Dorket No. ~O-8Ol7 Your l~tter of August 31, 1978, enclosed a Notice oi Vlolati~n and An J.E.

lnspt:>ction Report So. 40-8027/78-0l.

Your lt>tter asks that 1..c respond to these docuc~nts.

The at:~ched dlscus~ion outltnes the actions we are takin~

to correct the infractions cl ~d and review activities already ~ompleted, nr*ar coir,pletion or plann~d.

~e feel char Infraction 1, should hav~ been classified in the b~sic category oi a deiicI~ncv c~ l ss s~v~re c1assfftcation) for t~o re~sons:

(a) because the 2,000 dpn/1OO cm valu~ ln question is ~n action level, not a limit

~hich if ~xc, cded ~eans non-comp1ianc~ ~nd {b) efforts have been taken t o reduce conta~lnation levels as revcal~d in the attach~d discussion.

We also believe th1it lnfractlon (i6 should be reclassified as a defkienc,.Y becDuse action co obtain Che sampling tn ~uestion was in ptogte~s prior to

>our inspection.

The details of this action are tn the attach d di cusslon, We are hopeful that you fJnd this reply a sat isf~ctory response to your conc~rns.

Very truly yours, A

eJ2/?&.y*

~lation 1nd Cont~

!2.. ~2£~

M~nufactur ing and Market i ng WJS:RPL;hw Enclosures

Attachment t~ Letter of September 22. 1978 from w. J. Shelley to Glen 0. Brown.

Infraction l(a)

"At the time of the inspect\\on, twelve workers had not cow1,,leted a res-pirator fitting and training pro9ram prior to the use of respiratory equ,prr.1!ntl a-s -required by Section C of Regulatory Guide 8. 1511.

Th1s ficting a~d training has b~en accomplished for the twelve workers.

We have now incorpordted into our new employee or1,,tation procedures the requirement that a~l uranium workers ~ fitted and trained to use respiratory rrotective equipment prior to their use of such equipment in the operating areas of the pl3nt. This fitting an~ training is dent in accordance with Section C of Regu1atary Cuide 8.15.

Infraction l{b)

"Half-mask respirators are not being tested for fit with irritant smoke, prior to use, each time such equipment is donned as required by Table 1, Footnote f, of Regulatory Guide 8.15".

.J.)

The sampling plant is the on1y area where ha1f-nasks ar~ u~ed for produc-ti on or maintenance type,-,ork.

A retr~ining session has been held for all sampling pl~nt personnel. This training ~ession has been documented.

ln addition, signs have been posted in the sampling plant reminding the employ-ees of the need for the smoke tube test.

Infraction l(c)

"Half-~as~ respirators are used with head straps over the hard hat which prevents straps from lying in their nonnal posilion next to the head as required by Sectioo 13.5 of NUREG-004l1 which is ref~~nced in Section C.S.n of Regulatory Guide 8.15 11 The above mentioned retraining session also covered the proper fitting of the half-mask with the head straps lying in their normal position.

Infraction 2 "Contrary to 10 CFR 20.203(c)(2), the ash recei Yer ~nc1osure, a high radi-ation area in the fluorination area, was not equipped with entrance or access control devices or maintained locked when acc~ss wa\\ not required".

The ash receiver enclosures ha~e been decontaminated to levels which will not require this area to be controlled as a high radiation area. More frequent surveys and decontamination efforts will be used to maintain these lower le~els.

Infraction 3 "Contrary to l O CFR 21. 21(a). approprigte ;,rocedu *e~ have r,ot b<:en adopted that would provide for the P.v~luation and reporting of defects in basic components as defined in S£:.. tion ?l.3 of 10 CFR 21 11 "Procedures, as appropriate, ~'11 be developed to satisfy 10 CFR 21.21.

These will be prepared by CctoLJer 20, 1978.

Infraction ~

License Condition 9 requires that licensed activiti~s be c.e,nducted in 0 ccordance with statements, representat;ons, procedures and conditions stated in the License Application, Appendix A, and Section 2.0 of App~ndix 8 II*

Jnfraction 4(a)

"Duri ng the period October 1977 to August 1978, surface contamination levels in the operating areas of 2he plant exceeded and rer!lained above the control value of 2,000 dpm/100 cm smearable activity as specified in Section 3.4.3 of Appendix A".

Section 3. 4.3 of Appendix A, subsection 2, "Contarni,1ation Control" regard-ing operating areas states: "Routine mcasurernr:nts of surface contamination are m3c!e weekly.... "

11Cleanup activity is perfor~ed promptly when smear-able alpha contamination exceeds 2,000 dpm/100 cm in the operat;ng areas".

Cleanup activ,ty has been and is performed as ccrrvnitted, however, during the period cited, an abnorma ~ frequency of uranium contai nrnent failures has occurred with the construction and start-up of ne'ti equipment installed to expand the production capacity. Repairs are made to stop leakage as soon as possible. Secondary control methods are used to prevent persons from receiving internal exposures of uranium.

These intermittent uranium lea~age problems continue and cc.use the surface contamination. Correction of these unfavorable conditions combined with an improved housekeeping effort will reduce the contamination to more accept-able levels. This wi ll be accomplished as follows:

• 1)

Engineering studies have been conducted and are continuing regarding the prevention of packing leaks and pressure problems within various equipment.

Engineering will be pcrfor~ed to provide additional ventilation con-trol if leak pre~ention methods cannot prQvide the desired containGent.

,3)

Some new equipment has been installed or is on order as described, n items 1-8 of our reply to your I.E. inspection report. More equipment for contamination control will be procured and installed as needed.

4)

Admini strative controls will be emphasized to accomplish more timely detect ion and repair of lec1ks.

F'or example, documentation wi 11 be

\\.

.... ")

I

5) made of correct1ve action ta~en as a result o~ a shif wise inspection for uranium leaks and spills in the oper6ting areas. Pdditionally, our work permit will be audited to improve contar.i*nation control rneasurP.s when maintenance type work h performed on urar *!Jm containing equipment.

A major decontan1nation effcrc shall follow the accomplishment and implementation of the studies and additional cortrols de:cribed above.

The t im table for completion of the corrective measures are (a) Three months to achieve a significant reduction of containment problems. (b) A major de-contamination effort duriny the fourth r.onth and (c) Six months to achieve control wizh only occasional cases where contarninatic7 evels exceed 2,000 dom/100 cm by wipe test.

I nfraction 4(b)

"Annual ora 1 or written tests have not been given to mi 11 workers tn deter-mine their unde standing of radiation protection and uranium loss prevention as specified in Section 2.0 of Appendix B".

This testing will be completed during the next four r:onths. This will be docu~ented. Therefore, annual testing will be done.

lnfract ion 5

License Condition 12 reqt.ires, in part. that soil sar;ples be collected at 6000 foot distances from the rlant in the cardinal corpass directions and analyzed for uranium and fluoride.

Contrary to this rr, 1uirement :

Soil samples have not been collected at 6000 foot distances from the plant in the cardinal compass directions, since the rene.,ed license was issued".

These samples have been collected and sent to the laborJtory for analysis.

Henceforth, each April and October. similar samples wil l be obtained and analyLed.

Infraction 6 "license Condition 15 requires that samples of bottom sediments be obtained at meaningful upstream and downstream points of the plant o~tfal l into the Robert S. Kerr reservoir and analyzed as a means of evaluating t he effect of the liquid plant effluent on aquatic biota.

. Con rary to this requirement:

Bottom sedinent samples have not been obtained and analyzed, since the renewed license was issued".

Arrangements for a consulting group expert in the techniques of this type of samplin9 were made at our Oklahoma City headquarters. :Jrior to your inspection. funding approvals ~ere made on August 24. 1978.

An initial sampling will be accomplished before the end of October, 1978.

On page five of the I.E. Inspection report, No. 40-£027/78-01. it is statt:d:

"The inspectors were unable to clearly determine whlther the licensee*s efforts to provide en~ineering and process controls w re suff1cient to comply

~ith 10 CFR 20.l03(b)(l). The i tem was left unre~olved pending discussion with NRC Licensing."

Additional infomation to aid your determination follows:

l)

2)

3)

4)

5)

6)

7)

As men!ioned on page five, a rotary val\\e has been installed on the redrum hopper. This required replacement of the original hopper a~d installation of the rotary valve, electrical power for the valve, etc.

The valve with the new hopper and drum adap~er were placP.d in service*

on August 21, 1978.

It has reduced spillage in th1s area.

To reduce airborne conta~ination in the denitratirn aret, an AFE h,s been appro~ed for a U01 bucket ele~ator to replace the U01 Redler (CO 3448).

An abnormal number of breakdowns on the UO Redler Cor.veyor has.caused excessive maintenance increasing t~e airborne contamination.

The bud.et elevator was ordered July 21, 1978. It will be installed ~s soon as possible after it arrives, which,snow sch~duled for November.

This will be operated under a slight nega tive press~re to prevent spread of contamination.

A layout has bE-e11 made for re-routing of the WX headers to di vide th~

denitrators so th~t the original units exhaust to the original nitric acid absorber and the e~pansion units exhaust to the expan~ion absorber to provide improved vacuum control to reduce airborne contamination caused by fluctuating pressures.

Conversion Engineering. has been assigned to work with Maintenance and Production personnel to study pac~ing problems (~acking rnaterials, materials of construction, replacement freQuency~ etc.) to improvE dust control on convevors and agitators.

will be working in the field to aid Project Engineering, who was assigned to study th1s problem in the ast ALARA ~eeting held August 16, 1978.

Engineering has designed, materials have been procured and fabrication has already begun on a refeed drum dumping and conveying system to feed redruimed material to the digest bins through a system operating at a negative pressure. This is expected to be placed in service in November, 1978.

As operating experience 1s gained with the bucket elevator (item 2) and the refeed conveyor (item 5) op~rating at negative pressures, i t ts proposed to design and install a buc~et elevator to replace the L-type Redler Conveyors between the uF4 ~eal bins on 1A' and 181 lines and the storage hoppers.

A ventilated enclosure has been provided around the drum dumping equip-ment in the sampling plant. This has resulted 1n a significant reduction of airborne contamination problems at the op~rators work location.

8)

The engineering department will suunit applications for cxpt:nd1ture~

to provide funds for procurc1,1ent of contamination cvntrol equipm~n:

based upon a review of their st1,1dies.

The stt,dies will include th rccoor!ndc~ions of the ALARA colflmittee.

(,)

August 31, 1978 L1eens No. SUB-1010 Kerr-McGee Hucler Corporation ATTN: Hr. W. J. Shelley, 01.-ector Regulation and Control Kerr-McGee Bu11d1ng Oklahoma City, Oklahorca 73102 Gentlanen:

This refers to the 1nspect1on conducted by Messrs. A. J. Everett and C. L. Ca fn of thfs office on August 10-11, 1978. of the acth1t1es authorized by NRC Source Material License No. SUB-1010, and to the discussion of our f1nd1ngs held by He,sn. Everett and Ce1n w1th Messn. 8. E. Brown and C. £. Grossclaude on August 11. 1978.

The 1nspect1on was an examination of the act1vit1M conducted under the license es they relate to rad1atfon safety and canp11anee wtth the Corrm1ss1on*s rule5 Ind regulations, 1nd the cond1t1ons of the license.

Th* 1nspect1on cons1stad of selective eum1nat1ons of procedures and represent.a the records, 1nterv1ews of personnel, independent meuurements and observa t 1 ons by 't.he inspector.

The inspectors also revfewd the action you had taken with respect to t.o (2) items of nonc<np11ance observed during our previous 1nspect1on

• which was conducted June 15-17, 1977.

They ver1f1ed that the corrective 1ct1on ~1th respect to these 1terns was 1a,plemented II stated 1n your reply of July 20, 1977, to our letter dated July 6. 1977.

Based on the results of this 1nspect1on, 1t 1ppeart that cerU1n of your act1v1t1es were not conducted tn full CC1Dpl1ance "1th NRC requtrerlll!nts. as set forth 1n the Notice of Yto1at1on. enclosed herewith.

Thh not1ce h sent to you pursuant to th* prov1sh:,lS of Section 2.201 of the tlRC 11Rules of Practice,* Part 2, Title 10, Code of Federal Regu11t1ons.

• Section 2.201 require, you to sutmtt to thh office, withtn twenty (20) days of your receipt of thh notice, a wrttten atatauent or explanatton 1n "ply 1ncluding (1) correct1va artions which have been taken by you and the results achieved; (2) correcttva actions which w111 be taken to

,vo1d further 1wns of nonec,npl1anee; and (3) the date When full ~Hance w111 be ach1eYed.

I L RIV 0'2... 1

~l~

RJEvercftl/d CLCain 8/28/78 8/Z /78 ti GDB,X>wn 8/ /78 W£VetterX 8/ {,/78 I(\\

tf u a_ *ova t0<1UNt ""'"',.. o,r,ci*, IIH -.,......

/

J:arr~GN MuclMr Corpontton Augwlt 31. 1178 In accordance wfth S.Ct1on 2.790 of the *c *~1n of Prect1ca.* hrt 2.

Tttl* 10. Cod* of Federal leQulattont. a copy of tht1 letter and tt.e enclosed tn1pect1on report will be placed 1n the NltC'* Pub11c Ooc\\alftt Iba. If thh report co~t&1ns a,iy 1nfonat1on that you bel tew to be propr1ttlf'1* 1t ta necessary thlt you *k*

• wrttten a:,pl1cat1on w1thtn twlll~ (20) days to thh off1c* to withhold IUCh 1nforaat1on froa publ tc dbtlosurt. kty 1uch app11cat1on auat h*ch,de

• full 1t&ttant of the reasons 1t h clatNd that the fnfot"Mtton 1t proprietary. It should be prepa.-.d 10 thlt proprietary 1nfonn1tton tdenttfted h contah.S tn a aeparate part of tht dC'C~t. 11nce the appl tcatton. ucludtng thh separate part. w111 aho be placed fn the,ubltc l:k,c"""1t ~. If..

do not hear froa you tn thh "gird w1th1n ~

1pectfttd perfod. the npor-t wtl 1 be p la cad fn thl Pub 11 c Doa.9ln t llooa.

Should you h1v1 any questions concemf~ thh letter, pl1u1 let

• know.

Enclosures:

1. Hotfce of Vfo1at1on S1nctrtly.

Glen D. 8t"'OWI, 0,1ef Fuel F1cfltty and Matr111 Stftty Bnnch

2.

IE fn~pectton Report No. 40-8027/78-01 bee w/enel to R produet1on Unit for Distribution 9 / ~ / j -,}

AO/f fMS I

~P-IE FILES MSS:FC&MS SS :fCSL bee w/ ncl held for 20 days

• CtNl RAL Fl LES POR:HQ LOCAL PDR NSJC I

Septcmb~r 22, 1978 CERTIFIED MALL - RETUlCI RECEIPT REQUESTED

-tr. Glen 0. Brown, Chief Fuel Facility & Material Safety Branc~

U.S. Nuclea~ Regulatory Co'lI!llission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 RE:

License No. SUB-1010 Docket No. 40-80:!7

Dear Mr. ~~own:

Your letter~: August 31. 197e, enclosed a ~at1ce of Violation and an I.E.

Insp 0 ccion Report No. 40-8027/78-01.

Your letter asks that ve respond to th~se documents.

The atta~hed discussion outlines the actions ve are takin~

to correct the inf:actlons cited and review activities already cofflpl~ted, near c0t11pletion or planned.

~e feel that tnfraction J4 should hnve been classified in the basic category of a deficiency (u 1 ss sovere classifica:ion) for two rensons:

(a) because the 2,000 dpm/100 cm value in quest1on is an actio~ level. not a limit

~hich if exceeded means non-compliance ~nd (b) efforts hnve b~en tak~a to reduce contaminotion l~vels as revealr.d in the attached discussion, We also believe that I~fract!~n 16 should be reclassified as a deficiency becc11.1sa action to obtain the st*mpl.ing in question was in pro~ress prior to your inspection. n,e details oF this action are in the attached discussion.

We are hopeful t hac you find thls reply a satisfactory response to your COOCl'!rnS.

Endosures

7.

Attachment to Letter of September 22, 1978 from \\./. J. Shelley to Glen D. Bro*,-m.

Infraction l(a)

'1At the time of the inspection, t1-1elve i,.10rkers had not l".Ompleted a res-pirator fitting and truining program priot* to the use of respiratory equipment, as requir d by Section C of Regulatory Guide 8.15".

This fitting and train~ng has been accomplished for the t\\'lelve 1*1orkers.

We have now incorporated into our new employee o,ritnt~tion Qrocedures the requirement that all uranium workers be fitted ana trained to use respiratory prot~ctive equipment prior to their use of such equipment in the operating areas of the pldnt. This fitting and training is done in accordance with Section C of Regulatory Guide 8.15.

Infraction l(b)

"Half-mask respirators are not being tested for fit with irritant smoke) prior to use, each time such equipment is donned as required by Table 1, Footnote f, of Regulatory Guide 8. 1su.

The sampling plant is the only area where half*masks are used for produc-Lion or maintenance type work. A retraining session has been held for all s~mpling plant personnel. This training session has been documented.

In addition, signs have been posted in t'ie sampling plant reminding tl1e employ-ees of the need for the smoke tube test.

Infraction l(c)

"HaH-mask respirators are used with head straps over the hard hat which prevents straps from lying in their nonnal position next to the head as required by Section 13.5 of NUREG-0041, which is referenced in Section C.8.n of Regulatory Guido 8.15".

The above mentioned retraining session also covered the proper fitting of the half-mask with the head straps lying in their normal position.

Infraction 2 "Contrary to l~ CFR 20.203(c)(2), the ash receiver enclosure. a high radi-ation area in the fluorinacion areal was not equipped with entrance or access control de~ices or maintained locked when access was not required".

The ash receiver enclosures have been d~contaminated to levels which will not req*Ji re this area to be controlled as a high radiation area.

More frequent surveys and decontamination efforts 1-1il 1 be used to '"aintain these lower levels.

Infraction 3 11Contrdry to 10 CFR 21. 21 (a), appropriate procedures have not been adopted that would provide for the evaluation and reportir19 of defects in basic components as defined in Sectfon 21.3 of 10 CFR 21".

"Procedures, as appropriate, will be developed to satisfy 10 CFR 21.21.

These will b~ prepared by October 20, 1978.

Infraction 4 "License Condition 9 requires that licensed activities be conducted in accordance with stJtements, representations, procedllres and conditions stuted in the license Apn1ication, Appendix A, and Section 2. 0 of Appendix B".

lr,fraction 4(a)

"During the period October 1977 to August 1978, surface con~amination levels in th~ operating areas of zhe plant exceeded and remained above the control value of 2,000 dpm/100 cm smearable activity as specified in Section 3.4.3 of Appendix A.

Section 3.4.3 of Appendix A, subsection 2, Contam1nation Cor,tro1" regurd-ing operating areas states: "Routine measurements of surfnce contamination are made weekly....

11 11C1eanup activity is perfor~ed promptly \\o1hen smear-able alpha contamination exceeds 2,000 dpm/100 cm in the operating areas".

Cleanup acti 1ity has been and is performed as committed, ho\\'iever, during the period cited, an abnormal frequency of uranium containment failures has occurred with the, Jnstruction and start-up of new equipment installed to expand the production capacity.

Repairs are made to stop leakage as soon as possible. Secondary control methods are used to prevent persons from receiving internal exposures of ura11ium.

These intermittent uranium leakage problems continue and cause the surface contamination. Correction of these unfavorable conditions combined with an i proved house~eeping effort will reduce the contamination to more accept-able levels.

This will be accomplished as follows:

4)

Engineering stud*es have bePn conducted and are continuing regarding the prevention of packing leah and pressurf problems within various equ i prncn t.

Engineering will be performed to provide additional ventilation ~on-trol if leak prevention methods cannot provide tie desired containment.

So~e new equipment has been installed or is on order as described in items 1-8 of our reply to your 1.E. inspection report.

More equir,ment for contamination control wfll be procured and installed as ne~de~.

Administra:ive con:rols will be emf)hasi:.:~d to acco1::plish more tirr:ely detection and rc;>air of lea;.s.

r:or e<a111ple, documentation *.-1ill be

made of corrective action ta~en os a t*csul t of a shi ftwi se inspectfon for uranium le<lks and spills in the operating areas. Additionally~ our work pennit will be audited to improve contamination control measures when maintenonce type work is performed on uranium containing equipment.

S)

A major decontamination effort shall follow the accomplishment and implementatic.,n of the studies and additional controls described above.

The time table for completion of the corrective measures are (d) Three months ti..,

to achieve a significant reduction of containment problems, (b) A major de-1/

contamination effort during the fourth month and (c) Six months to achieve control wifh only occasional cases where contamination levels exceed 2,000 dpm/100 cm by wipe tesl.

In:*raction 4(b) 11Annu,1l oral or 1*1ritten tests have not been given to mill v,orkers to deter-mine *heir understanding of radiation protection and uranium loss prevention

1s specified in Section 2.0 of Appendix B".

This testing will be completed during the next four months.

This will be dJcumented. Therefore, annual testing will be done.

Infraction 5

~License Condition 12 requires, in part, that soil samples be collected at 6000 foot distances from the plant In the cardinal compass directions and analyzed for uranium and fluoride. Contrary to this requirement:

Soil samples ha*,e not been collected at 6000 foot distances from the plant in the cardinal compas~ directions, since the renewed license was issued.

These samples have been collected and sent to the laboratory for analysis.

Henceforth, each April and October, similar samples will be obtained and analyzed.

Infrilction 6 "License Condition 15 requires that samples of bottom sediments be obtained at meaningful upstream and downstream points of the plant outfall into the Robert S. Kerr reservoir and analyzed as a means of evaluating the effect of the liquid plant effluent on aquatic bt ~a.

Contrary to this requirement:

Bottom sediment samples have not been obtained and analy:ed, since the renewed license was issued".

Arrangements for a consul ting group expert *n.he technique!: of this type of $amplin~ were mad~ at our Oklanoma City headquarters, ~rior to your inspection. Funding appravals w~re made on AJgust 2~. 197S.

An initi~l sampling *,1ill be accomplished before the end of October, 1978.

On page five of the I.E. Inspection report, rlo. 40-8027/78-0l I it is stated:

"The inspectors we,*e unable to clearly determine 1-1het.her the licensee's efforts to provide engineering and process controls were sufticient to comply with 10 CFR 20.103(0)(1).

The item was left unresolved pending discur.::ion with ti RC Licensing.

11 Additional infonnation to aid your determination follows:

1)

2)

3) 4}

5}

6)

As mentioned on page five, a rotary valve has b0 ~n installed on the redrum hopper. This required replacement of the original hopper and installation of the rotary valve, electrical power for the valve. etc.

The va1ve with the new hopper and drum adapter were placed in service-on August 21. 1978.

It has reduced spillage in this area.

To reduce airborne contamination in the denitration area, an AFE has been approved for a U02 bucket elevator to replace the UOJ Redler

{CO 3448).

An abnormal number of breakdo1vns on the UO Redler Conveyor has caused excessive maintenance increasing t~e ~irborne contamination. The bucket elevator was ordered July 21, 1978. It will be installed as soon as possible after it arrives, which is now scheduled for November. This will be operated under a slight negative pressure to prevent spread of contamina:ion.

A layout has been made for re-routing of the NOX headers to divide the denitrators so that the original units exhaust to the original nitric acid absorber and the expansion units exhaust to the expansion absorber to provide improved vacuum control to reduce airborne contamination caused by fluctuating pressures.

Cleon Treet, Conversion Engineering, has been assigned to work *11ith

~~intenance and Production personnel to study packing problems (packing materials, materials of construction, replacement frequency, etc.) to improve dust control on conveyors and agitators. Hr. Threet will be working in the field to aid Mr. Walt Spencer, Project Engineering, who

\\'tas assigned to study this pi'oblem in the last ALARA meeting he1d August 16, 1978.

Engineering has designed, materials hav~ be0 n procured and fabric.ation has already begun on a refeed drum dumping and conveying system to feed redrurr.med material to the digest bins through a system oper11ting at a negative pressure. This is expected to be placed in service in November, 1978.

As operating experience is gained with the bucket elevator (item 2) and the rcfeed conveyor (item 5) operating at negative pressures, it is proposad to design and install a bucket elevator to replace the L-type Redler Conv~yors between the UF4 seal bins on 1A1 and 1 8' lines and the storage hoppers.

7)

A vent*iuted enclosure has been orovided arcund the drum dumping equfr-ment in the sampling plant. This has resulted in a signiricant r~duction of airborne contamination problems at the oper~tors work location.

8)

The engineer ing depurtrn1,;,nt will submit application!.i for expenditure!>

to provide funds for procurement of contamination control equipment based upon a review of their studies. The studies wi)l ;nclude the rccomrnendltions of Lhe ALARA committee.

License No.

SUB-1010 Notice of Violation Based on the results of the NRC inspection conducted on August 10-11.1978, certain activities appear to be in noncompliance with NRC regulation> and the con~itions of your License No. SUB-1010 as indicated below:

1.

Contrary to 10 CFR 20.103(,:). use of respiratory protec.tive equipment was not in accord with Regulatory Guide 8.15. "Acceptable Programs for Respiratory Protert1on~ in that;

a.

At the time of the inspection, twelve workers had not completed a respir~tor fitting and training program prior to the use of respiratory equipment~ as required by Section C of Regulatory Guide 8.15.

b.

Hdlf-mask respirators are not being tested for fit with irritant smoke, prior to use, each time such equipment 1s donned as required by Table 1. Footnote f, of Regulatory Gufde 8.15.

c.

Half-mask res?irators are used with head straps over the hard hat which prevents straps from lying in thefr normal position next to the head as required by Section 13.5 of NUREG-0041. ~nich 1s referenced in Section C.8.n of Regulatory Guide 8.15.

This fs an infraction.

2.

Contrary to 10 CfR 20.203(c)(2). the asti rece\\ver enclosure, a high radiat1on area in the fluorination area. was not equipped with entrance or access control devices or maintained locked when a~cess was not requ ired.

This is an fnfraction.

3.

Contrary to 10 CFR 21.2l(a}, appropriate procedures have not been adopted that would provide for the evaluation and reporting of defects in basic components as d fined in Section 21.3 of 10 CFR 21.

This is an infraction.

4.

License Conuitton 9 requires that licensed actt~itiei be conducted in accordance wfth statements, representations, proc dur sand conditions stated 1n the License Application, Appendix A, and Section 2.0 of Appendix B.

Contrary to this requirement:

a.

During the period October 1977 to Augu~t l978t surface contamina-tion levels in the operating areas of the plant exce~ded and remained above the control value of 2.000 dpm/100 cm smearable activity as specified in Section 3.4.3 of Appendix A.

b.

Annual oral or written tests have not been given to mill workers to detennine their understanding of radiation protection and uranium loss prevention as specified in Section 2.0 of Appendix B.

This is an infraction.

5.

License Condition 12 require~, in part. that ~oil samples be collectid at 6000 foot distances from the plant in the cardinal com ass directions and analyzed for uranium and fluoride. Contrary to this requirement:

Soil samples have not been collected at 6000 foot distanc~s from the plant in the cardinal compass directions, since the renewed license was Issued.

This is an infraction.

6.

License Condition 15 requires that samples of bottom sediments be obta1ned at aningful upstream and downstream points of the plant outfall into the Robert S. Kerr reservoir and analyzed as a means of evaluating the effect of the liquid plant effluent on aquatic biota.

Contrary to this requirement:

Bottom sediment sam~les have not b en obtained and analyzed, since th~ renewed li~ense was issued.

This is an infrattion.

License ~o. SUB-1010 UNITED STATES NUCLEAR RE.GULATORV cow.m:s10N REGION l'J 111 lilYANPL.AZAORIVE,SUlfE 1000 ARLINOTON, TEXAS 76011 0L:tObt>r 13, 1978

~err-~cGee Nuclear Corporat1on ATTN:

Mr. W. J. Shelley, Director Regulation and Control Kerr-McGee Building Oklahoma City, Oklahooia 73102 Gentlemen:

Thank you for your letter of September 22, 1978, in resp~nse to our lett£r and the attached Notice of Violation, dated August 31, 1978.

As a result of our review, we find that additional information as discussed with Mr. Shelley by telephone on October 10, 1973, is needed.

Relative to Item 1 of the Notice of Violation you stated in your letter that retraining sessions had been held to inform current employees of proper irritant smoke testing requirements and proper half-mask head strap use.

Please indicate to us actions which you plan to avoid further similar items of noncompliance relating to other employees.

Specifically describe your pro9ram for assur-ing that employees who are later assigned to use tt11s equipment have com-pleted the designated training.

Relative to Items 5 and 6 of the Notice of Violation you stated in you~

letter that so11 and bottom sediment sampling will be accomplished in accordance with License Conditions 12 and 15. Ple3se indicate to us actions which you plan in order to avoid further similar acts of non-compliance.

Relative to Item 4(,*) you stated in your letter that six months would tle required to achieve *ont;imination control 1Jrder levels of 2,000 dJ;.(11/100 cm2 b:, wip~ test. Since 1.'iis control level was originally stated b:, you in your license application 1 we assume that you were confident that such control could readily be achieved. A six-month compliance schedule therefore appears incongruous. Please subrr,it a revised, shortened sched~le for attaining compliance in tnis area.

CERT.F!ED :*\\Ail - RETlJR~l REC::I?T ?.EQUESTEO

....., 0 11 ~,

I~, ~

Kerr-McGee ~uclear Corpordtion October 13, 1978 You request~d that Itens 4 and 6 be reclassified in the category of "deficiencies" rather tnan 11 infractlons.

11 A "deficienci1 is defined as an itmi of noncompliance in which no undue expenditure of time er resources to implement corrective action is reqll,:-e~

Examples 1,,,,,*Jld include such items as nonconpliance with records, pusting, or labeling requireients which are not serious enough to amount to infractions.

Since you indicated ir your letter that corrective actions for rtens 4 and 6 will be (or have been) completed only dfter a substantial period, reclassification is unjustified.

You should submit the above requsted infomation,,.,1thin ten (10) days of your receipt of this letter so that we can continue our review of this matter.

Sincerely,

,'),,.

. f'

}z;, Lr/;/{;, /?z ( t 1,, i-Gren o. 8r-own, Chief Fuel Fcc1iity and Material s~fety Branch

~

KERR-MCGEE I

October 19, 1978 CERT fHEO '-!.\\IL -

RETt:P"'l R.ECEZ?t REQt:£S!rn Mr. Cten D. Br*vn, Chief Fuel Facility & ~nc~ri3: SJf~ty Br1ncn L'. S. Sudcar r.ei;ul cory Cot:uni.sslon Regi:,n !V 611 Rvau PLa~u Drive, Suite 1000 Arlingcon, Texas 76011 Your letter of October 13, 10'78, u~ks for adJitionnl inror.::ac1.on tn re-spouse to your earlier lecter ui Aususc Ji, 1978.

The rollowing discussiou answ~rs your qucsc!ons:

New sumpiing plnnt cmplo>"t)i!S or ochers.assibned to th.? sampl:ing plnnt will b~ c** *Lned by health ~nd s,fe~y pdrsnn~el co administer ch~ smoke tub~ t~sc p ron:ptly af c,~r donn:i:1s thel:: half-mask and to we<1r :.he m.tsk propt:dy to JSSure chat thu hcud scrBpa aru in the correct position.

Sa~pling plant r.upervi.sors wi.11 be l:>pt!clnlly instruct~d to enforce the proper ~<1Jt1.ng.:md testing o: t~e halr-~3sk =~spira:or.

Soll sa~pling ac the ~.ODO :eet discancc point from the pl~nt hai b~~n aadecl to our listing f :*uti~a environ~ental sacples.

L~s:ing chis on che schedule will issurc :hat these samp:es are ob:ained uc chd proper dme.

The rber botrom supling prog:-am has b**er-. placed under the -upervbion ~r a C.IJ:-,su!.canc, Dr. 1ro:* Dords of Aql:acic l.He Consulcanc Company.

"r. Dorris hnll l3fiu=e ch~c this ~ompling ts done pr,perly and in a t!mely manner.

the in1tt 1 sn::-pltng i..:as conducted on Occobt?1.* U,, L9-8.

This sampling re~uiremen: will Jlso be \\isteJ on :ne en;!ronmencaL samplina schedul~.

fhe ci:nt! till, t.:i [or co'"iplecion of co~recti'J1t n*e.isure co nchi *~V*-2 beccer c.0.1-tJmi:iation conc:-ol is redi.:;ed to -.he: i'!mi ot the fot r':h r.:onth Lnsteil.d of sf;,

months as in~1C3~ei in our ~ei:ter of September 22, 1()78.

t\\...ire currentlv rna~tng ext: etf r:~ to reduce con':a~1nat10n levels and Rre making me3sur-able ~:ogress chrough re-*-phasis er sdminiscrattvc contr~: pr1cc1c~3.

License ~o. SUB-10 o U'~ITEDSTATE UCL Ml R CULATORY CO',I\\IISSIO, REOION IV 011 Rv.-.r-, Pl.:\\l'.A ClRIVI! SUITE I o\\A l.lNG'rOt-, T \\AS ~au 11

,o*Je ber 7 ~ 1978 er** -.. cGee :uc 1 ear Corpora: ion An*::

'r. W. J. She 11 ey, D free tor Regul~t,on and Control Kerr-~~Gee Building Oklahoma Ci ty, OklahJma 73102 Gentlemen:

Thrnk you for your let~ers dnted September 22, 1978 and October 19.

19,8, in response to our letters dated i\\uguc.t. 13, *979 and October 13,

1978.

.,Je have no fur tner quest i ens at tni s time and,,111 re\\! 1 ew your cor *ecti'le ect ion durir,g a future inspection.

Sincerely,

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.

40-8027/78-0l Licensee:

Kerr-McGee Nuclear Corporation Kerr-McGee Center Oklahoma City, Oklahoma 73125 License No.

SUB-1010 Docket No.

40-80i7 Facility:

Sequoyah Uranium Hexafluoride Conversion Facility Inspection at: Gore. Oklahoma Inspection conducted: August 10-11.1978 Inspectors:

(' -P C,q,,"',_

~

n, R:!""'0"""0+1..... a t-f.... o-n--..-Sp_e_c-=-i-al'*1.-s""'t------*

R. J. Everett, Rddiation Specialist

/7'

a.

(Closed) roncompliance (40-8027/77-01): Th1s item involved failure to conduct monthly audits of health physics programs by facility manag nt required by License Cond1tion 8 of SUB-1010.

This license condition w s modified in the ren wed licen c issued Octob r 1977.

b.

(Closed) oncompl\\anc (40-8027/77-0l) :

This it<?m involv d failure to post radiat,on areas.

The insp ctors v r, id proper posting of radi tfon areas durfng the plant tour.

c.

(Closed) Unr solv d It*m (77-01/1) ~ Th1s it m involved the use of a complianc c rttficat issu d to Union Carbide (AEC-ORO 6273-48/AF) as authority to sh p type 8 qu ntitf s of UF6 fn a co"tain rd scrib d as OR0-651, Model 48x.

Th license h s now rec 1ved complianc certificate 16273, issued by the t~RC on July 29, 1977, and now f,lly complies with 10 CfR 71.12.

3.

Org n1zatfon and Admtn1~ ration Of cuss ions with Hccnsee management establish d the fo11ow1 ng corpor11te and facility organtzat1on on the dates of the inspection:

Ct>rporate, rgan Moor, Pr sid nt, K **r-McG Nuclear Corporation R. P. Luke, Vic Pre id nt, Manufacturing & Marketing G. J. S1n'e. Corporat H alth & Sarety Coordinator W. J. Sh IT y, Director, Nucl ar R g,,lation & Contra Sequoyah racilit1.,

8. E. Brown, General Manager, Nuclear Manufacturing C. E. Grossclaude, Manager, Health Physics & lndustrial Safety J. W. Craig. Manager. Conve1sion Engineering L. H. Harrison, ManaQer, Arlminfstration & Accounting

'The licensee stated that the facility staff is comprised of about l48 employees,. which includ s about 78 1n production. 40 in maintenance end 30 salaried wor~ers.

4.

facilities and Egujpment The inspectors toured the plant and the liquid effluent retention areas on August 10, 1978, to observe op rations in pr~gress and verify that equipment and facilities ~ere in accordance with app1ic4ble license requircmenls. The licensee stated that the plant capacity had been doubled to 10,000 tons per year contn ncing April 1978, as author1ted by a rim *w 1 icense date11 October 1977. lhe 1 fcensee stat d that the plant operating schedule was twenty.fo,r (24} hours per day, seven (7) days per week.

During the plant tour the 1nspec r veri fi d that corr*ective action had been m 1ntained regarding the posting of radiatiou areas. an 1tem of noncompliance from tie June 15, 1977, inspection.

The pl nt was observed to b operating and housekeeping was not d as be1ng poor.

n1c 1 fcC!ns

~lated that this 1,;0ndi tion was due in large d gree to the recent plant oodtf1ca ionr. n cec nry to incr asc production cap1city.

A tour of the waste pondlrtg areas revealed that a pit harl b n dug for bu, i l of fluoride sludge ul the south side of the exclusion area.

Tho lfc nsee indicated that ftn additional liqufd pfflu~nt retention pond was bing pl nncd for construction outh or the exclusion area frnce.

5.

Int rnal Exposure Control lh 11c nse 's air sampling program is described in the License Application. Appendix A.

Liens records listed 45 airs mplfng 1

tons in wor locattons within th pl int.

These s mple r

c I d each 8-hour sh1f and anulyzed t*adiometrical ly for total a1pha emfss fon after 4-hour delay. £ach worker is rcqufred to tabulat his wo-r

• time 1n each area.

Th HPC*hour xposure 1s then c 1culated on sev n-d y exposure p riod.

Th license stated th t air sampling 1n th solvfnt cxtractton hulldin had be n tetmfn~tcd.

s inc results obtc1in d ov r many yf.iiH'S of operat Ion h d shown 1r act1vittcs in this ar to be le s that 2si of 10 CFR 20, A~pcndtx 8, Tabl l, limt ts.

.a

-5*

A review of air sampling data revealed many areas in the plant where airborne radioactivity conc~ntrations exceeded Part 20, Appendix B.

Table l, limits. [xposure records indicated no evidence of overexposure to personnel. This was achieved by limiting occupancy and/or utilizing respiratory protection equipm nt. Daily Radiological Status Reports l'isting air sample results greater than 0.5 MPC ~ere reviewed.

These reports were noted to be distributed to various pla~t and corpora e management personnel. Process engineering controls

h.

~een implemented to reduce airborne radioactivity concentrations, but concentrations were st111 recorded above those that would delimit an afrborne radioactivity ar a.

A rotary valve had been instal~ed on the re-drum hopper in the sampling plant and additional ventilation had been installed.

The licensee stated that several other measures had been ~tudied, but none of these had yet been fmplcmented.

Ihe fosp.. ctors were unable to clearly determine whether the licensee's effo,.ts to provide engineering nd pl"Ocess controls were sufficient to comply with 10 CFR 20.103(b)(l). The item was left unresolved pending discussion with NRC Licensing.

The 1 icensee stated that a rcspf ratory protect for, proc ram has been established in accordance with Regulator"y G~id 8.15.

Internal exposure r cords were found to apply protection factors for those personnel wearing r spirators. A polydispersc OOP man-test system with a fitting camber has b en used in conjunction wfth the pr"O!Jram.

Records 1ndicat d hat personnel h d rec ivcd m dical exruninations including lung dyn mies test~ as a part of the p,ogram.

Copies of written e 1m1nations relating lo respiratory protection were contained in employ e, cord files. Comprehensiv writl n procfdures w re found describing th program.

Ovring the plant tour. fnsp ctors observed that ha1f'-mask rcspira ors w re worn wi h head sttaps over hard ht helmets and th t irritant smoke t sting was not performed, prior to use. ach time respirators w re donn d.

Th licensee also fndic d that tw lve (12) wor~ r, who raceived llow nee for respir tor us

• h d not completed the resp1r tor fitting and te ting progr m.

lh fnspectors slated that these items cons ituted noncomp11oncc with 10 CFR 20.103(c).

The licensee's bioassay program 1 d scribed tn S ction 3.4.2.*

Appcndh A of the pplicat1on.

Th 1n p ctors' di cussions wtth the l icense and a rev! w of perttn nt r r.ords established that th program being cond cted 11 s as described 1n th application.

Th bf-nw:mthly urinalysis sch dule for plant work rs 1s d 1gn d ta rronitor the controls fmplcmented for routtno ~rker c pour. lh 1n p ctors noted som data 1n xc ss of 20 mfcrog, m~ pr lit r ct1on 1 vel and 10qu1red a to th licensee's evalu~tion.

lh lien stat d that 1n each case tho worker was r str1cted from furth re posur until th n~xt Moassay indfcat d normal levals. The 11c n e tat d furth r that som of the highs mples may have been contamin1tcd. The insp ctor not d that the bioassay laboratory did not, in two in~tances, report levels in e cess of the action lev 1 in a timely manner, sufficient to allow re ampling to confirm the result from en acute exposure standpoint.

However, once the l1cens was infonn d, samples were coll cted and theses mples yield~d nonnal values. The licensee stated that acute e*po~ures should be readily 1dentifi d so that more fr quent sampling can be conducted, and d1scussions uld be held with th bioassay laboratory 1n ord r to expedite the r porting of data.

license r cords rndic ted th t ~ vivo lung counting is p rfonn d by a

ndor es d scribed,n t e Lien e Application, Ap? ndix A. A r vi w of curr nt d ta revealed nor sul 1n cess o 10 CFR 20.103( )

1 lmi ts.

Th insp ctors noted h the license doc m nt d alpha contamination surv y data for appro ima ly 100 points within the pl nt. Surveys w re doc ntcd as b ing perform d w ly. S ction 3.4.3 of Appendix Asp cifi s th top ra 1ng ar as will be cl ned so as tor main blow 21000 dp /100 cm smear bl activity. Surveys of th oper t ng ar s w r no d to xc d this limit dur1ng th p riod Oc ob r 1977 to August 1978.

Th insp ctors ated thnt f 11ur to maintain con minat1on 1 vcls b lo th1 l1mit cons i utcd nonco pl1anc with L1c n e Condition 9.

6.

Ext Con rol

7.

Lie r

s ind,cat tat film badg s are provided to all wor n

nth c ng.

rnal xposure da a was revi w d and p

s w o d In s of 20.101 limit.

The 1nsp ctors conf1rm d th t xt rnal r diation urv ys h ve been m d mon hly l n1n t n (19) d s gn l d locations. Masur m nts

• high 1100 mR/hr (cont ct) in th ash r c 1v r enclosure w re no d.

Th whol bod_y dos r wfthi n this ar a w s h1 gh r th n 100 mR/hr.

nd th raw appropri t ly post d as a htgh radiation area.

t r a was not u1pp d with entrance or cc s

s 1nt 1n lo d wh n cc ss w s not r qu1r.

s d th t i1 to provid control devtc or con ol tu noncompl nc with 10 CFR 20.203(c)(2).

He

's nv1,*onm n1 oring progr 1 d crib d pplic tion r peclfled In Lien\\ COndft1on The liquid fflu nt tr am from the plan fs continuously s mpl d at th site bounJary.

ily grab s mples arc an lyzed for uranium.

fluorid

• nitrate. pH, tnd t mp ra ur.

~thly c0!!1pos1t s re an lyz d for uranium, gross alph, gross b ta, ni rat. nd fluorid.

Quart rly anal ses are p rfonn d for R -226 and Th-230.

All radio-log,c l data w r ls than the applic~bl Par 20, App ndix B, labl Jl. valu s. A teview of nonrad1ologic1l pararn t rs r v led no upw rd r nding.

An ly s for fluor1d, uranium. and nt rate ar p rforn d at th quoy h Facility. An lyses for* gross alpha.

gross b

• radi m, nnd thorium rep rform d t the rr-Ge r chnic t c nt r, O tanom City.

Surf c wat r i col1 ct d nd yz d from th Ar~ nsas, J)l,no;s.

nd S lt Forl riv rs and thr by ponds s d scrib din th lie nse pplic t1on. Ground r 1 c c

m four (4) s tllni asin itor (1) res1 n

1. and thfrty*nin (39) ra fi pond t

lls. Cone s w r found to b b low lie bl C'

r unr str1c

s.

n 11 combustion burn1 n

d t

a t

o on f

fl s

i h

b o

a h

burials t

n t1on.

A1 r mp l I ng is p r for d s, nd s ; at four (4) lo tions with c

a riv

5) loc t1ons o -si S

for gross alph rid fluorfd.

bound r

• Th-230, nd

-22. Data fo to w 11 b 1ow appl ic bl PC ta u d by th 11c ns tr r

fl for co 11 ioing of gross lp on n t d the boun ry s mp 1 r 1 n i n di r n 1 um

-2 2,

nC1 lh-2 a

A1 l1c o 14 d to 1

t p nuc t cks should b p

to c n df tton was not c

t h

olv d p ndtng d

w tng.

£ngfo rinp i

1n o.-d r to eon irm th th pl nt building und (1

ch ng pr hour r quir d by

\\1c ns Cond

8.

( L1cens Condition 12 require that soil and v~g tation samples be coll cted at 1000 foot and 6000 foot distances from the plant in the cardinal compass point direct on and that they be analyzed for ur n1um and fluoride.

The inspector *tated that contrary to th1s requir ment so11 samples had not been obtained at the 6000 foot distances, sine the renewtd license had be n 1ssu d.

The insp ctors stated that failure to obtain such samples constituted noncomp11ance with License Condition 12.

L1c n e Condition 15 requires obtaining nd analyzing samples of bottom sed1m nts at m an1ngfu1 upstream and downstr m points of the plant ou fall nto the Roberts. Kerr reservofr. as am ans of val~ t1ng the effect of the liquid plant fflu nt on a uatic biota.

l 11r. ns tated tat thi

~ mpl1ng program had not be n 1n1tiated sine th r new d liens w s issued.

Th insp cto, r sp nd d that failut o obtain sue ampl const,tut d noncomp1i nee with License Condition 15.

R ports of we ly. monthly, and quart rly ud ts w r r viewed and found to b performed a r qu1r d by App ndix A.

Oocum nt d m1nu es of sf ty,r. tfngs wer also review d. Licensee tra1nfng actJvit1es a, d tail d 1n app nd1c s of the Uc nse AppHcation. N w l'mploy es r c 1v t hour of ety training and a saf ty handbook at tim of hir. A cond training scss fon of t m hours duration fs provfded within s vcral cks of hir. ih 1 ic nsee tated th t f le ploy s ar instructed int cont nts of Regulatory Gu1d 8.13 and t sign tory v r1ficat1on of this instruction 1 r ufr d.

S ction 2.0 of App ndh 6 t ts hat r** rs w1l1 b t t d annu ny to d t nn1n thctr und rstanding of rad\\ t1on prot ctton and uran1u lo~s pr v ntton. lh license tated that such t tin h d not b n pr orm d.

Th ltc ns e was tnform d by the tnspector that faiJur to admin1st r uch t ;ting constituted noncompli nee w1th Lien Condition 9. The insp ctors 1nterv1ew done worker and d t nn1n d that her und rstaniing of th radiological h zards was ufffcient to compJy wfth 10 CFR 19.12.

g.

(

Plan111 ng & Fi re Protect ton l

s rg ncy plann1n nd fir protection progr1m ar d

Ap dh A.

f1r rotectfon program 1nc)ud s t

ct t d foam ray 1n th SX Bufldfng, sprfnkl r bl tray, rat tivated n1trog n purge 1n the f

room, and manua 1 rt t 1ngu1 h r throughout th

( pl nt. lh license 's ir,surancc und rwrHcr inspectton was la t p rtorm d during th second quarter of 1978.

Th fire horn and me,.gency g nc, ato,* are tested monthly. Hfn hose sta ions are

• uppli d by a 150,000 gallon holding t n and are fed by di sel 1nd el ctrical pumpfng equipment which is al o checked monthly. Observa-t1on of oppro trnat ly 10 m nua\\ extfngui$h rs r veal d that thes were in p cted monthly.

Em rgency teams on each shfft hav had 1nstructfon

• the use of eJf-con alncd bra h1ng app ratus. S v ral 1ndiv1duals on ch tam have had first aid training.

Th liens stated that th r ad b en neith r s im 1h t d fir c rciscs nor* ff re dr'f 11 s sf nee the the last inspection.

The 1 \\c ns e was found to have veral docum nt d proc dur spraining to firer spons and to syst sop rations and insp ction.

10. posting, L orts.

11.

12.

insp c or no cd ht incoming end outgoing shipping contain rs lab 1 d a LSA a11d r dioac:

fonns NRC-741. complet d upon ipt nd tr n of sourc

r1al, 1

d; and complianc wHh 10 CFR 40.6 was vcr1 The 1 r

ort. required by 40.64(b) was r v

d.

1h f

to,..s no d u s

r post d qulr 10 CFR 10.11, but that no on o oc ur s post lat ng to Par T

11c t

t t re~ r no proc d r ht1ng to th r

g o

. l ins ctors st t d th 11ur to s b u

pro cont t d noncomplianc with 10 CFR 21.21( ).

lh 1nsp ctors no ed con inuou f nc1ng of th r strict d ar and cc ss control at the ma1n gat. lh pl n ntrance w spot d with the rnfonnatton that 11\\ ar a within th mill m y conta In radfoactiv mat r1al.

Aw t p1 wa n d from combfn d fflu nt tr am tt th nolyz~d for ur n1um, gros alph

• analytic 1 r uJts from Idaho bo nd c.

l h p 1 w 111 s

-226, Th-230.

t v

s L ry wl l 1

pl s at th Ur solv d 1t s or m tt r in ord r to d nnin w1, th none plfancc, or d v1atlon.

during th 1n p ctlon. 1h nd 7.

tr comp rd to th 11c n$

1 location.

bOut which onn tion ts qu1 r d t1y r 1t H

o Two unr s s

id n f i d 1t r

1n grap 5

10-

13. Exit Interview The inspectors met with licensee management (See paragraph 1) at the conclusion of the inspection on August ll. 1978. lhe fnspectors sufMlarized the purpose and scope of the inspection and surrmnrizcd the findings.

Jun, 25, 1979 tiCfflH UJ.-1010 l.an--Mc

• Nuclur Corporatt.oa AlTN:

Kt. W. J. Shelley, Direetor Je ul1tioo 1od Control l.er-r-Kc:C11 lu Ud tq 0

a City, Okl1ho.u 73102 Cientl**ns Thi, T*f*~* to ~h* in.pection co~duet.,d bJ Kr. C. L. Cain of thia office on H.y 21-24, 1979, of th* 1ctivitle1 *uthor11.t by C Source Material Ltc1oe1

. S - 1010 and to th-9 dhcua,ioo of our UnJ1na* t.eld b1 H:r. C.14 "1th M111r1. J. W. Cral1 aod C. t. Gro11claud1 OD Kay 24, 1979.

n

• iaap* tion va1 an et

• tnAtion of the 1ct1*lth1 con.Juc ta1 under the Hc,n,1 11 they relate to radiation,.t,ty and to cooplt* nc* with t ht Coimtaaion** Nl**

and rt ulattona, *ad tha condition, of th* llc*n*** Th* 1naptct1oo corwl1t of

• • lectlv*

a Jnatloo1 of proc.Surea aod t1pr111obttv1 record*. Jntervi~* of per1onnel, tnd p*ndeat u1ur eat* and oba n1t!on1 bJ th* tupector, Caitl *ho revie\\led the actSoo you had taiken vtth reap t to au (6) tt**

ncomp111nc1 obaened during cx,r prn1ou, tn~ectton, vhich w I conducted 1t 10-11, 1978.

He ~*rift* ttwt the corrective actloa vith rarpecc to t *** lt

• v11 pl ent 11 etated tn your repl1** of Sept ber 22, 1978, aDS Octo er 19, 1978 1 to our l1tt*t* dattd Au1u*t 31, 1q1e, and October ll, 1978.

8A1ed oa the r lt1 of thia iaap tioa, lt appear, tl\\at ooe of 7our acttvltl**

v** Mt ~aad~ct in full c pliao

• v1th C r9qult**nt** ** **t fortb ln the tic* ot Vtolatfon, enclo1 d lerew1tb, Th.fe it* of none pli*nc* hA* b~*o c1t1aorhed into the 1.-.,11 ** ducdbed tn th* con-upondenc* t.o,ou dated Decmbet ll, 1974.

Thie aotiC* 11 **nt to you purauaot to tbe provt1ton* of S* tioa 2.201 *f th*

iltC lute* of Puctlce," Part 2, title 10, Cod* ot P.Jaral le ulatfooe.

S tfoa 2,201rtqutr111ou to bQic to thl1 o!ftce, vi to tvent7 (20) d111 of your t

eipt of thil t:lce,

• vr:lt.tan et.At ent or placation in reply/incl\\1dhlf&

(1) cort tv, t ctlone - hich ha** ba t*~*a by 7ou and the r1tult1 1chtned1 (2) corr t1** t ct!on* w'hlch wtll b* tJ~" to avoid further it

• or noac pllance;

• ~ (]) th* d*U V'han full compl unce "111

• echhv.-f *

)

'""r..,...

I ------.i~

........;..~.... -~;.;.;.;..;..;.......;.;..;.;.;.;.;,;.;,;,;.;~;.;.;.;.;..;.;;;.;.;.;.;,;..:.;~~~:.:,;;;.;,:.;.;.;:.;.;.;;;...,;.;,;.;.:.a;.;,,:," :.:.;***;.;.:**::.:**.:,;" :.;,"*:.:.:*:.:.:**:;.:":.;,*":;*~~-:----

tlltfftlttftlltlt ftflftfl ttt'ltftftllttftt I lftt ti

• "* ~-*******--** *.,,.**,,., *.***.*..

lta-rr-McC.* Nuclu T Corporation June 25, l 979 In accordance with Section 2. 790 or th* NJtC "RulH of Practic*," Pert 2, Titlt 10, Code o! 1idaral Regulatton,,

• copy of t h11 lett*r and t b* bclo1ed 1n1peetion report "111 be placed 1n tbe NRC'

• Publfc Docuamt looa. It th11 r*port cootain* an1 lnforiutioa that,ou belleve to be propri*t*t'J, it ia neceeaary that *.ou.,.k* a vrttten epplication Vi.thin tventJ (20) day* to thb office to v1thhold such tnfonution from public dhcloaure.

Ally, uch appllcaU.oa muat toclud*

• fl.lll et.u ent of the l"e&eon, it 1e chi.aid that the inforiution 1* proprieter,. lt ehould ba prepared, o that proprietary information identified 11 contained la* 1epar1te pert ot the dociment, 1tnc1 th* application, o cludina thla **raratt part, vill *l*o be plac~ Jn tha Public Document Ro011. If** do not hear froc you ta thi re ard vithin ht 1pactfied p1rtod, the report vtll be placed in the Public Document Roo,a, Should 1ou have any qu.,ationa coacerntna tht* letter, pl.. ** let** lcnov.

E.nelo1ur11:

1. r tice ot ~tol*tton

Sincerdy, Clen D. lrow

• tat f'u*l Pctlity aod &tart.al Sahty Branch

2.

IE ln.ap t!oo port

.49-901.7 /79-01 bee w/encl to Rtproductlon Unit for Di tributlon.._. ___ _

A.O/fFHSl IE FILES NMS~:101.S NMSS: 'FCSL bee w/ ncla. h ld for 20 daye C tmw. FILES POP.:HQ SIC

/µ,:,V. POO

License No. SUB-1O1O WOTICE Of VIOLATION Based oo the results of tbe ~"RC inspection conducted oo Hay 21*24, 1979, certain 1ctivities appe*r to be in nonco~pli3DCe with N'RC reguletions as indicated bdow:

Contrary to 10 CFR 2O. lOJ{c), use of respiratory protective equipmeot w,u not io accord with. Regulatory Gulde &. l~, Accepta.ble Programs tor Rupiratory P,rotection" in that

• bal (-muk respiutor was used witb bead straps over tbe bard bat which prevented 1ttaps fro~ lytng in tb~it aonnal position next to the head a, required by Section 13.5 of NUREC-0041, which i1 referenced io Section C.8.o of Reaulatory Cuide 8.15.

This is ao infraction.

• J

u. s.

1CLf.AR REGUL~TORY co~r~SlO.

OFFICE OF lNSPECilO~ AND £SFORCEM£NT RHHOS IV Report No. 40-8027/79-01 Licensee: Kerr-McGee Nuclear CorporallOD Kerr-McGee Center Oklahoma City, Oklahoma 73125 L1cense No. SUB-1010 Docket No. 40-8027 Fae 1h ty: St>quoyah llran1um Hexa tloundc Conver& ion fac111 ty lnsp~c.t1on at : Gore, Oklahoma Jo pecto, :

los ect1on Suuv11 n

.!.'!! tction on H1v 21* 4 1979 Hc_port 'o. 40 08027/79-01)

, un*nnounc d inspci;t1on of ur mum conv"r 10n h cCJly opeuticns nd raM tion p,o i: m rncluchn organ1ut100 and adm1ni trat1on; f cil 1t1e ud,_,.,iu1pml!nt; internal exposure control; xtern I expo ure control; e(1lu~nt and nv11orun nt 1 mon1tor1n ; *ud1l1 nd tr,ning; em rg *ocy planning and tire p,otect1ott; po t i n, l b~ltn aud r~ports; n.. trwn nt l ion; nd od,*pendent a11 11urem nts.

Tht. in11r, ct1on involvt!rl t~cnty-tbrce (23) hours on site by one in p ctor.

Re ulta :

Of th d vutions were noo omp 11 nc:e w h lf-m k resp 11 t~n (10) arr.a 1nsp ted, d~nt1! cd n 010 (9) are 1tl nt f1ed 1n one (1) ar tor, r~f. i ra raph 5).

no tttms of noncompl1ance or

one (1) apparent 1t~m of a (1nfr c 100* mprop r u,~ ot

2 DETAILS

1.

Ptrsons Coot cted

• J. ~- Craig, ana er, Sequoy b Facility

• C. r.. Cro& clJude 1 Han1ger, Health Physic5 & Industrial Safely L. H. Harrison, Manager, Admin1strat100 & Accounting

• Members present at exit iolervtew.

In add1t1on the inspector 1ntcrv1ewed on member of the plant oper ting force.

2.

I.1ceolle Ac:t1oh Jn Prev1ou"' Ins ecl1on f10din s A.. (Open) None mpl1 nc~ (~0-80 7/78 OlJ :

This item involved r 1,ure to use rcspLraLory protecl1\\e equ1pm~at 1n accord ~ith R gul~tory Gu1d 8. 15.

The 1nspe tor ve,1f1ed that all workers usrn such equipment had nimpleted a f1tl101 and training program nd tbat workers ~ho used h lf-mask re p1rators ptrformcd an irritant smoke test each t1me uch cqu1pmeot was donned.

However, th 1osp~~tor observed use of a h lf*mask re pint.or \\Jlt.h head stra1,1 phcc;d over the bard b l thus pr veotrn str ps from lyio 1n their normlll pos1t1on next to th heu,f as require,! hy NUREC-0041.

8.

(Clo cd) Noncompl 1ance ( 0*8027 /78-01):

Thi 1 tem iovol vcd fat lure t o equ1p high rad, t1on area w1Lh ent.ranc or a c ss control dev1ces.

Th n pect.or ob rvtd no 1ea1 posted** hi *h rad1at1on r

at the time of the 1nsprc t1on.

C.

(Clos <l) Non~ompl1ance (40-8027/7 *01):

Thia 1 ~m 1nvolv~J f llure Lo establi h pro dur"s rciartlin 10 CFR 21 1mplcm nL4'tion.

D.

Tbe :insp,.ctor ob1crv *d Lh L uch procetlur s bad b en a,lopt *d.

(Cl~ ~d) Nonco1pl1ance (40-8027/78-0l); Thi f !lure to control cool min L1on l~vel nd to t.c work rs.

Thi! 1n~pe 1 f u~d that w r b 1ng m ot 1ned tbe control nations b d b~en a1~1ni 10 ~ork~r,.

lt m rnvolv d administ r annual ontaminatlon level and that

£.

(Clo d)

(40-8027 /78*01) : Thu nr.111 involvt!J

r.

f I lure o obtun and n lyz 101 I arnptu.

Tile nip lor vcn 11t*I that uch mplf!I h d b n obt II ed and analyzed.

(Clos d)

(40*8027/18*01): Tht item,nvolv d fa lur~ to nbt Jn n n lyz,. re rvo11 bottom dam~nl ampl ver1f1,.d tlust au h lrDJllo h d l, r.n obtain d incl

3

3.

Organization and Adminstration

4.

Discussions with l1censee aoagement established tbe following corporate and facility orgaoizatioo oo the dates of the inspection:

Cor2orate P.H. Hoore, Pres1deut 1 Kerr*HcCee Nuclear Corporat100 R. P. Luke, Vice President, Naoufacturiog & Narketiog B. E. Brown, General Minager, Nuclear Hanufaeturiog

w. J. Shelley, Director, Regulation & Control C. J. Sinke, Coord1n1tor, Radiation Health & ~fety Sequoyah Fac1l1ty J. *

• Craig, Ha1ager, Sequoyah Facility C. E. Grossclaude, Manager, Health Physics & Industrial Safety L. H. Harr1aoo, Manager, Administration & Accounting Tbc licensee atated that Nr. J. W. Craig was,ppointed to his per.sent pos1tion during Dec~mber 1978 at wh1ch time Hr. B. t. Brown was relocated to the Kerr-McGee main office in Oklabou City.

The licensee stated that the factlity staf( is compr1&P-d of 156 employees. The H~altb Pbyeics and lndustraal Safety organi1.at on includes one (l) manager, six (6) technicians, and one (1) clerk.

racil1ties and E9~F~

The inspector Loured the plant on Hay 21, 1979. and the l1guld effluent retention areu on Hay 23, 1979, to observe operations in progress and to verify that equapmenl and facil1 t1e1 were in accordance wath appl1cable 11cense rPqui rement1,

The licensee stated tbat the plant process rate ~as approximately 7800 short tons per Y'-*r, and that the plant operating schedule was t~enty-four (24) hours p~r day, eeven (7) days per week.

The inspector observtd that retention w1ll1 had bern constructed *round the process boildown tanks to contain any overflow such 1s that which occurred dur1n1 Decemb~r 1978 (Ref.

IE Iovest1gation Report 78-02 dated 1/10/79).

Al o ev1deoced was a major effort to decontainate and paint *any plant process areas.

Under connruc:tJon vere facil1t1es to proceu 1Jf4 slurry.

A tour of the w*ale ponding areas revealed lhat conatruct1on of Pond No. 3 was co~plete. Tb~ lic~nsee stated that two ~1lliou gallon, of pro esaed

4 raff1nat~ from Pond No, I had be~n transfer1ed to tbis new pond,

Tbe inspeclor sought to deteranne 1{ ur6 cylioder valve pac~iog nuts identified a& potent1 lly defective by DOE had been located and w1tbdra~0 from use. The licensee~** io possess1on of* letter dated January t.S. 1979, from Supt11or Valve Company._bicb identified tb, quest1ouable valve~ hv d,te codP. and heat number.

The l1censee stated that the packing nuts on these valve, had been replaced ~itb one!. of established good quallty and that the removed nuts were being held for eventual deitruction. The 1nspectoc observed tlat the quest1ooable outs were btl4g 5tored 10 a holding area,

5.

lnt~~nal Ex o&ure Cvotrol The licensee's 11r sampling program i, described 1n the Lictnse Application, Appendix A.

Lirensee records llsted 4S air sampl1~g locaLions 10 ~ork locat1ans w1th1n the plant.

These sample~ art collected each &*hour sh 1L and analy~ed rad\\ome~rically for total alpha emission. Each worker is r~qu1red to tabulate his woik t1m~

in each areoa.

The HPC-hour ~xpo.surc i6 then calculated on * &e\\*en-da.y exposure period.

A review oJ 11r sa~pling data revealed some ar~Js 10th~ plJnt wbere airborne r~d10, ct1v1ty conceolrat1ons exceeded Part 20, Appendix 8 1 Table l, luuts.

Exposure ret:ords 1n,hcated no evidence of ovcruposure to persorinel.

Th,s w r.h1eved by 1:iautin occupancy and/or ut1l111ng r~sp11Jtory protection equ1pm~nl, Daily Rad1olog1cMl Status Reports listing tlr 11mplr. results greater than 0.5 MPC were rev1f'O-lo~d.

Tbe reports wP.re noted to be disLr1buted to various plant and corporate man.a em**nt p rsonnc 1.

Prot:ess eng1 nee ring cont rola had betn 1mplcmenl~d lo reduce airborne radioact1v1ty concentr*tions, but tonccntrat1on, ~ere 1t1ll recorded above thos~ that would d~l1~1t an airborne r d1oact1v1ty area.

Process eng1n~r.r1ng controls added aince che lost fnsp~ctaon includrd tht foll owing:

A.

A rr.f ~d drwn dumping and conveying system with an enclosure bad bf'en addtd to the &amphng pl&l\\t.

8.

A uo3 scr ~ convr.yor had been r~rlaced with a buck t elevator.

C.

Vac.,1,im control had been mprovc(1 on dr.n1tr1tors.

D.

Reduct ion ftller burn h"'d b,- *n ro.. ted tt,rough du t collcctou.

E.

lmprov d patk1ng rin had be~n natall1~ on screw tonveyurs.

5 F.

An enclosure had been installt!d around

• drum dumper.

G.

Ao improvement to a UNH feed port on a deoitrator has resulted in less leakage through a packing assembly.

Establ1stuaent of several other controls was observed to be ia ~rogress.

Tbe licensee stated that a respiratory protection program continues to be utilized in accordance with Regulatory Guide 8.lS.

Internal exposure records were found to apply protection factorb for those personnel wearing respirators A pol~disperse DOP man-test system witb a fitting chamber 1s used 1n conjunction with the program.

R~cords 1nd1c ted that personnel had receiv~d medical examinations including lung dyn ic test$ as* part of the program.

Copies of written exam1natic relating to respiratory protection were contained 1n employee record files.

Comprehensive written procedures were found describing the program.

Durina lbe plant tour the inspector obser,,ed that ao individual was ~earing a half*mask resp1rator vitb head straps positioned over the barJ bat helmet.

The inspector stated that this item constituted nonrompl1ance w1tb 10 CFR 20. 103 (c). This is* repeat item.

Discussion with the licensee and a review of pertinent records estdbl1shed that the bioassay program bas been conducted as described in the appl1cat1on. The bi-monthly urinalysis schedule for plant workr.r&

1 designed to monitor the controls impl~menttd for cout1ne worker exposure.

Tht! inspec.tor noted,ome data 10 excess of 20 m1erograms per liter actton level and 1nquired as to the li ensee's evaluat100.

1hr. l1cena~e stated that io each case the worker was restricted from further exposure uot1l the next b1oassay 1nd1cated normal levels.

Lteensee records indicated that ~ ~

lu.na counting u performed by a vendor as described in the License App11cat1on, Appendix A.

A rev1r.~ o! current data reve1led no result in excess of JO CFR 20.103 (a) ltm: tc.

The h1ghest result was 10.3 mg natural uranium from counts perfor~r.~ during October 1978.

The ia6pector noted that the licensee docwn nted ahd graphed alpha conta111nat1on survey data re&ul ting froni weekly a.euuremt.nt.a at 70 loc1t1ons within tontrolled areas, 10 locations ~1thin uncontrolled areas. and 6 locations io un1Pstr1cted area,.

Tbe inspector observed that contaminatton level, within th~ plant were de r~as1ng.

The 11ccns~e stated that* maJor portion of the process areas had been clPaned with b1gh pressure w1t~r and th~n painted. The licensee further stated that th1* project which had begun in Febraury 1979 was approximately 70~ compJete.

The inspector reviewed Hazardous Work Permits used to <lesignate radi~tioa safety practices for specific jobs in pTocess areas.

6.

External Expo~ure Control Licensee records iodicat~d that film badges are provided to all workers on a moathly exch~nge,

External exposure data were revie~ed and no exposures were noted in excess of 20. 101 li~its.

The highest recorded annual dose {or 1978 was 800 millirem.

Tbe inspector coof1nn~d that external radiation surveys bave been ruade monthl y at t~eoty-five (25) designated locat1on,. Ho areas wer~ classified as high radiation areas.

7.

Efflu~ot and Env1roomtatal Honitor1ng The licensee's effluent and environmental mon1tor1ng program 1s described 10 license application referenc s specified in License Conditioo 12. !te liceosee sl~led that verbal approval had been granted by NRC Licensing LO l~ngthen the period t.. ween sper 1f1ed roviroQll)eotal sample,. Neither the hcl'!nsee oor the 10spector is aware of,ny license amendment documenting

,uch author1tat100. The licensee has been operating 1n accordance with the verbal authorization for several months.

This item was left unresolved pend1ng d1sr.uss1on with L1cens1n3.

The liquid e((lutnt stream [rom the planL 11 c~ntinously s~mpleJ et the site boundary.

O,ily anb Gal!'lple are aoalyz~d for uranium, f11.1oride, 01tnte, pH, and temperature.

Monthly composite5 are analyzed fot uraniWll, gross alpha, gross beta, nitrate, and fluoride. Quarterly aoalyses are perfonaed for Ra-226 aod Tb-230.

All rad1olo&ir1l data were less tb10 tbr. tppl1cabl~

Part 20 1 Appendix B, Table ll, values.

A review of nonrad1olog1c1l parameters revealed no upw,rd trending.

Analyses for fluoride, uraniwn, and niirate arr p~r{oT'11!ed at tbe Sequoyah }ac1lity.

Analyses for gro,1 alpha, gross beta, rad1Wll, and lhorllm are p~rronn d at the kerr-HcGee Tecl'utical Cecttec 1 Oklahoma City.

Surface water is collected and analyzed fro~ the Arkansas, lllinoia, and Silt Fork rivers end three nearby ponds,s deicribed in the J1ren1e appl1cat1on.

Ground ~ater is collected 1rom ~2 monitor wells.

Treated raf!inale continues to be used as fertili1.er on Let plota and incru$ed 01 tn.te levels b ve not. been detected at. 111oni tor ~e lla.

1'he licen ee stated thit there haJ been three (3) on-site burial of wastes s1nc'" th* last Jnspect1on. The hr e l wa 35~000 cubic fef't. o{ fluoridE<

Judge.

8.

7 Atr $ampling is perfonned at plant stacks, batches, and vents; at four (4) locations wltb1n the boundary fP.oce; and al five (S) locat1ons off-site.

Two boundary samples are analyzed for uranium, Th-230, and Ra-226.

Data for these boundary samples were noted to be,.ell below applic.-blP H.PC's f~r unrestricted areas.

The inspector verified that soil and vegetation samples bad been obtained and analyzed 1n accordance with License Condit100 12. Also r~v1e~ed were data pertaining to bottom sedlm~ot samp1es obtained by Oklahoma State University io accordance ~1th License Condition 15. A final report on this ioll11l sampling 1s st1ll pending by tbe licensee.

Audits and Training Reports of -eekly, monthly, and quarterly audits were revi~wed and found to be performed as rtqu ired by Append uc A.

I. i censee train iog programs ar~

detailed ic dppeod1ces of the License Appl1cat1on.

Sew employees receive comprebens1ve safety training and a trainin6 handbook at time of hire.

A training program has also been estahlished for contractor per~onnel.

The licensee st4ted that female employees are instructed 10 tbe contents of Regulatory Guide 8. 13 and that ; igoator) verification of this instruction is required.

The llcensee furtht"r stated tbat plant employees b ve been g1ven approximately three (3) hours of refresher training since the last 1nspPct100.

The inspector reviewed written examinations given in con-Ject100 ~1th this training.

Tbe inspector int~rv1e.ed one worker and determined that her understanding of ra~Hation safety practices was sufficieut to comply with 10 CFR 19. 12.

9.

tmer,&ency Plauu;ng and fire Protection The lic~nsee ' s emergency planning and fire protection programs are described 1n AppP.ndix A. The fire protection program includ, temperature acti~ated foam spray heads in tbe SX bu1ldiog, sprinkler systems in cahle trays, temperature activated n1trogeo purge 10 the fluoride cell room, and manual fire ext1oguisbers throughout tbe plant. Tbe licensee slated the iosuraoce undervriter had perfonned an inspection in recent mootbs.

Tbe fire born aod emergency generator are tested monthly.

Nine hose stations are supplied by a 150,000 gallon holding tank and are fed by diesel and electrical pWllping equipment wbicb is also checked monthly.

Observation of approximdtely 10 portable extinguishers revealed that these were inspecled monthly. The licensee stated that sprinklers had been recently inst.alled in tbe chemical storsg~ building behind the plant.

Emergency tearo~ on each shift have had 1nstruct1on in the usr of self-conta1oed breathing a~paratus and several individuals on

8 each team have bad f1rsL aid tra1nio~.

Thr licensee stated that

&imulated (1r~ fXtrClscs bad h~en p~rfoTmed by each sb1tt ere~.

The licenseP. ~as found t o have added a new procedure addressing reports of d1schar e of ha21rdous mat~rial.

10. Postin The inspector noted that 1ncom1ng and outgoio~ shipping containers were labeled as LSA and rad1oact1ve.

forms NRC-741 1 completed upon receipt and tr,nsfer of source matPrial, WP.re rev1ewed; and compliance

~ith 10 CFR 40.64 (a) ~as ver1!1ed.

The inventory report required by 40.64 (b) was rev1e~ed.

The inspector noted that the effluent monjtoriog

,eport, r~gu1red to be submitted to the NRC within 60 days after July 1~

1978, 10 accordance with 10 CFR 40.65, was not submitted until September 19, 1978.

The inspector also noted that documents -er~ r usted as required by 10 CFR 19. 11 and 10 CFR 21, and that ~b1pping container c~rl1f1cation>

~ere available for each type of container used.

The inspector observed coot1nuous feoclng around the restricted area and access control at the main gat~. The p"ant entrance wos posted -1th 1oformation that all areas within the mil\\ may contain radioact ive material.

11.

lostrumentat100 The inspr.ctot observed that tbe 1nveotory of portable survey instruments and laboratory counting lnstruments was fuff1c1ent to Slpport radiation iafecy programs.

Instrument calibration frequency, currency, and procedures were found to be as requ1red.

12.

lnd~Pndent Measurements A water sample was obtained from the co~bined effluent stream at the boundary fence. The sample ~111 be analyzed for uranium, Ra-226i Tb-230, gross alpha, and gross beta.

Air samples -ere obtained in the process area near tb~ denitrators on the second level and to tbe sampling plani oo the first level. The analytical results of all samples from Idaho Ht.altb Servtces Laboratory ~ill be later co~pared to the licensee's resul~* of samples taken at the same locatioo.

13.

Unr~solved }teas Unresolved ites are matters about ~bich more 1nfo[11Jalion is required in order to d~t~,ine ~hether they are acceptable items, 1tems of noncom-pliance, or deviations.

One unresolved item was identified during th~ inspection. This item is <l1SCUi&ed in paragraph 7.

9

14.

[x1t lotervJ!:

Tbe inspector met ~ith licensee managemenL (Re!. paragraph I) at the conclusion of thP. iospect100 on Hay 24, 1979.

The,nspeclor summarized the purpose and scope of the inspection and summar1ted the findings.

KERR*f,fCGfl:

Aug u t 2 9

• l 9 7,

!1*. Glen D. 3r:, :.1::, Chief Ra & i or. I*;

U.S. ~uclear legulac~:y CcQmission 611 Ryan P~a:3 Drive, Su!ce 1000 Arl!n~ton, Texas 75012 In accor!a~ce ~i:h 10 CFR 40.65 with a~pro?riate ~odificzcions

~a*e for th~ nature of the operation and data avail3ble. Eerr-

~cce~ ~~cl~ar Ccrporotion reports the release cf ~uclld~s ln

~=:luencs to ur.r~3tricced a:e3s duri~g the first six months oi 1979.

7hls repor~ cov~r6 activities performed ac our Sequoy3h Facili:y er r G~re, Oklahc~, und~r :icen~e ~o. SOB-10:0.

• ... JS :jb c:

Director, rr.spcct~on an~ Enforce:e~t t5) ih:cc~o~, :U?C (:!)

C

Radio ctiv-:y in Gaseous ~ffluent - 1st 1/2 1979 Parciculat

- Elevat d

~ tot l rele ses (No batch ~ode rete ses)

~~uclide Release~

Gross Alpha Uranium (Na:.)

Thoricm -

~30 Radiuc -

226 A 'H! r.16e re le as e

!or gro.ss alpha Volut:11? Rei."ase<!

rate Unit Ci Ci Ci Ci

v... 1 /!ec liters TABLE It l

t o,~acter 2.llE Z. OoE-02 2.5.. E-O..

~.39E-05

2. 68E-03

l. 75E-... 2 2nd Quarter 2. 89E-02 2. 87::-1)2 l.81E-04 3.7GE-Oo J... SE-0.3 2. 06E-1:

Radioacc1vlty in Liquid Effluent~ - 1st 1/2 1973 (~o batch noJe releas~s) lirle Released

'ni t Oua~ter 2nd 0

'I.:

1 -P arter G:-o

. l pha r: 1 o.51E-Ol 9.40£-01 t:r n iu

(~at.)

Ci

'.-eE- 01 o.7.JE-01 rice - 2 30 Ci L.27:.-05

?.05E-0 ',

RadL,a - :! 2 6 Ci 7.55E-Oll

8. OE-07 1* o l u:n e r,de ed liters l. OSE- 00

1. l u:~09

RECORD Of T[LEPHONE CONVERSATION Oa te:

10.:2-81 N~C Lie. No.

Kerr McGee SUB-1010 Time: _J: S5_£.M_ __

__._c.... o...

1..

ern-a.... n

......... S-rn... i~t.. h---- Tit 1 e Hoci ltb Cbys ic i H f I rm/ Organization Firm/ Organization

-;Investigation 0Not if ica t ion 0lnfo. Request State of OK Title D Overexposure S"uMMARY OF CONVERSATlor~

Allegation OL;c. Condition OLost or Stolen 0Misadmi ni strat101 l] Leaking Source

[i]Release of R.M.

Source

.

~" tr:.ic:. t,*anspor-t i ng a pac~.age containing approximately 350 gm of YC in th,..c('

glass ~i dls was destined for an independent testing lab on October 2, 19Rl.

Juring t,..ansport t he truci09hadverteniy came open losing the above pac~age.

The pac~age ' ell to the highway apparently brea~ing the three glass vials and relea si ng !he contents to the inside of the package.

When the material fell ft-or.. th" tri,c* ar. ~,r.identified individual radioed the t'Jl trnc~ that he h,HI loH d ;,~ci.a,;e.

!1~ u uc~ dr i ver iP-:mediatr.ly returned to the location \\-,her!? he had ic s~ t.~,e :.1cO*age or.ly to d'iscover that an or. Department. of iransportat_ion

,_.!.. ;.:.1c,:tee r,d*:! :.reached the DdC~.age spilling approximately 19 g~ of the VC r,a~'!r i a1.

He \\*ias ir:1mediatel :1 rushed to the r-~usi'.ogce General Hospital where

• • ,is '1an,:s and feet 1-,ere decontarninated "iy rr personnel.

Sut cessful 1P.contdr.ii ~cHion -..1as evidenced ty a radiation survey conducted by r.N personnel

f. ;a,:,;ile of,rini.? wa':> taten at this time and another sample was requested 2.: *: **.er,ce. al 1 of ;,:hkh are to bt> dnalyzed by t::*L

~aterial was lost at l-40 and US f9 at the C~ectoa~ overrass.

at !. h is l oca*ion -..,as,*eMovea by rJ*~ personnel.

jew/9-8 8112~90206 811002 IE ADOt~ 04008027 -

Prepared By:

TH1 n*

omc:a*

lfUCAMI.

OAff.

\\..,oc:li...tr T0-3=1 Jt.\\ '1, (.~Tt.

"S </~ -)~

• ""'~..

-~1r*.

~,.-

Or. M1ntoa."ti11ey Fuel Cycle ProJacU Manager**

Em 1 ronmenta 1 l11pect Sectf on Nuclear D1v1s1on P.O. Box X Olk Rtdge. TeMessee 37830 Deir Or. Kelley:

NOV 2 2 1983 DISTRIBUTION wfencl:

Docket File 40-8027

• ---,70-371 MJRhodes VLTharpe WTCrow NMSS R/F FCUP R/F Enclosed please ffnd revfsed copies of the env1ronnenta1 review schedules for Kerr-McGee SeQuoyah and United Nuclear Corporation, Uncasv111e, 11 we have d1sc:ussld 1nd agreed UPOn. It 1s cr1tfca1 that these sthedules be adhered to. If the need to devfate fran these schedules arises, please provide a wrftten rationale whfch explains your reason and proposed canpletfon date.

Enclosure:

As stated S3120702800B4lli~7 ADOCK

~

f.&UP..:).tt..........................

HJBhP.~'- 'i@.........................

11/~........ ***********.............

Sincerely,

/.s/

Kuc J. Rhodes uranft111 Process Lfcensfng Section Uranfurn Fuel Lfcensfng Branch Ofvfsion of Fuel Cycle and Material ~fety N.. HM*..

• M*e..

M...............................................

11t1111,1*91a ttA.an ~

MMI

~

KERR-MCGEE CtJffPt7i!1:!iON January 28, 1971 Mr. L. D. Low Director, Division of Compliance t:. S. Ator.lie Energ)' Commission Washington, D. C. ~0545

Reference:

Source }laterial Lic.::nsc r~o. SUB-lUlO Docket ~o. 40-8027 D<:ar Hr. Low:

In accordance with the provisions of 10CFR20.405, as applicable to the r~ference 1 icense, K~rr-McG~c Corporation reports on th\\!

exposure of one (1) individual ac its Sequoy~1 Facility co con-centrations of airborne radioactive material in c:-:cess of the occupational concentration limits in 10CFR20, Ap?endix B, Table 1.

,i1e exposure involved n.itun1l uranium as uo,,r..,.:rnd the c:,:posur~

calculations were made tram urinary excrcci6n-daca.

Table l Empfovee (1)

~

Period of Exposure Cone.,\\v~ra8ci*l) for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> *-

(uCi/m!)

A 12/27/70 - 1/3/71 (1)

In accordance with 10CFR20.405, the names, identification <lat~

and exposure dat.i for the individual employee ar..: liste.:cl in the cnclos.:<.I App~n<.lix.

(:!)

The :!!filr.iwn pcrmissiul.:! concentration in air nn*ca) limit ul 7xlU uCi/ml for solubl~ natural uranicm based on~ forty (40) hour expo:rnrc in a seven da>* period was applie:d.

The exposure occurr~d vili?n a lea;,. developed in.i srn.ill cuppc r lint bein~ used to transfor v~6 gas between two shippins cylint.lcr~

located in the Cylinder Scale Room.

Tile employee had with ltiia a full face respirator equipped \\Jith an "ultra" particul.itc filt.cr

\\olhich he used 1.*hile taking remedial control actions.

These actions includ~d closing a valve on each of the shipping cylinders and 8~1218001~

CF AOOCK lnfonnation in this record was deleted In accordance *r F!eedam1' lllfmll1'lill 11 o 12s exemptiona

~

0400602~~1P\\aj.ij

,;::~-

Mr. L. D, Low January 28, 1971 Page 2

• leaving the scale room.

Use of the plant vacuum systen to collect the UF6 gas at the point of leakage was not possible because 'the vacuum system was temporarily shutdown for maintenance.

A urine sample was collected from the exposed employee approximately two hours after the exposure occurred.

This sample i1ad a uranium concentration of 1660 pg/1,..hich was the highest concentr.:ition ob-served in any samples collected from the exposed employee.

Urine data was used to calculate the e111ployees exposure since there were no air samples collected in the immedi ate vicinity when the release occurred.

The individual involved is being notified of the nature and extent of his exposure in accordance with 10CFR20.405(c).

Corrective Action To protect against recurrence of similar future personnel exposures, the following actions have been taken.

1.

UF6 transfer lines are inspected for leaks and faults prior to use.

2.

UF6 transfer operations of the type described are done o~ly when the vacuum system is operating_properly.

Please advise us should you require any additional information.

AMV:dg Enclos11re cc:

Mr. Uonald Walker Region IV, Division of Compliance U. s. Atomic Energy Commission Sincerely, flit:~\\ Lh (:;*tr~:*~

Allen Valentine Coordinator, Radiation Health ;,.nd Safety Mr. Dale HcHard, Okl~ioma Department of Health Division of Occupational and Radiological Health Hr. Howard Eberline Director, Physical Science and Measurements Dept.

Appendix to letter from A. H. Valentine, Kerr-McGee Corporation to L. D. Low, U. S. Atomic Energy Commission, January 28, 1971.

APPENDIX A implovee Identification and Exposure Data Report Exposure(!)

Securicv Number (uCi/rnl)

Svmbol Emplovec' s :,.:une Birthdate Q

,._rx_'6)-------------~

8xl0-ll Period 12/27/70 to 1/3/71 (1) Average concentration exposure to airborne natural uranium as U<\\F2 for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> during the. reference seven (7) day period.

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KERR*MCIJEE CORPOR.4TION November 13, 1970 Mr. l.. D. l.ow UirectorJ Division of Compliance United States Atomic Energy c~111111i&&ion Washinaton, u. c. 20545 Refertnce:

Source Material License ~o. SUS-1010,

Uocket ~o. 40-8027 In accordance with t h provtsions o{ l 0CFR20. 40S, a;S c1pplicoblc t o the reference license, Kerr-McGee Corporation reports on the exposure& of eleven (!l) individuals at its Sequoyah Facility to con:entrations of airborne radioact i ve material in excess of the occupational concentration limits in 10CFR20, Appendix 8, Table l, Time weighted exposure calculations were made from measured concentrations and working ti~e tec~rds. The results foT t hose in~1viduals potentiJlly exposed to over limit a~ rborne concentrations are given in Table l, 1able l Personn~l Exposures to Airborne Concentrations

_t.rnployee (l )

B C

I,)

Period of Exposure Date * *

• 7/ 19 -

1/4 7/ 12 - 7/18 7/ 19 - i / 2S 1/12 -

7/18 7/ 19 - 7/25 7/ 26 -

6/ l 8/2

- 8/ 8 7/ 17, - 7/ 18 7/ 19 - 7/ 25 i / 26 - 8/ 1 8/ ~ - 8/8 8/ 9 - 8/ 15 9/ 20 - 9/26 I

Cone. r\\ve ragfq)

Co, 40 hou r s

~

(uCi /ml) ll:i<.10-ll

-11 16x10_11 l4xl0

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Mr. L. D. Low Novaiber ll. 1970 Page 2 F

c; H

1 J

K' Table 1 (continued) 8/2 - 8/8

'8/9 - 8/ 15 7/5 - 7/ll 8/23 - 8/29 7/19 - 7/25 7/26 !. 8/ 1 7 / 19 - 7/25 7/26 - 8/ 1 7/26 - 8/ 1 8/2 - 8/8

-ll 7x10_11 9xl0 l OxlO-ll 7xl0-ll

- 11 10xl0_11 7xl0

-11 14xl0_11 9xl0

- ll llxl0_11 12xl0 (1)

In accordance with* 10CFR20. 4*05 (b), the names, i dent ification data, and exposure data for t he individual employees are listed in the enclosed Appendix.

(2)

The ~f!1mum permissible concentration in air (MPCa) limit of bxlO uCi/ml for insoluble natural uranium based on a forty (40) hour exposure in a seven day period was applied.

These employees were exposed during performance of product ion duties in t he Sequoyah facili t y.

Unplanned equipment failures which resulted in t he l oss of uranium powder and excessive ai r concentrations in the working areas intermi ttently during July, August and September and t h~

failure of pf rsonnel t o wear adequate protective equipment du ring the clean-up of t he powder spills were the causes of overexoosurc.

Control procedures prevented t he spread of uranium outside restrict ed areas on people,or ot herwise, and all of the exposed individuals have and will continue to submit bioassay samples.

No allowance for exposure t o particles of a non*respirabl~ siie was taken in determining the exten t of exposure.

The individuals i nvolved are being notiiied of t he na t ur e and extent of their exposures in accordance with 10CFR10.405 (c).

Corrective Action To protect against recurrence of ai~ilar future personnel expoaurea.

the following actions have been taken.

' I

Appendix to letter fro* A, M, Valeotioe, Kerr-McGee Corporation to L, D, Lov, Uoited State* Atoai c Energy Coaua1iou, November L), 1970, APPE.\\'DIX A D<PLOYEE l DENTlFICATION AND EXPOSURE Report

£xposur e ( l)

Sj'111bol Em,2loiee 1 s Sa!lle Birt hdate Securi ti Number (uCi/ml)

Pe riod (1 970)

(b)(6) llxlO-ll A

7/ 19-7/25 8

- 11

'l/ 12-7/18 16xl0_11 14xl0 7/19-7/25 C

- 11 7/12-7/ 18 13xl0_11 l 0xl0_11 7/19-7/25 10xl0_11 7/26-8/1 9xl0 8/ 2 -8/ 8 D

l3xl0- ll 7/12-7/ 18 E

- 11 7/19-7/25 13xl0 - ll 19xl0_11 7/ 20- 8/l 16xl0_11 8/2 - 8/8 19xl0_11 8/9 - 8/ 15 l 0xl0 9/1.0- 9/ 26 s:'

- 11 8/2 - 8/8 7xlo_11 9xl0 8/ 9 -8/15 G

l Oxl O-ll 7/ 5 - 7/11 H

7>:10- ll 8/ 23-8/29

-u 7/l"J-7/25 10xLU_11 7x10 7/2b-8/ l

-11 7/ 19-7/25 J

14xl0_11

'ixl(I 7 /21:J-8/ l

- ll 7/ 26-8/ 1 K

l lxl0 -ll 12xlu fJ/ 2 - 8/ 8 (l) Average concentrati on exposure t o airborne nat ural urani um for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> duriog the refe renced seven (7) day per iod,

l A