ML022610647
| ML022610647 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 09/18/2002 |
| From: | Chamberlain D Division of Nuclear Materials Safety IV |
| To: | Finch D Cimarron Corp |
| References | |
| -RFPFR IR-02-001 | |
| Download: ML022610647 (26) | |
Text
September 18, 2002Douglas M. Finch, Program ManagerCimarron Corporation Kerr-McGee Center P.O. Box 25861 Oklahoma City, Oklahoma 73125
SUBJECT:
NRC INSPECTION REPORT 70-925/02-01
Dear Mr. Finch:
An NRC inspection was conducted on June 24 through 27, 2002, at your Cimarron site nearCrescent, Oklahoma, of activities authorized by NRC Special Nuclear Materials License SNM-928. The lead inspector conducted a telephonic exit briefing with you at the conclusion of the inspection on September 10, 2002, following our receipt of confirmatory sample results from the NRC's contractor laboratory. The enclosed report presents the scope and results of that inspection. This inspection was an examination of activities conducted under your license as they relate tosafety and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of a review of your organization and management, radiation protection, solid radioactive waste management, transportation of radioactive materials, environmental protection, and corrective actions on a previously identified violation. In addition, groundwater and surface water samples were collected for analysis, and independent confirmatory surveys in Sub-Areas N were conducted by the inspectors. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response, if you provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this inspection, please contact D. Blair Spitzberg,Ph.D. at (817) 860-8191 or Emilio M. Garcia at (530) 756-3910.Sincerely, /RA/Dwight D. Chamberlain, DirectorDivision of Nuclear Materials SafetyDocket No.: 70-925License No.: SNM-928
Enclosure:
Cimarron Corporation-2-NRC Inspection Report 070-925/02-01cc w/enclosures:Kerr-McGee Corporation Kerr-McGee Center P.O. Box 25861 Oklahoma City, Oklahoma 73125Karen Morgan, RSOCimarron Corporation P. O. Box 315 Crescent, Oklahoma 73028Mr. Earl HatleyOklahoma Toxics Campaign 3000 United Founders Blvd. #125 Oklahoma City, Oklahoma 73112P. L. Bishop, Senior Environmental SpecialistRadiation Management Section Waste Management Division Department of Environmental Quality State of Oklahoma 707 North Robinson Avenue Oklahoma City, Oklahoma 73102-6087Mike BroderickRadiation Management Section Waste Management Division Department of Environmental Quality State of Oklahoma 707 North Robinson Avenue Oklahoma City, Oklahoma 73102-6087 Cimarron Corporation-3-bcc w/enclosure (via ADAMS distrib):EWMerscoff DDChamberlain JEWhitten DBSpitzberg EMGarcia RRMunozMIS System Materials Docket File (5th Floor)DOCUMENT NAME: s:\dnms\fcdb\emg\207092501-emg.wpd r:\_dnms\RIV:DNMS:FCDBFCDB C:FCDBD:DNMSEMGarcia via e-mailRRMu nozDBSpitzbergDDChamberlain/RA//RA//RA//RA/09/11/0209/11/0209/11/0209/18/02OFFICIAL RECORD COPYT=TelephoneE=E-MailF=Fax ENCLOSURE 2U. S. NUCLEAR REGULATORY COMMISSIONREGION IVDocket No.:70-925License No.:SNM-928 Report No.:70-925/02-01 Licensee: Cimarron CorporationKerr-McGee Center Oklahoma City, Oklahoma 73125Facility:Cimarron Site Location:Crescent, Oklahoma Dates:June 24 - September 10, 2002 Inspectors:Emilio M. Garcia, Health PhysicistRick R. Mu noz, Health PhysicistAccompanied By:Kenneth M. Kalman, Project Manager, DWM NMSSJon M. Peckenpaugh, Groundwater Hydrologist, DWM NMSS Gary W. Purdy, Health Physicist, DWM NMSSApproved By:D. Blair Spitzberg, Ph.D., Chief Fuel Cycle & Decommissioning Branch
Attachment:
Supplemental Information EXECUTIVE
SUMMARY
Cimarron CorporationNRC Inspection Report 70-925/02-01The Cimarron Corporation has been conducting site remediation activities in preparation for thetermination of Special Nuclear Materials License SNM-928. Decommissioning inspections and radiological surveys had been conducted by the NRC at the Cimarron Site as part of the overall confirmatory survey process. This inspection was a continuation of that process. This inspection included reviewing organization and management, radiation protection, solid radioactive waste management, transportation of radioactive materials, and environmental protection. It also involved performing exposure-rate and direct alpha and beta contamination measurements and collecting soil samples from Sub-Area N, and water samples from groundwater wells and from two seeps. Management Organization and ControlsThe licensee
's organization was consistent with the license requirements.The licensee had conducted periodic audits of its licensed programs.Radiation ProtectionRadiation survey instruments were operable and within their calibration interval. No occupational exposure was received in 2001 or the first quarter of 2002. Radioactivesources were stored in a locked and properly labeled cabinet. The ALARA Committee had met quarterly in 2001, and the first quarter of 2002 with oneadditional Special ALARA Committee meeting on June 26, 2002.Radioactive Waste Management, Waste Generator Requirements, and Transportation ActivitiesThe onsite waste disposal cell was properly posted. There had been no offsite, nor onsite disposal of decommissioning wastes, norshipments of radioactive waste since the last inspection.Environmental ProtectionThe licensee had procedures and practices in place to implement the environmentalprotection program at the site. The Radiation Protection Plan needed to be updated to reflect the change frommonitoring Well 1317 to TMW-13. The licensee planned on revising and resubmitting their work plan for defining andevaluating the groundwater plume associated with Burial Area 1. All environmental samples were taken as required by the license. Closeout Inspection and SurveyThe results of confirmatory measurements made in Sub-Area N of the Cimarron Site bythe inspectors were all below the applicable NRC release criteria. These confirmatory measurements were consistent with the licensee
's determination that Sub-Area N of theCimarron Site meets the criteria established in NRC License SNM-928, License Condition 27 for unrestricted use.The groundwater analytical result from well TMW-13 exceeded the applicable releasecriteria of 180 pCi/l for total uranium. This sample was collected from a well located on a known groundwater plume. All measurement results for Tc-99 were below the release criteria as determined byNRC. However, for two samples the analytical results between the NRC contract laboratory and the licensee
's contract laboratory were statistically not in agreement. This lack of agreement in analysis results was also observed during the previous inspection and will continue to be tracked as an Inspection Follow-up Item.Follow-upThe inspectors confirmed that corrective actions for a violation previously identifiedrelated to a change in the Radiation Protection Plan without prior ALARA Committee approval had been completed and this followup item is considered closed.The inspectors and licensee discussed a followup item related to lack agreementbetween the licensee
's and NRC's contract laboratories on the analysis oftechnetium-99. However this item remains open. Report Details1.Management Organization and Controls (88005, 88104)1.1Inspection ScopeThe inspectors interviewed cognizant licensee staff regarding the licensee organization,management, and audits. The inspectors reviewed a number of documents related to these activities. 1.2Observations and Findings a.OrganizationBy letter dated December 20, 2001, Kerr-McGee notified NRC of a reorganization oftheir Safety and Environmental Affairs Division. This reorganization resulted in changes in personnel and positions. The Cimarron Corporation is a subsidiary of the Kerr-McGee Corporation. The senior person directly responsible for the site is titled Vice President Cimarron Corporation. The Program Manager reports to this position and the Manager, Planning and Regulatory Compliance reports to the Program Manager. Three individuals report directly to the Manager, Planning and Regulatory Compliance. These are the Quality Assurance Coordinator; the Decontamination Supervisor; and the Cimarron Radiation Safety Officer. Contractors from Kelly Services report to the quality assurance coordinator. Contractors from NEXTEP Environmental and Chase Environmental provide support to the decontamination supervisor and the health physics and safety coordinator. The individual working as the radiation safety officer was as noted in the license. b.AuditsThe inspectors selected for review the records of semi-annual corporate audits forcalender year 2000 and the first half of 2001. Semi-annual corporate audits cover the Kerr-McGee Cimarron and Technical Center sites.The audit for the first half of calender year 2000 was conducted on May 17 and 18,2000. The audit was conducted by an auditor from the corporate organization and a contractor from NEXTEP Environmental. The response to the audit findings was submitted on January 15, 2001. The audit identified internal program requirements that were not being performed. The licensee revised their radiation protection plan; many of the radiation protection procedures; and the site health and safety plan to reflect the change in site conditions and decrease in risks that resulted from the removal of most of the radioactive materials onsite. In addition, the 2000 audit covered the review of activities performed by Cimarron to support decommissioning efforts at the KMCLLC (Kerr-McGee Cimarron Limited Liability Corporation) and Technical Center auditing a number of areas slated for decommissioning. The audit for the first half of calender year 2001, was conducted on June 4-5, 2001. The audit was conducted by two auditors from the corporate organization and a contractor from NEXTEP Environmental. The issues identified in the audit were addressed in the site manager
's response to the audit dated July 11, 2001.At this site, the radiation safety committee is called the ALARA Committee. The ALARACommittee has license authorization to evaluate and approve changes to the Decommissioning Plan or Radiation Protection Plan in accordance with License Condition 27(e). Section 2 below discusses the ALARA Committee.1.3ConclusionsThe licensee
's organization was consistent with the license requirements. The licenseehad conducted periodic audits.2Radiation Protection (83822, 88104)2.1Inspection ScopeThe inspectors interviewed cognizant individuals regarding the implementation of theirhealth physics program, reviewed applicable records, and observed the storage of radioactive materials. 2.2Observations and FindingsThe licensee had submitted their revised radiation protection plan to the NRC for reviewand approval. The NRC accepted the revised plan on April 17, 2000. a.Survey InstrumentsThe inspectors selected two portable radiation survey instruments used by thelicensee to determine if they were operable and within their calibration frequency.
The instruments were operable, had charged batteries, responded to radiation and were within the calibration interval. The licensee has their instruments on a 6-month calibration interval. b.Personnel MonitoringThe inspectors reviewed the exposure reports for 2001 through April 2002submitted by the external dosimetry supplier; selected licensee reports; and internal memorandums related to external dosimetry. The external dosimetry supplier was accredited by the National VoluntaryLaboratory Accreditation Program (NVLAP). The licensee used thermo luminescence dosimeters (TLD) as the primary means of determining the dose of record. No occupational dose was reported as having been received for any of the quarters reviewed. A review of NRC Forms 4 and 5 for all monitored individuals indicated the forms were completed accurately. These forms were reviewed through March 4, 2002. A total of 24 visitor badges were reviewed forthe period covered. Administrative limits were set at 100 millirem for individuals and 200 mRem for collective dose. Doses for the year were 0 millirem for individual and collective dose. The licensee
's ALARA goals were met.c.Radiation Work PermitsThe licensee issues Radiation Work Permits (RWP) for work where the potentialfor significant exposure to radioactive materials exists and for which no standard operating procedure (SOP) exists. RWPs used by the licensee contain the details of the job to be performed; any precautions necessary to reduce exposure; and radiological monitoring and sampling necessary before, during, and following completion of the job. The RSO indicates, by signature, the review of each RWP prior to the initiation of the work. The work appears to be carried out in adherence to the conditions of the RWPs. A total of three RWPs have been issued since September 6, 2002. Two RWPs were general work permits for the characterization of buildings and sampling of soils. The other RWP was issued for the test pit excavation/FSS/backfill operations. Each work permit included a signed and dated sheet by all parties involved and initialed by the Health Physics (HP) Technician. The RWP program and RWPs issued appeared adequate. d.Radiation Protection ProgramThe inspectors reviewed selected records of the April 23, 2001, revised radiationprotection plan. The ALARA committee maintains procedure control over its Radiation Protection Plan (RPP) and SOPs by holding meetings to discuss changes to the SOP through License Condition 27(e) authorization. KM-CI RP-38 and RP-39 were modified on Revision 4. RP-38 revised radiological surveys, routine wipes and follow-up surveys and RP-39 addressed analysis procedures.
No apparent problems were noted. The records appeared to be maintained in accordance with the requirements of 10 CFR 20.2102.e.SecurityThe licensee maintained all radioactive sources in a secured cabinet. Thecabinet was observed to be locked and the appropriate posting was in place.
The last quarterly inventory was performed by the RSO on February 12, 2002, with all sources accounted for.f.ALARA CommitteeThe minutes of the quarterly ALARA committee were reviewed for calenderyear 2001 and the first quarter of 2002. Records indicate, and the RSO confirmed, that all subsequent ALARA committee meetings have occurred each calender quarter. A special ALARA Committee meeting was held on June 26, 2002, specifically to discuss the NRC Notice of Violation dated November 26, 2001, Cimarron
's response to the NRC Notice of Violation dated December 19,2001, and any additional actions that the ALARA Committee deemed warranted to assure that full compliance with license conditions are achieved at all times. The minutes of this ALARA Committee meeting appeared to adequately address measures to prevent recurrence. g.Wipe SurveysSurveys (wipes) are conducted weekly at 15 locations for alpha contamination. Building U, which has been released by NRC, is wiped at the driveway where trucks enter and exit the facility building. The men
's and women
's changerooms, offices, count and instrument rooms, soil count room, guard station and laundry room are included in the 15 wipe locations.
2.3ConclusionsRadiation survey instruments were operable and within their calibration interval. No occupational exposure was received in 2001 or the first quarter of 2002. Radioactive sources were stored in a locked and properly labeled cabinet. The ALARA Committee had met quarterly in 2001 and the first quarter of 2002, with one additional Special ALARA Committee meeting on June 26, 2002.3Transportation Activities (86740)Radioactive Waste Management and Waste Generator Requirements (84850)3.1Inspection ScopeThe inspectors interviewed the cognizant licensee representatives; toured the site; andreviewed applicable records related to radioactive waste management to determine if the licensee had established and maintained an effective program, and to determine whether transportation of licensed materials was in compliance with the applicable NRC and US Department of Transportation regulations.3.2Observations and FindingsThere were no temporary storage/staging areas for radioactive wastes from buildingdemolition, equipment dismantlement, or soil excavation. The onsite waste disposal cell was properly posted. The licensee had placed cairns on each corner of the disposal cell that indicate the cell
's location. The onsite disposal cell was adequately protected byfencing around the entire site, onsite security, and a 4-foot cap of clean soil.There has been no offsite nor onsite disposal of decommissioning wastes since the lastinspection.There were no radioactive waste shipments made since the last inspection. The lastshipment of radioactive waste was on October of 2000 involving one shipment of radioactive waste to an offsite facility. 3.3ConclusionsThe onsite waste disposal cell was properly posted. There had been no offsite noronsite disposal of decommissioning wastes, nor shipments of radioactive waste since the last inspection.4 Environmental Protection (88045, 88104)4.1Inspection ScopeThe environmental protection program was reviewed to assess the effectiveness of the licensee's programs and to evaluate the impact, if any, of site activities on the localenvironment.4.2Observations and Findings a.Environmental MonitoringSection 15 of the Cimarron Radiation Protection Plan requires the licensee to implementan environmental monitoring program. The licensee
's environmental monitoringprogram includes monitoring surface water and groundwater well sites. The licensee
'sprogram no longer requires the licensee to submit an annual environmental report to the NRC; however, the analytical data is retained on site. b. Surface Water MonitoringSurface water samples were collected annually at seven locations and were analyzedfor gross alpha, and beta concentrations. Additional analysis for isotopic uranium was performed if the gross alpha action level of 15 picocuries per liter (pCi/l) or gross beta action level of 20 pCi/l was exceeded. The inspectors reviewed analytical results for 2001 for gross alpha and beta. Additional analysis for isotopic uranium was performed when necessary. All results for total uranium analysis were below the applicable effluent concentration limit specified in 10 CFR Part 20, Appendix B, Table 2. c.Groundwater MonitoringWater samples were collected annually from 24 monitoring wells and analyzed for thesame constituents as surface water. The inspectors reviewed the 2001 analytical groundwater data used to compile the annual environmental report. Temporary monitoring Well 13 (TMW-13) had the highest sample measured 1722.1 pCi/l total uranium. On June 19, 2000, monitoring Well 1317 was replaced by TMW-13 because monitoringWell 1317 was not producing adequate water. TMW-13 was installed to provide more representative water volumes and samples than monitoring Well 1317 had in the past.
The licensee indicated their plans to update the Radiation Protection Plan and associated procedures to reflect this change. The licensee continued to monitor the contaminated groundwater within and adjacent toBurial Area 1. Monitoring wells in this area have reported total uranium concentrations in the groundwater greater than the 180 pCi/l total uranium release criteria specified in the license for groundwater. The licensee is continuing to monitor these wells on a quarterly basis as required. The licensee
's investigation consists of monitoring thegroundwater quality, hydrology and soil activity in the area of Burial Area 1. On April 17, 2002, the licensee submitted a work plan to delineate and evaluate the groundwater plume within and adjacent to Burial Area 1. During this inspection, the NRC Project Manager and NRC Hydrologist discussed the work plan with cognizant licensee representatives. The licensee
's management stated their intent to revise the work planand resubmit it to the NRC.
4.3ConclusionsThe licensee had procedures and practices in place to implement the environmental protection program at the site. The Radiation Protection Plan needed to be updated to reflect the change from monitoring Well 1317 to TMW-13. The licensee planned on revising and resubmitting their work plan for defining and evaluating the groundwater plume associated with Burial Area 1. All environmental samples were taken as required by the license. 5Closeout Inspection and Survey (83890)5.1Inspection ScopeThe site status and decommissioning activities were reviewed to determine if activitieswere being conducted in accordance with the license, regulatory requirements, and the Cimarron decommissioning plan. The Cimarron decommissioning plan committed to the recommendations in NUREG/CR-5849, "Manual for Conducting Radiological Surveys inSupport of License Termination.
" Confirmatory measurements were conducted duringthis inspection and included exposure-rate measurements, direct measurements of total alpha and beta contamination, soil sample locations in Sub-Area N and the disposal cell.NRC License SNM-928 issued to Cimarron Corporation lists the release criteria inLicense Condition 27. The applicable values are: a.Groundwater6.7 Bq/l (180 pCi/l) total uranium The attachment to a letter from the NRC Project Manager to the licensee
'sJess Larsen dated March 13, 1997, states that the technetium-99 concentration in groundwater should not exceed the US Environmental Protection Agency
'sInterim Primary Drinking Water Regulations (40 CFR 141.16). This regulation requires that the average annual concentration in drinking water shall not produce an annual dose equivalent to the total body or any internal organ greater than 4 mrem/yr. The NRC derived concentration limit for Tc-99 is 3,790 pCi/l.
b.Surface of buildings and equipment5,000 dpm alpha/100 cm 2, average over 1 m 25,000 dpm beta-gamma/100 cm 2, average over 1 m 215,000 dpm alpha/100 cm 2, maximum over 1 m 215,000 dpm beta-gamma/100 cm 2, maximum over 1 m 2c.SoilsEnriched uranium1.1 Bq/g (30 pCi/g) total uraniumNatural Thorium 0.37 Bq/g (10 pCi/g) total uraniumd.Exposure RatesSurface of buildings and equipment5 microRoentgen/hour (µR/hr) above background at 1 meter (3.3 feet) Soils10 µR/hr average above background at 1 meter (3.3 feet).20 µR/hr maximum above background at 1 meter (3.3 feet).
e.InstrumentsThe inspectors used a Ludlum Model 19, Micro-R Meter, NaI(Tl) Gamma Scintillator, Serial Number 32888, to measure exposure rates at the locations where soil samples were collected. This instrument was last calibrated on November 30, 2001, and is due for recalibration on November 30, 2002. The inspectors also used an Eberline Model 660E, Serial Number 790, NRCNumber 063473, with a dual phosphor scintillator detector. This instrument was calibrated with this detector on December 8, 2001, and is due for recalibration on December 8, 2002. The detector used was an Eberline SHP 380 AB, Serial Number 00907, NRC Number 072358.f.Results ComparisonsThe criteria in NRC Inspection Procedure 84525, "Quality Assurance andConfirmatory Measurements," was used for comparison of licensee and NRCresults. The table that follows lists the criteria. TABLE 1Acceptance Criteria 1Resolution 2Ratio 3<40.4 - 2.54 - 70.5 - 2.08 - 150.6 - 1.6616 - 500.75 - 1.3351 - 2000.80 - 1.25>2000.85 - 1.18 1 Criteria from Inspection Procedure 84525, Quality Assurance and Confirmatory Measurements for In-Plant Radiochemical Analysis 2 Resolution is the NRC result divided by its associated 1 uncertainty.
3 Ratio is the licensee result divided by NRC result.5.2Observation and Findings a.Background MeasurementsTo determine applicable background values for the surface of buildings and equipment,the inspectors obtained alpha and beta contact measurements from the Crescent Electric Substation. This Substation is located 5 miles from the licensed Cimarron site.
Selected locations on the concrete pads, supports, berms, electrical boxes, angle iron and metal supports within the Substation were surveyed. Table 2 summarizes the background measurements. Table 2Kerr-McGee Cimarron SiteConcrete and Metal Backgrounds MediaConcreteMetalNo. of Samples44MeasurementAlphadpm/100cm 2 Betadpm/100cm 2Alphadpm/100cm 2 Betadpm/100cm 2Average68.3739.514.7392.2Median67.7725.613.5389.0Lowest52.6709.311.2376.3Highest85.1797.720.5414.4Standard Deviation13.736.13.515.4 b.Sub-Area N On June 25-27, 2002, the inspectors conducted confirmatory surveys of Sub-Area N ofthe Cimarron Site. The inspectors selected 40 sample locations. The inspectors used the same grid system that had been established by the licensee for site remediation.
The sample points were located using the licensee
's global positioning system. Theinspectors measured the exposure rate at 1 meter above the surface of each soil sampling location, and specified where the licensee staff was to collect the soil samples. The 39 soil and 1 sediment samples collected were split between the licensee and theNRC. The NRC splits were sent to the NRC
's contractor laboratory operated byEnvironmental Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute for Science Education. The samples were analyzed for uranium and thorium.
The NRC splits were analyzed by the ORISE laboratory using a traditional peak identification gamma spectroscopy program. The licensee
's contractor NEXTEPanalyzed the samples at their Kerr-McGee Technical Center laboratory using their least-square resolution method. Table 3A summarizes the exposure rates and gamma spectroscopy analysis sample results. Samples where the total uranium as determined by gamma spectroscopy exceeded 10 picocuries per gram were selected for further analysis by alpha spectroscopy. Table 3B provides the results of these analysis.As noted on Table 3A all sample results and the average value were below the releasecriteria. The criteria in NRC Inspection Procedure 84525, "Quality Assurance andConfirmatory Measurements," was used for comparison of licensee and NRC results. All but two of the results were in agreement between the laboratories. With respect to the one uranium and one thorium result that were not in agreement, the respective values were well below the acceptance criteria. Therefore, in these cases the lack of analysis agreement between the laboratories is not considered significant. Alpha spectroscopy results confirmed that the release criteria was not exceeded. TABLE 3AKerr-McGee Cimarron SiteSub-Area N Soil Samples Exposure Rates and Gamma AnalysisSamples Collected on June 25-27, 2002LicenseeSampleNo.Location aDepth ExposureRate at 1 m(µR/hr)bTotal Uranium (pCi/g)Total Thorium (pCi/g) 8Bckgnd NRC(ESSAP)Results K-MResultsAgreementNRC(ESSAP)Results K-MResultsAgreementNA-4283125N 240E0-6"912.1 +/- 2.310.08Yes1.73 +/- 0.191.69YesNA-4284105N 310E0-1'814.9 +/- 2.99.12Yes1.67 +/- 0.221.69Yes NA-4285105N 235E2'-3'81.23 +/- 0.531.51Yes0.87 +/- 0.100.83Yes NA-4286090N 341E2'-3'93.16 +/- 0.892.90Yes1.70 +/- 0.171.62Yes NA-4287235N 365E2'-3'81.91 +/- 0.762.78Yes1.65 +/- 0.161.27Yes NA-4288235N 365E3'-4'81.95 +/- 0.842.20Yes1.99 +/- 0.192.05Yes NA-4289185N 130E0-1'814.5 +/- 2.513.70Yes1.52 +/- 0.171.45Yes NA-4290155N 200E0-6"98.7 +/- 1.57.39Yes0.83 +/- 0.100.80Yes NA-4291155N 200E1'-2'92.48 +/- 0.673.73Yes0.77 +/- 0.110.61Yes NA-4292120N 240E0-6"82.17 +/- 0.804.43Yes1.58 +/- 0.171.47Yes NA-4293110N 260E0-6"87.2 +/- 1.86.84Yes1.76 +/- 0.161.50Yes NA-4294110N 260E1'-2'86.7 +/- 2.76.49Yes1.60 +/- 0.181.42Yes NA-4295157N 344E0-1'81.95 +/- 0.882.45Yes1.61 +/- 0.171.32Yes NA-4296300N 350E0-6"103.49 +/- 0.803.58Yes2.39 +/- 0.221.97Yes NA-4297350N 360E0-6"1123.2 +/- 3.113.60Yes1.98 +/- 0.231.88Yes NA-4298350N 360E1'-2'112.8 +/- 1.03.86Yes2.35 +/- 0.211.66No NA-4299101N 283E2'-3'91.36 +/- 0.791.95Yes0.66 +/- 0.100.52Yes NA-4300145N 360E2'-3'81.64 +/- 0.682.92Yes1.65 +/- 0.151.38Yes NA-4301145N 360E3'-4'82.3 +/- 1.12.56Yes1.72 +/- 0.221.33Yes NA-4302140N 210E0-6"1016.2 +/- 2.717.20Yes1.77 +/- 0.171.53Yes NA-4303140N 210E2'-3'101.10 +/- 0.652.52Yes0.99 +/- 0.110.98Yes NA-4304430N 412E0'-1'91.80 +/- 0.462.85Yes0.70 +/- 0.080.72Yes NA-4305427N 411E0'-1'80.82 +/- 0.491.61Yes0.67 +/- 0.110.68Yes NA-4306410N 420E2'-3'92.12 +/- 0.603.06Yes2.13 +/- 0.18 1.68Yes NA-4307405N 490E1'-2'92.31 +/- 0.662.45Yes1.92 +/- 0.171.80Yes NA-4308405N 490E2'-3'92.6 +/- 1.04.10Yes2.06 +/- 0.201.97Yes NA-4309350N 495E1
'-2'101.94 +/- 0.852.28Yes2.04 +/- 0.201.92YesNA-4310270N 540E1'-2'102.91 +/- 0.902.41Yes1.73 +/- 0.181.47Yes NA-4311330N 595E1'-2'91.75 +/- 0.672.26Yes1.30 +/- 0.151.38Yes NA-4312330N 595E2'-3'90.95 +/- 0.561.94Yes1.31 +/- 0.131.05Yes NA-4313410N 610E1'-2'101.08 +/- 0.741.67Yes2.05 +/- 0.211.75Yes NA-4314410N 610E2'-3'101.71 +/- 0.862.00Yes1.72 +/- 0.171.57Yes NA-4315115N 215E0"-1'810.4 +/- 1.812.80Yes2.25 +/- 0.191.84Yes NA-4316300N 345E0-1'82.71 +/- 0.944.15Yes1.80 +/- 0.221.62Yes NA-4317134N 338E0-1'82.77 +/- 0.633.70Yes1.78 +/- 0.151.78Yes NA-4318134N 338E1'-2'88.7 +/- 2.56.09Yes1.80 +/- 0.191.52Yes NA-4319110N 236E0-1'912.1 +/- 2.310.96Yes1.45 +/- 0.181.35Yes NA-4320105N 207E0-1'71.05 +/- 0.763.65No1.79 +/- 0.201.52Yes NA-4321ddd2.43 +/- 0.823.36Yes1.05 +/- 0.140.99YesNA-4322eee9.1 +/- 2.07.49Yes2.23 +/- 0.191.92YesAverage8.85.01 5.021.611.44Median92.463.471.721.51Lowest70.821.510.660.52Highest1123.217.22.392.05Standard Deviation0.945.223.900.470.40 NRC release criteria c103010 a These are the designated locations on the licensee
's global positioning system grid.
b Background was not subtracted from these values.
c The NRC release criteria values noted are above background. Background was not subtracted from the analysis results.
d NA-4321 was a sediment sample collected below seep 1206, thus no location or depth was appropriateand no exposure rate was noted.
e NA-4322 was a sample collected from a pile of soil removed from another location, thus no location nordepth was appropriate and no exposure rate was noted. TABLE 3BKerr-McGee Cimarron SiteSub-Area N Uranium Isotopes in Soil Samplesby Alpha SpectroscopySamples Collected on June 25-27, 2002LicenseeSample No. LocationDepthRadionuclide Concentration (pCi/g)U-234U-235U-238Total UNA-4283125N 240E0-6"8.4 +/- 1.10.41 +/- 0.092.24 +/- 0.3111.1 +/- 1.1NA-4284105N 310E0-1'6.92 +/- 0.870.28 +/- 0.072.40 +/- 0.329.60 +/- 0.93 NA-4289185N 130E0-1'10.3 +/- 1.30.49 +/- 0.102.82 +/- 0.3813.6 +/- 1.4 NA-4297350N 360E0-6"19.5 +/- 2.40.86 +/- 0.145.85 +/- 0.7426.2 +/- 2.5 NA-4302140N 210E0-6"13.8 +/- 1.70.69 +/- 0.125.54 +/- 0.7120.0 +/- 1.9 NA-4315115N 215E0"-1'10.2 +/- 1.30.48 +/- 0.102.23 +/- 0.3112.9 +/- 1.3 NA-4319110N 236E0-1'9.6 +/- 1.20.41 +/- 0.092.56 +/- 0.3512.6 +/- 1.3 NA-4322 aa5.43 +/- 0.690.27 +/- 0.062.13 +/- 0.297.83 +/- 0.75 NRC release criteria b 30 a NA-4322 was a sample collected from a pile of soil removed from another location, thus no location ordepth was appropriate.
b The NRC release criteria values noted are above background. Background was not subtracted from the analysis results.
c.Cimarron Electric SubstationThe inspectors selected locations on the concrete pads, supports, berms, electricalboxes, angle iron and metal supports within the Substation to take alpha and beta contact measurements. Although some survey points were higher than background for both alpha (15 cpm) and beta (190 cpm), none of the measurements taken by the inspectors exceeded the criteria in License Condition 27. Tables 4A and 4B summarize
the results.Table 4AKerr-McGee Cimarron SiteSummary of the Alpha Survey of the Surface of the Electrical SubstationJune 26, 2002Media# ofMeasurementsAverage dpm/100 cm 2 Median dpm/100 cm 2Lowest dpm/100 cm 2Highest dpm/100 cm 2 StandardDeviationConcrete5-4.5-29.6-38.772.441.4Metals1087.063.8-14.7242.585.7NRC Release Criteria5,00015,000 Table 4BKerr-McGee Cimarron SiteSummary of the Beta Survey of the Surface of the Electrical SubstationJune 26, 2002Media# ofMeasurementsAverage dpm/100 cm 2 Medium dpm/100 cm 2Lowest dpm/100 cm 2Highest dpm/100 cm 2 StandardDeviationConcrete5214.8230.6-90.0455.6175.3Metals10366.5179.382.81003.2378.2NRC Release Criteria5,00015,000 d. Ground Water SamplesOn June 25-26, 2002, NRC staff observed the collection of 16 groundwater samplesfrom wells and two seeps. The samples were split between the licensee and NRC. The NRC hydrologist preserved the NRC splits by acidification on collection. The NRC samples were sent to ESSAP. The NRC splits were analyzed for gross alpha and gross beta, by alpha spectroscopy for uranium, and by chemical separation and radiological analysis for technetium-99. The licensee used their local laboratory to conduct the gross alpha and gross beta analysis. Splits were sent to two licensee contract laboratories for alpha spectroscopy and technetium-99 analysis. There is no NRC groundwater release criteria for gross alpha or gross beta. Table 5 summarizes the ESSAP and licensee
's gross alpha and gross beta sampleresults. Table 6 summarizes the uranium alpha spectrum analysis results. With one exception (TMW-13), all analytical results for total uranium, were below the applicable release criteria of 180 pCi/l. Well TMW-13 was located within a known plume within and adjacent to Burial Area 1. This plume is believed to be the result of radiological material that had been previously buried hydrologically up gradient from this well. The licensee was developing characterization and remediation plans to address the plume. Table 7 summarizes the technetium 99 analytical results. All measurement results forTc-99 were below the release criteria as determined by NRC. When the analytical results between the NRC contractor laboratory and the licensee contract laboratory are compared using the criteria in NRC Inspection Procedure 84525, "Quality Assuranceand Confirmatory Measurements," 6 of the 12 analyses were not in agreement. For fourof these analyses both laboratories provided results that were near their minium detectable concentration (MDC) and the lack of agreement is not considered significant.
However, the NRC contract laboratory had statistically significant results for the samples from Seep 1206 and well TMW-13, while the Kerr-McGee contract laboratory had values near their MDC. This lack of agreement in analysis results was also observed during the previous inspection and will continue to be tracked as an Inspection Follow-up Item. TABLE 5Kerr-McGee Cimarron SiteGroundwater Samples Gross Alpha and Gross Beta Analysis ResultsSamples Collected on June 26-27, 2002Sample IDALPHA ACTIVITY pCi/LBETA ACTIVITY pCi/LBeta/Alpha Ratio NRC(ESSAP)Results K-MResultsAgreeNRC(ESSAP)Results K-MResultsAgreeNRCK-M1432 Seep 1206159 +/- 15102.0N75.8 +/- 8.336.9N0.480.361429 Seep 1208232 +/- 2813.7N2320 +/- 240717N10.04 52.341411 Well 1312101 +/- 1224.3N575 +/- 53216N5.69 8.89 1414 Well 131324.1 +/- 3.714.7Y151 +/- 1566N6.27 4.49 1417 Well 13203.9 +/- 2.36.8Y5.5 +/- 2.67.33Y1.411.07 1399 Well 132114.5 +/- 8.018.8Y14.8 +/- 7.610Y1.020.53 1426 Well 132450 +/- 1382.1Y43.5 +/- 8.959.8Y0.870.73 1423 Well 13250.7 +/- 1.71.15Y2.2 +/- 2.42.30Y3.14 2.00 1444 Well 132656 +/- 12101N75 +/- 12102Y1.36 1.01 1441 Well 133185.8 +/- 6.7127.0N26.3 +/- 2.819.8Y0.310.16 1402 Well 133227 +/- 1621.4Y12 +/- 1011.1Y0.440.52 1405 Well 133334.3 +/- 6.530.9Y41.4 +/- 5.726.4Y1.210.85 1408 Well 133421.9 +/- 3.520.7Y17.4 +/- 2.412.2Y0.790.591420 Well 1335a7.5 +/- 2.111.5Y8.2 +/- 1.67.14Y1.09 0.621438 Well 1336a80.6 +/- 7.425.8N475 +/- 40291N5.89 11.281396 Well 133920 +/- 3120.5Y36 +/- 2620.2Y1.800.981435 TWM-13360 +/- 23411.0Y85.2 +/- 7.887Y0.24 0.21Duplicate-1331113.9 +/- 9.3127.0Y30 +/- 3.419.8N0.26 0.16 TABLE 6Kerr-McGee Cimarron SiteGroundwater Samples Uranium Alpha Spectroscopy Analysis ResultsSamples Collected on June 26-27, 2002Sample IDRadionuclide Concentration pCi/lU-234U-235U-238Total UNRCKMNRCKMNRCKMNRCKMAgreement1432 Seep 1206109 +/- 141116.8 +/- 1.23.8830 +/- 429.6146 +/- 14144.48Yes 1429 Seep 12088.2 +/- 1.310.50.83 +/- 0.320.3512.52 +/- 0.583.8611.6 +/- 1.514.71Yes1411 Well 131234.7 +/- 4.735.13.04 +/- 0.741.5610.5 +/- 1.710.448.3 +/- 5.047.06Yes 1414 Well 131311.2 +/- 1.710.10.96 +/- 0.360.3743.46 +/- 0.712.7815.6 +/- 1.913.25Yes 1417 Well 13201.33 +/- 0.421.390.11 +/- 0.140.1050.48 +/- 0.241.161.92 +/- 0.502.66Yes 1399 Well 132110.1 +/- 1.69.650.32 +/- 0.210.2064.93 +/- 0.94.3215.3 +/- 1.814.18Yes 1426 Well 13240.61 +/- 0.441.020.06 +/- 0.20.1110.55 +/- 0.340.761.22 +/- 0.591.89Yes 1423 Well 13250.81 +/- 0.310.960.13 +/- 0.150.150.19 +/- 0.180.3921.12 +/- 0.391.51Yes 1444 Well 13264.05 +/- 0.774.860.21 +/- 0.170.3991.21 +/- 0.362.045.47 +/- 0.867.30Yes 1441 Well 133192 +/- 1189.35.08 +/- 0.953.1317.6 +/- 2.417.4115 +/- 12109.83Yes 1402 Well 133221.4 +/- 2.922.10.62 +/- 0.260.25810.9 +/- 1.611.632.9 +/- 3.333.96Yes 1405 Well 13338.2 +/- 1.212.60.36 +/- 0.270.1233.1 +/- 0.613.7811.7 +/- 1.416.50No 1408 Well 13349 +/- 1.37.820.6 +/- 0.240.4724.44 +/- 0.773.6914.1 +/- 1.611.98Yes1420 Well 1335a1.05 +/- 0.313.260.07 +/- 0.10.60.67 +/- 0.240.8781.79 +/- 0.414.74No 1438 Well 1336a17.6 +/- 2.416.20.79 +/- 0.320.8815.8 +/- 15.7924.2 +/- 2.722.87Yes1396 Well 133914.5 +/- 2.116.30.48 +/- 0.232.324.57 +/- 0.834.0919.6 +/- 2.222.71Yes1435 TWM-13302 +/- 3729315.3 +/- 2.213.9185 +/- 23187503 +/- 43493.90YesDuplicate-133198 +/- 1289.34.49 +/- 0.853.1319.6 +/- 2.617.4122 +/- 12109.83YesNRC Release criteria180 pCi/l a Uncertainties are total propagated uncertainties at the 95% confidence level. TABLE 7Kerr-McGee Cimarron SiteGroundwater Samples Technetium-99 Analysis ResultsSamples Collected on June 26-27, 2002Sample ID NRC(ESSAP) ResultspCi/lKerr-McGee (STL) ResultspCi/lBeta/Alpha RatioAgreementStatus 1NRCKerr-McGee1432 Seep 120674 +/- 1419.90.480.36N1429 Seep 12082846 +/- 335264010.04 52.34Y1411 Well 1312867 +/- 1048245.69 8.89Y 1414 Well 1313192 +/- 261546.27 4.49Y 1417 Well 13209 +/- 91.591.411.07N 1399 Well 13213 +/- 9-0.1561.020.53N 1441 Well 133119 +/- 1010.10.310.16Y1402 Well 133213 +/- 9-0.0520.440.52N1405 Well 133318 +/- 914.61.210.85Y1408 Well 133417 +/- 94.180.790.59N1438 Well 1336a970 +/- 1167885.8911.28Y1435 TWM-1389 +/- 15-0.1890.240.21NDuplicate-133130 +/- 1010.10.260.16 NEquivalent to drinkingwater standard of 4 mREM/year criterion as determined by NRC3,790 pCi/L 1 Agreement status determined from Table 1 Acceptance Criteria above.
2 1206 and 1208 are seeps. Therefore the 60,000 pCi/l Part 20 Appendix B effluent release criteria applies.5.3ConclusionsThe confirmatory exposure-rate measurements, soil sample analysis results, and alphaand beta building measurements were all below the applicable NRC release criteria.
These confirmatory measurements were consistent with the licensee
's determinationthat Sub-Area N of the Cimarron Site meets the criteria established in NRC License SNM-928, License Condition 27 for unrestricted use. The groundwater analytical result from well TMW-13 exceeded the applicable release criteria of 180 pCi/l for total uranium This sample was collected from a well located on a known groundwater plume. All measurement results for Tc-99 were below the release criteria as determined by NRC.
However, for two samples the analytical results between the NRC contract laboratory and the licensee
's contract laboratory were statistically not in agreement. This lack ofagreement in analysis results was also observed during the previous inspection and will continue to be tracked as an Inspection Follow-up Item. 6Follow-up (92701)6.1(Closed) Violation 070-00925/0101-01: Change to Radiation Protection Plan withoutprior ALARA Committee Approval. License Condition 27(e).During the previous inspection, a violation of License Condition 27(e) was identified. The violation related to a change in the Radiation Protection Plan without prior ALARA Committee approval. In a letter dated December 19, 2001, to NRC in response to the Notice of Violation (NOV), the licensee stated that the NOV would be placed in the next agenda of ALARA Committee to discuss what additional action the ALARA Committee deem warranted to assure that full compliance with license conditions were achieved at all times. During this inspection the inspectors noted that there had been two ALARA Committee meetings since the December 19, 2001, letter, and that the NOV had not been included in the agendas nor discussed. This matter was brought to licensee
'smanagement attention and the licensee decided to conduct a Special ALARA Committee meeting on June 26, 2002. The minutes of this meeting indicate that the ALARA Committee identified causes and took two actions to prevent recurrence:1.ALARA Committee agendas were generated "from scratch
" at least 2 monthsafter the preceding meeting and it was easy for the chair, the individual preparing the agenda, to forget to include or accidentally omit potentially important issues.
To prevent recurrence, a preliminary agenda would be drafted at the same time as the meeting minutes were distributed. To this baseline agenda, members would remind the chair to add items as they are identified. Also, all NRC correspondence sent or received between ALARA Committee meetings would be added to the agenda.2.To prevent implementing changes prior to documenting ALARA Committeeapproval, the Committee decided to modify the change procedure by adding a signature line to the change evaluation form. The signature line would require the signature of the HP manager, showing the date of implementation. This signature would hold the HP manager accountable for when changes are implemented, and should ensure that changes are not implemented before they are approved by the ALARA committee and documented.These corrective actions address the concerns identified by the NOV and this item isconsidered closed.6.2(Discussed) Inspection Followup Item 070-00925/0101-02: Lack of Agreement betweenNRC and Licensee analysis for Tc-99.During the previous inspection, the inspector noted that when the analysis resultsbetween the NRC contractor laboratory and the licensee contract laboratory were compared using the criteria in NRC Inspection Procedure 84525, "Quality Assuranceand Confirmatory Measurements," four of the five analyses were not in agreement. During this inspection, 12 samples were analyzed for Tc-99. All results were below the NRC criteria but 2 of the 12 results were significantly not in agreement between the laboratories. This item was discussed during this inspection but not resolved. 7Exit Meeting Summary The inspectors presented the preliminary results of the inspection to licenseerepresentatives at the conclusion of the site visit. After receipt and analysis of the last set of sample results, a telephonic exit meeting was conducted on September 10, 2002, between the lead inspector and the Manager, Planning and Regulatory Compliance.
The licensee representatives acknowledged the findings as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
ATTACHMENTPARTIAL LIST OF PERSONS CONTACTEDLicensee Cimarron CorporationD. Finch, Program ManagerJ. Lux, Manager, Planning and Regulatory Compliance K. Morgan, Radiation Safety Officer L. Smith, Quality Assurance Coordinator H. Gay, Decommissioning Supervisor J. Crawford, Hydrologist R. Jones, Project ManagerNEXTEP Environmental (contractor)S. Marshall, PrincipalR. Callahan, Technician W. Rogers, Technical ConsultantINSPECTION PROCEDURES USEDIP88104Decommissioning Inspection Procedure for Fuel Cycle FacilitiesIP88045 Environmental Protection IP83890Closeout Inspection and Survey IP86740 Transportation ActivitiesITEMS OPENED, CLOSED AND DISCUSSED Closed070-00925/0101-01VIOChange to Radiation Protection Plan without prior ALARACommittee Approval. License Condition 27(e).Opened None Discussed070-00925/0101-02IFILack of Agreement between NRC and Licensee analysis forTc-99. LIST OF ACRONYMSALARAAs Low As is Reasonably AchievableCFRCode of Federal Regulations cpmcounts per minute dpm/100 cm 2disintegrations per minute per 100 squared centimetersESSAP Environmental Survey and Site Assessment Program HP Health Physics IFIInspection Followup Item KMCLLC Kerr-McGee Cimarron Limited Liability Corporation MDC minium detectable concentration
µR/hrmicroRoentgen/hour NVLAP National Voluntary Laboratory Accreditation Program pCi/gpicocuries/gram QAquality assurance RSORadiation Safety Officer RWP radiation work permit SNMspecial nuclear material SOP standard operating procedure TLD thermo luminescence dosimeters TMW temporary monitoring well VIOViolation