ML20151L056
| ML20151L056 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 07/31/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151L046 | List: |
| References | |
| 70-0925-97-02, 70-925-97-2, NUDOCS 9708060229 | |
| Download: ML20151L056 (13) | |
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{, ENCLOSURE U. S. NUCLEAR REGULATORY COMMISSION i
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. REGION IV
.i Docket No.: 70-925
. License No.: SNM-928 l Report No.: 70 925/97-02
- . Licensee
- Cimarron Corporation Kerr-McGee Center l Oklahoma City, Oklahoma 73125 i Facility: Cimarron Site i
! Location: Crescent, Oklahoma Dates: May 20, 21, and 27,1997 Inspector: Louis C. Carson 11, Health Physicist i Nuclear Materials Licensing Branch f Approved By: Charles L. Cain, Chief l Nuclear Materials Licensing Branch t
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9700060229 970731 PDR ADOCK 07000925 C PDR l
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EXECUTIVE
SUMMARY
l Cimarron Corporation, Cimarron Site NRC Inspection Report 70-925/97-02 Cimarron is in the final stage of site remediation in preparation for termination of its nuclear materials license. This routine inspection included a review of the site status, radioactive waste shipments, the radiation protection program, waste management, the environmental monitoring program, and followup of previous inspection issues. Radiological inspections and surveys have been conducted at Cimarron as part of the NRC confirmatory survey process.
This inspection report contains the results of confirmatory surveys that were performed by the NRC during a previous inspection on March 26,1997. The licensee is authorized to dispose of contaminated soil at an authorized low-level waste site. This inspection focused on contaminated soil being placed into 55-gallon drums and loaded into trucks for shipment to Envirocere of Utah, incorporated.
Insoection of Transportation Activities and Radioactive Waste Manaaement - Inspection of Waste Generator Reauirements, and Radiation Protection
- The inspector determined that waste shipment radiation levels were within the limits of 49 CFR Part 173 and met the requirements of 10 CFR Part 20 and 49 CFR Part 173.
The licensee's quality assurance program for radioactive waste processing and shipping was adequate. The inspector could not determine the adequacy of 49 CFR 172.704 waste processing and shipment training due to the unavailability of records. This i
. matter was identified as an Unresolved item (URI 70-925/9702-01) for review during I a future inspection (Section 2).
Followup to Previous inspection Findinas l
- A previous issue of technetium-99 in groundwater samples will remain open until the licensee's groundwater cleanup program is accepted by the NRC and the licensee ,
implements groundwater corrective action procedures (Section 3 ).
- The NRC confirmed that licensee soil being placed in Pit No. 3 had less that 100 picocuries/ gram uranium. No significant bias or statistical errors between the licensee's soil results and the NRC's results were identified. Therefore, the licensee's soil meowrement methods and counting times were found to be acceptable (Section 3).
- Based on the licensee's commitment to use a pressurized ion chamber ta support future exposure rate measurements, an open item concerning confirmatory surveys on Pit No. 3 soil samples and exposure rate measurements is closed (Section 3).
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s Report Details 1 Decommissioning Inspection Procedure for Fuel Cycle Facilities, Closeout inspection and Survey, Site Status (83890/88104)
The radioactive materials transportation, radiation protection, environmental protection, and radioactive waste management programs were inspected to determine if the licensee was implementing the programs in accordance with regulatory requirements and the license. Cimarror has been undergoing final remediation activities for termination of its NRC license. Remediation at the Cimarron site was more than 90 percent complete. The licensee's Decommissioning Plan had been submitted to the NRC in April 1995; howover, the plan, which is under review, has not been approved.
The licensee continued to implement the Decommissioning Plan, although the plan had not received NRC approval. The licensee's current activities included soil sampling and radiation surveying, characterization of radioactive materialareas, facility maintenance, and shipping waste to Envirocare of Utah, incorporated (Envirocare). The work activity at Pit No. 3 represented the final soil remediation effort underway by Cimarron and is planned for completion by this summer. Final survey activities for the site are underway. This inspection was a continuation of the NRC's confirmatory survey program for the Cimarron site. The inspector observed contaminated soil being placed into 55-gallon drums and loaded into trucks for shipment to Envirocare.
2 Inspection of Transportation Activities (86740), Radioactive Waste Management -
Inspection of Waste Generator Requirements (84850), Radiation Protection (83822) 2.1 Inspection Scope k The inspector reviewed licensed activities related to the transportation of waste
[ materials for disposal to determine compliance with the license, licensee procedures, and applicable requirements of the NRC and the Department of Transportation (DOT).
! The inspector reviewed licensee shipping documents including radiation survey records.
j 2.2 Findinas and Observations i
[ a. Radioactive Waste Shioments I
License Condition 18 requires the licensee to dispose of radioactive contarninated solid waste at a licensed low-level waste disposal site. The licensee's proposed i i Decommissioning Plan commits Cimarron to ship waste, as described in the 1981 NRC
- Branch Technical Position, to a low-level waste disposal site. Cimarron currently has
- a license from the Centralinterstate Compact to export waste material from Oklahoma to Envirocare in Utah. This license expires on June 30,1997, and Cimarron was i working to dispose of waste matenal before the license expires; otherwise, Cimarron ;
! must renew its license. The inspector verified that Cimarron had a copy of Envirocare's 1 j waste disposailicense to receive special nuclear material. Based on Envirocare's waste j disposal license, Cimarron's waste was limited to 350 grams of uranium-235 per !
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shipment. Cimarron's Procedure KM-CI-RP-23, Revision i, " Low Level Radioactive j i
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Waste Packaging and Shipping," Sections 4.4.1.4 and 4.4.1.7, incorporated the total uranium-235 limit and included a limit of 15 grams of uranium-235 per container.
As of this inspection, Cimarron had shipped two truckloads of waste (primarily soil, with lesser amounts of pellets, fiberglass insulation, paper, etc.) in 55-gallon drums.
The inspector observed the licensee loading a third truckload of drums with waste.
Each truckload contained about 60 drums weighing no more than 800 pounds each.
Cimarron also planned on shipping 12 intermodal railroad transport containers that will contain primarily scrap metal.
The waste shipments were designated as " Exclusive Use" shipments, and the waste material was classified as " Radioactive LSA [ low specific activity]-1." The inspector reviewed the licensee's Radioactive Waste Shipment and Disposal Records and Nuclear Material Transaction Report. The inspector determined from reviews of the log that only materialthat Envirocare was authorized to accept for disposal was being packaged in the drums. The inspector determined that the licensee had met the drum packaging and shipment acceptance criteria that were included in Section 4.4.1 of Procedure KM-Cl-RP-23.
- b. Quality Assurance Durina Radioactive Waste Processina The inspector reviewed quality assurance controls associated with implementing Cimarron's waste handling procedure as related to receipt, handling, and shipping of drummed waste. According to the licensee's procedure, the radioactive waste drums are inspected by Cimarron as follows:
- Upon receipt of empty drums from the supplier
- During drum packaging
- Before drums are loaded onto trucks
- During and after truck loading (1) Receipt of Drums from the Supplier Each drum was checked for integrity, and a number was assigned. The drums were found to be properly labeled in accordance with Sections 7.2.2 and 7.2.3 of Cimarron's radioactive waste procedure. The drum inspection numbers, initials of the inspector, date of inspection, status of the drum (" accepted" or
" rejected"), and the type of dium (17H or UN1 A2), were entered into the Drum inspection Log. The inspector noted that: (1) some record entries in the log were in pencil, (2) there were some erasures, and (3) there were no notations as to who made the changes.
From reviewing the log, the inspector noted that drum No.10884 had been rejected the previous day. The inspector asked Cimarron personnel to locate the rejected drum to verify that the rejected drum had not been later used as a waste package. The inspector noted some confusion in locating the drum, but eventually the drum was found. The inspector concluded that the particular drum in question had been properly rejected. The inspector discussed with the i
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licensee the possible need to review procedures to ensure that rejected drums l
- are moved to a location where they will not be mistaken for accepted drums. l (2) Drum Packaaina inspection
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i L Theinspector observed contaminated soilbeing loaded into waste drums. A%r l l the radioactive waste material had been packed into a drum, the drum was j sealed, weighed, and the arnount of uranium-235 was calculated. This j information was logged into the "Dium Loading Sheet," for each drum. In l l accordance with Section 4.4.1.4 of the waste handling procedure,' the log indicated that none of the drums contained more than 15 grams of U-235.
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l- Section 4.4.1.1 of the procedure required that the bolts on the closure ring be torqued to a minimum of 40 foot-pounds. Although no one could provide any verification of the torque on the wrench, Cimarron personnel interviewed were confident that the torque was more than 40 foot-pounds.
In accordance with Section 4.4.1.11 of the waste handling procedure, the log indicated that none of the' drums weighed more than 800 pounds. The inspector was informed by the licensee that the scale used to weigh the drums was calibrated on a daily basis.
Some information required by the waste drum loading sheets had not been' completed. For example, for drums Nos. 5456. 5425,5423, and 5427, "date" i and " reviewed by" spaces were blank. Section 4.4.1 of the procedure required that only new drums be used. The boxes for drums Nos. 5448 and 5456 were ;
not checked to show whether they were new or used drums. Corrections were i made on the loading sheets without notations of why each change was made or who made each change. The inspector concluded that these items were of l minor significance and did not constitute violations of any regulatory ;
requirement. j (3) Drum Shioment insoections Durina and After Truck Loadino ;
The inspector observed waste handlers during and after loading a truck for shipment. The inspector reviewed the " Notice of Shipment" sheets and verified ,
that information from the drum loading sheets had been accurately transferred '
! to the shipping manifest. The inspector observed the senior health physics technician survey the truck, prior to the shipment, using a calibrated survey instrument. All measurements were less than 0.2 mrem /hr. The inspector observed that the smearable contamination was within the requirements of j Section 4.4.1.2 of the procedure. In accordance with Section 7.2.6.4 of the j procedure, the Notice of Shipment was signed by the health physics technician ,
who conducted the inspection, and the shipment documents were approved and signed by the site manager, ,
) Section 4.6.3 of the licensee's waste procedure stated, in part, that the i maximum weight of a waste shipment could not exceed 42.000 pounds without
l 6-prior arrangements with the carrier. Of the four waste shipments that the !
licensee had processed, shipment No.3 which left site on May 20,1997, I weighed 42,165 pounds. Based on discussions with the licensee no prior I arrangements had been made with the carrier regarding the need to exceed the 42,000-pound shipping limit. At the time of this inspection, the licensee was not bound to follow its procedures by the current license. However, a pending license amendment when issued will require that the licent;ee comply with the radioactive waste processing and shipment procedure. The inspector verified that the licensee was in compliance with NRC and DOT waste shipment requirements. Licensee management stated that it was its intent to comply with the precedure. The licensee decided to remove the 42,000-pound limit from the procedure since neither the DOT, nor the carrier, required this shipment weight limitation. The inspector noted, however, that licensee qua'ity assurance audits missed identifying that the weight !imit on waste shipment No.
3 had been exceeded. The inspector concluded that this matter was minor because the licen::ee's weight limit did not have a regulatory basis.
Overall, the inspector concluded that the licensee's quality assurance program for radioactive waste processing and shipping was adequate.
- c. Personnel Radiation Protection Durina Waste Drum Loadina The inspector observed workers' radiation protection practices during waste drum loading operations. Workers wno were loading the drums with waste wore protective clothing consisting of gloves, coveralls, and boots. The waste workers were required to monitor themselves for contamination using an alpha survey meter prior to exiting the restricted area. Additionally, the workers wore lapel air samplers and had a continuous air sampler operating in the work area. Radiation protection staff required that personnel approach the waste loading area upwind to minimize potential exposure.
The inspector noted that the air monitoring devices did not appear to be close enough to the work area or directly downwind from the loading process. The inspector further noted that the monitors were operating when no one was loading the drums.
However, the inspector observed that the waste dirt was moist and generally did not appear to be airborne. The inspector concluded that radiation protection was adequate for drum loading operations,
- d. Radioactive Waste Worker Trainina The inspector reviewed training and qualifications of personnel associated with radioactive waste activities based on the following:
- DOT 49 CFR Part 172, Subpart H, Hazardous Materials Training (HAZMAT) a Recent changes in DOT 49 CFR Part 173
- Inspection & Enforcement Bulletin 79-20, " Packaging, Transport, and Burial of Radioactive Waste"
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- NRC Generic Letter 95 09, " Monitoring and Training of Shippers and Carriers of Radioactive Materials" l
The inspector reviewed the following licensee training attendance records:
- Low-Level Radioactive Waste Packaging and Shipping, Procedure KM-CI-RP-23, April 25,1997
- DOT General Awareness / Familiarization Training, March 7,1997 l
- HAZMAT Function Specific Training, March 13,1997 l
- Waste Packaging Training, March 18,1997 i i
The inspector determined that the licensee provided waste shipment and HAZMAT l training as required by the regulations. The licensee also provided a record of '
- certification that all Cimarron staff involved in waste processing and shipments were trained as required by 49 CFR 172.704. However, the licensee did not have detailed training plans, had not prepared training materials, and had not conducted proficiency tests. According to the licensee, training covered each relevant DOT and NRC regulation and Procedure KM-CI-RP-23, " Low-Level Radioactive Waste Packaging and Shipping." The license provided the inspector a copy of the test that employees took in November 1994. At the time of this inspection, the licensee could neither provide the details of all waste training nor the test results for employees. The DOT requires, j pursuant to 49 CFR 172.704(4)(d), recordkeeping by the licensee to include a j description, copy, or location of the training material used to meet the requirements of HAZMAT training, and a certification that the HAZMAT employee has been trained and tested. The licensee stated that it needed more time to gather all the required records.
1 The inspector concluded that the adequacy of the licensee's waste processing and shipment training could not be determined during this inspection. Therefore, this matter was determined to be an Unresolved item IURI 70-925/9702-01).
2.3 Conclusions The inspector determined that waste shipment radiation levels were within the limits of 49 CFR Part 173 and met the requirements of 10 CFR Part 20 and 49 CFR Part 173.
The licensee's quality assurance program for radioactive waste processing and shipping was deemed adequate. The inspector could not determine the adequacy of 49 CFR 172.704 waste processing and shipment training, due to the unavailability of records.
This issue was identified as an Unresolved item which will be reviewed during a future inspection (URI 70-925/9702-01).
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3 FOLLOWUP (92701) 3.1 (Open) Inspection Followuo item (IFl 70-925/9602-01): Technetium-99 in Groundwater l An IFl was previously opened to review the licensee's folbwup of radiological l occurrences according to procedural guidance, especially, pertaining to the licensee's l investigation of technetium-99 in groundwater. On April 21,1997, the NRC informed the licensee that a license amendment for the possession of technetium-99 was not required. The NRC also informed the licensee that it would reed to fully investigate ,
- sources of technetium-99 and establish a site-specific cleanu,o requirement when it !
responds to the NRC comments in its June 1997 groundwater report.
During this inspection, the inspector sought to determine if the licensee had completed the technetium-99 investigation, established site-specific cleanup requirements, and fully documented this matter in accordance with Procedures KM-CI-RP-5, " Radiological Occurrence Reports" and K M-Cl-RP-43, " Environmental Monitoring" used to 1 investigate action level exceedances. According to the environmental monitoring procedure, environrnental action levels were established for water samples that measured more than 15 pCill gross alpha radiation and greater than 20 pCi/l gross beta radiation. Section 5.7 of Procedure KM-Cl-RP-43 identified several actions that the ;
radiation safety officer was to perform when responding to and investigating i environmental action levels that have neen exceeved. One such action was to analyze and review probable causes. The inspector noted that the licensee had not initiated !
followup pursuant to the procedure. During this inspection, licensee management explained that the technetium-99 investigation was ongoing, although a groundwater !
characterization report had been submitted to and reviewed by the NRC. Therefore, the licensee had not fully documented and implemented corrective actions regarding technetium-99 in groundwater.
l This matter will remain open until the licensee's groundwater cleanup program is accepted by the NRC, and the licensee implements groundwater corrective action procedures to close the investigation on the technetium-99 issue. ,
3.2 (Closed) IFl 70-925/9701-01: Confirmatory Soil Samolina Scope Condition 23 of License SNM-928 authorizes burial of up to 14,000 cubic meters of i soil contaminated with low-enriched uranium with concentrations less than the Branch l Technical Position Option No. 2 concentration limits which are 100 pCi/gm soluble uranium and 250 pCi/gm insoluble uranium. The inspector reviewed the licensee's compliance with License Condition 23 for soil placed in Pit No. 3. This item involved the placement of in-situ soil meeting Branch Technical Position Option No. 2 criteria in Pit No. 3. The primary objective of this portion of the inspection was to confirm that
- the licensee placed soilinto Pit No. 3 that met the Option No. 2 criteria. Additionally, this item involved unexplained differences between the licensee's sodium iodide detector exposure rate measurements at Pit No. 3 compared to the inspector's measurements.
9 Results On March, 26,1997, the inspector observed the licensee collect ten soil samples from Pit No. 3. These soil samples were split for analyses by Cimarmn, the NRC's Region lli laboratory, and a contract laboratory at the Oak Ridge Institute for Science and Education (ORISE). The results of analyses of these soil samples were compared to the results of the soil samples collected at the same locations by Cimarron as part of the NRC's confirmatory sampling program for the Cimarron site. The table below presents the final results of the 10 confirmatory sample soil measurements.
Regarding Pit No. 3 exposure rate measurements, the proposed Cimarron Decommissioning Plan requires the licensee to follow the recommendations of NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination." Section 5.3 of NUREG/CR 5849 states that exposure rate measurements are to be conducted using a pressurized ion chamber (PIC). NUREG/CR 5849 further states that if use of a PIC is not practical then the licensee may opt to cross calibrate the sodium iodide detector with a PIC for the energy source of interest (i.e., radium-226, thorium, or uranium). The inspector noted that the licensee calibrated its sodium iodide detector with a cesium-137 radiation source which was not representative of the energy source of interest. On June 25,1997, the licensee committed to using a PIC to support future exposure rate measurements at the Cimarron site. The inspector determined that the exposure rate measurements taken by the NRC and the licensee during the previous inspection were not final release surveys for Pit No. 3. The inspector concluded that the licensee's commitment to use PICS would resolve the unexplained differences between the licensee's and NRC's sodium iodide detector exposure rate measurements at Pit No. 3.
. Soil Sample and NRC Survey Results From Pit No. 3 Sample # isotope Cimarron ORISE NRC NRC pCi/gm pCi/gm pCi/gm pR/hr 1 U-234 14.6 + /- 4.15 16.56 + /- 0.74 13 415N\510E U-235 0.7 + /- 0.1 9 0.78 + /- 0.09 U-238 4.7 + /- 0.2 9 4.98 + /- 0.2 8 Total U 19.9 + /- 4.62 22.32 + /- 0. 8 2 U-234 46.4 + /- 3.77 43.8 + /- 1.7 7 18 356N\525E U-235 2.1 + /- 0.1 7 2.21 + /- 0.1 7 U-238 14.2 + /- 0.29 16.73 + /- 0.7 3 Total U 62.7 + /- 4. 2 3 62.75 + /- 1.92 3 U-234 25.9 + /- 4.17 26.2 + /- 1.11 17 320N\525E U-235 1.2 + /- 0.19 1.46 A /- 0.13 U-238 15.2 +/- 0.3 12.06 + / 0.5 6 Total U 42.3 + /- 4.66 39.73 + /- 1. 2 5 4 U-234 42.2 + /- 3.99 16.5
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340N\515E U-235 1.9 + /- 0.18 1.1 + /- 0.24 ~
U-238 12.5 + /- 0.3 12 + /- 1.3 Total U 56.6 + /- 4.47 -
5 U-234 29.1 + /- 3.96 17 350N\520E U-235 1.3 + /- 0.18 1.3 + /- 0.3 -
U-238 11.5 + /- 0.29 10 + /- 1.2 ~
Total U 41.9 + /- 4.43 ~
6 U-234 48.3 + / 3.76 17 365N\515E U-235 2.2 + /- 0.17 1.3 + /- 0.2 -
U-238 12.9 + /- 0.29 7.3 + /- 1.0 ~
Total U 63.4 + /- 4.21 -
7 U-234 43 + /- 4.18 16 305N\515E U-235 1.9 + /- 0.19 1.5 + /- 0.3 U-238 17.4 + /- 0.32 14 + /- 1.4 Total U 6.2.3 + /- 4.68 8 U-234 39.1 + /- 3.62 15 ;
285N\520E U-235 1.7 + /- 0.16 1.2 + /- 0.3 i U-238 7.3 + /- 0.27 9.6 + /- 1.13 Total U 48.2 + /- 4.05 9 U-234 42.5 + /- 4.15 38.51 + /- 1.58 16 375N\520E U-235 1.9 + /- 0.1 9 2.94 + /- 0.2 _ _ _ _
U-238 14.0 + /- 0.31 14.59 + l- 0.65 Total U 58.4 + /- 4.64 56.03 + /- 1,7 2 10 U-234 29.3 + /- 3.8 27.01 + /- 1.21 16 395N\520E U-235 1.3 + /- 0 .1 7 1.39 + /- 0.1 4 ,
U-238 10.6 + /- 0. 2 8 9.41 + /- 0.4 8 Total U 41.3 + /- 4.24 37.81 + /- 1.31 +
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, Conclusions The NRC confirmed that soil being placed in Pit No. 3 had less that 100 pCi/gm uranium.
Therefore, the licensee was in compliance with Cimarron License Condition 23. No significant bias or statistical errors between the licensee's soil results and the NRC's results were identified. Licensee soil measurement methods and counting times were acceptable. Based on the licensee's commitment to use a PIC to support future exposure rate measurements, the open itern regarding confirmatory surveys on Pit No. 3 soil samples and exposure rate measurements is closed. ,
4 Exit Meeting Summary l The inspector presented the inspection results to the representatives of the licensee at the conclusion of the on-site inspection on May 22,1997, and during a telephone conversation 5
on May 27,1997. Licensee representatives acknowledged the findings as presented. 1 During a telephone discussion between the Cimarron site manager and the inspector on June 25,1997, the licensee committed to using a PIC to support future exposure rate measurements at the Cimarron site. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector. ;
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a i i PARTIAL L:ST OF PERSONS CONTACTED .
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Cimarron Corocration ;
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! M. Hodo, Quality Assurance Manager ;
J, Kegin, Site Manager '
- J. Larsen, Vice President,- Cirmarron ,
- K. Morgan, Radiation Safety Officer J. Stauter, Vice President, Kerr-McGee ,
Contractor Personnel .;
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H. Newman, NEXTEP Environmental i .W. Rogers, Technical Consultant !
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! l NRC Personnel K. Kalman, Project Manager, Nuclear Material Safety and Safeguards INSPECTION PROCEDURES USED IP ~ 83822' " Radiation Protection" IP 83890 " Closeout inspection and Survey" IP 84850 " Radioactive Waste Management -Inspection of Waste Generator Requirements "
IP 86740 " Inspection of Transportation Activities" IP 88005 " Management Organization and Controls" ,
l lP 88035 " Radioactive Waste Management" IP 88045 " Environmental Protection" 1 IP 92701 " Followup" l
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. ITEMS OPENED, CLOSED AND DISCUSSED Opened 70-925/9702-01 URI DOT training and test records not available 1
Closed l 70-925/9701-01 IFl Confirmatory Soil Sampling Discussed 70-925/9602-01 IFl Licensee followup of radiological occurrences.
ABBREVIATIONS USED DOT U. S. Department of Transportation HAZMAT Hazardous Material Training IFl Inspection Followup item LSA Low Specific Activity ,
ORISE Oak Ridge Institute for Science and Education l PIC Pressurized ion chamber URI Unresolved item Tc 99 Technetium-99 R/hr microRoentgen/ hour