ML20215F134

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Partially Withheld Insp Repts 70-0925/81-02 & 70-1193/81-02 on 810505-08.No Noncompliance Noted.Major Areas Inspected: Organization,Operations,Internal Audits,Training,Radiation Exposure Control,Security & Physical Barriers
ML20215F134
Person / Time
Site: 07000925, 07001193
Issue date: 06/15/1981
From: Greger L, Peck C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215F104 List:
References
FOIA-86-576 70-0925-81-02, 70-1193-81-02, 70-1193-81-2, 70-925-81-2, NUDOCS 8612230276
Download: ML20215F134 (11)
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT l REGION III s

Reports No. 70-925/81-02; 70-1193/81-02 Docket Nos.70-925; 70-1193 ' Licenses No. SNM-928; SNM-1174 Licensee: Kerr-McGee Nuclear Corporation -- .

Kerr-McGee Center Oklahoma City, OK 73102 Facility Name: Cimarron Facility Inspection At: Cimarron Facility, Crescent, OK Inspection Conducted: May 5-8, 1981 Inspector: C. C. Peck h (- t- (p!/4 7/

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Approved By: L. R. Greger, Acting Chief ( ////P/

Facilities Radiation / '

Prote.ction Section Inspection Summary Inspection on May 5-8 1981 (Reports No. 70-925/81-02; 70-1193/81-02)

Areas Inspected: Routine, unannounced health and safety inspection, including: organization, operations review, internal audits, training, external and internal radiation exposure control, radioactive waste management, transportation activities, and environmental monitoring.

Selected portions of the licensee's physical security program were also inspected, including: security organization, physical barriers, access controls, key control, and detection aids. The inspection involved 24 inspector-hours onsite by one NRC inspector.

Results: No items of noncompliance were identified in the areas inspected.

8612230276 PDR 861219 FOIA FOWLERS 6-576 PDR.

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DETAILS

1. Persons Contacted
  • A. W. Norwood, Cimarron Facility Manager
  • R. L. Fine, Health and Safety Supervisor
  • R. C. Borgmier, Plutonium Plant Decontamination Supervisor
  • V. D. Richards, Uranium Plant Decontamination Supervisor l
  • Denotes those present at the exit interview.
2. General This routine inspection began at 1:00 p.m. on May 5,1981, with a tour of the plutonium plant. The uranium plant, coal liquefaction facility, emergency building, and selected outside areas were toured during the following days to observe standby work activities and radiation protection practices.

4 In the plutonium plant, the principal current activity is repack-aging of low-level radioactive vaste to ensure that packages will meet package requirements of commercial or government-owned burial sites.

Equipment removal and decontamination work continue in the uranien plant at an incr. eased rate. .. Items are packaged for transport t9 a radioactive waste burial site, stored, or cleaned and released (or industrial use elrewhere.

Activity at the coal liquefaction plant continues. The facility occupies the warehouse, laboratory, and administrative, area of the shutdown uranium plant. A physical separation of the coal plant from the uranium plant is achieved by walls, fencing, and controlled doors. The coal plant organization is separate and independent of the uranium and plutonium plant organization, although air in the coal plant is centinuously monitored for radioactivity at selected locations.

The inspector also examined certain aspects of the licensee's physical protection system and the licensee's corrective actions for two items of noncompliance identified during the previous physical protection inspection in April 1980 (Report No. 70-1193/80-03). The items are considered closed. Details of the physical protection portion of the inspection are described in the Attachment (2.790(d) Information).

3. Organization There have been no major changes in the Cimarron facility organiza-tion since the inspection in September 1980 (Inspection Reports No. 70-925/80-03; 70-1193/80-05). A group of 28 employees is re-sponsible for the decontamination, maintenance, security, and accountability activities authorized by the NRC licenses. There has been a shift in emphasis from plutonium plant decontamination

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to the uranium plant, primarily because packaging and burial site regulations prevent disposal of plutonium - contaminated waste generated during decontamination.

4. Review of Operations
a. Plutonium Plant License No. SNM-1174 for the plutonium plant does not permit any process operations. Amendment No. 3 to the license authorized the removal of the solvent extraction (SX) system, a task that was the principal work activity during 1980. At the time of this inspection, all SX equipment had been removed from the single large glovebox and packaged in 55 gallon drums for eventual burial.

A plasma arc torch was used to reduce the long stainless steel columns to shorter segments for packaging. Work remaining is removal of steel equipment supports, and disassembly and volume reduction of the glovebox. The glovebox ventilation system remains in operation. In early 1981, work on SX system removal was discontinued temporarily to repackage the accumulated waste (Section 10).

Amendment No. 4 to the license authorizes decommissioning of the remaining systems and equipment in the plutonium plant. The work has not begun.

The report for the inspection conducted in September 1980 (In-spection Reports No. 70-925/80-03; 70-1193/60-05) described an accumulation of several 55 gallon drums partially filled with mop water slightly contaminated with plutonium. The licensee subsequently assembled a small ion exchange column about four inches in diameter, and removed the plutonium from the water.

The cleaned water was released to the sanitary lagoon.

b. Uranium Plant Equipment decontamination activities in the uranium plant have been accelerated. Since the inspection in September 1980, a decontamination system consisting of a steam cleaning unit and ion exchange columns was installed for the cleaning of larger pieces of equipment that cannot easily be cleaned by hand. The steam cleaning unit is located in a plastic tent. Condensate is collected in a sump, then passed through an ion exchange column to remove the uranium. The water is sampled and .*nalyzed for radioactivity, then discarded to the sanitary lagoon. The eluate from the ion exchange column is notgally concentrated about 7 g/l in uranium enriched about This material is blended with depleted ura(2.6% 'in uranium-235.ntumioo uranium oxide for shipment to the company's conversion plant.

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

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s i l Equipment found to be free of radioactivity may be released l unconditionally for industrial use. The licensee maintains a l

fenced area outside the restricted area ~where clean equipment _ '

is stored before release. The licensee said that survey and disposal records are being maintained .for all equipment that is released.

The licensee stated that a small amount of highly enriched uranium that was found in an unused screw feeder on April 6, 1981g had een mixed with depleted uranium to produce a blend witN t0.71 enrichment. Impurities in the blend made it unsuit-able 'for use in the fuel cycle and the material was packaged for shipment to a burial site. Analysis of the material before blend-in disclosedp27.1g f uranium with a uranium-235 enrichment of pl% A license amen ment is being considered in anticipation of pos'sible future findings of small quantities of higly enriched uranium. The present license does not provide for possession of uranium enriched over(5%}

The inspector toured the coal liquefaction plant briefly and observed that the facility is physically separated from the uranium plant by fences and building walls. Air in the coal plant is continuously monitored for radioactivity at three locations.

5. Audits The Staff Health' Physicist from the corporate office continues to con-duct quarterly audits of radiation safety performance and adherence to AI. ARA principles. Audits for the third and fourth quarters of 1980 and the first quarter of 1981 were reviewed.

The corporate Senior Compliance Specialist audits compliance with regulatory requirements quarterly. Audits conducted in October 1980, January 1981, and April 1981 were examined. In April, waste packag-ing and shipment procedures for the uranium and plutonium plants were audited.

!!onthly criticality safety audits are being conducted by a specialist from the corporate office. Criticality controls, the alarms in the plutonium plant, and the recently activated monitors in the uranium plant were reviewed in recent audits.

The Health Physics Supervisor conducts monthly housekeeping and safety inspections. Inspection reports are reviewed by management and correc-tive actions taken.

No items of noncompliance were identified.

6. Training Monthly safety meetings continue for Cimarron facility employees. A health physics subject is presented at least quarterly, while other meetings are devoted to appropriate industrial safety, fire safety, and criticality safety topics.

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- 1 Extensive training in fire safety continues. The facility has a fire brigade and maintains close liaison with the nearby Cashion and Crescent !

Fire Departments whose members recently made visits to gain familiarity with the site and to present training. The-Maintenance and Utilities Supervisor attended a one-week fire training program at Oklahoma State University in May 1981.

Annual employee safety retraining for 1980 was conducted beginning in October 1980, and continued into early 1981. The training sessions, which totaled 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, included sessions in radiation and its bio-logical effects, radiation detection and protection, criticality safety, emergency procedures, industrial safety, and security.

No items of noncompliance were identified.

7. External Exposure Control All employees are provided with film badges. Badges of maintenance, health and safety technicians, and operating people in the uranium and plutonium plants are changed monthly. Adminictrative and security employees change badges quarterly. The highest total whole body dose worker involved in the decommi(ssioning of the solvent extractionfor an system. Other totals were generally much lower.

No items of noncompliance were identified.

8. Internal Exposure Control
a. Air Sampling In the uranium plant, air is sampled continuously at about 21 locations. Samplers are also located in the office, laboratory, and laundry of the adjacent coal liquefaction plant. The samples are counted after eight or 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> collection cycles, then re-counted af ter about a week to permit radon decay. Examination of sample results accumulated since September 1980 disclosed no results exceeding the maximum permissible concentrations of IE-10 uCi/ml on the initi I count.

The air is similarly sampled and analyzed in the plutonium plant, at about 40 locations. Examination disclosed no samples exceeding the MPC of 2E-12 uCi/ml for soluble plutonium. Samples generally did not exceed 1E-13 uCi/ml Conditions of the licenses for the uranium and plutonium plants require that 50% of the individuals involved in maintenance and decontamination activities be equipped with lapel air samplers.

Records indicated that lapel samplers are being used as required in both plants. The data disclosed no exposures to concentrations above HPC.

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.b. Respiratory Protection Full-face respirators are used in the plutonium plant, while either full-face or-half-face respirators may be used for uranium work. Quantitative fit testing and annual retesting are a requirement.

c. Bir. assay Progran Annual lung counts were last conducted in August 1980. Results
  • were summarized in the previous inspection report (Inspection Reports No. 70-925/80-03; 70-1193/80-05).

Quarterly urinalyses are required for workers in the plutonium plant. An outside contractor analyzes the samples. Security people and administrative personnel submit annual samples.

Results since September 1980 disclosed no concentrations above the detection limit o.f 0.1 dpm/ sample.

Uranium plant workers submit biweekly samples that are analyzed by a radiometric technique at the licensee's Technical Center, located a few miles from the plant. The fluorometric method can also be used. The minimum detectable concentration for the usual radiometric method is 10 dpm/1. Concentrations above 65 dpm/1 call for resampling and an investigation of the cause. Work re-strictions are imposed at 260 dpm/l. The inspector observed no concentrati.ons above the 65 dpm/1 level in records since September 1980, but during the inspection the Technical Center reported the data tabulated below for two uranium plant workers.

Radiometric Fluorometric Date of Date Result Reanalysis Sample Reported dpm/1 ug/l I

Individual 1 4/3/81 5/5/81 579 86 l 4/15/81 5/5/81 27 -

4/21/81 5/6/81 103 28

\ s r r e Individual 2 4/2/81 5/5/81

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4/20/81 5/6/81 65 4.5 5/4/81 5/6/81 58 19.0

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The licensee promptly initiated an investigation to determine the significance and cause of the high concentrations. Addi-tional samples were collected from the workers. Both employees were engaged in the dismantling and steam cleaning of equipment and operation of the ion exchange system during the period when the elevated samples were submitted. Neither fixed air samples nor lapel sampler results gave an indication of airborne uranium that could have been inhaled. Respirators were apparently worn as required during equipment dismantling and removal. Neither employee could suggest a reason for the elevated sample concentra-tions. Both were restricted from work with radioactive materials pending further investigation and an evaluation of their exposure.

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Following the inspection, the licensee continued the investiga-tion. Urine samples were obtained for four consecutive days frem the individuals for analysis by both the radiometric and fluorometric methods. The licensee reported that all samples had concentrations well below 65 dpm/1 and most were below the minimum detectable concentration.

While examining urinalysis. data the inspector observed that the time between sample submittal and the reporting of the analytical result was frequently about five weeks, as in the data tabulated above. The inspector considered this to be too long an interval, and discussed the matter with the ricensee at the exit interview.

No items of noncompliance associated with internal radiation pro-tection were identified. The high uranium concentrations in the urine samples of the two uranium plant workers is considered an unresolved item, pending the licensee's evaluation of the data.

9. Radioactive Waste Management Liquid wastes are discharged to the east sanitsry lagoon onsite.

Transfer can then be made to a second sanitary lagoon but waste volumes have not been large enought to require use of the second-lagoon. Wastes from the plutonium plant consist of sanitary wastes plus mop water from which most of the radioactivity has been removed by ion exchange. The liquids are bate to the lagoons from a hold-ing tank af ter a.nalysis for radioacti j content. Uranium plant effluents are sanitary wastes plus mop water and waste liquid from the cleanup process from which most of the radioactivity has been removed. No liquids are released to the unrestricted area.

Gaseous effluents from the uranium and plutonium plants contain small amounts of particulate radioactivity. The air from the plutonium plant passes through a system of HEPA filters before exiting through a continuously monitored stack. The inspector examined records indi-cating that all. final filters in the ventilation system received an annual in place test in 1980 and were determined to be at least 99.95%

efficient. Data disclosed that the average plut ium concentration in the the effluent during maximum 1980 wad permissible [.32 E-15 uCi/ml concent(ration hich is less than of 6E-14

/ml, ufor release of soluble plutonium to an unrestricted area, without an allowance for dilution.

The radioactivity in gaseous releases from the uranium plant is measured at three stacks. Licensee calculations indicate that con-centrations measured at the stacks are each less than the limits for release to an unrestricted area.

The management of solid wastes in described in Section 10, Transpor-tation Activities.

No items of noncompliance were identified.

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10. Transportation Activities Radioactive materials are not received at the site, and shipments are limited to those radioactive materials packaged during decon-tamination activities.

There have been no shipments to waste burial from the plutonium plant in about two years. 'The plutonium content of packages shipped to com-mercial waste burial sites is limited by Department of Transportation regulations and burial site licenses to ten nanocuries per gram in low specific activity waste. The licensee has many drums of LSA waste in storage. Packaging is in new 55 gallon 17H drums to avoid possible packaging problems associated with the use of reconditioned drums.

The waste secumulated during dismantling of the solvent extraction system, most of which exceeds the LSA limit of ten ntnocuries per gram, is being repackaged in accordance with the Department of Energy 20 year retrievable storage requirements for possible disposal at a DOE waste storage site. After segregation into combustible and non-combustible wastes, the materials are being packaged in specification 17C drums which have a rigid 90 mil liner. The licensee has obtained a number of Model N-55 overpacks, an NRC-certified packaging for use in the transportation of greater than Type A quantities of plutonium.

Seven shipments of LSA waste from the uranium plant to commercial burial sites have been made since the inspection in September 1980.

(Inspection Repo.rt No. 70-925/80-03). New specification 17H steel drums were used in all shipments. The inspector examined the associated shipping papers and radiation survey records.

No items of concompliance were identified.

11. Environmental Monitoring The licensee continues to monitor air, surface water, well water, soil, and vegetation in the vicinity of the facility. An examination of data for 1980 disclosed no evidence of any significant environmental radioac-tivity.

Air samples were collected weekly at three stations located about a half mil'e from the restricted area. No results exceeded IE-14 uCi/ml of alpha acitivity.

Surface water samples were taken at about nine locations, including the nearby Cimarron River and several ponds on company property.

Gross alpha and beta activity in the river samples were less than the detectable limits of 10 and 18 pCi/1, respectively. All sample concentrations were less than the regulatory limit for release to an unrestricted area. The samples were also analyzed for fluoride and nitrate concentrations.

Water was sampled at three wells on company property and at an offsite farm. The farm well in IW showed no detectable radioactivity. One of the other three samples ontained a small concentration of radioac-tivity, but within the unrestricted area release limit.

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Soil and vegetation samples were collected at several locations from the perimeter fence to a distance of several miles. Results indicated no significant radioactivity in the samples.

13. Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. An unresolved item disclosed during the inspection is described in Section 8.
14. Exit Interview The inspector met with the licensee representatives identified in Section 1 at the conclusion of the inspection. The inspector sum-marized the scope and findings of the inspection.

The high uranium concentrations in recent urine samples submitted by two uranium plant employees were discussed (Section 8). The licensee said that the effort to determine the cause would continue, and that the data would be evaluated to determine exposures as required by 10 CFR Part 20. The licensee agreed with the inspector that the time required fer obtaining urinalysis results is too long. Frequently, there are five weeks between sample submittal and reporting of the results. The licensee said that the times for delivery of samples to the laboratory and for sample analysis would be reduced.

The inspector in" formed the licensee that no items of noncompliance had been found during the physical protection portion of the inspection and that two items of noncompliance identified during the previous inspec-tion of April 1980 (Inspection Report No. 70-1193/80-0 were considered closed.

Details are contained in the Attachment (2.790(d) Information)

Attachment:

Part 2.790(d) Information

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Attachment to Report 70-1193/81-02; 70-925/81-02 Kerr-McGee Nuclear Corporation Docket No. 70-1193

1. General During tours of the plutonium facility, the inspector observed the functioning of the security organization, physical barriers, access controls, key control system, and detection aids. The licensee's

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corrective actions for two items of noncompliance during the previous '

physical protection inspection were examined.

2. Action on Previous Inspection Findings

' (Closed) Infraction (70-1193/80-03): The

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[*h secondary alarm station.

id not annunciate at the 10 CFR 73.5 d)(1) requires that all 5#'# .

alarms other annunciate alarm station. in The a central alarm station and in at least one inspector verified that an alarm is receivedatthesecondarystationwheneachofthegouralarmjs the primary station are activated. t (Closed) Deficiency (70-1193/80-03):

been given writt.en examinations after(they had viewed traininwope tapes.

The inspector verified that tests were administered to the{two uards.

3. Security Organization The licensee continues to maintain an in-house security guard force consisting of~

per shift, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days } **g ,,

p, b- a week. Other emp oyees provide relief for the guards as

necessary. W[**#

The inspector determined from an examination of records that all present guards successfully passed a firearms qualification or re-qualification test between October 1980 and March 1981.

No items of noncompliance were identified.

4. Physical Barriers During tours of the facility, the inspector observed that physical barriers to the protected area, the vital area ntilation supply room and the wo ateria) access areas were a equate. Access to the ) vital areathe {an opaterial access areas requires passage through more than one ysical barrier. The isolation zone was clear of objects w' hich might conceal or aid in gaining entrance to the protected area.

No items of noncompliance were identified.

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3717 D.:C'JENT IS NOT TO E PIPRCLUCCD '.HTHOt:I SPECITIC APPROVAL Ol' RIII

[ 5. Access Controls The inspector noted that all individuals observed entering the pro-tected and an area were searched explosives detector. with the aid of a hand-held metal detector Exiting personnel were searched with the metal detector and an SNM detector. All hand-held packages were opened and subjected to a visual search.

Photo-identification badges are required for unescorted access into the protected area. The inspector observed that the guards required badges to be displayed before entry into the protected area.

An examination of the visitor's log for February and March 1981, indicated that each visitor was assigned an authorized escort.

No items of noncompliance were identified.

6. Key Control Keys are located in a locked box in the entral alarm station} hen notinuse,underthecontroloftheguar n duty. The inspector verified that the guards are maintaining a record of the issuance and return of keys.

No items of noncompliance were identified.

7. Detection Aids , ,,

- The inspector verified that the alarm system for detecting penetration of the protected area barrier was operable. Attempts to approach the perimeter fence caused activation of the alarms in the central alarm station.

Entrance into the vital areas and the two} material access areas are protected by ntrusion alarmQ except or the'Csingle personnel en-l trance door w ich has a combination lock] During tours of the mat rial operable.area, the inspector verified that selected @ trusion alarms ere access Packaged SNM is stored in room 121 of MAAko'. had in the vault which isMAAg.2 boxesandeq$OtherSNMisdistribu d in inaccessible form in glove-uipment within . 1 The ' ctor observed that the

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FEB 11 1983 Docket No. 70-1193 Kerr-McGee Nuclear Corporation ATTN: Mr. W. J. Shelley Vice President Licensing and Regulations Kerr-McGee Center Oklahoma City, OK 73102 Gentleman:

This refers to the routine safeguards inspection conducted by Ms.

at G. M. Christoffer of this office on January 17-21, 1983, of activities the Cimarron facility authorized by NRC Special Nuclear Material License No. SNM-Il74 and to the discussion of our findings with Mr. A. W. Norwood and members of his staf f at the conclusion of the inspection.

The enc:ssed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and

, interviews with personnel.

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During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix.

The inspection showed that action had been taken to correct the identified noncompliance and to prevent recurrence. Consequently, no reply to this noncompliance matter at is required and we have no further questions regarding this this time.

Areas examined during this inspection concern a subject matter which is exempt from disclosure according to Section 73.21(c)(2), Part 73, Title 10, Code of Federal Regulations. This information must be handled and protected in accordance with the provisions of 10 CFR 73.21. Consequently, the enclo-sure to this letter and our report of this inspection will not be placed in the Public Document Room.

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.' l Kerr-MeGee Nuclear Corporation 2 FEB 11 1933 We will gladly discuss any questions you have concerning this inspection.

Sincerely,  ;

. R. Miller, Chief

.aterials and Safeguards Branch

Enclosures:

1. Appendix, Notice of Violation
2. Inspection Report cc w/encls: >

B. E. Brown, General Manager Manufacturing IE/DFFMS/SB NMSS File NMSS/SG

. cc w/encls, w/o L3 CLASSIFIED SAFEGL'ARDS INFOR'!ATIGN:

DMB/ Document Control Desk (RIDS)

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(stoffer/jpr4eed ( ttf u Cl Pe Ridgway il er

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U.S. NUCLEAR REGULATOFY COMMISSION REGION III Report No. 70-1193/83-01(DRMS)

Docket No. 70-1193 License No. SNM-1174 Safeguards Group I Licensee: Kerr-McGee Nuclear Corporation Kerr-McGee Center Oklahoma City, OK 73102 Facility Na:ne: Cimarron Facility Inspection At: Cimarron Facility, Crescent, OK Inspection Conducted: January 17-21, 1983 Date of Last Physical Protection Inspection: April 4-8, 1982 Type of Inspection: Routine, Unannounced Physical Protection Inspector: ..

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M. Christoffer 9hk

/ bate hysical Protection Specialist Approved By: _

R. Creed, Chief date afeguards Section Inspection Summary Inspection on January 17-21, 1983 (Report No. 70-1193/83-01)

Areas Inspected: Included a review of Security Plan and Implementing Procedures; Security Organization - Manabement; Security Organization -

Personnel; Security Organization - Response; Records and Reports; Testing

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and Maintenance; Locks, Keys, and Combinations; Physical Barriers - PA; Physical Barriers - VA, MAA; Security System Power Supply; Assessment Aids; Access Control - Personnel; Access Control - Packages, Material and SSNM; Detection Aids - PA; Detection Aids - VA, MAA; Alarm Stations; and Communi-cations. The inspection involved 28 inspector hours onsite by one NRC inspector. 'Ihe inspection began during the day shif t; one inspector-hour was accomplished during of fshift periods.

Results: The licensee was found to be in compliance within the areas examined during the inspection except for the following item:

1. Physical Barriers - Protected Area: A portion of the perimeter fence was not properly maintained (Paragraph 11).
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