ML20141G929
| ML20141G929 | |
| Person / Time | |
|---|---|
| Site: | 07003073 |
| Issue date: | 05/19/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141G920 | List: |
| References | |
| 70-3073-97-01, 70-3073-97-1, NUDOCS 9705230094 | |
| Download: ML20141G929 (12) | |
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ENCLOSURE U. S. NUCLEAR REGULATORY COMMISSION l-REGION IV t
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l-Docket No.:
70-3073 i
4 License No.:
SNM-1999 J
Report No.:
70-3073/97-01 Licensee:
Kerr-McGee Corporation j
Kerr-McGee Center l
Oklahoma City, Oklahoma 73125 l
l-Facility:
Cushing Site i
Location:
Cushing, Oklahoma Dates:
April 22-24,1997 Inspector:
Louis C. Carson 11, Health Physicist Nuclear Materials Licensing Branch Approved by:
Charles L. Cain, Chief l
l Nuclear Materials Licensing Branch i
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Attachment:
Supplemental Information i
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9705230094 970519 I
PDR ADOCK 07003073 C
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EXECUTIVE SUMMAAY Kerr-McGee Corporation. Cushing Site NRC Inspection Report 70-3073/97-01 This inspection included a review of site status, management organization and ' controls, quality assurance, radiation protection, training, waste management, effluents and environmental monitoring, and a followup of previous inspection issues.
Site Status Full-scale remediation and decontamination of contaminated areas will not begin until the NRC approves the licensee's decommissioning plan which was initially submitted in April 1994 (Section 1).
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The licensee's current activities included soil sampling and surveys, characterization i
a of radioactive material areas, characterization of unaffected areas, and site maintenance (Section 1).
Manaaement Oraanization and Controls The licensee's management and organization structure was determined to be adequate for the decommissioning activities in progress at the Cushing site (Section 2).
The quality assurance program, nonconformance reports, and special work permit programs were found to be adequate (Section 2).
Radiation Protection
' The licensee had implemented a radiation protection program that met requirements L
established in 10 CFR Part 20 and the license. Personnel radiation exposures were consistent with the level of activity at the site. No individual exceeded exposure i
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. limits established in 10 CFR Part 20 (Section 3).
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Worker radiation safety training was adequate (Section 3).
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Site fences were in good condition, and perimeter postings met tne requirements of
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Radioactive Waste Manaaement and Environmental Protection i
The environmental monitoring and radioactive waste management programs were j
adequate and met license requirements. The licensee's f ailure to submit semiannual l
effluent reports pursuant to 10 CFR 70.59 needs further review by the NRC. This matter has been categorized as an Unresolved item (Section 4).
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l 3-Insoection Follow uo of Previousiv identified Violations A violation for failure to maintain the corporate and site organization as specified by
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the license was closed. The quality assurance coordinator position has been included as part of the site organization through an October-20,1996, license amendment request (Section 5).
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Report Details l
1 Site Status I
i The NRC granted Special Nuclear Material License No. SNM-1999 to Kerr-McGee l
Corporation's Cushing site on April 6,1993. The license covered all uranium and i
thorium present in concentrations above background levels. The license authorized Kerr-McGeelto possess contaminated soil, sludge, sediment, trash, building rubble, structures, and any other contaminated material at the Cushing site during remediation and disposal activities. Full-scale remediation and decontamination of contaminated areas will not begin until the NRC approves the licensee's decommissioning plan which was initially' submitted in April 1994. The licensee's current activities include soil sampling and surveys, characterization of radioactive material areas, characterization of unaffected areas, and facility maintenance.
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2 Management Organization and Controls (88005) 2.1 Insoection Scone The licensee's management, organ'izational, and program controls were reviewed to l
ensure compliance with license conditions and regulatory requirements.
l 2.2 Observations and Findinas l-The Safety and Environmental Affairs Division of the Kerr-McGee Corporation has been responsible for NRC licensing and compliance at the Cushing site. There were l.
.54 workers on site which included 12 Kerr-McGee employees. The radiation l
protection staff included three health physics technicians and the radiation safety officer. The site manager had 42 contract crew workers, office workers, and a l
quality assurance consultant. Crew workers were used for facility maintenance, earthwork, and site surveys.
The inspector reviewed implementation of the O'.ality Assurance Plan and procedures related to site reclamation and decommissioning to determine the l
effectiveness of the licensee's control of site activities. A Quality Assurance Plan was in place for implementing the decommissioning activities. The Quality Assurance Plan requires the licensee's quality assurance coordinator to assure that ll periodic audits are conducted to verify that site plans and procedures are being fully implemented. The inspector reviewed the following quality assurance audit reports that were conducted in 1996:
l Radiation Protection Program Audit Repo'rt, September 12,1996 Audit Report 96-3, June 19,1996 l
Au jit Report 96-4, August 20,1996 i
Audit Report 96-6, November 13,1996 4
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5-The inspector found that the audits were thorough and conducted by qualified j
personnel. As examples, the auditors identified failures to completely follow the details of radiation protection procedures and special work permits. The auditors also noted that management had not responded to audit findings in a timely manner.
The inspector reviewed the Quality Assurance Audit Report Open item List which
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identifies the individuals who were assigned to resolve audit findings. Generally, the auditors found no significant violations of requirements. The licensee's audits met the requirements of 10 CFR 20.1101 for annual radiation protection program reviews.
i The inspector reviewed the licensee's nonconformance report program described in Procedure KM-QA-03, " Reporting of Nonconforming Conditions." During 1996, the l
licensee issued 28 nonconformance reports. Some nonconformance reports addressed minor violations of regulatory and license requirements such as missed i
bioassay analyses, calibrations, and personal surveys. Management promptly i
resolved most of the problems identified in the nonconformance reports. Three nonconformance reports remained open. The inspector noted that some site problems and deficiencies reported by workers were not documented as j
nonconformance reports. ' Licensee management stated that they would enhance the nonconformance program and inform workers of their duties regarding l
nonconformance reports.
License Condition No.' 11(G) requires that all work in radioactive materials areas, restricted areas, or work with licensed material not located in radioactive materials areas be in accordance with approved radiation safety procedures.
l The inspector reviewed procedures associated with special work permits and radiation safety for compliance with the license and 10 CFR Part 20. Special work permits described the details of tasks and provided instructions relating to radiation and industrial safety hazards. Each special work permit had been approved by the site manager, the radiation safety officer, and the health and safety officer prior to implementation. Of the 12 active special work permits, the inspector reviewed 1
those that potentially involved work with licensed materials. The inspector noted I
from reviews of nonconformance reports, quality assurance audits, and annual training that the special work permit program had improved since the last inspection, i
2.3 Conclusions i
The licensee's management and organization structure was consistent with license requirements and adequate for the decommissioning activities in progress at the Cushing facility. The licensee's quality assurance audits met the requirements of 10 CFR 20.1101 for annual radiation protection program review. The inspector concluded that the implementation of the quality assurance program, nonconformance reports, ar.d special work permit programs were adequate, and the safety of workers was beitig maintained.
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Radiation Protection (83822) 1 3.1 Insoection Scoce An inspection of the radiation protection program was performed to ascertain l
whether the licensee was complying with regulatory requirements established in the license and 10 CFR Part 20. Areas inspected included program implementation for radiation detection instrumentation, external and internal exposure controls, l
radiologically restricted areas, radioactive material area controls, and posting of I
notices to workers.
3.2 Observations and Findinas The licensee maintained good radiological area control of the facility. Bulletin board postings required by 10 CFR 19.11, " Posting of Notices to Workers," were determined to be adequate. During the plant tour, site buildings, fences, gates, and operating equipment were observed. No significant health or safety hazards were identified. During the tour, ground moving activities were being conducted in unaffected (radiologically clean) areas of the site. Site fences and radioactive
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material areas were properly posted with radiological caution signs. The inspector determined that the licensee was complying with the requirements for posting j
specified in 10 CFR 20.1902(e).
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The external exposure protection program was reviewed. No site personnel received
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l external radiation exposure in 1996, which was consistent with the work being conducted at the Cushing site. Film badges were being processed as required by the site Radiation Safety Plan, and radiation workers wore film badges as required.
The internal exposure protection program was reviewed. - Urine samples were used to determine internal exposure to uranium. Urine samples were required to be collected and analyzed on a bimonthly basis from employees who routinely worked with radioactive materials. One internal exposure was detected in 1996, and the individual was assigned an internal dose of 0.102 rem. Fecal bioassay samples for internal exposure to thorium were collected only under special circumstances. No such circumstances had occurred since the previous inspection.
l License Condition No.11(C) requires both initial and annual radworker health and safety training covering the topics described in the application and 10 CFR 19.12.
The inspector attended the annual radworker training and reviewed the Radiation Safety Plan. Section 12 of the Radiation Safety Plan descnoes the licensee's L
training programs and lists the 22 training objectives and topics, duration, frequency, testing requirements, and record retention requirements for site workers and visitors who enter radioactive materials areas. The annual radworker training lesson plans, records, and files were compared to the Radiation Safety Plan statements. Allinitial and annual refresher training topics and objectives were not included during the most recent annual training session as described in the Radiation l
Safety Plan and Section 8.1 of the licensee application, " Training Objectives and
i 7-Topics." The licensee provided the inspector training records which demonstrated that the remaining topics were completed in September 1996. Most subjects required by the Radiation Safety Plan and 10 CFR 19.12 were thoroughly discussed in the training sessions including a specific training session on respiratory protection.
The inspector determined that Annual Radworker refresher training was successfully completed on April 23,1997. Records were being maintained by the licensee to document attendance and test results. Records indicated that radiation protection training was provided to new site workers and that training had been provided annually to site workers, i
License Condition 11(E) requires that equipment or packages being released from the restricted area be surveyed for radioactive contamination prior to release in accordance with " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated August 1987. The licensee's equipment release program was described in the Radiation Safety Plan, Section 11.0. The Radiation Safety Plan required health physics technicians to maintain records of facility and j
equipment release contamination surveys. According to the radiation safety officer, no equipment and facility release contamination surveys were performed in 1996.
j The inspector verified by reviewing records that no equipment was released off site so far in 1997.
The inspector reviewed radiation instrument procedures, calibration records, and operational check sheets. The inspector observed health physics technicians performing instrument operational checks pursuant to Procedures KM-HP-111,
" Calibration of the Ludlum 2224," and KM-HP-126, " Performing Operational Checks on the Ludlum 2224 Ratemeter," with a Ludlum gross alpha and beta survey detector. The inspector found that the licensee was calibrating radiation detection instruments at the frequencies required by procedures. Also, an instrument calibration tracking list was being maintained as required by procedures. The inspector observed that the technician operated and performed the source checks as required by the procedures, including recording results of the daily source checks on a quality control chart. However, the inspector found that the results of several l
days of data indicated a negative trending bias for some instruments. The inspector noted that the source check procedure and technician training did not address trending interpretations. Discussions with technicians indicated they were concerned with performance when performance data was outside the allowable limits. Discussions with the radiation safety officer revealed that management's expectation was that the technicians' investigate performance trends before the instrument's performance data was outside the allowable limits. The licensee decided to further pursue this matter, because a 1996 radiation protection audit identified a similar issue.
The inspector reviewed the licensee's radioactive source leak test and calibration standard inventory program to determine compliance with the license and 10 CFR Part 20. The radioactive source program was described in Procedure KM-HP-123,
" inventory and Leak Testing of Radioactive Sources." The inspector reviewed the i
. licensee's radiation source inventory list from 1996. The inventory list appeared extensive and satisfactorily maintained. Source leak testing was performed on a quarterly basis. The inspector determined that the licensee's radioactive source program was adequate.
3.3 Conclusions Personnel internal and external exposures were low or at minimum detectable levels.
f The licensee had implemented a radiation protection program that met requirements j.
established in 10 CFR Part 20 and the license. The licensee had complied with l
requirements regarding facility and equipment releases.
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Environmental Protection (88035)
Radioactive Waste Management (88035) 4.1 Insoection Scone The inspector conducted a site tour to verify that site activities were being conducted in accordance with applicable regulations and the license. The inspector reviewed the licensee's environmental and radwaste programs to ensure that controls were adequate to protect health and safety of the workers and the general public.
4.2 Findinas and Observations License Condition 11(B) requires that prior to demolishing potentially contaminated structures or relocating contaminated material that the licensee provide a description to the NRC of methods being used. License Condition 11(H) requires the licensee to have programs in place to meet the radwaste disposal and transportation requirements of 10 CFR Parts 61 and 71. Additionally,10 CFR 70.59 requires that the licensee submits semiannual effluent reports to the NRC.
On March 14,1997, the licensee submitted a demolition plan for the nuclear processing buildings as required by License Condition 11(B). The licensee does not anticipate starting building dismantlement and demolition until 1998. The inspector reviewed the state of the licensee's radwaste, environmental, and effluents programs. The inspector found that the !!censee does not have programs in place for handling radwaste, because they do not anticipate processing and shipping radwaste until 1998.
The environmental and effluent sampling programs consisted of ambient air sampling, radiation exposure levei monitoring, and periodic groundwater, surface water, vegetation, and soil sampling. The inspector reviewed the licensee's environmental thermoluminescent and air sampling data, and the review did not reveal any significant or unusual data. The inspector reviewed environmental surf ace water results from 1996 and 1997 for five locations around the site. The licensee had analyzed samples for thorium -228,-230, and -232 and uranium -234, l
. -235, and -238. Additionally, the inspector reviewed a radioisotopic analysis of water from a pond impoundment that the licensee wanted to drain. During the tour of the pond, the licensee stated that they were considenng applying for a state discharge permit to drain the pond. The level of radioactivity in the surface water and pond were found to oe well below 10 CFR Part 20, Appendix B, release limits.
The licensee was planning to wash contaminated clothing when full decommissioning started. The inspector further reviewed license and regulatory requirements regarding effluent and environmental monitoring. The inspector found that the licensee had nct submitted semiannual effluent monitoring reports to the NRC as required by 10 CFR 70.59. The Cushing site was licensed in April 1993.
Licensee management explained that since the cite was undergoing decommissioning operations as opposed to processing, fabrication, scrap recovery, or conversion operation, they were exempt from the requirements of 10 CFR 70.59.
The inspector concluded that this matter required further review by the NRC's Office of General Counsel and the Low-Level Waste and Decommissioning Projects Branch.
c Pending review of this matter by the NRC, this item will be categorized as an Unresolved item (URI 70-3073/9701-01).
4.3 Conclusions The environmental monitoring and radwaste management programs were adequate.
Site activities, which were limited to prereclamation, appeared to have been conducted in accordance with the license. The licensee's failure to submit semiannual effluent reports pursuant to 10 CFR 70.59 needs further review by the NRC. This matter has been categorized as an Unresolved item.
5 Follow-up on Corrective Actions for Violations and Deviations (92702) 5.1 (Closed) Violation (70-3073/9501-01): Kerr-McGee Cushina Oroanizatigo A violation was issued from the previous inspection for failure to maintain the corporate and site organization as specified by the license, Also, the licensee failed to have radiation safety procedures reviewed and approved by a corporate vice-president as specified by the license. The NRC issued a violation, because the licensee did not follow the Cushing license requirements or modify the license to reflect plans for decommissioning the facility.
During this inspection, the inspector determined that the licensee had submitted a license amendment request to update the existing corporate and site organizations that included the quality assurance coordinator position.
6 Exit Meeting Summary The inspector presented the inspection results to the representatives of the licensee at the conclusion of the on-site inspection on April 24,1997, and during a telephone conversation on April 29,1997. Licensee representatives acknowledged the
. findings as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.
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1 ATTACHMENT I
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PARTIAL LIST OF PERSONS CONTACTED i
i Lic.gnsee P. Defog, Quality Assurance Coordinator (Contractor)
T. Gibson, Clerk R. Jones, Health Physics Technician J. Lux, Project Manager l
T. Moore, Radiation Safety Officer, Kerr-McGee Corporation R Pounds, Site Manager, Kerr-McGee Corporation State of Oklahoma Gene Smith, Department of Environmental Quality, Radiation Management Section i
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ITEMS OPENED. CLOSED AND DISCUSSED
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. 70-3073/9701-01 URI Failure to submit semiannual effluent monitoring reports as l
specified in 10 CFR 70.59.
Closed j
70-3073/9501-01 VIO Failure to maintain the organization and manapument controls in accordance with the license.
Remained Ooen and Discussed l
None I
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