ML24138A072

FOIA-2023-000184 - Released Set

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

Text

UNITEDSTATES N UCLEAR REGULATORY COMt11SSION fH:GIOl'-l II/

s, 1 RY I\\N PLAZA OF\\IVE. SUITE 1000 ARLI/IIGTON, TE.* AS 76011 August 31, 197B License ro. SUB-1010

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

This refers to the inspection conducted by Messrs. R. J. Everett and C. L. Cain of this office on August 10-11; 1978, of tne activities authorized

by t!RC Source Mater ial License No. SUB-1010, and to tne discussion eif our findings held by Messrs. Eve r ett and Cain with Messrs. B. E. Brown and C. E. ~rossclaude on August 11, 1978,

The inspect-ion was,an examination of the activities conducted under the license as they relate to radiation safety and compliance with the The inspection consfsted of se1ect1ve e~aminations of procedures and Co, ission's rules and r egulations. and the conditions of the 1icen:;e.

representative records, interviews of personnel, independent meas~renents and observations by the ins?ec~or.

The fnspectors also reviewed the action you hud ta~en with respect to two (2) items of noncompliance observed during our previous inspec~ion, whicn was condu.. ed June 15 - 17, 1977. They verified that the corrective action with ret;pect to these items was implemented as stated in your reply of July 20, 1977, to ~ur !et~er dated July 6, 1977.

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

This notice is sent to you pursuant to the provisions of Section 2.201 of Sec.tion 2.201 requires you to submit to this office, withrn t*(lenty (20) the me "Rules of Practice," Part?., Title 10, Code of Feder'il1 Regulations.

days of your receipt of this notice. a written in reply 1ncludi:,g (1) corrective actions \\vhich have oeen taten by you statement or explanation a'.'oid furtner 1:.ems of r.oncomoliance; and the results achie1ed; (2) correctiv~ actions w~ich wi11 oe ta~en :o and ('.3) the da':.e wnen full compli~nce will be achieved.

781121 (/. J /

Kerr-*~cGee nuclear Corporation August 31, 19i8

Title 10, Code of fed~r~l Regulation~. a copy of th1s letter and the In accordance with Section 2.790 of the 'lRC "~ules of Prac~ice, 11 Part 2, enclosed inspection report w11l be placed in the ilRC's Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within twenty (20) days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons it is claimed that the infonnation is proprietary. It should be prepared so that proprietary infonnation identified is contained in a separate part of the document, since th~ application, excluding this separate part, will also be ~laced in the Public Document Room. If we do not hear from you in this regard within the specif'led period, the report wilJ be placed in the Public Document Room.

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

Sincerely,

,,{ "JV C ll # t ~.L I

/h Glen O. Brown, Chief Fuel Facility and Material

Sa fcty Branch Enc 1 osu res:

1. Notice of Violation

2. IE Inspect:ion Report ico. 40-8027/78-01 License i{o. SUB-1010

tlotice of Violation

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

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

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

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

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

This is an infraction.

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

This fs an infraction.

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

This is an infraction.

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

781121 1 //;

• f.nntrary to this requirement:

a. During the period October 1977 to August 1978, surface contamination levels in the operating areas of the plant eAce!ded and remained above the control ' alue of 2,000 dpr:t/100 cm srrearable activity as specified in Section 3.4.3 o Appendix A.

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

This is an infraction.

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

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

This is an 1nfraction.

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

Contrary to this requirement:

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

This fs an infraction.

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

REGION I'!

Report Ho. 40-8027/78-01 License No. SUB-1010 Licensee: Kerr-McGee Nuc1eur Corporation Ke rr -McGee Center Docket No. 40-8027

Oklahoma City, Oklahoma 73125 Facility: Sequoyah Uranium Hexafluoride Conversion Facility Inspectior. at: Gore, Oklahoma In~pection conducted: August l0-11, 1978

Inspectors; g/z'1 /1s C. [. Ca1n, Radiation Specialist Da te

R. J. Everett, Rad1at\\on Specialist

Approved by: G. O. Brown, Chief, Fuel.Facility and Material

Safety Branch

rnspection Surnary Inspection on August 10 and 11, 1973 (Report No. 40-03027/78-01)

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

.and administration; facilities and equipment; internal exposure control; ex~ernal exposure control; environmen~al monitoring, auaits and training; emergency planning and fire protection; posting, labeling, and reports; and independent measurements. The inspection involved sixteen (16) hours on site by two inspectors.

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

infraction - failure to obtain soil samples, see paragrdph li infractio n -

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

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

OETAILS

l. Persons Contacted

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

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

~Members present at exit interview.

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

2. License Action on Previous Inspection Findings

a. (Closed) Moncompliance (40-8027/77-0l): This item involved failure to conduct monthly audits of health physics programs by facility management required by License Condition 8 of SUB-1010. This license condition was modified in the renew~rl license issued October 1977.

b. (Closed) Noncompliance (40-8027/77-01): This item involved failure to post radiation areas. The inspectors verified proper oosting of radiation areas during the plant tour.

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

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

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

78112 1 01 5 v

Sequoyah Facility

8. E. Brown, General r**anager, C. E. Grossclaude, Manager, Heal th Physics ~ Industrial sa;ety tluclear ~anufact1.:ring J. W. Craig, ~anager, Conversion Engineering L. H. Harrison, Manager, Administration & Accounting employees, which includes about 78 1n production, 40 in maintenancThe licen~ee stated that the facility staff is comprised of about 14 8 e and 30 salaried workers.

4. Facilities and Equipment on August 10, 1978, to observe operations in progress and verify that The inspectors t oured the plant and the liquid effluent retention ~reas equipment and facilities were in accordance with app1icable l icense requirements. The l ice11see stated that the plant capacity had been doubled to 10,000 tons pe:-- year cof'11'11enc i ng April 1978, as authorized by a renewed license dated October 1977. The licensee stated that the plant operating <<.chedule was twent:;- fou?* (24) hours per day, seven (7) days per week. During the plant tour tne inspectors verified thot correcti~e aLtion had been maintained regarding the posting of r adiation areas, a~ item of noncompliance from the June 15, 1i nspect i on. The plant was observed to be operating and housekeeping 977, was noted as being poor. The license2 stated that this condition was due in large degree to the recent plant modifications necessary to increase production capacity.

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

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

5. Internal Exoosure Control The licensee's air sampling rogram is described in the license Application. Aµpendix A. Licensee records lisled 46 air sampling locations in war~ locations within the plant. - ~ ~se samples are collected s~ch 8-hcur shift and analyzed radiomftrically for tolal alpha emission after a 4-hour delay. Each worker is recuired to tabulate his work time in each area. The ~PC-hoer exposure is then calculatdd on a seven-day exposure perioc. The licensee s~ated that air sampling in the solvent extraction buildin~ had been terminated,

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

A review of uir sampling data revealed many areas in the plant where airborne radioactivity concentrations exceeded Part 20, Appendix B1 Tabler, limits. Exposure records indicated no evidence of overexposure to personnel. This was achieved by limiting occupancy and/or utilizing respiratory protection equiprner1t. Daily Radiological Status Reports listing air sample results greater than 0.5 MPC were reviewed. These reports were noted to be distributed to various plant and corporate management personnel. Process engineering controls had been implemented to reduce airborne radioactivity concentra tions 1 but concentrations were still recorded above those that would delimit an airborne radioactivity area. A rotary valve had been installed on the re-drum hopper in the sampling plant and additional ventilation had been installed. The licensee stated that several other measures had been studi~d, but none of these had yet been implemented. The inspectors were unable to clearly determine whether the licensee's effor*c; to provide engineering and process controls were sufficient to comply with 10 CFR 20.lOJ(b)(l). The item wa~ left unresolved pending discussion with NRC Licensing.

The licensee stated that a respiratory protection program has been established in accordance with Regulatory Guide 8.15. Internal exposure wearing respirators. A records were found to apply protection factors for those p~rsonnel polydisrerse OOP man-test system with a fitting chamber has been used in conjunction w1th the pr~gram. Records indicated that personnel had received medical examinations including lung dynamics tests as a part of the program. Copies of written examindtions relating to respiratory protection were contained in employee record files. Comprehensive written procedures were found descr ~bing the program.

were worn with head strap~ over hard hat helmets and that irritant During the plant tour, i~~pectors observed that half-mask ~espirators

smoke testing was not performed, prior to use, each time respirators w~re donned. The licensee also indicated that twelve (12) workersr who received allowance for respirator use, had not completed the respirator fitting and t~sting program. The inspectors seated that these 1tems constituted noncompliance with 10 CFR 20.103(c).

App~*dix A The 1 *c~nsee's bioassay program is described in Section 3.4.2., of the application. The inspectors' discussions with the lic~nsee and a review of pertinent records estJblished that the program being conducted 1tas as described in the app1 ication. The bi-roonthly urinalysis sched~le for plant workers is designed to ~onitor the controls implem~nted for routine worker expos11re. The ~nspector.s noted some data in exce,s of 20 micrograms per liter action lev&l and inquired as J the 1 icensee's evaluation. n1e licensee sta"ed that in ec1ch case the workar was restricted from further exposure until tile next bioaSiaY indica:ed normal levels. ihe licensee stated f~rther that

noted that the bioassay laboratory did not, in two instances, report some of the high samples may have been contaminated. The inspectors levels in excess of the action level in e timely manner, sufficient to allow resampling to confirm the result from an acute exposure standpoint. Powever. once the licensee was informed, samples were collected and t1*.~se samples yielded nonnul values. The licensee stated that acute exposures should be readily identified so that more with the Lioa~say laboratory in order to expedite the reporting of fref'!~~nt,";ampling can be conducted, and discussions would be held data.

L'icensee records ind,cated that in vivo lung counting is perforr.ied by a vendor as described in the License Application. Appendix A. A review of current data revealed no result in excess of 10 CFR 20.lOJ(a) limits.

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

6. External Exposure Control workers on a monthly exchange. External exposure data was reviewed Licensee records i ndi ca ted tr,a t film badges are provided to a 11 and no exposures were noted in excess of 20.101 limits.

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

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

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

7. Env i ronmental ri~oni toring The 1 in license appl1cation references specified in License Cicensee's environmental monitoring program is described ond i tion 12.

The liquid effluent stream from the plan~ is continuously sampled at the site bounda,*y. Daily grab samples are analyzed for uranium.

analyzed for uranium, gross alpha, gross beta. nitrate, and fluoride. fluoride, nitrate, pH, and temperature. Monthly co,:iposites are Quarterly nalyses ~re performed ior Ra-226 Jnd Th-230. All radio logical data were less than tne applicable Part 20, Appendix B, Table tt, values. A no upward trending. ~nalyses for fluoride, uranium, and nitrate review of nonradiological parameters revealed are performed at the SeQuoyah Facility. Analyses for gross alpha, gross beta, radium, and thorium are performed at the Kerr-McGee Technical ~enter, Oklahoma City.

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

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

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

• a siated that there had been no burials of wastes since the last inspection.

Air sampling is performed at plant stacks, hatches, and vents; at four (4) locations within the boundary fence; and at five (5) locations off-site. Samples are analyzed for gross alpha and fluoride. Two boundary samples are analyzed for uranium, Th-210, and Ra-226. Data for these boundary sampl~s were noted to be we 1 1 below applicable MPC's for unrestricted areas. These data are used by the licensee to determine release quantities to unrestricted areas for compl *ance with 10 CFR 40.65. The method entails ratioing of gross alpha concentrations between the stacks and the boundary samplers in order to determine total discharge of uranium. Ra-226.

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

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

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

The inspector stated that contrary to this requirement soil samples had not been obtained at the 6000 foot distances, since the renewed license had been issued. The inspectors stated that failure to obtain such samples constituted noncompliance with License Condition 12.

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

The licensee stated that this sampling program had not been initiated since the renewed license was issued. The inspectors responded that failure to obtain such samples constituted noncompli~nce with License

Condition 15.

8. Audits and Training Reports of weekly, monthly, and ~uarterly audits were reviewed and found to be performed as required by Appendix A. Documented mi nut es of safety meetirigs were also reviewed. Licensee training activities are detailed in appendices of the License Application. New employees receive two hours of safety training and a safety handbook at time of hire. A second training session of two hours dur~tion is provided within several weeks of hire, The licensee stated that female employees are Instructed in the contents of Regulatory Guide 8.13 and that signatory verification of this instruction is required.

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

loss prevention. The licensee stated that such testing had not begn performed. The licensee was informed by the inspectors that failure to a~ninister such testing constituted noncompliance with License Condition 9. The inspectors intervic,-1ed one \\*1orv.er and detennined that her un<lerstanding of the radiological hazards was sufficient to comply with 10 CFR 19.12.

9. Emergency Planning & Fire Protection The 11censee's emergen~!' planning :ind fire protection programs are described in Appendix A. Tr ~ fire protection program includes t~mpeN-+:trre activated foam spray heads in the SX 81Jildin9, sprinkler systems 1n cable trays, temp~r~cure activated nitrogen purge in the fluoride cell room, and manual fire extinguishers throughout the

performed during the second quarter of 1978. The fire horn and plant. The licensee's insurance underwriter i1,spection \\~as last emergency generator are tested monthly. Nine hose stations are

., I supplied by a 150,000 gallon holding tank and are fed by diesel and electrical pumping equipment which is also checked monthly. Observation of approximatelJ 10 manuul extinguishers revealed that these were inspected monthly. Emergency teams on each shift have had instruction on each team have had first aid training. The licensee stated that in the use of self -contained breathing apparatus. Seve ra l individual!

there had been neither simulated fire exercis~s nor fire drills since the the last inspectio n. The 1 icensee was found to have several documented inspection. procedures pertaining to f1re response and to systems operations and

10. Posting. Labeling and Reports The inspectors noted that inc:.iming and outgoing shipping containers were labeled as LSA and radioactilie. Forms tlRC-741, completed upon receipt and transfer of source material~ \\-iere reviewed; and cumpl iance with 10 CFR -l0.64(a) was verified. The 1nventory report required by 40.64(b) was reviewed. The inspe~tors noted that documents were posted as requ1red by 10 CFR 19.11, but that no regulations or procedures were posted relating to Pa rt 21. The licensee stated that there were no procedures relating to the reporting of defects. The ~nspect~rs stated that failure to establish such procedures consti~uted noncompliance with 10 CFR 21.Zl(a).

The inspectors noted continuous fencing of the restricted area and access control at the main gate. 1he plane entrance was posted with the information that all areas within the mill may contain radioactive material.

11. Independent M~asurements

A Yiater sample was obtained from tne combined effluent stream at the boundary fence. The sample will be,,nal"zed for uranium, gross alpha, gross beta, Ra - 226, and Th-230. The analytical results from Idaho Health Services Laboratory will be later compared to the: licensee's r esults of samples taken at the same location.

12. Unrs~o1ved items Unresolved items are matters about 'Hhich more infonnation is re~uired in order to determine ~,hether they are acceptable items, items of noncompliance 1 or dev1i.:1tions. Two unresolved items were identified duri n~ the insper.t icn These items are discussed in paragraphs 5 and 7.

78112~

13. Exit Interview The inspectors met with licensee management (See paragraph 1) at the conclusion of the inspection on August 11, 1978. The inspectors su:1111arized the purpose and scope of the inspection and sunmarized the findings.

KERR-MCGEE NUCLEAR t70R P/JPt ~t.

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

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

Fuel r1cility 6 Material Safety Branch -

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

RE: Llcense No. SUB-1010 Dorket No. ~O-8Ol7

Your l~tter of August 31, 1978, enclosed a Notice oi Vlolati~n and An J.E.

lnspt:>ction Report So. 40-8027/78-0l. Your lt>tter asks that 1..c respond to these docuc~nts. The at:~ched dlscus~ion outltnes the actions we are takin~

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

~e feel char Infraction 1, should hav~ been classified in the b~sic category oi a deiicI~ncv c~ l ss s~v~re c1assfftcation) for t~o re~sons: (a) because the 2,000 dpn/1OO cm valu~ ln question is ~n action level, not a limi t

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

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

>our inspection. The details of this action are tn the attach d di cusslon,

We are hopeful that you fJnd this reply a sa t isf~ctory response to your conc~rns.

Very truly yours,

~latio n 1nd Cont~

A eJ2/?&.y* !2.. ~2£~

M~nufactu r ing and Market i ng

WJS:RPL;hw Enclosu r es

.J.)

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

Infraction l(a)

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

Th1s ficting a~d training has b~en accomp lished fo r the twelve workers.

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

Infraction l{b)

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

.., The sampling plant is the on1y area where ha1f-nasks ar~ u~ed for produc tion or maintenance type,-,ork. A retr~ining session has been held for all addition, signs have been posted in the sampling plant re minding the employsampling pl~nt personnel. This training ~ession has been documented. ln ees of the need for the smoke tube test.

Infraction l(c)

"Half-~as~ respirators are used with head straps over the hard hat whi c h prevents straps fr om lying in their nonnal posilion next t o the head as required by Sectioo 13.5 of NUREG-004l1 whi ch is ref~~nced in Section C.S.n of Regulatory Guide 8.15 11

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

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

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

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

.. tion ?l.3 of 10 CFR 21*

These will be prepared by CctoLJer 20, 1978. "Procedures, as appropriate, ~'11 be developed to satisfy 10 CFR 21.21.

Infraction ~

License Condition 9 requires that licensed activiti~s be c.e,nducted in

0 ccordance with statements, representat;ons, pr ocedures and conditions stated in th e License Application, Appendix A, and Section 2.0 of App~ndix 8 II*

Jnfraction 4(a)

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

Section 3. 4.3 of Appendix A, subsection 2, "Contarni,1ation Control" regard ing operating areas states: "Routine mcasurernr:nts of surface contamination are m3c!e weekly.... " 11 Cleanup activity is perfor~ed promptly when smear able alpha contamination exceeds 2,000 dpm/100 cm in the operat;ng areas".

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

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

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

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

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

4) Admini s trative controls will be emphasized to accomplish more timely detect ion and repair of lec1ks. F'or example, documentation wi 11 be

.... ") I

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

5) A major decontan1nation effcrc shall follow the acc omplishment and implementation of the studies and additional cortrols de:cribed above.

The t im table for completion of t he corrective measures are (a) Three mon ths contamination effort duriny the fo urth r.onth and (c) Six months to ach ieve to achieve a significant r eduction of containment problems. (b) A major de dom/100 control wi zh only occasional cases where contarninatic7 evels exceed 2,000 cm by wipe test.

I n frac tion 4(b) mine their unde standing of radiation protection and uranium loss preventio n "Annual ora 1 or written tests have not been given to mi 11 workers tn deter as specified in Section 2.0 of Appendix B".

This testing will be completed during the next four r:on ths. This will be do cu~en ted. Therefore, annual t es ting will be done.

lnfract ion 5 6000 foot distances from the rlant in the cardinal corpass directions and License Condition 12 r eqt. ires, in part. that soil sar;ples be collec ted at

analyzed for uranium and fluoride. Contrary to th is rr, 1uireme nt :

Soil samples have not bin the cardinal compass directi on s, since the rene.,ed license was issued". ee n co llec ted at 6000 foot dis tances from the plant

Hen ce forth, each April and OThese samp les have been collected and sent to the laborJtory for analysis.

analy Le d. ctober. similar sa mp les wil l be obtained and

Infra c tion 6

\\.

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

. Con rary to this requirement :

Bottom sedinent samples have not been obtained and analyzed, since the re ne wed li ce nse was is sued".

Arrangemen ts f or a con sulting group expert in the te chniques of this type of samplin9 were ma de at our Oklahoma City headquarters. :J rior to your inspection. funding approvals sampling will be accomplished before the end of October, 19 78. ~ere made on August 24. 1978. An initial

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

efforts t o provide en~ineering and process controls w re suff1cient to comply "The inspectors were unable to clearly determ ine whlther the license e*s

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

Additional infomation to aid your determination follows:

l) As men!ioned on page five, a r otary val\\e has been installed on the redrum hopper. This requ ired replace m installation of the rotary valve, electri cal power for the valve, etc. ent of the or iginal hopper a~d The valve with the new hopper and drum adap~er were placP.d in service*

on August 21, 1978. I t has reduced spillage in th1s area.

2) To r educe airborne conta~in ation in the denitratirn aret, an AFE h,s been appro~ed for a U01 bucket ele~ator to replace the U0 1 Redler (CO 3448). An abnormal number of breakdowns on the UO Redler co ntaminatio n. The bud.et elevator was ordered July 21, 1978. It Cor.veyor has. caused excessive maintenance increa si ng t~e airborne will be installed ~s soon as possible after it arrives, which,snow sch~duled for November. This will be operated under a slight ne ga tive press~re to prevent spread of contamination.

3) A layout has bE-e11 ma de for re-r outing of the WX headers to d i vide th~

acid ab sorber and the e~pansion units exhaust to the expan~ion absorber denitrators so th~t the original units exhaust to the original nitric caused by flu ctuating pressures. to provide improved vacuum control to red uc e a i rborne contamination

4) Maintenance Conversion En ginee ring. has been assigned t o work with rnaterials, materials of construction, replacement fre Qu ency~ etc.) t o and Production personnel to study pac~ing problems (~acking working in the field to aid Project Engineering, wimprovE dust control on convevors and agitators. will be was assigned to study th1s pro blem in the ast ALARA ~eeting held ho August 16, 1978.

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

6) and the refeed conveyor (item 5) op~rating a t negative pressures, it As operating experience 1s gaine d with the bucket elevator (item 2)

L-t ype Redler Conveyors between the uF 4 ~e al ts proposed to design and install a buc~et elevator to repla c e the and the storage hoppers. bins on 1 A' and 1 8 1 lines

7) A ventilated enclosure has been provided around the drum dumping equip me nt in the samp ling plant. This has resulted 1n a significant reduction of airborne contamination problems at the op~rators work location.

.. (,)

8) The engineering department will suunit applications for cxpt:nd1ture~

to provide funds for procurc1,1 ent of contamination c v ntrol equipm~n:

based upon a review of their st1,1dies. The stt,dies will in clude th rccoor!ndc~ions of the ALARA colflmittee.

August 31, 1978 L1eens No. SUB-1010

Kerr-McGee Hucler Corporation ATTN : Hr. W. J. Shelley, 01.-ector Regulation and Control Oklahoma City, Oklahorca 73102 Kerr-McGee Bu11d1ng

Gentlanen:

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

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

Th* 1nspect1on cons1sta d of selective eum1nat1ons of procedures and and observa represent.a the records, 1nterv1ews of personnel, independent t 1 ons by 't.he inspector. meuurements

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

• which was conducted June 15-17, 1977. They ver1f1ed that the corrective 1c t1on ~1th respect to these 1terns was 1a,plemented II stated 1n your reply of July 20, 1977, to our letter dated July 6. 1977.

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

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

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

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

I L

RJEvercftl/d RIV 0'2... 1 CLCain ~l~ ti GDB,X>wn W£VetterX 8/28/78 8/Z /78 8/ /78 8/ {,/78 I(\\

tf u a_ *ov a t0<1UN t ""'"',.. o, r,ci*, IIH -.,......

/

J:arr~GN MuclMr Corpontton Augwlt 31. 1178

Tttl* 10. Cod* of Federal leQulattont. a copy of tht1 letter and tt.e In accordance wfth S.Ct1on 2.790 of the *c *~1n of Prect1ca.* hrt 2.

enclosed tn1pect1on report will be placed 1n the NltC'* Pub11c Ooc\\alftt propr1ttlf'1* 1t ta necessary thlt you *k* Iba. If thh report co~t&1ns a,iy 1nfonat1on that you bel tew to be twlll~ (20) days to thh off1c* to withhold IUCh 1nforaat1on froa publ

• wrttten a:,pl1cat1on w1thtn dbtlosurt. kty 1uch app11cat1on auat h*ch,de

• full 1t&ttant of the tc reasons 1t h clatNd that the fnfot"Mtton 1t proprietary. It should be aeparate part of tht dC'C~t. 11nce the appl tcatton. ucludtng thh prepa.-.d 10 thlt proprietary 1nfonn1tton tdenttfted h contah.S tn a.

separate part. w111 aho be placed fn the,ubltc l:k,c"""1t ~. If..

do not hear froa you tn thh "gird w1th1n ~ 1pectfttd perfod. the npor-t wtl 1 be p la cad fn thl Pub 11 c Doa.9ln t llooa.

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

• know.

S1nctrtly.

Glen DFuel F1cfltty and Matr111. 8t"'OWI, 0,1ef Stftty Bnnch Enclosures :

2. IE fn ~pec tton Report No. 40-8027/78-01 1. Hotfce of Vfo1at1on

bee w/enel to R produet1on Uni t for Distribution 9 /~ / j -,}

AO/f fMS I ~P IE FILES MSS:FC&MS * '

SS : fCSL

• CtNl bee w/ ncl held for 20 days POR:HQ RAL Fl LES I LOCAL PDR NSJC

Septcmb~r 22, 1978

CERTIFIED MALL - RETUlCI RECEIPT REQUESTED

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

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

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

Dear Mr. ~~own:

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

Insp 0 ccion Report No. 40-8027/78-01. Your letter asks that ve respond to th~se documents. The atta~hed discussion outlines the actions ve are takin~

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

~e feel that tnfraction J4 should hnve been classified in the basic category of a deficiency (u 1 ss sovere classifica:ion) for tw o rensons: (a) because the 2,000 dpm/100 cm value in quest1on is an actio~ level. not a limit

~hich if exceeded means non-compliance ~nd (b) efforts hnve b~en tak~a to reduce contaminotion l~vels as revealr.d in the attached discussion,

We also believe that I~fract!~n 16 should be reclassified as a deficiency becc11.1sa action to obtain the st*mpl.ing in question was in pro~ress prior to your inspection. n,e details oF this action are in the attached discussion.

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

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

Infraction l(a)

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

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

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

Infraction l(b)

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

7. The sampling plant is the only area where half*masks are used for producLion or maintenance type work. A retraining session has been held fo r all addition, signs have been posted in t'ie sampling plant reminding tl1e employs~mpling plant personnel. This training session has been documented. I n ees of the need for the smoke tube test.

Infraction l(c) prevents straps from lying in their nonnal position next to the head as "HaH-mask respirators are used with head straps over the hard hat which C.8.n of Regulatory Guido 8. 15". required by Section 13. 5 of NUREG-0041, which is referenced in Section

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

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

The ash receiver enclosures have been d~contaminated to levels which will not req *Jire this area to be controlled as a high radiation area. More frequent surveys and decontamination efforts 1-1il 1 be used to '"aintain these lower levels.

Infraction 3.,. *,

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

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

These will b~ prepared by October 20, 1978.

Infraction 4

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

lr,fraction 4(a)

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

Section 3.4.3 of Appendix A, subsection 2, Contam1nation Cor,tro1" regurd ing operating areas states: "Routine measurements of surfnce contamination are made weekly.... 11 11 C1eanup activity is perfor~ed promptly \\o1hen smear-able alpha contamination exceeds 2,000 dpm/100 cm in the operating areas".

Cleanup acti 1ity has been and is performed as committed, ho\\'iever, during the period cited, an abnormal frequency of uranium containment failures has occurred with the, Jnstruction and start-up of new equipment installed as possible. Secondary control methods are used to prevent persons from to expand the production capacity. Repairs are made to stop leakage as soon

receiving internal exposures of ura11ium.

These intermittent uranium leakage problems continue and cause the surface contamination. Correction of these unfavorable conditions combined with an

i proved house~eeping effort will reduce the contamination to more accept able levels. This will be accomplished as follows:

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

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

So~e new equipment has been installed or is on order as described in items 1-8 of our reply to your 1.E. inspection report. More equir,ment for contamination control wfll be procured and installed as ne~de~.

4) Administra:ive con:rols will be emf)hasi:.:~d to acco1::plish more tirr:ely detection and rc;>air of lea;. s. r:or e<a111ple, documentation *.-1ill be made of corrective action ta~en os a t*csul for uranium le<lks and spills in the operating areas. Additionally~ our t of a shi ftwi se inspectfon work pennit will be audited to improve contamination control measures when maintenonce type work is performed on uranium containing equipment.

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

ti.., to achieve a significant reduction of containment problems, (b) A The time table for completion of the corrective measures are (d) Three months major de-1/ contamination effort control wifh only occasional cases where contamination levels exceed 2,000 during the fourth month and (c) Six months to achieve dpm/100 cm by wipe tesl.

In:*raction 4(b)

11 Annu,1l oral or 1*1ritten tests have not been given to mill v,orkers to deter mine *heir understanding of radiation protection and uranium loss prevention :1s specified in Section 2.0 of Appendix B".

This testing will be completed during the next four months. This will be dJcumented. Therefore, annual testing will be done.

Infraction 5 6000 foot distances from the plant In the cardinal compass directions and ~License Condition 12 requires, in part, that soil samples be collected at analyzed for uranium and fluoride. Contrary to this requirement:

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

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

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

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

Contrary to this requirement:

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

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

sampling *,1ill be accomplished before the end of October, 1978.

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

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

with 10 CFR 20.103(0)(1). The item was left unresolved pending discur.::ion with ti RC Licensing.. 11

Additional infonnation to aid your determination follows:

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

on August 21. 1978. It has reduced spillage in this area. The va1ve with the new hopper and drum adapter were placed in service

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

{CO 3448). An abnormal number of breakdo1vns on the UO Redler contamination. The bucket elevator was ordered July 21, 1978. It Conveyor has caused excessive maintenance increasing t~e ~irborne will be installed as soon as possible after it arrives, which is now scheduled for November. This will be operated under a slight negative pressure to prevent spread of contamina:ion.

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

4} Cleon Treet, Conversion Engineering, has been assigned to work *11ith materials, materials of construction, replacement frequency, etc.) to ~~intenance and Production personnel to study packing problems (packing improve dust control on conveyors and agitators. Hr. Threet will be working in the field to aid Mr. Walt Spencer, Project Engineering, who

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

5} Engineering has designed, materials hav~ be 0 n procured and fabric.ation has already begun on a refe ed drum dumping and conveying system to feed redrurr.med material to the digest bins through a system oper11ting at a November, 1978. negative pressure. This is expected to be placed in service in

6) As operating experience is gained with the bucket elevator (item 2) and the rcfeed conveyor (item 5) operating at negative pressures, it is proposad to design and install a bucket elevator to replace the L-type Redler Conv~yors between the UF 4 seal bins on 1 A1 and 1 8' lines and the storage hoppers.

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

8) The enginee r ing depurtrn1,;,nt will submit application!.i for expenditure!>

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

License No. SUB-1010

Notice of Violation

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

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

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

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

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

This fs an infraction.

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

This is an fnfraction.

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

This is an infraction.

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

Contrary to this requirement:

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

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

This is an infraction.

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

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

This is an infraction.

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

Contrary to this requirement:

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

This is an infrattion.

UNITED STATES NUCLEAR RE.GULATORV cow.m:s10N REGION l'J 111 lilYANPL.AZAORIVE,SUlfE 1000 ARLINOTON, TEXAS 76011

0L:tObt>r 13, 1978 License ~o. SUB-1010

ATTN: Mr. W. J. Shelley, Director ~err-~cGee Nuclear Corporat1on Kerr-McGee Building Regulation and Control Oklahoma City, Oklahooia 73102 Gentlemen:

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

As a result of our review, we find that additional information as discussed with Mr. Shelley by telephone on October 10, 1973, is needed. Relative to Item 1 of the Notice of Violation you stated in your letter that retraining sessions had been held to inform current employees of proper irritant smoke testing requirements and proper half-mask head strap use. Please indicate to us actions which you plan to avoid further similar items of noncompliance relating to other employees. Specifically describe your pro9ram for assur ing that employees who are later assigned to use tt11s equipment have com pleted the designated training.

Relative to Items 5 and 6 of the Notice of Violation you stated in you~ letter that so11 and bottom sediment sampling will be accomplished in accordance with License Conditions 12 and 15. Ple3se indicate to us actions which you plan in order to avoid further similar acts of non compliance.

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

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

..... I~, ~, 0 11 ~,

Kerr-McGee ~uclear Corpordtion October 13, 1978

You request~d that Itens 4 and 6 be reclassified in the category of "deficiencies" rather tnan 11 infractlons. 11 A "deficienci1 is defined as an itmi of noncompliance in which no undue expenditure of time er resour ces to implement corrective action is reqll,:-e~ Examples 1,,,,,*Jld include such items as nonconpliance with records, pusting, or labeling requireients which are not serious enough to amount to infractions. Since you indicated ir your letter that corrective actions for rtens 4 and 6 will be (or have been) completed only dfter a substantial period, reclassification is unjustified.

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

Sincerely,

,'),,.. f'

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

~ KERR-MCGEE * ' I

October 19, 1978

CERT fHEO '-!.\\IL - RETt:P"'l R.ECEZ?t REQt:£S!rn

Mr. Cten D. Br*vn, Chief Fuel Facility & ~nc~ri3: SJf~ty Br1ncn L'. S. Sudcar r.ei;ul cory Cot:uni.sslon Regi:,n !V 611 Rvau PLa~u Drive, Suite 1000 Arlingcon, Texas 76011

Your letter of October 13, 10'78, u~ks for adJitionnl inror.::ac1.on tn re spouse to your earlier lecter ui Aususc Ji, 1978. The rollowing discussiou answ~rs your qucsc!ons:

New sumpiing plnnt cmplo>"t)i!S or ochers.assibned to th.? sampl:ing plnn t will b~ c***Lned by health ~nd s,fe~y pdrsnn~el co administer ch~ smoke tub~ t~sc p ron:ptly af c,~r donn:i:1s thel:: half-mask and to we<1r :.he m.tsk propt:dy to JSSure chat thu hcud scrBpa aru in the correct position. Sa~pling plant r.upervi.sors wi.11 be l:>pt!clnlly instruct~d to enforce the proper ~<1Jt1.ng.:md testing o: t~e halr-~3sk =~spira:or.

Soll sa~pling ac the ~.ODO :eet discancc point from the pl~nt hai b~~n aadecl to our listing f :*uti~a environ~ental sacples. L~s:ing chis on che schedule will issurc :hat these samp:es are ob:ained uc chd prope r dme.

The rber botrom su pling prog:-am has b**er-. placed under the -upervbion ~r a C.IJ:-,su!.canc, Dr. 1ro:* Dords of Aql:acic l.He Consulcanc Company. "r. Dorris hnll l3fiu=e ch~c this ~ompling ts done pr,perly and in a t!mely manner.

the in1tt 1 sn::-pltng i..:as conducted on Occobt?1.* U,, L9-8. This sampling re~uiremen: will Jlso be \\isteJ on :ne en;!ronmencaL samplina schedul~.

fhe ci:nt! till, t.:i [or co'"iplecion of co~recti'J1t n*e.isure co nchi *~V*-2 beccer c.0.1 -

tJmi:iation conc:-ol is redi.:;ed to -.he: i'!mi ot the fot r':h r.:onth Lnsteil.d of sf;,

months as in~1C3~ei in our ~ei:ter of September 22, 1()78. t\\...ire currentlv rna~tng ext: etf r:~ to reduce con':a~1nat10n levels and Rre making me3sur able ~:ogress chrough re-*-phasis er sdminiscrattvc contr~: pr1cc1c~3.

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

.....,o*Je ber 7 ~ 1978

License ~o. SUB-10 o

An*:: 'r. Wer** -.. cGee :uc. J. She 1 ear Corpor a: 11 ey, D ion free tor Kerr-~~Gee Building Regul~t,on and Control

Oklahoma City, OklahJma 73102

Gentlemen:

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

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

1978..,Je have no fur tner quest i ens at tni s time and,,111 re\\! 1 ew you r cor *ecti'le ec t ion durir,g a futu r e inspection.

Sincerely,

OFFICE OF INSPECTION AND ENFORCEMENT U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Report No. 40-8027/78-0l License No. SUB-1010 Licensee: Kerr-McGee Nuclear Corporation Kerr-McGee Center Do cke t No. 40-80i7 Oklahoma City, Oklahoma 73125 Facility : Sequoyah Uranium Hexafluoride Conversion Facility Inspection at: Gore. Oklahoma Inspection conducted: August 10-11.1978

In spectors: (' -P C,q,,"',_ ~ n, R:!""'0"""0+1..... a t-f.... o-n--..-Sp_e_c-=-i-al'*1.-s""'t------*

R. J. Everett, Rddiation Specialist

/7'

a. (Closed) roncompliance (40-8027/77-01): Th1s item involved failure to conduct monthly audits of health physics programs by facility manag nt required by License Cond1tion 8 of SUB-1010. This license condition w s modified in the ren wed licen c issued Octob r 1977.

b. (Closed) oncompl\\anc (40-8027/77-0l) : This it<?m involv d failure to post radiat,on areas. The insp ctors v r, id proper posting

of radi tfon areas durfng the plant tour.

c. (Closed) Unr solv d It*m (77-01/1)of a comp lianc c rttficat issu d to Union Carbide (AEC-ORO ~ Th1s it m involved the use 6273-48/AF) co"tain rd scrib d as OR0-651, Model 48x. Th license h s as authority to sh p type 8 qu ntitf s of UF6 fn a now rec 1ved complianc certificate 16273, issued by the t~RC on July 29, 1977, and now f,lly complies with 10 CfR 71.12.

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

Ct>rporate,

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

.a

Sequoyah racilit1.,

8. E. Brown, General Manager, Nuclear Manufacturing J. W. Craig. Manager. Conve1sion Engineering C. E. Grossclaude, Manager, Health Physics & lndustrial Safety

L. H. Harrison, ManaQer, Arlminfstration & Accounting

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

4. facilities and Egujpment The inspectors toured the plant and the liquid effluent retention areas on August 10, 1978, to observe op rations in pr~gress and verify that equiprequircmenls. The licensee stated that the plant capacity had been ment and facilities ~ere in accordance with app1ic4ble license doubled to 10,000 tons per year contn ncing April 1978, as author1ted by a rim *w 1 icense date11 October 1977. lhe 1 fcensee stat d that the plant operating schedule was twenty.fo,r (24} hours per day, seven (7) days per week. During the plant tour the 1nspec r veri fi d that corr*ective action had been m 1ntained regarding the posting of radiatiou areas. an 1tem of noncompliance from tie June 15, 1977, inspection. The pl nt was observed to b operating and housekeeping was not d as be1ng poor. n1c 1 fcC!ns ~lated that this 1,;0ndi tion was due in large d gree to the recent plant oodtf1ca ionr. n cec nry to incr asc production cap1city.

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

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

5. Int rnal Exposure Control lh 11c nse 's air sampling program is described in the License Ap plica tion. Appendix A. Liens records listed 45 airs mplfng 1 to ns in wor locattons within th pl int. These s mple r c I d each 8-hour sh1f and anulyzed t*adiometrical ly for total a1pha emfss fon after 4-hour delay. £ach worker is rcqufred to tabulat his wo-r

• time 1n each area. Th HPC*hour xposure 1s then c 1culated on sev n-d y exposure p riod. Th license stated th t air sampling 1n th solvfnt cxtractton hulldin had be n tetmfn~tcd.

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

-5*

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

Table l, limits. [xposure records indicated no evidence of overexposure to personnel. This was achieved by limiting occupancy and/or utilizing respiratory protection equipm nt. Daily Radiological Status Reports l'isting air sample results greater than 0.5 MPC ~ere reviewed. These reports were noted to be distributed to various pla~t and corpora e management personnel. Process engineering controls

h. ~een implemented to reduce airborne radioactivity concentrations, an afrborne radioactivity ar a. A rotary valve had been instal~ed but concentrations were st111 recorded above those that would delimit on the re-drum hopper in the sampling plant and additional ventilation had been installed. The licensee stated that several other measures had been ~tud i ed, but none of these had yet been fmplcmented. Ihe effo,.ts t o provide engineering nd pl"Ocess fosp.. ctors were unable to clearly determine whether the licensee's controls were sufficient to comply with 10 CFR 20.103(b)(l). The item was left unresolved pending discussion with NRC Licensing.

The 1 icensee stated that a rcspf ratory protect for, pr oc ram has been es tablished in accordance with Regulator"y G~id 8.15. Internal exposure r cords were found to apply protection factors for those personnel wearing r s pi rators. A polydispersc OOP man-test system with a fitting cam1ndicat d ha t personnel h d rec ivcd ber ha s b en used in conjunc tion wfth the pr"O!Jram. Records m dical exruninations including e 1lung dyn mm1natio ns relating lo respiratory protection were contained in ies test~ as a part of the p,ogram. Copies of written employ e, cord files. Comprehensiv writl n procfdures w re found des cribing th program.

w re worn wi h head sttaps over hard ht helmets and th t irritant Ovring the plant tour. fnsp ctors observed that ha1f'-mask rcspira ors smoke t sting was not performed, prior to use. ach time respirators w re donn d. Th licensee also fndic d that tw lve (12) wor~ r, who raceived llow nee for respir tor us

• h d not completed the resp1r tor fitting and te ting progr m. lh fnspectors slated that these items cons ituted noncomp11oncc with 10 CFR 20.103(c).

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

Appcndh A of the pplicat1on. Th 1n p ctors' di cussions wtth the l icense and a rev! w being cond cted 1 1 s as described 1n th application. Th bf-nw:mthly of perttn nt r r.ords established that th program urinalysis s ch dule for plant work rs 1s d 1gn d ta rronitor the controls data 1n xc ss of 20 mfcrog, m~ pr lit r ct1on 1 vel and 1fmplcmented for routtno ~rker c pour. lh 1n p ctors noted som 0 qu1red a to th licensee's evalu~tion. lh lien stat d that 1n each case tho worker was r str1cted from furth re posur until th n~xt Moassay indfcat d normal levals. The 11c n e tat d furth r that

som of the highs mples may have been contamin1tcd. The insp ctor not d that the bioassay laboratory did not, in two in~tances, report levels in e cess of the action lev 1 in a timely manner, sufficient to allow re ampling to confirm the result from en acute exposure standpoint. However, once the l1cens was infonn d, samples were coll cted and theses mples yield~d nonnal values. The licensee stated that acute e*po~ures should be readily 1dentifi d so that more fr quent sampling can be conducted, and d1scussions uld be held with th bioassay laboratory 1n ord r to expedite the r porting of data.

license r cords rndic ted th t ~ vivo lung counting is p rfonn d by a ndor es d scribed,n t e Lien e Application, Ap? ndix A. A r vi w of curr nt d ta revealed nor sul 1n cess o 10 CFR 20.103( )

1 lmi ts.

surv y data for appro ima ly 100 points within the pl nt. Surveys Th insp ctors noted h the license doc m nt d alpha contamination

w re doc ntcd as b ing perform d w ly. S ction 3.4.3 of Appendix Asp cifi s th top ra 1ng ar as will be cl ned so as tor main blow 2 1 000 dp /100 cm smear bl activity. Surveys of th oper t ng ar s w r no d to xc d this limit dur1ng th p riod Oc ob r 1977 to August 1978. Th insp ctors ated thnt f 11ur to maintain con minat1on 1 vcls b lo th1 l1mit cons i utcd nonco pl1anc with L1c n e Condition 9.

6. Ext Con rol wor n nth c ng. rnal xposure da a was revi w Lie r s ind,cat tat film badg s are provided to all d and p s w o d In s of 20.101 limit.

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

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

Th whol bod_y dos r wfthi nd th raw appropri t ly post d as a htgh radiation area. n this ar a w s h1 gh r th n 100 mR/hr.

t r a was not u1pp d with entrance or cc s s 1nt 1n lo d wh n cc ss w s not or con ol tu noncompl nc with 10 CFR 20.203(c)(2). r qu1r. s d th t i1 to provid control devtc

7.

He 's nv1,*onm n1 oring progr 1 d crib d pplic tion r peclfled In Lien\\ COndft1on

The liquid fflu nt tr am from the plan fs continuously s mpl d at th site bounJary. ily grab s mples arc an lyzed for uranium.

an lyz d for uranium, gross alph, gross b ta, ni rat. nd fluorid. fluorid

• nitrate. pH, tnd t mp ra ur. ~thly c0!!1pos1t s re Quart rly anal ses are p rfonn d for R -226 and Th-230. All radiolog,c l data w r ls than the applic~bl Par 20, App ndix B, labl Jl. valu s. A no upw rd r nding. An ly s for fluor1d, uranium. and nt rate teview of nonrad1ologic1l pararn t rs r v led ar p rforn d at th quoy h Facility. An lyses for* gross alpha.

gross b

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

Surf c wat r i col1 ct d nd yz d from th Ar~ nsas, J)l,no;s. nd S lt Forl riv r s and thr by ponds s d scrib din th lie nse pplic t1on. Ground r 1 c c m four (4) s tllni asin itor, (1) res1 n 1. and thfrty*nin (39) ra fi pond t lls. Cone s w r found to b b low lie bl C' r unr str1c s.

n 11 combustion burn1 n d t a t o on f fl s i h b burials t n t1on. o a h

A1 r mp l I ng is p r for d, s, nd s ; at four (4) lo tions with c a riv 5) loc t1ons o -si. S for gross alph rid fluorfd. bound r

• Th-230, nd -22. Data fo to w 11

b 1ow appl ic bl PC ta u d by th 11c ns tr r fl for co.. 11 ioing of gross lp on n t d the boun ry s mp 1 r 1 nC1 lh-2 a A1 l1c o 14 d to n i n di r n 1 um - 2 2,

1 t p nuc t cks should b p to c n df tton was not c t h olv d p ndtng d w tng.

£ngfo rinp i 1n o.-d r to eon irm th th pl nt building und (1 ch ng pr hour r quir d by

\\1c ns Cond.

(

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

The inspector *tated that contrary to th1s requir ment so11 samples had not been obtained at the 6000 foot dis tances, sine the renewtd license had be n 1ssu d. The insp ctors stated that failure to obtain such samples constituted noncomp11ance with License Condition 12.

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

l 11r. ns tated tat th i ~ mpl1ng program had not be n 1n1tiated sine th r new d liens w fa ilut o obtain sue ampl const,tut d noncomp1i nee with License s issued. Th insp cto, r sp nd d that Condition 15.

8.

R ports of we ly. monthly, and quart rly ud ts w r r viewed and found to b performed a r qu1r d by App ndix A. Oocum nt d m1nu es of sf ty,r. tfngs wer also review d. Licensee a, d tail d 1n app nd1c s of the Uc nse AppHcation. N tra1nfng actJvit1es w l'mploy es r c 1v t hour of ety training and a saf ty handbook at tim of hir. A cond training scss fon of t m hours duration fs provfded within s vcral cks of hir. ih 1 ploy s ar instructed int cont nts of Regulatory Gu1d 8.13 ic nsee tated th t f le and t sign tory v r1ficat1on of this instru ction 1 r ufr d. S ction 2.0 of App ndh 6 t ts hat r** rs w1l1 b t t d annu ny to d t nn1n thctr und rstanding of rad\\ t1on prot ctton and uran1u lo~s pr v ntton. lh license tated that such t tin h d not b n pr orm d. Th ltc ns e was tnform d by the tnspector that faiJur to admin1st r uch t ;ting constituted noncompli nee w1th Li en Condition 9. The insp ctors 1nterv1ew done worker and d t nn1n d that her und rstaniing of th radiological h zards was ufffcient to compJy wfth 10 CFR 19.12.

g. ( Plan111 ng & Fi re Protect ton l s rg ncy plann1n nd fir protection progr1m ar d Ap dh A. f1r rotectfon program 1nc)ud s t ct t d foam ray 1n th SX Bufldfng, sprfnkl r f room, and manua bl tray, rat tivated n1trog n purge 1n the 1 rt t 1ngu1 h r throughout th

(

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

• uppli d by a 150,000 gallon holding t n and are fed by di sel 1nd me,.gency g nc, ato,* are tested monthly. Hfn hose sta ions are el ctrical pumpfng equipment which is al o checked monthly. Observa t1on of oppro trnat ly 10 m in p cted monthly. Em rgency teams on each shfft hav had 1nstructfon nua\\ extfngui$h rs r veal d that thes were

on ch tam have had first

• the use of eJf-con alncd bra h1ng app ratus. S v ral 1ndiv1duals aid training. Th liens stated that th r ad b en neith r s im 1h t d fir c rciscs nor* ff re dr'f 11 s sf nee the proc dur spraining to firer the last inspection. The 1 \\c ns e was found to have veral docum nt d spons and to syst sop rations and insp ction.

10. posting, L orts.

insp c or no cd ht incoming end outgoing shipping contain rs lab 1 d a LSA a11d r dioac:. fonns NRC-741. complet d upon wHh 10 CFR 40.6 was vcr1 The 1 r ort. required by ipt nd tr n of sourc r1al, 1 d; and complianc 40.64(b) was r v d. 1h f to,..s no d u s r post d qulr 10 CFR 10.11, but that no on o oc ur s no proc d r ht1ng to th r g o. l ins ctors post lat ng to Par T 11c t t t re~ r with 10 CFR 21.2 1( ). st t d th 11ur to s b u pro cont t d noncomplianc

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

11.

Aw t p1 wa n d from combfn d fflu nt tr am tt th bo nd c. l h p 1 w 111 nolyz~d for ur n1um, gros alph

• s, -226, Th-230. t v s L ry wl l analytic 1 r uJts from Idaho tr comp rd to th 11c n$ 1

1 pl s at th location.

12.

Ur solv d 1t s or m tt r bOut which onn tion ts qu1 r d in ord r to d nnin w1, th t1y r 1t H o during th 1n p ctlon. 1h none plfancc, or d v1atlon. 1t r 1n grap 5 Two unr s s id n f i d nd 7.

10-

13. Exit Interview The inspectors met with licensee management (See paragraph 1 )

at the conclusion of the inspection on August ll. 1978. lhe fnspectors sufMlarized the purpose and scope of the inspection and surrmnrizcd the findings.

Jun, 25, 1979

tiCfflH UJ.-1010

l.an- -Mc

• Nuclur Corporatt.oa AlTN : Kt. W. J. Shelley, Direetor Je ul1tioo 1od Control

l.er-r-Kc:C11 lu Ud tq 0 a City, Okl1ho.u 73102 Cientl**n s Thi, T*f*~* to ~h* in.pe c ti on co~duet.,d bJ Kr. C. L. Cain of thia of fi c e on H.y 21-24, 1979, of th* 1c tivitle1 *uthor1 1.t by C Source Material Ltc1oe1

. S - 1010 and to th-9 dh cu a,ioo of our UnJ1na* t. eld b1 H:r. C.14 "1th M111r 1. J. W. Cral1 aod C. t. Gro11claud 1 OD Kay 24, 1979.

n

• iaap* tion va1 a n et

• tnAti o n of the 1c t1*lth1 con.Ju c ta1 under the Hc,n,1 11 they relat e t o radiation,.t,ty and to cooplt

• nc* with t ht Coimt aa ion** Nl**

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

• • lect l v

• a Jnatl oo 1 of proc.Sure a aod t1 pr111obttv1 record*. Jntervi~* of per1onnel, tnd p*ndeat u1ur eat* and oba n1t!on 1 bJ th* tupector,

Caitl *ho revie\\led the a ct Soo you had taiken vtth reap t to au (6) tt**

1t 10-11, 1978. Hncomp111nc 1 obaened during cx,r prn1ou, tn~ectton, vhich w I conduct ed e ~*rift* ttwt the corrective a c tloa vith rarpecc to a DS Octo er 19, 1978 1 t o our l1tt*t* dattd Au1u*t t *** lt

• v11 pl e nt 11 etated tn y our repl1** o f Sept ber 22, 1978, 31, 1q1e, and October ll, 1978.

8A 1ed oa the r lt 1 of thia iaap tioa, lt a ppear, tl\\at ooe of 7our a cttvltl*

• v** Mt tic

• ot Vtol atf on, enclo 1 d lerew1tb, Th.fe it* ~aad~ct in full c pliao

• v1th C r9q ult**nt** o f none pli*nc* hA* b~*o ** **t fortb ln the c1t1aorhed into the 1.-.,11 ** ducdbed tn th* con-upondenc* t.o,ou dated Decmbet ll, 1974.

Thi e aotiC

• 11 **nt to you purau aot to tbe provt1ton* of S* tioa 2.20 1 *f th*

iltC lute* of Pu c tlce, " Part 2, title 10, Cod

• ot P.Jaral le ul at foo e. S tfoa 2,20 1rtq u tr111 ou to bQic to thl1 o!ftce, vi to tvent7 (20) d111 of your t ei p t of thil t:lce,

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

(1) cort tv, t c tl on e - h ich ha** ba t*~*a by 7ou and the r1tult1 1 chtned1 (2) corr t1** t ct!on* w'hl ch wtll b* tJ~" to av o id further it

• o r noac pllanc e ;

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

• e ch hv.-f *

).... '""r..,... tlltfftlttftlltlt ftflftfl ttt'ltftftllttftt I lftt ti I ------.i~........;..~.... -~;.;.;.;..;..;.......;.;..;.;.;.;.;,;.;,;,;.;~;.;.;.;.;..;.;;;.;.;.;.;,;..:.;~~~:.:,;;;.;,:.;.;.;:.;.;.;;;...,;.;,;.;.:.a;.;,,:," :.:.;***;.;.:**::.:**.:,;" :.;,"*:.:.:*:.:.:**:;.:" :.;,*":;*~~-:----

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

lta-rr-McC.* Nucl u T Corporation June 25, l 979

In a ccord ance with Section 2. 790 or th* NJtC "Rul H of Practic*," Pert 2, Titlt 10, Code o! 1idaral Re gulatton,,

• copy of t h1 1 lett*r a nd t b* bclo1ed 1n1peetion report "111 be pla ced 1n tbe NRC'

• Publf c Docuamt looa. It th11 r*port cootain* an1 lnforiutioa that,ou bell eve t o be propri *t*t'J, it ia neceeaary that *.ou.,.k* a vrttt e n epplication Vi.thin tventJ (20) day* to thb office to v1thhold such tnfonution from public dhclo aure. Ally, uch ap pllc aU.oa muat toclud*

• fl.lll et.u ent of the l"e&eon, it 1e chi.aid that the inforiution 1* proprieter,. lt e hould ba prep a red, o that proprietary information identifi e d

11 contained la* 1epa r1te pert ot the dociment, 1tnc1 th* a pplic a tion, o cludina thla **raratt part, vill *l*o be plac~ Jn tha Public Document Ro011. If** do not hear froc you ta t hi re ard vithin ht 1pactfied p1rtod, the report vtll be placed in the Public Document Roo,a,

Should 1ou have any qu.,ati on a coacerntna tht* letter, pl.. ** let** lcnov.

Sinc erdy,

Clen D. lrow

• tat f'u*l P ctlity aod &tart.al Sahty Branch E.nelo1ur11:

1. r tice ot ~to l*tton

2. IE ln.ap t!oo port. 49 -901.7 /79-01

bee w/encl to Rtproductlon Unit for Di tributl on.._. ___ _

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

/µ,:,V. POO License No. SUB-1O1O WOTICE Of VIOLATION

Based oo the results of tbe ~"RC inspection conduc ted oo Hay 21*24, 1979, certain 1ctivities appe*r to be in nonco~pli3DCe with N'RC reguletions as indicated bdow :

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

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

This is ao infraction.

• J u. s. 1CLf.AR REGUL~TORY co~r~SlO.

OFFICE OF lNSPECilO~ AND £SFORCEM£NT RHHOS IV

Report No. 40-8027/79-01 L1cense No. SUB-1010

Licensee: Kerr-McGee Nuclear CorporallOD Docket No. 40-8027 Kerr-McGee Center Oklahoma City, Oklahoma 73125

Fae 1h ty : St>quoyah llran1um Hexa tloundc Conver& ion fac111 ty lnsp~c.t1on at : Gore, Oklahoma

Jo pe c to, :

los ect1on Suuv11 n

.!.'!! tction on H1v 21* 4 19 79 Hc_port 'o. 40 08027/79-01)

, un*nn ou nc d inspci;t1on of ur mum conv"r 10n h cCJly opeuticns nd raM tion p,o i: m rncluchn organ1ut100 and adm1n i trat1on; f cil 1t1e ud,_,.,iu1pml!nt; internal exposure control; tr,ning; em rg *ocxtern I expo ure control; e(1lu~nt and nv11orun nt 1 my planning and t ire p, otec t1ott; po t i n, l b~ltn aud r~ports; on1tor1n ; *ud1l1 nd

n.. trwn nt lion ; nd od, *pendent a11 11u rem nts. Tht. in11r, c t1on involvt!rl t~cnty tbrce (23) hou rs on site by one in p ctor.

Re ulta : Of th t~n (10) ar r.a 1n sp ted, no tttms of non compl1ance or d vutions were d~nt1! cd n 010 (9) are : one (1) apparent 1t~m of n oo omp 11 n c:e w 1tl nt f1ed 1n one (1) ar a (1nfr c 100* mprop r u,~ ot h lf-m k resp 11 tor, r~f. i ra raph 5).

2

DETAILS

1. Ptrsons Coot cted

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

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

• Members present at exit iolervtew.

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

2. I.1ceolle Ac:t1oh Jn Prev1 o u"' Ins ecl1on f10din s

A.. (Open) None mpl1 nc~ (~0-80 7/78 OlJ : This item involved r 1,ure to use rcspLraLory protecl1 \\e equ1pm~at 1n accord ~ith R gul~tory Gu1d 8. 15. The 1nspe tor ve,1f1ed that all workers usrn such equipment had nimpleted a f1tl101 and training program smoke test each t1me uch cqu1pmeot was donned. However, th 1osp~~tor nd tbat workers ~ho used h lf-mask re p1rators ptrformcd an irritant observed use of a h lf*mask re pint.or \\Jlt.h head stra1,1 phcc;d over the bard b l thus pr veotrn str ps from lyio 1n their normlll pos1t1on next to th heu,f as require,! hy NUREC-0041.

8. (Clo cd) Non compl 1ance ( 0*8027 /78-01): Thi 1 tem iovol vcd fat lure t o equ1p high rad, t1on area w1Lh ent.ranc or a c ss control dev1ces. Th n pect.or ob rvtd no 1ea1 posted** hi *h rad1at1on r at the time o f the 1nspr c t1on.

C. (C los <l) Non~ompl1ance (40-8027/7 *01): Thia 1 ~m 1nvolv~J f llure Lo establi h pro dur"s rciartlin 10 CFR 21 1mplcm nL4'tion.

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

D. (Cl~ ~d) Nonco1 pl1ance (40-8027/78-0l); Thi lt m rnvolv d f !lure to control cool min L1on l~vel nd to administ r annual t.c work rs. Thi! 1n~pe 1 f u~d that ontaminatlon nations b d b~en a1~1ni 10 ~ork~r,. w r b 1ng m ot 1ned tbe control level and that

£. (Clo d) (40-8027 /78*01) : Thu nr.111 involvt!J f I lure o obtun and n lyz 101 I arnptu. Tile nip lor vcn 11t*I that uch mplf!I h d b n obt II ed and analyzed.

r. (Clos d) (40*8027/18*01): Tht item,nvolv d fa lur~ to nbt Jn n n lyz,. re rvo11 bottom dam~nl ampl ver1f1,.d tlust au h lrDJllo h d l, r.n obtain d incl 3

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

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

w. J. Shelley, Director, Regulation & Control C. J. Sinke, Coord1n1tor, Radiation Health & ~fety Sequoyah Fac1l1ty J. ** Craig, Ha1ager, Sequoyah Facility C. E. Grossclaude, Manager, Health Physics & Industrial Safety L. H. Harr1aoo, Manager, Administration & Accounting pos1tion during Dec~mber 1978 at wh1 ch time Hr. B. t. Brown was Tbc licensee atated that Nr. J. W. Craig was,ppointed to his per.sent relocated to the Kerr-McGee main office in Oklabou City.

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

4. racil1ties and E9~F~

The inspector Loured the plant on Hay 21, 1979. and the l1guld effluent retention areu on Hay 23, 1979, to observe operations in progress and to verify that equapmenl and fa cil1 t1e1 were i n accordance wath appl1cable 11cense rPqu i rement1, The licensee s tated and that the plant operating schedule was t~enty-four (24) hours p~r tbat the plant process rate ~as approximately 7800 short tons per Y'-*r, day, eeven (7) day s per week. The inspector observtd that retention w1ll1 had bern constructed *round the process boildown tanks to contain any overflow such 1s that wh ic h occurred dur1n1 Decemb~r 1978 (Ref.

IE Iovest1gation Report 78-02 dated 1/10/79). Al o ev1deoced was a major effort to decon ta inate and paint *any plant pro cess areas.

Under connruc:tJon vere facil1t1es to pr oceu 1Jf4 slurry. A tour of co~plete. Tb~ lic~nsee stated that two ~1lliou gallon, of pro esaed the w*ale ponding areas revealed lhat conatruct1on of Pond No. 3 was 4

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

Tbe inspeclor sought to deteranne 1{ ur6 cylioder valve pac~iog nuts identified a& potent1 lly defective by DOE had been located and w1tbdra~0 from use. The licensee~** io possess1on of* letter dated January t.S. 1979, from Supt11or Valve Company._bicb identified tb, quest1ouable valve~ hv d,te codP. and heat number. The l1censee stated that the packing nuts on these valve, had been replaced ~itb one!. of established good quallty and that the removed nuts were being held for eventual deitruction. The 1nspectoc observed tlat the quest1ooable outs were btl4g 5tored 10 a holding area,

5. lnt ~ ~nal Ex o&ure Cvotrol The licensee's 11r sampling program i, described 1n the Lictnse Application, Appendix A. Lirensee records llsted 4S air sampl1~g locaLions 10 ~or k locat1 a ns w1th1n the plant. These sample~ art col le c ted each &*hour sh 1L and analy~ed rad\\ome~rically for total alpha emission. Each worker is r~qu1red to tabulate his woik t1m~

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

A review oJ 11r sa~pling data revealed some ar~Js 10th~ plJnt wbere airborne r~d1 0, c t1v1ty conceolr at1on s exceeded Part 20, Appendix 8 1 Table l, luuts. Exp osure re t:o rds 1n,hcated no evidence of ovcruposure to persorinel. Th,s w r.h1eved by 1:iautin occupancy and/or ut1l111ng r~sp11Jtory prote c tion equ1pm~nl, Daily Rad1o log1cMl Status Reports listing tlr 11mplr. results greater than 0.5 MPC were rev1f'O-lo~d. Tbe reports wP.re noted to be disLr1buted to various plant and corporate man.a em**nt p rsonnc 1. Prot:ess eng1 nee ring cont rola had betn 1mplcmenl~d lo redu ce airborne radioact1v1ty concentr*tions, but airb orne r d1oact1v1ty area. Pro cess eng1n~r.r1ng con trols added aince tonccntra t1on, ~ere 1t1ll re corde d above th os~ that would d~l1~1t an che lost fnsp~ctaon includrd tht foll owing :

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

8. A uo 3 scr ~ conv r.yor had been r~rlaced with a buck t elevator.

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

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

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

5

F. An enclosure had been installt!d around

• drum dumper.

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

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

Tbe licensee stated that a respiratory protection program continues to be utilized in accordance with Regulatory Guide 8.lS. Internal exposure wearing respirators A pol~disperse DOP man-test system witb a fitting records were found to apply protection factorb for those personnel chamber 1s used 1n conjunction with the program. R~cords 1nd1c ted that personnel had receiv~d medical examinations including lung dyn ic test$ as* part of the program. Copies of written exam1natic relating to respiratory protection were contained 1n employee record files.

Comprehensive written procedures were found describing the program.

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

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

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

1 designed to monitor the controls impl~menttd for cout1ne worker exposure. Tht! inspec.tor noted,ome data 10 excess of 20 m1erograms per liter actton level and 1nquired as to the li ensee's evaluat100.

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

Lteensee records indicated that ~ ~ lu.na counting u performed by a vendor as described in the License App11cat1on, Appendix A. A rev1r.~ o! current data reve1led no result in excess of JO CFR 20.103 perfor~r.~ during October 1978. (a) ltm : tc. The h1ghest result was 10. 3 mg natural uranium from counts

The ia6pector noted that the licensee docwn nted ahd graphed alpha conta111nat1on survey data re&ul ting froni weekly a.euuremt.nt.a at 70 loc1t1ons within tontrolled areas, 10 locations ~1thin uncontrolled areas. and 6 locations io un1Pstr1cted area,. Tbe inspector observed that contaminatton level, within th~ plant were de r~as1ng. The 11ccns~e stated that* maJor portion of the process areas had been clPaned with b1gh pressure w1t~r and th~n painted. The licensee further stated that th1* project which had begun in Febraury 1979 was approximately 70~ compJete. The inspector reviewed Hazardous Work Permits used to <lesignate radi~tioa safety practices for specific jobs in pToc ess areas.

6. External Expo~ure Control Licensee records iodicat~d that film badges are provided to all workers on a moathly exch~nge, External exposure data were revie~ed and no exposures were noted in excess of 20. 101 li~its. The highest recorded annual dose {or 1978 was 800 millirem.

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

7. Efflu~ot and Env1roomtatal Honit or1 ng The licensee's effluent and environmental mon1tor1ng program 1s described 10 liceosee sl~led that verbal approval had been granted by NRC Licensing LO license application referen c s specified in License Conditioo 12. !te l~ngthen the period t.. ween spe r 1f1ed roviroQll)eotal sample,. Neither the hcl'!nsee oor the 10spector is aware of,ny license amendment documenting

,u ch author1tat100. The licensee has been operating 1n accordance with the verbal authorization for several months. This item was left unresolved pend1ng d1sr.uss1on with L1 c ens1n3.

The liquid e((lutnt stream [r om the planL 11 c~ntinously s~mpleJ et the site boundary. O,ily anb Gal!'lple are aoalyz~d for uranium, f11.1oride, 01tnte, pH, and temperature. Mon thly composite5 are analyzed fot uraniWll, gross alpha, gross beta, nitrate, and fluoride. Quarterly aoalyses are perfonaed for Ra-226 aod Tb-230. All rad1olo&ir1l data were less tb10 tbr. tppl1cabl~

Part 20 1 Appendix B, Table ll, values. A review of nonrad1olog1c1l parameters revealed no upw,rd trending. Analyses for fluoride, uraniwn, and niirate arr p~r{oT'11!ed at tbe Sequoyah }ac1lity. Analyses for gro,1 alpha, gross beta, rad1Wll, and lhorllm are p~rronn d at the kerr-HcGee Tecl'utical Cecttec 1 Oklahoma City.

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

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

Treated raf!inale continues to be used as fertili1.er on Let plota and incru$ed 01 tn.te levels b ve not. been detected at. 111oni tor ~e lla. 1'he licen ee stated thit there haJ been three (3) on-site burial of wastes s1nc'" th* last Jnspect1on. The hr e l wa 35~000 cubic fef't. o{ fluoridE<

Judge.

7

Atr $ampling is perfonned at plant stacks, batches, and vents; at four (4)

Two boundary samples are analyzed for uranium, Th-230, and Ra-226. Data locations wltb1n the boundary fP.oce; and al five (S) locat1ons off-site.

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

The inspector verified that soil and vegetation samples bad been obtained and analyzed 1n accordance with License Condit100 12. Als o r~v1e~ed were data pertaining to bottom sedlm~ot samp1es obtained by Oklahoma State University io accordance ~1th License Condition 15. A final report on this iol l11l sampling 1s st1ll pending by tbe licensee.

8. Audits and Training

Reports of -eekly, monthly, and quarterly audits were revi~wed and found to be performed as rtqu ired by Append uc A. I. i censee train iog programs ar~

detailed ic dppeod1ces of the License Appl1cat1on. Sew employees receive comprebens1ve safety training and a trainin 6 handbook at time of hire. A training program has also been estahlished for contra c tor per~onnel. The Regulatory Guide 8. 13 and that ; igoator) verification of this instruction licensee st4ted that female employees are instructed 10 tbe contents of

is required. The llcensee furtht"r stated tbat plant employees b ve been g1ven appr oximately three (3) hours of refresher training since the last 1nspPct100. The inspector reviewed written examinations given in con Ject100 ~1th this training. Tbe inspector int~rv1e.ed one worker and determined that her understanding of ra~Hation safety practices was sufficieut to comply with 10 CFR 19. 12.

9. tmer,&ency Plauu;ng and fire Protection

The lic~nsee ' s emergency planning and fire protection programs are described 1n AppP.ndix A. The fire protection program includ, temperature a cti~ated foam spray heads in tbe SX bu1ldiog, sprinkler systems in cahle trays, manual fire ext1oguisbers throughout tbe plant. Tbe licensee slated temperature activated n1tr ogeo purge 10 the fluoride cell ro om, and the iosuraoce undervriter had perfonned an inspection in recent mootbs.

Tbe fire born aod emergency generator are tested mon thly. Nine hose stations are supplied by a 150,000 gallon holdi ng tank and are fed by diesel and electrical pWllping equipment wbicb is also checked monthly.

Observation o f approximdtely 10 portab le extinguishers revealed that these were inspecled monthl y. The licensee stated that sprinklers had been re c ently inst.alled in tbe chemical storsg~ building behind the plant. Emergency tearo~ on each shift have had 1nstruct1on in the usr of self-conta1oed breathing a~paratus and several individuals on 8

each team have bad f1rsL aid tra1nio~. Thr licensee stated that

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

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

10. Postin The inspector noted that 1ncom1ng and outgoio~ shipping containers were labeled as LSA and rad1oact1ve. forms NRC-741 1 completed upon receipt and tr,nsfer of source matPrial, WP.re rev1ewed; and compliance

~ith 10 CFR 40.6 4 (a) ~as ver1!1ed. The inventory report required by 40.64 (b) was rev1e~ed. The inspector noted that the effluent monjtoriog,eport, r~gu1red to be submitted to the NRC within 60 days after July 1~

1978, 10 acc ordance with 10 CFR 40.65, was not submitted until September 19, 1978. The inspector also noted that documents -er~ r us ted as required by 10 CFR 19. 11 and 10 CFR 21, and that ~b1pping container c~rl1f1cation>

~ere availab le for each type of co ntainer used.

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

11. lostrumentat1 00

The ins pr.ctot observed that tbe 1nveotory of portable survey instruments and laboratory counting lnstruments was fuff1c1ent to Slpport radiation iafecy programs. Instrument calibration frequency, currency, and procedures were f ound to be as requ1red.

12. lnd~Pndent Measurements A water sample was obtained from the co~bined effluent stream at the boundary fence. The sample ~111 be analyzed for uranium, Ra-226i Tb-230, gross alpha, and gross beta. Air samples -ere obtained in the process area near tb~ denitrators on the second level and to tbe sampling plani oo the first level. The analytical results of all samples from Idaho Ht.altb Servtces Laboratory ~ill be later co~pared to the licensee's resul~* of samples taken at the same locatioo.

13. Unr~solved }teas

Unresolved ite s are matters about ~bich more 1nfo[11Jalion is required in o rder to d~t~,ine ~hether they are acceptable items, 1tems of noncom pliance, or deviations. One unresolved item was identified during th~ inspection. This item is <l1SCUi&ed in paragraph 7.

9

14. [x1t lotervJ!:

Tbe inspector met ~ith licensee managemenL (Re!. paragraph I) at the conclusion of thP. iospect100 on Hay 24, 1979. The,nspeclor summarized the purpose and scope of the inspection and summar1ted the findings.

KERR *f,fCGfl:..,. -..

Aug u t 2 9

• l 9 7,

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

U.S. ~uclear legulac~:y CcQmission 611 Ryan P~a:3 Drive, Su!ce 1000 Arl!n~ton, Texas 75012

In accor!a~ce ~i:h 10 CFR 40.65 with a~pro?riate ~odificzcions

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

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

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

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

• ... JS :jb

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

C

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

Parciculat - Elevat d ~ tot l rele ses (No batch ~ode rete ses)

~~uclide Release~ Unit l t o,~acter 2nd Quarter Gross Alpha Ci 2.llE 2. 89E-02 Uranium (Na:.) Ci Z. OoE-02 2. 87::-1)2 Thoricm - ~30 Ci 2.5.. E-O.. l.81E-04 Radiuc - 226 Ci ~.39E-05 3.7GE-Oo

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

!or gro.ss alpha ;v... 1 /!ec 2. 68E-03 J... SE-0.3 Volut:11? Rei."ase<! liters l. 75E -... 2 2. 06E-1:

TABLE It

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

" lirle Released 'ni t Oua~ter 2nd 0 'I.: 1 -P arter :.,..

G:-o. l pha r: 1 o.51E-Ol 9.40£-01 t:r n iu (~at.) Ci '.-e E - 01 o.7.JE-01

- rice - 2 30 Ci L.27:.-05 :?.05E-0 ',.

RadL,a - :! 2 6 Ci 7.55E-Oll 8. OE-07

1* o l u:n e r,de ed liters l. OSE - 00 1. l u:~09 RECORD Of T[LEPHONE CONVERSATION Oa te: 10.:2-81 N~C Lie. No. Kerr McGee SUB-1010 Time: _J: S5_£.M_ __

__._c.... o... 1.. ern-a.... n......... S-rn... i~t.. h---- Tit 1 e Hoci ltb Cbys ic i H f I rm / Organization State of OK

---

Title Firm/ Organization

, __ -;Investigation, D Overexposure 0Misadmi ni strat101 0Not if ica t ion S"uMMARY OF CONVERSATlor~ Allegation l] Leaking Source 0lnfo. Request OL;c. Condition [i]Release of R.M.

OLost or Stolen Source

.

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

glas s ~idls was destined for an independent testing lab on October 2, 19Rl.

Juring t,..ansport the truci 09hadverteniy came open losing the above pac~age. The pac~age ' e ll to the highway apparently brea~ing the three glass vials and relea sin g !he contents to the inside of the package. When the material fell ft-or.. th" tri,c* ar. ~,r.identified individual radioed the t'Jl trnc~ that he h,HI loH

d ;,~ c i.a,; e. :!1~ u uc~ d r iver iP-:mediatr.ly returned to the location \\-,her!? he had ics~ t.~,e :.1 cO *age o r.ly to d'iscover that an or. Department. of iransportat _ion

,_.!.. ;.:.1c,:te e r,d*:! :.reached the DdC~.age spilling approximately 19 g~ of the VC r,a~'!r ia 1. He \\*ias ir:1mediatel :1 rushed to the r-~usi'.ogce General Hospital where

• • , is '1a n,: s an d feet 1-,ere decontarninated "iy rr personnel. Su tcessful 1P.c o ntd r.ii~cHion -..1as evidenced ty a radiation survey conducted by r.N personnel

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

~ate ri al was lost at l-40 and US f9 at the C~ectoa ~ overrass.

at !. h is lo ca*ion -..,as,*eMovea by rJ*~ personnel.

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

- TH1 n*

\\..,oc:li...tr T0-3=1 Jt.\\ '1, (.~Tt. "S </~- )~

NOV 2 2 1983

• ""'~..

-~1r *~,.- '.

Or. M1ntoa."ti11ey DISTRIBUTION wfencl:

Fuel Cycle ProJacU Manager ** Docket File 40-8027 * ---,70-371 Em 1 ronmenta 1 l11pect Sectf on MJRhodes Nuclear D1v1s1on P.O. Box X VLTharpe Olk Rtdge. TeMessee 37830 WTCrow NMSS R/F FCUP R/F Deir Or. Kelley:

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

Sincerely,

/.s/

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

Enclosure:

As stated

S312070280 0 B4lli~7

• ADOCK ~

omc:a* f.&UP..:).tt.................................................. N.. HM*.. *M

• e.. M......................................................................

lfUCAMI. HJBhP.~'- 'i@................................. "........................................................ ".................................................

OAff. 11/~........ **.............................................. "......... _..................................... -.......................

11t1111,1*91a ttA.an ~ MMI

~ KERR-MCGEE, CtJffPt7i!1:!iON

January 28, 1971

Mr. L. D. Low Director, Division of Compliance t:. S. Ator.lie Energ)' Commission Washington, D. C. ~0545

Reference:

Source }laterial Lic.::nsc r~o. SUB-lUlO Docket ~o. 40-8027

D<:ar Hr. Low:

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

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

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

calculations were made tram urinary excrcci6n-daca.

Table l

Cone.,\\v~ra8ci *l)

Period of for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

• Empfovee (1) Exposure (uCi/m!)

~

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

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

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

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

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

located in the Cylinder Scale Room. Tile employee had with ltiia a full face respirator equipped \\Jith an "ultra" particul.itc filt.cr

\\olhich he used 1.*hile taking remedial control actions. These actions includ~d closing a valve on each of the shipping cylinders and

lnfonnation in this record was deleted 8~1218001~ 11 o 12s exemptiona, ~, * * *In accordance *r F!eedam1' lllfmll1'lill _ -, -

CF AOOCK 0400602~~1P\\aj.ij,;::~ ---_,.,:,,

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

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

A urine sample was collected from the exposed employee approximately two hours after the exposure occurred. This sample i1ad a uranium concentration of 1660 pg/1,..hich was the highest concentr.:ition ob served in any samples collected from the exposed employee. Urine data was used to calculate the e111ployees exposure since there were no air samples collected in the immed i ate vicinity when the release occurred.

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

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

1. UF 6 transfer lines are inspected for leaks and faults prior

2. UF 6 transfer operations of the type described are done o~ly to use.

when the vacuum system is operating_properly.

Please advise us should you require any additional information.

Sincerely, flit:~\\ Lh (:;*tr~:*~

Allen Valentine Coordinator, Radiation Health ;,.nd Safety

AMV:dg

Enclos11re

cc: Mr. Uonald Walker Region IV, Division of Compliance U. s. Atomic Energy Commission Mr. Dale HcHard, Okl~ioma Department of Health Division of Occupational and Radiological Health Hr. Howard Eberline Director, Physical Science and Measurements Dept.

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

APPENDIX A

implovee Identification and Exposure Data

Report Exposure(!)

Svmbol Emplov ec ' s :,.:une Birthdate Sec u ricv Number (uCi/rnl) Period 8xl0-ll 12/27/70 to Q,._rx_'6)-------------~ 1/3/71

(1) Average concentration exposure to airborne natural uranium as U<\\F 2 for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> during the. reference seven (7) day period.

___ ___......, ___..,........,..___,.,.......,,.,,._,"?, __.,..........,......,,.._

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~ KERR*MCIJEE CORPOR.4TION

November 13, 1970

Mr. l.. D. l.ow Ui r ectorJ Division of Compliance United States Atomic Energ y c~111111i&&ion Was hi nato n, u. c. 205 45

Refertnce: Sou r ce Ma t erial Li c ense ~o. SUS-1 0 10,

Uoc ket ~o. 40-8 027

In accorda nce wit h t h provt sions o { l 0CFR 20. 40S, a ;S c1 p pli c oblc t o the refere nce li cense, Ke rr-McGee Co rp oration r epo rts on t he exposu re & o f eleven (!l ) individuals at its Se quoy ah Facilit y t o con: entrations of air bo r ne ra dioac t i ve ma t e ri al in excess of t h e occupational concent rati on

limits in 10CFR20, Appendix 8, Table l, Time we ighted ex pos ure calculations were made from measur ed c oncentrati ons and wo rk ing ti~e te c~ rds. The results foT t hose in ~ 1viduals potentiJll y exposed t o over limit a~ r borne conc ent r atio ns ar e given in Table l,

1 able l Pe rs onn~l Ex pos ur es to Airborne Concentrati ons

Period of Exp os ure Cone. r\\ve r agfq ) Co, 4 0 ho u rs ~

_t.rnployee ( l ) Da te ** * (u Ci /ml)

7/19 - 1/4 ll:i<.10 -ll B 7/12 - 7/18 16x10 _11 -11 7 /19 - i /2S l4 x l 0

C 1/12 - 7/18 7 /19 - 7/25 7/26 - 6 /l 8 /2 - 8 /8

I,) 7/17, - 7 /18

7/19 - 7/25 i /26 - 8 /1 8 /~ - 8/8 8 /9 - 8 /15 9 /20 - 9 /26

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

Table 1 (continued)

F 8 /2 - 8/8 7x10 _11 -ll

. '8/9 - 8 /15 9xl0

c; 7/5 - 7/ll l OxlO-ll

H 8/23 - 8 /29 7xl0-ll 1 7 /19 - 7/25 10xl0 _ 11 - 11 7/26 !. 8 /1 7xl0 J 7 /19 - 7/25 14xl 0 _ 11 -11 7/26 - 8 /1 9xl0 K' 7/26 - 8 /1 llxl0_ 11 - ll 8/2 - 8 /8 12 xl0

(1 ) I n a cco rdan ce with* 10C FR20. 4*and exposure data fo r t he individual emplo y ees ar e listed in t he 05 (b), t he names, i den t ification d ata, en closed Appendix.

(2) The ~f! 1mum permissible concen tration in air bxlO uCi/ml for insoluble natura l ura nium based on a fo rt y (40) (MPCa) limit of hou r expo su r e in a seve n da y peri od was applie d.

These emplo y ees were e xposed during performance o f produc t ion duties in t he Sequoyah facili t y. Unpl anned equipment fa ilu r es which r esulted

in t he l oss of ura nium powder a nd excessive a i r concentrati ons in t he work ing area s in term i tte n tl y du ring July, August an d Sep tem ber an d t h~

failure of pf r so nnel t o we ar a dequa te pr o te c tive equipm ent du r ing the clean-up o f t he powd er spills wprocedures prevented t he spread of ura nium outside r estric t ed area s on e r e th e causes o f over exoosu r c. Co ntr o l

pe ople,o r o t herwis e, a nd all of the exposed in div id uals ha v e a nd will c ontinue to submi t bio ass a y samples.

No all ow an ce f o r ex posure t o part icl es of a non* re spi ra bl~ siie was ta ke n in determining the ex ten t of exposure.

The indivi duals i nvolve d are bei n g not ii ied of t he na t ur e a nd ext ent o f their exposure s in ac co rdan ce wit h 10CFR1 0.405 (c).

Co rrective Ac ti on To protect aga inst recurren c e of ai~ilar future pers on nel expoaurea. the following a c tions have been take n.

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Appendix to letter fro* A, M, Valeotioe, Kerr-Mc Gee Cor porati o n to L, D, Lov, Uoit e d State* Atoa i c Energ y Coaua 1 iou, No vem b er L), 197 0,

AP P E.\\'D IX A D<PLOYE E l DENT lF IC ATI ON AND EXP OSURE

Report £x pos u r e ( l)

Sj'111b o l Em,2l oie e 1 s S a!lle Bir t hd at e Sec ur i t i Nu mb e r ( uCi/ml) Pe r iod (1 9 70)

(b) (6) llxl O A 7/19 - 7/2-ll 5

8 - 11 'l/12-7/18 1 6 x l0 _ 11 14xl0 7/19-7/2 5

C - 11 7/13xl 0 _ 11 12 - 7/18 l 0xl 0 _ 11 7/19-7/25 10 xl 0 _11 7/26-8/1 9x l0 8 /2 -8 /8

D l3 xl 0 - ll 7/1 2-7/1 8

E - 11 7/1913xl 0 - ll - 7/25 1 9xl0 _ 11 7/20 - 8/l 16xl0 _ 11 8 /2 - 8/8 1 9 xl 0 _ 11 8 /9 - 8 /15 l 0 xl 0 9 /1.0- 9 /2 6

s:' - 11 8 /2 - 8/8 7xlo _ 11 9 xl 0 8 /9 -8/15

G l Ox l O-ll 7/5 - 7/11

H 7>:1 0 - ll 8 /23 - 8/29

- u 7/l"J-7 /2 10 xL U_ 11 5 7x10 7/2b-8 /l J 14xl 0 _ 11 -11 7/19 - 7/25

'i x l(I 7 /21:J-8 / l K l lxl0 -ll - ll 7/26 - 8 /1 1 2xl u fJ /2 - 8 /8

( l) Averag e con c en tra t i on ex pos ur e t o air bo r ne na t ura l urani um f o r 40 ho ur s durio g the re fe r en c ed seve n ( 7) da y p e r iod,

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