ML19207C256
| ML19207C256 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 08/15/1979 |
| From: | Bartz H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7909100559 | |
| Download: ML19207C256 (3) | |
Text
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D L D MEMU,:N!DUM FOR: Jim Partlow OO FRO." :
Harry Bartz '
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SU3 JECT:
EXXON - RICHLNID TRIP REPORT H. Cart visited Exxon-Richland on August 8 through 10, 1979 to familiarize the reviewer with tht "w facility and to explore several open i tems. The open items were listed in a memo dated June 29, 1979 from Don Joy to Jim Partlow. They are listed below in the same order m.
found in the memo.
L' l.
Exxon is not fully satisfying the intent of License Condition 6.5 in that they use shippers analytical results combined with Exxon's weight values to determine what is booked for UF receipts.
6 The UF cylinders are the property of Exxon. At least once c
each ydar they are cleaned-refinished and tare weighed by MFS.
.; hen a full cylinder is received from Oak Ridge, Exxon verifies the gross weight and empty weight (including UF. heel).
The heel t.eighs between 2 and 2.'l/2.Kg.
The heel d3es not appear separate in the OR report except that the heel is included in al' futu re tare weights. Therefore, the receivers seight, which. icludes the Nels in the tare is a by-difference value and the only correct net
- i;ht.
The percent uranium in UF is verifled and is always found tu be chemically equivalent to OR.6 Exxon does check the isotopic
..eight to confira OR value. Since the isotopic is very accurate for U-235, the value is very accura te and the shippers U-235 is generally accepted. To use the receivers isotopic value does not inprove known accuracy. Either value would be correct within the state of the art.
2.
Exxon's liquid waste ceasurements appear to be biased low based an annual lagoon inventory measurements.
The li.;uid wastes of Exxon are discharged into large solar evaporation la;aons. Originally, the largest quantity of uranium was found in grinder sludge (5 gallon containers), mop water (5 gallon containers)
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In earlier years, the five gallon pails were eyeball calibrated, apted with a stick, and sampled. The accuracy was equal to a good
- uess basis. Large streams (centrate) were sampled three times a day.
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This was also approximate. The ID was large 0.5 to 0.8% of throughput.
With the new regulations 10 CFR 70.51, Exxon had to get greater accuracy in the waste stream measurement.
j In June 1975, Exxon made their first attempt to inventory the lagoon.
They tried to calculate the volume of the lagoon and to take representative i
samples of both the liquid and the solid phase. With the crude procedures used and making conservative estimations they measured 353 Kg U versus a book value of 57.6 'Kg. U.
The LE was not calculated, each year p',-
there after.
In April f976 they tried again to calculate the SNM in l-the lagoon. This tia.a they calculated LE was 24%. A noticeable improvement.
For the most recent physical inventory, June 1,1979, Exxon added amnionuim carbonate and oxalic acid to convert the uranium to the liquid phase in orJer to get more representative samples. preliminary data indicates that 93". of the uranium is in the liquid phase. The limit of error is shown to be between 3 and 4%.
Exxon wants to book these values and adjust
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the books to the prior period.
It should be noted that Exxon did book prior lagoon inventories. Data from prior inventories is attached.
gr The reviewer believes the 1 icensee s hauld book the most accurate numbers available.
In this case the number would be the lagoon inventory.
The revieser does not accept the Limit of Error value as being as accurate as Exxon calculated it.
The lagoon measurements are not highly accurate and the solid phase quantity can only be considered a good estimate.
Exxon has dropped their plans for the new accountability measurement tanks.
The original cost estimate was g, $35,000. The current estimate is about 3150,000.
The original stainless steel tanks were 1000 gallons each.
Current engineering estimates show that each tank has to hold 10,000 gallons each to keep up with production.
3.
Based on data from the distructive analysis of 22 solid waste drums, Exxon believes that their NDA waste drum measurements are uiased 36T, low.
Experimental work on additional drums have confirmed original data that uaste drum measurements are inaccurate a't higher concentrations.
Current data shows that the NDA method is accurate for drums containing 4 to 5 crans U-235 each. A bias correction must be made for greater quantities of S$".
A formal report will be issued within sixty days.
To obtain uranium element values for individual waste drums, Exxon uses a nomir.al enrichment factor.
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10minal enrichment factors are also used to convert measured total V values to U-235 values for liquid waste batches.
This has been changed. Samples are now taken at the lagoon and I
assayed for U and U-235.
6.
At the time of physical inventory, Exxon remeasures boats and trays of UO2 pellets by weighing, but no sampling or analysis are done.
1 This is an open item. NRC policy is being reviewed.
7.
Because of the large number of solid waste drums on hand at inventory r~
Exxon would like to start listing these drums before the official inventory starting date.
Exxon has approximately 2000 - 55 gallon drums of waste.
These are tamper-safed and stored on an open concrete pad. At their latest inventory these drums were prelisted about 15 days prior to inventory.
C arrently generated drums were checked and added to the list.
ISE Region 5 cited Exxon for this practice.
The reviewer agreed that this practice does not meet the requirements o f 10 CFR 70.51.
It was suggested that the prelisting practices would
- sim, be acceptable if Exxon would use a valid statistical sampling plan to verify seal numbers and seal integrity.
Sf additional concern is why are 2000 waste drums in storage af ter a multi year period? 10 CFR 70.58(i)(2) requires all scrap ~ measured with an uncertainty greater than + 10", be removed within 12 months. Although the Exxon material is called waste, it is carried on Exxon inventory for possible future recovery.
num The reviewer suggested Exxon request a license condition to allow starage of this waste for a finite period of time until a disposal / recovery Jacision is made.
Durin) discussions with Exxon personnel it was stated that Exxon is not willing to upgrade physical security at their site for strategic special nuclear ma te rial. Accordingly, they are negotiating for shipment / sale of their plutonium to others.
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