ML20198A651
| ML20198A651 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 11/22/1974 |
| From: | Hind J US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Thornburg H US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20198A623 | List: |
| References | |
| FOIA-85-647 NUDOCS 8605210168 | |
| Download: ML20198A651 (5) | |
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GLcN cLLYN. ILLINOIS Oo137 0123c58-2660 November 22, 1974
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Har ld D. Jh'dqburg, Chief,' Field Support and Enforcement Branch Dirch te of R latory Operations, Headquarters KERR-MCGEE NUCLEAR CORPORATION - POSSIBILITY OF DIVERSION OF TRICGE h;j QUANTITY OF PLUTONIUM (DOCKET NO. 70-1193) o MJ In response to George Smith's request of November 21, 1974, the following
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discussion concerning the rationale why RO:III concludes that no diversion of a trigger quantity of plutonium has occurred at the. subject licensce's
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plutonium facility is presented.
4-5h Safeguards regulations desig.ted to strengthen existing requirements for e
the physical pro'tection and material control of special nuclear material
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in plants and in transport and protection of the plants were issued for
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public comment in early 1973.
These regulai; ions which evolved from t
'd extensive studies by the AEC staff, licensees, and other. technical experts, were publislyed as eftective rules in late 1973 after considering the comments frc.:. iadustry and Une puLile., Resulas.ious in 10 CFR 70 und 75 required r; err-l McGee to submit plans to Licensing stating how they were to comply with the
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phys'ical protection (fixed site and intransit) and material control h].
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, regulations.
After careful review and study by Licensing which included field. trips to the Kerr-McGee site, approved physical protection cnd material p' mot control plans and specific license conditions were finalized.
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The next step was to impicment an inspection and enforcement program to assure g*' J.
that applicabic requirements are met.
The licensee's degree of compliance
, v.v M with the material control requirements was determined by the chemists, auditors, Wsi-and statistician of the M&PP staff while physical security specialist of*the h?
M&PP staff were responsibic for review of the licensee's implementation of gj fixed site and intransit security requirements.
l TheKerr-McGeesecurityprograminclude$hpecialnuclearmaterialdetectors i
located at the!
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'Testsofthesjdetector! during inspections indicated no malfunctions." The security p1~an also requires-an inspection of alll
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exiting the access area. This physical search is for. concealed SNi Entrance f
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U 110 CFR 2.790 INFORT/ATION
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liarold D. Thornburg, Chief November 22, 1974 of a 'vchicle into the protected area is restricted to business vehicles and is generally limited to those delivering or receiving SICI materials and trash.
Each vchicle is examined for clearance prior to departure. No Pertinent locks and personal vehicles are permitted in the protected area.
keys are issued and controlled by Facility curity.
The perimeter fence around the protected area is equipped wit The emergency exits of the processing bui 2.ngareprotectedbyintrusion
- 1 jlarmd Certain.arcas' within the processing building are protected by These devices and procedures plus o'thers eN 2n the security ]ilan deter the dTversion of* plutonium from the Kerr-McGee Kerr-McGee has not reported any breaches of the protective facility.
j measures which would indicate a diversion or attempted diversion.
&q;, j Physical security inspections were conducted in January 1972, January 1973, In general, Kerr-McGee's security Marcl} 1974, May 1974, and September 1974.
program has been effective, however, violations have been identified. The g
4 May 1974 inspection was our initial inspection of Kerr-McGee's implementation 1l of the new physical security plan.
Several violations were identified, but thel ollowup inspection in September 1974 indicated that Kerr-McGee was f
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Icsponsive in correcting the violations.
Only two items whicli did not repres:nt dr.curity deficiencics associate
- wii.h divewiuu were idencified.
The material control systems assist'us in assuring that the physical
_,, 7],q-protection system used for safeguards has been successful in preventing
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The new material control requirements deal mainly with the diversion.
[.y p quality of measurements and evaluation of material unaccounted for (MUF) fy]
Recent inspections indicate that proper measurements of production quantitics.
material are being made by Kerr-McGee; however, additional effort on the part jt.a -
of Kerr-McGee is still needed to further refine their laboratory and ucighing P.{j standards programs in order to make their present measurement limits of error (Q
programs and resulting calculations more accurate and precise by determining The most re' cent gu w.
the contribution of specific random and systematic crrors.
d Kerr-McGee limits of error calculations did not include these more definitive The Kerr-McGee decisions of "not n significant MUF when g,.,
s'mcasurement errors.
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l compared.to the 'LEMUF" wouid not have significantly changed to a "significant MUF.when compared to the LEMUF" if the data had been included.
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i 1.0 CFR 2.790 iNFORMATICN November 22,_1974
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Ucrold D. Thornbj -
Within the last nine months, Kerr-McGee has experienced two significant MUF t
quantitics. As a result of these larger than expected imbalance numbers, Kerr-McGee responded by curtailing production operations and itmediately
'o started 'a new inventory.
In both instances, an.RO:III inspector observed i
s-the preparations for taking the inventory, the actual listing of the h
inventory, and finalization of the material balance numbers.
Both reinventories resulted in MUF gains which would indicate that the first 7
' MUF imbalance was not due to a diversion of a significant quantity of plutonium. Further evaluation of the reinventory results showed that the MUF gains were mainly due to better measurements of certain materials on inventory and a more thorough cleanup of equipment.
Our inspectors were satisfied with Kerr-McGec's reinventory efforts in both instances. Another gauge of the adequacy of Kerr-McGee material control system is the t
cummulative MUF figure. For the FFTF contrac't period starting in mid 1973,
-1 the cunmulative MUF is 1.9 kgs. Fu loss. This is not indicative of a real l
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, diversion.
The constant material holdup quantity entered in the Kerr-McGee records in June 1973 is still in the records. 'By license condition effective in May 1974, the SNM content of essentially all material on inventory was t.
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to be based on measurementr.
Since July 1974 Kerr-McGee has started a
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nondestructive (ND) measurement program which entails the use of ND techniques
<jg to measure this holdup quantity contained in piping'and equipment in the fp production and recovery areas. This endeavor is unique to a plutonium prodvetion plant.
Kerr-McCnc has been remiss in not inxtituting thly gystem c
in a more timely manner. Preliminary HD calculations indicate a significant portion of the holdup quantity on a measured basis. Also the small cummulative MUF number at this time can be considered an indicator of the c
hh accuracy of the estimated holdup quantity determined in mid 1973. With all "w h considered, RO:III does not feel this holdup quantity problem has resulted in 43 an undected diversion of a significant quantity of material.
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.Our inspections have also indicated that.no significant shipper-receiver
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differences has occurred.
In considering material diversions, the suitabifity and availability of trigger quantitics of Kerr-McGee plutonium for bomb threat and radiological incidents is mainly dependent upon material type, quantity of plutonium in specific items, and material control procedures and physical protection requirements specific to that material type and quantity. RO:III is presently developing a " diversion path analysis" for the Kerr-McGee plutonium facility. This will assist us in establishing a definite response plan when a diversion of trigger quantitics of plutonium is suspected.
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November 22',~1974 Harold D. Thornburg, Chief
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C Using the above rationale (Licensing process in establishing physical protection and material control plans and their review and approval of such plans, and the RO routine and special inspection results) there is
,g no indication that a trigger quantity of plutonium has been diverted from the Kerr-McGec plutonium facility.
l While it is also our opinion that the Kerr-McGee security and material control
,s' plans for the protection of nuclear materials is adequate in light of current assessment of credibic threats, we recognize that no system of safety or 3
security can prevent all possible incidents, or diversion schemes.
i f..'llin, Chief B
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Protection Branch cc: J. Davis
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C. Kuhlman
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