ML20207N473

Partially Deleted RO Insp Rept 70-1193/73-01 on 730114-16. Noncompliance Noted:Permanent Cement Structure Housing Transformers & Emergency Power Supply Sys Located within 15 to 20 Ft Inside Perimeter Fence

ML20207N473
Person / Time
Site:	07001193
Issue date:	02/16/1973
From:	Finley A, Patterson J US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML20207N448	List: ML20207N446 ML20207N473 ML20207N508 ML20207N532 ML20207N564 ML20207N577 ML20207N591 ML20207N602 ML20207N625 ML20207N635
References
FOIA-86-281 70-1193-73-01, 70-1193-73-1, NUDOCS 8701140240
Download: ML20207N473 (28)

Text

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0F.SPECIAL SAFEGUARDS

.s NUCLEAR INSPECTION KERR-McCEE MATERIALS T A

CORPORATION CRESCENT, OKLAH s

1 SNM-1174' OMA '

DOCKET RO INSPECTION NO. 70-1193 REPORT NO. 070-1193/73

~

I.

FINAL Inspection dat REPO n'

-01 II.

esi AEC anuary personnel partici 14, 1973 through III. ReportA. G. Finley pating in the in January spection 1.6, 1973 prepar d by A J. P. Patterso 3

e were:

IV.

Date report

. G.'Finley n

V.

pr SCOPE epared:

iPebruar,y,3 6,1973 ~

_..m 1

Title 10The licensee's CER Part 73 andcompliance tained in license with were the reviewed.

conditionsphysical protecti safegu VI.

ards requirements

SUMMARY

of FINDINGS SNM-1174, Amend on OF requirements of A.

Nonc

- ment No. SG-2 con-Items of.

1 ompliance License Conditio cement structur e housing transfon 9.4.1 - Th power insidesupply system lo nsee has of 55 gallon drums the pe imeter fc ted within 15akermanent-a rmers r

feet from the in and the of liquid solventsenceg There to 20. fee 2

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side barrierLicense Conditio were southwe t cornerapproximately also the s

eight n 9.4.3 for evidencesurrounding the p(Tae perim

- of the fence.

work hours (8:00 a.mof breaching or irotected are eter of the physical ntr a is

. to 4:30 p.m.u not

). n during theinspected normal

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8701140240 870109 h u k 6-281 PDR M

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r NUCLEAR HATERIALS SAFECU.ARDS INSPECTION OF"SPECIAL NUCIEAR NATERIALS. AT KERR-McdEE CQRP'OR TIdN CRESCENT, OKIAHOMA.

~

, SNM-1174

~

Close-out Meeting notes with Management -,IDte:7 anuary 16, 1973 J

Facility Personnel AEC Personndi'.

r-Wrgan & or Cimarron Facility Manager A. G. F.in1ey

/ k and Accountability-

~

, J. P. Patterson'

' Ray Janka}

nager, Administration Fred H. Welch} Plant Security Officer t

No significant comments were made by Licensee personnel regarding items of noncompliance.

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end considered in uno.of the FFTF ma for the This is,in 1,1guid foru the gpmaining FFTF matsycten and not readily a material is in building protected by w erial w ccessible,.

wall storage as in vault storage inFox th with contro11 re tors nd intrusiona J

)(Thisstoragevault1'sawind' ala east and north wallsapproximately wall, flo oviese u

r, and ceiling concretenclosure w j

floo vau IC*il south and west walls ov Qll entrance The Closing bn i

e covers t entire entrance at the gat t is the requirements oes conc that the licensee's s(tspec'ify' aot comply with 3 k) becausespect steel door comply with at least~ one (inch eel door that clones on th

. mechanism] 10 CFR 73.3(k) because it I

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Results contains no at(3Boes not not egnaistently document dof the lice ocking are with License Condition 9 4 on alarm inspections e

and contribute to and tests

.8 Records for contro111ng' noncompliance keys and locks are consideredaccess to the protected

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Additional License Conditi satisfactory.

area and to 9.2.0 ons Physical Protection O

)(hhelicenseehas rganization-to the plutonium faciliwho man the o

In a'ditionStation an r armed i

one, sometimes two ty.

problems 2) In additionconduct the two d

ss at least utility people observe equipment systema, gaug,es e to work.

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o etc...but do no repair The Cimarron facility h Manual with documented p as rocedures for the foll

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O "It to Plutonium Plcut cpacur' curran

. cuch no a w2ekend rcticas 'for n terminatin

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the processing ar to remove shutdown pu a

't shutdown in order toene.into theall plutonium of a

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furnace loadsone hour tornadomeet those are alert. -

conditions are required ork overtimeout even t run rG 7g glove box to w and stored'in the ~ a,ul belief i.

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persoon

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that no this practice. processing ar remains in the v

t.It is our sible pluton the. walls of,equiincidentally lo

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Plutonium as remaining is thata

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columns pment and glove boxesand

" Based upon this down period, we plant cond during shutdown,thetherefore,ition during a be do shut-interpretat'ionclassified as. an plant access intent of these,sewe believe it is wi area. With thiswould man, i.e.

utility operatorcurity regulat

,I the basis during shutdowbuilding a the at one equipment onwho surve l

on about assignment of athe plutonium procn pe a

routine essing area move "In the second man toremainwithout the overtime isevent that operationswith him.

or to assig required, it isneed to

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purposes.n two our continue operators into any ar,ea fornormal pra

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"This interpretati safety personne1 'during plantaddition it considerable n the assignment o in a' letter dated shutdown periods." f tj{W. J. Shelley{ June 21, 1972 he AEC stated the foll, from R. G "We are in in your lettersubstantial agreemen owing: set forth a plutonium th May 22,1972the views in access of criteriaaccordance with thearea is' shut do When and contains one hour. tornado orarily specified in your lettno plutonium alert

• be permitted er except that to move free,ly abouta lone ' employee will the area without

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f.- ,{ + the assignment of a se,cond man to remain with him. Accordingly, under the shutdown ' conditions specified above, the requirements 'of the first sentence in 9.3.3 of the amendment to SG-2, dated March 24, ~ 1972, need not apply. In all other respects - however, such an area.shall continue to be pro-tedted as a plutonium access staa." IThe storage, vault area r'equires'the presence of two ~ (authorized individuals for all. receipts into and issued. on the vault. The vault is locked when unmanned. J ~\\ P n ,opersonalvehiclesarEpermittedwithintheprotectep area. In additiion 'to the requirements of th,e li' cense condi-tions, Kerr-McGee's contract with Hanford Engineering Development Laboratory (BEDL) places an additional requirement for visitor control. This requirement is in'corporated into Kerr-McGee's security program - and states in part: Except with prior written consent of Westinghouse Hanford and the Commission, contractor shall not permit any visitor to the contractor's plant, g office or facility to view or examine the product specified to be delivered *under this contract, or major sub-assemblies of such product, or to obtain. information or data concerning such product." Visitor means any person who visits contractor's plant, office or facility and does no't represent either con-tractor, Westinghouse Banford; or the Government in the performance of this contract. All employees who have access to the plutonium plant have their names embossed on either a green tapes red tape or blue tape on,a board mounted on the wall in the Central Control Station. With each name is a lateral switch and an embossed label indicating "in or out". A switch to the right indicates the employee to be out of the plant and if the switch is resting on the left side, the employee is in the plant. 'A letter U for uranium and F for plutonium after each name signifies where the individual' keeps his film badge. It,is the employee's responsibility to switch I e - e m e 9 --ym---- ---em,--,.,wy., ,. _,. ~..- - - -, -, - -,, - - - - -.,, ~ ~ -. - - - - - -. - - - - - -. - - - +

e ] e .f 9.4.3 Non Compliance 1. No perimeter patrols condocted durin i 8:00 a.m. - 4:00 p.m.). g normal working hours h m. Our 3 month check (October thru D . x1 of the two other shifts (1600-2400 separate days showed no evidence that a ad been performed. perimeter patr on 9 4 b. Walkie ' Talkie not.always used (thi Vation) when he is on perimeter patro s does'not give the 0.K.[Pu detectorMt point of entranc 9.4.4 J 9.4.5 0.K. e and exit. 9.4.6

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g. 9.4.7 Not vdtified - Alarms and detectors t . : l ** 9.4.8 Non-Compliance ested and proved satisfactory. ~ .--~~ 1. Records do not consistently document testing. Without documentation compliance canresults of inspec not be assured.

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~ c-- g l . a. FINAL MEETING NOTES 9.6.0 Consnunications i ). 9.6.1 Each guard or watchman on duty shall have the capal consnunication with a manned central station. This { the capability and authority to call for reinforcen 9.6.2 In addition to conventional telephone service, at I voice communication link shall be established betve and the LLEA; this link shall utilize radio or some means cap'able of supporting two-way voice consnunica q of offsite transmission lines.. 9.6.3 All communication equipment shall, have the capabili 24 hours from power sources indepbndent of the prim the facility. ~ 9.6.1' K.M. edloyee has capability of continuous communica station. manned by watchman if Walkie-Talkie ia utilf l 9.6.2 0.K. 6 Radio Phone 9.6.3 0.K. Cdpability greater than requirement. sI s< se eee e G

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~ .(. m. ) ~ l .e g NUCLEAR MATERIALS SAFEGUARDS INSPECTION ~ OF SPECIAL NUCLEAR MATERIALS AT KERR-McGEE CORPORATION I CRESCENT, OKLAHOMA I i RO INSPECTION REPORT NO. 070-1193/73-01 s i l l t I i l l l e e

q 3. , vault eterog2 arca has been establ luton 3 plutonium ccess area rate ..: ~p. , j, 0 - a steel oor pt least one inch thick with a built-in l I / -h"$y .4. that testing of the intrusion alarms forL ock. s' records indicate functional performance in all cases is not b i operability and as required.. e.ng accomplishe. B. to Kerr-McGee Corporation from CStatus of Pr reference letter March 6,' 1972) . D. W. Thornton dated. y Contrary to 10 CFR 73.41(b), records of th tests, inspections, and maintenance perfe, res'ults of all ~ by the licensee pursuant to the requirem s utilized Part 73 had not been~ maintained. of 10 CPR Status: The complete recording of intrusion alarm test was not accomplished by the licensee s License Condition 9.4.8.. repeated as a curr and is VII. DETAILS OF INSPECTION l I a A. 10 CFR 73 A total of three shipments of 5 kgn. plutonium w the inspection period for which the license ere made for protection responsibility. g has intransit Hanford by exclusive use truck.Two shipments were F. 0. B. from The third shipment'was a truck shipment fr ~ l - and receipt. Hanford. with the carrier and quantity informProper notification e licensee to ~ xecuted Protective signatura service was' requ'ation was documented. shipments. ested for all three No shipments were delayed that required a trace investigation. The authorized individual list included the nam not been signed by licensee management.end t es, addresses, ut had listings be signed. Facility Manager was obtained, and we a uture - 2' - -.m.

r m , p. .\\. it was noted'that the utility man did not have his "valkie-talkie" with him. 'He was'inf'ormed that this is,necessary equipment,in orde'r to have continuous . communication with the manned Central Control Station during his patrol. Be agreed. ~ nses has a mobile r upplied by Telephone C,rry ;.' u-In wu.n t un of Kingfisher,(15 miles away). Once the erato is . contact this back-up s em has the same potential ~ as any o e or busines one <x $I A six-week test period was conducte_d and dqcumented by ) f[L -,p the licen ilizing the bile radio phone 2 The., watchman any of th loyees daily to c' heck out th About $9 were completed and These tests were disc {onunuea in mid-Decealleu,) date and delay logged as hom was 972. The inspection team observed a,tast of th,is ho ich resulted in rer;.ponse fromQhe Kingfisher ppera 30 secondsafter@iialing r Commun'ication equipment dependent on the primary power l source for the facil y--"poortedbyanemergency l power system emel pggered generator 3 capable of ( I operating longer inan'q4,lhou This system is located l within themeted area 5 to-40-fest Trittiin eng Qimetdf' nce))/ y-l e VIII. ADDITIONAL INFORMATION The Cimarron Facility went on strike November'30, 1972, and was still on strike during the inspection. The union on strike is the Oil Chemical and Atomic Workers Union (OCAWU). The licensee is aware that a few employees have t,aken other jobs and will not be returning if and when the strike is. settled. As a result of the strike, the licensee has l added a company pick-up truck equipped with a spot light and temporary workers to constantly patrol the licensee's property perimeter during the night hours. .6 J. A. Eind, Chief Materials and Plant Protection Branch Enclosure Closeout Meeting Notes (2) % p~g < le rehrd m A eJf n

( (. e s FINAL PS!ETING NOTES. ~ PLUTONIIM 10 CFR 73 ' ~ ~ 73.31 A *ntal of 3 shipments above 5 kas above 20% were made for the ',ir.. ;, tion period. Two were F.O.B shipinents from Hanford by. truck exclusive use. One of these shipments involved a custody change for which.there was a hand receipt. The third shipm.ent 'was from Kerr-McGee to Hanford wTch proper notifications of ETD's and ETA's, carrier and quantities docume'nted. Protective signsture servic_e was requested for.all 3 shipments. No shipments were delayed that requ' ired a trace investigatio,n. 73.31 Satis fac tory e h l t l l 4 e l i g l + Ihcb (29) L Ya bl (fc &.t

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( (. (.T ~ ~ PLUTONIUM 10 CFR.73 73.32,(a).special nuclear material used only in protected area - access is controlled and authoriied individu'als listed for the entire. Cimarron Facility (both pla.nts) and separptely for' the ~

• plutonium facility.

1. The entire plant list was not signed. Signature of' facil$ty manager was obtained. ~ Suggested future lisgs for authorized individuals be s. , signed.- .s F (b)Nintrusion alarmsThe storage area (Vau&t) is in a lock'ed building protec 4* s, A detectors and access control". p3 j wJ r j 73.32 Satis fac tory LL~..), 3L s 4 e .,+ g l i e e P 4

^ ' cc ( PLUTONIUM ~ .l,. .c. 10 CFR'73

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r. 73.3'3 (a) 0.K. - Ala'rms and de tectors 'were tested.

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c-(b) Proc *edures call for intrusion alarms to be inspected and tested for performance at least,every seven (7) days. ..n,g 73.33 Satisfactory-73.41 (a ). o. R;,, (b), Non. compliance: (9 8),

1. _ Intrusion alarm inspections and testa not consistently documented.

Patrol log records were

• incomplete because perimeter a.

patrols in some instances were not recorded for some shifts. (c) Satisfactory records available dor the 3 shipments of SNM above 5 kas above 207, enrichment. (d) Satisfactory procedure for access and control to keys and locks. 73 42 No unaccounted for shipments, suspected theft or unlawful diversion for period of inspection. i 1 g O e t ,j '4' o .t,, h*f.*{ Y P$ ( in f g ..v- / ' l.a..:

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( ' (' (,f-i 7 PINAL HEETING NOTES j 9.1.0 Definitions applicab.le to Physical Protection Requirements - 9.1.1 Except where sp,eci.fically, note (., the requirements contained in these lice,nse conditions are in addition to those specified in Part 73. In any. case where inconsistencies may appear, the license conditions shall prevail. ~ 9.1.2 'the following terms shall have the meanings defined in 10 CFR Part 73:

• authorized individual, guard, lock, physical barrier, protected area, vault, and watchman.

9 ~ 9.1.3 " Intrusion alarm" ideans' an electrical, electromechanical.. electro-optical, el'ect'ronic, or similar de'vice capable of detecting intrusion i ~ by an individual, into a building, protected area, or plutonitan access , area, by means of actuated visible and audible signals. 9.1.4 "Plutonitan access area" means any, location within a protected area which is enclosed by a second

• physical barrier or substantial interior partitions, and which contains plutonium.

8 Non-Compliance : 9.4.3 9.4.8 e e I e l l e e i l i e s g h e

L . L c. ^ FINAL NEETING NOTES 9.3.0 Access Constraints 9.3.1 Plutonitan shall be stored and/or processed only in a plutonium access area. 9.3.2 ne licensee shall establish a separate plutonium access area for each vault or other location used primarily.as a plutonium storage area. When manned, a plutonissa access area shall be manned by two or more 9.3.3 authorized individuals shall be observed by another authorized individual. When urunanned, a:plut"diiium access ar'en shall be locked. 9.3.4 No personal vehicles shall be permitted within the protected area. 9.3.5 Personnel access to the protected area shall be controlled by a guard or watchman. i ' * *f " :*11" A*.u.... ' :" :: **:'.d*.- 9.3.6 Packages entering a plutonium access area shall be'je' arched for devices which could aid an individual in the theft.or. diversion of plutonitsa or in sabotage of a facility. ~ 9.3.7 The licensee shall registFvisitors, vendors and*bth'ef Ton-employee's'" entering the protected area, recording name, date', time, purpose of visit, and person visited. 9.3.8 Visitors, vendors, and other non-employees shal..be escorted by a. guard, vacchman, or authorized individual while within the protected area. i 9.3.9 Access to each plutonissa access area shall be under the control of an authorized individual and access shall be limited.co individuals.who-...... require such access to perform their duties. l 9.3.10 Keys, locks, combinations 5'related equipment information shall be promptly changed whenever there is a possibility.of their having been-l compromised, and on termination of any employee having access.to keys, locks and combinations, etc. Comply hlus combinations change monthly by maintenance and documented. l Personnel on strike have no keys to Pu llidg. 9.3.1 0.K. l 9.3.2 0.K. l 9.3.3 0.K. 9.3.4 0.K. ',n.,, %,3 g g 9.3.5 0.K. ~ P'- Y 9.3.6 0.K. h 4 w. 9.3.7 0.K.. loga reviewed

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(*.,*, g' * ' ' s .1 4 FINAL MEETING NOTES 9.6.0 Consuunications 9.6.1 Each guard or watchman on duty shall have the capsbility of continuous comunication with a manned central station. This individual shall have the capability and authority to c'all for reinforcements. 9.6.2 In addition to conventional telephone service, at least one other two-way voice communication link shall be established between the central station and the LLEA; this link shall utilize radio or some other electromagnetic ~ means capable of supporting two-way voice comunication and must be independen-of offsite transmission lines.. 9.6.3 All communication equipment shall, have the capability 'of operating for 24 hours from power sources independent of the primary power source for the facility. 9.6.1' K.M. edioyee has capability of continuous communication with control station. manned by watchman if Walkie-Talkie is utilized on patrols. 9.6.2 0.K. n Radio Phone 9.6.3 0.K. Cipability greater than requirement. II -S$ se eeo w l n e' .6 eq,

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== s wa h 70-1193 h Files INSPECTION REPORT NO. 070-1193/73-01, PHYSICAL PROTECTION PIPORT, KERR-McGEE CORPORATION, CRESCENT, OKLAHOMA, DOCKET NO. 70-1193 The inspection consisted of an examination of the licensee's com-pliance with the physical protection requirements of the safe-guards amendment to License No. SN!!-1174 and with the require-ments of 10 CFR 73. The Directorate of Licensing amended License Condition No. 9.4.1 on February 23, 1973, to permit the licensee's emergency power equipment to be located within the cleared area inside the peri-meter fence. Hence, Item 2 of the subject report relatinE to the power equipment was not cited as an item of noncompliance. There were no other substantive co==ents as a result of Eead-quarters Mt.PP03 staff review. 5 Erick L. !!ay, Jr. Chemist / Statistician Materials and Plant Protection Operations Branch Directorate of Regulatory Operations 4 e I e o e 9 G g e = h

0FFICIAL USE ONLY 6 NUCLEAR MATERIALS SAFEGUARDS INSPECTION OF SPECIAL NUCLEAR MATERIALU AT KERR-McGEE CORPORATION CRESCENT, OKLAHOMA RO INSPECTION REPORT NO. 070-1193/73-01 e S 9 [i j 9 e, e I .i OFFICIAL USE ONLY t j 8 ) 1 e f a ~ e V e

l: ,1 ,c. Fira f I b. Criticality j c. Severe weather d. Accidental release of hazardous material e. Accident investigation and reporting f. Electrical failures The inspection team' informed management that procedures documenting the command and responsibility structure during both normal and threat situations should be incorporated in this manual. 9.3.0 ' Access Constraints Plutonium is stored and processed only in plutonium access areas. The plutonium facility has been divided into two access areas. One encompassing all production and laboratory areas and one including only the vault stor&ge area. The licensee's procedures state that the plutonium access areas are to be manned by two or more individuals at all times plutonium is not in locked storage. When plutonium process materials have been transferred to and locked in wall storage and vault storage during one hour alert weather status or shutdown conditions requiring no operating staff, a Safeguard Release i for Single Occupancy in Plutonium Access Area is to be filled out by the supervisors of the wet process area, fabrication area, and laboratory areas. The completed form is then transmitted to the watchman to inform him that plutonium is in locked storage and one man may be allowed in the plutonium process area. The watchman is to keep in contact with the person in the process area on an hourly basis. m In a letter dated May 22, 1972, fr@qk.J. Shelley,k Director,'RegulationandControl,Nu(clearDivision},' l l Kerr-McGee Corporation to R. G. Page, Chief, Materials and Plant Protection Branch, DOL, the licensee stated the following: _4 e e i l 9 t

j

• L, c :.,. 4 "It is our current practice when terminating Plutonium Plant operations for"a shutdown period such as a weekend to remove all plutoni' m from the processing areas into the-vault prior to shutdown in order-to meet those conditions required of a one hour tornado alert.

In addition, sintering. furnace loads are run out even though personnel are required to work overtime, removed from the glove box and stored in the vault. It is our i belief that no significantly accessible plutonium remains in the processing area as a result of this practice. Plutonium remaining is that incidentally loaded onto ion columns and wetting the walls of equipment and glove boxes. i-I " Based upon this plant condition during a shut-down period, we, therefore, do not believe that during shutdown the plant processing area would be classified as an access area. With this 4 interpretation, we believe it is within the intent of these security regulations that one

man, i.e.,

the utility operator who surveys the building and ventilation equipment on a routine ~ i basis during shutdown periods, can freely move about the-plutonium processing area without the assignment of a second man to remain with him. 4 I "In the event that operations need to continue ) or overtime is required, it is our normal practice. to assign two operators into any area for safety purposes. "This interpretation will penmit considerable additional flexibility in the assignment of personnel during plant shutdown periods." l In letter dated June 21, 1972,.from R[ G. Page W.J. Shelley}ltheAECstatedthefollowing: t b "We are in substantial agreement with the views set forth in your letter of May 22, 1972. When [ a plutonium access area is shut down temporarily in accordance with the one hour tornado alert criteria and contains no plutonium except that specified in your letter, a lone employee will be permitted to move freely about the area without i 4 l t ' I 5 j i i ame* ....r---w-,mgemwme,-n----,n--w,-we-., s---n.e-.n--- -,-r+ .,www.- .en,~... - -._.,,, me-r-enw,,,,-m--w-r--,-m.-w,w-m mw n wo a - -e-,,*,---. w

~ tha ccsign=nt of a cacend man to rsmain with him. Accordingly, under the shutdown conditions specified above, the requireman.ts of the first sentence in 9.3.3 of the arcendment te SG-2, dated March 24, 1972, need not apply. In all other respects, I { however, such an area shall continue to be pro- } tected as a plutonium access area." 'The storage vault area requires the presence of tuo authorized individuals for all receipts into and issues from the vault. The' vault is locked when uncanned, j No personal vehicles are permitted within the protected area. In addition to the requirements of the license condi-tions, Kerr-McGee's contract with Hanford Engineering Development Laboratory (HEDL) places an additional requirement for visitor control. This requirement is incorporated into 1(err-McGee's security program and states in part: 2 "Exoept with prior written consent of Westinghouse llanford and the Commission, contractor chall not permit any visitor to the contractor's plant, office or facility to view or examine the product specified to be delivered under this contract, or major sub-assemblics of such product, cr to obtain information or data concernics such product." I Visit.or means any person who visits contractor's plant. ~ office or facility and does not represent either* con-i; tractor, Westinghouse Hanford, or the Government in l the performance of this contract. All employees who have access to the plutonium plant have their names embossed on either a green tape, red tape or blue tape on a board mounted on the wall in the Central Control Station. With each name is a l lateral switch and an embossed label indicating "in l or out". A switch to the right indicates the employee to be out of the plant and if the switch is resting on the lef t side, clie employee is in the plant. A letter U for uranium and P for pluconium after each name signifies where the individual keeps his film badge. It is the etcployee's respeasibility to switch e*y } r-

e hiccoif in cnd cut of thp plcat each time h2 cntsrs or leaves while the guard observes his picture badge. At the end of the working day each* day shift employee working in the plutonium building will have switched out and surrendered his film badge (if a plutonium plant worker). If normally a uranium employee, the film badge will be dropped off at the front reception desk at the uranium building, but his switch will be on the out position at the plutonium plant. The green tape personne1'have unlimited access and includes supervisory and management personnel who have completed the required haalth physics training and are the qualified escorts.. The red tape personnel have also completed the necessary. safety training and have access without escort only during duty hours. If a red taped employee was to work other than his normal work hours, he must notify the watchman, be escorted by a supervisor, sign the employee log book and switch in. The escort supervisor would also sign the employee log as escort and when the employee leaves, he would sign out and switch out. The blue tape personnel are licensee personnel with semi-limited access and are not regularly assigned to the plutonium plant. They must inform the watchman whom they wish to see and the watchman will inform that individual. If the blue taped individual has a V following his name (licensee employee who occasionally visits the site) he will be issued a visitor's badge, require an escort, switch in and sign the visitor's log. Another access category is licensee personnel whose names do not appear on the switchboard. These personnel are handled as visitors and must sign the visitor's log and be escorted. Plant employees who forget their badges are issued visitor badges and in addition to switching in, must sign employce's log. Both vendors and visitors must first sign in at the receptionist's desk at the uranium plant before entry into the plutonium plant. Visitors and vendors are escorted and vendors are not permitted in the pro-cessing areas. ~ Plutonium is never removed from the plutonium plant unless it is being externally shipped or intended for burial. Material determined for burial is put in a j ll 1 i ' 7-0 V hD $ f f -,--,,e---.

10ck2d burici van lecctsd at,tha 1ciding d:ck (within [. tha p2rinstar fence until there is enough to comprise a shipment). A memo from the Facility Manager to all plutonium plant personnel requires all packages, lunchboxes and brief' cases for all licensee employees and visitors to be opened and inspected by the watchman. Vehicles entering the protected area are searched for devices which coul,d aid in sabotage. Combinations to locks on the change room and vault are changed monthly by maintenance personnel and recorded. With the inception of SG-2, lock tumblers for the front door lock and two gate padlocks (truck and sample ~ window gates) were changed. Haster keys to these locks are in the possession of the plant superintendent, process engineer, and the engineer maintenance man. The remaining three master keys are in the Security Vault a key should terminate. Locks will be changed if any employe The inspection team was keys to aither plant. assured that none of the personnel now The inspection team observed access procedures, reviewed key and lock controls and access constraint plutonium building and concluded tham to be satisfactory. 9.4.0 Detection Aids A tour of the plutonium plant periceter fence was con-ducted by the inspection team. The fence is constructed of No. 9 American wire gauge and has an overall height including three barbed wire strands of not less than eight feet. The top brackets angle outward. The perimeter fence has six gates with the truck gate i and laboratory gate being used more often. The remaining four gates are crash gates used only if there is a criticality alarm or practice criticality drill. L The truck and laboratory gates are secured with a six The remaining four gates are point master key lock. secured with a horizontal lock bar attached to the gate i latches and a vertical steel post cbout four feet inside l i i / m pp <+ k reAwJ ~, h. e bret _y e

ll ~ the fence. This lock bar is hinged with a bolt con-taining a lead seal at the point it is attached to the vertical post. The following objects were noted within the perimeter I fence: 2, s 1. Permanent cement structure housing transformers i and the emergency power supply system located within fif teen to twenty feet of the inside of the perimeter l'ence on the east side of the plutonium plant. The structure is approximately 3 twenty feet long, seven feet high, and deven feet I wide. The structure can not be seen from'the i watchman's Central Control-Station and could j easily conceal an individual. This is in noncom-pliance with License Condition 9.4.1. A letter fro . S. Dun roup Vice President, s Kerr-McGee C oration,. R. C. Page, Chief, Materials 'and Plant Protection Branch, AEC Headquarters, dated June 30, 1972, forwarded a pro forma statenant and description of the revised security system for the licensee's Cimarron Plutonium Plant. In this security system des-cription, the licensee recognizes that the only j exception to the 50 foot clear space inside the fence is the location of emargency generator and transformers on the east side of the plant. This i system description also indicates this problem was discussed with the AEC and that moving this fence would result it being located in a gulley an*d the perimeter would be out of line of sight. i I' We discussed this problem with Mr. Carl B. Sauyer, l Materials and Plant Protection'Brahch, Directorate of Licensing. Mr. Sawyer saii that at this time,

• l

'the licensee's position in this matter has been i accepted in lieu of moving thz fence and final resolution is being considered by Directorate of Licensing. I 2. Eight 55-gallon drums of liquid solvents approxi-1 mately ten feet from the insida southwest corner ] of the fence. The licensee was told by the I inspection team that these drums should be removed i, . 5 -\\ i 1 9 1 ~ d -,n-, ,---.a c _,,, ,-n .ne_., ,,.-e..,-en_-- --.--.--_n,- m,w-,. n.- w w -- ,,.,,w n m wm,xw,, m n, ,-~em,

s ,"s an individual and are within 50 fee e of the perimeter fence. At the time of writing this report, these drums had not been removed. is in noncompliance with License Condition 9 4 1 This ' 3. Pipe and metal along the west side of the peri fence. conceal an individual.These items are icw prefile an meter Evidence of soil, erosion was noted on the north a d permit entrance without digging. east side of th n fence does not go into the ground (about a two inchTh space). This combined with easy digging could permit access. The inspection team suggested this be corrected The inspection team in conjunction with the plant patrol to inspect perimeter lighting. security is considered very satisfactory and capable ofThe lighting detecting an intruder in the adjacent as well as th fenced-in area. e during the day shift.No perimeter patrols are conduc noncompliance with License Condition 9.4.3.The licens for the period 1600 to 0800 hours (two s Only Results of the licensee's perimeter fence inspection are recorded on patrol check log sheets. s .the sheets generated during the October through'pected We ins December 1972 period to determine if the required number of inspections had been performed during the Missing entries on nine separate days wer I At two-hour intervals, four entries would be required { for each shift or eight entries per two shifts 92 days (three months) there should have been 736 In, entries. i entries less.We accounted for only 700 entries or 36 Thirty-two of these 36 missing entries 1 occurred on eight days during the period November 30 through December 25, 1972. during this period. The' plant was on strike The remaining four entries were missing on the patrol check log dated October'19, 1972. i I . I. i e 4 D Q Y l0 ) . O e

N'y 'jl Tha plutonium buildin is e pp'ed wit E' e la oratory -y window and the loading dock. In addition lutonium MA detectors with a sensitivity of.1 gram plutonium are located at the point of personnel entrance and exit j (Central Control Station @ inside thefir-locked doors of the dor' pod the laboratory sample window'. Packages and vehicles are inspected by the watchmen before exiting the protected area. The is in the on position at all times except when the watchman is notified of activation because of a recei or shi ment. In addi-

)y)/.tiontothe ynb b

The plutonium storage vault, required by License Condition 9.3.2 to be a separate plutonium access area, is net protected by an intrusion alarm. This is in noncompliance with License Condition 9.4.5. The inspe'etion team in conjunction with the plant security officer, tested all plutonium detectors and intrusion alarms. One member of the inspection tean participated'in the testing uhile the ocher member remained at the Central Control Station to confirm creditability of the alarm systems. Each alarm and detector annunciated loud and clear at the points checked and at the Central Control Station. In addition, respective lights flashed for the numbered alarms at the Central Control Station. The auditory alarm, with lights for location, in the administr.ative area also annunciated during the tests. Our review of the watchman's log for three months revealed only two occasions when results of tests, inspections and maintenance on intrusion alarms were recorded. Therefore, the licensee was cited for noncompliance with License Condition 9.4.8. Review o'f such recordr, is the only method by which the l inspection team can ascertain that the required intrusion alarm tests and inspections are being performed. ~

p .y 9.5.0 Re::ponca The watchmen have procedures, and have had some (ndividual instructions by the plant security officer, but have had no formal training. The primary action of the watchmen in a threat situation is to contact a supervisor (during normal work hours) and utility-personnel (during off-hours) responsible for perimeter patrols, unauthorized removal and sabotage. ~ Protection of the pladt agninst sabotage and unauthorized removal of SNM is a combined effort of watchmen, supervisors and utility personnel. It was suggested that periodic training be conducted for these personnel for familiarity of proceduren and such training I sessions be documented. The licensee has established liaison with local law enforcement authorities. Wi

• normal telephone

+ T vice Crescent, Oklahoma an respond in five ] j minutes; Guthrie, Oklahoma, 10 minutes; and r Kingfisher, Oklahoma, in 15 minutes.

• The Highway S (

. Patrol responsible for Logan County can respond as ' quickly as 10 minutes or as long as 42 minutes ding on their location During this inspection, the inspection team did not request the licenses to test these response times since prior attempts by the licensee to test the i response times have not been successful. These t . local law enforcecent agencies have assured response and cooperation if help is needed. Watchmen at present have no access to the processing L areas (health physics orientation planned), but g through telephone, "walkie-talkie," and the public a address system,.the watchmen have continuous contact. with supervisors and utility employees who are capable of responding to an alarm within five minutes. a l 9.6.0 Communications l l Watchmen continuously man ti e Central Control Station h i and have communication' capability and authority to call for reinforcements. During the inspection team's participation in the licensee's night perimeter patrol, j r. 12 - l 1 e D ff er$ ,f p l J. hf \\\\

l f-(, s. s. .e e.. ~ m... m W CLEAR MATERIALS SAFEGUARDS INSPECTION. OF SPECIAL NUCLEAR IOTERIAL AT, KERR-McGEE CORPORATION '~ CIMARRON PLUTONIUM FACILITY CRESCENT, OKLAHOMA' SNM-1174 DOCKET NO. 70-1193 5 .RO INSPECTION REPORT NO. 7 -03 SECIION I' i ~ I. Inspection dates: ebruary 21 through February 23, 1973 a ~ h 12_ through March it), 19 /.s. c II. Inspection period: January 17, 1972 through March 12, 1973. III. AEC personnel participating in the inspectizn were: ) J. A. Hind A. G. Finley C. C. Peck J. P. Pattersan IV. Report prepared by: J. A. Hind l l V. Date repore prepared: March 27,".1973~'7? s VI.

SUMMARY

OF FINDINGS A. Items of Noncompliance: 1. License Condition 3.4 - A report, Jated February 15, 1973, ~ ~ was issued by the licensee to comply with this license condition, but the report did ' ot include a quantitative n calculation of limits of error of the measurement system. 2. License condition 3.7 - This licerse conilition was effective on August 1, 1972. A report of thi results of the licensee measurement evaluation within six months af ter commencing operations on the FFTF project has not been submitted to AEC, Headquarters. I, m \\ .m="* a M 'S V f (*'n E Pc o.c/,, p.f, c f) ~\\ i emes

i ( .s.. s 3. License Condition 6.5 - The licensee has not closed a material balance around plutonium in process at intervals not to e,xceed thirty days. 6 4. License Condition 7.1 - Materiai balance area and, plant. records are not being reconciled.st the end of each accounting period. 5. License condition 8.1 - A report dated September 28, 1972, outlined the, findings of an internal audit of the safeguards and measurement and limit of error program, but an internal review of the remaining parts of the special nuclear material control system has not been conducted duri, g the inspection n periods In fact, no such review has been conducted since the origination of the plutonium facility.,Ihe licensee stated this type of review will be conducted by the corporate. internal auditing department within the next couple of months. ~ B. Status of Prior Items of Noncompliance (reference letter to Kerr-McGee Corporation from C. D. W.' Thornton, dated March 6,1972). 1. Contrary to Condition 8.1 an independent internal review of the nue-lear materials cor. trol procedures and management of the overall system of special smelear material control had not been conducted within the. 3ast 12 months following the last review. Status: The licensee is still not in full compliance with this license condition since the nontechnical portion of such a review had not been performed during the last 12 months.,This noncompliance item is repeated. 2. It appears that certain of your activities were not in full compliance with the requiremerts of 10 CFR Part 70 in that contrary to 10 CFR 70.54 ani the instructions for completing and distributing Form JGC-741: a. Limits of error were not inc11ded on the forms documenting receipts; b. Limits of. error for shipments were not reflected on the licensee's record copy of the form; and c. All forma for receipts were not completed and dis-tributed within the time perini specified.

,s. n t OFFICIAL USE ONLY t Status: These noncompliance items were corrected during the inspection pe:iod, and theref are, were not . reported. 3. It was also noted that you had not followed the special Kerr-McGee dated February 2,1971) for iniintaining re[ cords instructions. (letter R. G. Page, NSS, th. E. Wuller and reports under an assigned R15 (YUW) fo.r nuclear material of Canadian origin. Status: This situation was corrected prior to this inspection and therefore is not repeated. The licensee has no Canadian owned nuclear material.at this time. t C. Licensee personnel urnishing informatien on the items of noncompliance we ay Janka, Gavin Mallet, Bill Shelley, DonBristolgand re Welch Q,d Y I (/ J. A. Hind, Chief Materials and Plant Protection Branch i t 4 OFFICIAL USE ONLY m mo e N y y

'.a. C, ..- o .e-MEASURIENTS AND STATISTICAL CONTRdIA De licensee, thall determine the U-235, U-233, and/or Fu content of all receipts, shipa.ents, intentional discards and material inventoried, along with the limits of e'tror.essociated with these quantities. '!he licensee shall make sufficient measurements to substantiate the stated guantities and associated limits of error. Measunaments are not re- ' quired on items which have been determined by other means to contain less than ten (10) grams W235, W233, and/or Pu each. Limits of error

• as used herein means the boundaries within which the true or best value of the parameter being measured lies with a probability of 951.

A' program of standariaation and calibration of measurement equipment and analytical

• procedures shall be maintained to provide dets to sub-4 stantiate the limits of error associated with all measurements required for safeguards purposes.

All measurements required by this amendment she'll be reviewed annually by the Manager, Administration and Accountability. This review shall include a quantitative calculation of limits of error of the measure-ment system. The Manager, Administration and Accountability, shall utilise date obtained throuhh calibrations specified in codition 3.2 to monitor performance of the meawrement system to assure calculated limits of error are maintained between reviews. gecords of reviews, esiculations, and use of calibration data shall be kept by the Manager, Administration and Accountability. Af ter any physical inventory the material unaccounted for (MUF) and the limits of error associated with the material unaccounted for shall be computed promptly. He limits of error associated with MUF shall be calculated by statistica*11y combining the Ilmite.of error determined for shipeents, receipts, beginning inventory, ending inventory, and 1 measured losses for the period since the last inventory. L If the quantity of MJF' exceeds the associated limits of error, the licensee shall promptly notify the Atomic Energy Coassission, Division of Nuclear Materials Safeguards, District II, Oak Ridge, Tennessee. The licensee shall investigate the MJF and notify the Division of Nuclear Materiale p.- Safeguards within thirty (30) days after the initial notice, specifying the probable reasons for the MUF and the corrective action taken or planned.

• oss Mechanisms Review - October 1972 selected for verificationd.back-up L

dets for losses - review not complete. l ITS: eral, we're~ satisfied with measurements being made en receipts, shipments, as, and material on inventory except UF6 **** Pts. . full cann11ance (UFJ - 3.1 re EU values being accepted without downstream correlation being made to the values. This has to be done in order to accept the EU values. itives (1) set up ownesupling stattom and analyse sua easples (2) obesia Other stative sempelo from ABC and have them analysed by tedependast gab and values em 741 and ta'oestret socords. 3 did not include qua:.titative calculatior, og LE of meenrersent s as ao validation or ug.datug of 14 valust or factors used for receipts, to, discards', and int entory 1.M caledatione % pge cm Ae. rele.ud k Ah/ 1

(- V c ..,.. ~ 5.0 MEdSUREfCNTS AND STATISTICAL CCHIROLS (esat'd) during the inspection period. We think most of the data has been gene' rated from various control programs, but as stated, the date has not been utilized in current LE calculations. by Heagerty lest year for his invent'ory calculations will have to be utilize for this inspection period inventory. of scrap during the inspection period and quite a bit of it is'en thisThere has bee inventory. associated with this procedure,Some studies by Hallet are now beginning to det , Think that an extensive review of this system is needed to estab"lish flow of measureme-t and standardization data to the end product of 12 Computorized syster. similar to the plutonitas system is be and this uranium facility, but I don't think you can wait for this., Emnhesitet types of information needed for.LE calculations (3) procedure will be complied with (annual review, monthly, etc.). 3*'

• 11 alculated. 2-3 weeks after Pu calculations which will e

b -n,.s p,e c h a n J,,, yd r 8 0 2:. ~, a is ; _ )'**) $ ' - S.l V V a-i, ,Y wai_d!~w'*&s.%sa' .~ 4 - w ,~._. ,.,, w.~n.d. w,3. %.- l w l r. ., n,. [ 2 f M e 4 i 1 l

.d ' ng. { i.- 4.0 SHIPPING AND RECEIVING t 4.1 All shipper-receiver' differences shall be brough to the attention of the Managdr, Administration and Ac. countability, who shall evaluate these differences to determine whether they are statistica11y'signifi cant and of sufficione magnitude to warrant investigation., Administration and Accountability, shall investigate all statistically Asie Manager, significant differences which exceed $500 value. A shipper-receifer dif-ference shall be considered statistically significant when (1)'the dif- . ference exceeds the stati'stical combination of the limits of error the shipper's and receiver's measurements, or. (2) if the shipper's limit of error is unknow, for the receiver's. measurement.the difference exceeds twice the l Statistical analyses of past perfor-Manager, Administration and Accountability.mance, measurement u COMMENTS S/R differences being evaluated by the above procedures. .Our review indicates no significant S/R's that have,not been investigated. Ihls p~j c my be rele m ) h> /ei/ l l I

-s / 5.0 STORAGE AND INTERNAL TRANSFERS 5.1, A doclamented " system of control over special nuclear material s r d processed wi' thin the facility shall be maintained which 'will pro' vide continuous knowledge of. the location and quantity of all material contained in discrete, identificable items,or containers. / 5.2 All transfers of special nuclear a[aterial between HEA's shall be docu . mented to show the identity, quantly, and isotopic analysis of the material transferred. licensee for the distribution and accounting of all transfer d 5.3~ Each document supporting a transfer of material between MBA's sha' ll be signed by the delegated individual. COMMENTS: 5.1 Check of production logs indicate the'information in the logs will identify and locate discrete items if job identification and enrichment are,know. Not stated in the license condition but implied (we think) is a method by which a system can be tested and records maintained of such test. Best time t,o test the system is at inventory time. 5.2 Transfers between MBA's (75% U-235 and ( 5% U-235) a're practically nonexistent. the 75% U-235 to the (5% U-235 MBA.During inspection period, seven tra Six of these transfers were accomplished by journal entries and one by transfer document. of limited activity between MBA's, we have no si*gnificant problem with Because these six transfers b*eing accomplished by means dther than transfer docum Internal transfer documents have been issued for possible use and were n s. accounted for. 5.3 by delegated individual. Documents supporting the transfers were signed 8 )

1. )

bb 4 / *) =7 D = "

I k!r. \\ - - r;; .\\ 6.0 INVENTORY 6.1 A complete physical inventory of all special nuclear material subject to this license shall be conducted annually, but in no case shall more ' than fourteen months elapse between inventories. 6.2 Prior to each compGete physical inventory, written procedures shall .be prepared which: ,6.2.1. specify the extent to which each MBA is to shut down and clean out process equipment; 6.2.2. specify.the extent to which each HEA is to remain static during the ' inventory; 6.2.3. identify the basis for accepting for inventory purposes previously made measurements and their Ibaits of error; 6.2.4. designate measurements to.be ma-de for inventory purposes to establish and demonstrate the limits of error associated with the quantity of material on inventory; and 6.2.5., identify the manner by which material on inventory will be listed to assure each item is inventoried and there are no duplications or omissions. 6.3 The book inventory shall be reconciled with and adjusted to the results of the physical inventory upon completion of the physical inventory. 6.4 Special physical inventories of an NBA shall be conducted whenever there is reason to believe that subsequent to the, last prior physical inventory a particular MBA has experienced losses or gains that are different by a statistically significant amount from those expected. 6.5, Number of samples taken and results of gamma count and checkweighing. CAT. I - 37 CAT. II - 34 CAT. III - 38 l Total - 109 All to NBL.. COMMENTS: 6.1 - OK '6 2 Written proced'ures covered outlined items. Our checks indicate very satisfactory clean-up for inventory. l 6.3 ~ book reconciled with and adjusted to results of physical 6.4 no special inventories taken. S 'Ths pap 4 Je ra/egd m ffl I oe .~,, - - + - y, ..-.._,--.-.7-.-. .w, --,-w y-

7.0 RECORDS AND REPORTS ,7.1 The licensee shall establish and maintain a records system which will provide' sufficient i.nformati'on to maintain a material balance around each MBA and the total plant. These records shall contain information ' pertaining'to all receipts, shipments,. measured dis-cards, inventory, and MUF for each material balance.~ MBA and plant records shall be reconciled at the end of each accounting period. All entries in the records shall be supported by appropriate docu-ments. ,7.2.All measured discards and MUF shall be reported on a inonthly basis by the Manager, Administratiog and Accountability, to the Cimarron Facility Manager. ~ 7.3 The licensee shall report 'on a monthly b' asis all intentional dis-cards and material unsecounted for.. The HUF shall be that which has been determined during the month as a result of completing a material balance ar6und a single operation, a number of operations or the entire plant. This report shall be made within fifteen (15) day) after the end of the month in which the discard was made or the material unaccounted for was detensined. Reports shall be sent to the U. S. Atomic Energy Commission, Division of Nuclear Materials Safeguards, District II, Oak Ridge, Tennessee. Each report shall be identified by the Rep' rting Identification Symbol (s) (RIS) assigned o to the licensed operations and shall include 'a statement of the nature of the discards, the probable reasons for the MUF and any actions taken or planned with respect.to the MTF. 7.4 (a) 70.42 - transfer to authorised recipients,' SPM4Md-4MMhewMwkwwWe (b) 70.53 - status reports (c) 70.54 - transfer documents CatectTS: g 7.1 total plant records - CK j 5% W 235 MBA; approx. 14 kas W 235 5% W 235 MBA: approx. 1338 kgs. W 235 l e MBA records can't be reconciled with control because losses and ? adjustments aren't in MBA records but since the 75% contains small. amount of total inventory and* limited activity, the isolation of losses can be accomplished and reported by use,of job ledgers. Also this> 5% macerial in this MBA is becoming smaller and will probably eventually disappear. Therefore, the required reconciliation of NBA anti total plant records that isn't being done will not be reported as noncompliance. If the >5% W235 account becomes active from the standpoint of activity.other than downgrading, this will not be the l . case, and reconciliation will be expected; crosscheck would be i necessary. t l 7.2 - et 7.3 - CK 70.42 - OK ~ 70.53 - OK 70.54 and special instructions for completing 741 documents: lbt in full compliance Not all AEC-741's documenting receipts were dispatched within the required time limit; 18 documents (UF ); ranged g from 35 days to 6 mos. Material preordered and is in yard for varying periods of time before feeding and obtaining measurement values..If think necessary - ask for exception from I.teensing. ~ k g O z 7% pye u, de ce/w/ m M)

(- NUCLEAR MATERIALS SAFEGUARDS INSPECTION ~ 0F SPECIAL NUCLEAR MATERIAL AT 'KERR-McGEE CORPORATION ~ CIMARRON PLUTONIUM FACILITY CRESCENT, OKLAHOMA SNM-1174, Close-out Meeting notes with Management - Date:__. 3/16/73 Preliminary.Mee ting Final Meeting K-M _AEC ~ ~ c. K-M AEC R.Jaskaj J. Hind P. Welch C. Peck W. Moore 'l J. Hind QC.Hallet A. Finicy W. Shelley D. Cothamj C. Peck / J. Patterson M. Binetock D. Rhodes A. Finley M. Hodo J. Marler D.Bristob R. Janka C. Mallet I f T. Clantoni .s r r L-. ~ _MISCELIANEOUS 1/17/72 - Inspection Period:- 3/12/73 ' 2/21-23/73 __ Dates Field Work Pe'rformed:_ 3/12'-16/73 In'ventory Date:_ 3/12/73 l 1 1 t e ~ - - - ~ - - i

-i : : ( ( 8.0 MANAGEMENT OF MATERIALS CONTROL SYSTEM 8.1. Licensee management, independent of the ' Manager, Administration and ..ecountability,.shall conduct, at least once each year, an internal. review of the nucicar acterials control procedures and management of the overall system of special nuclear material control and, report the findings to the Cimarron Facility Manager. 8.2 An estimate of anticipated losses (measured discard's plus MUF) for

• each period of time between inventories chall be prepared. for each MBA, with the ' oncurrence of the Manager', 'Administrati.on and Account-c ability, and shall be based on prior experience, throughout quantities and rates, etc.

If losses exceed the estimate of those anticipated, they shall be investigated by the

• Manager, Administration and Account-ability, and the results of his investigation shall be. reported to the Cimarron Facility Manager.

8.3 Any apparent loss of a discrete item or container of special nuclear material which cannot be resolved by an immediate investigation shall be reported to the Manager, Administration and Accountability, who shall prompty notify the Atomic Energy Commission, Division of Nu-clear Materials Safeguards, District II, Oak Ridge, Tennessee, and sha11' conduct an investigation of the loss. The Manager, Administra-tion and Accountability, shall report the results of his investigation to the Cimarron Facility Manager. COMMENTS: Internal review combenced 4/19/72 - report issued 6/9/72. Conduc ted 8.1 l I by Internal Auditing Department, K-M Corp. This review did got t indluda me urement & LE's. We consider audit' performed' bfijeagerty and Malle report issued September 19, 1972) as completinj the required internal iew. l 8.2 iM; 8.3 No apparent loss of discrete item reported. e e 4 e'

~ ~... ',,.,., { ~ 4,'.' ~ 1.0 FACILITY ORGANIZATION

• - 1.1 ne Cimarron Plutonium P'lant knager shall develop, revise, implement, and enforce the nuclear material control procedures,

and manage an overall system ' f special nuclear material co'ntrol.' o 1.2 Nuclear material control procedures and revisions thereto'shall be ' approved by the Cimarron Plutonium Plant Manager, and the kna'ger, Administrat, ion and Accountability. A manual contain'i'ng all current nuclear material control procedures shall be maintained i by the k nager, Administration and Accountability. ne Nanager, Administration and Accountability, sha11' assure that 1.3 ~ the nuclear material control procedures are appropriately reflected in process specifications, manufacturing instruction, st'andard - opera ting procedures, or similar detailed management instru'ctions. 1.4 All delegations of safeguards responsibilities by the Cimarron Plutonium Plant k nager shall be in writing. COMMENTS: 1.1 OK when considering knual, LE &nual (both being revised) and SOP's 1.2 issued by the Safeguards group 1.3 - Formalize method with document contro1 officer by which he asks the preparer of SOP's what areas of responsibility are involved in the pertinent SOP'-s and if nuclear material control is involved, include knager, Administration and Accountability in the 1,ist of necessary review and approval signatures. -QK 1.4 D e e e O e l f l e O 2 i e b

• • .=,. _...

e n.

I ( ( l .\\ 2.0 FACILITY OPERATION Material ~ Balance Areas hiBA's) shall be esta'blished by the Manager, 2.1 Administration and Accountability. ~ 2.2 Each MBA shall be an identifiable physical area into and out of which movement of special nuclear material can be measured. 2.3 Sufficient numbers of MBA's shall be established so that losses of spec'al nuclear material can be identified and localized. 2.4 1 All operations within an MBA shall be the responsibility of a single employee who shall als'o be responsible for the custody of special nuclear material within his MBA. 2.5 All operations on FFTF material shall be performed completely independent of other operations such that.no other special nuclear material becomes mixed with FFTF material. 2.6 Possession limits (10 CFR 70.41) Authorized Limits Possession 360 Kg.s Pu 117.5 Kgs Pu (Book as of 3/12/73) 1.1 Kgs U-2)5 0 CO E NTS: 2.1 For this inspection period, four MBA's including MBA for enriched uranium; planning 8 MBA's including enriched U as an NBA. 2.2 OK 2.3 ' OK 2.4 OK 2.5 Ok; only approxir ately 1 KG Pu in privalety owned. O e f b

( e. g mm STATISTICAL CONTROLS - ~

• gicensee shall de' ermine the U-2M, U-N3, and/or Pu content t

11 rece1 ts, sh'ipments, inteational*diccards and material *. P [nve,ntoried, along with the Ifmits 'of error assoicated with these g quantities. The licensee shall make sufficient measurements to substantiate the stated quantities and associated limits of error. Measurements are not required on. items which have been determined by other means to'contain less than ten (10) grams U-235, U-233.. 'and/or Pu each. Limits of error as used herein means the boundaries within.which the true or best value of the param'eter being measured 1ies with a probability of 951. 3.2. The frequency and quality of the meas'urements made to comply with the' license conditions shall be controlled so that the limits of error associated with the plutonium material unaccounted for (Lt . for the 30-day period does not exceed the larger of (s)36 g' rams plutonium or, (b) 0.5%.of either the additions to or removals from the plutonium in process for the month, whichever i is greater. 3.3 A program of standardization and calibration of measurement equipment and analytical procedures shall be maintained to provide data to substantiate the limits of error assoicated with all measurements required for sa'feguards purposes. ,3.4 All measurements required by this amendment shall be reviewed ar.aually by the Manager, Administration and Accountability.- This review shall include a quantitative calculation of limits of error of the measurement system. 4 The F.an' ger, Administrati*on and Accounta. a bility, shall utilize data obtained through calibrations specified in Condition 3.2 to monitor performance of the measurement system to assure calculated limits of error are maintained be' tween reviews. 6 Rmrds of reviews, calculations, and use of calibra' tion data sh411 be kept by the Manager, Administration and Accountability. After any physical inv'entory the material unaccounted for (m) and 3.5

• the limits of error associated with.the material unaccounted for

~ shall be computed 'promptly. The limits of error associated with e-M shall be calculated by statistically combining the limits of error determined for shipment', receipts, beginning inventory, s ending inventory, and measured losses for the period since the last inventory. 3.6 If (1) the quantity of plutonium HUF exceed its assoicated limits of error, or (ii) the limits of errer associated with the plutonium ' HUF (7 exceed th*e limit specified in Condition 3.2, the dall promtly notify the Atomic Energy Coassission, licensee Directorate of Regulatory Operations, Region III, Glen Ellyn, Illinois. The licensee shall conduct an investigation and notify the Directorate of Regulatory Operations, Washington, D. C., within thirty (30) days after the intital notice, specifying the probable reasons for the excessive values and the corrective action taken or planned. 3.7 The asasurement review required by Condition 3.4 of the safeguards amendment to this license, shall be performed within six months after commencing operations on the FFTF projecg, insofar as this condition applies to measurements made on FFTF project plutonium. l The licensee shall submit to the U. S. Atomic Energy Con.nission, Directorate of Regulatory Operations, Wash,ington, D.C., within thirty (30) days after the evaluation, a report of the results of the evaluation.' i e Y Y

(.. l ( 3.8 At the completion of the FFTF project the li to. the U. S. Atomic Energy Comission censee shall submit Operations, Washington, D.C., a report whichDirectorate of Regulatory j error for each component, the cumulative materialc sumarizes all

the limits of, and the c,umulative limits of error for the materi l unaccounted for t

for. th'e last product. shipment is made.This report shall be submit a unaccounted days, after ~ COMMENTS: by the licensee during this' inspection periodComments m ted activity' experience ~d 3.1 ' For this inspection perio'd activity we feel sufficie t 'have been made to substantiate stated'qu n measurements different material balance elements (receiptsantities of material in LE's on these receipts, shipments etc. were es,sentiallshipments,etc) The on a receipt by receipt basis, etc. l y calculated calculations will be reviewed after submittedThe ending inventory LE 3.2 No 30-day period balances reported on activit'y duri period, therefore this LE not evaluate your system to ascertain if it would meet thicr gp W_ e did values against the criteria.The " proof of the pudding" is when yo s criteria. s ng 30-day LE strin'ent and would require monthly investigationsK-H contends this cr g g t being proposed by K-M to. Directorate of Licensing New procedures 3.3 , Program of standardization and calibration of meagurement a d . analytical procedures involvf ng material activity during thi n u inspection period, we feel, is satisfactory s in general being answered with the submission of ne Questions we had qts) are. '3.4 and 3.7 procedures. comply with 3.4 did not include a quantitative calcula re-made to of error of measurement system and in. connection with 3 7 of limits measurement review report has not been submitted to Headqu , the required required. Effective date of 3.7 was August 1,1972. arters,se hpplies to 30 day inventory period but no 30 day inven ~3.5 Since January 1972, physical inventories taken on Is inventory was booked and lethe resulting March 18 HUF was not boo om the July calculations for the period January 7. .7, 1972 were made. This pebd calculation will be fo'r the period J l 1972.through March July 12, 1973. period after they have been made.We will review your calculations for this

uy8, 3.6 Discussion about the fact that a 6 month LEonly criteri (i) w calculated.

e. MUF does not hav e to be 3.8 - Not applicable yet. e cp $e. Y YN 2 m ~ ,-__r_ __,_.m._-...~.___,,_-m.-,,.,,,_mm-m._,,m ,,,. mm .__.m,,--,.____,-,,,-.-y,m. - - -,. -. -., - _ _, -, _ _,

.' 2 \\. ( 4.0 SHIPPING A' 3 RECEIVING 4.1 All shipper-receiver differences shall be brought to the attention of t'he Manager, l.Jainistration and Accountability, who shall evaluate the ic differences t6 determine whether they' ar,e statistically significant and of sufficient magnitude to warrant investigation. The Manager, Administration a'nd Accountability, shall investigate all statistically significant. differences which exceed $500 value. A shipper-receiver difference shall be considered statistically significant when (1) the difference exceeds the statistical combina-tion of the limits of error of the shipper's and, receiver's measurements, or (2) if the shipper's limi't of error is unknown, the difference exceeds twice the limits of error for the receiver's measurement. Statistical analyses of. past performance, measurement' , uncertainites and other data shall be kept by the Manager, Administration and Accountability. 4.2 The licensee phall retain a sample of pellets for'the Directorate of Regulatory Operations from each shipment, identical to that taken for his measurements. 4.3 Except for ultimate products, no plutonium shall be transferred or dispospd of until written approval of the controls and measurements involved 's granted by the Directorate of Regulatory + Operations, Washington, D.C., / COMMENTS: e 4.1 Two major shipments received on which LE of receiver's values calculated. .The first receipt *(HUA-YEC#2; S/R difference of 395-grams.Pu; K-M LE was f 189 grs Pu;_doublihg thi,s.L.E - t 378 grs Pu) indicated significant S/R ' difference. -Subsequent licensee investigation indicated that K-M LE value was unrealistic. On second shipment received - no significant S/R difference. Third shipment received has not been ful,1y analyzed and evaluated for LE ' calculations. For inspection period - procedures being followed. 4.2 Pellet samples being retained 4.3,- Written approval from Headquarters (Ltr. of 5/16/72 from Page t khelle 5 of controls and measurements for material to be disposed of. e e l S 0 q

(. ..~ ~ ~ 5.0 STORAGE AND INTERNAL TRANSFbRS 5.1 A. doc mented system of control over special nuclear material stored and processed within the facility shall be maintained which will provide continuous knowledge of the location and quantity of all material containeJ in di.screte, identifiable items or containers. 5.2 All transfers of special nuclear material between NBA's sinall be documented to show the identity, quantity, and igotopic analysis of the material transferred. A system of controls shall be maintained by the licepsee for the distribution and accounting of all transfer documents. 5.3 Each' document supporting a transfer of material between MBA's shall be signed by the delegated individual. COMMENTS: 5.1 Check df vault material logs indicated no discrepancies. Initiation of computer system will strengthen the controls outlined in this license condition. Included in this system should be procedures to audit the printout for accuracy. 5.2 System of controls maintained for the distribution and accounting of all transfer. documents is satisfactory. 5.3. - OK g O g 9 e u O g e ^% 0 Q e y 3 e

t \\ 6.0 IN TOR .~ 6.1 A complete physical inventory of all special nuclear material subject to this*1icense shall be' conducted at'approximately six-month intervals, but in sio case, shall more than eight raonths', elapse between inventories. 6.2 Prior to each complete physicai inventory, written procedures shall be prepared.which: 6.2.1 specify the extent to which each HPA is to shut down and clean out process equipment' 6.2.2 specify the extent to which' each HBA is to remain static during the inventory; 6.2.3 identify the basis for accepting for inventory purposes previously made measurements and their limits of error; 6.2.4 designate measurements to be made for inventory purposes to establish and demonstrate the limits of error associated with the quantity of material on inventory; and '6.2.5 identify the manner by which material on inventory will be listed to assure each item is inventoried and there are no duplications or omissions. 6.3 ne book inventory shall be reconciled with and adjusted to the results of the physical inventory upon completion of the physicat inventory. 6.4' Special physica1' inventories of an MBA shall be conducted whenever there is a reason to believe that subsequent e.o the last prior physical inventory a particular HBA has experienced losses or gains that are different by a statistically significant amount 'from those expected. 6.5 n e licensee.shall close a material balance around plutonisms in . process, (by algebraically combining data for receipts, shipments, discards, beginning and ending inventories) at intervals not to exceed thirty (30) days. Material in process means any plutonitss. possessed by the licensee, except in unopened receipts ar.d ultimate

• product, where the ultimate product is maintained in a manner which ensures the integrity of previously made measurements. All components of the material balance (additions, removals, and material on inventory) shall be determined on the basis of measurement; limits of error shall be established for each component and for the material unaccounted for. The material unaccounted for shall be determined and the limits of error calculated within ten (10) days af'ter the completion of tihe material balance.

I l CCR91ENTS: s 6.1 OK 6.2 - Written procedures co red requirements ouclined. 6.3 ' Reconciliation being made. 6.4 No special' inventories conducted under this criteria. 6.5 Item of noncompliance - closing of material balance around plutonium in . process et intervals not to exceed 30 days not being performed. Verification Samples 3 pellet samples in duplicate 2 U-Pu solution samples ,f,y,,,,gg, 239 & 241y g,, 4, 74 / a f c.n, le +eA.sJ i., M / l l l l

s. ( e 1 7.0 RECORDS.AND REPORTS 7.1 The lice'nsee-shall, establish and maintain a record system which will each MBA and the total plant.proviue sufficient information to maintain a ma These records ah11 contain information pertaining to all receipts, shipments, measured discards, inventory, and MUF for each material balance. reconciled at the end of each accounting period.MBA and plant records shall be re, cords shall be supported by appropriate documents.All entries in the I 7.2 All measured discards and MUF shall be reported 'on a monthly basis by the Manager, Administration and Accountability, to the Cimarron Plutonium Plant Manager. 7.3

• The-licensee shall submit Form AEC-742 Material Status Reports', comp in accordance with the printed instructions, as of the last day of each month for all plutonium.

within fifteen (15) days after the end of the period covered by theTh report, with a copy sent Region III, Glen Ellyn, Illinois.t6 the Directorate of Regulatory operations, 7.4 (a) 70.4,2 transfer to authorized recipients. (b) --70.51 (c) 3:::iled ce.t ci rece:ds (c) 70.53 ::::se i go. ;.e-(d) 70.54 transaction reports COMMENTS: .i L 7.1 Record system for tota 1; plant -nOK MBA records inadequate: (1) Losses not posted (2) Adjustments to external activity not entered. Item of noncompliance - no reconciliation of MBA and plant records being made. 7.2 OK i 7.3 Seatos reports being submieted. l l 70.42 OK i l 70.54 OK 1 6 h \\ % p.ge a, le <de A ) M i ,,c-g= e -,en----------m --,,n ,,-,------,------------------e

( - (' 'c s ' w ~ ) i i 8.0 MANAGEMENT OF MATERIALS VONTROL SYSTEM I 8.1 Licensee managem'ent, independent'of the Manager, Admin 5tration and Accountability, shall conduct,,at:1 east once each year

• an ' '

internal review of the nuclear materials control procedures and management of the overall system of special nuclear material control and report findings to the Cimarron Plutonium Plant hbnager 8.2 An. estimate of antic ~ipated losses (measured discards plus MUF) for each period of time between inventories shall be. prepared for each NBA, with the concurrence of the Manager, Adminstration an'd ~ Accountability, and shall be based on prior experience, throughout quantities and rates, etc. If losses exceed the estimate.of those .antici,,ated, they shall be investigated by the Manager,

• Administration and Accountability, and the results of his investigation shall be reported to the Cimarron Plutonium, Plant Manager.

8.3 Any apparent loss of a discrete item or container of special nuclear material which cannot be resolved by an immediate investigation who shall promptly notify the Atomic Energy Commission of Regulatory Operations, Region III, Glen Ellyn, Illinois, and shall conduct an investigation of the loss. The Manager, Administration and Accountability, shall report the results of his investigation to the Cimarron Plutonium Plant Manager. COMMENTS:

1..

8.1 Internal audit of Safeguards and Measurement and LE.ProgrgmaAe and r,eported in letter of Sept. 28, 1972. u ]Not in full' compliance. because internal review on respining parts of nuclear control system not performed during inspectiogberiod (actually none performed since origination of Pu plant). Internal review by corporate auditing staff planned within couple of months. f~~ l $.2 OK 1 8'.3 No, apparent loss been reported. ~ l I l .,. c e \\ hoj~ L con. t O d C* n t l l = - .-w,u -w x, g .,----.,,y.

" ~ .s 1.0 FACILITY ORGANIZATION ~ 3 1.1 Ihe 'Cimarron Facility Manager shall be responsible for developing, revising, implementing, and enforcin'g the nuclear material control - procedures and managing an over'all system of special nuclear material ~ control. ~ 1.2 Nuclear material control procedur'es and 'revisiops thereto s' hall be approved by,the, Manager, Administration and Accountability, and the Manager, Cimarron Facility. A manual containing all current nuclear material control procedures 'shall be mainta'i' ed by the Manager, Ad-n miriistration and Accountability. u ' Die tianager, Administration and Accountability, shall' assure that the 1.3 ~ -nuclear material control procedures are appropriately. reflected in process specificetions; manufacturing instructions, standard operating procedures, or similar detailed management' instructions. 1.4 All delegations of safdguards responsibilities by the Cimarron Facility Manager shall be in writing. COMMEN'IS : 1.1 Reviewed the Manual and' SOP's Manual needs updati sampling and I.E 1.2 program to incorporate eithe eagerty's or Mallet' thods and also ] method by which annual review of measurement syste are performed. i 1.3 Formalize method with document control officer by.which he asks the preparer of SOP's what areas of responsibility:a're. involved in the pertinent SOP's, and if nuclear material control is involved, include ,, Manager, administration and accountability in the list of necessary i 6 review and approval signatures. l 1.4 OK l P l F g 1 S l l l = l

..'.*,b ~ \\, .. s. r ~ tl})CL$AR EATER ALS SAFEGNARDS

• INSPEC

'. 0F SPECIAL NUCLEAR MATERIAL AT KERR-NcGEE CORPORATION. CIMARRON ENRICHED URANIUM FACILITY CRESCENT, OKLAHOMA . SNM-928 ~ s. Close-out Meeting notes with Management - Date: 3/16/73 Fralirninary Meeting -M ._ Final Meeti,ng AEC K-M

1. Jnnka J. Hind AEC

, Walch C. Pck M. Moore i* . Mallet /' . Cathsd A. Finley , W. Shelley J. Hind C. Peck J. Patterson N. Binstock- . H:do . Rhodes 'A. Finley ) ,, J. Marler 1 D. Bristol R. Janka G. Ma11et , T. Clanton( L s w a-s MISCELIANEOUS ~. 1/17/72 - 1" Inspecti(on Period: _ 3/12/73 Dates Field Work Performed2/21 - 23/73 Inventory Date 3/12/73' _ 3/12 _16/73 4 "g 3

\\.. N.* .~.. y 2.0 FACILITY' OPERATION. ~ ~ 2.1 Material Balance Areas (MBA's) shall be 'e'stablished by the Manager, " Administration ind Account; ability.. 2.2 Each MBA shall be an identifiable physical area into.a.nd out of which m ,moyement of special nuclear material can be measured. 2.3 Sufficient numbers of MBA's s.. 'special nuclear material can be identified and localized.. hall be establishe 2.4 A.11 'oerpations within an W shall,,be the responsibility of a single employee who shall"also be_ responsible for. the custody of, special nuclear material within his MBA. 2.5 Possession limits (10 CFR 70.41) '~ Authorized Limits Possession 6000 kgs. U-235 1352.5 kgs. U-235 (Book as of 3/12/73) COMMENTS: 2.1 - OK Two MBA's - <5% U-235 and > 57. U-235 .2. 2 - OK 2.3 - OK 2.4 - OK s ~

• /derA k n/m~),u yj

) l e e L

W-n..- ,, /3 3 /"7 '/ /M # / a 74.J,. 1 ] / Material Control and sical Protection (Pu)_ (I pq L / Dates of Inspection "1/17-21/72 v Report No. : 50-II- .a m lat ontrol and Security - Pu and U Plan s) h9 l Description of Violatio 1. No independent internal review. (U and Pu) (L.C.8.1). ) 2. LE's not included on shipping documents (U and Pu) (70.54). 3. Receipt forms not completed and distributed within required j time (U and Pu) (70.54) 4. Enriched U (greater than 20% U-235) not in separate fenced area outside (U) (73.32(c)). ' 5.' Security test of equipment records not maintained (U and Pu) (73s41(b)). Dates of Inspection: 1/14-16/73 Z Report No.: 070-1193/73-01 (Physical Protection) Violations: - 1. Permanent structure within 20 f t. of inside of fence (L.C.9.4.1).

2. [ Perimeter fence not inspected during work hours (L.C.9.4 3.

(L.C.9.4.5 and 73.3(k)). 4. ' Intrusion alarms not being tested as required (L.C.9.4.8).

I 5.

Dates of Inspection: 2/21-23 and 3/12-16/73 i 1teport No.: 070-1193/73-03 (Material control) . Violations: 1. Measurenent review not complete (L.C.3.4). '2. Not closed a 30-day material balance (L.C.6.5). 3. MBA and plant records not reconciled (L.C.7.1). i l..,. .4. Not in full compliance with independent audit requirements (L.C.8.1). ..i Dates of Inspection: 12/3-7/73 Report No.: 070-1193/73-08 (Material control) Violations: . LEMUF for five material balance periods exceed speci'fication of 1.5 Kgs. Pu (L.C.3.2). ~ Dates of Inspection: 2/26-37/74 Report No.: 070-1193/74-03 (Material Control) Violations: None l t ummmmmuums l & Le pge <~~ de <e%./ 3 _ __ ... _ g, 1

r Material Control and Physical Protection (Pu) Dates of Inspection: 3/11-13/74 Report No.: 070-1193/74-02 (Physical Protection) . Violations: ~ 1. Combination lock on vault broken (73.3(j) and 73.3(e)). 2. Visitors log information not complete (L.C.9.3.7 and 9.3.8). Pro ram Weakness: purious Pu monitor alarms at dock area 2 .a Dates of Inspection: 5/6-9/74 Report No.: 070-1193/74-04 (Physical Protection) Violations: 1. (' Failed to relocate TV camera at dock are2(73.60(a)(7)). 2. Not conducting communications check with LLEA; should be each shif t rather than daily (Plan 10.4). 3. Levels of illumination not as required on all sections-of physical --..j barrier (Plan 2.1.2.2). -l 4. ample windov not alarme4] (L.C.9.3.2). 5. etal de'tector f or exit search not installed (L.C.9.3.4).

6. [ Installation of motion detector in vault not complety(L.C.9.3.5).

.i 7. Protective personnel were not armed or uniformed (73.50(a)(1)). Ioorbetweenexhaustairfanroomandsupplyairfanroomnot] I 8. D l i alarmed (L.C.9.5). 9. 1 required portals not installed with magnetic switch intrusio

, j alarms rather than plunger types (L.C.9.7).

10. Secondary alarm annunciator not installed or operable at Uranium Post No. 2 (L.C.9.18.1).

11. Ihatal detect.or at entrance search installed but not operablel Qnd electric door lock not installedf(1.C.9.16.1 and 9.16.2 and s-9.18.2).

12. Intrusion alarms not installed in storage areas in fabrication {j. area and in the inspection and assenhly area (L.C.9.17.2).

13. Fonly one armed guard assigned to each shift rather than the) i l.

l % required two and an armed shif t supervisq6(L.C.9.18.3)., 1, 14.LAll existing intrusion alarms did not meet Federal specificationg 2. (L.C.9.18.4).

15. Log of individuals granted access to a normally unoccupied

.c -: vital areas not being maintained (73.70(d)). ..? Dates of Inspection: 7/23-25/74 Report No.: 070-1193/74-06 (Material Control) Violations: On three occasions when delayed measurements were made, the 741 l was not completed within 30-day period (70.54). 'g fa y w be re le a L e., k e k / 3 ,7 9 L.' _ 1.... . _. :.). _,._

F Haterial control and Physical Protection (Pu) f Dates of Inspection: 8/21-23/74 Report No.: 070-1193/74-07 (Haterial Control) Violations: 1. Accounting data for biases which exceed 10% of their standard deviations (L.C.3.5). 2. Tamper-safing seals not being used (L.C.6.3). 3. All SIM on inventory not based on measurements (L.C.6.4.2). , 4. Frequency of measurement of standards not being adhered to (L.C.3.3.2). Date of Inspection: 9/11/74 Report No.: 070-1193/74-08 (Physical Security) Violations: I ~ 1. Explosive detector not completely operable b ause ofj spurious sI larms due to other types of material, i.e. perfume,Vmoke (73.5 f) (1)),

2. fof the 12 intrusion alarms to b,e con,verted f plunger, type Lto magnetic switch types, all had been converted except one (L. C.9. 7).

1 ~ - g e O e e e g e k <e I&.J a.6 elf rulpyi cu, 3-t I W8mmuuuummuun 4 g 1 l' j

Material Control nnd Physical Protection (U)_ Dates of Inspection: 4/21-23 and 4/28-5/2/69 Report No.: 50-II-18 (Material Control) Violations: None Dates of Inspection: 1/7-15/70 Report No.: S0-II-33 (Material Control) Violations: 'LE's on ceasurement system and on receipts,' shipments, discards and MUF have not been established (FMX 3.0 and subparts). Dates of Inspection: 10/5-9/70

• Report No.: S0-II-56 (Material Control and Physical Protection)

Violations: 1. No manual continuing current procedures (L.C.1.2). 2. No LE program on measurement system and on receipts, shipments, dis, cards and MUF (L.C.3.0). . 3. Not accounted for all internal transfer documents nor docucented all internaf transf ers (L.C.S.2). 4. Stored material outside in an area not separately fenced (73.32(c) i 5. No records designating' authorized individuals (73.41(a)). s % fje c4 Le refe 6./,,,f e,L J, m. 9 l i a g c.. ...__._____.....f._..

m Meterfal Control and Physical Protectfon (U)_ ~ Dates of Inspection: 1/16-18/73 4 Report No.: 070-925/73-01 (Physical Protection) Violations: None ? Dates of Inspection: 2/21-23 and 3/12-16/73 Report No.: 070-925/73-03 (Material control) violations: 1. No independent percent element measurement of UF-6 receipts (L.C.3.1). 2. Measurement review not complete (L.C.3.3). 3. Not all 741's on receipts being dispatched on time (70.54). ' Dates of Inspection: 11/13-16/73 Report No.: 070-925/73-07 (Material Control) g Violations: No independent percent element measurement of UF-6 rec.eipts 1. (L.C.3.1). , 2. Not all 741'd on receipts dispatched on time (70.54). Dates of Inspection: 11/25-27/74 Report No.: 070-925/74-02 (material Control) Violations: j 1. No material control plan submitted to Licensing (70.51(g)). 2 2. Measurement review not complete (L.C.3.3). Dates of Inspection: 9/22-26/74 Report No.: 070-925/74-04 (Material Control) Violations s j 1. Standards data not being accumulated (L.C.3.2.3). t .l 2. Frequency of replicate sampling of process materials not. . t. complete (L.C.3.2.2). i. , 3. all biases not being determined (L.C.3.3) 4. Material accounting data not adjusted for biases (L.C.3.4). 5. LE's do not include systematic errors (L.C.3.8). } l ~. i gf f $n l l p mc' can be:" i _)

• m'

~ t- } J* g j,- 3 i t. 1 i

_m l..

__._-.t. l

INCLOSiJRE Kerr-McGee Nuclear Corporation p) License No. SNM-1174 e The following apparent violation of AEC requirements is considered to be of Category II severity: License Condition 3.2, Amendment No. MPP-1, License No. SNM-1174 h ents made to "The frequency and quality of t e measurem comply with the license conditions shall be controlle states: for the 30-day material balance period does not exceed one and one half (1.5) kilograms of plutonium." Contrary to the above, the LDMF quantity reported to the Region III, Office of the Directorate of Regulatory 0peracions for the material balance period ending December 5,1973, exceeded one and one half Further, the LDEF grantities that you have kilograms of plutonium. reported to us for th,e four preceding invent exceeded one and one half kilograins of plutazium. 2 TRmF (kts) Period 29f t 7/1/73 - 8/10/73 6. 8/11/73 - 9/11/73 9/15/73 1 10/10/7 6. 54 10/11/73 - 11/9/73 6.802 11/10/73 - 12/5/73 e Se e S O 4 ) f m ee e e e es ee e = = em ane se -e e- .m

e. U. 5. ATOMIC ENERGY COMMISSI0tt DIRECTORATE OF REGULATORY OPERATIONS REGION III ~ 30 Inspection Report No. 070-1193/73-08 "I.icensee: Kerr-McGee Corporation

• Kerr-McGee Building Oklahoma City, Oklahoma 73102

. l License Nc. SNM-ll74 'k Cimarron Facility Plutonium Plant Crescent, Oklahoma 73028 Priority: I Category: A(1) i 8 Typeofbicensee: Plutonium Fuel Fabricator k. Type of Inspection: Special Nuclear Materials. Announced Observation of Plutonium Inventory j t' l. Dates of Inspection: December.3-7, 1973 Dates of Previous Inspection: October 19, 25, 26 and November 2, 1973 2.!/J!N Imad Inspector: C. C. Peck @ ate) I d None ,Other Accompanying Personnel: /.3!7[ Revieve By: id ief (Date) terials and Plant Protection Branch

Attachment:

~' Findings (Exempt from Disclosure) l I p-el%;h,',) g g j'9dj t tem t. 19 fgD$O@b DJ a v w.e 3 7 ,g

j

SUMMARY

OF FINDINGS Enforcement Action The following item of noncompliance was identified: The licensee's limit of error of material unaccounced for (L or the 30-day material balance period ending December 5, 1973, wa .802

ilograms, and the LEMUF quantities for the four previous material balance periods, were as follows:

j Period Ending LEMUF (kgs) b-Im k*'b ', 8/10/73 639 y g 9/11/73

6. 27 10/10/73

.3 7 ~ 11/9/73-6.54 License Condition 3.2 states: "The frequ ncy and quality of the measurements made to comply with the license conditions shall be controlled so that the limit of error associated with the material unaccounted for (LDIUF) for the 30-day material balance period does not exceed one and one half (1.5) kilogramr of plutonium." Licensee Acticn on Previousiv Identified Enforcement Items Items of noncompliance identified in the previous inspection (February 21-23 and March 12-16, 1973) were not within the scope of this inspection. The status of these ite=s will be investigated in a future inspection. Unusual Occurrences: None Other Significant Findings: None Management Interview A closcout meeting was held December 7, :1973, by C. C. Peck with R. A. Janka, Manager of Administration and Accountability and G. R. Mallett, Safeguards The discussion centered on the physical plutonium inventory Specialist. The conducted by the licensee December 3-6 and witnessed by the inspector. 8 ee e e., eme- .o. e m L-----.. _, oe -

licensee representatives were advised that in the opinion of the inspector the observed portions of inventory had been conducted in accordance with the licensee's established inventory procedures. Instances were discussed in which minor violations of the procedures had occurred. It was concluded that these were occasioned by inadequate understanding of the inventory procedures on the part of individuals involved in conducting the inventory and could be corrected in the future by continued emphasis on personnel training. l l I l l i ? { ~ 0 h f '3 - g 4 6 g

REPORT DETAILS Persons Contacted R. A. Janka, Manager of Administration and Accountability W. J. Shelley, Director, Regulation and Control G. R. Mallett, Saf eguards Specialist J. V. Marler, Plutonium Plant Superintendent F. Welch, Accountability Analyst - Plutonium [ T. Clanton, Auditor - Kerr-McGee Corporation \\ / P. Carst, Safeguards Analyst A D. Oswald, Safeguards Clerk C. Gender, Safeguards Clerk i J. V. Smith, Process Supervisor, Plutonium l R. Borgnier, Process Supervisor, Plutonium R. J. Adkisson, Contract Relations Representative R. Marshall, Manager - Laboratory S, cope of Inspection The inspection was an observation of a plutonium physical inventory conducted i by the licensee from December 3-6, 1973. Such inventories are required at intervals not exceeding thirty days by License Condition 6.0 of the Materials and Plant Protection Amend =ent to License No. S2'-1174. The reasons for observing the particular inventory of December 3-6 were: (1) the licensee i had been unable in previous inventories to comply with License Condition 3.2 which states that the limit of errc associated with the material unaccounted for (LDNF) for the 30-day inventory periods shall. not exceed 1.5' kilograms of plutonium, and (2) the material unaccounted for (MUF) quantity calculated from material balance for the previous inventory conducted November 9 r va 6.0 gs; although within the LDMF of 6.5 kgs, this absolute value is unusua ly high. Hence the circumstances called for'an inspection and appraisal of the licensee's inventory performance. The process of conducting the inventory which consists generally of counting, weighing, sampling, and listing all plutonium-containing items was observed from December 3 through 6. Some of the preparations of the material balance areas were also observed, although in some cases preparations had been made prior to the inspection. For any physical Inventcry it is necessary to use previously obtained measurement data for all items that are known to have been in an unchanged condition since the previous inventory, ard to perform current measurements only on new items or those that may have changed during the inspection period. An attempt to perform current measurements on all ~ r

Thus, inventory items, normally nu= bering over 2000, would be impossible.

it is necessary in any inspection to accept many measurements that have been made at an earlier date. Results of the inventory, that is, the construction of the material balance and calculation of the MUF and LEMUF quantities were not determined until j several days after the end of the actual inventory process and were not witnessed as part of the inspection. C'ompliance with license conditions other than 6.0, Inventory,' was inspected only to the extent that certain other conditions are related to inventories and could be evaluated. The following sections, whose titles correspond to license conditions, present the details of the inspection.. Facility Operation (License Condition 2.0) As required by the license condition, the plutonium facility uses the material in controlling SNM. Seven MBA's have been balance area OIBA) concept established, each of which is the responsibility of an M3A custodian, in most Custodians in some cases have responsi-instances the supervisor of the area. Movenent of SNM between MBA's is controlled, bility for more than one MBA. a'nd the various poine.s at which losses can occur are identified as required by the license condition. MBA's and their custodians are listed below: HBA Number Custodian 11 Chem Process Supervisor Scrap 11 lab Manager I Laboratory Ceramic 13 Chem Process Supervisor Records Clerk 12 Vault ~ Pellet Manufacture 21 Fabrication Supervisor Pellet Storage, East 22 Fabrication Supervisor Pellet Storage, West 23 Fa,brication Supervisor Fabrication Supervisor Pabrication 31 O . []E W bL N &$ In ik; d'n wk) M se em

Measurements and Statistical Controls (Lic'ense Condition 3.0) Sufficient information was acquired during the inspection to confirm the fact that the licensee is making all the measurements required by 3.1 to determine the quantities of plutonium and the limits of error associated with receipts, shipments, discards, and inventories. License Condition 3.2 requires the licensee to control the frequency and quality of his measurements so that the limit of error associated with the material unaccounted for (LEMUF) for each 30-day material balance period does not exceed 1.5 kilograms of plutonium. t The frequency of measurements is considered adeqaate. Each bottle of plutonium nitrate received and each lot of product pellets shipped is measured by weighing and assay of samples, liquid and solid discards are measured by radioassay and neutron counting respectively, and inventory items are measured by an appropriate method at the time of inventory or prior to the inventory. Quality of the measurements was not examined in detail during this inspection. Previous inspections have disclosed scale and balance accuracy to be acceptable end it has been observed that i I sufficient mixing and blending are perf ormed to ensure representative samples for analysis. The current inspection disclosed no evidence of One instance inadequacies in these aspects of the measurement system. of inaccurate weighing was found by the licensee during the inspection when weighing errors of more than a hundred grams each were discovered while reweighing four cans of certified pellets containing an average of 2100 grams each. The corrected weights increased the plutonium inventory l by 100 grams. The errors in the original weighings were attributed to insuf ficient understanding of the weighing procedures, specifically incorrect use of tare weights. Although these errors resulted in a change in the plutonium inventory, it was not of such a magnitude that weighing errors could be considered responsible for the large MUF quantities that the licensee has experienced. No other weighing errors of consequence were detected during the inventcry. 1.aboratory analyses of samples are the component of the measurement system that inherently produces the largest limits of error. The licensee uses amperometric titration as his basic method of analysis for plutonium nitrate solutions received, for product pellets, and for some intermediate materials with high plutonium concentrations and good purity. The method is widely Corrections must used in industry for such materials and has good accuracy. be made for the presence of chromium and manganese in the samples, and the licensee does make these corrections. A secondary assay method employed is radioassay, or alpha counting, an acceptable method when samples are impure 6 e.. A N., *4 _**= up sup **

8 l The accuracy and/or dilute and do not represent a large amount of plutonium. of the method is not high; claims of 10% to 20% accuracy expressed as the This level of coefficient of variation of a single analysis are common. acceracy is acceptable, provided the samples analyzed do not represent major portions of the material balance. To ' test the quality of licensee's analytical measurements, three solution samples were taken during the inspection for analysis by Los Alamos The samples chosen were froin scrap area wall tanks ( Scientific Laboratory. containing several kilograms of plutonium. Two samples were solvent extrac-l solvent extraction product. Scrap area samples were tion feed, the other selected because this area has the largest variability of any of the MBA's l and the wall tanks in the area contain large amounts of plutonium. The AEC samples were taken at the same time the licensee took replicate samples for i his own analyses for inventory purposes. The licensee stated during the inspection that the product sample would probably be analyzed by amperometric titration, and the feed samples by radioassay, because the large impurity content would make the more accurate-l amperometric method unreliable. Instead all thr,ee samples were analyzed by radioassay. g Arrangements were made with Los Alamos to analyze the AEC samples by isotopic dilution, with additional verification by amparometric analysis and/or i. j radioassay. Results of the AEC analyses were received February 5, 1974. A comparison of AEC and licensee results is tabulated below: Sample Wt Solution (g) Cone (g/gl PU (g) L AEC L AEC N I 6,7,8,9; Product 43Q4 0 0. 5 O. 06 19 90 89 ~ ~ 16,18,20; Feed 296 0 0. L926 0.0 405 5 0 2 W lt,17,19; Feed 3 15 .0j905 0.0 0 2 g 1 385 7965} _, Dif ference: 421 grams The licensee stated that the limit of error for each sample was 0.0034 g/g. Application of this limit of each of the three solution weights produces limits of 1463g, 1008g, and 1041g. These limits produce a combined limit .a "S ff % be refeMeY in, k &,,(h v ~ ' ~ ~ v.

of 2059g, which exceeds the one and a half kilogram limit of error imposed on the entire material balance 91thout regard to any other inventory measure-ments made. Agreement between licensee and AEC analyses ranged from excellent to very Collectively the difference of 3421 grams represented by the poor. differences between AEC and licensee resbits exceeds reasonable limits of error that could be established. The licensee has agreed to analyze replicate samples that were taken during the inspection in an effort to resolve the difference. If it can eventually be concluded that AEC analyses are correct, the licensee could be considered to be in violation of license ,{ condition 3.2 on the basis of the poor quality of his measurements. i After the physical inventory was completed, the plutonium MUF and limits of error associated with the MUF were completed promptly as required by License Condition 3.5. The period between conclusion of the inventory and completion of the material balance necessary to determine the MUF was about five days. This is the normal amount of time required to obtain analytical results on items that were sampled fpr inventory, calculate plutonium quantities for each item, and establish limits of error for each item. Calculations are d accomplished manually and by computer, the manual calculations being con-sidered necessary because the computer program has been in use only a short time and is considered not yet reliable. kesults of the inventory are presented in detail in the section Inventory. Storage and Internal Transfers (License Conditice 5.0) l The Safeguards group has continuous knowledge of all SNM transfers between MBA's through the use of internal transfer forms (IT's). The group issues serially numbered IT's to the various MBA custodians who are required to use them for each material transfer. Type and quantity of material trans-ferred and initials of the custodians of the areas involved are required information to complete the forms. The completed forms are used by the Safeguards group to prepare the material balance for the inventory period armnd each MBA. It was noted that the licensee *. ras able during the observed inventory tc account for all internal transfer forms that had been used during the inventory period. There were over two thousand of these forms to account for. Inventory (License Condition 6.0) As required by License Condition 6.1, the licensee since July 1, 1973, has been closing material balances around the facility by material balance areas f je % be rel ease) ,f k

I i 5 .I at intervals not exceeding thirty days. 6n the one occasion in which the interval exceeded thirty days, a request for an extension was approved by Licensing. Limits of error have been calculated for all components of these material balances, that is, receipts, shipments, and inventories as required, and these limits have been used to calculate the limit of error of the material unaccounted for (LEMUF). In none of the five t:aterial balance periods to date has the licensee's calculated LEFSF been within the 1.5 kilogram limit imposed by License Condition 3.2. The variability of the inventory component of the material balance has been too large to permit attainment of this limit. Sinc'e the licensee has an " inventory - 1 dominated" system, since the inventory is of a much larger magnitude than I the receipt or shipment components of the caterial balance, there is small probability that the 1.5 kilogram limit can be attained. The measurement methods for in-process materials do not have the precisions that would be i required to achieve a 1.5 kg LEMUF. In addition to receipts, shipments, and measurable materials in inventory, the licensee has a large quantity of unmeasurable plutonium in his system. This " holdup" is required to.be a fixed quantity by. License Condition 6.2 and accordingly has been " set at 18.7 kilograms. A fixed limit of error 1,s i also required to be associated with this holdup. The li=it of error that j has been established is about five kgs. This quantity by itself is much j - larger than the 1.5 kg limit of License Condition 3.2. Combining this LE associated with the unmeasurable materials with the LE of the measurables, I the overall LE of material unaccounted for has consistently exceeded six kilograms. In the attach =ent to.this report, the licensee's material balances for all five inventory periods are summarized in tabular form. License Condition 6.3 sets forth requirements for inventory procedures. The licensee has such written procedures, approved by the responsible heads of the groups involved in the inventory. These are the facility manager, accountability canager, plutonium plant superintendent, and laboratory manager. The procedures meet the requirements of the license conditions and observations during the inspection disclosed that the inventory and inventory preparations were conducted in accordance with the procedures. l In the ceramic area (MBA 13) all scrap powder had been swept up and removed to the vault. The precipitation equipment had been rinsed. There was no evidence of any unmeasurable solutions in glovebox sumps. In the pellet manufacturing area (MBA 21) the equipment appeared clean and all scrap powder and contaminated waste had been removed to the vault. In the. pellet l storage areas (MBA's 22 and 23), all pellets were in storage containers and gloveboxes appeared clean. To aid in the preparation of the MBA's for g (Q Gy be yelnse-) s.-,k $h,.e }, M l

the inventory, a series of checksheets, one for each of the MBA's, are completed by the MBA custodians and approved by the Safeguards group. The checksb ets require the custodians to affirm that the plutonium in each area is in a locatiun and form amenable to inventory, tha't equipnent has been cleaned, that logs and other paperwork are up to date, and that trans-fer forms have all been accounted for. After all areas have been prepared in' accordance with the checksheets and have been approved by the Safeguards group, the inventory is conducted. MBA custodians in each area identify each inventory item observed by members of the safeguards group who prepare the inventory lists, one for each area. t Summary of Inspection Status [ Ihe tabulation below summarizes the status of the licensee with respect to each license condition and regulation at the conclusion of the inspection of December 3-7, 1973. Inspection (Note 1) Previous Present License Condition 3/73 12/73 Future I 1.0 Organization 1.1 OK Inspect-OK Routine Check 1.2 Unsatisfactory Inspect-OK Routine Check 1.3 OK Inspect-OK Routine Check 1.4 OK Inspect-OK Routine Check s 2.0 Operation 2.1 OK Inspect-OK Routine Check 2.2, OK Inspect-OK Routine Check 2.3 OK Inspect-OK-Routine Check 2.4 OK Inspect-OK Rcutine Check 2.5 OK Inspect-OK Routine Check 3.0 Heasurements and Statistical Controls Routine Check Inspect 3.1 OK 3.2 OK Noncompliance (Note 2) Inspect 3.3 Unsatisfactory Routine Check (Note 3) Inspect 3.4 Noncompliance (Note 4) Omitted Inspect 3.5 OK Inspect-OK Routine Check 3.6 NA (Note 5) (Note 6) Inspect 3.7 NA NA Inspect 3.8 NA NA NA 1 'A (byC & n be rdln.sttY in i.s eAh!kef -

.l Inspection (Note 1) cont. Previous Present License condition 3/73

• 12/73 Future 4.'O Shipping and. Receiving Omitted Inspect 4.1 OK 4.2 OK E

NA 5.0 Storage and Internal controls i 5.1 OK Inspect-OK Omit 5.2 OK Inspect-OK Routine Check 5.3 OK Inspect-OK Routine Check 6.0 Inventory 6.1 OK Inspect-OK Routine Check 6.2 NA Inspect-OK (Note 7) Inspect 6.3 OK Inspect-OK Routine Check 6.4 OK Inspect-OK Routine Check 6.5 OK Inspect-OK Inspect 6.6 NA NA NA-7.0 Records and Reports t 7.1 Noncompliance (Note 8) Routine Check-OK Inspect 7.2 OK Omitted-Inspect 7.3 OK Inspect-OK Routine Check 8.0 Hanagement of Materials Control System 8.1 Noncompliance (Note 9) Omitted Inspect 8.2 CK Omitted Inspect i 8.3 OK Omitted Routine Check i 9.0 Physical Protection 9.1 - 9.6 OK (1/73) Omitted Inspect Part 70 70.54 OK omitted Inspect _ 21._ l em 4e <chnd m k e&f. l pye 'n

(. ( Note 1. Definitions of terms used in table: "OK" or " Inspect-OK." Item was inspected and licensee found to be in compliance. " Routine check." A general investigation to determine compliance with no effort to collect detailed information or data. " Inspect." 'A co=plete investigation, consisting of examination of all data and procedures. " Unsatisfactory." Indicates that licensee was in' compliance, .but that quality of effort was less than desirable. "NA." Not applicable. Note 2. Licensee has consistently been unable to meet 1.5 'kg LDIUF limit. I Standardization and calibration data were in early phase of Note 3. development in 3/73. A general check 12/73 indicated that efforts were satisfactory. ( Note 4. No measurement review had been made as of 3/73. Ifeasurement i review must be made by 3/74 to avoid repeat item of noncompliance. l Note 5. No NUF or LDiUF data as of 3/73. Licensee was in process of determining holdup quantity. I Note 6. Licensee's notifications of corrective actions to reduce LD1UF considered insufficient during period prior to inspection. Licensee' response considered satisfactory in Decembe,r 1973. Note 7. LE for holdup varies slightly around 5 kgs Pu. Note 8. Material balance and plant records were not being reconciled ~ prior to 3/73. No review of the SNM control system uns made prior to 3/73. Note 9. ~ Review required prior to 3/74 to avoid repeat noncompliance item.

Attachment:

Plutonium Plant Inventory Summary g m pye en la re &.. :/,+,A, J n /, s j

M11dfla A A ALW11/tdQ@@Q, ' i, ,i ATTACHMENT I l PLUTONIUM PLANT INVENTORY

SUMMARY

i ~! INVENTORY DATE 8/10/73 9/11/73 10/10/73 11/9/73 12/5/73 NET FOR 5 PERIODS INVENTORY DATE (GRAMS) f 49 98804 97072 120694 140813 77449 BEGINNING INVENTORY RECEIPTS 1922 7 24478 39918 39114 122740

• SHIPMENTS 187 3864 49 13763 403 18266 ENDING INVENTORY 98804 072 120694 140813 186171 186171 HOLDUP 18700 18

~18700 / 18700 18700 18700 / (6648) (4238) i ~ (2319) (2125). 06 6036 MUF \\ x 1 LIMIT OF ERROR DATA (GRAMS)., i j BEGINNING INVENTORY 1618 714 324 2469 2453 1618 I RECEIPTS 43 0 197 272, 282 441 ' SHIPMENTS' 22 11 05 20 208 f l - . ENDING INVENTORY 714 324 2469 245 2825 2825 ) i LEMUF (EXCLUDING HOLDUP) 1769 784 2498 3497 52 3292 j LEMUF-(INCLUDING HOLD ) 6299 6127 6337 6542 6802 LE (HOLDUP O ) 4399 5094 3372 4612 6016 s 6016 l l

• SHIPMDrr INCLUDE MEASURED LOSSES f

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