ML20207N508

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Trip Rept of 731102 Site Visit Re Licensee Consistent Inability to Meet Lemuf Limits Imposed by License SNM-1174. Findings & Recommendations Discussed
ML20207N508
Person / Time
Site: 07001193
Issue date: 12/04/1973
From: Peck C
US ATOMIC ENERGY COMMISSION (AEC)
To: Hind J
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20207N448 List:
References
FOIA-86-281 NUDOCS 8701140260
Download: ML20207N508 (6)


Text

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UNI D STATES k

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[.f ATOMIC ENERGY COMMISSION

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yg DIRECTORATE OF REGULATORY OPERATIONS

%Fas o' "y REG lCN lll 799 ROOSEVELT ROAD ggggpgogg GLEN ELLYN. ILLINOIS 60137 012)85s-2660

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. Decem.ber 4, 1973 J. A. Iliud, Chief Hatorials and Plant Protection Branch TRIF REPORT - KERR !!cCEE CORPORATIO.1, CIMAPJtott PLUIONIUM FACILITT.

CRISCENI, OKLNIOMA On Novonber 2,1973. I visited t.he Kerr-1:cceo F utoniura plant to l

investinate the rossons for the licensee's consistant inability to meet the LUiUF linito immosed by the license conditions of S!:M-1174, and to discuss other related tatters.

Findings and recomanifations are presented in this actso. A report containinr. vore dotsil ca the licenseo's inventory and statistical control procedures vill be prepared later.

'Tindings i

1.

The licmsee has developed notorial balances based ou measurencnts l

(physical inventorics) in the last three inventory periods that have resulted in the following in.T and LE;fUF totals.

l Date IMF (Limit LEJF)

LCUF (Li nit 1.5 kas)_

l 8/10

-2.319 kas.

6.3 kcs.

9/11

-2.125 kas.

6.1 kgs.

10/10 0.006 kas.

10.3 kgs.

The 10.3 kg LETF, the statistic that is furthent out-of-line, was discovered to be in error. The correct LMF in 6.3 hts, in linu with data for ene previous tionths. Tho error was diacovered while I was calculatinn from the licenace's originsi data in an effor to understand ti20 statistics.

R. A. Jenksh'ansner Administration and Accountability. an Ifallet Safeguard SpecLilist, are pessiaistic about the possibility of nceting the LC;u7 requirement in the future. They would not state positively that they could not, and at their levels-probably do not have the authority to do so.

I rocaived the 1:apression that they could preifer 8701140260 870109 PDR FOIA CANTREL86-281 PDR l'

to continue on the current basis and that eventually the data vill provo cunclusively vbother they can or cannot ncet' the linits.

They believe that early data, taken prior to Juna vore not ro11oble, principally because early inventories vera taken under conditions that were not controlled as voll as at prescot.

Another reason for their anticipating that futura data vill be reliable enough to be conclusive is that the process is now closer to an equilibriun. Until now the plutonium inventory hao been increasing; since almost no product has como out of tho systen. The licensee was in the process of v.aktur: the first sir:nificant product shipacnt at the time of the visit. This propress 1.as unde possibla the r.ovenant of a largo inventory out of the scrap area, the area with the largest ir.ventory uncertainty and holdup. I.icenace representatives hopod that this cont;cstod condition vould not ba repeated and regarded at as an unusual condition, althou7.h they were not prepared to state positively that tho scrap area vould not again becomo congested because of the uncertainties of the procens.

l The IN quantities that resulted from the three inventories were also discussed. The fact that the two inrr,er !%F's are negative (neaning that core plutonium was accounted for than was expoeted) is an indication that the licensea's selection of 10.7 krs as the cou'-

staat value for in-process holdup car have been a kilos'ra:2 or two I

high. The licenaae, prior to July 1,1973, was pornitted to assumo that the 2M in the caterial balanco equat' ion was zero in order that An of he night be able to assir.n some constant valua to holdup.

July 1, four inventories had bacu perfor: sed arid four natorial bolaucas developed assi::nia;; coro to the PJF componaut of the matorial balance equation. The holdup quantities calcitlated from these four balances were 11.3 k s,12.6 kes,15.2 kr.o, and 13.7 kgs in that order. These quantities vero too variable to par:2it colection of a constant holdup with any confidence, but as requir sd by the licenso conditions, the licenses decided on a ntuaber at the official The choice was id.7 k;s. The licenson contended that the holdup.

availsblo data were insuf ficient and did not represant normst operat-ing conditions, sinco during the period in vMch they pctnitted to assune zero la!? in order to escoblish constant holdup, the in-process plutonium was increasing and had not ru.ched a saturation or equilibrium point. The liciassee voald have proferrod to continue to assuno soro IMF for severni ooro r.ouths, af ter v'aich he belioved a constant holdup could be assigned with more confidence.

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3 In addition to the satablislzant of a fixed valus for holdup, the

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license conditions also requira that a fixed valos to asni.,ned to e

In the three material tbs licit of error of the holdup by July 1.

balances thus for, the 11ait of error for the holdup hsa been variable, and thcoretically will continue to be variniile in the The magnitude system of calculations being used *oy.the licensea.

of this holdup L2 has in each of the three instances boon large enough by itself to exceed the 1.5 kg limit on LCWF.

l Whether a fixed holdup can have a variable lisit of error is debatabic, but nevertheless the failure of the licensee to establish a fixed LE on the holuup is a violation of tha license conditions Tho licensac represcutati w s stated that vill have to be resolved.

that they had overlooked tha requirst for a fiand LI on thu i

They could establish a fixed LE of 4.3 kp.s. the value holdup.

correspondia; to the fixed holdup of 10.7 kg4 established July 1 Giace later La's oa the holdu:e have and recalculate overall L.:'s.

been loss than 4.3 kus, and have not boaa very ' variable, thy were told to continua their present practico, but that they would be Iha a: cts i:.:; ortant part asked to fix a value in the near futura.

of this pro'oleis is tha reduction of the uacultudo of the LCC!?

itself.

fhe licensee has developed detailed invcatory procedures that 2.

proscribe tha preparations to v.aha the plutosiirs ia cach inventory The e:cchanics area as atsenable to accurata inventory us possibic.

  • hese proecdures were of performin.~. tho invsntory are also covered.first develop a

There has apparc=tly been seen difficulty interpret the situation.

in r.cating tou acceptance of the production eupartuent and perhaps the laboratory, because of the belief that ths inver.tery interfered inordinately with prodi/ctica. The procedures. accenst modiflod.

f were approved by all departuents ad plant =acadeccat in late October and are expected to produce improvad re.aults.

l Recent reorganization has resulted in surc cabasis en :::ascureents, Iha 3.fccuard I;ccialist now 3.

inventorics, ano statistical controls.

Their vork is has four full-tica croloyees who report to him.

concerned with inventories, caterici valancas. and statisticci centrois (livits of error on analytical methods, duaAin$, scales and bal.nce Tha group also is respouvible for uraniau p2sr.t ccasure::.ccts, but frior to the re-plutoniuu is the principle concern oc present.organizstion but obtained clerical help as needed.

S

4" Flutonitan material balance and statistical control data are now l

being dovaloped by an off-site computer in the tuahoca City office.

l It was stated that the cocputer is I

There is a terminni on-sico.

handling matcrial balance data well, but is not relishle on Because of computer uncertaintics all d.sta are statistical data.

still being calculated manually to check the computer.

Discussions were bold with the !fana er, Mainfstration and q

Accountability, coaccruing the lack of specific information being 4.

provided to Region III on EP's and LOWY's that exccad th'eir limits.

In each instance the licensee is required to provide reccons for the Tha excessive quantity and the correctivo action taken or planacd.

licensee has been providing briof rossons that have not alvnys been 111uvinating, and has not provided any correctiro action information j

at all. 'The reason for the large LIJ-WF given f a tho licensco's report on the insterial Lahnce taken in October was discussed at The reason stated in the reportwe that "cany solutions which were (previously) covariant -.~have been processed."

sono length.

i Af ter discussion, it was concluded that a more understandable renon would have been, "There vera r.any solutions in the scrap area with During prior.itventory r.any of there largo irherent li:aits of error. solutions wore covariant, being present In the Inventories, so enat they did not contribute to the Tl.i:iUF.

prescat inventory period there was covement of many of thess solutio Tho con.~ostion in the scrap aros bss now been causing a lar;;u !.CTJP.

reduced so that the effect of the inr;;n LCIUP af the scrap eroa should The licencea stated that sitnough he

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be 1cas in futura inventories.

regarded the scrap area congcction ao an abno l

the scrap area invectory would be the correctise action to be taken, because ha did not have control over futura peduction requirenents.

This is a specific exsmpla of an instance in Wich production require-souts are inimicable with good inventory requicements.

In the discussion of corrective actions it was pointed out that the increased nanpower being davoted to inventorixs. the develop:2ent computer prograns, and the pro;;ress in obtainta approved invnnto might have been iteca that could be considorcF r and caterial balances which vore never reportal to K0 III.

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,.5-1 Reco mendations Although the three lid? quantities calculated to date tend to indicate l

that the 13.7 krs. holdup estimate ray be too high, the data are insufficicat to justify any chances at present. Quantities have been l

1 both positivo and negative. chich is encoura:Inc..

Ideally. MLT should 1

of course be =ero, the next best situation being one in which !!d7's are positive and net.stive in about equal nu:ber and tend town. d 4 cunulative zero. Th e licecscs's data are not tencing tovasd soro, i

probably because of a biaced holdup cocctant.

At present there is no j

reason to suoi ect loso or diversica of pittonium. After a six e nths j

period the licensee =* +8araemina cumulativa 1:CF cod at CNt tint 3

data r.ay be conclusive enough to justify a change in the constant holdup.

i 4

The LDmF is unlikely to be reducible to the 1.5 kr.c required by the a

licence conditions.

Inproved inventory and ecasurement procedures may reduce the error acccciated with neasurabia 2:ateriala to so.to-

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thing Icss than.the ~avorage of 1.7 k;s that bas been stecined in the three inventories conducted.

The larger portion of the LCWF 9

which is assceinted with the 18.7 heldup does not appear to be reducible to the extsat that overall LCIF would be reduced from L:

the present 6 kgs to 1.5 k2 The post recent Lt of the holdup was t

3.9 kgs.

3 k

One solution to the L:1"JP problam would be to perforte s flushout of

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the system fc11oveJ by an inventory. The flush would reduce the (j

holdup and its limit of error to :cini=un cecun'ts. This v.cched of P

inventory is not required by the licct.cc conditions entil the ti conclusion of ths IT?r proart.a.

Cuch a procedure venti be dio-ruptive to production, requiro scversi VM.n. cud perh:ps vuuld et l

not even to fessiMa until met of the 120 kilo:;r.u.s nov in the l

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syste:. Lava toen rec.oved at the product end.

At'the conclusion of s; -

the flushout inventory, the return to normni operations vould pro-

-d-duce the ss.e large boldup uncertainty opin, !Lun a flushout and 4

inventory sould be only a one-ti:c.c colutica to the probic= vhich l

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could not be ropcated on a routiac basio.

f Another approach which dt,ht bn more pr'uctienble then a fluuhout I

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inventory nir,ht be to occablich a nunir.un quoutity for in-procces 2

plutonius of 50 kgs er 100 kcs. Presently the ntuintity to about 120 kas nad thin is expected to increaan to r.oro than 200 kas.

Uhether the process could be operated successfully and whether t

contract oblit,ations could be tac with cuch a licitatica are not i

known. It dous seen likely, howevor,' tlat ruch a reduced.

inventory would sake fer unre accurato inventories with staaller limits of error.

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4 An increase in the trM.'F limit from 1.5 kgs to so:ee limit that the liccacee ceuld feasibly rect does not scam justifiable at this tino becausa date. are linitud. Althutsch it is not expected that the licecaco vill be chio to L prove the situatiota sirmificantly, he should coct!nue to try to achieve the 1.5 linit smtil the end of the firnt six t-entim pericd.- It' m y then tre advisable to recornize the futility of ti,ht LE.'"JF constraiuta and place safe--

giurdo c.snurance on rentonchly Icv valuns of abselute I W 's and geod physice.1 protection.

i C. C. Peck, Cher_ tat Hatorials and Plant Protection Braveh ces FSrM,rh MIPPD,30 l

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