ML20209D289
| ML20209D289 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 10/17/1974 |
| From: | Shelley W KERR-MCGEE NUCLEAR CORP. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20209D148 | List: |
| References | |
| FOIA-86-281 NUDOCS 8609090259 | |
| Download: ML20209D289 (8) | |
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$18 dm KERR-McGEE NUCLEAR CORPORATION EERR.McGEE CEMfER. OsLAMOMA CITY, OKLAMOMA 73125 h[
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Mr. James G. Keppler Regional Director U.S. Atomic Energy Commission Directorate of Regulatory Operations Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Please refer to your letter of September 26, covering the inspecti.on 6f our activities under L.icense fio. Stim-1174 In accordance with 10 CFR 2.201 on August 21 - 23, 1974..
We a response to the observed violation is attached.
assume that this response will be withheld from public disclosure in accordance with 10 CFR 2.790.
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Sin eg.rel yours',
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{L W. J. Sh' ell ey, <6i re ctor R gulation land Control
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PN ENCLOSURE
,.. e Nuclear Corporation s,.
SNM-1174 1
VIOLATIONS
,tewing are our comments and corrective actions the cited violations during the audit of our 3y
.g.n plant.
- ense Condition 3.5 - 10% Bias Correction
. modification of License Amendment MPP-1 to SNM-1174 been submitted to Mr. R. G. Page, Directorate of
.ensing, to provide a more adequate means of applying Th is dias correction as required by the license.
- gram will be in effect by Hovember 1,1974.
A copy
- his modification request is enclosed under Attach-e: II.
- ense Condition 6.3.- Tamper Safing
(
umper safing seal program will be initiat'ed by
(
< ember 1,1974.
A revision to the program as outlined
~
- ur Material Control Plan has been submitted to l
- 1. Page, Directorate of Licensing, to provide a more l
3nable approach to the application of'the tamper 1g seals.
This.revis' ion does not constitute a lower l
- "ee of security.
A copy of this modification is
' ssed under Attachment I.
95e Condition 6.4.2 - Physical Invent'ory Measurements
"*ral attempts have been made to " measure all plutonium i n ve n to ry. "
As outlined in our
, ' 97 a physi cal Plan, a system was proposed to measure
' tal Control the various pipelines in the wet process
' 'aterial in As outlined in our Progress Report of September 30,
.'. this technique d'id not show a significant increase a%ured holdup as expected.
As a consequence, Ke rr-w has instituted a program to measure this material s'sh the use of Hon-Destructive Analysis.
This program tarted during our September Inventory and has been
'i' led to the fullest extent possible during the re-ntory in October,1974.
It is our current plan to 0
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En cl os ure t
continue to expand and develop this technique of measure-ment in order to measure as complete as possible all material within the plutonium plant.
It. is estimated that it.will require two or more periods to establish calibration and pr~ecision of the methods and equipment employed.
As the precision of.the method develops, the inventory reports and AEC 741 reports will reflect these measurements, and include the. plutonium in a
holdup as a measured item.
- 4. ' Li cense Condi tion 3.3.2 - -Standards Program As you had indicated in your letter of September 26, 1974, a standards program had been implemented.
Data has been accumulated in this program and will be analyzed and applied for limit of errur calculations.
The implementation of the program for the radioassay standards will be complete by December 1,1974.
PROGRAM WEAKNESSES In reference to the. program weakness which you described con-cerning the use of the gamma auto-radiography system as. a safe-guard tool for a nondestructive over-check, our procedure will be modified to include this requirement.
This procedure will-be modified by November 15, 1974.
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ATTACill1ENT I Kerr-McGee Nuclear Corporation requests that the !!aterial Control Plan for the Cimarron Plutonium Plant be modified as described below:
Replace Section 1. Tamper Safing, with the following:
"1.
A program to insure that material maintained in stprsge is not tampered with aft'er measurement and wfl1 be employed within the plutonium plant.
All packages containing in excess of 10 grams of plutonium will be gross weighed, including bag enclosure and the weights recorded by the Safeguards Clerk upon receipt in the vault (MBA-12).
Packages will be reweighed when leaving the' vault to another
' material balance area to insure that no change has occurred.
Check weights that do not measure the initial weight recorded above will result in the package being retained in the vault and an immedia'te notification to the clerk's superior for investigation and resolution."
Tamper safing labels are applied to packages containing plutionium materials in accordance.with 10 CFR 70 as follows:
Portable transfer carts are tamper safed for inven-a.
tory at the time of original packaging and witnessed by a ' safeguards clerk.
b.
Pellet storage wells in ioom 123, glovebox 18, are j
tamper safed for inventory purposes.
A weight verification of each can of pellets is witnessed I
by a safeguards clerk during the loading of the M
~
O ior to inventory.
.orage tanks loaded with sampled, plutonium
. solution will be tamper safed by applying
)
to the valve handle of the cell upon com-l
, of blending and witnessed by the safeguards o
- er welding will not be tamper safed since e in that condition as welded.
- containers of plutonium nitrate prior to
- will not be tamper safed since they are
.i:h the shipper's seal.
..;te m$teriaIs after measurement for disp ~osal ar safed by sealing the drum in which it is
- ' the Material Accounting ' Plan will be un-
- nstitute a lower degree of' security during
- rovide significantly greater control by
'~f out of the vault storage in the presence l
' dill insure that the material remains un-
~ ige period.
l b.
' is under surveillance of the vault custo-
' :t is available for transfer.
When the
the vault, materials are protected by
- th a combination lock and an intrusion 9
c
' etion detector on the interior.
These
redundant precautions insure no unauthorized entry during the custodian absence from the -vault.
Check weighing procedures will provide assurance to the re.ceiving MBA that material received contains the quantity stated.
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v;tlMENT II bnendment MPP-1 to SNH-ll74 be
..pment acgounting. data shall
..rement bias as determined when the effect of such, the total material repre-
. ements."
.2d upon the following:
10% of the
.r:-term systematic bias would amount
...u that the assay must be reported
,~r significant fi.gures than the
- trt
- technology, and 23 plutonium metal standard
. Is program is. based.
- e typical CPF material balance of approximately 100 gms. (.03%)
ment of 1 gm. to the MUF.
When
'f this magn'itude on control
ind the techniques ~and procedures
'inated, prior to performing
ose of SNM transfer.
It seems
'itory operation is in effect
' laboratory with a large random
'er would not need to apply such
rement works to the disadvantage
- / *ffort.
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-a.
'The alternate test proposed appears to meet the requirement of the' AEC while restricting it only to those cases where material balances are measurably distorted by systematic error.
There may be other alternate methods more appropriate. to the intent of the license requi rement.'
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