ML20215F121
| ML20215F121 | |
| Person / Time | |
|---|---|
| Site: | 07000925, 07001193 |
| Issue date: | 02/19/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215F104 | List:
|
| References | |
| FOIA-86-576 70-0925-81-01-0, 70-1193-81-01, 70-1193-81-1, 70-925-81-1, NUDOCS 8612230271 | |
| Download: ML20215F121 (10) | |
Text
{{#Wiki_filter:faammmu-manummum ( DETAILS 1. Persons Contacted
- A. W. Norwood, Standby Plant Manager
- R.
Fine, Health and Safety Supervisors
- M.
Hodo, Administration and Accountability Clerk
- V.
Richards, Decontamination Supervisor and Custodian
- J.
L. Kegin, Maintenance and Utilities Supervisor
- R. Borgmier, Decontamination Supervisor
- Denotes presence at exit interview.
2. Licensee Actions on Previous Inspection Findings There were no items of noncompliance noted on the previous inspection report (Report No. 80-04). 3. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on January 29, 1981. The inspectors summarized the reviews conducted, scope and findings of the inspection in-cluding the one noncompliance under License No. SNM-928 (uranium) and three noncompliances under License No. SNM-1174 (plutonium). The inspectors made the following suggestions: 1. That tamper-safe seals and internal transfer forms (all were accounted for) be logged when issued for use. 2. That initials and date be recorded when tuo people attest to and witness the contents of a container. In some instance for consecutive entries an arrow was used rather than initials and date for line entries. The inspector remarked that one of the items, of noncompliance cited was for not measuring at least two plutonium standards during the week NDA measurements were made on plutonium waste items removed from the solvent extraction equipment in Glovebox 27 A. This License Condition 4.2, was one of three license conditions added for better measurement control by the Material Control and Accounting Licensing Branch of the Division of Safeguards, NRC Headquarters in a letter dated September 22, 1980. The inspector also recommended that closer supervision by the licensee plant management be made to assure all required aspects of the plutonium measurement control program are being followed. l ( In his review of NDA measurements for uranium waste, the inspector i noted that the calibration curve used should be updated without j further delay. A wider range of uranium standards should be included S-ra W -'o Cc.py d' of __1/_ ce; ie. l Q i: ". :n ' d.O.'" ~ !~' 8612230271 861219
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to plot more points on the curve. Also more than. End ' uranium NDA standard should be run when NDA measurements are made' for uranium vastes. A review of the quantities currently being measured in-cludes amounts up to 12 grams t-235. Standards up to or exceeding this amount should be routinely run from now on. Licensee representatives did not verbalize any coments on these suggestions, either positive or negative. 4. Facility Organization (85202 B) No items of noncompliance noted. The inspection results were attained through discussions with licensee management and review of uranium and plutonium procedures. There have been no major changes in the site organization as it pertains to the Standby Operation. On the corporate level, the Director, Regulation and Control, to whom the Standby Operations Manager reported was promoted effective October 1, 1980 to Vice President, Nuclear Licensing and Regula-tion. In addition, to designated custodians for the plutonium plant, three positions primarily have responsibility for material control and accountability. These positions are Standby Operations Manager, Health and Safety Supervisor and Administration and Accountability Clerk. These position responsibilities for the Nuclear Materials Management Unit are in practice as described in Kerr McGee Procedure KM-NC-15-7. The Administrative and Accountability Clerk is responsible for Shh records, Sh3 reporting and shipping and receiving. While this is not ideal for separation of function purposes, the facility is not proc-essing, on a standby status, is not receiving Sh3 and the only external shipment activity is offsite burial shipments. Since the primary operation as it pertains to Sh3 is decontamination and plant cleanup the dual functions of the Administrative and Accountability Clerk were considered acceptable. Continuous decontamination of equipment, instruments, desks, chairs, lockers, etc., of the uranium plant is in progress. In addition, the uranium plant front office area, front laboratory area, warehouse building and n:en and women change rooms have been decontaminated for the benefit of employees engaged in the Kerr McGee coal liquifaction project. Not very much of the previously used high enriched uranium line at the uranium plant has been cleaned. It is expected as this program continues that some high enriched uranium will be recovered. Unless some license changes are requested and granted the licensee would be in constant noncompliance because the present,Sh3-928 license authorizes possession of enriched uranium not to exceed 5% enrichment in the isotope U-235.
MC 5. Facility Operation (85204 B) No items of noncompliance were noted. The inspection results were attained through a walk-through of plant areas, review and observa-tion of new uranium processing method for waste cleanup solutions, review and observation of plutonium plant operations, review of internal procedures and interviews with key operating personnel. Uranium Plant Dismantling and decontamination of process equipment is continuing at a somewhat erratic pace due to occasional other priority jobs in both this plant and the plutonium plant. Areas and equipment still not dismantled and cleaned include the." Big Shot" work hood, a series of gloveboxes which were used to make: high enrichedi (93%' U-235) buttons, drying ovens, and the process lines used for UAl whiJh c'ontains glove-boxes enclosing crushing and milling equipment and other process para-phernplia. All these areas included processing of enriched uranium to over 5% U-235. Any accountable amounts of SNM found here and verified by anafysis to contain uranium enriched to over [Si U-235 will result, again in the licensee being found in noncompliance with its authorized possession limits under SNM-928. The inspector discussed with the Standby Operations Manager the soon to be implemented ion exchange system. This process will be utilized to reduce the volume of the liquid waste solutions accumulated from decontamination and clean up operations of plant surfaces, piping and dismantled equipment. An anion exchange resin will be used to adsorb anionic complexes of uranium in Na C03
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" 9" 2 resulting from the ion exchange system will meet NRC release limits to unrestricted areas according to the license. Solids and solutions will be pretreated with Na.,C0 f r the ion exchange process. The system 3 includes four ion excliange columns which receive the filtrate from the decontaminated solution treatment tanks and extract the uranium from the filtrate. Uranium Accountability Procedure No. KM-NU-15-100 is being drafted l now by licensee plant management and will include a description of i sampling procedures, size of samples, frequency of sampling, and types of analyses which will be made to comply with accountability requirements. Suspended weigh scales will weigh one of two sets of four vertical, five inch diameter,(1.D.) tanks at a time. The limit of uranium concentratiprt will be: 60 grams, 'of uranium per liter of solution of less than 5% fnriched U-235 material. The new ion exchange system should' tie operational by February 15, 1981. 6. Plutonium Plant The inspector observed a test demonstration of the plasma are torch as performed in a glovebox in the uranium plant. A piece of Section 80 stainless steel pipe was cut, and the safety controls were activated l l i l 1
~ ( ( ~ b to test the capebility of the operation to shut itself off if oxygen limits are exceeded. All controls functioned as designed when the circuitry was properly installed. This plasma torch was moved to the top level of the solvent extraction glovebox in the plutonium plant later in the week prior to the completion of this inspection. This torch which will cut the piping into two feet sections in a nitrogen atmosphere (less than 3% oxygen) is being used to dismantle 17 steel tanks up to 32 feet in length in the solvent extraction glovebox system of the plutonium plant. All other equipment has already been removed, gamma counted for plutonium content, and stored in tamper-safe sealed 55 gallon drums in:R,oom 12,1, All drums stored irt Ioom 12j 'will have to be repackaged prior to shipment to a burial site. Polyvinyl inserts recently purchased and new drums will have to be used to comply with the latest federal revisions to acceptable containers for transporting plutonium wastes. Also the packaging requirements for containers to be stored at the licensed burial sites do not appear to coincide with the transporta-tion requirements for containers. This must be resolved between state and federal agencies before any shipments can be made by the licensee. 6. Measurement and Statistical Controls (85206 B) No items of noncompliance in the uranium plant. One item of non-compliance in the plutonium plant. The licensee failed to measure plutonium standards at a minimum of two per week during any week NDA measurements were made. The inspection results were attained through a review of the NDA method for measuring uranium, a review and demonstration of meas-uring plutonium standards for the NDA measurement system used in the plutonium plant, review of internal records and ledgers for both plants, and discussions with the Health and Safety Supervisor who has direct measurement responsibilities for NDA in both plants. Uranium Plant Since the previous inspection in June 1980, Report No. 70-925/80-04, a total, of'536 grams of U-235 have been measured by NDA. At this time M drums containing uranium wastes whose SNM contents were measured by NDA are in storage in the uranium plant. A log contain-ing measurement data, count rates, background counts, and data from NDA standards along with description of the item measured was re-viewed by the inspector. The ins,pector noted that a few items con-tained from seven to twelve grams of U-235. The standards made up ~ presently go up to 4.26 gramj t-235, therefore these higher results exceeded the currentiy available in house standards. The inspector recommended more standards be prepared from UO Pellets 2 or other material available with analytical data from prior analyses. Some pellets are being kept on the uranium inventory for this purpose, 4
(MC i.e., to be used with the proper matrix for NDA standards if required. In this context, the calibration curve should be updated using more points, up to a level of [0 or 15 grams U-235 to include the range of quantities anticipated in further NDA measurements. Uranium measurements on liquid waste solutions are still being made by the licensee's Sequoyah Plant. Isotopic analyses for percent U-235 are contracted out to Isotopic Analysis, Incorporated of Tulsa, Oklahoma. The operation of the ion exchange system for separating out uranium from inputted liquid and solid wastes will help eliminate large accumulation of waste containers during an inventory period and get measurement values in less time. Being a Groups V licensee with less than one effective kilogram of Shh, the licensee has limited measurement cont.ol requirements, however, limits of error (L.E.'s) are calculated for SNM items prior to shipment to waste burial sites. These L.E.'s have been calculated and reported on the NRC-741 as determined by the inspector for the two waste shipemnts made since June 11, 1980. Plutoniem Plant New license conditions have been imposed on the licensee by the Material Control and Accountability Licensing Branch of the Division of Safeguards NRC Headquarters in a letter dated Septml - 22, 1980. Three of these license conditions relate to measurement control. One of these three, License Condition 4.2 has not been adhered to by the licensee as determined by the inspector. The licensee has failed to measure any plutonium standards at the same time measure-ments were made on plutonium waste items as removed from the solvent extraction glovebox No. 27A. These NDA measuremen,ts are being made by the Health and Safety,(H&S) Supervisor using a (,ndium Scintillation Counter with a Model 25 ratemeter and a cesium-137 transmission source. Earlier plans were for a SAM-ll single channel, scintillation counter with a NaI crystal Thallium activiated, to be used when the pouched items were to be measured in a portable glovebox in a room adjacent to the SX Glovebox area. Instead the pouched items were to be neasured for plutonium have been transferred to Room 123 for gamma counting prior to pack-aging in 55 gallon drums in MBA 121. The SAM-II counter is available and operable, however, if needed. The inspector had the H&S Supervisor go through the operation of the Ludlum instrument in measuring some plutonium standards. Thus, the inspector was more assured of the operability of the instrument and the transmission source as well as the capability of the operator. The NDA measurement system is being calibrated over the range of operations with standards containing plutonium in matrices and geometries similiar to that encountered in operations. The in-spector noted that this information could be better defined in - -
f documentation than is presently being done. The major shortcoming is that at least two of the applicable plutonium standards are not being routinely measured when NDA measurements for the plutonium waste items are made. This resulted in an item of noncompliance. The inspector pointed out this license requirement as well as the other two to clarify the requirement to the operator and later to the Standby Manager. Limits of error data on NDA measurements are being developed on a current basis and will be accumulated to establish an LE for the quantities to be shipped to burial prior to shipment. Licensee management expects the LE to perhaps evea exceed the total grams of plutonium measured, i.e., to be greater than 1007.. Since the previous inspectisn in June 1980, Report No. 70-1193/80-03, Q drums of plutonium waste have been accumulated. The total amount of plutonium as measured by NDA_as of Jar 3uary 29,1981, is: L43.36 grams, Using the established value of.L592 grams of plutonium, the estimated amount of plutonium remaining in Glovebox 27A and 27B is 648.64 grams; Closer supervision over the NDA measurement program by licensee manage-ment is recommended by the inspector. This will help assure the develop-ment of bonafide statistical data and the accuracy as well as the pre-cision of the measurements taken. 7. Shipping and Receiving (85208 B) No items of noncompliance were noted. Inspection results were attained by review of limited external activity and record reviews. The licensee in its present standby status has no external receipts. Holdings are increased as a result of uranium plant cleanup and re-ported as an inventory difference gain. This recovered material i,s packaged and drummed for subsequent shipment to burial. During the inspection period:thred ' shipments were made to the Nevada burial site for a total of h,430 graqi uranium and 126 gramd 6ranium 235. Good waste can be degraded and liquified to normal uranium and shipped as feed to the Ker McGee Sequoyah Plant, but for this inspection period this activity did not occur. 8. Storage and Internal Controls (85210 B) l Items of noncompliance were noted. The inspection results were l attained by a review of internal transfer (IT) documents, internal control procedures, tamper-safe seals and physical verification of MBA transfers. The lic.ensee failed to initiate internal transfer documentation for some 32 transfers of SNM moving from MBA 50 to the Vault (MBA 12) for pac'kaging. Sometimes this material is in thi vault.' for short periods of time, other times, due to the availability of drums, the -_
r t t material may remain in the. vault _ for days. Upon completion of pack-aging, an IT is prepared in the gault reflecting a transfer from NBA 50 to Room 121 when in fact it is being transferred from the E,ault r The' authorized vaul( custodian signs as shipper 2 rom MBA 50 instead of the MBA 50 authorized custodian (noncompliance). The licensee failed to apply acceptable tamper-safe seals as defined in Regulatory Guide 5.15, Section C and as required by License Condition 7.4 of Amendment MPP-3. Prior to this license condition (September 22, 1980), the licensee did not have the acceptable tamper-safe seals. These accept-able seals were received by the licensee December 17, 1980, and as cf the inspection dates (January 26-29, 1981), the licensee had not applied the acceptable seals for drums generated after December 17, 1980. The entire uranium plant is considered one MBA, therefore internal transfers are not utilized. Tamper-safe seals are controlled by the Administrative and Accountability Clerk (AAC) and stored in a fire resistant combia stion lock file cabinet for the uranium plant. Uranium plant seals are applied and removed by the AAC and verified by the Health and Safety Supervisor by initials and date in the tamper-safe seal log. Type C paper sealq' ire utilized in the uranium plant and for the period of inspection (June 1, 1980 - December 26, 1980) seal nos. 2179-5000 were accounted for as follows: Used 2179-2391 Unused 2392-3000 Issued Pu Plant 3001-3651 Unused 3052-5000 Seals are monitored during the uranium plant inventory and seal inspections noted and dated in the record log by the seal number ent ry. Tamper-safe seals in the plutonium plant are controlled by the H&S Supervisor and Storage Custodians. All seals applied to containers are documented by number on the internal transfer form. Signatures on the internal transfer s arms signify proper application and witness by shipper and receiver signatures. The inspector's review of internal transfers from June 1,1980 to December 31, 1980 verified internal transfers and seal numbers. No exceptions were noted. All seals and internal transfers were accounted for, but it was suggested that both seals and internal transfers be logged when issued reflecting numbers, dates and to whom issued. Also for the uranium plant seal log initials and dates for attesting to container content and seal application be documented on each line entry instead of arrows for consecutive line entries. i
( ( 9. Inventory (85212 B) No itemr of noncompliance were noted. The inspection results were attained through a review of internal inventory procedures, a piece count inventory of the uranium plant, a complete physical inventory of the items in the plutonium vault, observations of the inspector and discussion with key personiIel. ' Uranium Plant i l Physical inventories are being performed every six months as required by the licensee's internal procedure, No. KM-NU-15-8, and verified by the inspector. A piece count inventory was taken by the inspector as-sisted by the Administration and Accountability Clerk. No discrepancies were detected. Several milk cans of liquid waste cleanup were on hand, unmeasured at this time. These were generated since the previous in-ventory in June 1980, and must be measured and tamper-safe sealed before the next physical inventory. The licensee informed the inspector that these plus others generated in the next month will be feed material for the new ion exchange system (previously described in Paragraph 5). Measurements will then be a made on the uranium separated by the ion exchange columns. Plutonium Plant Acompletephysicalinventoryofallitemsintheplutoniumgaultl HBA 12 was taken by the inspector assisted by t.he MBA custoulan. No discrepancies were detected. A piece count of 121 drums of plutonium vaste made up the inventory in MBA 121. Thepaperseal[onthevalves, plant operating equipment and gloveboxes were~not inspected during this inspection. The upper level area of the SX system for Glovebox 27A was observed by the inspector to reveal only the Section 80 stainless steel tanks remaining in the system. The plasma are torch was to be installed later that day to begin cutting the pipe into two foot sections prior to being pouched in polyvinyl and measured for plutonium content by NDA after removal from the system. The inspector reviewed inventory records and concluded they were being made bi-monthly and properly documented as required. Also a piece count inventory is being taken and recorded in a log in the vault each time the vault is entered as the licensee's internal procedure requires. 10. Records and Reports (85216 B) One item of noncompliance was noted. The inspection results were attained through review of license authorization, licensee ledgers, licensee offsite burials and agreement with Forms NRC-742 for the inspection period. The licensee,was found in noncompliance for possessing kigh enriched uranium [931) 'as a result of uranium plant clean up. The Uranium License No. SNM-928 authorizes the licensee to possess enriched uranium.
( not to exceed $% enrichment in the isotope U-235. On August 15, 1980 the licensee found two vials of U 0 Powder located on an in-33 strument from the wet ceramics control panel. This seven grams U and _six grams U-235 was blended with low enriched urafiium powder for degradation and is now carried as part of the low enriched uranium holdings. This is not the first occassion, nor is it unexpected, and in all probability will occur again when more emphasis is put on the cleanup of the previously used high enriched uranium line. Some license modifications will have to be initiated to avoid a sustained future noncompliance status. Some of the areas in the high enriched uranium line, yet to be de-contaminated and cleaned, are the UALx hoods, UALx gloveboxes, hood for the conversion from T6' [93%1 'and are furnaces. The only plutonium activity for the inspection period was the decay deductionfortheplutonium241-{fourgrams). 1'his was calculated by the inspector for agreement with licensee reported values. Forms NRC-741 for the three uranium offsite burial shipments were traced to supporting data and agreed to the Facility Uranium Ledgers. Forms NRC-741 were prepared and destributed as required by 10 CFR 70.54 and related instructions. All the ledger entries for enriched uranium for the period of inspection except for the three shipments to offsite burial resulted from journal entries, a form provided as a source doc-ument to support ledger entries. All journal entries were signed by both the Administration and Accountability Clerk (orginator) and approved by the Standby Qperations Manager. All journal entries were supported and traced to the facility ledgers for agreement and were prepared to account for inventory discrepancies, gains to inventory due to uranium plant cleanup, and bias contributions. Journal entries for the inspection period accounted for inventory discrepancy gains of 28,362 gram} pranium and 825 grams, uranium 235. License No. SNM-1174 (plutonium) authorizes possession of 11.475 kilograms plutonium and.240 kilograms plutonium in samples and sealed sources for a total of 11.715 kilograms. The licensee possesses a plutonium 238 source containing 1.0 grami plutonium and ~8 grams isotope. License No. SNM-928 (ur,anium) authorizes possession of 2 kilograms U-235 not to exceed 5% enrichment in the isotope U-235. ~' Exhibits A and B reflect respectively the activity for License No. SNM-1174 (plutonium and License No. SNM-928 (uranium) for the period of inspection (June 1, 1980 - January 26, 1981) and agreed with the facility ledger balances as of Janauary 26, 1981. 11. Managesent of Material Control System (85218 B) No item of noncompliance was noted. The inspection results were at-tained through review of procedures and independent corporate audit review. - /
( In compliance with procedure KM-NP-15-45, a timely review of Uranium and Plutonium Accountability Procedures was conducted by the Supervisor, Kerr McGee Nuclear Accounting Group on September 22, 1980 with findings reported to plant management by letter dated September 26, 1980. The scope of the records review was to audit the actions followed by the Cimarron personnel for compliance with their established procedures. No variances resulted from the uranium and plutonium procedures reviewed 1 i -
[ [ i KERR-McGEE CO2?2!!.*1??Ofi utRa ucGEE CENT (R. OwLAMOwA CIT V. OKL AMOWA F3:25 (NVIRONuf NT ANO ME At ?H M AN AGEMENT D#vessON March 26, 1981 CERTIFIED MAIL - RETURN RECEIPT REQUESTED Mr. J. A. Hind Safeguards Branch US Nuclear Regulatory Commission Region III 799 Roosevelt Rd. Gltn Ellyn, IL 60137
Dear Mr. Hind:
Please refer to your letter of February 20, 1981 transmitting the results of an inspection performed by your office on January 26-29, 1981. This inspection examined records of activities authorized by NRC licenses, SNM-928 and SNM-1174. The letter also included a " Notice of Violation" generated as a result of the inspection. Kerr-McGee's response to the Notice of Violation is attached. Since the Notice of Violation concerned subject matter exempt from disclosure, we request that in accordance with 10 CFR 2.790, our response to this notice be withheld from public disclosure. We regret this response was not submitted in accordance with the normal schedule. We have taken steps to ensure that such an oversight does not occur in the future. If there is additional or more detailed information you require, please let me know. I Sincerely, W. Shelley, Vice-President Nuclear Licensing and Regulation WJS/pls Attachment (- o n w r,,,pt uir> c os ' 5R 3 o 19 % 9/z- .}}