ML20215F156

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Partially Withheld Details of Insp Repts 70-0925/83-02 & 70-1193/83-03 on 830502-09.No Noncompliance Noted.Major Areas Inspected:Facility Organization,Measurement & Statistical Controls & Storage & Internal Controls
ML20215F156
Person / Time
Site: 07000925, 07001193
Issue date: 05/06/1983
From: Creed J, Kniceley J, Madeda T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215F104 List:
References
FOIA-86-576 70-0925-83-02-0, 70-1193-83-03, 70-1193-83-3, 70-925-83-2, NUDOCS 8612230285
Download: ML20215F156 (10)


Text

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2. Inspectors: The report clearly addrenes all safety concerns.

The report _does not clearly address the follo.ing safety concerms: I 1 1 I

3. Inspectors: I belfeve All! is effectively dealing with all safety concerns.

See attached c I do not believe RIII is effectively dealtog with all safety concerns, I suggest l

                 .  '                                  .the following actions to assure effective R!!! action:

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              .'I See attached page l
                                                   $ W i. W 4 QRW                                                   _1/S/n f Inspectors' $tgr.atures I/                                         V
                                                                                                          \         Date 4           Supervision:

I . If the fespector does t'ot believe that all safety concerns are addressed in the

            "                                        report or that Rl!! is not effectively dealing with all safety concerns provid your petition on thest e.stters including dates by which actions trill be taken. e I'

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          , fop.gurrener (Only when Section 4. It required to te ccrp*1eted.)

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_ _----{ DETAILS

1. persons Contacted
                                  *A.
                                  *R. W. Norwood, Standby Plant Manager
                                 *H.

Fine, Health and Safety Supervisor

                                 *V. Hodo, Administration and Accountability Analyst
                              * *R. Richards, Decontamination Supervisor and Custodian
                                 *J. Borgmier, Decontamination Supervisor L. Kegin, Maintenance and Utility Supervisor
                                 *W.

Rogers, Health Physics Specialist w# n,-

  • Denotes those present at the exit interview.

2. Licensee Action on Previous Inspection Findings i There were (Report No. no items of noncompliance noted on the previous inspectio 70-925/82-02; 70-1193/82-02) .

3. Exit Interview I '

at the conclusion of the inspection The oninspectors May 4, 1983.The in noncompliance were identified during this inspection. ems of de 4. Facility Organization and Operation No items of noncompliance were identified.

                         - There Standby were      no major changes in the site organization that pertain to th Operation.

Executive Vice President of the Kerr-McGee AtNuclear Corpor . present, the number of employees including the Standby Operation Man supervisors, and guards is '33." The primary responsbility for material , control and accountability rests with the Standby Operations Manager Health and Safety Supervisor, and Administration and Accountabilit Analyst in addition to the plutonium plant MBA custodians Decontamination finished by the end of 1986. and cleanup of the uranium plant continues and ma Escalated transportation and burial costs may result in usable equipment (decontaminated, if possible) being sold as scrap metal if it cannot otherwise be disposed. which involves the removal of remaining plan,t equipm m Plant Completion of roject IV is estimated for the end of 1984'. ' The licensee is utilizing for storage of packaged ' waste material awaiting S-T3 I Copy - of d copleG 3 4 vexur rS m To t Ft.PRODWCD WITHOUT C.Wir ATPROVAL OF RIII g

( ( 6 shipment as indicated in the Sht-ll74 Termination Plan. Except for equipment being used in the ion exchange system for removal of plutonium from decontamination solutions, all equipment is being decontaminated and prepared for shipment. f. - Licenses No. Sht-ll74 and ShH-928 expire March 31, 1988. Due to requests from DOE for research to be done by the licensee, there is no~~ projected date for completing the Termination Plan. v.*

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The inspection results were attained through review of uranium and plutonium procedures, and discussions with licensee personnel. The inspectors determined that the procedures are being followed and appear to be adequate.

5. Measurement and Statistical Controls No items of noncompliance were noted. The inspection results were attained through a review of non-destructive analysis (NDA) methods used in both the uranium and plutonium plants, review of internal records and discussions with individuals who have measurement responsibilities for NDA in both facilities,
a. Uranium Plant Uraniummeasurementsaredoneby[ammacount]f:(LudlumMod and when necessary, isotopic analyses for pern nt U-235 are contracted out to an independent contractor (Isotopic Analysis Incorporated-of Tulsa, Oklahoma). During plant cleanup, any uranium found which is enriched greater tha fivejercentisimmediatelymixedwithdepleted uranium and degraded obelow'five] percent. This method is authorized if the licensee does not excee its present authorization after degradation) of(.2 kilograms)
                                                         -235 enriched to less tha Good material degraded   ive}to natural percent in the isotope    U-235.

(liquid) is shipped to the Kerr McGee Sequoyah Plant as " feed." Nonusable material resulting from plant cleanup is picked up as an inventory gain and removed as a measured discard (offsite burial).

                                                               ~

Durin thisinspectionperiodM2,798(graQofuraniumand. 725 grams: -235wereremovedtooffsiteburialand@,292gra

                                              ~

of uraniuman@heinspectorsalsoreviewedthelicensee'smethodto09 offsite. T calculate Limits of Error (L.E.'s). The inspectors verified that licensee figures (noted above) were accurately presented on the NRC-742's for this inspection period.

b. Plutonium Plant cram determination in 1he plutonium facility is by NDA using j
                    ' tudlum Model 25 Scaled Standards for' o^peration are sampledQ0
                  .      imes"Jeach month to establish upper and lower limits. These limits are then used to enjablish control charts. Each standard is counted QvetimedonbothgondayandWednesdaypfeachweek.

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( 8mmemummmmmen ( The licensee has two categories of plutonium material which are accounted for: non-transuranic material and transuranic waste. Non-transuranicmaterialhasaplutoniumcontentlimitationof(0003 9 rams';Jand each package for shipment to vaste burial is limited to ten nanocuries per gra for the inspection period, the licensee as shipped to burial drums. As of the inspection, the licensee hasgevenpackedand(sea " The rema}ining category d drums of non-transuranic of plutonium material onsite. is transuranic waste.

      -                                                                                               Transuranic
  • vaste is waste with a plutonf un, content of greater than(0003 grams 2 -'

The transuranic gram limit per package isd5 grams"pu-239 andC.0 c

                           '      ' grams 3for hydrogenous magtrial such as oil. As of the inspection period, the licensee ha4457)ackaged and sealed drums of transuranic waste onsite. The inspectors verified that the licensee's figures dealing with plutonium were accurately transferred from licensee documents to NRC-742 forms for this inspection period.
6. Shipping and Receiving ..

No items of noncompliance were noted. Inspection results were attained through a review of records and NRC-741 forins. The licensee in its present standby status has had no external receipts during this inspection period. During this inspection period, 5 shipments ofuganiumweremadetowasteburialsitestotalingh2,798 gram $ uranium and-1,725 gramjU-235. One shipment of degraded material (FEED) totaling {3,32 gramsbranium andQ09 grams}U-235 was sh ped to the Kerr-McGee Sequoia facility. For ttie plutonium facility; hipments p35 dFiEs)foi non-transuranic waste comprise less than{o,ne gra were shipped To~lT."S. Ecology, Beatty, Nevada. All NRC-741 Forms appeared to be properly documented and filed within the required time period (for shipments - the day of the shipment or the next working day). As required by procedure, all NRC-741 Forms were filed by the Standby Operations Manager.

7. Storage and Internal Controls No items of noncompliance were identified.

The entire uranium plant is consideredj~Ieliis's Therefore, internal transfers are not required. {Iamper-safe seaQs are controlled by the Administrative ntabilit p

               *'$         are applied by the AAA and postedAnal   to t forstthe (AAA) uranium and amper-s     se ant. stored Meals and us in a b is verified by the Health and Safety Sup{ervisor, are used in the uranium plant.

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( ( (amper-safe sealhia the plutonium plant are controlled by the Health and Safety Supervison and storage custodians. (All sealj applie ' to containers are cross referenced on the i ternal tran1 fer form and the drum is assigned the same number as th . applied seaQ[ Sijnature on the internal transfer form signify proper ap e by the shipper and receiver signatures. 'nofth(seal)ndwitness sealgare used in the Plutonium Plant. Material resulting from dismantling in MBA 50goldup Plutonium and General Laboratoryjand transferred to MBA 12[Vaulths transferred on waste cards which accompany the drums. When tTe drum is packaged each vaste card representing items is inserted into the drum. In addition, a listing of waste card material is maintained in the NDA Log by the Health and Safety Supervisor which allows for traceability of each item in the drums for subsequent shipment. Hovement of SNM into and out of MBA's is based on NDA measurement. Losses can be localized and discrete item control is on an MBA basis. The inspectors determined through interviews, observation, and records

;                               review that procedures are being followed and appear to be adequate.

g 8. Inventory - k No items of noncompliance were identified.

           }!       -

Physical inventories at the Uranium Plant are being performed every six months as required by 10 CFR 70.51 and licensee procedure, KM-NU-15-8. SNM Inventory Reports are submitted to NRC Region III within 30 days af ter the start of each ending hysical inventory as required. The j and6ightstandardginstorageattheUran(iumPlalicensee t. The uranium presently has(wo l inventory as of December 15, 1982 was uranium and U-235 described as follows: ' U U-235

a. Solids F4,556 9 ~ 118 3
b. Soda Ash Solution 2,613 72
c. Drummed Waste 4,224 124 I 2,797 '
                                                                                                                              '          1
d. Standards -

75 - ' Total Q4,190; j9y I l Physical inventories at the Plutonium Plant are being performed every 60 days as required by both 10 CFR 70.51 and licensee procedures. Reports of each inventory are submitted to the NRC Region III as required. lovebox lloldup Plutonium all SNM Except is storedfor the in th p(lutonium Vault}(HBA 12)inan MBAoom121and12$onsists)ofSNH 50 3acka to burial. T aul ventory was comprised of

,                        j                                                                                   ts o Rooms            1 and               onsisted o ra -               waste]      ie p utonium inventory as o Apra             ,    19 3 was j                                                      f plutonium broken down by NBA as follows:

Part 2. 1

q .- l MBA Plutonium

a. 2kVault))
b. oop 121 and 12M'a te Storage)
c. OMGloveboxHoldup [

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  • Total 3

The inspectors reviewed inventory records since the last inspection and conducted approximately a ten percent physical inventory of items in both the uranium and plutonium plants. The inspectors determined that pro-cedures were followed and items accounted for.

9. Records and Reports No items of noncompliance were identified. The inspectors verified by observation, intervtews, and record reviews that the records required by the licensee's nuclear procedures and 10 CFR 70 were properly maintained.

The following records were reviewed by the inspectors. Records Dates Reviewed Nuclear Material Transfer April 1982 to March 1983 Reports (NRC-741) (10 transactions were reviewed) Nuclear Material Status April 1982 to March 1983 Reports (NRC-742) (2 reporting periods were reviewed) Plutonium Plant Inventory March 1982 to April 1983 (Bi-monthly) (7 inventories were reviewed) Uranium Plant Inventory December 1981 to December 1983 (Semiannually) (3 inventories were reviewed) Forms NRC-741 and 742 were prepared and distributed as required by 10 CFR 70.54 and 10 CFR 70.53 and related instructions. Possession and use of SNM was confined to locations and purposes authorized by license. The licensee's nuclear procedures and records system provide sufficient information to comply with the requirements of 10 CTR Part 70. Exhibits A, B, and C which are enclosel vith this report reflect, respestively, enriched uranium belo and plutonium activity fivejpercent, enriched uranium abov4fivepercent, or this inspection period.

10. Management of Material Control System No items of noncompliance were identified. Inspection results were at-tained by review of licensee procedures and SNM audits. The licensee is required on an annual basis to conduct an independent audit of the nuclear material control procedures and management of the overall SNM control system.

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( l The inspectors reviewed an SNM audit that was conducted on November 11 and 12, 1982. This was the only MC&A audit conducted during this in-spection period. The audit was conducted by the corporate of fice and consisted of a review of all accountability procedures (20), interviews, review of selective records, and observations. The audit results verified that there were no variances from the procedures. Attachments:

1. Exhibit A - Kerr-McGee Nuclear Corporation Enriched Uranium Material Balance Statement Below 5 Percent
2. Exhibit B - Kerr-McGee Nuclear Corporation Enriched Uranium Above 5 Percent - Material Balance Statement
3. Exhibit C - Kerr-McGee Nuclear Corporation Plutonium Material Balance Statement l

l l 8

Kerr McGee Nuclear Corporation - YEC , Enriched Uranium Material For Period 4/1/82 to Balance 3/31/83 Stater.ent L Belof5%3 1 Enriched Uranium in Grams a U U-235 Beginning Inventory 4/1/82 9 l Receipts - Depleted to Enriched Total to Account For

                                                                                                                          ~

i Shipmen t s ' Q [, -) > Degradation (to natural) 43,292 309 Measured Discards (of f site burials) 62,798 1,725 l l Inventory Discrepancy (61,493) (1,802) Ending Inventory 3/31/83 l l Total Accounted For ) i

                                             /s o ri O ( Y       @                                     I"   YY%    d 4/ m 06                           gg h$
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l EX111 BIT A

     ,    . - . , , - - - - - - . . - . ~ -.               . - _ _ - - - . . - - - - . - - - - . , - .                             . - - .                            . --- .-         -

Kerr McGee Nuclear Co poration - YEC - ShH - 928 Enriched Uranium Above 5% Material Balance Statement For Perio 4 1/82 to 3/31/83 Enriched Uranium In Grams U U-235 r # s = Beginning Inventory 4/1/82 1 Tro: Other SNM Material (Depleted) 485 1 Total to Account For 485 1

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s w .- T InventoryDifferences(AboveQ%)J (39) < { (22) < To Other SNM Material (Belos 5% f 524 23 Ending Inventory 3/31/83 0 0 Total Accounted For 485 1 En l><c pa3 c vn , le ec le~ 2e.) EX)llBIT B

, Kerr McGee Nuclear Corporation . Plutonium Katerial Balance Statement For Period 4/1/82 to 3/31/83 Plutonium

;                                                                              In Grams i

Pu Isotope i I Beginning Inventory 4/1/82 Pu-241 Decay )

  • i f Inventory Dif ferences i i .

Ending Inventory 4 Sunnary 1 .. MBA - 50 (Holdup) l 3 f MBA - 12 (Vault) , MBA - Room 121/123 (k'aste Storage) Total t I

k. ,
                                    * *O        YN* f      ri v .% P9b h$    b5$Uh { It} ff l

1/ Includes akne gram -238 neutron source

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