ML20215F159

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Partially Withheld Details of Insp.Major Areas Inspected: Inventory,Records & Repts,Storage & Internal Controls, Measurements & Statistical Controls & Facility Organization
ML20215F159
Person / Time
Site: 07000925, 07001193
Issue date: 03/31/1984
From:
NRC
To:
Shared Package
ML20215F104 List:
References
FOIA-86-576 NUDOCS 8612230287
Download: ML20215F159 (8)
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Text

sumusunute 4

DETAILS 3

1. Persons Contacted
  • A. W. Norwood, Standby Plant Manger,
  • R. Adkisson, Director, Contract Management & Cimarron Operations
  • R. Fine, Health and Safety Superv,isor
  • V. Richards, Decontamination Supervisor and Custodian
  • W. Rogers, Decontamination Supervisor
  • C. Thompson, Health Physics Specialist
  • R. Jones, Administration Clerk
  • Denotes those present e'. the exit interview.
2. Licensee Action on Previous Inspection Findings There were no items of noncompliance noted on the previous inspection.

(Report No. 70-925/83-02; 70-1193/83-03)

3. Exit Interview The inspector met with the licensee representatives denoted in Section 1 ~

at the conclusion of the inspection on June 1, 1984. The inspector detailed the scope and findings of the inspection and stated that no items of noncompliance were identified during this inspection. The licensee agreed to expand the scope of the next MC&A audit to include our concerns regarding irregularities in filling out NRC forms 741 and 742 (Section 9).

4. Facility Organization and Operation There were no major changes in the site organization pertaining to Standby Operation. The Standby Operation Manager continues to report directly to the Executive Vice President of the Kerr-McGee Nuclear Corporation. At present, the number of employees at the facility in-cluding the Standby Operation Manager, supervisors, and guards is 34.

The primary responsibility for material control and accountability rests with the Standby Operations Manager, Health and Safety Supervisor, and Administration and Accountability Analyst in addition to the plutonium plant NBA custodians.

Decontamination and cleanup of the uranium plant continues and may be finished by the end of 1984. Escalated transportation and burial costs may result in usable equipment (decontaminated, if possible) being sold as scrap metal, within limits, if it cannot otherwise be disposed.

At the Plutonium Plant, the licensee is currently engaged in Project IV which involves the removal of remaining plant equipment. Completion of Project IV is estJmated for the end of 1986. The licensee is utilizing

$ooms121and12%iforstorageofpackagedwastematerialawaiting shipment as indicated in the SNH-1174 Termination Plan. Except for h 22 g 7 061219 g eq,, ,,

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equipment being used in the ion exchange system for removal of plutonium from decontamination solutions, all equipment is being decontaminated and prepared for shipment. The licensee utilizes four modified gloveboxes for decontamination of equipment. Two of these are for the ion exchange clean-up and the other two are for plasma arc cutup.

Licenses No. SNM-1174 and SNM-928 expire March 31, 1988. Due to requests from DOE for research to be done by the licensee, there is no projected date for completion of the Termination Plan of the Plutonium facility.

The inspection results were attained through review of procedures, and discussions with licensee personnel. The inspector determined that the procedures for each facility are being followed and appear to be adequate. ,

l

5. Measurement and Statistical Controls I The inspection results were attained through a review of non-destructive analysis (NDA) methods used in both plants, review of internal records j and discussions with individuals who have measurement responsibilities i for NDA in both facilities. The inspector determined that the practices which the licensee employs appear to be adequate and effective.
a. Uranium Plant Uranium measurements are done b and when necessary, isotopic ana ammacount(LudlumModel2500 ses for percent U-235 are contractedScaler)]

out to an independent contractor Isotopic Analysis Incorporated of Tulsa, Oklahoma) During plant cleanup, any uranium found, which is enriched greater}than{five) percent, is immediately mixed with uranium and diluted or degraded below{five] percent. This method is authorized if the licensee doe not exceed its present possession limit (after degradation) of .2 kilograms'*U-235 enriched to less '

than five] percent in the isotope U-235. "EnYiched material degraded to natural liquid form is shipped to the Kerr McGee Sequoyah Plant as " feed." No shipments of this type were made during this inspec-tion period. Nonusable raterial resulting from plant cleanup is picked up as an inventory gain and removed as a mea _sured discard (offsiteburial). Duri this inspection period, 14,872 grams I uranium andQ1,154 grams -235wereremovedtoof(fsiteburial.]of The inspector also reviewed he licensee's method to calculate Limits of Error (L.E. 's). The inspector verified that licensee figures (noted above) were accurately presented on the NRC-742's for this inspection period.

b. Plutonium Plant Gram determination iDtheplutoniumfgcilityisbyNDAusingakudlum Model 2500 Scalejr twenty individualfcounts are taken on both the

{igh and low endjsources to establish control charts for the month.

That chart is then compared to the original calibration control chart.

Each day the NDA count systcQls used, the licensee takesjive counts on the high [and low standardJwice a day, for a total of;Q 3

GhYW (19e 9 be rclmse)

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The licensee has two categories of plutonium material which are accounted for: non-transuranic material and transuranic waste. Non-transuranic material has a plutonium content limitation of;$2.7 nanocuries er gram and each package for shipment to waste burial is limited to 00 nano] curies p(er gram'ffor the R Currently, he licensee has 182 packed and sealed drums of non-transuranic material onsite.

The remaining category is transuranic waste. Transuranic waste is wastewithaplutoniumcontentofgreaterthanf0175 rams The transuranic gram limit per package is per drum for hydrogenouspalerial as such(15 oil. As gramspu-2393nd of the inspection 0 gr period, the licensee had(49Jpackaged and sealed drums of transuranic waste onsite. The inspector 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 Inspection results were attained through a review of records and NRC-741 forms.

During this inspection period, shi ments of uranium were made to waste burial sites totalingd4,872 gram uraniumandj5,154 grams')U-235. No shipments of diluted material (FE ) were made. For the plutonium facility, the shipments of non-transuranic waste to U.S. Ecology, Beatty, Nevada, comprised less than,@ne gram] The licensee's performance in this matter was determined to be adequate and effective.

7. Storage and Internal Controls Theentireuraniumplantisconsidered(oneM8 therefore, internal transfers are not required. (amper-safe seal re controlled b the Administrative and Accountability Analyst (AAA and stored in a tre resistantcombinationlockfilecabinet~ffortheuranium ant) Seals 3 are applied by the AAA and posted to the,{famper-safe seal og, se is verified by the Health and Safety SupTrvisor. {ype paperseals3 are used in the uranium plant.

(' and Safety Superv'sor and storage custodians. 611 scald containers are cross referenced on the internal transfer form and the drum is assigned the same number as th{ applied seal Signatures on the internal transfer form signify proper application of he seal 3Oegl'k secu ty isalso verified by the shipper and receiver ignatures. fype E seals re used in the Plutonium Plant.

Material resulting " rom dismantling in MBA 501 oldins Plutonium and GeneralLaboratory)fandtransferredtoMBA12iVault)Jlstransferredon waste cards which accompany the drums. When t e drum is packaged each waste card representing items is inserted into the drum. In addition, a listing of waste card material is maintained in the N0A Log by the Health and Safety Supervisor which allows for traceability of each item in the drums for subsequent shipment.

4

_ = , - _ - - - __ ,

Movement 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 inspector determined through interviews, observation and records review that procedures are being followed and appear to be adequate.

8. Inventory 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 physical inventor re ired. The uranium inv 15, 1983 was uranium and;%entory as of December U-235. -

N ___ - .. . -- - - - A y

Physical inventories at the Plutonium Plant are being performed every 60 days as required by both 10 CFR 70.51 and licensee procedures 7 Reports of each inventory are submitted to the NRC Region III as required.

ExceptfortheplutoniuminMBA50[).GloveboxHoldupPlutonium3all SNM is stored in the ault MBA 12 Material in rooms 121 and 123 consistsofSNMpack(aged q or shipment to burial. The vault inventory was comprised of four standards, and one Pu-238 neutron so~urce. The contents of Rooms 121 and 123 consisted of 49 drums of transuranic waste and 182 drums of nontransuranic waste. The plutonium inventory as of May 1,1984 was 5,890 grams of plutonium broken down by MBA as follows:

MBA Plutonium (grams)

a. 12 Vault 3 '
b. fo{m 121 and 123 (Waste Storage)3
c. 50tGloveboxHoldup&

Total N

The inspector reviewed inventory records since the last inspection and conducted approximately a twenty precent physical inventory of items in both the uranium and plutonium plants. The inspector determined that procedures were followed and items accounted for.  ;

9. Records and Reports The inspector verified by observation, interviews, and record reviews that the records required by the licensee's nuclear procedures and 10 CFR 70 were properly maintained, with the following exceptions.

A review of the licensee's NRC 741 and 742 forms, by the inspector on May 31, 1984, showed several errors which were noted as concerns during the exit meeting on June 1,1984. These inconsistencies did not repre-sent noncompliance or a misinterpretation of data by the inspector. An earlier memo from Union Carbide (OAK RIDGE) dealt with some of the same

concerns. These recurring problems necessitated a request by the in-spector for the licensee to correct the deficiencies as well as include a review of this area in their annual audit,

a. Form 741 Report Period 4-1-83 to 9-30-83 (1) line 40 (23,548shouldread23,538)

(2) Material Type when using "20" enter El through l E4 in lieu of "20". This better describes material enrichments as noted in the hand book.

b. Form 742 YEC-VRA (HANFORO)

(1) (4-23-84) Nature of transaction was left blank Number of Data lines incorrect Line Numbers incorrect (2) (10-10-83) Data lines incorrect Nature of transaction blank j

(3) (9-5-83) Nature of transaction blank The following records were reviewed by the inspector.

Records Dates Reviewed l

l Nuclear Material Transfer April 1983 to April 1984 Reports (NRC-741)

Nuclear Material Status April 1983 to March 1984 i

Reports (NRC-742)

Plutonium Plant Inventory May 1983 to April 1984 (81-monthly)

Uranium Plant Inventory December 1982 to December 1983 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 CFR Part 70. Exhibits l A and B which are enclosed with this report reflect, respectively,

' enriched uranium below five percent and plutonium activity for this inspection period.

10. Management of Material Control System Inspection results were attained by a review of licensee procedures and SNH audits. The licensee is required on an annual basis to conduct an independent audit of the nuclear material control procedures and manage-ment of the overall SNM control system.

6 At py % > relmrcl

1 The inspector reviewed an SNM audit that was conducted on November 17, 1983. This was the only MC&A audit conducted during this inspection j period. The audit was conducted by the corporate office and consisted {

of a review of all accountability procedures (20), interviews, review i of selective records, and observations. The audit results verified that there were no variances from the procedures.

The inspector requested and the licensee committed, that the next audit by corporate personnel would irJclude a review of the weaknesses identified by the inspection and previously mentioned (Section 9) of this report.

The licensee will address the discrepancies found on NRC 741 and 742 forms and document actions taken to correct such discrepancies.

Attachments:

1. Exhibit A - Kerr-McGee Nuclear Corporation Enriched Uranium Material Balance Statement Below 5 Percent
2. Exhibit 8 - Kerr-McGee Nuclear

, Corporation Plutonium Material

) Balance Statement l

7

_.y Kerr-McGee Nuclear Corporation - YEC Enriched Uranium Material Balance Statement Below{5%)'.

For Period 4/1/83 to 3/31/84 Enriched Uranium (GM3)

Beginning Inventory 4/1/83 U-2 Receipts Depleted to Enriched g Total to Account for Shipments s ,

, - f,' f Degradation to Natural > -

' )

Measured Discards 25,154 685 Inventory Discrepancy (19,258)! 413)

(10,637) 2 Ending Inventory Total Accounted for s

i Exhibit A M fj-g.1;.,,') , v., h s [hr~ rl -) . p e.d x D ff G & ^'M we 8

Plutonium Material Balance Statement For Period 4/1/83 to 3/31/84 Plutonium in Grams

~

Beginning Inventory 4/1/83 [ ,

Pu-241 Decay ,,-

Measured Discards '

4,588.c y

Inventory Discrepancy 4, (1

Ending Inventory 3/31/84 -

, ,, ) [yii[ 6Lik' A ' ' ' ' -'

,e- a;

.,,,,.,\)

> r - f * '- ~

Exhibit B 4

9

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