ML20215L685
| ML20215L685 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 09/24/1974 |
| From: | Hind J, Peck C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215L523 | List:
|
| References | |
| FOIA-86-281 70-1193-74-07, 70-1193-74-7, NUDOCS 8610290245 | |
| Download: ML20215L685 (70) | |
Text
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8 plutonium nitrate from Atlantic Richfield Han licensee did not on three occasions, when del.
s
~made, complete and report reviews measurement:
Form AEC-741 within the required thirty days.
involved and the number of days taken to comp:
are as follows:
Document HVA-YEC #14 -
54 days Document HVA-YEC #16 -
21 days Document HVA-YEC #18 -
40 days 1
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Attachment:
Exhibits A through C up
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8610290245 861023 PDR FOIA CANTREL86-281 PDR
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KERR-HCCEE INCLEAR CORPdRATION - TEC HATERIAL BALANCE STATEMENT - LEASED FLUTONIUM 2/27/74 - 7/23/74 5
Job 9201
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PLUT0 NITE PU ISOTOPE
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s 1I 94450 93 Beginning Inventory 2/27/74
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1 995 14.80s Receipts 40k2k6
{4k40f Total to Account For r i su 16
'l 149 40 Shipments 46 3S Heasured Discards Haterial Unaccounted For (MUF) 6)
./(29k7)
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865k6 25241
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Ending Inventory 7/23/74 Total Accounted For
- 5440h, 40021
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In 1/ From Inspection 070-1193/74 2/26/74 e
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Eghibit A i
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a KERR-MCGEE NUCLEAR CORPORA 1 4
MATERIAL BALANCE STATDfENT - PRIVATI 2/27/74 - 7/23/74l 1
Beginning Inventory 2/27/74_/
1 3
Receipts Total to Account For Shipments Hessured Discards Material Unnaccounted for (MUF)
,Ending Inventory (o
t Total Accounted.For
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1 1
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From Inspection 070-1193/74 2/26/74-G m
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v' KERR-MCGEE NUCLEAR CORPORATION - FEM MATERIAL BALANCE STATEMENT - C,0NTRACT PLUIONIUM 2/27/74 - 7/23/74
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FLtrTONIUM
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PU ISOTOPE 7-r Beginning Inventory 2/27/731./
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Receipts Total to Account For i
Shipments Measured Discards
't Material Uncccounted For (MU'F)
Ending Inventory 7/23/74 2__
l Total Accottnted For 3
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JJ From Inspection 070-1193/74 2/26/74 Exhibit C e
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1 U. S. ATOMIC ENIfRGY C0F011SSION j
DIRECTORATE OfREGULATORY OPERATIONS I
REGION III J
l Is 10 Inspection Report No. 070-1193/74-07 Licensee:
Kerr-McGee Nuclear Corporation Kerr-He ;ee Building r
Oklahoma City, Oklahoma 73125 Cimarron Facility Plutonium Plant License No SNM-1174 Crescent, Oklahoma 73028 Priority:
I Category: A (1)
Type of Licensee:
Plutonium Fuel Fabricator Type of Inspection:
Special Nuclear Materials, Announced,l. #
y:
Date of Inspection:
August 21-23, 1974 Date of Previous Inspection:
July 23-25, 1974 (Safeguards)
Principal Inspector:
C.
.P F
(Dat'e)
Ms<x
, Accompanying Inspector: p. A. Hind Other Accompanying Personne : None Reviewed By:
Hin, Chief 2
Materials and Plant (Date)
Protection Branch
Attachment:
Tindings (10 CFR 2.790 INFORMATION) 8 e
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SUMMARY
OF FINDINCS i
wforcement Action:
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- ;/O the following Category II items bf noncomplianc l b
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1.
License Condition 3.5 states:
" Material a edjusted for any measurement bias, as dete
. 3.3.2, which exceeds 10% of its standard d The licensee's material accounting data ar measu. ement biases which. exceed 10% of the requirement of License Condition 3.5.
The analytical bias limits, and measurements e not used. This principal of accepting no however, the licensee's bias limits appear standard dcviation at:d thus biases exceedi tion are not being corrected and can be af ments.
In addition, weight measurements a-bias.
2.
License Conditica 6.3.4 states: " Seals sha:
after measurements. or sampling."
C, The licensee has not inii.iated the use of t use of such seals is required by License Ce gg, is described in the licensce's material cor plan, both of which became effective in g 2
h 3.
The licensee has continued to include.18.7 9
in his inventory as in-process holdup. All this total was unmcasured, being calculated basis in June 1973.
License Condition 6'.4.2, effective in May 1 SNM be measured during physical inventory e-and minor items containing less than ten gr.
6.4.3.1 permits 1.1 kilograms of plutonium !
t License Coridition 6.4.2 states:
"All spect:
shall be measured at the time of ph'sical 1:
y items previously measured whose integrity b:
tamper-safing and those items exempted by C:
License Condition 6.4.3.1 states:
"The lies holdup value of 1.1 kilograms of plutonium a specified in Condition 6.5 is conducted."
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M is a clean-out physical inventory to be conducted at the conclusion of the FFTF contract.)
License Condition 3.3.2 states: "A standards program shall be 4.
maintair.ed co provide a minimum of two measurements of standards per wcck for each measurement type."
The licensee has impimeneted the program but is not in full com-pl,iance with this license con'di, tion because the requirement frequency in the measurements of radioassay standards has not been achieved.
Licensee Action on Previously Identified Enforcement Items The previous inspection of July 23-25, 1974, disclosed one apparent item of noncompliance concerned with the licensee's f ailure to complete Forms AEC-741 for plutonium nitrate receipts with thirty days af ter receipt of the material. There has been insufficient time for the licensee to respond to the notice of violation, and the matter was not a subject of this inspection.
The inspection of December 3-7, 1973, disclosed and apparent violation.
The licensee's limit of error of material unaccounted for (LDNF) had exceeded the limit of 1.5 kgs imposed by. License Condition 3.2 for five
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consecutive inventory periods. The principle contributor to the exces-sive LDNF was the large uncertainty that the licensee associated with his 18.7 kilograms of unmeasured holdup.
In response to the notice of violation the Licensee stated that he would:
(1) Achieve positive control and recording of material movements by the addition of safeguards clerks to the staff.
(2) Investigate alternate assay methods to improve Both of these corrective actions have been achieved, analytical precision.
although (2) has not yet resulted in the application of any alternate The amendment to License Condition 3.0, effective in May 1974, methods.
increased the LDNF limit to 1.8 kilograms and, by requiring the licensee to measure all SNM during inventory, prohibits the use of any 1&rge The licensee in unmeasured holdup and its associated large yncertainty.
g his July 1974 inventory reported a LDNF of(1.6) kilograms, within the
$( 3,. /
However, this LEMUF was achieved, primarily because the new limit.
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licensee did not include a calculation of the uncertainty around the 18.7 kilogram holdup in his LDNF determination. The LDNF violation, t.#
although not considered resolved, is considered to have been superseded
'p by the present violation, which is concerned with the licensce's contin-uing practice of including a large unmeasured holdup in his inventory, regardless of whether or not he associates any uncertainty with this holdup.
Unusual occurrences _: None l
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Other Significant Findings One item, considered to be program weakn. css, was identified during the inspection. This was:
The gamma autoradiography system by which each fuel pin is nondestructively overchecked is. considered a satisfactory means of complying with License Condition 3.2.
However, the licensee hah no procedure identifying and describing the use of gamma authoradiography
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as a safegua'rds system, a program defic 1ency.
Management Interview A close out meeting was held August 23, 1974, by C. C. Peck and J. A.
Hind with the following members of the licensee's staff:
M. Moore li. Shelley R. Janka M. Binstock R.'Adkisson G. Mallett The group was informe,d by the,, inspectors of the three violations and two program vcaknesses.g Mr: Moory stated that correction of two of the noncompliance items ans the two veaknesses could be accomplished without difficulty, but that the noncompliance f. tem involving the unceasured inventory holdup would be a significant problem.
(Note: Subsequent to the closecut interview, it was decided to report the matter concerning the lack of measurements of the radionssay standards required b'y License Condition 3.3.2 as a violation rather than program weakness.) Further discussion was concerned with the holdup problem.
The licensee representatives stated that they have attempted to measure the 18.7 kilograms of holdup in accordance with plans that they had discussed in meetings with representative of Licensing.
The principle effort has been an attempt to measure liquid holdup in pipelines. Lines in which liquid is known to be heldup because of 'its location (horizontal a
runs of low piping) have been measured to determine liquie volume.
The volume multiplied by the concentration of solution in the lines results in a determination of the plutonium quantity heldup in the lines. This effort has been disappointing in that it has resulted in the measurement of only small quantities of plutonium, for example,165 grams in July.
There has also been consideration given.to measuring holdup in vessels and gloveboxes by non-destructive testing, but high background inter-ferences caused by the proximity of plutonium - containing equipment other than that being measured has made these attempts unsuccessful.
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. The licensee confirmed ~the inspectors' belief that their efforts to measure in-process holdup had been overly-optimistic in that they expected that they would be able to measure directly a major portion of the 18.7 kilogram holdup. This optimism perhaps led Licensing to believe that most of the 18.7 kilograms would be recovered and that the unmeasured holdup limit of the license conditions could therefore reasonably be set at a low level. The limit of 1.1 kilograms that was established by the May amendment to the license conditions permits no holdup other than what was measured by NDT methods in the flushed-out system before the FFIF compaign began. The licensee s* tate.d that he had not expected the
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condition,to be so restrictive.
The licensee stated that he did not know what could be done to solve the problem. The inspectors recommended that further discussions with Licensing seemed appropriate.
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REPORT DETAILS Persons Contacted R. C. Janka, Manager, Administration and Accountability W. J. Shelley, Director, Regulation and Control G. R. Hallett, Safeguards Specialist R. J. Adkisson, Contract Relations Representative and Safeguards Supervisor P. Carst, Safeguards Analyst D. Sanders, Plutonium Laboratory Supervisor Scope of Inspection The inspection was announced and was primarily for the purpose of invest-igating the licensee's compliance with License Condition 3.0, Measurements, and certain parts of License Condition 6.0, Inventory.
The amendment to MPP-1, effective in May 1974, and the licensee's material and accounta-bility control plan both require that additional specific measures be adopted in the measurement of plutonium and performance of inventory.
Some of these modifications appeared to require major modifications to
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the licensee's system.
Facility Organization (Licen'se Condition 1.0)
One si gificant change has been made in the organization of the Safeguards
. R. J. Adkisson,; Contract Relations Representative, has been made Group.
supervisor of the Safeguards Group. The assignment is in addition to bis contract responsibilities.
G. R. Ma11ett'yho formerly has responsi-
. bilitics for both supervision and the technical and statistical develop '
ment of safeguards is now responsible only for the* technical aspects of the program.
Measurements (License Condition 3.0) 3.1 Mcarurements and Statistical Controls The licensee continues 6. measure plutonium nitrate receipts, product shipments, discards. and inventory items as required.
No detailed information was obtaine'd on, receipt or discard measure-Inquiry disclosed that such measurements ment during the inspection.
are continuing as in the past..
On receipts each of the several ten liter bottles in a shipment is sampled. Two samples are taken from two of thq bottics. The single samples are analyzed to. assure that'there is no significant difference among concentrations of s'olutions in the bottles.
The duplicate, samples are used to detchnine concentration of the
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J lot for accountability purposes. The concentration is multiplied by the weight of solution, determined from the weights of the loaded and empty bottles. The Toledo scale used for bottle weighing is checked with three standard weights covering the range of opera-tion once a week. Data are recorded for statistical control purposes.
Scrap materials transferred to the vault, MBA-12, are individually 1
measured by an active neutron system. Those materials containing 1ess than two grams plutonium are discarded, other items are repro-cessed unless recovery is deemed to be uneconomical by production supervision..The safeguards group has assumed the responsibility for all the scrap measurements by neutron counting, a change in the accountability system.
Production was formerly responsible for this work. The discard measurement system was not inspected in detail.
Product shipment quantities have increased in the past five months to the rate expected for the FFTF campaign, about 40,000 grams of plutonium per month in two lots.
Each' lot of about 20,000 grams contains approximately 500 fuel pins. The accountability for plutonium in each lot is determined from the weights of the approxi-mate 140 pellets in each pin multipled by the plutonium assay for the lot. The stack of 140 pellets is weighed on a Mettler P-200N balance.
Plutonium assay for the lo.t is determined from analysis of fifteen pellets, selected at random from the lot Each of the fiften pellets is individually analyzed by amperometric citration for plutonium concentration and by nass cpectrometer for isotopic composition. The fif teen pellets from a lot of about 70,000 pellets represent 0.02% of the total. The measurement plan is as agreed upon in the FFTF contract.
3.2 Nondestructive Overcheck of Fuel Pins This is a new condition requiring the licensee to test nondestruc-tively each fuci pin to assure that all.SNM, the approximate 140 plutonium - bearing pellets are contained'in the pin.
A gamma autoradiography system that satisfies this requirement has been in use since the start of FFTF.
Several pins, usually about thirty, are simultaneously X-rayed to determine structural integrity of the pins. The same group of pins is then subjected to gamma autoradiography. The gamma radiation from the 140I. 3 pellets in the pin are detected by the X-ray film. The presence of each plutonium-containing pellet can be verified by visual examination of the film..iny uranium pellets, elugs, or plutonium pellets with signifcantly off-standard assays are detectable by the autoradiograph.
A pin not having the correct quantity of acceptabic pellets would be detected and rejected by the inspector and thus the utility of the system for safeguards purposes in automatic.
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w The licensee has no procedure or mention of autoradiography in his material control plan, recognizing and describing the method as a safeguards aid. This is considered a program weakness and the licensee was advised of the fact.
3.3 Hessurement Control Program The license condition has been modified to require more frequent checks with weighing and analytical standards to improve limit of error data.
License condition 3.3.2 requires the licensee "To prov'ide a minimum of two measurements of standards per week for each measurement type." This it interpreted as meaning that the licensee shall check each balance that is important to accountability twice a week with standard weights, and shall analyze each analytical standard twice a veek in the laboratory.
Balance control records for the Mettler F-2000N scale in the rod loading area were examined and indicated a frequency in excess of' twice a week during the July-August period. This is the scale most important in the accountability for finished product pellets. The Toledo blend scale, used in weighing plutonium nitrate-uranyl nitrate blends is checked prior to the weighing of each blend.
This frequency, although less than twice per week is adequate, because blends are made up normally only about twice a month.
The blend scale is important to accountability in the measurement of solutions in the ceramic area for inventory purposes. The plutonium nitrate weigh scale, used to determine the weights of receipts, was e
not specifically investigated.
In the past this scale has been checked over its range each time a series gf bottles is weighed, usually about twice a month. This proceduf% was stated to be continuing. All scale identifications and checkweighing frequencies are listed in the licensee's procedure, KM-NP-15-46, dated June 18, 1974.,
Analytical sta'ndards measured under 3.3.2 are of the following types, designated by letter:
A Amperometic B Radioassay C Neutron Activation F X-ray Flourescence Licensee records disclosed that A and C type standards are being analyzed at the required frequency. F type standards, representing a new method, were analyzed at the required frequency in August.
The B type standards, radioassay, were not analyzed at the required e
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fraqu2ncy.
(See note in Management Interview Section);Tha lice License Condition 3.3.3, a new requirement, licensee shall maintain a program of replicate sampling and m specifies that the ment of process materials.
material shall be measured per material balance period.
had a program of replicate measurement of process materia The licenst to the time the new license condition became effective materials sampled under this program and their frequencies are Process listed below:
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Estimated Sets Per Material Balance Per
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I Plutonium Nitrate Receipts Blended U-Pu Powder 4 Sets of-10 each -40 Pellets 4 Sets of 8 each -32 4 Sets of 15 each -60 In addition solvent extraction product solutions are submitted this replicate sampling program, although frequency is not kn own.
It was noted that strictly speaking the number of sets of in-process types does not meet the license condition requirement of fifteen.
However, the large number of replicates in each set be divided into subsets as desired. offsets this deficienc therefore considered to meet the requirements of 3.3 3The licens 3.4 Bias and Systematic Error Determination The licensee has had a system for determining biases and sys errors since the beginaing of the TFTF program.
The system was computerized, data were updated cach material balance period, and the data were used to determine limits of error for al balance items and the overall LEMUF.
random error data meets the requirements of License condit The licc.nsee has had to modify his data collection and statistica calculation procedures because of the larger quantity of data required by the new License Conditions 3.3.2 and 3.3.3.
presently being hand-calculated because the established computer Data are program would not accommodate the expanded data collection requ ments.
I',1 cense Condition 3.4 specifies that biases be calculated fro measurements of standards as required by L.C.3.3.2 and random errors from the sampling and measurement of process materials as required by L.C.3.3.
standards in the case of mass measurements and from reference standards made up from prdces,s materials in the case o analytical measurement.
1 Random errors are determined weight standards i
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\\and in the analytical laboratory, from both reference standards and replicate process samples. The reference standards provide the basic random error for the method and the replicate proceas samples introduce a process variability factor.
The licensee's system for determining biases and random errors is considered to be in compliance with the requirements of L.C.3.4.
3.5 Adjustment of Accountability Data for Measurement Bias This new license condition requires the licensee to adjust his accounting data,for any measurement bias exceeding 10% of its standard deviation.
Although the licensee determines biases as explained in the previous
'section for the purpose of using them in the calculations of limits of error and' LDfUF, he has made no attempt to factor them into accountability measurements. Weight biases, although their effect on materisi quantities, would probably be' insignificant, are not considered at all. Analytical biaces calculated from the data on duplicate reference standard determinations which are analyzed in conjunction with process samples, are recorded on control charts.
However, when the analysis of the duplic' ate reference standards 1 exceeds either upper or lower control limits for the method, the analytical result on the associated sample is. discarded and the analysis repeated. Thus no analytical biaces are permitted to exist. This principle of eliminating biases would be acceptable and would meet the license condition provided control limits were set not to exceed 10% of the standard deviation of the method.
The l
limits however, exceed 10% of S.D.
For failure to make bias adjustments, as explained above the licensee was found to be in noncompliance with License Condition 3.5.
Inventory (License Condition 6.0) 1 I
6.3 Tamper Safing This new condition states:
" Seals shall be applied immediately,
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after measurements or sampling." The statement implies that tamper-safing seals shall be used.
In addition the licensee's material control plan acknowledges this requirement and describes
'the details of the usage of seals.*
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Both the license condition and material control plan were effective in May 1974. No positive efforts were mede until July to acequire the seals.
Several additional weeks elapsed before delivery was obtained, and at the time of the inspection the tamper-safing l
system was not yet in effect.
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Failure of'the licensee to use his tamper-safing system at an earlier date was determined to be an item of noncompliance.
In a discussion of the use of the s'eals the licensee suggested that seals be used to tamper-safe the vault, in lieu of the several hundred items normally contained within the vault.
Such a pro-cedure would require that the vault be sealed several times each day. The. inspectors agreed that the 10 CFR Part 70 requirements allow for tamper-safing vaults, but since their proposed change to the material control plan constittites a major change, prior approval of the Commission is necessary.
6.4.2 Measurement of All Sm! for Inventory Purposed This major inventory requirement states that all special nuclear saterial must be measured during inventory with the exception of tamper-safed items, scaled sources, and sample items containing less than ten grams of plutonium.
L.C.6.4.3.1 allows the 1.1 kiiogrrms of plutonium measured in the process before the start of the FFTF campaign to be.carred as holdup, but this is the only measured holdup pemitted by the license conditions.
In violation of the license, the licensee'has continued to carry
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18.7 kilograms of holdup in his net balcnce in the one inventory conducted since the new license conditions became effective. Only 1.1 kilogram of this total can be considered to be measured. The remaining 17.6 kilograms is the same unreasured quantity that has been a part of the inventory since June 1973.
It was' determined on a by-difference basis.
No limit of error is now associated with the holdup as was the practice under the earlier license conditions. The large limit of error of the holdup was the major contributor to the licensee's excessive LD1UF quantitica which consistently exceeded the licensee limit of 1.5 kilograms.
Under the new license conditions, the problems of whether or not unmeasured holdup should have a limit of error and how it should be determined are resolved by the elimination of unmeasured holdup and consequently its limit of error. The contin-uing existence of holdup constitutes the viointion rather than its debatable limit of error.
Prior to the issuance of the amended license conditions, the
' licensee was optimistic about plans for physical measurement of the inaccessible holdup material. The' major portion of the holdup was believed to be in liquid form in pipelines in the wet ceramic and scrap arcas. Attempts were made to measure the volumes of pipline sections known to contain liquid and to calculate the plutonium content by multiplying these volumes by the estimated or measured concentrations of the solutions. The licensee reported during the inspectica that these efforts as well as endeavors to measure
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m, previously inaccessible solid material in $he system had not been effective, sir:ce i: hey resulted in the measurement of only a couple of kilograms. The licensee stated that further efforts would be made to measure the holdup, but did not seem optimistic about the results.
It was noted during the inspection that the licensee's July inventory listed several measured items that possibly could be considered a part of the 18.7 kilograms of holdup which is a separate item in the Itcensee's net balance.
Since the holdup was determined by difference, it is not physically defined, so that the questions as to whether the July inventory items are aise part of the holdup cannot positively be resolved. However, the ite.ms in question are of a type not previously listed as measured items. The significant of this possible " double inventory" of some materials will not be clear until there is some satisfactory resolution of the holdup violation problem. The inspectors did not discuss the matter with the licensee in any detail during the inspection.
The specific inventory items that might be considered part of holdup are listed below:
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Item hrea Pu Content (g)
Pipeline Sulution Ceramic 166 SX Organic Scrap 608 SX Aqueous Scrap 936 II Column Scrap 15 1,725 O
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Octobar 3.1974 C.pe 1115 tory Plutonium RO-III KERR-McGEE NUCLEAR CORPORATION SNM-ll74 Docket 70.1193 YEC s
Kerr-McGee Nuclear Corporation Oklahoma City, Oklahoma 73102
_ Table of Contents I.
Date License Initially Issued
- Page, II.
Purpose 1
III.
Basic License Material Control Amendments 1
IV.
Special Remarks Regard.ing License SNM-1174 1
V.
Inspection Violations and Status 21 A.
23 Materials Control and Physical ProtectionComp B.
23 VI.
Specific License Conditions for MUF 27 VII.
Quantitative Inspection Findings 35 43 D
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s Case,111s tory Plutonium RO-III KERR-McGEE NUCLEAR CORPORATION SNM-1174 Docket 70-1193 YEC Kerr-McGee Nuclear Corporation Oklahoma City, Oklahoma 73102 1.
Date License Initially Issued: January 21, 1970 1
1 License issued to Kerr-McGee Corporation, Oklahoma City, 8
i Oklahoma 73102 for operation of plutonium laboratory facili-2 ties, Cimarron Plutonium Plant.
Logan County, Oklahoma.
Expiration date of original license was January 31, 1971.
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Possession limits - 250 gm.
withPu-2fj',astheprincipaliso-tope, in the form of oxide or other compound.
I II.
Purpose:
Operation of plutonium laboratory facilities in the Cimarron plutonium plant, Logan County, Oklahoma.
III.
Basic License Material Control Amendments:
l Date Amendment Purpose 1/22/70 Amend. 1 Increase possession limits to include 2 gm. Pu-233, encapsulated as a sealed I
source at Cimarron Plutonium Plant and Cimarron Uranium Plant Logan County, Oklahoma.
l 4/2/70 SG-1 Amendment establishing controls for the l
safeguarding SNM for facility organiza-tion, operation, measurement and statisti-cal controls, shipping and receiving, storage and internal transfers, annual inventory, records and reports and management of material control system.
(See VI. Special License Conditions for MUF.)
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Date Amendment Purpose 4/2/70 Ltr.
Complete revisio :
Licensee: Kerr-McGee Corporation Kerr-McGee Buildinig Oklahoma City, Oklahoma 73102 Expiration Date: April 30, 1971 Possession' Limit:
a.
Plutonium:
(1) 360 kilograme', with Pu-239 as the principal isotope, j
in the form of oxide or other compounds.
(2) 2 grams, with Pu-238 as the principal isotope, encapsulated as a sealed source.
b.
Uranium enriched in the U-235 isotope: 1050 grams of j
contained U-235.
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c.
Natural or depleted 7 uranium:
j 700 kilograms.
Authorized Use:
s.
Manufacture of nuclear fuel rods, including:
(1) Conversion of plutonium 7
and uranium nitrates (or other compounds to oxides and mixed oxidesl I
(2) Production of U-Pu mixed oxides fuel pellets.
(3) Pabrication of nuclear l
l fuel rods containing U-Pu i
mixed oxide pellets.
b.
Recovery of plutonium from unirradiated scrap materials.
c.
Laboratory operations including l
analytical and quality control services in the areas of chemica]
metallurgical ~and yhysical testir l
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Date Amendment Purpose 6/10/70 SG-2 See VI. Special License conditions for MUF.
12/22/70 Amend. 1 Increase in natural and depleted uranium to 3200 kgs.
1/21/71 SNM-1231 Authorizatips to import from Canada 3 kgs. P.u.
5/20/71 Amend. 2 Increase in possession limits and addition of U-233; 100 milligrama.
i U-233 and 100 milligrams Pu-242.
3/24/72 SG-2 Amend.
See VI. Special License Conditions for MUF. Listed below is a summary to other basic changes to SG-2:
A new condition 2.5 is added:
2.5 All operations on FFTF material shall be performed completely independent of other sperations such that no other spec,isi nuclear material becomes mixed with FFTF material.
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A new condition 4.2 is added:
4.2 The licensee shall retain a samp3e of pellets for the i
Division of Nuclear Materails Safeguards from each l
shipmen't, identical to that takes for his measurements.
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A new Section 9 is added:
i 9.0 PHYSICAL PROTECTION REQUIREMENTS i
9.1.0 Definitions applicable to Physical Protection Requirements l
9.1.1 Except where spec 5fically noted, the re-quirements contsized in these licenge conditions are in addition to those speci-fied in Part 73. In any case where incon-sis.tencies may apgear, the license conditions shall prevail.
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9.1.2 The following terns shall have the meanings defined in 10 CFR Part 73:
authorized individual, guard, lock, physical barrier, protected area, vault, and watchman.
9.1.3 "Intrusien alarm" means an electrical, electromechanical, electro-optical, electronic, or similar device capable of detecting intrusion by an individual into a building, protected crea, or plu-tonium access area, by means of actuated visible and audible signals.
9.1.4
" Plutonium access area" means any loca-tion within a protected area which is enclosed by a second physical ba.rrier or substantial interior partitions, and which contains plutonium.
9.2.0 Physical Protection Organization 9.2.1 A force of guards, watchmen and employees shall be' established to protect plutonium against theft and diversion and to protect the facility against sabotage which could result in a radiological hazard to the i
public health and safety.
9.2.2 The command and responsibility structure l
during both normal and threat situations shall 8
be documented.
9.3.0 Access Constraints 9.3.1 Plutonium shall be stored or processed only I
in a plutonium access area.
9.3.2 The licensee shall establish a separate plutonium access area for each vault or other location used primarily as a plu-I tonium storage area.
i 9.3.3 When manned, a plutonium access area shall be manned by two or more authorized individuals
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or the activities of a lone authorized individual shall be observed by anoth,er authorized individual. When unmanned, a plutonium access area shall be locked.
9.3.4 No personal vehicles shall be permitted within the protected area.
9.3.5 Personnel access to the protected arca shall be controlled by a guard or watchman.
9.3.6 Packages entering a plutonium ' access area shall be searched for devices which could aid an individual in the thef t or diversicn of plutonium or ir sabotage of a facility.
p.3.7 The licensee shall register visitors, vendors and other non-employees entering the protected area, recording name, date, time, purpose of visit, and person visited.
9.3.8 Visitors', vendors and other non-employees shall be escorted 5y a guard, watchman, or authorized indiviabal while within the protected area.
9.3.9 Access to each pittonium access area shall be under the contral of an authorized indi-vidual and access shall be limited to indi-viduals who requite auch access to perform 3
their duties.
t 9.3.10 Keys, locks, comb 3xations, related equipment information shall te promptly changed when-ever there is a possibility of their having l
been compromised, and on termination of any empicyee having acmess to keys,1+cks and combinations, etc.
9.4.0 Detection Aids i
j 9.4.1 The area along the physical barrier surround-ing the protected area shall be kept clear of i
objects that would aid in concealing an indi-vidual as follows:
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(i) When the physical barrier is a fence, such objects shall not be permitted to
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remain within 50 feet of the inside of the fence and 20 feet of the outside of the fence; (ii) When the physical barrier is an exterior wall of a building, such objects shall not be permitted to remain within 20 feet of the exterior wall outside the protected area.
9.4.2 The boundary area specified in 9.4.1 shall be illuminated so that any horizontal surface in the area receives at least 0.2 foot-candles of light at all times.
9.4.3 The perimeters of the physical barrier sur-rounding the protected area shall be inspected i
for eviden:e of breaching. hour's.'
or intrusion at intervalsnotexceedin(
9.4.4 Packages, vehicles, and the following classes of individuals shall be checked for concealed plutonium before exiting a building containing a plu~tonium access area:
(i) Each package and vehicle which have been within that plutonium access area; (ii) Each individual who has entered that plutonium access area; (iii) Each individual who is authorized to enter that pistonium access area.
I 9.4.5 Each plutonium access area when locked shall be protected by an intrusion alarm on active status.
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9.4.6 Intrusion alarms shall annunciate in a central
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place manned continuously by a guard or watchman.
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9.4.7 Design of intrusian alarms shall be guided by considerations similar to those set forth in Interim Federal Specification W-A-00450A (CSA-FSS), Alarm 5tstems, Interior, Security, Components for.
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I 9.4.8 In lieu of the provision of 10 CFR 73.33(b),
each intrusion alarm used in the protection of plutonium shall be tested for operability and functional performance at the beginning and at the end of each interval during which it is used for protection, but not less often than once every, 7 days.
9.5.0
Response
9.5.1 Cuards, watchmen, and other members of the physical protection force shall be trained, equipped, and prepared to defend against unauthorized removal of plutonium or sabo-tage of the facility.
9.5.2 The li'censee shall establish liaison with local law enforcement authorities (LLEA) with the object of forming a cooperative pit.n for using LLEA forces as part of the total response force during threat situations.
The licensee shall determine the response time for various LLEA force levels to arrive at the facility and shall incorporate these factors into his overall physical protection plan.
9.5.3 The intrusion alarm system shall be furnished with alarm points at locations such that an alarm summons guards or watchmen to the i
l building, protected area, or perineter of l
the plutonium access area involve.d. in no more than',5 minutesi,'
9.6.0 communications 9.6.1 Each guard or watchman on duty shall have the capability of continuous cocaunication with a manned central station. This individual shall have the capability and authority to call for reinforcements.
j 9.6.2 In addition to conventional telephone service, t
at least one other two-way voice communication link shall be establithed between the central station and the LLEA; this link shall utilize 9
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radio or some other electromagnetic means capable of supporting two-way voice communi-cation and must be independent of offsite i
transmission lines, j
9.6.3 All communication equipment shall have the capability of operating for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Irom power sources independent or the primary power source for the facility.
Date Amendment Purpose 2/23/73 SG-2 Amend.
License Condition 9.4.1 changed as follows:
9.4.1 The area along the physical barrier surround-ing the protected area shall be kept clear of objects that would aid in concealing an individual as follows:
i (i) When the physical barrier is a fence, such objects shall not be permitted to remain within 60 fema _of the inside of the fence and ED fee,tFof the outside of i
the fence with"the following exception:
I (a) Emergency power equipment consisting of a generator and two (2) trans-formers'are permitted as shown on i
Kerr-McGee Corporation's drawing
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number CPP-100-M-630, SG-2, dated April 4, 1972.
(ii) When the physical barrier is an exterior l
wall of a building, such objects shall not be permitted to remain within 20 fa*ME of the exterior wall outside the prot (cted' area.
Date Amendment Purpose 5/5/73 MPP-1 Modification to safeguards amendment (SG-2) to reflect organizational change within AEC, (See VI.
Special License Conditions for MUF)
Section 9.0, Physical Protection, is as stated above.
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9 Date Amendment Purpose 1/2/74 Ler.
Corporate name changed effective January 1,1974, to Kerr-McGee Nuclear Corporation with only one basic amend-ment to the current license.
1.
New address: McGee Tower Oklahoma City, Oklahoma 73102 3/6/74 MPP-1 Amendment deleting old License Condition 9.0 by adding the following:
4 9.0 FACILITY SECURITY 9.1 The licehsee shall implement and comply with the facility security plan for the plutonium plant dated January 5, 1974, as revised February 27, 1974, and as modified by these license conditions.
9.2 No statement in the licensee's facility security plan shall relieve the licensee of a requirement of 10 CFR Part 73 unless granted in a specific exemption or excep-g tion set forth as a condition of this license.
8 9.3 In addition to the commitments contained in the licensee's facility security plan, as revised, the following additional conditions shall be complied with on and after March 6, 1974.
e In any conflict between the licensee's facility security plan and a condition below, the condition shall be complied with by the licensee.
l 9.3.1 The licensee shall include drawing SG-2 of i
the facility security plan dated January 5, l
1974, as an addendum to the February 27, 1974 revision to the plan, or modify drawing SG-2 i
of the February 27, 1974 revision, to include j
the levels of illumination at the various points in the isolation zone.
The',iaIo1 Ivindow in the makt wg11 of the plant 9.3.2 shall be alarmed to detect' unauthorized opening and locked from the outside. In addition, the g
licensee shall comply with the search requirements t
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of 10 CFR 73.60(a)(6) and 73.60(b) for any transfers through this access point.
9.3.3 All door hinges shall be welded in place or secured in a manner such that removal from the exterior is' precluded.
9.3.4 The licensee shall select metal, explosives, and special nuclear material detectors which have the detection capabilities specified in Regulatory Guide 5.7, " Control of Personnel Access to Protected Areas, Vital Areas, and Material Access Areas."
At the point of the exit search from a mate-rial access area, the licensee shall use a metal detector in conjunction with the special nuclear material detector.
9.3.5 The licensee shall install a motion detector in the storage vaultiwhich sha'll meet the requirements or 10 CFR 73.50(d)(1).
9.3.6 The licensee shall instruct the armed members 8
of the licensee's security organization to i
use their firearms as appropriate to protect the special nuclear material from theft and the plant from industrial sabotage.
9.3.7 The licensee shall employ operating personnel l
as a supplement to the security organization during security threats to the plant.
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9.3.8 During any emergency or drill evacuation from a material access area when normal exit search l
requirements cannot be met, the licensee shall l
conduct the evacuation under conditions which assure that personnel will be kept under obser-vation until they return to a material access area or until a normal exit search is conducted, in order to minimize the opportunity for diver-I sion of special nuclear material during such l
evacuations.
i 9.3.9 The licensee shall document the arrangements that have been made with the local law enforcement authority concerning assistance capability during
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9.4 The inner barrier of the plutonium plant designated as the physical barrier of the material access area shall meet the substantial construction requirements of 10 CFR 73.2(f)(2).
9.5 The door between the ex _aus.t a1Q rnom'iRoom 2011 and the supp1v sir fan room Room 2074 shall be alarmed to detect unauthorized opening in accordance with 10 CFR 73.50(d)(2) and 73.60(c).
9.6 In addition to the visitor's registration data provided for in the licensee's facility security plan, as revised, the licensee shall require all visitors to register the name of the person to be visited in accordance with 10 CFR 73.50(c)(5).
9.7 The plunger type intrusion alarus do not meet the requirements of Interim Federal Specification W-A-00450 B (GSA-FSS) and are not tamper indicatipe The licensee shall install balanced magnetic swit g.
type intrusion alarum o.n all emergency exits and all normally locked points of ingress and egress in accord-ance with 10 CFR 73.50(d)(1) and (2) and 73.60(c).
9.8 The licensee shall provide for both central alarm stations to be continually manned in accordance with 10 CFR 73.50(e)(1) and (3). During a security organi-ration response to a security threat, the central alarm stations are required to be manned.
9.9 The licensee shall assure that an individual is not used as a guard or a watchman unless such individual has been properly trained and equipped.
9.10 The licensee shall report security threats to the AEC in accordance with 10 CFR 73.'71(b).
9.11 The licensee shall submit all changes or revisions to the facility security plan to the AEC in accordance with 10 CFR 70.32(e).
9.12 The licensee shall test all intrusion alarms for operability and required performance in accordance with 10 CFR 73.50(f)(2) and 73.60 (d)(2).
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9.13 The licensee shall maintain records of the names and addresses of all authorized individuals as required by 10 CFR 73.70(a).
9.14 The licenses is granted'an exception from the requirement that the' emergency power supp1v.be located within a vital area provided that the licensee complies.with the commit-ment for a pecondary emergency power suppiv:As specified in Paragrapn 2.2 of the licensee's facilit'y security plan, as revised.
9.15 The licensee is granted an exception to the requ'irement that the search for concealed SNM be conducted at the material access area exit point provided:
9.15.1 Such search of all individuals is conducted within th'e corridor immediatelyto,utside the locker rooms as indicated on Drawing SG-1 of the licensee s security plan, as revised. The licensee shall locate the detectors such that the location of the detectors in the corridor precludes any individual from exiting the material access area and not being searched for concealed special nuclear material.
9.15.2 that an SNM detecto;r he maintained and employed within thq airlock adjacgnt.to the shipping / receiving doqs on the p st.'
side of the plutonium bull ~ditg.
9.15.3 All packages exiting the material access area via the corridor shall be searched by the indi-vidual manning alarm station fl.
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9.16 The licensee is granted an exception to the requirement for search of individuals and packages at the entrance point into the protected area provided:
9.16.1 That a weapon,(metal) detector is located outside the. guard station (alarm station #1) i j
either in t'ne breezeway or witpin an enclosure constructed within the breezeway yuch that an individual is searched for weapons prior to entry into the guard station.
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Y 13 9.16.2 That an electric door lock is provided on the outside door to the guard station which is operated from within the guard station.
9.16.3 The licensee shall nrotect the' guard house (alarm station ID py covering 7he windows and doors with Juliet-resistant material equivalent to' two (2)_, flush mou@.ag o_f 3/16-inch L7ega3 Any walls of this guard house not 'canstructed of concrete, brick, or cement black shall be similarly protected.
9.16.4 All handcarried packages remain outside the guard station until an authorized individual or the guard supervfsor can relieve the guard at the alarm statica such that the guard can retrieve and search the packages.
9.17 The licensee is granted an exception to the definition of material access area and the permissible activities therein with respect to the various labsratory and maintenance areas within the plutonium facility as indicated by Drawing SG-1 of the security plan provided:
9.17.1 That when an area is shut down, af ter the plutonium has been removed from that area, two individuals, at lease one of whom is an author-ized individual, inspect the area to verify that no plutonium remains within the area other than residual holdup as allowed during tornado condi-tions.
9.17.2 ne storage areas in the fabrication area and in the assembly area shall be protected by intrusion alarms whm these areas are unoccupied.
9.18 The licensee is granted an excegcion to certain commitments and requirements which are depardhnt upon the acquisition and installation of equipment and/ar completion of new construc-tion. This section does not re3ieve the licensee from any commitment of the security plan,, condition of license, or requirement of 10 CFR Part 73 unless specified below, and such exceptions are granted only until May 6,1974. If acquisition and installation of equipment or new construction I
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for which a specific exception has been granted is completed prior to May 6, 1974, the licensee shall comply with the security plan, conditions of license, and requirements of 10 CFR Part 73, from which the exception is granted.
9.18.1 The licensee shall station an individual in the uranium plant office ar,ea knd shall provide for two-way radio communication capability between the primary central alarm station and this individual.
9.18.2 The licensee is granted an exception from the commitment to use detectors to search individuals entering the plutonium facility protected area provided a hands-on search is performed under the surveillance of a guard. The licensee shall conduct the search at the points identified in License Condition 9.16.
9.18.3 The licensee shall employ the contract guard service as specified in the licensee's security plan, as revised, provided that the size of the temporary guard force is as specified in the lice'nsee's plan for the permanent guard force.
l 9.18.4 The licensee is granted an exception to the l
requirement that all alarms meet Interim l
Federal Specification W-A-00450 B (GSA-FSS) provided existing alarms are maintained until replaced with alarms meeting the above speci-fication.
l 9.18.5 The licensee is granted an exception to the badge requirements of the security plan pro-vided current badge practice is continued until the new badging system is available.
9.18.6 The interior portion of the isolation zone l
around the perimeter of the protected prea shall be patrolled by a guard or watchman my fifteen (15) minu.te intervals except during the.. daylight hours when the patrols may be sti,two (2,hour i
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15 intervals.
The guard or watchman on patrol shall contact the individual in the guard house at least once during each patrol interval.
Date Amendment Purpose 3/19/74 MPP-1 Revision to Condition 9.17.2 above as follows:
9.17.2 The licensee shall store special nuclear material only in AEC-approved storage areas.
These storage areas shall be locked and protected by motion detector intrusion alarms vnen the storage areas are unoccupied.
3/25/74 MPP-1 Amendment incczporating license conditions for transportation security as follows:
10.0 TRANSPORTATION SECURITY 10.1 The licensee shall follow the plan for protection of specfal nuclear material in transit as submitted with letter dated February 22, 1974.
I 10.2 No statement in licensee's security plan shall relieve the licensee of a requirement of 10 CFR Part 73 unless granted in a specific exemption or exception set forth as a condition of this license.
10.3 In addition to commitments made in the licensee's transportation security plan the following additional conditions shall be complied with:
10.3.1 The licensee shall require the agent or carrier who has an AEC-approved transportation security plan to notify him of any changes made to the originally-approved AEC plan before the changes are implemented. Kerr-McGee shall determine whether a change decreases the effectiveness of the plan, and if it does, shall assure that the change is not implemented until it has been approved by the Commission.
l-16 10.3.2 The licensee shall assure that tri-State Motors, Inc. has in advance of tne shipment determined the radiotelephone or telephone call-in times, determined the applicable law enforcement agency telephone numbers, and recorded the persons and telephone numbers to contact in case of an emergency.
10.3.3 The licensee shall assure that. the local law enforcement authority and the USAEC Directorate of Regulatory Operations, Region III, shall be notified immediately if a call has not been received at the sche,duled call-in time and efforts to establish communications with the vehicle have failed.
10.3.4 The licensee shall assure that the' Security Officer is responsible for notifying the person who delivered the shipment to a carrier for transport immediately upon arrival shipment at its destination and within,of a 30 minut'es of a scheduled arrival time if' the shipm'ent has not arrived as planned.
10.3.5 The licensee shall assure that the Manager of Administration and Accountability will notify the AEC immediately after the shipper has been informed of a late shipment, unless i
the reason for the delay is known, the ship-l ment is safe, and a new arrival time has been l
established.
10.3.6 The licensee shall assure that tamper indicating seals shall be used to secure each shipping container of SNM which requires protection in transit.. Seal identification shallbeprovidedto'Ifi-StateMotors.Inc.!,
and to the consigned prior to each shipmeds -
and recorded in the Kerr-McGee shipping records.
10.3.7 All information except item (1) (small"L")
listed in Paragraph 5.5.6 of your February 22, 1974 plan shall be recorded before a shipment is made.
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Y 18 3.5 Material accounting data shall be adjusted for any measurement bias, as determined under Condi-tion 3.3.2, which exceeds 10% of its standard deviation.
3.6 The data generated under the measurement control program shall be utilized to monitor and control measurement performance.
3.7 The measurement program required under this section shall be reviewed annually by the Safeguards Specialist.
Results shall be documented and reported to licensee management.
3.8 Limit of error calculations shall include considera-tion of both random and systematic errors in all com-ponehts of measurement. All identifiable covariance effects shall be taken into account in the calculations
.of LEMUF.
(SEE SECTION VI, SPECIAL LICENSE CONDITIONS FOR HUF FOR CONDITIONS 3.9, 3.10 AND 3.11.')
6.0 Inventory
,1 6.1 The licensee shall follow the material control and accounting plan entitled "Cimarron Plutonium Plant Material Control Plan," dated April 27, 1974, and as i
revised with the exception of paragraphs 1.2, 4.0, 5.8, 5.11.2, 6.1, 6.3, 6.4, 7.2, 7.3, and 7.4 and l
Appendix I, and all tables attached to paragraph 5.11.1.
6.2 No statement in the licensee's material control and accounting plan shall relieve the licensee of a requirement specified as a condition of this license or of a requirement of 10 CEL 70 unless granted in a specific exemption or exception set forth as a condi-tion of this license.
6.3 Tamper-Safing l
6.3.4 Two individuals shall attest to the contents of containers and vaults prior to tamper-safing.
Seals shall be applied immediately af ter measurements or sampling.
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19 6.4 Performance 6.4.1 Each inventory team shall consist of at least two individuals.
6.4.2 All special nuclear material shall be measured at the time of physical inventory except those items previously measured whose integrity has been maintained by tamper-safing and those items exempted by Condition 3.1.1.
Each such item shall be checked for verification of its physical presence.in its assigned location, and for verification of intact tamper-indicating devices.
(SEE SECTION VI, SPECIFIC LICENSE CONDITIONS FOR MUF FOR 6.4.3 AND 6.5.) -
7.0 Records and Reports 7.4 All measurement source data shall be included in the accounting records retained for five (5) years.
7.5 The licensee shall submit a progress report covering the material control and accounting j
improvement program every four (4) months starring in September. 1974, to the Materials and Plant Protection Branch, Directorate of g
Licensing, USAEC, Washington, D. C. 20545.
Date Amendment Purpose 7/19/74-Ltr An amendment to extend exceptions as follows:
1.
The date for completion of additions to the primary alarm station is extended until May 10, 1974.
2.
The date for completion of the second alarm station is extended until May 24, 1974.
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Date Amendment Purpose 5/10/74 MPP-1 Amendment incorporating revised Sections 3.0, 6.0, 7.4 and 7.5 as foll6ws:-
3.0 Measurements and Statistical Controls 3.1 The licensee or his designated agent shall measure,
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except as specified in Condition 3.1.1, the uranium, plutonium, and U-235, content of all special nuclear material receipts, shipments, waste i
discards, and material inventoried; and the isotopic
' content of offsite plutonium receipts and shipments.
3.1. }, Measurements are not required on sealed PuBe sources, and those samples intended for analysis and testing which have been deter-mined by other means to contain less than 10 grams U-235 or Pu each.
3.2 Each fuel pin shall be nondestructively overchecked to verify the presence of the assigned special nuclear material content.
3.3 An ongoing measurement control program covering all SNM accounting measurements shall be maintained.
3.3.1 All measurement systems shall be calibrated I
against standards over the range of operation.
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3.3.2 A standards program shall be maintained to provide a minimum of two measurements of e
1 standards per week for each measurement type.
3.3.3 A program of replicate sampling and measure-ment of process materials shall be maintained to provide a minimum of fifteen (15) repre-sentative data sets for each measurement type per material balance period.
l 3.4 The licensee shall determine measurement biases and systematic errors from the standards program and t
random errors from the replicate sampling and measure-g ment of process materials.
Estimates of random and systematic errors shall be updated every material I
balance period and used in the determination of current LEMUF.
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20 Date Amendment Purpose 3.
The date after which the metal detector must be used in con-junction with the SNM detector is extended until May 24, 1974.
4.
The date for movement of the TV camera from the outside location into the reterial air lock is ex-tended until May 24, 1974.
5.
The date for installation of the exhaust fan room alarm is extended until May 31, 1974.
7/25/74 MPP-i An amendment to Condition 9.3.2 as follows:
9.3.2 The licensee shall comply with the search requirements of 10 CFR 73.60(a)(6) and 73.60(b) for transfer t;hrough thelsamples window in the east wall or the plant. In adalcion,'this window shall be protected by one of the followizg methods:
l (a) The window shall be alarmed to detect unauthorized opening and locked from the outside; or (b) The window shall be equipped wish a device or structure cajable of preventing the j
unfetected passage of plu-torium through the window to the outside.
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5 21 IV.
Special Remarks Regarding License SNM-1174 In Section VI, Special License Conditions for MUF, note the section, " Treatment of Equipment Holdup." Also note License Condition 6.2 of Amendment MPP-l' dated 5/573 where equipment holdup was to established by June 30, 1973.
Since July 29, 1973..the licensee has been using a set inventory holdup quantity of 18,700 gm( From data provided by the licensee to RO-III inspector during a' meeting on July 25, 1973, and other documents on file at Herdquarters, the following tabulation has been constructed from the licensee's Material Balance Stateme of 3/12/73, S/14/73, 6/11/73 and 6/29/73.
The sequence of events leading to the MUF listed for the period March '72 to 7/7/72 was as follows:
1.
January 16, 1972 - physical inventory date of first regulatory inspection covering the period from first receipt of material, 2/21/70.
2.
January 17, 1972, to March 1972 the licensee cleaned out the system in preparation of pro-cessing Pu for the FFTF.
l 3.
March 1972 - the licensee gamma measured equip-i ment and determined that'1,100 gnEg;.of b,rivately-oM non-FFTF plutonium was in the systE~
4.
Between March and July 1972 FFTF plutonium was I
introduced into the system.
5.
j July 7,1972, the licensee stated ',4',539 gag, of plutonium was held up in the syst'em from process-I ing FFTF material between March and July 7,1972.
6.
j Ergo, from above the plant total of.$63jl for the period March 1972 to July 7,1972 is, established as follows:
March -
j July 7,'Wiwately.:-ages 1,100 gas.
1972 FFTF (7.,539' s l
Total 15,639' t
t' l4 reh w Y M h N T h is g t Cean ee.
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Kerr-McGee Plutonium Holdup Grams i
Total Scrap Vault Ceramic Pellet Fabrication Plant MUF for the Period:
March '72 to 7/7/72 3728 659 1252 5639 7/7/72 to 3/12/73 (3115) 8983 (41) 5827 Cumulative to 3/12/73 613 9642 1211 11466 3/12/73 to 5/14/73 (128) 1575 (219)
(45) 1183 Cumulative to 5/14/73 485 11217 992 (45) 12649 m
5/14/73 to 6/11/73 2524 (2)
.(671) 76 632 9
2568 2
Cumulative to 6/11/73 3009 (2) 10546 1068 587 9
15217' 6/11/73 to 6/29/73 3069 1389
_(975) 3483 March 1972 to June 29, 1973 6078
'2) 10546 2457 388 9
18700
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1 - Facility Table shows zero HUF; however, the balance sums out with a MUF of (2) gas.
2 - The elimination of within plant receipts and removals do not equal by nine grams, thus causing a plus 9 grams MUF.
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Y 23 V.
Inspection Violations and Statua (N.B., tabulated below are inspections for Health and Safety and Materials Control and Physical Protection.)
A.
Compliance Inspections for Health and Safety:
Inspection Dates Reearks 12/8-10/70 Letter D'cember 29, 1970, noted four items e
of noncompliance:
1.
Drums of Pu bearing waste material stored periodically in a semitrailer parked adjacent to the loading and receiving dock.
2.
Pu nitrate solutions, low level, in polyethy-lene bottles stored in the vault are not vented continuously.
3.
Normal and/or depleted uranium, during the period 9/15/70-12/10/70 was in excess of 700 kg. possession limit.
The 12/29/70 noncompliance letter notes that i
Lic. Amendment No. 4 dated 12/11/70 corrected the above items of noncompliance.
1/19-21/71 No items of noncompliance or safety significance.
7/20-22/71 An investigation of unplanned release of Pu l
on 6/16 and 28/71 and exposure of ten employees.
The investigation confirmed the company's statement that improper piping design permitted the Pu-bearing liquids to enter the chemical addition system through a header with sufficient force to flow out of a funnel which on both occasions had not been properly valved off.
The company was cited for not immediately notifying the AEC of the 6/26/71 incident which resulted in loss of use of the scrap recovery area for a period of about one month.
10/21-22/71 Nc items of noncompliance.
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h 24 Inspection Dates Remarks 2/17-18/72 No items of noncompliance.
6/14-16/72 No items of noncompliance.
N.B., two employees were exposed to 6.6 times HPC for soluble Pu on 2/24/72.
10/19-20/72 No items of noncompliance.
N.B., Four employees were potentially exposed to airborne Pu concentrations in excess of occupational exposure limits.
2/12-16/73 Two items of noncompliance:
1.
Nuclear criticality safety not audited on a monthly basis.
2.
A glove box in Pu waste recovery not posted with a hood inventory record.
3/7-9, 13&l4, An inspection to examine the circumstances 18629/73 of the fire which occurred during bag-out from a glovebox.
No items of noncompliance; however, there were certain matters requiring attention:
1.
Delays were noted in the collection of bioassay samples and between the submittal time for analyses and the receipt of results.
2.
The medical consultant was not notified immediately.
3.
Prior to the fire, during bag-out operations i
e respirators were not required.
l 4.
The continuous room air monitor chart ran out the day before the fire.
6/18-22/73 Items of noncompliance:
1.
Pu glovebox 1A did not have posted a "Clovebox Status Sheet" stating the fissile content in the glovebox.
2.
Fu glovebox 40 contained 3 one-liter containers, two of which were less than 12 inches apart.
f
)*
Y 25 Inspection Dates Remarks 9/17-21/73 An inspection resulting from a phone call to the Chairman's office regarding allegations of spills of plutonium and some leakir3' tanks.
In summary, the report states there is little doubt but that strained management-employee relations were the probable basis for the allegations. Also, as a result of the inves-tigation, it is concluded that no significant health and safety problems were associated with the occurrences reported in the allegations.
Items of noncompliance were as follows:
1.
No offsite surveys were performed on April 17, 1972, to evaluate two employees leaving the facility in a contaminated 1
condition.
2.
Records were not maintained of survey results of residual contamination levels on the solid traste storage van prior to coating the undercarriage of the van with paint in August 1973.
3.
Waste shipped for burial was not in a dry I
j solid form.
4 9/17-21&26/73 Items of noncompliance:
1.
During the week of July 8-14, 1973, an i
employee was exposed to airborne concen-trations which when averaged over 40 hrs.
j were 1.3 times the specified limits.
I 2.
Only one inspection of Raschig rings has j
been made since plant startup which inspection did not fulfill the require-ments of the standards.
j 3.
On 2 occasions wastes shipped for burial i
were not in a dry solid form.
l 4.
An organization structure change made g
which included filling the License and I
Safety Officer position with an employee whose experience did not meet conditions of the license. These changes were not formally reported to the AEC.
i l
l 7 % p p o,, k <e l u d,;, kd./
k 26 b
Inspection Dates Remarks 5.
The required management appraisals were not doc 6mented for one-hour tornado alerts received by the licensee.
The items of noncompliance cited,during the 6/18-22/73 inspection were considered resolved.
2/11-15/74 Items of noncompliance:
1.
During the week of 10/28-11/3/73,seven employees working in Pu Rm. 128 were exposed to airborne concentrations which averaged over 40 hrs. were 1.2 and 1.6 times the specified limits.
2.
During the week of 11/25-12/1/73, an employee surveying glovebox gloves in Rm.127 was exposed to airborne concen-trations of Pu which averaged over 40 hrs.
was 1.5 times specified limits.
3.
During the week of 2/10-16/74, two employees working in Rm.124 were exposed to airborne concentrations of Pu which when averaged over 40 hrs. were 1.4 times specified limits.
l The items of noncompliance cited during the 9/17-21 and 26, 1973 inspection were considered resolved.
5/20-24/74 Items of noncompliance:
i 1.
The annual requirement for testing the g
final high efficiency filter, Bank No. 33, had not been met.
2.
Improper methods for calculating criticality safety analysis was used for vault storage.
3.
Nuclear safety asalyses made prior' to 1973 had not been verified by the Licensing and Regulations Officer.
4.
No evidence was produced that the physical I
inspection of several equipment and facility j
changes had been made prior to usage.
l t.
l 5....
t
h 27 l
Inspection Dates Remarks 5.
Plutonium had been stored outside gloveboxes in sub-floor storage wells and glovebox storage wells.
The items of noncompliance cited during the February 11-15, 1973 inspection were considered resolved.
B.
Material Control and Physical Protection Inspection Report No.
Date Remarks S0-II-87 Sec. I Initial inspection for Pu facility.
1/27/72 For the period of first receipt of Pu on 2/21/70 through 1/16/72. The Sec. II inspection included both material 5/5/72 control and physical protection.
Five items of noncompliance:
- 1..An independent internal review had not been conducted of the overall system of SNM control within the last 12 months.
2.
LE's were not included on forms docu-menting receipts or licensee record copies of forms reflecting shipments.
3.
Form reflecting receipt of SNM not completed and distributed within required time period.
i 4.
Items of enriched U >20% U-235 l
stored outside not protected by separate fencing within the large protected area.
5.
Records were not maintained which show all tests, inspection and maintenance performed on security containers, intrusion alarms and protected areas.
de relewd m MI TM p9 <-
3-
Y 28 Inspection Report No.
Date Remarks 070-1193/73-01 2/16/73 A physical protection inspection only.
Items of noncompliance:
1.
A permanent cement structure housing transformers and the emergency power supply system located within 15 to 20 feet of the inside perimeter fence; Also eight 55-gallon drums of liquia solvents located approximately ten feet from inside the fence.
2.
The perimeter of the physical barrier surrounding the protected area is not inspected for evidence of breaching or intrusion during normal work hours.
3.
The Pu storage area was not protecteo by a steel door or an intrusion alarm, a
4.
Records indicated that testing of the e
intrusion alarms for operability and functional performance was not being accomplished as required.
I The prior item for physical protection of noncompliance is repeated above, t
l 73-03 3/27/73 A materials control inspection.
Sec. I Items of noncompliance:
1.
Inadequate management review of measurement system.
2.
Monthly inventories not conducted.
3.
NBA and plant records not reconciled.
4.
Audit unsatisfactory of ' accountability records.
73-03 8/20/73 Evaluation of acalytical samples indicated Sec. II significant disagreement on one of the a
U-Pu nitrate solution samples.
Investi-gation failed to disclose a positive reason for the difference.
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29 Inspection Report No.
Date Remarks 73-08 2/13/74 Item of noncompliance:
The LD1UF for five. 30-day matettal balance periods s_xceeded 1.5 kg,'as stated as a condfEion of'Re~ri1McGee's license.
(See VII - Quantitative Findings.)
s Items of noncompliance identified in the February and March 1973 inspections were not within the scope of this inspection.
2/28/74 Region III was notified by telephone
~
that the February monthly plutonium inventory indicates a positive MUE loss j uantity.,of 11 Q as Pu wJth associcted limits of error of, 3.4 kg.s.
Pu..MUF exceeded LEMUF and LEttdF con-tinues to exceed specification.
3/1/74 Region III personnel discussed by telephone the February inventory results with Kerr-McGee management.
The licensee s:opped production activities as of March 1, 1974 with the exception sf the pellet sintering furnace and initiated a new inventory on March 1,19'4.
Region III also informed the licensee that it was our understanding. hat production activities l
would not be resumed until the MUF had been resolved to the satisfaction of both the licensee axd Region III. Results of this telephone conversation were confirmed i
by letter datei March 5,19.74, from l
J. G. Keppler to P. S. Dunn,' Kerr-McGee.
i The February 1 ventory data and results 8
of Region III telephone conversation
~
were forwarded to Headquarters.
l kg/ra s c CW/ N W
30 w
Inspe:ction Report No.
Date Remarks s.
3/6/74 Directorate of Regulatory Operations Notification of Incident:
On February 28, 1974, Region III was notified by Kerr-McGee by telephone that the February monthly plutoniva,phy-
.mical inventory indicated a MUFilog of 11.5 kilog a m of plutohium with a Bessurement uncertainty estimated by thelicenseeto'b[+8.4kilograssPu.
The MUF quantity ir significant oecause the January 1974 was. also's loss ~
ventoryJF quantity kggJ. Also of P
concern is'the uncertainty va]ue of
+0.4 kilogrims'of plutonium @ ich excee43, the operating' limitation of L),,hilog specified by technical specificacions, g 1
Invastigation by the licensee has -
failed, so far,,to reveal"bxact causes of the MUF. Regulatory Operations has no evidence thac the MUF might have 3
been diverted.
I Fabrication of fuel has been stopped and a new inventory is being' conducted.
Fabrication of fuel will not be resumed until the MUF is resolved to the satis-faction of the licensee and Region III.
8 An inspector is at the site.
i, 3/14/74 Directorate of Regulatory' Operations i
Notification of Incident:
From March 1 through 11, 1974, the licensee conducted a new inventory I
which involved an extensive cleanout of process equipment and a reevaluation of pr vious megsurements, and accounted for'jLO.1 krs_Pm, reducing the February l
HUF'to; (4 k p'(s'ince August 1973, the S
i cumulative MUF k,6 kggpout of a total throughput of 480 kgs.; This MUF is not i
r bis page fan le.relVA k lpb)
I
. y-31 Inspection Report No.
Date Remarks cons'idered significant and in believed to be in the process piping systems.
There is no indication of thef t or diversion.
The licensee resumed production on March 11, 1974.
3/20/74 AEC representatives (Region III RO:HQ, DL, and DS) met at Headquarters to discuss Kerr-McGee LEMUF problems in preparation for a meeting with Kerr-McGee management the following day.
3/21/74 AEC representatives met with Kerr-McGee top management at Headquarters.
74-02 4/11/74 A physical protection inspection -
ltems of noncompliance:
1.
Storage vault combination lock j
., found broken and has been for y
1 approximately three weeks.
2.
Visitor log did not provide a g
section for purpose of visit and person visited. Over the past year several sheets did not indicate identity of escort.
3.
Records did not indicate that each alarm is checked by authorized
' personnel to determine cause.
i 74-03 4/15/74 SNM inspection - no items of noncom-pliance. All items of noncompliance noted during the last inspection were found to have been resolved.
74-04 5/24/74 Physical Prctection inspection.
Items of violation found in the prior inspection reported 4/11/74 that were not corrected are.,repengf.here.
d 1.
The method,f,TV camere<,to provide immediate cIapability'to the guard upon activation o,fgPu-monitor alarm had not been corrected.
[ho's$djC Dn N N W l;$
l n 0
Y 32 Inspection Report No.
Date Remarks' 2.
Communication equipment tested weekly instead of at the beginning of each security personnel work shift.
3.1 Illumination of fence corner, front of Pu buildgg main entry area and fence line,;N_id not meet the minimum 0.2 foot candles requirement.
4.
The sample window in th e.as't wall of the plant had not bee (n equipped with an alarm or exterior lock.
5.
A metal detector has not been installed at the point of exit search from the material access, area.
6.
A action detector was found partially installed, but not operable or tied into the alarm console.
7.
, Protective personnel assigned to post and supervisory duties were not uniformed or armed.
8.
An alarm had not been installed on the door between the exhaust air fan room and the supply air fan room.
j 9.
Plunger-type alarms igaraad of j
balanced magnetic switch ' type 2'ntrusion alarms were found on emergency exits and normally locked points of ingress and egress.
- 10. The seconfary alarm annuncigtor had net en installed at Uranium Po*C 42.
- 11. t e trpt ed metal detector outside t<c'l c ard station #1 had not been i
coJL/ iced or operakie. Also an electric door lock had not been i
installed on the outside door to the guard station, j
- 12. Intrusion alarms had not been in-g stalled at the storage areas in the g
' fabricatios area and,in the inspec-don and assembly area. r
- 13. The metal. letector, a'1though installed in the' estarior breezeway for the purpose of searching individuals entering tie Pu plant protected area, was tot operational.
Thh pye can be relemd m htl 37-
4 Y
33 j
Inspection Repert No.
Date
_ Remarks The 14.
Onlyfyt ontractor guard was
- assi ne 4
to each shift instead of twigg Also, Kerr-McGee employees who h, ave been trained as guards were not armed or in uniform.
15.
Existing alarms had not been replaced with alarms meeting Interim Federal Specification W-A-00450B.
16.
A log containing name, badge number, time of entry, reason for entry and time of exit for all individuals granted access to a normally unoccupied vital area had not been maintained.
74-06 8/22/74 A material control inspection.
Item of noncompliance:
1.
On three occasions, whe'n delayed measurements were made, the licensee i
did not complete and report the measurements on a Form AEC-741 within the required 30-day period after receipt of Pu nitrate.
74-07 9/24/74 A material control inspection -
j inspection conducted 8/21-23/74.
Inventory date 7/2/74. Quantitative remarks regarding the physical inventory were not covered in the report.
I.
Items of noncompliance:
1.
Accounting data are not adjusted for biases, analytical and weighing, which exceed 10% of their standard deviations.
2.
Tamper-safing seals are not being used.
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35 VI.
Specific License Con'ditions for MUF:
Amendment SG-1 dated 4/2/70 3.0 MEASUREMENTS AND STATISTICAL CONTROLS 3.1 The licensee shall determine the U-235 and/or Pu content of all receipts, shipments and measured discards. The U-235 and/or Pu content shall also be determined for all material inventoried.
The limits of error
- associated with these quantities shall be determined. Sufficient measurements shall be made to substantiate the stated quantities and associated limits of error.
3.4 After any physical inventory the material unaccounted for (MUT) and the limits of error associated with the material unaccounted for shall be computed promptly.
The limits of error associated with MUF shall be calculated by statistically combining the limits of error determined for shipments, receipts, beginning inventory, ending inventory, and measured losses for the period since the last inventory.
3.5 If the quantity of MUF exceeds the associated limits of error, the licensee shall promptly notify the i
Atomic Energy Commission, Division of Nuclear' Materials Safeguards, District II, Oak Ridge, Tennessee.
The licensee shall invet*igate the MUF and notify the Division of Nuclear liaterials Safeguards within thirty (30) days after the initial notice, specifying the probable reasons for the MUF and the corrective action taken or planned.
I
- Limits of error as used herein means the boundaries within j
which the true (best) value of the parameter being measured lies with a probability of 95%.
i I
l 8.0 MANAGEMENT OF MATERIALS CONTROL SYSTEM I
8.2 l
An estimate of anticipated losses (measured discards plus MUF) for each period nf time between inventories shall be prepared for each MBA, with the concurrence 71a p.ye cm le e/eed in 66/
f
, 7-.
36 of the Manager, Administration and Accountability and shall be based on prior Experience, throughput quantities and rates, etc.
If losses exceed the estimate of those anticipated, they shall be investigated by the Manager, Administration and Acc'ountability and the results of his investigation shall be reported to the Cimarron Plutonium Plant Manager.
8.3 Any apparent loss of a discrete item or container of special nuclear material which cannot be resolved by an immediate investigation shall be reported to the Manager, Administration and Accountability, who shall promptly notify the Atomic Energy Commission, Division of Nuclear Materials Safeguards, District II, Oak Ridge, Tennessee, and shall conduct an investigation of the loss.
The Manager, Administration and Accountability, shall report the results of his investigation to the Cimarron Plutoni6m Plant Manager.
Amendment SG-2 dated 6/10/70 Condition 3.1 changed as follows:
3.1 The licensee shall determine the U-235, U-233, and/or Pu content of all receipts, shipments, intentional discards and material inventoried, along with the limits of error associated with these quantities.
The licensee shall make sufficient measurements to substantiate the stated quantities and associated limits of error.
Measurements are not required on items which have been determined by other means to contain less than ten (10) grams U-235, U-233, and/or Pu each.
Limits of error as used herein means the boundaries within which the true or best value of the parameter being measured liec with a probability of 95%.
I i
Amendment to SG-2 dated 3/24/72 l
A new condition 3.2 is added:
l 3.2 j
The frequency and quality of the measurements made to comply with the license conditions shall be controlled so that the limits of error associated with the plutonium material unaccounted for (LENUF)-for the 30-day period s
% pye be. relessd in bh/
en 1_
37 does not exceed the larger of. (a) 200 grams plutonium or (b) 0.5% of either the additions to or removals f plutonium in process for the month, whichever.is greater.
A new condition 3.6 is added:
3.6 At the completio,n of the Fast Flux Test Facility (FFTF)
- project, the licensee shall submit to the U. S. Atomic 4
Energy Commission, Division of Nuclear Materials Safe-guards, Washington, D.
C., a report which summarizes i
all components of the material balance for the project; the limits of error for each component, the cumulative material unaccounted for and the cumulative limits of error for the material unaccounted for.
This report shall be submitted within sixty (60) days after the last product shipment is made.
3.6 revised in its entirety as of 8/1/72:
1 3.6 If (i) the quantity of plutonium MUF exceeds its asso-ciated limits of error, or (ii) the limits of error associated with the plutonium MUF (LEMUF) exceed the limit spec *fied in Condition 3.2, the licensee shall promptly notify the Atomic Energy Commission, Division of Nuclear Materials Safeguards, District II, Oak Ridge, Tennessee.
The licensee shall conduct an investigation Washington, D.
C.,
within thirty-(30) days after theand notify the initial notice, specifying the probable reasons for the excessive values and the corrective action taken or planned.
I l
A new condition 6.5 is added:
6.5 The licensee shall close a material balance around i
plutonium in process, (by algebraically combining data j
for receipts, shipments, discards, beginning and ending l
inventories) at intervals not to exceed thirty (30)
I days.
Material in process means any plutonium pos-I sessed by the licensee, except in unopened receipts and ultimate product, where the ultimate product is maintained in a manner which ensures the integrity of previously made measurements.
All components of the material balance (additions, removals, and material on O
Q ge ca be volead in hU n
e
\\
38
\\
i 5
1 inventory) shall be determined on the basis i
measurement of each compone;nt and for the material un The material unaccounted for shall be determ the limits of error calculated within ten (10) d and after the completioh of the material balance.
ays Amendm&nt MPP-1 dated 5/5/73 License condition 3.1 remains as stated abov 6/10/70.
following: All other MUF conditions are superseded by the ated E
3.2 The frequency and quality of the measurements mad with the license conditions shall be controlle e to comply the limit of error associated with the material at for (LEMUF) for the 30-day material balance period d unaccounted not exceed one and one half (15)' kilograms of plutoniu oes 3.5 After any physical inventory, the material unacco (MUF) and the limits of error associated with unted for unaccounted for shall be computed promptly e material of error associated with MUF shall be calculated by The limits statistically combining the limits,of error determined for shipments, receipts, beginning inventory tory, and measured losses for the period since th
, ending inven-inventory.
e last 3.6 If (1) the quantity of plutonium MUF exceeds its a limits of error, or (ii) the limits of error associ t d ssociated with the plutonium MUF (LENUF) exceed the limit sp ae in Condition 3.2, the licensee shall promptly notify t e
Region III office of the Directorate of Regulatory e
Operations, U. 5. Atomic Energy Comnission l
take immediate action to investigate the cause f and shall excessive values.
or the notice, the licensee shall notify the Region III j
of the Directorate of Regulatory Operations in writin l
of the probable reasons for the excessive values and corrective action taken or planned.
l 3.7 If (i) the cumulative LEMUF for plutonium for a six period exceeds the larger of (a) C.5 kilograps of plutoni
?
-month um e
M
_e m = *e.
+9 9-m m
.e.
,-e w-,
V
(
/
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39 or (b) 0.5% of additions to plutonium in process for the period, or (ii) the cumulative MUF exceeds its LEMUF for a six-month period, the licensee shall l
promptly notify the Region III Office of the Direc-torate of Regulatory Operations, U. S. Atomic Energy Commission, and shall take immediate action to investi-gate the cause for the excessiva values. Within thirty (30) days after the initial notice, the licensee shall notify the Region III Office of the Directorate of Regulatory Operations in writing of the probable reasons for the excessive values and the corrective action taken or planned.
This evaluation shall be performed at the end of each 30-day material balance period for the previous six months. Under this condi-tion,' the first evaluation shall be performed for the July-December 1973 time period.
3.8 At the completion of the FFTF project, the licensee shall submit to the Materials and Plant Protection Branch, Directorate of Licensing, U. S. Atomic Energy Commission, Washington, D. C. 20545 with a copy to the Region III Office of the Directorate of Regulatory Operations, a report which summarizes all components of the material balance for the project; the limite of error for each component, the cumulative material l
unaccounted for and the cumulative limits of error for the material unaccounted for. His report shall be 1
submitted within sixty (60) days after the last product shipment is made.
4.0 and 5.0 - These sections are for Shipping and Receiving and l
Storage of Internal Transfers.
6.0 INVENTORY (only those parts of this section pertaining I
to MUF are listed) 6.2 Fixed values shall be established for the quantity and l
the limit of error of equipment b31 dup of plutonium by June 30, 1973, according to the procedure described in l
l l
your amendment application dated April 27, 1973. These fixed values shall be incorporated in subsequent inventory determinations with the exception of the inventory specified in Condition 6.6.
?
1% na cu Le eek-sd m MI l
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(
- p 40 6.6 A clean-out physical inventory of plutonium subject to this license shall be conducted at the end of the FFTF contract.
In addition, equipment holdup was discussed as follows:
TREATMENT OF EQUIPMENT HOLDUP Tour use of engineering estimates, based on past experience and engineering judgment, for the initial establishment of the quan-tity and the variability for the equipment holdup of plutonium at time of physical inventory, is acceptable. The appropriateness of your assigned values will be evaluated at the time of inspection by the Directorate of Regulatory Operations.
It is our intention that your LEMUF determinations shall include the variability asso-ciated with equipment holdup. Unless you can demonstrate otherwise, the holdup uncertainties should be treated as independent components in error propagation rather than dependent variables which would be subject to large covariance cancellation.
In response to your letter dated April 27, ye believe that your estimate of holdup variability of 1 kilogram for a single inventory is reasonable.
As a result of a review of the holdup information that you have provided, we believe the quantity of holdup assigned to your existing operation should fall within the range of 8 to 13 kilo-grams of plutonium.
In your letter dated December 15, 1972, you i
provided one estimate of holdup that was approximately 8 kilograms.
'In your letter dated March _.20, 1973, you proposed the use of a control limit for BPID of 5 kilograms. _ Assuming that you allowed approximate 1/ 2 kilograms' (3 sigma for LEMUF., h appears that your estimate for holdup quantity should not exceed L3 kilograms. At the recent meetings in Oklahoma City, it seemed to us that there j
was a consensus of those in att'endance that a holdup value in the e
g range of 8 to 10 kilograms was reasonable.
i l
Our acceptance of your inventory plan was predicated on the premise that you will be able to establish a reference inventory position i
that can be duplicated at the time of subsequent inventories within an j
acceptable allowance for process variation. It was pointed out in the recent meetings in Oklahoma City that the value for holdup cannot be varied over time to accommodate any occurrence of MUF.
i Once a value is established, there is little material control value in varying the reference quantity. However, a significant i
change in your equipment, process, or physical inventory procedures would merit reevaluation of the holdup value. Please notify us when you consider it is necessary to request a change in the referdnce holdup values.
1 7k pye ca-La alm & m MI.
.. ~... _., - -... -.. _. _ -. _ _ _ _ _ -. _
_, _ ~. - _
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9 l
Amendment MPP-1 dated 5/10/74 See Section III, Basic License Material Control Amendments for amendments other than for MUF.
3.9 In.accordance with the provisions of 10 CFR 70.51(e)(6),
the licensee shall, until May 2, 1975, establish and maintain a system of material control and accounting such that the limits of error associated with any MUF for the plutonium plant shall not exceed T.8 kilograms of plutonium per inventory period.
3.10 If (i) the cumulative LEMUF for plutonium for a six-month period exceeds the larger of (a) > kilograms of plutonium or (b) 0.5% of additions to plut' onium in proc'ess for the
~
period, or (ii) the cumulative MUF exceeds its LENUF for a six-month period, the licensee shall promptly notify the Region III Office of the Directorate of Regulatory Operations, U. S. Atomic Energy Commission, and shall take immediate action to investi;2te the cause of the excessive values. Within thirty (30) days after the initial notice, the licensee shall notify the Region III Office of the Directorate of Regulatory Operations in writing of the probable reasons for the excessive values and the corrective action taken or planned. The cumula-tive MUF and LEMUF evaluation shall be performed at the end of each six-month material balance period. Under i
this Condition the first evaluation shall be performed for the six-month period beginning with the September 1974 inventory.
3.11 By January 31, 1975, the licensee may request higher limits than those specified in 10 CFR 70.51(e)(5) based on system capability and demonstrated performance. The Commission will approve higher limits than those specified in 10 CFR 70.51(e)(5), if the licensee demonstrates:
(i) That he has made reasonable efforts and cannot meet the limits of error of MUF specified in 10 CFR 70.51(e)(5),
(ii) That he has implemented the program of improvement described in his plan dated April 27, 1974, and 7ks pp c.>n le re/~ red k U l
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^ * " ' '
42 (iii) That he will initiate a program to achieve additional improvements in his material control system so as to meet the limits specified in 10 CFR 70.51(e)(5).
6.4.3 Holdup factors shall be based upon measurements and updated at least every three material balance periods, except as specified in Condition 6.4.3.1.
6.4.3.1 The licensee may use the measured holdup value of 1.1 kilograms of plutonium until the inventory spe'cified in dondition 6.5 is conducted.
6.4.4 The Manager, Administration and Accountability, or his designated representative shall verify the completeness of each physical inventory.
6.4.5 Each plan $t MUF and LEMUF determination shall be verified by an individual not involved in the original calculations.
6.5 A clean-out physical inventory of plutonium subject to this license shall be conducted at the conclusion of the FFTF contract.
1 l
l 4
i J ev h j')df (Um C-YC NS*
I.,
" ' - - - " ' ' ' ' - ~ ~ ~ '
VII. Quantitative Inspection Findings A
?
Plutonium k[
Grams Inspection License Report Inventory Period ThroughputM MUF/
2 Limits No.
Date Covered Pu g % Throughput LE(MUF)
MUF LE(MUF) 1 N ' ros hout S0-II-87 1/16/72 let receipt
~370,547 4,172 1.13%,"
2/21/70 g1 through
/
1/16/72 p
j t
070-1193/73-03 3/12/73 1/17/72-
.129,808 836 0.64%g
{
3/12/73 r ~~
070-1193/73-08 3/
7/10/73-96,672 (2,319)4 2.4%
6,2991 /
5/. 1.5 kg. O 8/10/73/
3 1
8/10/73-98,811 (2,125)1 ~2.2%
6,1271/ "
5/
1.5 kg.
~
9/11/73 in lu l 5 kg.
9/11/73-121,550 807.-./
0.7%
6,3371/
5/
4 4
i 10/10/73 e
10/10/73-160,612 6,0361/
3.8%
6.5421/
5_/
I 1.5 kg. -
s-b2/
11/9/73 th p
the
's y
11/9/73-1 179,927 : t (6.647)N v3.7% able 6,8020.11:
5/
UF1.5 kg, 12/6/73 cc 5
our i
.es j3 070-1193/73-08 12/6/73 7/10/73-200,189 (4,248)b d. 2.1%
5_/
1.5 kg.
12/6/73 as 6_/
12/6/73-
.:265,352 1 I 6,4841/
2.4%
7,678 5/
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1/17/74 1/17/74-I: 274,794 H 11.474b! s 4.2% ss Ke8,364 se's
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2/15/74-299,851 10,006 II 3.3%
9.251 5/
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l VII. Quantitative Inspection Findings (Continued) i 7 - Cumulative data for the period 7/10/73 to 3/11/73 derived from _6_/ above.
8 - Book recorded quantities are shown. The physical inventory was conducted by the licensee on 7/3/74 while the RO-III inspection was conducted July 23-25. 1974.
The licensee had not finalized the physical inventory calculations or plant material balances at the time of the inspection.
9 - Quantitative information regarding the physical inventory was not provided in the report. The scope and purpose of the inspection was to investigate the licensee's compliance with license conditions regarding measurements and certain parts of the conditions regarding inventory.
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Lr COMMENTS ON CASE HISTORY PLUTONIUM RIII KERR-MCCEE NUCLEAR CORPORATION SNM-1174 i
DOCKET NO. 70-1193 l
YEC The preparation of the case history was 'an internal staff effort to extract from voluminous government docket files a concise summary of the inspection history of this fuel fabrication facility at Crescent, Oklahome, for the five year period 1970 to 1974. The staff effort was commenced in mid-1974 and continued on an as-avaiable basis into 1975.
The file material available at the time of preparation generally l
covered up through the year 1974, a period prior to the establishment of the Nuclear Regulatory Commission.
~
The case history covers both health and nuclear safety inspection results and material and plant protection inspection results.
From the inception of this license in 1970 to January 1975 the health and safety aspect of the licensee wqre under the cognizance of AEC Office of Regulation.
NRC has had cognizance over both health and nuclear safety and safeguards since its inception in Janaury 1975.
The compiled case history is directed primarily to a listing for the period under regulatory surveillance of weaknesses and items of non-compliance identified during inspections.
The history does not include a large volume of enforcement correspondence and subsequent actions taken as a result of the listed inspection items. Since 1963 this information has been made available in the public document rooms in those instances where the information is not of a proprietary nature or protected under common defense and security provisions.
4 During the period of FFTF (Fast Flux Test Facility) production at Kerr-McGee, j
significant regulation changes designed to provide strengthened physical l
protection and material control for special nuclear material in plants and in transport and protection of plants in which the materials were used, became effective.
Kerr-McGee has generally been responsive to the, continually changing and upgrading of the safeguards programs and has taken proper corrective actions to the items of noncompliance.
Prior to May,1974, date of significant new pateriaJ control and physical protection regulations, Kerr-McGee allocated 18.7 kgs Pu to process holdup and was permitted to carry this constant valha on inve' tories. The value n
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was based on measurements of plutonium input and output during startup of the FFTF production system.
Subsequent to this date, the Commission required the holdup to be measured. Kerr-McGee had some difficulty in measuring the actual holdup quantity because of equipment accessibility and plant design but eventually was able to accomplish the requirement by using nondestructive measurement techniques.
During the twenty-nine month period, M'rch 1972 to September 1974, a
nine inspections and one investigation were conducted.
As a result of 'hese inspections and investigations, nineteen items t
of noncompliance with AEC regulatory requirements were found. Four of the nineteen items of noncompliance related'to exposure of eleven Kerr-McGee personnel to airborne concentrations of plutonium above AEC permissible limits.
(In addition, two airborne overexposures involving six employees, which occurred during this period, were examined and reported in a later AEC inspection report.)
Results of bioassay analyses and whole body counting of the seventeen exposed employees indicated that no significant uptake of plutonium had occurred.
Seven of the nineteen items of noncompliance found during this period resulted from the licensee's failure to carry out special conditions of the license, such as audits, inspections, equipment tests, or administrative reviews. Five of the nineteen items of noncompliance resulted from the licensee's failure to notify licensing prior to making a change in facilities and organization structura. While none of the items by,themselves were of great significance, collectively they indicated management controls being exercised s' hould be strengthened. The Regional Director and members of his staff met with Kerr-McGee Corporate Management, including the Chairman of the Board, on November 2,1973, to discuss these problems. Subsequent to this time, although additions 1 viola-tions of AEC regulations were found, continuing stead improve-ments in the licensee's program were observed.
During the period following the contamination and OCAW inves-tigations, seven health and safety in'spections and one l
tions utilizing IE personnel from outside Region III. These investigation have been conducted with three of these inspec-j inspections, part of a special comprehensive accelerated program performed at the facility, were unannounced and the initial
" walk through" of four were conducted during off-normal hours.
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3 In general, the overall findings were that measurable improvements had occurred in connection with the safety of operations at the Cimarron Plutonium facility since the beginning of 1975. The improvements could best be illustrated by the reduction in airborne overexposure incidents from eight in 1974 to two in 1975. Notwithstanding the above, there were a number of noncompliance items identified by the inspectors relating to two overexposure incidents involving seven employees with no measurable uptake of plutonium, failure to carry out conditions of the license.
and failure to have or to follow certain written procedures.
There have been no liquid releases from the facility except for laundry waste water which is released into the sanitary waste system well below release limits. Caseous vastes have been well below release limits. Soil samples taken by the licensee, AEC, and EPA have been essentially at backgrodnd levels.
Plutonium plant operations ceased in late 1975, and af ter facility cleanout was concluded in 1976. The NRC, through ERDA, arranged for an independent verification of the inaccessible plutonium remaining in the equipment, piping, etc. in the plant by specialists from Los Alamos i
and Brookhaven Laboratories. This team's measurements supported the credibility of the licensee's measurements and it was their opinion that the distribution of plutonium within the plant as it is now in standby is not a divertable source of plutonium. On June 10, 1977 Kerr-McGee license was amended to reflect shutdown conditions and that
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decontamination of the plant cannot start unti1 such a plan is spproved by the Commission.
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UPDATED CASE HISTORY KERR-NCCEEhLUTONIUM)
CRESCENT, OKLAHOMA LICENSE NO. SNM-1174 DOCKET NO. 070-1193 4
Y.
Inspection Violations and Status A.
Complainee Inspections for Health and Safety INSPECTION DATES REMARKS -
9/27/74 Heating with members of the
... Chemical and Atomic Workers in NRC Headquarters during which 39 items of concern were alleged in the areas of training and education, respirator fitting, HP staffing and surveys, violation of procedures, delays in Air sample counting, and deficiencies in shower facilities and work clothing. These areas of concern
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vere investigated 11/21-22,12/5-7/74.
(see below) 11/7/74 An employee and the apartment of two employees was found to be contaminated with plutonius.
11/8-12/74 Investigation revealed that:.
(a) The above contamination spread was not caused by any release at the plant (b) Urine and fecal samples contained exogeneous plutonium, (c) One item of noncompliance concerning two urine samples that were improperly identified.
Corrective actions were taken and the apartment was decontaminated and released on 12/2/74.
l 11/21/74 The investigation of OCAW health and safety allegations made on September 27, 1974, was begun. Thirty-nine items covering four j
areas of concern were investigated. Only two of those items, and a third which was not among the allegations, were found to l
be in apparent noncompliance with AEC requirements. gighteen others found to have sore substance were called to the attention of Kerr-McGee, but did not result in identification of noncompliance with AEC i
reguistory requirements. The three items i
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)0 of noncompliance, involving reporting and improper use of plutonium, did not I
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INSPECTION DATES REMARKS 11/21/74 pose a hazard to workers or the public.
(Continued)
Proper corrective action was taken.
(Investigation Report No. 070-1193/74-10 and Inspection Report No. 070-1193/75-02) 11/21/74 The AEC Division of Inspection conducted to an investigation of four OCAW allegations 12/1'0/74 concerning Kerr-McGee quality assuranca in the manufacture of FFTF fuel. Although the investigation showed some evidence to support two of the allegations, there was no evidence that the quality of the fuel pins had been compromised.
(Division of Inspection Report No. 44-2-339) 12/19-20/74 An investigation was conducted into the December 17, 1974 report that four employees were exposed to airborne plutoniu:2.
In an unrelated occurrence, the hand of another employee had been conraminated.
The following items of noncompliance were observed:
1.
Four individuals wori.ing in a restricted area on December 17, 1974, were exposed to airbor.te concentra-tions of plutonium which, when i
averaged over 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, e/ceeded the specified limits.
2.
Ilespiratory equipment ussd on December 17 included respirator canisters which had not been approved under test schedules of the U.S. Bureau of Mines.
Appropriate corrective action was taken.
(Investigation Report No.
070-1193/74-11) t t
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E INSPECTION DATES AEMARKS 1/6/75 AEC representatives met with Kerr-McGee ar.d management OCAW representatives, and the 1/7/75 news media in Oklahoma City to discuss the results of the Silkwood and OCAW allegation investigations.
2/3-7/75 An inspection revealed that on three occasions employees were exposed to airborne plutonium concentrations greater than applicable limits as follows:
(a) Hay 19-25, 1974, one t
employee, (b) August 18-24, 1974, five employees (c) November 17-23, 1974, four employees. Actions were taken to prevent recurrence of these exposures.
(Inspection Report No. 070-1193/75-02) 3/3-5/75 An inspection revealed the following items
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j of noncompliance:
1.-
On two occasions posted safe operating limits were exceeded.
2.
On two occasions material was stored contrary to conditions used in the t
vault safety analyses.
i These items were corrected and actions were taken to prevent recurrence.
(Inspection Report No. 070-1193/75-03) 4/14-17/75 An insp'ection revealed the following items of noncompliance:
1.
A HEPA filter containing greater than a Type A quantity was shipped in a Type A package.
l 2.
Required monthly team audits by the
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Criticality Specialist and License l
and Safety officer were made by only the criticality specialist.
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Four cases of not following approved operating procedures.
4.
Air-balance betwwen the laboratory l
and hall leading to the locker room permitted a reverse air flow.
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c INSPECTION DATES REMARKS 4/14-17/75 5.
On March 23, 1975, three employees Continued were exposed to air concentrations exceeding applicable limits.
Actions were taken to correct these items and prevent recurrence.
(Inspection Report No. 070-1193/75-05) 5/20-27/75 An inspection revealed the following items of noncompliance:
1.
The storage of material in the vault outside of approved locations.
2.
Personnel were not required to wear finger ring monitors for extremity exposure evaluation.
These items were corrected.
(Inspection Report No. 070-1193/75-06) 6/2-5/75 An inspection revealed the following items of noncompliance:
1.
Physical inventories of SNM in some controlled areas were not maintained.
l 2.
An approved written procedure was not available for a washing operation in one glovebox.
3.
An approved written procedure was not l
available for the calcining of com-bustible vaste in two gloveboxes.
4.
Glovebox d ove ports were not provided l
with inner sealing rings.
5.
Licensee failed to notify' NRC when a shipping container was received with greater than allowable removable contamination.
l Actions were taken to correct these items.
l (Iaspection Report No. 070-1193/75-08)
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INSPECTION DATES
, REMARKS 6/30 to 7/14/75 Muclear Engineering Company notified Kerr-McGee and the NRC of the arrival at the NECO Nevada burial site of scorched i
HEPA filter in a waste shipment. The inci-dent resulted in no plutonium contamination problems. An investigation revealed one item of noncompliance regarding improper packaging of the filter. Proper corrective action was taken by Kerr-McGee.
(Investigatio:
Report No. 070-1193/75-09 and Inspection Report No. 070-1193/75-15) 9/75 to 10/75 FFTF fuel pin shipments were completed.
Scrap reprocessing and cleanout of the facility was begun. Work force being reduced for facility standby status.
An informal license amendment application to put the facility on standby status was submitted te Licensing.
(Inspection
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i Report No. 070-1193/75-15) 11/3-7/75 An inspection revealed that on' October 21, 1975 four employees were exposed to airborne concentrations of plutonium in excess of limits. Actions were taken to prevent a recurrence of such exposure.
(Inspection Report No. 070-1193/75-15) 2/28/76 The Cimarron Plutonium Plant cleanup had progressed to the point that no significant I
amounts of plutonium were being recovered.
I Combustibles and gloves were removed from 1
3 oveboxes, which were then sealed and tamper-proofed. The work force had been reduced to twenty-two people.
(Inspection Report No. 070-1193/76-03) 3/16-18/76 An inspection revealed no items of noncomplianc (Inspection Report No. 070-1193/76-03) 9/8-10/76 An inspection revealed no items of noncomplianc (Inspection Report No. 070-1193/76-06) 5/18/77 Amendment No. 9 was issued authorizing possession only and prohibiting any decontamination of the facility other than that necessary for standby conditions.
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6 JNSPECTION DATES REMARKS 6/7-10/77 An inspection revealed no items of noncompliance.
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UPDATED CASE IIISTORY (MATERIAL CONTROL AND PilYSICAL PROTECTION)
KERR-HCCEE (PLUTONIUM)
. CRESCENT, OKLAll0MA LICENSE NO. SNM-1174 DOCKET NO. 070-1193 l
DATES OF INSPECTION REMARKS 7/23-25/74 A routine material control inspection for the purpose'of auditing accountability records disclosed one item of noncompliance concerning reporting measurement data on transfer documents within 30-day period.
The item was corrected.
8/21-23/74 A material control inspection resulted in noncompliance concerning measurement bias corrections, tamper-safe seals, measurement i
of standards, and not measuring all plui. onium during the July, 1977 inventory (holdup quantity assumed to be constant). The l
licensee stated an intention to develop a non-destructive assay method (NDA) for.
measuring holdup, but said this would require several months.
9/11/74 A physical security inspection resulted in two items of noncompliance concerning security devices not yet installed or not operating l
as required.
W e ~ items were corrected.
10/74 The Limonthly inventory resulted in a HUF that exceeded its limit of error. As in March 1974, the plant was shut down and another inventory conducted with an AEC inspector present, sucessfully accounted for the MUF. Operation was resumed.
10/74 - 2/75 Kerr-McGee continued to develop their HDA measurement system. Discussions between AEC Licensing and Kerr-McGee took place.
Kerr-McGee requested an increase in the LEMUF limit of their license, because the new NDA measurement system was not con-sidered precise enough to permit the exis, ting limit.
New license conditions became effective which 2/75 increased the LDIUF limit.. To compensate for the larger limit, additional physical securit'y requirements were imposed on Kerr-HeCee.
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e DATES OF IMSPECTION REMARKS 2/18-22/75 A physical security inspection was made to inspect an intransit shipment. Six t
deficiencies and one infraction concerning communications, driver qualifications, procedures review and records were identified.
These items were corrected.
3/6-12/75 A material control inspection was accomplished during the licensee's bimonthly inventory.
This was the first inventory and inspection since new license requirements became effective. Physical security infractions associated with observations of internal i
i transfers of plutonium, control of packages, etc., entering and exiting the material access area, building exits, and monitoring of i
material control performance were Tdentified.
These items were subsequently corrected. Two deficiencies pertaining to measurement statistics were also identified and subsequently corrected. Samples of the entire inventory were obtained by the inspectors for analysis by a governement laboratory. Results of these analyses disclosed no major differences with licensee results.
5/20-22/75 A physical protection inspection disclosed three i
infractions pertaining to changes made to the security plan without prior approval, use of a vault lock of an incorrect type, and inadequate frequency of security drills.
These
, items were subsequently corrected.
7/2/75 A former Karr-McGee employee, armed with a rifle, arrived at the main gate and demanded to talk with the facility manager. After she had climbed the outer perimeter fence she was disarmed by :he manager and a guard. The rifle was found to be unloaded. The assailant was placed in the custody of the county sheriff and was subsequently placed on probation.
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DATES OF INSPECTION REMARKS 7/31 and 8/1/75 A material control inspection was conducted to l
observe the Kerr-McGee non-destructive assay inventory. No items of noncompliance with any of the aspects of the method such as completeness or interpretation of data were found.
10/9-10/75 A material control inspection consisting primarily of an audit of the records and measurement system was performed.
No noncompliance items were found.
Licensee management discussed their plan to place the plutonium plant in standby status.
Contractual obligations to deliver apprcximately'18,000f'elpiEIhadbeen u
satisfied.
Th1re was to be no further production and efforts to convert the remaining plutonium in the plant to an oxide powder and cleanout the facility were underway.
The work force was to be decreased gradually.
Operations were to close December 31, 1975, after which time a small standby force would be retained.
It was estimated that several kilograms of inaccessbile plutonium would remain in the process even af ter cieanout.
10/15-16/75 A physical protection inspection was conducted to review previously corrected noncompliance and ascertain the extent to which the licensee had conducted pre-employment screening of guard
' applicants, in general. rand one Caonardo Crusher (Garland Bufor in particular. No noncompliancewasiden$1 tified, but during this period when the NRC is considering specific regulations concerning the nature and extent of preemployesnt screening of applicants.
the licensee was encouraged to strengthen their pre-employment screening practices to minimize the possibility of hiring personnel who might compromise security.
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.o, DATES OF INSPECTION REMARKS 11/3-7/75 A material control inspection was performed to observe the licensec's bimonthly inventory.
There were no noncompliance items.
12/17/75 Kerr-McGee proposed to NRC Licensing changes in their physical security plan tailored to the planned stand-by mode of the plant.
12/31/7,5 Plutonium plant operations officially ceased.
The number of employees was reduced to about twenty.
l 1/5-9/76 A physical security inspection was conducted to observe intransit protection of SNM in the final, major shipment of plutonium from the plant to Richland, Washington. A Region V inspector was also involved.
One deficiency, subsequently corrected; concerning communications' records was identified.
1/13-14/76 A material control inspection coinciding with a bimonthly inventory was conducted. No items of noncompliance were identified.
It was observed that cleanout was virtually completed except for final cleanout in some gloveboxes. The cleanout work was expected to be completed by the few remaining employees within a month.
2/9-13 Facility cleanout was concluded. Removal of 2/23-27/76 gloves from all glovebox ports was completed 9
and all ports were sealed with tamper-safe devices.
At the request of the NRC and with the cooperat:
of ERDA, a team of NDA specialist from Los Alamos and Brookhaven National Laboratories spent two weeks making an independent measurement of the inacesr.ible plutonium remaining in the facility for comparison with Kerr-McGee's measurements.
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The inventory was 11.475 kilogrces 'of plutonium.
3/20/76 Licensing reviewed proposed changes in the modified Kerr-McGee security plan and amended the license by revising license conditions tailored to the stand-by mode of the plant.
At this time, a bimonthly plutonium inventory is still required by license but could consist of verification of camper safing seals on process.nloveboxes and a. piece count of stored items an the vault No measurements were necessary. -
5/18-20/76 The first facility physical protection inspection was conducted since the plant went into standby status. Six infractions and one deficiency were cited regarding perimeter alarm system; izternal alarm system; retraining of pards; change of lock cos.bination; ca?.ibration of SNM detector; conducting of giard drills; and secondary emergency power supply.
The items were cited against the secirity plan which had been approved for the operations phase of the plant a additional revision of the security plan was
(
necessary to reflect more completely the standby phase of the operation. The items were subsequently corrected or resolved with changes l
X to the security plan.
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8/7/76 A license application describing their complete program for their standby mode of operation was submitted to NRC for approval.
8/9/76 ERDA submitted 23 NRC its final report on the independent messirements.
The report is exempt from public disclosure under the l
provisions of 10 CFR 2.790.
Findings can be j
summarized by tus statements: (1) Kerr-McGee's measured inventtry total lies within the upper and lower Sounds of the ERDA measured estimate (2) It is the ERDA team's opinion j
that the distrihation of plutonium within the l
plant is such thic it is not a divertible source of plutottua.
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- .a DATES OF INSPECTION REMARKS A physical protection inspection was 9/1-3/76 conducte.d. One. infraction regarding the perimeter alarm system and one deficiency regarding testing of the alarm system were disclosed during this inspeccion. The i
licensee has taken corrective actions.
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11/22-23/76 An inspection of ttie licensee's plutonium inventory and inventory procedures was conducted. No items of' noncompliance
-were identified.
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11/22-23/76 A folluvup physical secuiity inspection verified that corrective, action had been taken on previously identified noncompliance.
4/13-15/77 A material control inipection of if censee's acasurement and stat.istical controls for previous material baiaites periods identified no noncosiiliance.
5/18/77 NRC issues licens emendment reducing the possession limit-and prohibits the processing of SNM.
6/10/77 NRC issues new safeguards amendment
]
that reflects cur'Jent state of plant shutdown end the restrictions not to process SNM or to ' decontaminate equipment or gloveboxes. ' Any. future licensee applicaton for suthorization for decontaminatic:
or decommissioning' activities has to include i
appropriate sections on physical security and material control and accounting.
The licensee has indicated they plan to f
4 decontaminate and decommission the plutoniur facility.
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