ML20215L728
| ML20215L728 | |
| Person / Time | |
|---|---|
| Site: | 07001193 |
| Issue date: | 04/24/1975 |
| From: | Mcgonnagle W, Patterson J, Peck C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215L523 | List:
|
| References | |
| FOIA-86-281 70-1193-75-04, 70-1193-75-4, NUDOCS 8610290261 | |
| Download: ML20215L728 (18) | |
Text
{{#Wiki_filter:[,'* L/[
/V 8
' U. S. NUCLEAR REGULATORY CO.TilSSION 3
OFFICE OF INSPECTION Ah*D ENFORCD ENT
~
REGION III f IE Inspection Report No. 070-1193/75-04 t Licensee: Kerr-McGee Nuclear Corporation Kerr-McGee Building-
- 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 Incpection: Special Nuclear Materials, Announced
-~
Dates of Inspection: March 6, - 12, 1975 - ,. .
- k. #
Dates of Previous Inspection: tiarch 3-5, 1975 (M& PPB) Principal Inspector: C. C. Peck hb fcc S 3 f7 ' (Date) Accompanying Inspectors: J. P. Patterson - W Y',2J 0[ (Date) W. J. McGonnagle pf, 3- @J Other Accompanying Personnel: None Reviewed By*
.h J. A.
.4ut (Ind, C ief .
/ /c
/ 2.t[f 7J Materials and Plant Protection Branch '(Date)
Attachment:
, Findings (10 CFR 2.790 Information) l
, ./.' .
s-I I . l'
. 8610290261 861023 PDR CANTREL86-201 FOIA P D,R
\' % .
- _ j 3 b)// .
o SUVJiARY OF FINDINGS Enforcement Action , The following items of noncompliance were identified during the inspection: Violations -
\
None
^
'e
- O. /
Infractions V
- 1. Contrary to License Condition 3.9.10 of Amendment MPP-1,' transfers of plutonium from operating hoods and boxes and were not being observed and accompanied by a safeguards clerk or other designated individual in addition to the person making the transfer. .
- 2. Contrary to License Condition 3.9.14 of Amendment MPP-1, packages and containers not needed in support of operations within the material access area (MAA) were permitted entry into the HAA. The routine entry of women's handbags into the change room is a specific ' example.
- 3. Contrary to License Condition 3.9.15 of Amendeent MPP-1, the two rear entrances into the general laboratory from the plant corridor were not panic locked and in use onip ior emergency exits.
- 4. Contrary to License Condition 0.9.16 of A:nendment MPP-1, there was no prohibition against packages, containers, or coats being carried -
through the search devices by personnel exitir.; the MAA. Women's handbags were observed being carried through the search devices.
). Contrary to License Condition 3.9.17 of Amendnent MPP-1, roving observers, one per shift, were not monitoring material control and accounting performance.
These above infractionu had the potential for causing or contributing to occurrences related to common defense and security. Deficienciec
- 1. Contrary to L'icense Condition 3.3.3 of Amendeant MPP-1 the program of replicate sampling and measurement of process materials failed to provide the minimum of fifteen (15) represcutative data sets for several measurement types during four' material balance periods from
. Hay 1974 to December 1974. Specific types of measurements for which the frequency was low are x-ray fluorescence, and the four
.}* ,, amperometric measurement typesIEthat you employ.
Inspection Rpt No. 070-1193/75-04
~ ~
IE:III Copy No. of # 6 Tks me w be alend m ht
q .
- 2. Contrary to License Condition . Amsndment MPP-1, material accounting data were not being justed for measurement bias which s exceeded 10% of its standard deviation.
This deficiency was also identified during the previous inspection
, of August 21-23, 1974 at which time the licensee had neither analyzed nor attempted to apply bias data to his accountability measurements, y The present inspection disclosed improvement. Bias data for some major measurement types have been analyzed and application to \
accountability data was attempted. The attempt had no effect on accountability data because the biases were too small relative to the accountability quantities. Ilowever, bias data on all measurement types have not been analyzed or applied and consequently the licensee continues to be in noncompliance. . Licenste Action on Previously Identified Enfortement Action - The following noncompliance items wer- identified during the inspection of August 21-23, 1974:
- 1. Contrary to License Condition 3.5 of Amendment MPP-1, material accounting data were not being adjusted for measurement bias which exceeded 10% of its standard deviation.
The licensee continues to be deficient as described previously
, under " Deficiencies."
- 2. Contrary to Licence Condition 6.3.4 of HPP-1, tamper safing seals were not being used.
The licensee is using tamper safing seals and tiiis item of noncompliance is considered resolved.
- 3. Contrary to License Condition 6.4.2 of MPP-1, the licensee was not measuring all special nuclear materials at the time of physical inventory. A 17.6 kilogram quantity of pluton,ium, determined on a l
by-difference basis, was being carried on inventory. The licensee has developed a non-destructive assay technique for measuring holdup, and has indicated that he will include the results of such NDA in his March 1975 inventory. This is considered an unresolved item. ,
- 4. License Condition 3.3.2. states: "A standards program shall be ma'intained to provide a minimum of tw'o messurements of standards per week for each measurement type."
IE Inspection Rpt No. 070-1193/75-04 [ .- M
~ ~
IE:III Copy No. of l l ..; . 1 1
\
f ($n W f*$ in ,
~
The licensee was found to be in noncompliance with the above requirement in August because the frequency of measurament of some standards was less than two per week. The system in use during this inspection is producing standards data at the rate of two Per week for all.significant measurement types and the item of noncompliance is considered corrected. posual Occurrences
\
None JtherSignificantFindings . An item defined as a " program weakness" was identified during the August 1974 inspection. This consisted of failure on the part of the' licensee to recognize formally gamma autoradiography as a nondestructive overcheck for plutonium in fuel pins. Use of. the method as a safeguards overcheck is now covered in a procedure, KH-NP 15-21, Revision 4, dated November 5, 1974, and this procedural weakness is considered corrected. Management Interview A closecut mecting was held March 12, 1975 by C. C. Peck with the following members of the licensee's staff: M. Moore, Manager, Cimarron Facility R. Janka, Manager, Administration and Accountability , H. Binstock, FFTF Project Manager R. Adkisson, Plutonium Accountability and Safeguards Supervisor - D. Rhodes, Plutonium Plant Superintendent The group was advised that based on the'ir observations the inspectors considered the preparation for the physical inventory to have been thorough and in accordance with procedures. The items of noncompliance found during the inspection were then discussed. It was emphasized by the inspector that the Commission'as w highly interested in the licensee's safeguards program and particularly in the rigid implementation of the new LDIUF and security - type requirements of License Condition 3.9. It was explained that the findings of noncompliance had been based on the state of compliance found to ex'st i at the time of the inspection, without regard to the efforts that the licensee had made I or was making to achieve compliance in the future. The manager of the Cimarron Facility stated that although he understood this ground rule,
. he had strong objections to the wording of the transmittal Ictter that Accompanied the new 3.9 license conditions which unde these new conditions
" effective immediately." This letter was received about February 27, 1975,
( .. [ /* IE Inspection Rpt No. 070-1193/75-04
~ ~
IE:III Copy No. of I L m.
a week prior to the inspection. The nanager said that imnediate compliance, especially with those conditions requiring addf tional surveillance had been impossibic because additional pecple were needed to perform the ~ surveillance functions. He. emphasized that although compliance had not been immediately attained, efforts to achieve compliance had begun immediately. The inspector agreed with this statement and stated that the inspection had provided evidence that efforts to reach compliance had begun immediately upon receipt of the new requirements. The noncompliance items were discussed one-by-one. Licensee representatives expressed an intent to comply, and pointed out steps that they were taking or would take to be in compliance. With respect to the noncompliance item
. associated with License Condition 3.9.16, the licensee was un'certain on how compliance would be achieved.
==
l f hI a-). m - y, ale (d^ - 7 i5 f 1
. /
IE Inspection Rpt No. 070-1193/75-04 IE:III Copy No. of M l , l .
.. h -
- O REPORT DETAILS s
Persons contacted . H. Moore, Manager - Cimarron Facility W. Shelley, Director - Regulation and Control R. Jenka, Manager - Administration and Accountability R. Adkisson, Supervisor - Safeguards and Security D. Rhodes, Superintendent - Plutonium Plant J. Smith, Supervisor - Pu Plant G. Hallet, Safeguards Specialist. P. Garst, Safeguards Analyst - -
"R. Marshall, Analytical Specialist J. Steele, Foreman - Pu Plant J. Harrison, Foreman - Pu Plant B. Bathe, Safeguards Clerk H. Smith, Safeguards Clerk J. Carver, Laboratory Supervisor - Pu Plant D. Sanders, General Analytical Chemist - Pu Plant F. Welch, Security Supervisor Scope of Inspection -
The inspection was announced because one of the primary objectives was observation of the licensee's bimonthly physical inventory and the taking of NRC verification samples for analysis by LASL. Therefore it was necessary to obtain the licensee's inventory schedule in advance and to preplan details of sampling and shipping. In addition to the inventory matters, inspection of the licensee's compliance with the new license conditions of section 3.9 was a major part of the inspection. These conditions hich were eTTEt %'e immediately were received by the licensee q_out February _27, 1975. 3 They primarily consist of added surveillance requirements, and are intended as a " trade-off" or' substitute of observational requirements for a relaxed LEMUF limit. In discussions of these new conditions
, prior to the inspection, it was learned that there would be noncompliance with some of them, because the licensee stated that increased manpower would be needed for compliance and that such manpower was being hired but was not yet available.
Such other license requirements as it was possible to inspect during the inventory were also covered. The tabulation below lists license conditions covered (C) and those not covered (NC): 1.0 C ,, r2.0 NC k' ' 3.0 3.1 NC .
,. 3.2 C '
3.3 3.3.1 NC t IE Inspection Rpt No. 070-1193/75-04
* /!
IE:III Copy No. of // M s --
/?ofenve & Ave /hf f
3.3.2 C 3.3.3 'C 3.4 NC' 3.5 C 3.6 3.7 NC' C j 3.0 C 3.9 3.9.1 C
, 3.9.2 C , \
3.9.3 C -
, 3.9.4 NC .
3.9.5 C ' 3.9.6 NC 3.9.7 C 3.9.8 C 3.9.9 C 3.9.10 C . 3.9.11 NC 3.9.12 NC 3.9.13 NC 3.9.14 C 3.9.15 C 3.9.16 ^ C 3.9.17 C 3.9.18 NC 3.10 NC 4.0 NC 5.0 NC 6.0 6.1 C 6.2 C 6.3 C ' 6.4 6.4.1 C 6.4.2 C 6.4.3 NC 6.4.4 NC 6.4.5 NC 6.5 NC
- 7.0 NC 8.0 NC 9.0 NC FacilityOrganization(LicenseCondition1.0}
The principle organizational change affe'c ting safeguards since the inspection of August 1974 has been the hiring of eight additional people whose functions will consist entirely of safeguards, according I to the licensee. The people were hired during the week of March 3, train.ed during the veck of March 10 and assumed their jobs on four s,hif ts beginning the week of March 17, two on each shif t. One of ' IE Inspection Rpt No. 070-1193/75-04 Q ,, IE:III Copy No. / of // N T k;, paje - cs., be rele-rd m MI
)
cac'h pair will function sa e health physics technician, st ione in the corridor just outside the vault. Ile will monitor materials s going into and out of the vault, observe personnel and materials exiting the laboratory, at times act as the second person in the vault, or the second person required to accompany a material tranfer. The second person on each shif t will act as roving observer whose sole duty will be the monitoring of material control and accounting performance. When not roving, this second person will be stationed at the same location as the health physics technician, to assist or replace the latter in his observational and material transfer functions. The licensee expects that this pair on each shift will permit compliance with all the curveillance requirements of the new section 3.9 license conditions. - A technically trained employee (mathematician) has been hired recently with the title of Safeguards Control Chemist. His principle function appears to be to assist the Safeguards Specialist in the development of measurement data and statistics.
~
Heasurements and Statistical Controls (License Condition 3.0) 3.2. Nondestructive Overcheck of Each Fuel Pin. , The licensee was cited for- what was termed a " program weakness" in the August 1974 inspection. He employs a gamma autoradiogrophy system to produce a radiograph of each finished fuel pin. The radiographs clearly show*the presence of cach plutonium oxide - uranium oxide pellet in the pin and would detect the absence of any pellets or identify any, non-plutonium pellets. The method is satisfactory as a nondestructive overcheck, but at the time of the inspection there was no procedural recognition of the technique
'as a safeguards method. It was not clear that absences' of or substitutions for plutonium pellets would be brought to the attention of the safeguards organization. The licensee has corrected this procedural flaw in his procedure KM-NP 15-21. dated November __5, iv/4. The procedure states that the radiograph of each pin is
_ reviewed h thc lua] t D E urance group, and the presenca..of acceptable pellets is one of the criteria used_in_pIgparing the Troduct snipMnrtist- The safeguards group receives a copy of each shipping list. 3.3.2. This license condition requires that a program shall be maintained to provide a mini' mum of two measurements of standards per week for each measurement type. The inspection of August 1974 disclosed that a standards measurement program had been implemented but that frequencies in general and the frequency for the radioassay method in particular did not meet the two
,pe,r wcek requirement. From August through January the frequency of
* /
IE Inspection Rpt No. 070-1193/75-04 IE:III Copy No. /! of // y b[ % h & 7 4tT e .
ctandards r:casurem:nts has shown improvement and ad quate frequency in most weeks for major measurement tyMs. Major types are considered to be amperometric titration, x-ray fluorescence, neutron activation, the stack makeup scale (#6), and the pellet storage scale (#10). Beginning in February 1975, a system was initiated that requires that two measurements of analytical standards be made each week and reported on a single reporting form. The same sort of system has been adopted for scales and balances, with the safeguards clerks being required to obtain a pair of standards measurements each week on'each scale, recording the data . on a single form. These systems appear to be functioning better than those previously used which relied on the laboratory and production to initiate standards measurements. All required data have been obtained since mid-February.
- The principle problem in cbtaining the "two measurements of standards per week" frequency was the fact that in many weeks certain scales or analytical methods vere not used, and in such weeks attempts to measure the standards were seldom made. Now that a system has been devised that should produce the standards data despite the absence of sample measurement requirements, the licensee will encounter a i
period of phasing out of various measurement types as the FFTF program comes to an end. For example, the plutonium nitrate weigh scale (#1), will probably not be used after April since all nitrate will have been received. In a request to Licensing dated February 25; 1975, the licensee has requested that L.C.3.3.2 be modified to permit
. measurements of standards only in conjunct'on with actual material measurements.
3.3.3. This license condition requires that a minimum of fifteen - replicate sets of measurements, of process materials be made for each type of measurement per material balance period. \ - The licensce's measurement frequency has been less than fifteen per material balance period for some analytical methods and scales according to frequency data tabulated by the licensee. The analytical methods are mass spectremeter and x-ray flourescence for which frequencies have averaged only about five replicate sets per material balance period. Replicate measurcment frequency has also been low for the pJutonium nitrate weigh scale, the two blend scales, the powder scale and the pellet storage scale. The system introduced in mid-February for complying with License condition 3.3.2 will also serve to correct the low frequency of the measurement of process materials if the system is used consistently. 1 However, the licensee has not been able to meet the required frequency i for any c4aterial balance period for all measurement types and the new l system has not been in effect long enough to demonstrate that it is ( currently effective in meeting the frequency requirement, so tha licensee was found to be in noncompliance. Thh licensee's annual internal audit of,the measurement system uas of assistance in identifying the inadequate
+ ,ftcquency.
e 'l IE Inspection Rpt No. 070-1193/75-04
~
IE:III Copy No. of M a i
~1ks pne ck be nknd w M4 ~~
mg i There will be a gradual phasing out in the use iof,some alytical methods and scales and balances as the FFTF protra. ars cumpletion, and the licensee has requested a change in this condition also to allow these replicate measurements to be made only in e :ijuction with analyses and weighings of actual materials. Frequencies c' less than fifteen per period would then be permissible. 3.5. This condition requires that measurement data be corrected for biases that exceed 10% of their (own) standard deviation. The licensee was found in nonco'np1iance in August 1974 for failure to correct measurements for bias. The licensee contended that from the information he had at the time on biases, the' magnitudes were so small that the effect on measurements would be negligible. The inspectors agreed that bisses could be small, even when larger than 10% of their standard deviations, but that the requirements to accumulate, analyze, and attempt to apply the data could not be waived. Accumulated bias data on amperometric titration and some sesics (stack makeup, pellet storage, and nitrate blend scales) were analyzed during the inspection period. The bias or systenatic error for the amperometric methud was calculated to be 0.000024346 g/g. This quantity, despite the f act that it is 36% of it's standard deviation, is too small to af fect any of the measured material balance items significantly. Biases
= calculated for the scales were found to be similarly small.
Despite the fact that bias data analyzed to daEc indicate that the effect to bias on measurements is negligible, the licensee needs to continue to accummulate and analyze the data, and to extend the study to measurement types other than amperometric titration and a few scales. Because the study has not been extensive enough to cover analyticci methods other than amperometric titration and some scales, the licensee l was again found to be in noncompliance. The licensee's annual internal audit of the measurement system described under 3.7 was of assistance in identifying this item of noncocpliance. 3.7. This requirement states that the Safeguards Specialist must review the measurement program annually and that tha review must be documented and reported to management.
. .~
The required review covering the period December 1,1973 to' November 30, 1974 was made. The report consists'of a reviev'of licensee performance
'Dn aceting each of the requirements of Section 3.0, Measurements and Statistical Controls. TheIt report is concise and critical of the l
measurement performance. was useful to the inspector in appraising l the licensee's performance. The report contains recommendations for improvement in several areas. IE Inspection Rpt No. 070-1193/75-04
, /*
# "' IE:III Copy No. of //
% pp cn k re /e sd m M/
Ni l . _ O
3.8. This requirement states that limit of error calculations include random and systematic errors in all measurement components and that all identifiable covariance effects shall be taken into account in the calculation of LEMUF. , , Although this requirement was not inspected in detail, i considered that the licensee is in compliance. Calculated LE's i u e the random errors associated with analytical methods and scales and bslances. The frequency of accumulation of the data has been less than that required however, and the licensee is therefore deficient in ecmplying with L.C. 3.3.3. Indications are that systematic errors are not significant and need not be included. Although data analysis of systematic error was
' not extensive enough and the licensee was therfore considered to be in noncompl,iance with L.C. 3.3.2 as a result of the previous inspection, this condition has been corrected and compliance achieved. Covariance effects are considered in the calculations of LEDF as required.
3.9.1. This new condition requires the licensee to maintain a system of
- material control and accounting such that the limit of error accociated with any MUF shall not exceed 3.0 kilograms of plutonium per inventory period.
The licensee's compliance with this requirement was not a subject of the inspection, since the inventory in progress during the inspection was
. the first one to which the condition will apply, and material balance, HUF, and LEMUF data were not available or expected to be a.ailable for several weeks.
This new 5.0 kg LEMUF limit plus the surveillance-type requirements of
. .section 3.9, replace the previous License Condition 3.9 which stated that the LDIUF limit should not exceed 'l.8 kgs of plutonium. The 1.8 kg limit was in effecr. from May 1974 through February 1975, a period during which the licensee performed five inventories. At the time of the ,
previous inspection, August 1974, the licensee had been successful in meeting the 1.8 kg limit (see tabulation below), but only because he had l not included in-process holdup in his measurement data. This unmcesured l holdup of 18.7 kilograms was and is required to be measured by License l Condition 6.4.2 which permits no unmeasured holdup except for 1.1 kilograms. Accordingly the licensee was f ound in noncompliance with L.C. 6.4.2. Following the August inspection the licensee began to develop a system of non-destructive assay which would enable him to measure the holdup. However, he realized that the large limits of errer associated with non-destructive assay would result in an inability to comply with the 1.8 kg limit of L.C. 3.9. The inventories of October nnd December 1974 in l which NDA was used to a limited extent indicated that the 1.8 kg limit ! could not be achieved with NDA. The LDIUF limits for these two inventory l ' periods were 2.0 kgs, although the LEMUF linits were less than 1.8 kg if
. /
, g , IE Inspection Rpt No. 070-1193/75-04 l
lE:III Copy No. of [ l rde~wd in ich i 7hy po1e es- hgesammaammmmmmuum
i M ) NDA measurements were not included. In . late 1974 the licensee began to correspond with Licensing in an effort to obtain relief from the 1.8 kg limit which would be impossible to meet when NDA measurements were used in a full-scale program to measure all the holdup. The licensee ' was not' cited for noncompliance for the LDIUF's that slightly exceeded 1.8 kgs during this period. The negotiations with Licensing resulted in the relaxed LDIUF limit of 5.0 kilograms, plus additional conditions requiring tighter surveillance and control of plutonium. A summary of the licensee's performance with respect to the LDfUF limit of 1.8 kgs is presented below: . 17:24UF (kg) Inventory Date Not Including ND4 Including NDA i t.O '. .s July '74 1.617 -- yg September 1.850 1.818 2,000 [6 i.) October j[' W % , s t December 1.697 2,009 ( January '75 1.020 i 1,241
~
h 3.9.2. This new condition specifi h at vor ng surfaces a ods, b xes b\- and equipment shall be cleaned for physical inventory. e L
.- Operating equipment was inspected prior to inventory. Gloveboxes in the " dry" area consisting of pellet fabrication, pellet storage, and 5,in fabrication areas were observed to be ostensibly clean. No material that could be identified as plutonium-containing was observed in any of the boxes other than the pellets in the storage wells.
Cleanup in the " wet" area consisting of the ceramic and scrap areas was extensive. Flushing, wiping, and scraping of gloveboxes and equipment within the boxes was the primary occupation of the ceramic and scrap ' area operators on all shifts for about three days. It is estimated that over a hundred plastic bags containing contaminated wipes, gloves and junk were removed from wet area gloveboxes during this . period for neutron counting in the vault and disposal to waste burial. Acid solutions introduced into the gloveboxes for flushing eventually were collected in scrap area wall tanks for inclusion in the inventory. It was especially noted that the precipitation equipment was flushed and the bottoms of boxes No. 4 and No. 39 were cleaned. 3.9.3. This condition states that nondestructive assay methods shall be used to determine the residual holdup of plutonium on hood, box and equipment surfaces.
~ }g yehM*N InIE Inspection Rpt No. 070-1193/75-04 g'3 p[ / IE:III Copy No. of // .
8 1 . 0 w 9
N Y Two NDA systems were employed during the inventory. Each consisted of a sodium iodide detector and a Ludlua analyzer. One was used f or determining the plutonium content of pipelines, the other for gloveboxes and filters. Measurements were scheduled af ter cleanup of equipment had been completed and at times when background interferences from activities in nearby areas would not affect the readings.
- Each of the two systems was calibrated using speciraens prepared by the licensee. Flat-type specimens containing various measured amounts of plutonium were used for calibrating the s'ystem used for gloveboxes and filters. Dissolved pelletc placed inside Ib inch schedule 40 pipe were used to calibrate the s): tem used in measuring pipelines. ,
Throughout the NDA inventory, it was the practice to obtain two gross counts and two background counts at each position. Counts were obtained over , ten second periods. Background counts were obtaine'd by covering the collimated detector opening with a b-inch thick lead shield. In making all measurements efforts were made to duplicate as closely as possible the conditions used in calibrating the system with the standards. Glovebox measurements were made from preselected positions at equally spaced intervals about three feet apart. Interpretation of data vill presumably consist of averagint the counts over the area of the glovebox involved. In measuring pipes, readings were usually taken at two or more positions so that vertical and horizontal legs could be included.. Taking into account such variables as counting statistics, variations in pipe diameter, vall thickness, pipe contour, and length of pipe it is . estimated that the amount of plutonium determined should be accurate to about 25%. The plutonium" content of. boxes and filters are expected to be accurate to about 15%. The better accuracy is expected in boxes and filters because of higher counting rates, more accuracy in calculating surface areas, and more complete knowledge of the attenuation factors of the boxes and filters. 3.9.5. This condition states that perpetual inventory records shall be maintained of all containers and items of plutonium in storage.
- The principle storage area for plutonium-containing items is the vault.
A perpetual storage log is maintained of all items stored. Items are listed by IT number and type of material such as powder, pellets, nitrate, ash, etc. In addition a log of all waste i'tems that are counted by neutron activation is maintained. Such items are logged, counted and placed in a drum for burial if the count indicates less than five grams of plutonium. Log sheets are later computerized. The relatively few items that are found to contain more than five grams of plutonium are stored and logged
.in the storage log.
y- IE Inspection Rpt No. 070-1193/75-04 IE:III Copy No. of [
;cy,s. pq e c . be reksd m Id)
Product pellets are stored in six wells in the pellet storage area in
, metalcansin(anargogatmosphere. A perpetual record of the contents of each can inNach wdll in terms of pellet weight is maintained on internal transfer forms, one form for cach can.
Product fuel pins, each of which has an identifying number, are stored in metal assemblics or shipping containers which have spaces for 120 pins. Presently only 86 pins are stored and shipped in each assembly, because of a shipping regulation that limits the amount of plastic that can be l present in a shipping container. Each f,uel pin is wrapped in plastic. A record of'the fuci pin numbers by location in each assembly is maintained on a QC record form. The pins are stored in locked storage wells in the floor of the pin storage area to await shipment. , 3.9.7. All vault operations are to be conducted in the presence of two persons. The licensee stated that he is complying with this requirement, and observations during the several days of the inspect. ion did not disclose any violations. On occasion it was necessary to vacate and lock the vault because of the unavailability of a second person. The licensee stated that this requirement was handicapping vault operations which are normally almost continuous at inventory time but that the presence of the new-hired health physics technician and roving observer beginning March 17 would eliminate the operating delays. 3.9.8. All bags and containers of plutonium entering vault shall be tamper-safed and gross weighed. The licensee's procedures require that all items brought to the vault be gross weighed. If neutron counting indicates less than five grams of plutonium the items are allocated for burial. Items containing more than five grams are logged, stored, and tamper safed. No violations of these practices were observed. 3.9.9. All plutonium removed from operating hoods and boxes shall be encapsulated, containerized, or bagged and sealed. The removal of all' materials from plutonium - containing boxes must be accomplished by bagout in a sealed plastic bag. This is a standard operating procedure that is unlikely to be violated. 3.9.10. Removal and transfer of plutonium from the vault and from operating hoods and boxes shall be observed and accompanied by a safeguards clerk or other designated individual in addition'to the person performing the operation. , IE Inspection Rpt No. 070-1193/75-04
, IE:lII Copy No. of //
\
( . cs,- />c V P&l tn hhl \ 1%. 983e
The licensee acknowledged that he was not yet in compliance with this
, require;nent. Transfers of plutonium were not being observed by a second individual during the inspection. The lic,ensee stated that immediate compliance had not been possibic because manpower was not available, but that efforts to hire the required peopic had begun immediately upon receipt of the license conditions. Eight additional employees had been .~
hired during the week beginning March 3 and were receiving health and safety training and Beneral orientation during the veck of March 10. The licensee stated that the neu employees would be on duty March 17 for the purpose of meeting this and other surveillance requirements of Section 3.9. Other conditions of th'is type are L.C. 3.9.11, 3.9.12, 3.9.13 and 3.9.17. 3.9.14. No packages or containers shall be permitted entry into the material access area (MAA) unless needed in support of operations within the MAA. The licensee stated that he was in noncompliance with this requirement. There has been difficulty in achieving immediate compliance because the men's and wonien's change room by definition are within the MAA boundary. Women's handbags and other container-type personal items, after being inspected by a guard at the entrance into the building may be carried into the change rooms. Such items may also be carried into the administrative area which is outside the MAA, but from the administrative area undetected entry into the MAA is possible. The licensee has no immediate solution to the probicm, but stated that a request for redefinition of the MAA was the probable solution that would be sought. l -3.9.15. The two rear entrances into the general laboratory from the plant corridor shall be modified with panic locks. l The licensee stated prior to the inspection that he was in noncompliance because no panic locks had been installed. Initially this safeguards measure was proposed to Licensing by the licencee as a means of controlling laboratory traffic, and Licensing incorporate? the Adca into the license. The licensee has since decided that equally effec.tive control of plutonium exiting the laboratory could be achieved by panic locking only one door. The remaing two would be under the continuous visual surveillance of the additional health physics employee beginning March 17. A request for this
' change, dated March 11, has been sent to Licensing. . The licensee acknowledged noncompliance with the present requirement.
3.9.16. In accomplishing the required search of personnc1 exiting from the MAA, no packages, containers, or coats shall be carried through. the scarch devices.
)* IE Inspection Rpt No. 070-1193/75-04 1 ,
I l I IE:III Copy No. of [ 1 i
%paj'e e.u- Le mLy/ A 46/ !
~
amummmmmmmme . W The licensee stated the he was not in compliance with this requirement,
- and some violations confirming this admission were noted during the inspection in the form of women's handbags being carried through the
' search device which combines gamma detection with explosives detection.
People exiting from the M1A (or from the administrative area which is the same thing since it is impossible to distinguish who camc~from which area) may presently carry packages through the device. Handbags are the most frequent items, since coats, lunchboxes, and other packages are normally lef t on the exit side of the search device, but there is presently no prohibition against anyj of these items. People and the items they are carrying are routinely inspected by a guard after passing through the search device and before exiting the building. , 3.9.17. One roving observer shall be provided per shif t whose sole duty shall be to monitor material control and accounting performance. The licensee stated that he was not in compliance with 'this requirement, but anticipated that compliance would be achieved, as in the case of other
- surveillance requirements previously described, beginning on March 17. The additional people needed to meet the requirement were expected to be available on that date.
Inventory (License Condition 6.0)- .
. 6.1-6.2. These conditions require the licensee to follow the "Cimarron Plutonium Plant Material Control Plan" in conducting his inventory.
The inspection disclosed no deviations from the Control Plan except in the use of tamper safing seals. A description of the situation with regard to tamper safing is presented in section 6.3. . 6.3. This requirement pertains to the licensee's use of tampet' safing seals. The license condition specifies only that camper safing seals must be used. Details of where they are to be used are contained in the Material Control Plan. In August 1974, the licensee was found to be in noncompliance because he had l i failed to initiate the use of tamper safing seals. This inspection disclosed that seals are in use and the item of noncompliance is considered corrected. It was observed that the licensee's seal control was in accordance with Control Plan requirements. Two individuals were involved in afixing seals, l all seals in use were observed to have the initials of the person responsible for the seal, and a current los book record of all seals was being maintained in the safeguards office. IE Inspection Rpt No. 070-1193/75-04
'e*
IE:III Copy No. f of M m p"e o k reiwd m MI m . ___ [
The licensee's use of the seals varies from the description in the Haterial Control Plan. The plan states that seals are to be used: (1) On powder, pc11 cts, and scrap materials in the vault, (2) On waste containers scheduled for burial, (3) on pellet storage wells, (4) On the valve handles' of wall storage tanks. After committing himself to the use of seals in the vault, the licensee decided that equally effective control could be achieved by the check ~s weighing of materials in and out of t;he vault. This change was requested in a letter to Licensing dated October 17, 1974. The request was denied in a letter f rom hicensing dated January 14, 1975. In the interim period no seals were used in the vault. Following receipt of the denial, the use of seals in the vault was initiated. Since a licensee may make changes in his material control plan without prior approval in accordance with 10 CFR 70.32, no noncompliance was involved. After experimenting with the use of tamper safing seals on vaste containers and pellet storage wells, the licensee concluded that these uses were not practical and he was not using them for these purposes during the inspection. It was explained to the inspectors that seals were difficult to handle inside gloveboxes without inadvertently ; breaking them and that senis would not adhere to the storage wells. The explanation for not using the seals on waste drums was that the drums could not be moved without breaking the seals. The scals appear to be suitable for use only on stationary objects. The licensee stated that he considered that these two changes did not decrease the effectiveness of his material control plan. In a letter to Licensing dated March 12, 1975 describing these changes, the use of a motion detector is proposed as a substitute for tamper safing seals on the pellet storage wells, and the use of Icad seals on the waste drums as a substitute for tamper safing seals. The inspection disclosed that the use of tamper safing scals on the valve handles of wall storage tanks was as described in the material control plan. 6.4. This licensee condition titled " Performance" consists of several miscellaneous subsections requiring the licensee to follow certain practices in conducting an inventory.
. Condition 6.4.1 states that each inventory team shall consist of two individuals. It was observed that two people were involved in listing inventory items. ,
Condition 6.4.2 states that all SNM must be measured at the time of inventory except for previously measured items whose integrity has been assured by tamper safing. No unmeasured holdup is permitted except for 1.1 kilograms of plutonium which was measured by NDA in the process
- s* .
IE Inspection Rpt No. 070-1193/75-04
- , 17 -
IE:III Copy No. of ys pye on Le ic/wd m MI '
- M prior to the start of the FFTF program. The inventory that was observed will be the first one conducted by the licensee in which the previously unmensured holdup, assumed to be 17.6 kilograms on the basis of by-difference calculations in 1973, will be measured. The licensec is committed to including the quantities accounted for by NDA techniques in the ending inventory. The item of noncompliance found during the August 1974 inspection based on the licensee's failure to measure his entire inventory would then be corrected.
To obtain information on the accurancy of the licensee's analytical measurements, the licensee was requested to provide the inspection team with sampics of inventory items for analysis by Los Alamos Scientific Laboratory. The inspectors prepared a sampling plan prior to'the inspection
, designed to indicate with 95% confidence that no more (or more) than 10%
of the licensee's analytical measurements exceed their analytical limits of error. A total of 87 samples were taken. An IE:III inspector was present to witness all of the sampling, except for the sampling of product pellets. The pellet samples were taken by the licensee prior to the inspection at the same time that he took pellet samples for his own measurements. The remaining sampics were taken. during the inspection. It is estimated that the sampling process took abouE 32 working hours and required about 200 man hours of licensee time. The samples were packaged for shipment during the in'spection and departed the facility via motor freight on March 17, 1975. A summary of samples that were taken is tabulated below. Arca HBA Items on Inventory Sampleable Items Samples
~
Vault 12 480 $tems 123 45 Scrap 11 8 solutions 5 5 Ceramic 13 10 solutions 7 7 Pellet Storage 22, 23 2 lots 2 lots 2 lots
', (30 pellets)
~
y g (pn bt N )' O
/
-{ IE Inspection Rpt No. 070-1193/75-04
~ ~
IE:III Copy No. of
.m}}