ML20215L526

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RO Insp Rept 70-1193/74-03 on 740226-27.Major Areas Inspected:Facility Organization & Operation,Measurements & Statistical Controls,Shipping & Receiving,Storage & Internal Transfers,Inventory & Repts & Records
ML20215L526
Person / Time
Site: 07001193
Issue date: 04/15/1974
From: Finley A, Hind J, Peck C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215L523 List:
References
FOIA-86-281 70-1193-74-03, 70-1193-74-3, NUDOCS 8610290079
Download: ML20215L526 (17)
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Text

D v' DIRECTORATE OF REGULATORY OP .

RATION r

. REC 10N III *~

RO Inspection Report No )

Licensee: 070-1193/7 -03 f k

" Rerr-McGee BuildingKerr-McGee on Nuclear Oklahoma City, Oklahoma 73102 .

License No. I SNM Priority:

Crescent. OklahomaCimarron Facility Category:Plutoni ant A (1)

T .

- YPe of Licensee: .

T YPe of Inspection: Plutonium Fuel Fabricator RSpecial

'ine, Nuclear Materials

' nanno

,, Dates of Inspection:

ebruary 26-27, 1974 Dates of Previous Inspect on:

February 11-15,1974 (Mat Principal Inspector: erials)

C. C. Peck h

/6' 7 Accompanying Inspector: & ce % 7; 4 (Da/e)

A. G. Finley *

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Other Accompanying Personn l (Date)

. ' e: None '

Reviewed By: .

n, ief Materials and Plant

Attachment:

Protection Branch _/ #

',! 7 #[

(Date)

Pindings (Exempt from Discl osure) '

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hTR 6-281 PDR 1 i

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SUMMARY

OF FINDINGS Enforcement Action: None -

Licensee Action on Previously Identified Enforcement Items The item.of noncompliance identified in the previous inspection, December 3-7, 1973, pertaining.to the licensee's failure to comply with the 1.5 kg. LDfUF requirement of License Condition 3.2 was not within the scope of this inspection. The status of this item will'be inspected at a future date.

Licensee actions on items of non-compliance identified in the, inspection of February 21-23, 1973, and March 12-16, 1973 have been as follows:

1. License Condition 3.4 - A report, dated February 15, 1973 was issued by the licensee to comply with this license condition, but the report did

. not include a quantitative calculation of limits of error of the measurement system.

Status - A report dated February 1974 was prepared by the Manager, Administration and Accountability, to comply with License Condition 3.4.

The report contains quantitative calculations of' limits of error. This

. item of noncompliance is considered corrected.

2. License Condition 3.7 - A rep' ort of the results of the licensee measuremen,t evaluation was not sub=itted to AEC, Headquarters within six months after commencing operations on the FFIF project.

Status - This item was partially resolved in a series of verbal and written communciations between the licensee and Licensing which terminated in April 1973'. Revised license conditions dated May 5, 1973 ,were

, subsequently issued, and this item of non-compliance is no longer applicable.

3. License Condition 6.5 - The licensee was not closing a material balance around plutonium in process at intervals not to. exceed thirty days. (This requirement is now contained in License Condition 6.1 of Amendment No.

i HPP-1)'.

Status - The licensee has closed material balances around plutonium, based on physical inventories, at intervals not exceeding thirty days since May 1973. This item is considered corrected.

4. License Condition 7.1 - Material balance area and plant records were not being reconciled at the end of each accounting period. -

Status - Material balance area and plant records are being reconciled monthly. This item is considered corrected.

-]n ny w. 6 reAud a w ~

5. License Condition 8.1 - An annual internal review o

, materials control procedures and management of the s not conducted in the period January 17,1972 'to Mar Status - An audit of the overall system dated Novem performed. This item is corrected.

Unusual Occurrences: None y Other Significant Findings A. Current 71nd'ings: None * '

B. Unresolved Items: None '

Management Interview A, closecut meeting was held February 27, 1974, by C. C.

Licensee representatives in attendance were: R. A. Janka and Accountability; G. R. tbliett, Safeguards Specialist Contract Relations Representative.

The license conditions that were investigated during the discussed with the licensee representatives. These were 1.0 2.0 3.0 (3.4 only) 4.0

~

5.0

' 6.0 (6.4 only) 7.0 8.0 '

, The group was informed that no violations had been ident$

of any of the license conditions listed above. It was pc license condition 3.2, which wa's the subject of a violat

  • the licensee a few days prior to the inspection was not i inspection . .

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. 8 RFFORT DETAILS 9 .

Persons Centacted

- R. A. Janka, Manager, Administration and Accountability C. R. Mallett, Safeguards Specialist

- R. J. Ad1(isson, Contract Relaticns Representative F. Welch, Accountability Analyst - Plutonium

~

H. Hodo,. Accountability Clerk . ,- '

C. Cender, Safeguards Clerk Scope of Inspection The inspection covered those license conditions and appropriate regulations of 10 CFR Part 70 that were not covered in the inspection of December 5-7, 1973. Conditions inspected were 1.0, 2.0, 3.4 only of 3.0, 4.0, 5.0, 6.4 only of 6.0, 7.0, and 8.0. Measurements and statistical controls and inventory were in general omitted since they have been recently covered.

Facility Organization (License' Condition 1.0)

The Manager, Administration and Accountability, delegated by the Cimarron Facility manager, continues to enforce, develop, and revise the~special nuclear materials control system.

Nuclear material control procedures are formally approved by the Cimarron

  • Facility Manager, and the Manager of Administratira andthe Accountability Safeguards! at , .

Icast. Approval of the Plutonium Plant Superintealent, Specialist, and the Quality Assurance Manager are Procedures aremaintained also required by when pro-the Technical cedures are of. interest to them. The Writer, who reports to the Manager, Administrariam and Accountability.

procedures are reviewed and updated, if necessary, on an annual basis or as revisions are required. The nuclear material control procedures are not kept in a separate manual, but are an integral portion of a multivolume collection of all procedures for the Cimarron facility.

  • The organization of the nuclear materials control system'is considered to be satisfactory.

Facility Operation (License Condition 2.0)'

l The Plutonium Facility continues to maintain sever NBA's as described in the l

repcrt for the previous inspection, December 5-7, 1973.

To improve MBA control, the licensee has recently There added are six Safeguards such clerks, Clerks and to the staff of the Safeguards specialist.

one will be on duty in the plutonium facility durfing all operating shif ts.

Principle duty of the clerks is to be present during all transfers of material from one MBA .to another to verify the physical morement and correct completion of the transfer forms by the MBA custodians. Implementation of this system will begin on March 11, 1974.

4 6 . .

The licensee's facility operation is satisfcetary.

Hessurements and Statistical Controls (License Condition 3.4 only)

The Manager, Administration, and Accountability, performed and documented an annual review, intended to comply with the license condition. The review consists of ssmple sets of calculations illustrating the method of calculating the plutonium MUF for the overall plant. No conclusions are drawn concerning the data. The review, while it complys with the letter of-the license condition, circumvents the intent of the requirement.

- l 8 The review is similar in format and conten't to that made to comply with the identical' license condition for the uranium facility. The licensee is '

considered to be in noncompliance for an unsatisfactory uranium facility annual review. However, in the case 6f the plutonium plant, all limit of error data are updated and examined month 19 in connection with physical inventories, and the licensee must provide the AEC with probable causes and corrective actions for excessive limits of error. For this reason the '

licensee's annual review is considered to be in compliance.

Shipping and Receiving (License Condition 4.0)

The limits of error for all major shipments and receipts for the period March 1973 to February 1974 were examined. .

The completed AEC-741 forms for plutonium nitrate receipt numbers 4-9 were inspected. The receiver's limits of error for plutonium and the fissile I topes were recorded on all the forms. Thew 1-Pits of error averaged 1 of an individual receipt, normally abou ,~000. grams of plutonium.

ipper-receiver differences were all well it a the receiver limits of error. ,F the six receipts examined, the net shipper-receiver difference was on1 79- grams of plutonium which is 0.08% of the 240,000 grams of

. plutoni eceived.

l The licensee has modified his method of measuring plutonium nitrate receipts

'

  • since the inspection of March 12, 1974. The receipt measurement is again being based on the analyses of samples taken from individual bottles, rather

- than on the analyses of samples taken from the combined contents of all the bottles in the shipment in the plutonium nitrate weigh tank. A single sample is taken from each of the ten or twelve bottles in the shipment, and duplicate samples are taken from two of the bottles. All samples are analyzed by

- amperometric titration. The assay for the shipment is determined from the

- two sets of duplicates. The single analyses from the remaining bottles serve to detect any significant assay differences among bottles from the same lot.

The limit of error for the shipment is calculated by statistically combining the LE of the assay method and the LE of the weigh scale. This combined LE for the shipment is calculated by the safeguards analyst and transmitted to '

. the accountability clerk for entry on the AEC-741.

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l Th2 limit of error data for all finished product l were also inspected. Pins containing approximatc' 5

plutonium were shipped in the period from March 3 the inspection. The s hipments have vari

' ranged from abo .

4 to Id% for individual shi all the shipments was calculatp'd to be 0.73%'.

Thelimito5errorfortheplutoniuminashipmer statistically combining the current LE of the ass

,, scale, and the number of pins in the shipment.

No receive'r measurements are possible, so there a

, differences for pin shipments.

_ Storage and Internal Transfers (License Condition The licensee is continuing to use prenumbered int for all plutonium transfers a=ong HBA's.

'A computer program was initiated during the inspe of accepting all IT information and calculating a each MBA. The program will also identify any mis:

not yet function reliably so all data is still re Internal transfer forms for the month of December of the inspection. Twelve of 625 forms were unacc computer and manual records. The problem of miss1 when the system of having safeguards clerks on eac Harch. The clerks will issue the IT's as needed I system of issuing the forms .in blocks to MBA custe Inventory (License Condition 6.4 oniv)

The licensee is adjusting his book inventory to th inventory at the end of'each' month as required by adjustment consists of adding or subtracting the M conducted during the month to the book total.

f The information for making the adjustment is trans 1 .

\O h*l ha Y h0g accountability clerk tiy the Safeguards Specialist.

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ya [ 4 licensee that this information and its entry into by signature of the accountability clerk and filed

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i Records and Reports (License Condition 7.0)

The licensee's records' system provides sufficient information to maintain a material balance around cach MBA and ~the total plant as required by 7.1. AEC was abic to reconcile MBA balances to plant records for the months of September, October, November, and December 1973 without difficulty.

Measured plutonium discards and M'JF quantities have been reported monthly by the Manascr, Administration and Accountability, as required by 7.2. AEC-742, Material Status Report forms, have been sent monthly to RO:111 as' required.

~

Ma'agement n of Materials *Contro1* System YLicense Condition 8.0)

A management review, independent of the Manager, Administratio'n and Accountability, was made during the inspection period to comply with License Condition 8.1. The review was dated November 10, 1973 and addressed to the Cimarron Plutonium Plant Manager. The review was examined and found to be critical of the licensee's nuclear materials control system in many of the same afeas in which the system has been criticized by AEC. Some of'the shortcomings noted were the lack of sampling limits of error, the inadequate frequency with bhich reference standards are analyzed in the laboratory, and the obvious impossibility of meeting the 1.5 kg. LDIUF reiguirement. The review is considered satisfactory. . ,,

Compliance with the requirement for estimating anticipated losses for periods between inventories was not investigated during the inspection.

There were no apparent losses of discrete items during the inspection period.

Summary of Inspection Status ,

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The tabulation below summarizes the status of the licensee with respect to each license condition'and ' regulation at the conclusion of the inspectfon of February 26-27, 1974.

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' Inspsetien Date Previous Present '

Futurc License Condition 3/73 or 12/73 2/74 .

1.0 Organization 1.1 OK OK Routine Check 1.2 OK OK Routine Check 1.3 OK , OK Routine Check 1.4 OK OK Routine Check 2.0 Operation 2.1 OK -

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Routine Check 1.2 OK OK Routine Check 2.3 OK OK Routine Check 2.4 OK OK Routine Check 2.5 OK OK

  • Routine Check 3.0 Measurements and Statistical controls 3.1 OK Omitted Inspect

. 3. Noncomp (Note 1) Omitted Inspe'et

.3 OK Omitted Inspect 3.4 Noncomp (Note 2) OK Routine Check 3.5 OK Omitted Routine Check 3.6 ~

OK Omitted Routine Check 3.7 .Noncomp (No'te 3) Omitted Routine Check 3.8 EA. NA NA

. 4.0 Shipping and Receiving 4.1 OK OK Routine Check

. 4.2 OK NA NA

- 5.0 Storage and Internal Transfers l OK -

Routine Check i 5.1 07.

. 5.2 OK OK

. Routine Check l 5.3 OK ,

OK Routine Check 6.0 Inventory 6.1 OK (Note 4) Omitted -

Routine Check 6.2 OK Omitted Routine Check 6.3 OK Omitted Inspect 6.4 Omitted OK Routine Check 6.5 OK Omitted ' Routine Check 6.6 NA NA NA 7.0 Records and Reports _

7.1 Noncomp (Note 5) OK Routine Check 7.2 OK OK RoVtine Check 7.3 OK OK Routing Check ,

Part 70 .-

70.54 OK OK, . Routine check

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Note 3. Noncomp to subm-conditi-t Note 4. Licensc

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. .. . m Kerr-McGee Corporation Material Balance Su:nmary Report For Lease Plutonium For Period 3/13/73 to 2/26/74 Crams

. Pu Isotope 11 2 7 1 27 Beginning Inventory 3/13/73 277 67 24 17 Receipts ,

95] 51 8 778' Shipments '

2( 49 1 102 Measured Discards 34 1066 Material Unaccounted For 29 4h0 2592 8 Ending Inventory 2/26/74 y e

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Kerr-McGee Corporation Materini Balance Summary Privately Owned Plutonium For Period 3/13/73 to 2/26/74 .

Grams

. Pu. Isotope I

Beginning Inventory 3/13/73' 31h h74 j .

Receipts .

10 Shipments /0 ,

Measured Discards . ,

,2 s Material Unaccounted For 0 0 Ending Inventory 2/26/74 31 72

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h terial Balance Summary for Contract Plutonium - FBM For Period 3/13/73 to 2/26/74 i

Grams .

Pu, Isotope

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. Receipts Shipments 3 . 0

. Hessured Discards Material Unaccounted For Ending inventory 2/26/74 0

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DIRECTORATE OF REGULATORY OPERATIONS -

NOTIFICATION OF AN INCIDENT OR OCCURRENCE ~

Pacility: KERR-McGEE' NUCLEAR CORPORATION CIMARRON FACILITY - PLUTONIUM PLANT

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Problem:

I SIGNIFICANT MATERIAL UNACCOUNTED FOR (HUF) QUANTITY This is to supplement the notification of March 6, 1974, regarding the February plutonium materihl unaccounted for loss quantity o 1.5 ograms of plutonium at Kerr-McGee. -

During the period from March 1 through 11, 1974, the licens'ee conducted

, a new inventory. This inventory, which involved an extensive cleanout i-of process equipment and a reevaluation of previous measurements, accounted for 0.1 kilograms of plutonium reducing the February material unaccounted for t . 4, ilograms.

Since the start of , reporting of material unaccounted for quantit es in August 1973, the cumulative material unaccounted for kilograms of plutonium out of. a total system throughput 400 kilograms.

' This unaccounted for plutonium in not considered significant for the operation involved and is believed to be in the process piping systems. There is no indication of theft or diversion.

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The licensee resumed production operat' ion on Narch 11, 1974..

Action by Regulatory Operations: -

1. An R0 inspector wds on-site from Narch 1 - 11 and observe'd the' preparation for and completion of the licensee's new inventory. -
2. An RO physical security inspec' tion vas conducted.

No significant deficiencies were identified.

3.

Based on the results of the licensee's reinventory and the findings from our inspection, the licensee was permitted to resume production operations. RO will continue to monitor closely subsequent licensee inventories. -

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4. The assis'tants to the Commissioners, the staff of* the' Joint Committee cn Atomic Energy and the Office of Information Services have been i

notified by telephone. '

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Contact:

Further information concerning this occurrence can be obtained from:

I S. E. Bryan 17353 R. D. ThornburgI 17353 I -

J. C. Davis . 17541

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ERR-McGEE NUC EAR CORPORATION N \ LICENSE SNM-1174 h e%9 N, -

/ 0' In reply to he apparent violation cited in the inspection report enclosed with the February 19 letter from Mr. James M. Keppler, the following written statement and explanation answer the require-ment of 10 CFR 2.201. . '!

The citation quotes erroneously that the LE (MUFH) which according to our license was to be determined and reported as of June 30, for exceeding the limit of 1.5 kgs. specified in the license for LE (MUF). Th E (MUF) e,xpe

  • need by the Plutonium Plant has varied from.O grams to' 0 rams during the same period. While we point out this as an a aly in your citation, we nevertheless recognize this as a
  • serious situation.

The determination of holdup and the related LE was extensively discussed with the Directorate of L1 censing in 1973 prior to the establishment of MPP-1. Our experience in the interin has con-t'inued to demonstrate the difficulty cf close control of these values in the continuous inventory-dominated process in use in the Cimarron Facility.

In recognition of this situation, the following steps are in progress to better . control the holdup quantity in. its variability.

1. Safeguards clerks have been added to the staff to achieve positive control and recording of material m,ovements as of March,11, 1974.
2. The primary source of this difficulty as noted by your inspector has been the assay and the quantities of dilute e

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scrap solutions awaiting recovery in the s.olvent extraction cy cl e .

I We aree currently investigating alternate assay procedures employed by other laboratories to improve our analytical precision.

The incorporation of improved methods will not occur before May 1,1974.

I Demonstration of full compliance with this license may require up to six months to determine the effec'tiveness of the changes described above.

In our proposed material control plan submitted March 5 to the Directorate of Licensing, copy to your Mr. Jack Hynd, describes alternate license provisions and the justification more complete'ly.

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_ REVISIONS T0 !!ATERIAL AND PLANT PROTEC AMENDMENT tiPP-1 TO LICENSE NO. SNM-928 ,,

1. Condition 3.6
  • The measurement program required under this Section shall be reviewed atinually by the Safeguards Specialist be documented and reported to licensee manageme. n t. Results shall
2. , Condition 6.5.3 The Manager, Administration and Accountability, or his riesignat representative shall verify the completeness of each physical inventory. ,

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