ML20215F169

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Partially Withheld Details of Insp Repts 70-0925/82-02 & 70-1193/82-02.No Noncompliance Noted.Major Areas Inspected: Security Organization,Training,Guard Qualification,Physical Barriers,Intrusion & Detection Alarms & Key Control
ML20215F169
Person / Time
Site: 07000925, 07001193
Issue date: 03/31/1982
From:
NRC
To:
Shared Package
ML20215F104 List:
References
FOIA-86-576 70-0925-82-02, 70-1193-82-02, 70-1193-82-2, 70-925-82-2, NUDOCS 8612230290
Download: ML20215F169 (15)
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Text

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< mr i DETAILS O

  1. ]! f hI
1. Persons Contacted
  • A. W. Norwood, Standby Plant Manager
  • R. Fine, Health and Safety Supervisor
  • M. Hodo, Administration and Accountability Clerk
  • V. Richards, Decontamination Supervisor and Custodian
  • J. L. Kegin, Maintenance and Utility Supervisor
  • R. Borgmier, Decontamination Supervisor
  • W. Rhodes, Decontamination Supervisor
  • Denotes those present at the exit interview.
2. Licensee Action on Previous Inspection Findings (Closed) Noncompliance - Severity Level VI (70-1193/81-01): Failure to measure { standards 3uring the week NDA measurements were made on lutonium wastes. Status: Once per month'(each standard is sampled

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0 times with higher and lower limits)to establish control charts, standard] The inspector's review of th(is documentation indicated-ver compliance. Also, the review of the Plutonium Plant Shift Routine form documented the completion of(five counts per standard)n each Monday and Wednesday.

(Closed) Noncompliance - Severity Level V (70-925/81-01): Unauthorized possession of enriched uranium greater than@ercent enrichment.

Status: Amendment No. 5 to SNM-928 dated June 9, 1981, includes condi-tien No. 17 which permits, if during decontamination of the uranium plant and equipment, uranium solutions compounds are generated that have U-235 isotope content greater tha 5 ercent, prompt action shall betakentodegradethesematerialsbelow5)ercentU-235. The licensee was found in compliance with this requirement.

(Closed) Noncompliance - Severity Level VI (70-1193/81-01): Failure todocumenttransfersfromMBA50toMBA12(Vault) Status: Vaste cards are prepared for the transfer of material from HBA50 to MBA12 which reflect a description of the material, NDA values, date of trans-fer, and signed by the MBA50 custodian. These waste cards stay with each drum and are inserted into each waste drum packaged. In addition, a listing of waste card material is maintained in the NDA log by the Health and Safety Supervisor and provides traceability for each item in the drums stored ir(room 121)for subsequent shipment.

(Closed) Noncompliance - Severity Level VI (70-1193/81-01): Failure to use acceptable (tamper-safe seals 3 Nonco 11ance with Licerg e Condition 7.4 of MPP-3. Status: All drums ealed in room 12 y and S-F3 # #I 2 Cop M of 6 copie THIS E ' b i'T IS Z'? TC REPRODUCED WITHOUT SPECI APPROVAL OF RIII 8612230290 B W 19 PDR hLE --576

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containersinthe,hault}ith0.53gramsormorewerebaled3Rith acceptable ofHPP-3.{ypeEmetalseals o comply with License Condition 7.4

3. Exit Interview The inspector met with licensee representatives (denoted in paragraph
1) at the conclusion of the inspection on April 8,1982. The inspector summarized the reviews conducted, scope and findings of the inspection, and status of the previous items of noncompliance (70-925/81-01; 70-1193/81-01), and noted that no items of noncompliance were revealed as a result of this inspection. The inspector did suggest, however, that the material control and accounting procedures be revised to include a description for the use of waste cards in transferring material from MBA 50(drum waste storage) to MBA 12{ Vault 3for packaging. Licensee representatives noted suggestion.
4. Facility Organization No items of noncompliance were noted. The inspection results were attained through review of uranium and plutonium procedures, and discussions with licensee personnel.

There have been no major changes in the site organization as it pertains to the Standby Operation. About 13 new employees have been hired and five lost to other Kerr McGee divisions which resulted in a net increase of eight employees.

A Decontamination Supervisor position has been created. At present, the number of employees including the Standby Operation Manager, Supervisors, and Guards is 38. On the Corporate level, Mr. B. E. Brown, General Manager, Nuclear Manufacturing, to whom the Standby Operations Manager reported, was transferred in September 1981 to the position of Manager of the Southwest Refining Corporation, Corpus Christi, Texas (a subsidiary of Kerr McGee). From September 1981 to January 1981, the Standby Manager reported to Mr. R. P. Luke, Executive Vice President of the Kerr McGee Nuclear Corporation. Effective in January 1982, Mr. M. H. Binstock, Director, Contract Manage =ent and Cimarron Opera-tions became the responsible individual to whom the Standby Operations Manager reports.

Other than plutonium plant MBA custodians, the primary responsibility for material control and accountability still rests with the Standby Operations Manager, Health and Safety Supervisor, and Administration and Accountability Clerk.

5. Facility Operations No items of nonccmpliance were noted. The inspection results were attained through a review and observation of uranium and plutonium 3

( f plant operations, review of internal procedures, and interviews with key personnel.

Uranium Plant Decontamination and cleanup of the uranium plant continues. Most equipment from the Wet Ceramic Process Area has been removed and all the equipment from ceramic line two has either been sold, transferred to other Kerr McGee facilities, or if not usable, shipped to waste.

Most of ceramic line one equipment has been removed but the licensee has a 20 foot calciner that has not yet been decontaminated. In the pellet area, one grinder and one pellet press has been decontaminated, but most pellet area equipment,is still on hand and this area is currently being worked as time permits. "Ihe pellet process area has about one year's cleanup and decontamination to be completed. The remainder of the scrap processing and storage areas will also require about a year's cleanup and decontamination work. About 50 percent of the equipment in this area has been removed in order to provide space for decontamination. The uranium plant could be finished by the end of 1984. Escalated transportation and burial costs may result in usable equipment (decontaminated, if possible) being sold as scrap metal if it cannot otherwise be disposed. At least another year could be required for the decontamination of usable equipment that has been removed.

Plutonium Plant The licensee is currently engaged in Project III (removal of the solvent extraction system) of its Termination Plan dated November 29, 1978. All equipeent has been removed with glovebox 27A about 75 percent removed; this project should be finished by July or August 1982.

Project IV, as described by the Termination Plan dated January 8,1980, involves the removal of remaining plant equip =ent. All equipment has been removed fromgoom 12} (rod loading, welding, testing, and x-ray).

hoom 1233 presently being utililized for equipment decontamination, is being planned for thehurt@iBA for waste shipment storage. Pro-jected date for completion of Project IV is the end of 1984.

koom 123)as been approved for a storage MBA for packaged waste material awaiting shipment as indicated in the SNM-1174 Termination Plan approved by letter dated October 8, 1980, from Advanced Fuel and Spent Fuel Licensing Branch, Division of Fuel Cycle and Material Safety. Procedures are bein revised to include this MBA and installa-pg, 3 tion of H }S'f) , u r *.

g An amendment for reactivation of the ion exchange system for removal of plutonium from decontamination solutions was submitted to NRC by the Corporate office on March 24, 1982. On March 29, 1982, a sub-4

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mittal was made for the renewal of License SNM-1174 and SNM-928 which were due to expire June 30, 1982.

A tentative date of January 1, 1985 is projected for completing the Termination Plan so that the plutonium building can be used for other purposes.

- ;dyL Measurements and Statistical Controls i

No items of noncocpliance were noted. The inspection results were attained through a review of the NDA methods used in both the uranium and plutonium plants, review of internal records, and discussions with the Health and Safety Supervisor who has measurement responsi-bilities for NDA in both plants.

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. M Uranium measurements are by gamma count'; and when necessary, isotopic analyses for percent U-235 are contracted out to Isotopic Analysis, Incorporated of Tulsa, Oklahoma. During plant cleanup any uranium foundenrichedgreaterthan(5}ercent is immediately mixed with depleteduraniumanddegradatedtobelo(Shercentenrichment, this is authorized if the licens does not exceed its present authoriza-tion (after degradation) o kilograms)-23',enrichedtolessthan (5 ]percent in the isotope U-235. Good material degradated to natural as a liquid can be shipped to the Kerr McGee Sequoyah Plant as

" feed". Nonusable material resulting from plant cleanup is picked up as an inventory gain and removed as a egg,syred discard (offsite burial). During the inspection perio 't?Ugrams of uranium and ha t;46f tgrams U-235 were removed to of fsite burial which involved

. C seveYshipments to Beatty, Nevada, and-six-shipments tr Harnwell, SoutlE-Es rol fra. *d S " /* ' > -J .e T

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The application for use of the ion exchange system for separation of uranium should result in decreasing large waste accumulation and more timely measurement results.

limited measurement control i:The licensee is a Safeguards Group V with equirements with an authorization ofdwe noo .,:,-

Mkgram@-235 enriched to belowMpercent in the isotope U-235.

Limits of error (L.E. 's) were calculated and reported for thMkfsite waste shipments for the inspection period. , - . > , - - . w e . . s r, e, ,,

.~ 1S.r' . . . . . - . .: M. .- ,:s  :. e .

e Plutonium Plant Gram determination in the plutonium lant is by NDA using ahudlum Model25Scaledanda(y,aI(th)Crysta Standards in matrices and geometrics appropriate for operations are sampled 20 times 3each month witQigher/ lower limits 3to establish control cha(rts. Each standard' is counted {five timepn both Monday and Wednesday of each week.

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fOfthek,592gramh 59 rojected to be in the solvent extraction , p f.;

ksystem,asofMarch4,Q77.792gramQU-235.$v1982,Q a remaining balance of 214.208

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gram Non-transuranic material, previously known as non-line material, has a plutonium content limitation of(0003 grams)and each package for shipment to waste burial sites is limited to , ten nanocuries per gram in low specific activity (LSA) waste, p'rtheinspectionperiod,the licensee had shipped to waste buria -

drums f solid non-transuranic waste. As of the inspection, the licensee ha ackaged and sealed drumsofnon-transuranicwasteinfrees121(wsstestorageg WA -

Transuranic waste is waste with a plutonium content of greater than

[0003 grams)materialingloveboxes,andgloveboxitems. The waste resulting from the dismantling of the solvent extraction system is primiarily transuranic in excess of the LSA limit of ten nanocuries b@

per gram. 'Ihe transuranic gram limit per package is grams h U for metal, glass, etc. , and@ gramsjfor hydrogenous [ material such as oil. As of the inspection period, the licensee hadhhadaQd h and sealed drums of transuranic waste in, men 121 (waste storage)dc

'A3A Shipping and Receiving . f;r ,...;,

. . , , No items of noncompliance were noted. Inspection results were attained g

f,., q, . ' by review of records and Forms NRC-741.

9 ' 'A # ',' " ~ ". .The licensee in its present standby status has had no external receipts.

Holdings in uranium are increased as a result of uranium plant cleanup

y. . I.k' ^" reported as an inve tgry difference gain. This recovered material is degradated if abov SJpercent enrichment and if usable,j liquid form,

,g~, it is shipped as feed to the Sequoyah Plant. If below5 ercent enrich-p ment and not usable, the material is drumged, for subse uent shipment to burial. During the inspectiong[eriod, made to waste burial sites totalri 803 0754-3 gramship ~

[ments of uranium 'M d were grams U-235. For the plutonium plant waste comprising negative quantities (less$46 thandrum 1 gram) #o'fwere'nos'shipped transuranic to U. S. Ecology, Beatty, Nevada.

8. Storage and Internal Controls No items of noncompliance were noted. The inspection results were were attained by reviev of internal transfer documents and seal accountability in the plutonium plant.

ne entire uranium plant isconsidered(oneMB "Iherefore, internal transfers are not required. (amper-safe seals re controlled by the Administrative and Accountability Clerk (AAC) and stored in a fire resistant combination lock file cabinet for the uranium lant. 19eals3 are applied by the AAC and posted to the{ampersafe seal og and use is verified by the Health and Safety Supervisor. {ype C paper sea 1Q' are used in the uranium plant.

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hamper-safeseals)intheplutoniumplantarecontrolledbytheHealth and Safety Supervisor and storage Custodians. 11 seals"%ppliedto containers are cross referenced on the interna transfer form and the drumisassignedthesamenumberasthehpliedseal) Signature on theinternaltransferformsignifyproperapplicationofthepea}

and witness by shipper and receiver signatures.

,hetaltypeEseal) pre-numberedfromnumberonetoonethousandwere accountedforasf89used{ealgand611unusegals],

Material resulting from dismantling in MBA50 oldup Plutonium and fieneral Laboratory and transferred to MBA1 on waste cards whi accompany the drums. Vaulthistransferred en the drum is packaged each waste card representing items is inserted into the drum. In addition, a listing of waste card material is maintained in the NDA Log by the Health and Safety Supervisor which allows for traceability of each item subsequent in the drums stored irhoom 121 (Waste Storage}for shipment.

Movement of SNM into and out of MBAs is based on measurement. Losses can be localized, and discrete item control is on an MBA basis,

9. Inventory No items of noncompliance were noted. The inspection results were attained by physically accounting for all items in both the uranium and plutonium plants and review of inventory procedure.

Uranium Plant Physical inventories are being performed every six months as required by 10 CFR 70.51 and licensee procedure, KM-NU-15-8. SNM Inventory Reports are submitted to NRC Region III within 30 days after the start of each ending physical inventory as required. Except for the soda ash solution contained in tanks, the inspector physically verified the 14 drums of solids, 30 drums of drummed waste and 8 standards in storage at the uranium plant. The uranium inventory as of March 31, 1982, was (4,513 grams}uraniumandkS1 grams)-235describedasfollows:

.U. U-235

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a. Solids 11,2227 I 302 I
b. Soda Ash Solution 29,295 258 l
c. Drummed Waste 13,092 <262 s  ;(

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Standards

904 29 i

r Total 54 ,513s(

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Plutonium Plant Physical inventories are being performed every 60 days as required by both 10 CFR 70.51 and licensee procedures. Reports of each inventory are submitted to NRC Region III as required. Except for the plutonium in MBA50{Glovebox holdup plutoniumgall SNM is stored in thehault)(MBA12) andQoom 121}hich consists of SNM packaged for shi ment to burial. The%y,ault)(MBA50) inventory was comprised of hour ' standards, an(ongTPu-238 neutron source.

'Ihe oom12@BA consisted of g42prums of transuranic waste and(18){ rums of non transuranic waste which were physically verified b the ctor..

The plutonium inventory as of March 31, 1982, was ^'W' "

plutonium broken down by NBA as follows:

9 //M MBA Plutonium /

a. 12kault)3
b. hoom12h(WasteStorage) h*
c. 50,hloveboxholdup)

Total 3

g Records and Reports No items of noncompliance were noted. The inspection results were attained through review of licensee authorizations, licensee journal entries used to post uranium gains, blending and degradation resulting

. from cleanup, and Forms NRC-741 and NRC-742.

Amendment No. 5 to License SNM-928 dated June 9, 1981, from Uranium Fuel Licensing Branch, Division of Fuel Cycle and Material Safety allows for prompt action to degrade material greater tha(5)ercent enrichment generated as a result of plant decontamination. This change was needed to avoid a continuous state of noncoepliance for possessing enriched uranium enriched greater thadS)ercent. Such material has been recovered and probably will continue since the f acility once percent processed high enriched uranium (above both(5 and 203 enrichments).

The only plutonium activity for the inspection period was the shipment of non-reportable SNM as .aon-transuranic material comprised of 16 3 drums to waste burial and a deduction for plutonium,241 decay jlOs I

Forms NRC-741 for the 13 uranium offsite burial shipments were traced j(f0 tri to supporting data and agreed to the Facility Uranium Ledgers. Forms NRC-741 were prepared and distributed as required by 10 CFR 70.54 and related instructions.

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All ledger entr,ies for enriched uranium for the period of inspection except for the 13 shipments to offsite burial, resulted from jourrial entries, a form provided as a source document to support ledger entries.

All journal entries were prepared to account for inventory difference gains due to plant cleanup, blending with depleted uranium, All journal entries were supported and traced to ,the percent.

facility (m agreed to Forms NRC-742 for periods ending March 1981, September 1981, and March 1982, signed by the Administration and Accountability Clerk, and approved by the Standby Operations Manager.

Recovery of enriched uranium greater tharhercent in the isotope U-235, resulting f rom plant cleanup, requires that it be promptly degradated to less thar{hpercent enrichment. This activity results in a reopening of the above 5 percent uranium ledger and a separate Form NRC-742, the above@p[er] cent activity for the period o is documented in Exhibit B of this report.

License No. SNM-Il74 authorizes possession of 11.475 kilograms of plutonium and .240 kilograms plutonium as samples and sealed sources for a total of 11.715 kilograms. The licensee possesses a plutonium 238 neutron source containing AseparateFormNRC-742ispr(eparedtoreport.0 grams)1utonium this material type. and(

License N . SNM-928 authorizes possession of two kilograms U-235 not to exceed ercent enrichment in the isotope U-235. Exhibits A and B document, respectively thelessthan(5)percentenricheduraniumand the greater thanhercen,t enriched uranium activity for the period of inspection (January 27, 1981 to March 31, 1982). Exhibit C reflects the plutonium activity for the same period.

Attachments:

1. Exhibit A - Kerr McGee Nuclear Corporation Enriched Uranium Material Balance Statement Below 5 Percent
2. Exhibit B - Kerr McGee Nuclear Corporation
3. Enriched Uranium Above 5 Percent - Material Balance Statement Exhibit C - Kerr McGee Nuclear Corporation Plutonium Material Balance Statement 9

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Addendum 1 to Report 70-1193/82-02; 70-925/82-02 Kerr McGee Nuclear Corporation Docket No. 70-1193

1. General i

During the routine MC&A inspection, the inspector reviewed and observed the physical security system including security organiza-l i

tion, guard training and qualification, physical barriers, intrusion detection alarms, records of events, access controls, and key control.

No items of noncompliance were noted.

2. Security Organization The Corporate Security Director is located in the Corporate Office in Oklahoma City. The Standby Operations Manager acts as the onsite Se

%curityDirector. '!he site security organization is comprised of Kerr McGee employees categorized as follows:

a. supervisors (includes Site Manager)
b. guards
c. health physics personnel d.

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' utility operators.

The licensee maintains security seven days a week, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, and operates on three shifts. In order to maintain three shifts,

% guards are required. The site security program rotation is divided into four shif ts (A. , S. , C. , and D.), on each shift ish health physics employee, and M utility operator. These employees are trained to relieve the guards as necessary.

The licensee facility has on1 1 ot er s within the MAAs except the include the rocessing area an aterial Access areas orator ndthegault (room 126h The primary central alarm station is located in the A second central a arm station is established at The on t e oorways, th a the isolation zone, and the en alarm annunica ce metal ctor visually and audibly at both alare stations.

e testing of the alarms at the Cimarron Facility, t e nspector verified that the alare station responded to this unannounced testing.

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3. Training ne inspector's review of training records revealed that training had been accomplished for supervisors, guards, and security organization employees as follows:

June 1981 - The annual rity qualification test including guards  ;

guard relief personnel supervisors g and employees l Third Quarter 1981 - Review of physical securit frements of  !

Amendment MPP-3 of License Sh?! 1174 attended by guards, supervisors, and % facility employees.

First Quarter 1982 - Training conducted by the Standby Operations Manager on March 29 and 30, 1982, on the following topics.

a. Demonstration and trespasses b.

Emergency building lights and gates through fence to coal yard area c.

Tour of plutonium plant to observe and discuss vaste shipment loadout operations and security alare systees.

This class was attended by % guards, supervisors,. relief g personnel ghealth physics andgati ity operator), an i

facility employees.

4. Guard Physical Examinations Annual physical examinations for the guards were dated as follows:
a. guard 3/31/80, 3/18/81, and 3/26/82.
b. guard 9/22/80 and 8/28/81.
c. guard 6/26/81 (new employee)
d. guard 12/4/80 - 2/19/82 (December 1981 physical delay ecause of illness).

There were no noted physical impairments which would preclude carrying out of job requirements. '

5. Guard Qualification An employee from the Oklahoma City Police Department (OCPD), Assistant Gun Range Master is hired by the licensee to conduct qualification requirements for th guards at the licensee's range (built in the Tall of 1978). All guards qualified twice from the period 10/5/80 to 4/4/82. n inspector reviewed the targets used, which were signed by both the instructor and participant, the scores ranged from 82 to 98, and the average for the eight qualifications was 93.5.
6. Physical Barriers:

The inspector noted that the perimeter fence was in good repair and no openings due to damage or erosion were observed. ne isolation zone was clear of objects to prevent concealment and to aid in observing entrance into the protected area. Entrance to the vital area and material access areas requires passage through more than one physical barrier.

7. Intrusion and Detection Alarms:

Operating Sh3 detectors are located at the personnel and material exits of the plutonium lant buildings. The ere checked and determined operable by the inspector.

I Using the securit guard weekly check sheet, the ins ector tested the alarms on the the the l

the the and )

tests. arms were ound operable. tempts to approach the vehicle gate and the perimeter fence i Alarms were tested for opera 1 aty at least each seven days as required.

! The inspector reviewed the security guard daily check lists which included tests of the ShH detectors (entrance and dock area), metal detector, explosive detector, plutonium plant fence, isolation zone seals on plutonium plant emergency gate, condition of uranium plant fence, seals on the uranium plant emergency gate, outer fence area for damage, and the condition of the perimeter fence. In addition, the shift check lists included checks on the ano t

8. Records of Events i

Host of the unusual incident reports re riewed by the inspector involved only weather and electronic failures and minor trespassing j problems with remedial action noted.

l In July 1981, some temporary communication problems existed for '

about one week because the tel hone company converted their tele-phone system which resulted in a temporary loss of the communication system ~

1981, the telephone company converte o the to correct the communication problem.

9. Access Controls l

All yees (including coal liquification employees) have a E  !

or entrance to the protected area. He inclusion 1 3

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area is controlled by guard access. Visitors a Corporate personnel i

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All 38 employees have plant access to all vital areas and MAAs. New employees are escorted until training is completed. Visitors, including j Corporate personnel, require escort. Nine employees are allowed access j without escort at any time, and no escort is required for the other i 29 employees during normal duty hours. Escort is required for these r employees during off-duty hours.  !

i The vital area is and a r log for access is maintained documenting date, time, individual,  ;

i badge number, and reason for entry.

1 Photo-identification badges are required for unescor the protected area. Personnel and packa e search )

i is performed on a )

The is conducted

10. Key Control j

Issuance and control of keys is the responsibility of the Standby Operations Manager.

a Key control is maintained by security, and receivers sign for keys. Keys for security locks were maintained in a locked cabinet in the Combinations I are issued on a need-to know basis and supervisory personnel are authorized to issue combinations.  !

i In a letter from Division of Safeguards, h3SS, dated August 21, 1980, the licensee was granted an exemption to the requirement of the l " Upgrade Rule" to submit '

! a revised " Category I" physical security plan. 1 1 This exempted the licensee f rom the requirements of Sections 73.20, 73.45, and 73.46, as pertains to the submittal of a revised physical security plan.

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Kerr lear Corporation - YEC Enriched Uranium Material Balance Statement Beloyhh For Period 1/28/71 - 3/31/82 Enriched Uranium In Grams U __U-235 Beginning Inventory 1/27/81 .

Receipts Total to Account For j -

Shipments p- )

Degradation (to natural) 26,803 620 - ~'

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Measured Discards (of f site burials) 80,075 2,788

. Inventory Discrepancy (141,903) (3,725) 3? S 1

Ending Inventory 3/31/82 3' i

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y Total Accounted For _

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EX111 BIT A

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Kerr McGee Nuclear Corporation - YEC - SNH - 928 EnrichedUraniumAbove{$%)-MaterialBalanceStatement For Period 1/27/81 - 3/31/82 Enriched Uranium In Crams U U-235 F~

Beginning Inventory 1/28/81 -0~

From Other SS Haterial (Depleted)

Total to Account For Inventory Dif ferences (AboveQ1)j

},. (11,336) -

(1,178) T 3

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To Other SS Material (Below5%) g 26,136 1,208 Ending Inventory 3/31/82 Total Accounted For 3

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EXHIBIT B

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_g Kerr McGee Nuclear Corporation Plutonium Material Balance Statement For Period 1/27/81 - 3/31/82 Plutonium In Crams Pu _

Isotope Beginning Inventory 1/27/81 Pu-241 Decay (-)

Ending Inventory 3/31/82 E

Summary MBA-50$(eHoldup)]

MBA - 12 Vaulth MBA - Room 121' Waste Storage)

Total

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  1. M viog t,)) #5 g t) f O l

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AI Includes a one gram Pu-2 EXHIBIT C

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