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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20127N1661992-11-24024 November 1992 Submits Results of Review of Oak Ridge Assoc Univs Survey Repts on Burial Ground in Northeastern Portion of Site & Two Sewage Lagoons as Part of Site Decommissioning.Two Areas Adequately Decontaminated.Closure Recommended ML20153F3531985-12-20020 December 1985 Recommends Approval of 850806 & 1119 Applications for Amend to License SNM-1174,revising Organization & Administrative Controls of Health & Safety Program ML20211L4231984-10-25025 October 1984 Forwards Dept of Labor Notice of Alleged Safety or Health Hazard.Investigative Effort Unwarranted at Present. Allegation Will Continue to Be Carried as Open in Allegation Tracking Sys,Pending Final Resolution ML20211L4951983-04-0303 April 1983 Summarizes 830406 Investigation of Allegation Re Burial of Pu Waste Along Banks of Cimarron River.Region III Records Indicate Licensee Did Not Bury Wastes Onsite ML20211L5101983-02-22022 February 1983 Forwards Ltr Received on 830222 Alleging That Large Quantities of Pu Wastes & Associated Contaminated Matls Buried Along Banks of Cimarron River.W/O Encl ML20147B9131978-11-14014 November 1978 Summarizes 781102-03 Trip Rept in Support of Licensing Review of Proposed Amend Allowing Dismantling & Removal of Solvent Extraction Equipment & Related Glovebox ML20148K1591978-10-24024 October 1978 Notice of Meeting on 781018 to Discuss Part III of Lic Termination Plan of Subj Plutonium Plant,Which Proposes to Dismantle the Solvent Extraction Equip & Its Associated Glove Box.Site Visit Planned for 781030 ML20148K1711978-10-13013 October 1978 Notice of 781017 Meeting w/Kerr-McGee Nuc Corp to Discuss Part 3 of Termination Plan for Lic SNM-1174.Incl Dismantling & Removal of Plutonium Plant'S Solvent Extraction Equip & Associated Glovebox ML20235A7991978-02-0303 February 1978 Responds to 780202 Telcon Request for Reasons That Region III Diversion Risk Analysis Study on Facility Should Not Be Released to Parties Involved in Legal Action Re K Silkwood Incident ML20235A7081976-05-11011 May 1976 Forwards Gossick Opening Statement for 760426 Kerr-McGee/ Dingell Hearings & Supplemental Testimony Prepared in Response to Issues Raised.Meeting Requested for 760514 to Discuss Encls & Other Major Issues ML20136E4131975-08-15015 August 1975 Forwards Investigation Rept 70-1193/75-09 Re Nitric Acid Reaction During Waste Shipment.Div of Matls & Fuel Cycles Should Be Notified of Problem.Listed Position in Reg Guide 3.12 Should Be Made License Condition.Related Info Encl ML20209D7781975-04-23023 April 1975 Forwards Licensee 750408 Response to 750319 Items of Noncompliance.Response to Deficiency 3 Re Transportation Security Plan Should Be Referred to NMSS for Resolution ML20198A6991975-03-20020 March 1975 Summarizes Osha,Ocaw & NRC Inspections of Kerr-McGee Cimarron Facility.Unsafe Allegations from Ocaw Come Prior to Contract Bargaining.No Evidence That Ocaw or Employees Attempted to Resolve Alleged Unsafe Practices ML20209D3031975-01-15015 January 1975 Forwards Info Re Muf Incidents,Corrective Actions & Enforcement Actions at Facility,Per Bryan Request ML20198A6691974-12-30030 December 1974 Partially Withheld Ltr (Ref 10CFR2.790) Discussing Unusual Incident Involving U Dioxide Pellets Found Outside U Fabrication Facility at Cimarron Plant.No Health or Safety Threat Involved ML20198A6571974-12-0909 December 1974 Partially Withheld Rept (Ref 10CFR2.790) Re Diversion Risk Analysis of Major Fuel Processing Facilities.Suggests That Consideration Be Given to Amending Licenses or Adding Regulations ML20215L7091974-11-22022 November 1974 Forwards Chronology of Violation History Resulting from Criticality,Health Physics,Matl Control & Physical Security Insps,Per Bryan 741121 Telcon Request ML20198A6511974-11-22022 November 1974 Partially Withheld Ltr (Ref 10CFR2.790) Discussing Possibility of Diversion of Trigger Quantity of Pu.No Indication That Diversion occurred.Kerr-McGee Security & Matl Control Plans Adequate ML20215L5361974-05-13013 May 1974 Summarizes 740509 Meeting Re F Welch 740506 Internal Memo Entitled, Rept of Exposure. Licensee Asked to Explain Why Matter Not Reported to Region III When First Known.Informant P Ellis Vague,Changed Story & Had No Evidence of Claim ML20209D2761974-04-0303 April 1974 Forwards Kerr-McGee Summary Rept Re Cimarron Pu Plant Inventories of 740215 & 0308.Corrective Action Should Produce Better Matl Balance Results.Licensee Does Not Recognize Limits of Error Associated W/Holdup Quantity ML20209D2651974-03-14014 March 1974 Forwards Notification of Incident or Occurrence Containing Results of Mar 1974 Pu Reinventory.Recommends Notice Be Issued as Blue Sheet ML20209D2471974-03-12012 March 1974 Discusses Kerr-McGee Feb 1974 Muf Quantity.On 740228, Licensee Notified Region That Feb Monthly Pu Inventory Indicated Positive Muf Loss Quantity.Cause Under Investigation.Fuel Fabrication Stopped ML20209D2591974-03-12012 March 1974 Advises That Licensee Feb 1974 Muf Quantity Does Not Present Health or Safety Problem Based on 740211-15 Insp ML20209D2141974-03-0101 March 1974 Forwards Draft Notification of Incident or Occurrence Re Kerr-McGee Pu Muf Quantity.Recommends Issuance as Blue Sheet ML20151L3991966-08-12012 August 1966 Forwards Compliance Investigation Rept on 660713-14 Re Apollo,Pa Resident Allegation Concerning Effluent from Facility 1992-11-24
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20127N1661992-11-24024 November 1992 Submits Results of Review of Oak Ridge Assoc Univs Survey Repts on Burial Ground in Northeastern Portion of Site & Two Sewage Lagoons as Part of Site Decommissioning.Two Areas Adequately Decontaminated.Closure Recommended ML20153F3531985-12-20020 December 1985 Recommends Approval of 850806 & 1119 Applications for Amend to License SNM-1174,revising Organization & Administrative Controls of Health & Safety Program ML20211L4231984-10-25025 October 1984 Forwards Dept of Labor Notice of Alleged Safety or Health Hazard.Investigative Effort Unwarranted at Present. Allegation Will Continue to Be Carried as Open in Allegation Tracking Sys,Pending Final Resolution ML20211L4951983-04-0303 April 1983 Summarizes 830406 Investigation of Allegation Re Burial of Pu Waste Along Banks of Cimarron River.Region III Records Indicate Licensee Did Not Bury Wastes Onsite ML20211L5101983-02-22022 February 1983 Forwards Ltr Received on 830222 Alleging That Large Quantities of Pu Wastes & Associated Contaminated Matls Buried Along Banks of Cimarron River.W/O Encl ML20147B9131978-11-14014 November 1978 Summarizes 781102-03 Trip Rept in Support of Licensing Review of Proposed Amend Allowing Dismantling & Removal of Solvent Extraction Equipment & Related Glovebox ML20148K1591978-10-24024 October 1978 Notice of Meeting on 781018 to Discuss Part III of Lic Termination Plan of Subj Plutonium Plant,Which Proposes to Dismantle the Solvent Extraction Equip & Its Associated Glove Box.Site Visit Planned for 781030 ML20148K1711978-10-13013 October 1978 Notice of 781017 Meeting w/Kerr-McGee Nuc Corp to Discuss Part 3 of Termination Plan for Lic SNM-1174.Incl Dismantling & Removal of Plutonium Plant'S Solvent Extraction Equip & Associated Glovebox ML20235A7991978-02-0303 February 1978 Responds to 780202 Telcon Request for Reasons That Region III Diversion Risk Analysis Study on Facility Should Not Be Released to Parties Involved in Legal Action Re K Silkwood Incident ML20235A7081976-05-11011 May 1976 Forwards Gossick Opening Statement for 760426 Kerr-McGee/ Dingell Hearings & Supplemental Testimony Prepared in Response to Issues Raised.Meeting Requested for 760514 to Discuss Encls & Other Major Issues ML20136E4131975-08-15015 August 1975 Forwards Investigation Rept 70-1193/75-09 Re Nitric Acid Reaction During Waste Shipment.Div of Matls & Fuel Cycles Should Be Notified of Problem.Listed Position in Reg Guide 3.12 Should Be Made License Condition.Related Info Encl ML20209D7781975-04-23023 April 1975 Forwards Licensee 750408 Response to 750319 Items of Noncompliance.Response to Deficiency 3 Re Transportation Security Plan Should Be Referred to NMSS for Resolution ML20198A6991975-03-20020 March 1975 Summarizes Osha,Ocaw & NRC Inspections of Kerr-McGee Cimarron Facility.Unsafe Allegations from Ocaw Come Prior to Contract Bargaining.No Evidence That Ocaw or Employees Attempted to Resolve Alleged Unsafe Practices ML20209D3031975-01-15015 January 1975 Forwards Info Re Muf Incidents,Corrective Actions & Enforcement Actions at Facility,Per Bryan Request ML20198A6691974-12-30030 December 1974 Partially Withheld Ltr (Ref 10CFR2.790) Discussing Unusual Incident Involving U Dioxide Pellets Found Outside U Fabrication Facility at Cimarron Plant.No Health or Safety Threat Involved ML20198A6571974-12-0909 December 1974 Partially Withheld Rept (Ref 10CFR2.790) Re Diversion Risk Analysis of Major Fuel Processing Facilities.Suggests That Consideration Be Given to Amending Licenses or Adding Regulations ML20215L7091974-11-22022 November 1974 Forwards Chronology of Violation History Resulting from Criticality,Health Physics,Matl Control & Physical Security Insps,Per Bryan 741121 Telcon Request ML20198A6511974-11-22022 November 1974 Partially Withheld Ltr (Ref 10CFR2.790) Discussing Possibility of Diversion of Trigger Quantity of Pu.No Indication That Diversion occurred.Kerr-McGee Security & Matl Control Plans Adequate ML20215L5361974-05-13013 May 1974 Summarizes 740509 Meeting Re F Welch 740506 Internal Memo Entitled, Rept of Exposure. Licensee Asked to Explain Why Matter Not Reported to Region III When First Known.Informant P Ellis Vague,Changed Story & Had No Evidence of Claim ML20209D2761974-04-0303 April 1974 Forwards Kerr-McGee Summary Rept Re Cimarron Pu Plant Inventories of 740215 & 0308.Corrective Action Should Produce Better Matl Balance Results.Licensee Does Not Recognize Limits of Error Associated W/Holdup Quantity ML20209D2651974-03-14014 March 1974 Forwards Notification of Incident or Occurrence Containing Results of Mar 1974 Pu Reinventory.Recommends Notice Be Issued as Blue Sheet ML20209D2471974-03-12012 March 1974 Discusses Kerr-McGee Feb 1974 Muf Quantity.On 740228, Licensee Notified Region That Feb Monthly Pu Inventory Indicated Positive Muf Loss Quantity.Cause Under Investigation.Fuel Fabrication Stopped ML20209D2591974-03-12012 March 1974 Advises That Licensee Feb 1974 Muf Quantity Does Not Present Health or Safety Problem Based on 740211-15 Insp ML20209D2141974-03-0101 March 1974 Forwards Draft Notification of Incident or Occurrence Re Kerr-McGee Pu Muf Quantity.Recommends Issuance as Blue Sheet ML20151L3991966-08-12012 August 1966 Forwards Compliance Investigation Rept on 660713-14 Re Apollo,Pa Resident Allegation Concerning Effluent from Facility 1992-11-24
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/ 4, UNITED STATES
['r 4 NUCLEAR REGULATORY COMMisslON jI
, I. I j WASHINGTON, D. C. 20555
% 'N OCT t 3 -- .
..... yo-nes !I Docket No.1193 MEMORANDUM FOR: Richard W. Starostecki, Chief
Fuel Reprocessing and Recycle Branch Division of Fuel Cycle and Material Safety FROM: Charles J. Haughney Fuel Reprocessing and Recycle Branch Division of Fuel Cycle and Material Safety
SUBJECT:
UPCOMING MEETING WITH KERR-MCGEE NUCLEAR CORPORATION o
Date and Time: October 17, 1978, 9:00 a.m. '
. Location: 5th Floor Conference Room (Rm 517)
Willste Building, 7915 Eastern Avenue ,
Silver Spring, MD i f
Purpose:
To discuss Part III of the Termination Plan for License SNM-1174.
Part III deals with the dismantling and removal of the plutonium plant's solvent extraction equipment and its associated glovebox. The attached list of conments will serve as a basis for discussion during the meeting.
Participants NRC Kerr-McGee C. J. Haughney G. L. Sinke C. N. Smith A. W. Norwood, et al.
N. Ketzlach, et,al_.
Attendance by persons other than meeting participants is permitted.
However, in order to accomplish the purpose of the meeting, discussion during the meeting will be limited to the meeting participants.
. /
Charles J. aughney b 781117db 40 Fuel Reprocessing and hecych.L ranch Division of Fuel Cycle and Material Safety
Enclosure:
List of comments
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COMMENTS ON PART III 0F THE TERMINATION PLAN (SOLVENT EXTRACTION EQUIPMENT AND GLOVEB0X REMOVAL)
A. Prevention of Inadvertent Criticality The license conditions for the standby operation authorized' under License SNM-1174 do not contain requirements to prevent nuclear criticality. The NDA measurements following plant cleanout indicate the presence of 1592 grams of plutonium in glovebox 27A.
The activities associated with decontamination and removal of glovebox 27A will cause redistribution of that plutonium.
Although Part III of the termination plan briefly touches upon some methods of preventing an inadvertent criticality, sufficient information has not been provided to allow a determination of the adequacy of criticality prevention measures. The nuclear criticality safety aspects of each step of. the decommissioning activities need evaluation and justification.
Some examples of unresolved criticality safety issues are presented below:
- 1. There is no mention of the use of a criticality monitoring and' alarm system as required by 10 CFR 70.24.
. 2. Five inch diameter, four. liter bottles will be placed in the
, bottom of the glovebox to collect oil from the hydraulic pumps. What array of bottles, and justification for its nuclear criticality safety, both inside and outside the glovebox, will be used to prevent criticality?
- 3. The plan states that decontamination solutions inside the glovebox will be diluted to less than 10 grams of plutonium per liter and that these solutions will not accumulate to a depth greater than two inches in the bottom of the glovebox,
- a. How will the concentration of the decontamination solutions be determined to be less than 10 grams per liter?
- b. How will the solution depth be maintained less than two inches?
- c. Are there any sumps or unusual configurations in the bottom of the glovebox or in the equipment used to transfer used decontamination solutions that are geometrically unsafe?
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'd. IDuring unbolting, cutting and removal of equipment-
.inside glovebox 27A, what. provisions will'be made to collect ' solution _ drainage?1 Nill geometrically safe containers be used?' What will be the array.and spacing.of>any such containers both inside and outside,
-the glovebox?
- e. Specifically which geometrically safe receiver tanks will be used to receive used decontamination solutions?~
- f. Describe the method of1 transferring the used decon -
tamination solutions from the receiver tanks.to the solidification equipment. Include. assurances that '
this transfer will take place in geometrically safe equipment..
- g. How much of the' plutonium in glovebox 27A is in the form of 4 deposited solids,.both inside a'nd outside equipment in the glovebox? What measures will be taken to prevent collec- i tion and concentration of any such solids in a critical
. configuration?.
- 4. The administrative controls that are needed for criticality safety have not been addressed. A description of these administrative controls should discuss training and procedural
- control. ;
B. Fire Prevention The dismantling plan for glovebox 27A states that the halon fire extinguishment system will be preserved as long as possible.
- 1. . At what stage in the dismantlement will the halon system-be disabled?
- 2. Can it be preserved until after removal of decontamination solvents? .
- 3. How much cutting of metal components must take place follow-ing disabling of the halon firo system?
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C. Work Practices i
- 1. Cutting and Rigging of Heavy Equipment More information is needed on procedures to be employed when cutting, rigging and removal of heavy equipment from glovebox 27A. Precautions to be employed to prevent dropping heavy components, personnel injury and breaching the glovebox confinement boundary need to be discussed. Discussion of any scaffolding needed to accomplish dismantling is also needed.
- 2. Glovebox Lighting and Visibility Is the existing glovebox lighting adequate for the dismantling activities? Are there sufficient existing glovebox windows to permit disassembly of internal equipment and piping?
Will special lights or windows have to be installed?
- 3. Dismantling Sequence Although the Part III termination plan lists major equipment to be removed from glovebox 27A, a sequence of dismantling steps was not provided. In a manner similar to that provided for your revised Part I termination plan submitted October 11, 1977, include the sequence of equipment removal and dismantling steps for glovebox 27A. Identify the specific equipment by number.
- 4. Control and Scheduling of Daily Work Will the dismantling of glovebox 27A take place on day shift only? If so, what provisions are made to insure a safe shutdown of decommissioning activities at the end of a shift?
Who will certify that a safe shutdown has been conducted?
D. Contamination Control and Monitoring
- 1. Part III of the termination plan states that contamination controls' described in your general termination plan dated ;
November 8,1977 and in your Part I termination plan dated October 11, 1977 will apply to activities conducted under Part III. However, the Part III plan does not discuss the use of tents or " greenhouses" for contamination control during dismantlement of glovebox 27A. - A description is needed of the use of tents or " greenhouses" for additional contamination control, j l
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- 2.:iMonitoring Provisions j
' Part' III of the' termination ' plan. states that.monitorirJJ il
' described -in the general termination plan dated November 8, 6'
- .1977 and in the Part I termination plan dated October .ll',1977 ,
!will apply. But neither of these plans ' discuss air inonitoring d' in rooms B-05 and 127 containing glovebox 27A or in ~the rooms
~used to package waste shipment-containers. The monitoring f:
provisions needed for activities in Part III. need to be specifically addressed. ;t t:
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