IR 05000264/1978004

Sanitized Version of Insp Rept 50-264/78-04 on 781116 & 17. No Noncompliance Noted.Major Areas Inspected:Snm Control & Accountability,Including Facility Organization & Operation, Measurement & Controls,Inventory & Shipping & Receiving

ML20137D370
Person / Time
Site:	Dow Chemical Company
Issue date:	12/27/1978
From:	Hind J, Patterson J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137D185	List: IR 05000264/1976002 IR 05000264/1978004 IR 05000264/1983001 ML20137D178 ML20137D322
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 50-264-78-04-01, 50-264-78-4-1, NUDOCS 8508220464
Download: ML20137D370 (8)

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JAN 02 379

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Docket :.e. 50-26 Dev Cherical Company ATi;;: Dr. R. R. Langner, Chairman Radiation Saf ety Cor:-it tee

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Ecilding 1603 d > < Midland, Michigan 48640 ,,

Gentlenen:

This refers to the safeguards inspection of your TRIGA reactor facility conducted on November 16 and 17, 1976, by Mr. J. P. Patterson of this office and to the discussion of our iindings with Dr. G. Kochanny and Mr. K. Kelly of your staf f at the conclusion of the inspection. Your activities pursuant to Title 10, Code of Federa.1 Regulations, Part 70,

"Special Nuclear Material" as they pertain to License No. R-108 were the subject of this inspectio The enclosed copy of our inspection report identifies areas examined

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during the inspectio Within these areas, the inspection consisted of a selective exarination of procedures and representative record observations, and interviews with personne No ite:s of noncompliance with NRC requirements were identified during the course of this inspectio Areas examined during the inspection concern a subject matter which is exempt from disclosure according to Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Tederal Regulations. Consequently, our report of this inspection will not be placed in the Public Document Roo \ ,

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We vill gladly discuss any questions you have concerning this

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Safeguards Branch I

. F.nclosure: IE Inspection

' Report No. 5 0-264/78-04

! (Part 2.790(d) Information)

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U.S. NUCLEAR REGL"LATORY COSMISSIO:;

0FFICE OF INSPECTION A'O ENr0RCE:ENT

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Report ;;e. 50-261/76- .

- Docket Se. 50-26; License ';e. E-10E

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License (: Dow Chemical Company building 1603 Midland, Michigan 456'O Tacility Name: TRIGA Reactor, Building 1602 Inspection At: Reactor Site, Midland, Michigan Inspection Conducted: November 16 and 17, 1970

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Inspectors: 9. P. P&tterson l'-/ ' ~ ! ,

J..;f: ,[...t Approved By: A. Hind, Chief y / ~ [. Measurement and Controls Usaga of the 100 kilowatt TRIGA Mark I research reactor has been gyl'T), ' ' determined by thg. Reactor Supervisor from cu'rrent operating data to be an average of hours. equivalent full power per wee By 3' . -) , _

the licensee's method of, calculating burnup, this amounts tc 33 grams total uranium and_, , gram U-235 over a two year period. Up to the previo >s inspec tion of March,1976 no burnup had been reported by.the licensee. The licensee, as a result of that inspection, issued a revised Material Status Report for the period ending December 31,

. 197S, reporting 7 grams U and 6 grams U-235 for the first 8.5 years of the reactor's operatio . .

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The licensee reported, jgrams U and { grams U-235 on the NRC-742 ending March 31, 1978. For the most recent NRC-742 reporting period ending September 30, 1978, another 0.4 gram U and 0.3 gram U-235 was reported. At this rate ,jgrams total U would be accumulated in two years (4 reporting periods).

The inspector calculated burnup for both the two year period and the most recent six month period ending September 30, 197 His

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results were within 0.1 to 0.2 gram of the licensee's value Again, as in the previous inspection, it was pointed out to the licensee that the NRC-742 report should be kept in whole gram units. The burnup amounts could be kept "in-house" until 1.0 grar accrues and report it then, keeping smaller amounts off the report until they reach a whole number. The Laboratory Director stated that he would bring this to the attention of the Reactor Superviser when he returns to work f rom a current business tri g..g a y- - ,.. < ,- s .

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This research reactor operates only during normal work day shif ts and f or periods of . time less than one hou Its main use is f irradiating chemical samples for neutron activation analyses. A:.

.. sanples put in the reactor are representative of the licensee's

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chenical manufacturing and processing busines . Shipping and Receiving There have been no shipments or receipts during the inspectic-period. The recently issued safeguards procedures stipulate that tronsfer of SN:: shall require approval of the Radiation 5.fety Committee as well as the Reactor Superviso . Storage and Internal Control All fuel elements and the two fission counters are stored in the f

iLocations of the fuel elements are listec on metal tags hung on a large core diagram mounted on a status beard on one wall of the reactor room. There have been no transfers to different core locations since the previous inspection. When the annual inventory is taken, reactor procedures do require temporary transfer of two fuel elements to the storage rack until all the fuel elements have been verified by serial nucber. Then these two elements are returned to their original core position. These transfers and any checkouts of fuel are docurented in the Reactor Log Boo . Inventory

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This 100 KW TRIGA reactor has 91 positions in the core, only l which contain f uel element The remainder positions are for graphite elements, control rods, a transfer tube and one location, F-17, which contains the Am/Be neutron source. These TRIGA fuel elements are made up of 91% Zr, 1% H, and 8% U by weight, cladding being either aluminum or stainless stee The initial enrichment was 19.88% U-23 Since the fuel already had some exposure when the fuel was received f rom General Atomic in 1967, the current enric hment is slightly less than tha For inventory verification - reactor core positions out of were

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randomly selected by the inspector. Fuel elements from these positions were withdrawn and raised to near the top of the poo There under a spotlight, the fuel element was manuevered to enable the serial number to be read. All Merial numbers were compared with the location in the pool from a large status board mounted on the rear wall of the reactor room. All' fuel elements were

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properly identified by location and serial numbe Location of the two fission counters in the pool was also pointed out te the inspector. These locations were confirmed by entries in th(

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Reactor Log Look made for the annual fuel' checkout when

.- all fuel elements are raised from the core and identified bv th(

serial number. Documentation that annual physical inventories are being taken was confirmed by the inspector by audit of the reactor log book. Reactor log book No. 26 noted an inventory was taken o Tebruary 2, 1977. Reactor Log Book ::o. 2E also had entries e Februarv 13, 1978, that confirmed all 76 fuel elements were ver-fied by serial numbe The only other SNM at this facility consisted of encapsulated Pu-238 sources held. under License No. SNM-145 This license was recently renewed and has a present expiration date of January 31, -

1980. A total of 180 millicuries (mc.) were inventoried consisting of two 30 cc. sources and one item containing four separate, 30 r. sources mounted in one metal holding device. These four sources in one mounting were formerly.in a Texas Nuclear Corporation, custom made thickness gauge device. All these sources are assigned to responsible staff personnel as authorized and controlled by Radiation Safety Committe . Records and Reports The records review included the period from the previous inspection date, March 4, 1976 until the present inspectio In that time span there has been no. activity except for the inclusion of burnur data on two Material Status Reports (SRC-742). The revisien i to the NRC-742 form for the period ending December 31, 1975 requested

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during the previous inspection has.been made by the license This included an entry of' 'hrams U and kramsU-2'35forthecumulative burnup since the rea'etor became operational in July, 1967. Subsequent

.burnup data has been reported as described previously in Paragraph 3 of the report detail The Radiation Safety Officer has been signing the KRC-742 forms beginning with the March,1978 report. Formerly the Panager of

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Business and Government Statistics had been signing them as the authorized representativ c The inventory amounts reported on the NRC-742 form as of September 30, 1978, were verified by the inspector as being accurate. No transactions have occurred since that date to change these amount Exhibit A reflects the activity for License R-108 for the period of inspectio . .a 2

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There has been no change in the authorized lir.it of SNM of kg. r-235 f or License R-106 with the issuance of A.,endrent ':c . 3 to the facility license which extended the operating licenst te

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December 20, 395

The lic ensee's 'autherized lirit s and holdings as of March 5, Ic7'

by docket and 3fcense are as follows:

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Declet License Authorized Lirit Possescier 3':-'7E 5n-264 E-105 3.4 kg . r- 235

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70-1467 SSM-1451 270 cc. Pu-23E There was ne apparent loss or theft of SNM that requires reperting as required by 10 CFR Part 70.5 The Ifcensee's records system provide sufficient informatier te comply with the record requirements of 10 CFR Part 7 . Exit Interview The licensee's representatives were briefed on the areas inspected as described in the preceding paragraphs. They were informed that no itees of noncompliance were identified by the inspector as a result of this inspectio The safeguards procedures written as a result of the previous inspection were considered satisfactory for this research reactor authorized to possess less than one effective kilogra of SNM. The inspector recinded those present of the error in Saragraph o of the procedures which stated that any receipt or transfer out should be reported to the Region III of fice. This will be changed and NRC-741 transfer forms issued will be sent to the. Department of Energy at the address listed under 10 CFR Part 70.5 Other minor suggestions relating to the safeguards accountability procedures include adding the words " annual physical inventory" on the Approval Sheet for Special Experiments, a required written procedure needed to perform the annual checkout of the reactor fuel elements. Also, to Paragraph 7 of these safeguards procedures relating to report of a loss of any SN>', the 10 CFR 70 ref erence should be more specific as 10 CFR 70.5 This would make the-code reference more readily available for compliance if the occasion

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should arise. Again, the inspector emphasized the reporting of burnup on Line 73 of the Material Status Report should be in whole numbers rather than to 0.1 grar. as still being done by the licensee. Current instructions for completing the NRC-742 state that reporting shall be to the nearest grar (Ref. Pages 3 and 4 of

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blue-colored instruction booklet). The Health Physicist, actin:

in absence of the Radiation Safety Officer, has a copy of this instruction booklet. He was also inforced of reporting in whole grar

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units, although the Reactor _ supervisor supplies the data, to be use?

on the Material Status Repor ..

The laboratory Director indicated he vould notify the Eeacter Supervis::

of the suggested changes brought out at this exit interview. The Reactor Supervisor was not onsite durinF the inspection and therefere unavailabi Attachment:

Exhibit A

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DOW CHEMICAL CO.U AW - RIS-YFX N terial Balance Statement - Privately Owned Enriched Uranium

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Grats

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Enriched Uranium Number of Tuel Elements U U-235 Beginning Inventory 3/5/76 Receipts

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Totsl to Account For

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Shipments '

Depletion Ending Inventory Total Accounted for d

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s-n. 71 -?S L Copy _ 4 ef ( eeple:

P A age THIS DOCit'II:T Is ' - -* .

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Far t :t. 7i ? ( I 7 - I e r i 1.- Exhibit A

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