IR 05000264/1979003

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Forwards Insp Rept 50-264/79-03 on 791022-24 & Notice of Violation
ML20137G406
Person / Time
Site: Dow Chemical Company, 05000000
Issue date: 12/05/1979
From: Heishman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Langner R
DOW CHEMICAL CO.
Shared Package
ML20136D183 List: ... further results
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 NUDOCS 8508270291
Download: ML20137G406 (2)
v • d • e


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Docket No. 50-264 N-O b Dow Chemical U. ATTN: Dr. R. R. Langner Radiation Safety Committee 1603 Building Midland, MI 48640 Gentlemen: This refers to the inspection conducted by C. H. Brown of this office on October 22-24, 1979, of activities at Dow TRIGA Reactor authorized by NRC Operating License No. R-108 and to the discussion of our findings with H. H. Gill, Research Manager, Analyic Laboratory and O. U. Anders-Reactor Supervisor at the conclusion of the inspectio The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of precedures and representative records, observa-tions, and interviews with personne During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulation Section 2.201 requires you to submit to this office within twenty days of your receipt of this notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieve In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room, except as follows. If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this lettet, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the 8500270291 850712 PDR FOIA J KOHN85-256 PDR *

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Dow Chemical U. C'JO 51979 information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application, We will gladly discuss any questions you have concerning this inspectio

Sincerely, R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch

Enclosures:

1. Appendix A, Notice of Violation IE Inspection Report No. 50-264/79-03

REGION III== Report No. 50-264/79-03 Docket No. 50-264 License No. R-108 Licensee: Dow Chemical 1803 Building Midland, MI 48640 Facility Name: Dow (TRIGA) Inspection At: Dow (TRIGA) Reactor Facility Inspection Conducted: October 22-24, 1979 Inspector: C. H. Brown M /2 - 3 "N . Approved By: D hief Reactor Projects /2- 3'W Section 3 Inspection Summary Inspection on October 22-24, 1979 (Report No. 50-264 79-03) Areas Inspected: A routine, unannounced inspection of logs and records, review and audit, requalification training, procedures, surveillance, and experiments. The inspection involved 16 inspector hours onsite by one NRC inspecto Results: Of the six areas inspected, one item of noncompliance (deficiency-failure to perform monthly check list in June) was found in one area, no items of noncompliance were found in the other five areas.

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DETAILS Persons Contacted T. Quinn, Reactor Operator 

*0. Anders, Reactor Supervisor
*H. Gill, Research Manager, Analytic Laboratory K. Kelly, Reactor Operator
* Denotes licensee personnel attending management intervie . Organization The facility organization was found to be as delineated in the Technical Specifications. A review of the facility staffing records indicates that, during periods of reactor operations, two operations personnel are assigned to operate the reacto . Logs and Records The required logs and records were reviewed. These were found to be available and logical. The maintenance log contained all items re-quired. The entries appeared to provide sufficient information and proper guidanc No items of noncompliance or deviations were identified in this are . Review and Audit The Reactor Operation Committee meeting minutes were reviewed for the period included in the inspection. The minutes indicated that the meeting requirements had been satisfie The replacement of a safety channel with a Keithley Picoammeter was reviewed by the Committee and found to be acceptable. The activation of 1.5g of natural U 038 in the " Lazy Susanna" was reviewed and approved (Experiment 61). ThE audits are performed initially by personnel associated with the reactor with a backup review by a qualified person not directly responsible for the reactor operations. The audits appear to provide sufficient contro No items of noncompliance or deviations were identified in this are . Requalification Training The facility requalification training records were found to be up-to-date and all required documentation was available. All the recent changes to the facility and procedure changes and additions were included in the training progra c
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No items of noncompliance or deviations were identified in this are . Procedures The administrative and startup procedures were reviewed. The startup of the reactor was observed and the startup procedure was followe The startup procedure appeared satisfactory. The administrative pro-cedures were reviewed with no commen No items of noncompliance or deviations were identified in this are . Surveillance The facility surveillance program was reviewed. The performance of procedures for the various surveillances and checklists appeared satisfactory. The surveillances had been completed and documented with the exception of the monthly checklist which was not completed for the month of June 1979. This is considered an item of noncomplianc Section I.7 of the Technical Specifications require " Approved written procedures shall be in effect for all operations involving the reactor, including a. checkout, calibration and determination of operability . . . 

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Contrary to this the procedural monthly checklist was not performed 

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for the month of June, 197 . Experiments The experimental records were reviewed and the irradiation of small samples remain the major of the experiments. The fuel removal and inspection was performed under experimental procedure as befor (The fuel removal and inspection is written-up and approved each time it is performed).

No items of noncompliance or deviations were identified in this are . Management Interview A management interview was held on October 24, 1979 at the conclusion of the inspection with personnel as denoted in Paragraph 1. The scope and findings of the inspection was discussed with the licensee. They were informed of the nonperformance of a monthly checklist that is considered to be an item of noncomplianc r e fi - 

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MAY 111977 

   ,x-Docket No. 50-264 '

Dow Chemical U. ATTN Dr. Ralph Langner Chairman, Radiation Safety Conalittee 1803 Building Midland, MI 48640 Gentlemen: This refers to the inspection conducted by Mr. J. A. Finn of this office on April 25 and 26, 1977, of activities at Midlan Michigan, authorised by License No. R-108 and to the discussion 

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of our findings with Drs. Kochanny and Anders of your staff at the conclusion of the inspectio The enclosed copy of our inspection report identifies areas arm =ined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne No items of noncompliance with NRC requirements were identified during the course of this inspectio In accordance with Section 2.790 of the NRC's " Rules of , Practice," Part 2, Title 10, Code of Federal Regulations, a l ' copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follow If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to 

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withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the applicatio , M5 

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now Chemie.1 v. MAY 111977 We will gladly discuss any questions you have concerning this 

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Sincerely, ! i i i James M. Allan, Chief 

  ,    Fuel Facility and Materials Safety Branch Enclosure IE Inspection Rpt No. 50-264/77-01 cc w/ encl:

Central Files Reproduction Unit NRC 20b PDR NSIC TIC Ronald Callen, Michigan Public Service Commission 

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ,

REGION III

. Report No. 50-264/77-01
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Docket No. 50-264 License No. R-108 Licensee: Dow Chemical U. Building Midland, MI 48640 Facility Name: TRIGA Reactor Inspection at: Midland, MI Inspection Conducted: April 25 and 26, 1977 Inspector: J. A. Finn P 5-////7 7 

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y % Approved by: W.L.FishNr,aChief $~[///77 Fuel Facility Projects and (Date) Radiation Support Section Inspection Summary: Inspection on April 25 and 26, 1977 (Report No. 50-264/77-01) Areas Inspected: Facilities and equipment; organization; training; radiation protection procedures; health physics instrumentation; exposure control; posting, labeling, and control; materials records; surveys; notifications and reports; radioactive effluent releases; and liquid and solid waste. The inspection involved seven inspector-hours onsite by one NRC inspecto Results: No items of noncompliance or deviations were identified in the twelve areas inspected.

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DETAILS 1. Persons Contacted 

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,G. L. Kochanny, Jr., Manager, 1602 Building O. V. Anders, Reactor Supervisor R. A. Olson, Health Physicist
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Denotes those present at the exit intervie . Facilities and Equipment The inspector toured the facility to observe hcusekeeping, equipment, storage, and postin . Radiation Protection Staffing R. A. Olson continued as Reactor Health Physicis Additional health physics coverage is available from the licensee's Industrial Hygiene staf . Licensee Audits Industrial Hygiene (Health Physics) perforns audits and surveys quarterly. The inspector reviewed audit records for the period April 1976 to April 197 . Training Reactor operators undergo annual requalification training and testin This program includes lectures on radiation protection, radwaste, license requirements, and NRC requirements. This train-ing reets the requirements of 10 CFR 19.1 . Radiation Protection Procedures Radiation protection and radwaste procedures are available and appear to be adequat . Health Physics Instrumentation Portable Survey Instruments The licensee has on hand survey instruments capable of measuring beta, gamma, and neutrons. These are calibrated semiannuall r-- 

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. . Area Radiation Monitor (Technical Specifications G.1 and G.2)

The area radiation monitor consists of a Geiger tube mounted on the reactor room wall about 13 feet from the reactor, and a meter readout and alarm at the operating panel. The area radiation monitor is calibrated semiannually with a 10 milli-gram radium source. The alarm is set daily at 0.6 milli-roentgens per hour as part of the Daily Startup Checklis Water Monitor Pool water is filtered and portions are demineralize Before filtering, the water passes through a water monitor vessel containing a Geiger tube. The signal is fed to a readout and alarm located at the operation consol The water monitor is calibrated semiannually. The alarm is set daily at 80 counts per second as part of the Daily Startup Checklis Continuous Air Monitor (Technical Specifications G.2 and G.3) The continuous air monitor (particulate) is located in the reactor room with readout (chart) and alarm on the monitor itsel The monitor is operated in the fixed air sample mod Each day as part of the Daily Startup Checklist the chart ,. reading is recorded, the filter is moved, and the alarm points I are set. Thelowalarmissggat1,000countsperminute l 

 (equivalent to about 2 x 10 microcuries per milliliter on
an eight-hour sample). The high alarm is set at 5,000 counts per minut The monitor is calibrated weekly with a beta source.

, 8. Exposure Control External Exposure i l Assigned personnel use beta-gamma-fast neutron film badges ! provided monthly by R. S. Landauer. Visitors are also pro-vided badges. The badge supplier's report is the equivalent of Form NRC- Self-reading dosimeters are used as deemed appropriat Ranges , available include 0 to 200 milliroentgens and 0 to 1 roentge I l 

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A review of film badge reports for CY1976 and CY1977 through January 14, 1977, showed the maximum annual whole body ex-posure was 470 millirem Internal Exposure Particulate air activity is measured by a continuous air monitor located in the reactor room. The readout chart is checked daily when the sample filter is changed. Charts are maintained on file. In the 12-month period from April 1976 to April 1977, no particulate activity was detecte Argon-41 concentration calculations in the SAR, assuming continuous generation of argon in the rabbit system, are below Part 20 limits. The rabbit system is used less than five percent of the tim Film badge data indicate no overexposures to argon-4 . Posting, Labeling, and Control During a tour of the facility, the inspector observed that posting and labeling were in accordance with 10 CFR 20.203 requirement The licensee's response to IE Circular No. 76-03 was reviewe At the time of the inspection no high radiation areas existe Radiation areas that exist temporarily following removal of activated samples are surveyed and controlled administrativel Notices required by 10 CFR 19.11 were posted at the entrance to the buildin . Materials Records of receipt, transfer, and disposal of licensable material were reviewed. No problems were identifie . Surveys The reactor room sample storage area is surveyed daily. Surveys are also made during removal of samples from the lazy susan or from the rabbit syste During a tour of the facility the inspector made surveys of the reactor room, the storage areas, and the water treatment syste No unusual radiation levels were observe _ 

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_ 12. Notifications and Reports Reports are made as required. Individuals are notified if any radiation exposure is incurre . Radioactive Effluent Releases No radioactive liquids are released from the reacto Liquids are transferred to the licensee's byproduct material license for solidificatio Particulate gaseous effluents are measured by the continuous air monitor located in the reactor roo (See paragraph 8.b) No particulate activity has been detected in the latest 12-month perio Argon-41 concentration calculations in the SAR, assuming continuous generation of argon in the rabbit system, are below Part 20 limit The rabbit system is used less than five percent of the tim . Solid Waste Solid radwaste is transferred to the company byproduct material license for shipment to a licensed waste disposal agency. Liquid wastes are also transferred for solidification before shipment offsite. There have been no shipments of reactor waste in the latest 12-month perio . Records and Documents Reviewed Daily Startup Checklist Weekly Instrumentation Checklist Monthly Checklist Semiannual Checklist Radiation Monitoring Instruments Calibration Book Film Badge Reports, CY1976 and CY1977 Reactor Operations Committee Meeting Minutes Reactor Operators Requalification File and Tests Reactor Activation Request Forms-5- 

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o REGION til 799 nooSEVELT nO AD f {- p 8 GLEN ELLYN, ILLINOl5 60137 5 

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N Dow Chemical Company .. h ATTN: Dr. R$1ph Langner g;jj Chairman, Radiation p' Safety Committee Building 1803 ', ?( is Midland, MI 48640

Gentlemen: o , . :w 3 This will confirm the telephone conversation of February 2, 1978, 

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1' c between Mr. J. Donahue of my staff and Mr. G. Kochanny of your staff, l - ' that a meeting will be held between the NRC (Region III) and Dow Chemical 

,  Company representatives at the Dow Research Reactor Facility (Building 1602) on Tuesday, February 7, 1978 at 2:00 This meeting, requested

by Region III, is to discuss the results of the physical security inspection conducted at the Dow Research Reactor Facility on January 10-12, 197 i

Sincerely, !

t J. A. Hind, Chief Safeguardo Branch 

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Dunleavy Donahue Hind Fiorelli Keppler 

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OFFICE OF INSPECTION AND ENFORCMENT NOTICE OF SIGNIFICANT LICENSEE MEETING Name of Licensee: Dow Chemical Company 7 Name of Facility: Dow Research Reactor Facility

0 Docket No: 50-264 o ... Date of Meeting: February 7, 1978 at 2:00 Location of Meeting: Dow Research Reactor Facility 

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Building 1602 Midland, Michigan 

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Purpose of Meeting: To discuss results of physical security inspection conducted on January 10-12, 197 IE Attendees: 

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C. Norelius, Assistant to the Director, RIII 

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J. Donahue, Chief, Security and Investigation Section, Safeguards Branch, RIII J. Dunleavy, Physical Security Inspector, RIII e w ' 

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Licensee Attendees: _ 

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G. Kochanny, Jr., Research Manager, Analytical Laboratories W. Lee, Manager, Health and Safety L. Nute, Legal Representative, Michigan Division y Note: Attendance by NRC personnel at this IE/ licensee meeting should be made known by 5:00 p.m. February 6, 1978, via telephone to R. G. McCormick, 492-8080 

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Distribution: e Haller, Director Division of Safeguards Inspection, IE McCormick, Acting Assistant Director, Division of Safeguards Inspection, IE Jordan, Executive Officer for Operations Support, IE Miller, Assistant Director for Reactor Safeguards, NRR R. Clark, Chief, Reactor Safeguards Licensing Branch, NRR i 

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 {     The Dow Omatiesi Company      Decket No. 50-264 ,
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ATTN: Mr. D. D. haf f ra . p, 2 ) 

 ,      Qiairman, Radiation Safety Coomdtten

. Building 47 ' 

 ,     Midland, Michigan 48640

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This refers to the inspection oeuducted by !Y. J. A. Fina of this office on April 7,1976, of activities at Midland Eichigan authorised by Liaanse No.1-108 and to the discussion of our findings with Dr. Andere of your statf at tha conclusion of ' the inspection.

! , The esalesed copy of ser inspection report identif tsa areas emanined durisas the inspection. Within these areas. the inspection aemoisted of a solactive ===mination of procedures and representative records, ekservations, and interviews with personne No itema of noncompliance with NRC requirements were ides-tified within the scope of this inspection.

< In accordance with Seatloc 2.790 of the NRC's " Rules of Practice, Part 2. Title 10. Code of Federal Regulations, a

sopy of this letter and the enclosed inspection report vill be placed in the NRC's Public Desument Beam, except as follows, i If this report contains informaties that you or your contractors -

believe to be proprietary, you must apply la writing to this office, within twenty days of your receipt of this letter, to

withhold such information from public disslosure. The j sppliestion must include a full statement of the reasons for which the information is semaidared proprietary, and steeld be prepared so that proprietary information identified in the
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application is contained in an enclosure te the applicatio { 

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Sincerely yours, 

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James H. Allan, Chief Fuel Facility and Haterials Safety Branch Enclosurca 

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No. 050 264/76-03 bec w/ enc 1: PDR NSIC TIC Ronald Callen, Michigan Public Service Commission EQ Emproductien l l l i 

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.- U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

IE Inspection Report No. 050-264/76-03 Licensee: The Dow Chemical Company 1701 Building Midland, Michigan 48640 TRIGA Reactor License No. R-108 Midland, Michigan Category: F Type of Licensee Research Reactor Type of Inspection: Routine, Unannounced Date of Inspection: April 7, 1976 Principal Inspector: J. A. Finn b v I /76 (bate) Accompanying Inspectors: None Other Accompanying Personnel: None 

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e 1 Reviewed By: W. L. Fisher, Ch ef' * YhC/76 Fuel Facility Prcjects and ' (Dat'e) Radiation Support Section 

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a SUMMARY OF FINDINGS Inspection Summary Inspection on April 7, 1976, (76-03): Review of radiation protection and radwaste programs, including records, procedures, equipment inventory, and interviews with facility personne Enforcement Items Non Licensee Action on Previously Identified Enforcement Items Non Other Significant Items Systems and Components Non Facility Items (Plans and Procedures) Non Managerial Items Non Noncompliance Identified and Corrected by Licensee Non Deviations None.

{ Status of Previously Reported Unresolved Items ' F.

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l Management Interview l A management . interview was conducted with Dr. Anders, Reactor Supervisor.

l The inspector described the scope of the inspection and stated that no items of noncompliance had been identified, i -2- 

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REPORT DETAILS 1. Persons Contacted O. Anders, Reactor Supervisor T. Quinn, Reactor Operator G. Engdahl, Health Physicist R. Olson, Health Physicist 2. Personal Monitoring Film badges are obtained monthly from a commercial supplie The badges monitor beta, gamms, and fast neutrons. Visitors are provided badges. Forms NRC-4 are not completed for reactor personnel. The badge suppliers' report is the equivalent of Form NRC- Self-reading dosimeters are used as deemed appropriate. Ranges avail-able include O to 200 milliroentgens and 0 to I roentgen. Results are recorded in the experimental logboo A review of film badge reports for CY1974 and CY1975 showed the maxinum annual whole body exposure was 50 millirems. Skin exposures have been minimal. Exposures for CY1976 were " minimal" for the period ending February 14, 197 . Surveys and Survey Instruments The licensee has on hand survey instruments capable of measuring beta, gamma, and neutrons. These are calibrated semiannuall The reactor room sample storage area is surveyed daily. Surveys made during removal of experiments from the lazy susan or from the rabbit system are recorded in the expcrimental logbook In addition, Industrial Hygiene (Health Physics) performs audit surveys quarterl . Radioactive Waste No radioactive liquid effluents are released from the reactor. Liquids are collected in plastic containers, which are packaged in 55-gallon drums for shipment to a licensed waste disposal agency. The inner containers are surrounded by enough absorbent material to absorb any leakagi Solid waste is transferred to a licensed waste disposal agenc rx 

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Particulate gaseous effluents are measured by a continuous air monitor located in the reactor room. The readout chart is i checked daily when the sample filter is changed. Charts are maintained on file. No particulate activity has been detected j above backgroun I Argon-41 concentration calculations in the SAR, assuming continuous generation of argon in the rabbit system, are below Part 20 limit j However, the rabbit system is used less than five percent of the i tim l 

~ 5. Area Radiation Monitor (Technical Specifications G.1 and G.2)

The area radiation monitor consists of a Geiger tube mounted on the reactor room wall about 13 feet from the reactor, and a meter readout and alarm at the operating panel. The area radiation monitor is calibrated semiannually with a 10 milligram radium source. The 1 

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alarm is set daily at 0.6 milliroentgens per hour as part of the Daily Startup Checklis . a W'ter Monitor Pool water is filtered and portions are domineralized. Before filtering, the water passes through a water monitor vessel con-taining a Geiger tube. The signal is fed to a readout and alarm located at the operation console. The water monitor is calibrated semiannually. The alarm is set daily at 80 counts per second as part of the Daily Startup Checklis , Continuous Air Monitor (Technical Specifications G.2 and G.3) The continuous air monitor (particulate) is located in the reactor room with readout (chart) and alarm on the monitor itself. The monitor is operated in the fixed air sample mode. Each day as part of the Daily Startup Checklist the chart reading is recorded, the filter is moved and the alarm points are set. The low alarm is set at 1,000 counts per minute (equivalant to about 2 x 10-11 micror" ries per milliliter on an eight-hour sample). The high alarm is set at 5,000 counts per minute. The monitor is calibrated weekly with a beta sourc . Postina l The inspector observed that posting meets the requirements of i 10 CFR 20.203 and 10 CFR 19.11 Sample Handlina The licensee described and demonstrated insertion and removal of samples from the lazy susan. A Juno survey meter is positioned to monitor samples as they are removed. Tongs are used to remove samples from capsules. De-encapsulation is done in a radiochemical hoo . . 

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10. Records The following records were reviewed for items concerned with radiation protection and radwaste: Daily Startup Check List - 7/30/75 to 4/5/7 Weekly Instrumentation Checklist - 7/30/75 to 4/5/7 Monthly Checklist - 7/30/75 to 4/5/7 Semiannual Checklist - spot checke Reactor Operating Log - spot checke Radiation Monitoring Instruments Calibration Boo Film Badge Reports - CY1974, CY1975, CY1976.

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