IR 05000264/1980002

IE Insp Rept 50-264/80-02 on 800910-12.No Noncompliance Noted.Major Areas Inspected:Qualifications,Audits,Training, Radiation Protection Procedures,Instruments & Equipment Exposure Control

ML19338G472
Person / Time
Site:	Dow Chemical Company
Issue date:	09/22/1980
From:	Fisher W, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19338G465	List: IR 05000264/1980002 ML19338G464
References
50-264-80-02, 50-264-80-2, NUDOCS 8010290403
Download: ML19338G472 (6)

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O U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

RFGION III Report No. 50-264/80-02 Docket No. 50-264 License No.-R-108 Licensee: Dow Chemical U.S.A.

1803 Building Midland, MI 48640 Facility Name: TRIGA Reactor Inspection At: TRIGA Reactor Site, Midland, MI Inspection Conducted: September 10-12, 1980 Inspector:

P. C. Lgve., dale 9/24/80 4/ ' A Approved By:

W. L. Fis er, Chief 7 28

Fuel Facility Projects and Radiation Support Section Inspection Summary Ir ection on September 10-12, 1980 (Report No. 50-264/80-02)

Areas Inspected: Routine, unannounced inspection of radiation protection and radwaste management program. including:

qualifications; audits; training; radiation protection proceduus, instruments and equipment; exposure control; posting, labeling, and control; surveys; notifications and reports; records

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of effluents; radioactive waste; IE Bulletin No. 79-19; IE Circular No. 80-14; a previous item of noncompliance; and transportation activities. The inspec-tion involved 13 inspector-hours onsite by one NRC inspector.

Results: No items of noncompliance or deviations were identified.

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DETAILS

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1.

Persons Contacted

• Dr. 0. U. Anders, Reactor Supervisor

• Mr. K. J. Kelly, Assistant Reactor Supervisor

• Mr. J. M. Macki, Senior Research Manager

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• Mr. E. E. Bickel, Health Physicist

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• Dr. C. W. Kocher, Radiochemist Mr. T. W. Parsons, Health Physicist

• Denotes those present at the exit interview.

2.

General This inspection, which began with visual observation of facilities and equipment, posting, labeling, and access controls at 10:30 a.m. on September 10, 1980, was conducted to examine the routine operational radiation protection and radwaste mansgement program. During this and subsequent tours, the inspector used a licensee survey instrument to monitor the reactor area. The highest radiation level, about 7 mR/hr, was found at waist level above the reactor pool. No proU ams were noted.

3.

Previous Item of Noncompliance (Closed) Noncompliance (50-264/79-02): Failure of the Reactor Operations Committee to meet during second quarter of 1979.

A " reminder board" is now in use to prevent recurrence (Paragraph 5).

4.

Organization The following changes in the reactor staff have been made since the last radiation protection inspection (October 1979):

Mr. K. J. Kelly has been appointed Assistant Reactor Supervisor; Mr. J. M. Macki has replaced Mr. H. Gill as Research Manager in building 1602; Mrc E. E. Bickel has replaced Mr. T. W. Parsons as Reactor Health Physicist. No problems were identified.

5.

Licensee Audits Minutes of the Reactor Operations Committee (ROC) and Radiation Safety Committee (RSC) meetings held since October 1979 were reviewed. Member-ship and meeting frequencies for both committees were as required in Technical Specifications I.2 and I.S.

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As a result of a previous inspection,1/ the licensee instituted a e

" reminder board," which lists required due dates for ROC and RSC meet-ings so that they will not be missed.

No items of noncompliance were identified.

6.

Training Except for the reactor staff, no other individuals frequent the reactor area. The reactor staff receives raaiation protection training during annual requalification, which meets the requirements of 10 CFR 19.12.

Also, female employees receive additional training as outlined in Regulatory Guide 8.13.

No items of noncompliance were identified.

7.

Radiation Protection Procedures The inspector reviewed the procedures contained in the "TRIGA Operations Manual," including calibration procedures for the area radiation monitor, continuous air monitor, and water radiation monitor.

No items of noncompliance were identified.

8.

Instruments and Equipment a.

Portable Survey Instruments Operable and calibrated instruments capable of detecting beta, gamma, and neutron radiations are available at the reactor.

Additiopal instruments are available from the Industrial Hygiene Office as needed. Records indicated that instruments are calibrated either quarterly (ionization type and neutron meters) or annually (Geiger-Mueller type meters). No problems were noted.

b.

Area Radiation Monitors Records reviewed indicate that the monitor was calibrated in March and August 1980.

(Technical Specification G.3 requires an annual frequency.) The inspector observed a calibration check of this instrument and verified that the monitor's audible alarm was func-tional and that the alarm setpoint was correct. No problems were noted.

c.

Continuous Air Monitor (CAM)

The inspector reviewed records of calibration and alarm setpoint checks performed since October 1979 and noted that the frequency 1/ IE Inspection Report No. 50-264/79-02.

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was as required by Technical Specification G.3.

The inspector

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observed a calibration check of this instrument and verified that the monitor's audible alarm and visual alarms were functional and that the alarm setpoint was correct. No problems were noted.

No items of noncompliance were identified.

9.

Exposure Control a.

External Exposure The vendor's film badge reports were reviewed for the period October 1979 to date. The greatest whole body and extremity doses received

in CY1979 were 210 mrems and 180 mrems, respectively. No measurable whole body dose ~has been received in CY1980 to date; the highest extremity dose was 40 mrems. 'No problems were noted.

b.

Internal Exposure The licensee has no routine bioassay program for the reactor staff and relies on the CAM, contamination surveys, and pool etivity measurements to define any problem areas. The inspector reviewed recordsofpheseindicators;noproblemswerenoted. A previous

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inspection 2 noted that pool water was last analyzed for tritium in 1971. The licensee has recently analyzed the pool wateg for tritium and found it to be less than approximately 1 x 10 pCi/ml, their lower detection limit. No problems were noted.

The inspector reviewed action taken by the licensee relating to IE Circular No. 80-14 " Radioactive Contamination of Plant Deminer-alized Water System and Resultant Internal Contamination of Personnel." The only possible means of contaminating the deminer-alized water storage tank is through a hose used to add makeup water to the reactor pool. The hose is short enough so that it can not be physically submersed into the pool.

It is unlikely that contamination of the demineralized water tank could occur

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via this route. No problems were noted.

No items of noncompliance were identified.

10.

Posting.and Labeling The licensee's compliance with posting and labeling requirements specified in 10 CFR 19.11 and 10 CFR 20.203 were reviewed.

'T No items of noncompliance were identified.

2/ IE Inspection Report No. 50-264/79-02.

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11.

Transportation Activities

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The licensee stated that no radioactive material has been received under the TRIGA license since the last radiation protection inspection

'(October 1979). The inspector reviewed records of radioactive ship-ments made since October 1979. No problems were noted.

The licensee has not submitted a quality assurance program satisfying the requirements of 10 CFR 71, Appendix E and has no plans to do so.

No shipments of greater than Type A quantities have been made.

The inspector reviewed the licensee's response to IE Bulletin No. 79-19.

No problems were noted.

No items of noncompliance were identified.

12.

Surveys The reactor staff performs contamination and radiation surveys monthly.

The Industrial Hygiene Office performs quarterly contamination surveys of the facility. Results of these surveys were reviewed. Only occa-sional low-level contamination is found in known contamination areas.

No items of noncompliance were identified.

13.

Notifications and Reports A review of records and discussions with licensee representatives indicated compliance with 10 CFR 19 and 10 CFR 20 requirements.

No items of noncompliance were identified.

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14.

Radioactive Waste a.

Liquid Radioactive Waste The licensee stated that they do not release liquid radioactive waste from the facility. Any liquids requiring disposal are solidified and shipped to a licensed burial site.

b.

The facility has no gaseous effluent monitor, since calculations in the SAR determined that 10 CFR 20 limits will not be exceeded with continuous r > bit operation. The rabbit system is used only a few hours per week.

Particulate effluents would be detected by the CAM. No significant particulate activity has been noted.

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c.

Solid Radwaste Solid radioactive waste generated at the reactor facility is collected by the Industrial Hygiene Office and transferred (under

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NRC Byproduct License No. 21-00265-06) to a licensed disposal vendor. About one 55-gallon drum of waste is generated annua'lly.

The. inspector noted that the licensee has been incinerating by-product material (approximately 11 millicuries of carbon-14 and l

hydrogen-3 in CY 1979). The licensee stated that this practice has been conducted under Byproduct License No. 21-00265-06 for

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approximately seven years. The licensee further stated that the license did not specifically allow them to incinerate byproduct material, but that they had interpreted the regulations to_mean that they could incinerate as long as the limits of 10 CFR 20-

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Appendix "B" Table II were not exceeded. This matter will be reviewed during a future inspection of Byproduct License No. 21-00265-06.

No items of noncompliance were identified.

15.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on September 12, 1980. The inspector summarized the scope and findings of the inspection.

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