IR 05000264/1981002
| ML20040D043 | |
| Person / Time | |
|---|---|
| Site: | Dow Chemical Company, 07001487 |
| Issue date: | 01/11/1982 |
| From: | Boyd D, Ridgway K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20040D040 | List: |
| References | |
| 50-264-81-02, 50-264-81-2, 70-1487-81-01, 70-1487-81-1, IEC-81-02, IEC-81-2, NUDOCS 8201290525 | |
| Download: ML20040D043 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-264/81-02; 70-1487/81-01 Docket Nos. 50-264; 70-1487-License Nos. R-108; SNM-1451-Licensee: Dow Chemical, U.S.A.
1602 Building Midland, MI 48640 Facility Name: Dow TRIGA Reactor Inspection Conducted: December 7 - 10, 1981 ld./? $tbvost Inspector: K.R.hidgWay D
// f,/f2_
AWhy&
D. C. Boy, Chief
/ ~ M~- M Approved By:
Projects Section-1A Inspection Summary Inspection on December 7 - 10, 1981 (Report Nos. 50-264/81-02; 70-1487/81-01)
Areas Inspected: Routine, unannounced inspection of records, logs and organization; review and audit functions;-requalification training; pro-cedures; surveillance and maintenance; experiments; radiation protection program; radwaste management program; security program and implementation; material control and accountability; emergency plan; and followup relative to IE Circulars, Licensee Event Reports and Open Inspection-Items. This inspection involved a total of 45 inspector-hours (32 onsite) by one NRC inspector including 0 inspector-hours onsite during offshifts.
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Results: No items of noncompliance were identified in the areas inspected.
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8201290525 820113 DR ADOCK 05000264 PDR
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DETAILS 1.
Persons Contacted
- L. Rampy, Chairman, Radiation Safety Committee
- 0. Anders, Reactor Supervisor
- J.
Maki, Building Supervisor
- K. Kelly, Assistant Reactor Supervisor
- C. Kocher, Assistant Reactor Supervisor
- T. Quinn, Senior Reactor Operator
- T.
Parsons, Radiation Safety Officer R. Kolesar, Director, Medical Department D. Ducommon, M.
D., Medical Deparument M. Graham, Director of Nursing, Medical Department W. Heitzig, Manager, Security L. McJames, Supervisor, Emergency Services R. Olson, Industrial Hygienist
- G.
Dixon, Industrial Hygienist C. Vaughn, Industrial Hygienist
- Indicates those present at the exit interview.
2.
General The inspection, which began at 8:30 a.m. on December 7, 1981, with a walk through at the facility to observe existing conditions was conducted to examine the overall safety and security program. No problems were noted.
The Dow TRIGA Reactor is a part of the Analytical Laboratory and is used almost exclusively as a neutron source for activation analysis.
It is used almost every day and in most cases, several times per day.
The total operating time per week is about 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and on the average about 300 irradiations are made each month.
3.
Organization, Logs and Records The facility organization was reviewed and verified to be consistent with the Technical Specifications and/or Hazards Summary Report. The minimum staffing requirements were verified to be present during reactor operation, and fuel handling or refueling operations.
The reactor logs and records were reviewed to verify that:
a.
Required entries were made.
b.
Significant problems or incidents were documented.
c.
The facility was being maintained properly.
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d.
Records were available for inspection.
The following organizational changes had been made during 1981.
e.
Dr. L. Rampy was elected Chairman of the Radiation Safety j
Committee on August 25, 1980,~ replacing Dr. R. Langner.
f.
Dr. C. Kocher replaced Dr. O. Anders as Reactor Supervisor.
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C. Kocher, T. Hiller, and D. Krueger received NRC Senior Operator
Licenses on April 14, 1981.
h.
T. Parsons replaced E. Bickel as Radiation Safety Officer.
No items of noncompliance or deviations were identified.
4.
Reviews and Audits
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The licensee's review and audit program records were examined-by the
inspector'to verify that:
a.
Reviews of facility changes, operating and maintenance procedures,
design changes, and unreviewed experiments had been conducted by
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a safety review committee as required by Technical Specifications or Hazards Summary Report.
b.
That the review committee and/or subcommittees were composed of qualified members and that quorum requirements and frequency of meetings had been met, c.
Required safety audits had been conducted in accordance with r
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Technical Specification requ'vements and that any identified
. problems were resolved.
j The license and technical specifications do not require any internal audits, however, the Industrial N;3 ene' Laboratory reviews radiation i
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safety practices annually at the Reactor Facility.
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No items of noncompliance were identified.
5.
Requalification Training l
The inspector reviewed procedures, logs and training records; and j
interviewed personnel to verify that the requalification training program was being carried out in conformance with the facility's l
approved plan and NRC regulations. Five requalification examina-
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tions had been conducted in January 1981.
No items of noncompliance were identified.
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6.
Procedures The inspector reviewed the licensee's procedures to determine if procedures were issued, reviewed, changed or updated, and approved in accordance with Technical Specifications and HSR requirements.
This review also verified:
a.
That procedure content was adequate to safely operate, refuel and maintain the facility.
b.
That responsibilities were clearly defined.
c.
That required checklists and forms were used.
The inspector determined that the required procedures were available and the contents of the procedures were adequate.
The licensee had several ginor changes to the Operating Procedure Manual in early 1981 and had started an overall revision on the manual. The inspector suggested several additions and changes that would better define control of procedures, dates of revisions or ROC approvals, who could make various kinds of changes and better documentation that all changes and other pertinent information had been reviewed by all concerned persons.
No items of noncompliance were identified.
7.
Surveillance The inspector reviewed procedures, surveillance test schedules and test records and discussed the surveillance program with responsible personnel to verify:
That when necessary, procedures were available and adequate to a.
perform the tests.
b.
That tests were completed within the required time schedule.
c.
Test records were available.
The inspector noted that in some cases where maintenance work had been carried out on safety instrumentation, there was incomplete documentation of what, if any, checks or calibrations were required before restarting the reactor. The licensee indicated a check sheet to document the evaluation and work would be developed.
No items of noncompliance were identified.
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8.
Experiments The inspector verified by reviewing experiment records and other reactor logs that:
a.
Experiments were conducted using approved procedures and under approved reactor conditions.
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b.
New experiments or changes in experiments were properly reviewed and approved.
c.
The experiments did not involve an unreviewed safety question, i.e., 10 CFR 50.59.
d.
Experiments involving potential hazards or reactivity change were identified in procedures, e.
Reactivity limits were not or could not have been exceeded during the experiment.
No items of noncompliance were identified.
9.
Radiation Control The inspector reviewed records, interviewed personnel, and made observations and independent surveys to verify that radiation con-trols were being carried out in accordance with the license and NRC regulations. The areas covered were:
a.
Posting and labeling of restricted areas and radioactive materials.
b.
Control of irradiated samples.
c.
Calibration of radiation detection instruments.
d.
Required periodic dose and contamination surveys.
e.
Exposure records of personnel.
f.
Personnel training.
The inspector noted that two doserate meters assigned to the Reactor Laboratory had not been calibrated since July 1981. The Dow Radiation Protection Manual states " ionization chamber instruments are calibrated quarterly". A licensee representative stated that he assumed quarterly to mean calendar quarterly and that the instruments were to be calibrated before the end of the fourth quarter 1981. The licensee agreed to change the quarterly frequency definition in the manual to agree with the standard quarterly definition of 92 days plus 24 days.
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A The licensee makes monthly contamination wipe tests and radiation dose rate surveys in several laboratory rooms in the 1602 Building including the reactor room and laboratory rooms surrounding it.
The dose rate-surveys for September and October 1981 had been overlooked.
The survey for November showed no change from the last survey in August 1981.
The license and technical specifications do not require radiation control procedures and the frequency of the above surveys is not specified in the Radiation Protection Manual. The licensee stated that the surveys would be conducted monthly in the future.
No items of noncompliance were identified.
11.
Radioactive Effluents The licensee had not released any liquid radioactive wastes since the last radwaste inspection in September 1980.
The facility has no gaseous effluent monitor since calculations in the Safety Analysis Report determined that 10 CFR 20 offsite limits would not be exceeded with continuous pneumatic sample operation.
The pneumatic sampler is used only a few hours per week. The air in the
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reactor room is continuously sampled for particulate activity with
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local alarm and remote alarm in the Security Dispatcher's Control Station.
No items of iloncompliance were identifiedF ~---
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12.
Security Program _
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On October 20, 1978, the licensee applied for and NRR: approved License lI Amendment No. 4, dated June 28, 1979. The amendment concerned minor changes to the Physical Security Plan. The inspector reviewed the approved plan and determined that the requirements of the plan were being carried out in the areas of:
Physical Protection Security Organization and Training Access Control Alarms Systems Keys, Locks, and liardware Communications Surveillance Security Procedures Security Program Review Protection Against Sabotage
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The licensee had recently conducted a key inventory with laboratory personnel assigned to operations who had access to laboratory rooms connected with the reactor room.
No items of noncompliance were identified.
13.
Material Control and Accounting The inspector determined that the licensee has not received or shipped any fuel or SNM since the last material control inspection in NovemLer 1978. All fuel is being used on a current basis and excess reactivity is determined daily when the reactor is in use. The inspector reviewed these records and visually counted the fuel. Records of the last annual fuel inventory completed in December 1980, documented in the Reactor Log Book, and the required NRC-42 submittals were reviewed.
The plutonium-238 sources carried under License SNM-1451 were inventoried and records of the semi-annual leak test were reviewed.
No items of noncompliance were identified.
14.
Emergency Plan The inspector reviewed the TRIGA Reactor Emergency Plan which had been updated and approved by the RSC on August 28, 1980.
Changes to the plan were only to meet formal recommendations in Regulatory Guide 2.6, dated January 1979.
The inspector reviewed records and interviewed personnel from the-Analytical Laboratory, Industrial Hygiene Laboratory, Medical Department and Plant Security to determine that commitments made in the plan were being met; that emergency systems and equipment such as alarms, radia-tion detection equipment, respiratory protection devices and other supplies were available; and that the required tests and drills had been conducted.
No items of noncompliance were identified.
15.
Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of. records, the following event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifi-cations.
On March 24, 1981, the licensee notified Region III that their Constant Air Monitor (CAM) was found to be leaking air around an
"0" ring seal'
which allowed part of the sampled air to bypass the filter thus de-grading the sensitivity of the monitor. To correct the problem a new
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"0" ring was installed, the vacuum relief valve was relocated to permit checking the
"0" ring seal, the filter locking device adjusted, and procedures developed to check the seal daily during the reactor startup check.
16.
IE Circular Followup For the IE Circular listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed, and that if -the circular was applicable to the facility, appropriate corrective actions were taken or were scheduled to be taken.
IEC 81-02 - Performance of NRC-Licenced Individuals While on Duty.
17.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on December 10, 1981, and summarized the scope and findings of the inspection.
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