IR 05000264/1983001

Sanitized Version of Matl Control & Accounting Insp Rept 50-264/83-01 on 830405-06.No Noncompliance Noted.Major Areas Inspected:Facility Organization & Operation,Measurement & Statistical Control & Storage & Internal Controls

ML20137D418
Person / Time
Site:	Dow Chemical Company
Issue date:	04/29/1983
From:	Creed J, Kniceley J, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137D185	List: IR 05000264/1976001 IR 05000264/1976002 IR 05000264/1983001 ML20137D178 ML20137D255
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 50-264-83-01-01, 50-264-83-1-1, NUDOCS 8508220477
Download: ML20137D418 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Fcport No. 50-264/83-01(DRMS)

Docket No. 50-264

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License No. R-108 Licensee:

Dow Chemical Company Building 1803 Midland, MI 48640 Facility Name:

TRIGA Reactor Inspection At: Dow Chemical, Building 1602, Midland, MI Inspection Conducted:

April 5 - 6, 1983 Date of Last Material Control and Accounting Inspection: November 16 and 17, 1978 Type.of Inspection: Unannounced, Material Control and Accountability s & [r

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A v b y-Inspector:

T. J. Madeda

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Physical Protection Specialist h.0 Y..oas 4lC'1 fi3

.).R.Kniceleyh (Date)

Physical Protection Specialist

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Approved By: Q L-

1. $ M Y/J9[M J. R. Creed, Chief (Date)

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Safeguards Section Inspection Summary Inspection on April 5 - 6, 1983 (Report No. 50-264/83-01(DRMS))

l Areas Inspected: Material control and accountability including facility

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organization and operation, measurement and statistical control, storage l

and internal controls, shipping and receiving, records and reports, inventory

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and inventory verification.

The inspection involved 18 inspector-hours on-site by two.NRC inspectors and was begun during the regular hours.

Results: The licensee was found to be in compliance with NRC requirements in the six areas examined during the inspection.

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DETAILS 1.

Persons Contacted

• F. Knoll, Reactor Committee Chairman, Research Manager

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Kocher, Reactor Supervisor

• K. Kelly, Assistant Reactor S_upervisor R. Olson, Radiation Safety Officer T. Farsons, Industrial Hygiene Laboratory

• Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings There were no items of noncompliance noted on the previous inspection (50-264/78-04).

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3.

Exit Interview The licensee representatives, denoted in Section 1 vere briefed on the scope and findings of the inspection. The licensee was informed that no ite=s of noncompliance were identified during the inspection. The inspector identified one section (Chapter 3, 3.4.3(9)) of the SNM pro-cedures that should be reviewed (refer to Section 4).

1he licensee agreed to revise that section of the procedure.

Facility Organization and Operation No itets of noncompliance were identified.

The DOW TRIGA Research Reactor is a 100 KW Reactor and is located in the analytical laboratory, 1602 Building.

It's purpose is to provide a source of neutron and ga==a radiation for research and development.

The Radiation Safety Committee of the DOW Chemical Company holds the NRC Operating License for the reactor facility and is responsible for the operation of the facility. The Radiation Safety Committee is comprised of five individuals who are supported by a seven person Reactor Opera-tions Committee. There is one Reactor Supervisor and two Assistant Reactor Supervisors who report to the Reactor Operations Committee.

The safeguardi.7g and maintenance of all SNM is the responsibility of the Reactor Supsrvisor. Additionally, semiannual Material Status Reports and Nuclear Material Transaction Reports are issued by the Radiation Safety Com=ittee staff.

The operating License (R-108) was renewed on November 21, 1977, and expires as December 20, 1986.

The Ifeensee's authorized limits and holdings as of April 6, 1983 by docket and license are as follows:

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Docket License Autherfred limit Possession 4/6/83 i

50-264 R-108 3.4 Kg. U-235 70-1487 SNM-1451 270 me Pu-238 During a review of the Instruction Manual for the Dow TRIGA Research Reactor the inspectors discoverd an error in Chapter 3, Section 3.4.3 Subsection 9. which stated that any receipts or transfers out should be reported to the Region III office. The inspectors requerted that all

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transfer docueentation be sent to the Department of Energy, P.O. Box E, Oak Ridge, Tennessee 37830 and not to the Region III office.

The li-censee agreed to make this change.

5.

Measurerent and Statistical Controls No items of noncompliance were identified.

Use of the research reactor hasbeendeterminedbytheReactorSupervisortobeanaverageof; equivalent full power par week. The reactor operates only during

, normal Work day shif ts and fo-periods of less than one hour.

The Reactor Supervisor is responsible for computation of uranium deple-tien. His results are reported on NRC-742 forms in whole gram units.

The burnup amounts are kept "in-house" until whole gram units accrue and then reported.

The inspectors reviewed the NRC-742 forms issued by the licensee since the last inspection. The forms were properly completed and issued in the proper time frame. The licensee's calculations appeared adequate.

By letter dated February 28, 1983, the licensee was advised by Material Transfer SG Licensing Branch of the NRC that they are required to com-plete and submit DOE /NRC Form 742 C as well as DOE /NRC Forn 742 for all licensed special nuclear material and source material in their posses-sion, regardless of ownership. The licensee was unaware of the addi-tional requirement until they received the February 28, 1983 letter and will now comply with the requirement.

6.

Shipping and Receiving

No items of noncompliance were identiffed. There were no shipments or receipts since the last inspection. Section 3.4.3 of the administrative

and safeguards proceduress address the Safeguards for Special Nuclear l

Material and any receipt, transfer, or loss of SNM requires specific action and approval by the Radiation Safety Com=ittee as well as the Reactor Supervisor.

7.

Storage and Internal Control No items of noncompliance were identified.

All fuel elements are stored in the'

or adjacent to the core in M

Atthetimeoftheinspectioj,allfuelelementswere

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l in-the Locations of the, were shown using metal tags which hang on a status board or, one wall of the reactor room.

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The inspectors verified, by interview, observation and records review,

that the storage and internal control procedures as described in Chapters 3 and 4 of the Instruction Manual for the D0k' TRIGA Research Reactor vere being followed and appeared to be adequate.

8.

Inventorv No itees of noncoepliance were identified.

The licensee has all of which are kept in the The inspec ors concucte( a complete piece count of the fuel elecents, comparing the location of each elecen_t as listed on the status board against the Reactor Log Book.

All fuel elements, vere accounted for. Addition-ally, the inspectors randomly selected, teactor core positions to verify by serial nucher.

Fuel ele =ents for these positions were withdrawn and raised,to near the top of the pool where the serial number could be read and coepared with the location on the status board.

All, fuel elements vere properly identified by location and serial number. These entries were confirmed by entries in the Reactor Log Book made during the annual fuel inventory.

The inspectors reviewed Chapter 4 Section 4.3.3.5 (Guideline for Annual TRIGA Fuel Inventory check) and determined that the procedure is being followed and is adequate.

The only other SNM at this facility consisted of encapsulated Pu-238 sources held under License No. SNM-1451. The inspector inventoried two 30 me sources and one 120 cc source (containing four 30 me soures mounted in one metal holding device).

All these sources are assigned to respons-ible staff personnel as authorized and controlled by the Radiation Safety Committee.

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The inspector verified the presence of these sources by using a Victoreen Model 470 A " Panoramic" survey meter which is used for quantitative measurement of beta and gamma radiation. All sources permitted under Licences No. SNM-1451 were accounted for.

The inspectors also reviewed licensee records of physical inventories.

These inventories are conducted on an annual basis (serial number / location)

for fuel element and semiannually for other SNM. No discrepancies were noted in these inventories except for Form 742C which is a requirement the licensee was not aware of.

(Refer to Section 5 for further details.)

9.

Records and Reports No ite=s of noncompliance were identified. The inspectors reviewed records from the previous inspection dated November.1978 until the present inspection.

The licensee's records system provide sufficient information to co= ply with the record requirements of 10 CFR Part 71.

The following records were reviewed.

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Records Dates Reviewed Nuclear Material Status October 1978-March 1983 Reports (NRC-742's)

Inventory / Reactor Loss March 1979-December 1982 (5 inventories were reviewed)

Approval Sheets for Special

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November 1978-March 1983 Experirents (19 sheets were reviewed)

Forms NRC-742 vere prepared and distributed as required by 10 CFR 70.54 and 10 CFR 70.53 and related instructions, except as noted in Section 5.

Possession and use of SNM was confined to locations and purposes auther-ized by license.

The ifcensee's nuclear procedures and records syste provide sufficient information to co= ply with the requirements of 10 CFR Part 70 for nuclear power reactors.

Exhibit A which is enclosed with this report, reflects the enriched uranium activity for this inspection period.

Atttachment:

Exhibit A -

Paterial Balance State - Enriched Uranium

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Part 2.790(d) Ir.fer atics

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nea 2 9 1983 Docket No. 50-264

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Dow Checical U.S.A.

ATTN:

Dr. L. W. Raepy, Chaircan Radiation Safety Coe=ittee 1803 Building Midland, MI 48640 Gentlecen:

This refers to the routine safeguards inspection conducted by Messrs.

T. J. Madeda and J. R. Kniceley of this office on April 5 and 6, 1983, of activities at the Dow TRIGA Reactor Facility authorized by NRC License No.

R-108 and to the discussion of our findings with Mr. f. Knoll and other members of the reactor staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

Ne itecs of noncompliance with NRC requirements were identified during the enurse of this inspection.

Areas examined during this inspection concern a subject matter which is

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exempt from disclosure according to Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Consequently, the enclosure of this letter and our report of this inspection will not be placed in the Public Document Room.

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We vill gladly discuss any questions you have concerning this inspection.

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Sincerely, 0:;ght! Si;nc3 by 1it. Ellec J. R. Miller, Chief Materials and Safeguards Branch Enclesure:

Inspection Report

No. 50-264/83-Ol(DRMS)

(Part 2.790(d)-Information)

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cc w/ enc 1:

Dr. C. W. Kocher, Reactor

Supervisor

T. J. Knoll, Research Manager

and Chairman, Reactor Operations

Committee

cc w/ enc 1, v/o Part 2.790(d)

Information:

DMB/ Document Control Desk (RIDS)

George W. Bruchmann, Michigan

Department of Public Health

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