IR 05000264/1985002

Matl Control & Accountability Insp Rept 50-264/85-02 on 850603-04.No Noncompliance Noted.Major Areas Inspected: Possession & Use of SNM & Control & Accounting of Snm. Details Withheld (Ref 10CFR2.790)

ML20126C597
Person / Time
Site:	Dow Chemical Company
Issue date:	06/12/1985
From:	Belanger J, Creed J, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19344C024	List: IR 05000264/1985002 ML20126C583
References
50-264-85-02, 50-264-85-2, NUDOCS 8506140471
Download: ML20126C597 (4)

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U.S. NUCLEAR REGULATORY COMISSION

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REGION III

Report No. 50-264/85002 Docket No. 50-264 License No. R-108 Safeguards Group V Licensee: Dow Chemical Company Building 1803 Midland, MI 48640 Facility Name: Dow TRIGA Research Reactor Facility Inspection At: Dow TRIGA Research teactor Facility, Building 1602 Midland, MI Inspection Conducted: June 3-4, 1985 Date of Last Material Control and Accolnting Inspection: April 5 and 6, 1983 Type of Inspection: Unannounced Materirl Control and Accounting Inspection

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Inspectors: . l#Sl W Physical Security Inspector Date T. J. Madeda b &I#W t s'

Physical Security Inspector Date Approved By: . . ie 6(8 M l Safeguards Section Date Inspection Summary Inspection on June 3-4, 1985 (Report No. 50-264/85002(DR$$))

Areas Inspected: Special Nuclear Materials Control and Accountability Inspection including possession and use of SNM and control and accounting of SNN. The inspection involved ten inspector-hours onsite by two NRC inspectors and was begun during regular hours.

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Results: The licensee was found to be in compliance with NRC requirements in the areas examined during the inspection. The licensee's program for controlling and accounting of Special Nuclear Material was found to be adequat (Attachment - 10 CFR 2.790(d) INFORMATION)

ATTAttEiDIT CONTAINS 10 CFR 2.790(d) II;F0 f

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l REPORT DETAILS

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1. Key Persons Contacted In addition to the key members of the licensee's staff listed below, the inspectors interviewed other ifcensee employees and members of the MC&A organization. The asterisk (*) denotes those present at the Exit Meetin *D. Berry, Reactor Committee Chairman, Research Manager

• C. W. Kocher, Reactor Supervisor

• T. W. Parsons, Senior Industrial Hygienist G. Er.dahl, Radiation Safety Officer 2. Followup on Previous Inspection Findings (MC 92701, 92702, 92703)

There were no violations, unresolved or open items noted on the previous inspection. (Inspection Report 50-264/83001)

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3. Entrance and Exit Interviews (MC 30703): l At the beginning of the inspection, the most senior material control and accountability (MC&A) organization management representative available was informed of the functional areas to be examined and the purpose of l this visi No written material pertaining to the inspection was left with license The inspectors met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on June 4, 1985. A brief description of the scope of the inspection was provided. Listed below is a brief description of the subjects discussed and the expressed positions of licensee managemen Two recommendations to improve the licensee's MC&A program were discussed. The first recommendation by the inspectors concerned the updating of MC&A procedures to accurately reflect the actual MC&A program that is being implemented. The latter recommendation requested that licensee personnel responsible for filing 741's (Nuclear Material Transaction Reports) review updated instructions for NUREG/BR-006, Revision 2 (Instructions for Completing 741's) which became effective March 1, 198 The Ifeensee agreed to both of the recommendation No violations, deviations, unresolved or open items were identified during the Material Control and Accounting Inspection. Exhibit A, which is enclosed with the report reflects the enriched Uranium activity for the inspection perio ATTACHMENT CONTAIUS 10 CFR 2.790(d) INFO

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. . Clear Functional / Program Areas Inspected:

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Listed below are the areas which were examined by the inspectors within the scope of this inspectien in which no violations, deviations, unresolved or open items were identified. The areas were reviewed and evaluated as deemed necessary by the inspectors generally using the specified Section 02 " Inspection Requirements" of the applicable Office of Inspection and Enforcement, Inspection procedure. The inspectors also pursued matters deemed appropriate in addition to the listed " Inspection Requirements."

Our sampling reviews included interviews with cognizant individuals, observation of activities, testing of equipment and procedure implementation, and record reviews. The depth and scope of these activities were conducted and deemed appropriate and necessary for the Program Area and current operational status of the security syrte Number Functional / Program Area and Inspection Requirements Reviewed 85012 Material Control and Accounting - Reactors: (01) Possession and Use of SNM; (02) Control and Accounting of SN . Material Control and Accounting - Reactors (MC 85012): Two inspector recommendations were identified and presented to the licensee regarding updating procedural requirements of their MC&A progra Inspection review showed that Sections 8 and 9 of Part 3. of the Instruction Manual for the Dow TRIGA Research Reactor implied that uranium burnup adjustments shall not be made more frequently than once every two years on material status reports (742's) and that transfers or receipts shall be reported to NRC Region III. Inspection review showed that both of these requirements are outdated and require procedural updatin Inspection results showed that in actual practice the licensee is recording and filing burnup as required by the regulation (10 CFR 70.54) and that receipts or transfers would be sent to

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the appropriate office. Based on our findings the licensee has agreed to review the entire MC&A procedure and to update the two sections in question and update other sections that may need modification. The licensee stated the review ar.d update would be completed by December 1, 198 Review of 741's (Transfer Reports) showed that the licensee was not documenting this action code portion of 741's for onsite losse ^

l NUREG/BR-0006, Revision 2, at Section II.7 states that this action

! code block is used to identify this type of transaction event being i l reported on the 741. M is the letter designation to be used in l

' reporting a one party transaction such as burnup. Inspection l results showed that the licensee was not aware that the action code block was required to be filled out. This type of failure does not represent a violation since the actual burnup figures were properly ATTACHMENT CONTAIMS 10 CFq 2.790(d) INF0

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submitted-but was a failure to properly document the form from an administrative view point. Based on our findings the licensee has

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agreed that the personnel responsible for submitting 741's will review the reporting instructions in NUREG/8R-006 to assure that all future 741's are properly filled out.

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ATT/""' int C0tiTAlll5 10 Ln s.i.4d) INFO

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