IR 05000264/1986001

Insp Rept 50-264/86-01 on 861118-21.No Violations or Deviations Noted.Major Areas Inspected:Records,Logs & Organization,Review & Audit Functions,Requalification Training,Procedures,Surveillance Activities & LERs

ML20214V148
Person / Time
Site:	Dow Chemical Company
Issue date:	12/04/1986
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214V127	List: IR 05000264/1986001 ML20214V124
References
50-264-86-01, 50-264-86-1, NUDOCS 8612090545
Download: ML20214V148 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-264/86001(DRP)-

Docket No. 50-264 License No. R-108 Licensee: Dow Chemical U. Building Midland, MI 48640

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Facility Name: Dow TRIGA Reactor Inspection At: Dow Chemical, Midland, MI

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Inspection Conducted: November 18-21, 1986

! Inspector: C. H. Brown

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Approved By:

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ney, b e

. / % v//6 Reactor Projects Section Date i Inspection Summary

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Inspection on November 18-21, 1986 (Report No. 50-264/8600l(DRP))

Areas Inspected: Routine, unannounced inspection of records, logs, and i

organization; review and audit functions; requalification training;

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procedures; surveillance activities; experiments; fuel handling activities; radiation control practices; radwaste management program; followup of i . licensee event reports; and followup of inspector identified items including

a violation.

Results

No violations or deviations were identified.

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DETAILS Persons Contacted

• J. M. Macki, Research Manager, Inorganic Analysis, and Chairman, 1 Reactor 0perations Committee-

• C. W. Kocher, Reactor Supervisor

• L. Rigot, Assistant Reactor Supervisor'-

T. J. Quinn, Senior Reactor Operator

'* Denotes those present at the exit intervie . General This inspection was conducted to examine the overall program at the Dow TRIGA Reactor, with the exception of security and materia accountability and control activities and covers the period October 26, 1984 thru November 21, 1986. The facility was toured and the conditions were found to be acceptable. A startup and operations of the reactor were observed. The removal'of samples from the reactor, the preparation,.

and then placing the samples in the counter was observe

The Dow TRIGA Reactor is part of-the Analytical Laboratory and most of the operating time'is used for neutron activation of samples for.

I analysis. The reactor is generally started up several times each day.

2 The Analytical Laboratory's new building is being built adjacent to the

,' present building. There are no plans to move the reactor to the new facilities.

1 Organization, Logs, and Records (40750)

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The facility organization was reviewed and verified to be consistent

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with the Technical Specifications and the Safety Analysis Report (1966).

The minimum staffing requirements were verified to be present during reactor. operation and fuel handling operation The reactor. logs and records were reviewed to verify the following:

Required entries were made Il

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Significant problems or incidents were documented

The facility was being maintained properly

Records were available for inspectio Dr. J. A. Macki is presently the Research Manager of Inorganic Analysis

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and Chairman of the Reactor Operations Committee (ROC). The licensee has applied for a new license for the facility. The Safety Analysis Report (SAR) has been updated and the Technical Specifications have been i

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rewritten in the generic format. The licensee is requesting the maximum authorized reactor power level be increased to 300 kilowatts, basically to allow activation of samples to be performed in less tim No violations or deviations were identifie . Reviews and Audits (40750)

The licensee's review and audit program records were examined.by the inspector to verify the following:

Reviews of facility changes, operating and maintenance procedures, design changes, and unreviewed experiments had been conducted by a safety review ccmmittee as required by Technical Specification *

The review committee and/or subcommittees were composed of qualified members, and quorum and frequency of meeting requirements had been me Required safety audits had been conducted in accordance with Technical Specifications requirements, and any identified problems were resolve The license and Technical Specifications do not require internal audits; however, the Industrial Hygiene Services Department reviews radiation safety practices at the Reactor Laborator No violations or deviations were identifie . Requalification Training (40750)

The inspector reviewed procedures, logs, and training records and interviewed personnel to verify that the requalification training program was being carried out in conformance with the facility's approved plan and NRC regulations. Requalification examinations.were conducted during January of 1985 and 198 No violations or deviations were identifie . Procedures (40750)

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 SAR requirement This review also verified the following:

Procedure content was adequate to safely operate and maintain the facility Responsibilities were clearly defined

Required checkli:t: and forms were used.

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The inspector determined that the required procedures were available and that the contents of the procedures were adequate. Minor revisions have been made in several procedures and checklists. These changes had been reviewed and approved by RO No violations or deviations were identifie . Surveillance Activities (40750)

The inspector reviewed procedures, surveillance test schedules, test records, and discussed the surveillance program with responsible personnel to verify the following:

When necessary, procedures were available and adequate to perform the test *

Tests were completed within the required time schedul *

Test records were availabl The licensee has developed a more informative maintenance log that includes the surveillances required to return the system to operable statu No violations or deviations were identifie . Experiments (40750)

The inspector verified the following by reviewing experiment records and other reactor logs:

Experiments were conducted using approved procedures and under approved reactor condition *

New experiments or changes in experiments were properly reviewed and approve *

Experiments did not involve an unreviewed safety questio Experiments involving potential hazards or reactivity changes were identified in the procedures.

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Reactivity limits were not or could not have been exceeded during the experimen In discussions with the licensee and review of the records it was determined that gem stones were not being irradiated nor was there any plans to do s No violations or deviations were identifie . - . - -

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- . Fuel Handling Activities (40750)

The facility fuel handling program was reviewed by the inspecto The review included verifying approved procedures for fuel handling, and .their technical adequacy in the areas of radiation protection, criticality safety, Technical Specifications,.and ' security plan requirements. The inspector determined, by records review and discussions with personnel, that. fuel handling operations, and startup tests were carried out in conformance with the licensee's procedure During early January of each year, as part of the requalification training program, all licensee operators participate in the inspection of each fuel element and each control element. Nothing unexpected was noted during the inspection of the fuel elements or the control element No violations or deviations were identifie . Radiation Control (40750)

The inspector reviewed records, interviewed personnel,'and made observations and independent surveys to verify that radiation controls were being carried out in accordance with the license and NRC

- regulations. The areas covered were as follows:

Posting and labeling of restricted areas and radioactive materials, a Control of irradiated sample Calibration of radiation-detection instrument *

Required periodic dose and contamination surveys.

Exposure records of personne . Posted areas of the facilit The Ra source was verified (found to be 9.12 mg vs. 9.2 mg) and used j to calibrate the fixed position area radiation monitor over the reactor.

, No violations or deviations were identified, i'

11. Radwaste Management (40750)

! The facility has no gaseous effluent monitor because calculations in the

- Safety Analysis Report demonstrated that 10 CFR 20 offsite limits would not be exceeded with continuous pneumatic sample operation. The

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pneumatic sampler is used only a few hours per week. The air in the

!. reactor room is sampled continuously for particulate activity. Solid waste is held for decay and monitored before removal from the facility.

j Samples that do not decty promptly (still radioactive, after about a

! year) are transferred to NRC By-Product Material License No. 12-00265-06.

i This material then is packaged and shipped to a licensed disposal site i.

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in accordance with applicable regulations. No solid waste had been transferred to the By-Product Material License during the inspection period. No liquid waste had been released during the inspection perio No violations or deviations were identifie . Followup on Previous Inspection Findings (92701 & 92702)

(Closed) Open Item 50-264/81002-01: During inspection 81002, the inspector noted that the maintenance log sheets should state what is required for the return of equipment to an operable status. The licensee has developed a maintenance sheet that includes:

System Symptoms Immediate action taken to bring the reactor to a safe condition

Reportability of the event to the NRC Diagnosis Action taken to repair Testing required to prove operability Signature and date for; approval to restart, returned to service by, and reactor supervisor A list of systems has been developed that requires a maintenance sheet be initiated before work on the system is performed. The response was considered to have met all the inspector's concerns in this area and the item is considered close (Closed) Open Item 50-264/84001-01: During inspection 84001, review of Reactor Operations Committee (ROC) minutes, the inspector noted changes and modifications had been reviewed by the committee but approval of these items was not clear. The ROC minutes now clearly state the approval of the committee. This item is considered close (Closed) Open Item 50-264/84001-03: During inspection 84001, the strength of a calibration source could not be determined. The strength of the source was verified and shown to contain 9.18 mg Ra compared to the reported 9.2 mg Ra. The item is considered close (Closed) Violation 50-264/84001-02: A notice of violation was issued to the licensee for failure to report a log channel failure during reactor operations. The licensee has developed a list of areas which require NRC reporting, and maintenance sheets include reportability of the event to the NRC. The cause of the failure to report appears to have been eliminated and the item is considered close '

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13. Followup on Licensee Event Reports (92700)

(Closed) 264/84001-LL, 264/85001-LL, and 264/85002-LL (Malfunction of

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the Wide-Range Log Channel During Operation of the Dow TRIGA Research Reactor): During startup the instrumentation did not respond properly during the three events. The connections and contacts of equipment and instruments of the wide-range log channel were inspected and cleaned and repaired as necessary. Circuit problems were considered to be the cause of the first two events and the " calibrate" switch caused the thir These LERs are considered close (Closed) 264/86001-LL (Source Interlock Failed to Prevent Control Rod Movement): During the pre-startup checkout, the source interlock operated, but did not prevent control rod motion. After the investigation, which included checking the function of the interlock, it was concluded that temporary loss of an electrical contact in the logic circuits was the most likely cause. This item is considered close . Exit Interview (30703)

The inspector met with licensee representatives (denoted in Paragraph 1.)

at the conclusion of the inspection and summarized the scope and findings of the inspectio .- --

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