IR 05000264/1990001

Insp Rept 50-264/90-01 on 900709-11.No Violations or Deviations Noted.Major Areas Inspected:Organization,Logs, Review & Audit Functions,Requalification Training, Procedures,Surveillance & Emergency Planning

ML20058N490
Person / Time
Site:	Dow Chemical Company
Issue date:	08/01/1990
From:	Dunlop A, Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058N487	List: IR 05000264/1990001 ML20058N484
References
50-264-90-01, 50-264-90-1, NUDOCS 9008140159
Download: ML20058N490 (9)

Text

-

,

.-.. ,  ;

9: 4 4 _

-

.

'

+ + 1 -*

U.S. NUCLEAR REGULATORY COMMISSION' 1

'

.

REGION III 't i

Report No. 50-264/90001(DRP)

Docket'No. 50-264- License.No..R-108? .

,i+

... ~ Licensee: Dow Chemical Company

+ ,

Facility Name: Dow TRIGA Research Reactor Facilit .

.

Inspection At': .Dow TRIGA Research Reactor Facility, Building 1602, i Midland, Michigan ,

<.

.

Inspection Conducted: ~ July 9-11,.1990: -

i

1. 7 du IM[

Inspector: ' A. Dunlop, J #- 1 v Date Approved By: . . .- ki e -f# ,

p actor P jects Section 3A . Date

,

{

ii Inspection Summary r Inspection on July 9-11, 1990-(Report No. 50-264/90001(DRP))

Areas Inspected: Routine, unannounced-inspection to. review actions on:  !

followup on previ.ous inspection items:(92701); organization, logs, and i records; review and' audit functions; requalification'traPing; procedures; surveillance; experiments; fuel handling activities; emergency: planning; . ,

radiation controls;.radwaste management (40750); and licensee event-reports '

~~

(92700). .

'

'Results: Of the 12: areas. inspected, no violations or deviations were .

identified. The licensee has a good overall program. Some of the commendable- l aspects include the requalification training program, the thoroughness of the  !

, ; Reactor Operations Committee, the special reviews performed by the Industrial .

Hygiene Department, and the eergency preparedness drills. and critique '

'-=

,;

!

>

~

n ,

.

' I 900814o159 900801 PDR '

O ADOCK 05000264 PDC d

j_ .  :

,

.

,

• ^ *

>

'

. ,

,

P ,

DETAILS

f persons: Contacted -

.

'

T -Dow Chemical Company-

• J. J. Havel,. Technical Manager Analytical Services and Chairperson-

.

'

.

. Reactor Operations Co.nmittee

• C, W. Kocher, Reactor Supervisor <

.

• L. Rigot, Assistant Reactor Supervisor . .

'

S. W. Maxey, Industrial Hygiene Department Health Physicist and Do a TRIGA Reactor Safety Officer

>

• T. J. Quinn, Senior Reactor Operator 1

• M. Buchman, Operator Trainee ,

a

• Denotes-those attending the exit meeting on July:11, 199 '

, General, '

This inspection, which began on July 9, 1990, was conducted to examine :

the research reactor program at Dow TRIGA Research Reactor. ;The facility i was toured: shortly-after arrival. The general housekeeping'of'the'

facility was goo I The reactor license was renewed on May 8,1989. In conjunction with the license renewal, the-Technical Specifications were updated to the -- J

- standard. format and the maximum. power level was increased from 100 kw-to '

300 kw. .The licensee has not opercted'above 100 kw limit at this time due to instrumentation-that would need to be recalibrated to the higher-power level. The licensee is in the process of acquiring'a new digital

. control console from General Atomics.to replace:the existing consol This console is designed for the 300 kw rating. The licensee-expects .

this to be accomplished later this yea ' The licensee operates the reactor daily. The reactorLis used primarily for neutron activations and some neutron-radiography. The inspector witnessed the performance of a daily checkout, a reactor startup, and a reactor shutdow No violations or deviations were identifie . Action on Previous Inspection Items (92'/01)

(Closed).Open Item (264/88001-01): No calibration information which relates to sensitivity to the vendor supplied radioactive source for the Continuous Air Monitor (CAM). The purpose of the CAM is to detect high radiation levels in the reactor room, most likely a fuel rod or samc le- "

failure. It is set to go off at three times the maximum background radiation level. It is not used to determine actual concentrations or u

, "

,

< v:

F ,

,.

. .*

P identifying the' radioactive material.' .If the alarm. sounds, an air sample is taken to determine this information. The licensee is in the process of- purchasing a calibrated source of Thallium-204, a pure beta emitter-that mimics the expected fission products. This will enable the licensee to determine the efficiency factor for the detector tube in the CA This. item is close No violations or deviations were identifie .' Organization, Logs, and Records (40750)

_

The facility organization was reviewed and verified to be consistent with the Technical Specifications and Safety Analysis Report (SAR). The- .

!

minimum staffing requirements were verified to be met.during reactor operation,'and fuel handling or tefueling operations, j The reactor logs and records were reviewed to verify that: Records'were available for. inspection, Required entries were mad Significant problems or incidents were documente ~

. The facility was being maintained properl The management organization for the reactor has not- changed since 'the -

last inspection. There are four licensed Senior Reactor Operators (SR0s) -:7 and two. individuals in training for operator. licenses, m la The licensee maintains a good log book of the. activities of the reacto Li A s eparate maintenance log is kept that identifies problems tor failures, j the corrective actions taken, the testing required to return the~ j equipment to service, and if the failure is reportable to-the NRC. The ;

updated Technical Specifications require the licensee to submit:an annua j report to the NRC within 90 days af ter the anniversary date of the 1 license. This will be the first annual report the' licensee has been 1 required to submit and will be reviewed during the next inspectio l No violations or deviations.were identifie ! ieviewsandAudits(40750)

'ie licensee's review and audit program records were examined by the inspector to verify that: Reviews of facility changes, operating and maintenance procedures, design changes, and unreviewed experiments were performed by the ,

Reactor Operations Committee (ROC) as required by Technical '

Specifications or SA i f 3

\

,

, ,

o y e -

,

t>

- ,

, 4

, <.

,

, .

~

,

,

b.- The Reactor Operations' Committee and/or subcommittee'were composed of qualified members and that quorum. requirements.and frequency. of

-

meetings had been met.-

q Required safety audits had been conducted in accordance.with Technical Specification requirements and that-identified problems were resolve The ROC met on a quarterly basis, Meetings are well: documented in the

. meeting minutes. . Items discussed by the ROC include review and approval ;

of procedures, fuel' movements, and new experiments; the acquisition-of- ;

the digital control console; inadvertent shutdowns; and reviewing NRC generic communications for applicability to the facility. .The updated .

Technical Specifications require an annual' audit of-reactor operations by- ,

the ROC. This audit has not been conducted at this time. Although a '

year has past since the. update, Technical Specifications allows up to :

15 months for the completion of annual items. This audit.will be *

reviewed during the next inspectio The Industrial Hygiene Department does conduct audits of the dose rate and contamination surveys performed by the operators. In addition, they have conducted two special reviews to determine radiation exposures 3 during. neutron . radiography operations and area monitoring for. radiation- y exposures in the reactor room. .The reports were'of good' quality and-

,

should be a useful ALARA tool to the operator .

'No violations or deviations were identifie . Requalification Training (40750)

'

The inspector reviewed' procedures, logs, and training records; and  ;

intervie'ed w personnel.to verify that the requalification training program 1 was being carried out in conformance with'.the facility.'s approved plan y and NRC regulations. Requalification exams were:successfully completed i by four SR0s in.1990, a}

'

V The licensee is on a 2 year requalification program. Training lectures -

are performed on a periodic basis. All operators participate-in the:

1ecture program. Training activities such as lectures,. quizzes, and comprehensive exams are well documented. There is no specific documentation to determine if each operator has met the requirements for

.the number of hours they operated the reactor or number of. reactivity .

manipulations. This information can, however, be obtained by ~ reviewing <

the operator logs. The licensee is sensitive to this. issue and ensures that all operators meet the requirements. This doer not appear to be a 3 concern to the inspector due to the frequent operations of the reacto ;

When the new digital control console is installed, this information will .;

automatically be entered and stored in the console's compute .

!

4

. .

, t

_

EE 1 h

,

[< 1

-

p . .

B .t

,

-

l

'No. violations or deviations'were~4dentifie .. Procedures (40750)

The inspector-reviewed the licensee's procedures to determine i procedures were issued.. reviewed, changed or updatea, and approved '

in accordance with Technical. Specifications-and'SAR requirement .

? This review also verified:

i That procedure content was adequate to safely operate, refuel, and maintain the facility, That responsibilities were clearly, define ,

. That required checklists and forms were use , i

~The inspector determined that the required procedures were available-to.the operators'and.the contents of selected procedures were found- a adequate. The licensee is in the process of updating their procedure Several procedures have recently been reviewed and approved by the RO The inspector reviewed several Activation Request Forms that list the .

purpose, elements involved, activation time, power level, expected curies being produced, and expected dose rates of samples after activations, No problems were note '

'

No violations or deviations were identifie . Surveillance (40750) ,

The inspector. reviewed procedures, surveillance-test schedules, and testL ,

records and discussed the surveillance ~and preventive maintenance program '

with responsible personnel to' verify: ,

, That procedures were available and adequate to. perform test !

< That tests were completed within the required time schedul ' Test records were available, lhe licensee has daily, monthly, semiannual, and annual checklists that schedule the required surveillances. Surveillances, in most ca'ses, are -;

performed more frequently than required by Technical Specification This frequency ensures the licensee meets the Technical Specification requirements and equipment is operating properly. When ao.ninistrative surveillance frequencies are missed, the ROC reviews the occurrence and

,

Justifies-the violatio <

No violations or deviations were identifie 't

!

t t'

' r --4

(

-

-

, .

>b g .

r 9.- Experiments (40750)

The inspector ~ verified by reviewing experiment records: and 6ther reactor

-

logs that:- t a., -Experiments were conducted 'using approved procedures and under ;

approved reactor condition ! New experiments or changes in experiments were properly reviewed and .

approve ' The experiments did not involve an unreviewed safety question,;i.'e.,

-

10 CFR 50.59e

, Experiments involving petential hazards or reactivity changes were > ,

identified in procedure '

' Reactivity limits were not or could not have been exceeded dur,ing an experimen "

The R9C approves all.nonroutine experiment Since the last inspection,;

two experiments were approved: ,

'+

, #87 Annual fuel inspection = and control rod inspection; .

1. 88 Approach-to criticality; inspection of control rodt; evaluation'of reactivity worth of fuel rod ;

'No violations or' deviations were identifie '

1 Fuel Handling'(40750)

The facility fuel handling program was reviewed by the inspector. The review included the verification of approved precedures for fuei handling

-

and their technical adequacy in the areas of radiation- protection, '

criticality safety, Technical Specification, and security plan requiremer,ts. The inspector determined by records review and discussions with personnel that fuel handling operations were carried out in

,

conformance to procedure Licensee-procedures require that the ROC approve all fuel movement The licensee moves fuel for inspections and approach to criticality expe*iments. With the increase in power-level, the licensee- plans to add several new-fuel elements to increase the reactivity of the cor No violations or deviations were identifie ;

.1

'

1 Emergency Planning (40750)

The inspector reviewed records and interviewed personnel to determine- I that the approved emergency plan was being carried out by verifying: 1 1 That procedures were in plice and required records were being kep I I

6 l-l w , -- .

-

r, ,

?

, * *

't .

I i 4s 1

,

Y cEn: ' ,;.

. That required drills were conducted and evaluate J:

'

j That required training had been conducted.-

The: licensee conducts- quarterly' building evacuat.ons and annual drills- to

'

'

'

,

evaluate personnel performance. Since.the last inspection, the licensee performed the following drills:

P December-12, 1988 - An activation sample detonating in the core damaging u fuel rod ctober 24, 1989 - Bomb threat Both drills adequately tested the personnel involved and were properly i

critiqued-to identify problems for resolution and' areas where performance could be improved. The requalification-program retrains the operators-in

,

the emergency plan and associated procedures. The' Industrial Hygiene Department retrains other personnel (security, medical) whotmay bo'

required to assist'the operators if an event occur No violations or deviations were identifie . Radiation Control (40750)

e The inspector reviewed the radiation protection activities since the last inspection. Records were reviewed, personnel were interviewed, and observations were made to verify that. radiation-controls were-being carried out in accordance with the license and NRC regulations.= The, ,

areas covered were: Posting and labeling of restricted- areas 'and radioactive materials,

' Control of irradiated samples, Calibration of radiation detection instrument ' Required periodic. dose. rate and co7tamination surveys,  ;

e, Exposure records of personnel, i Posted areas of facility, -

g, Personnel trainin ,

-The operators perform the routino radiologics1 controls for the reactor-and laboratory including required dose. rate and contamination survey ;

Industrial Hygiene Department conducts audits of these survey, calibrates radiation detection equipment, and maintains personnel exposure record According to personnel dosimetry reaorts, no person received a significant whole body dose from av y 198F through May 199 i L

i

f

-

.

y '

m c ,

, .

.

No' violations or. deviations were identifie : 1 Radwaste Managementi40750)

The facility has r.o gaseous effluent monitor because calculations demonstrated that 10 CFR 20 offsite limits would not be-exceeded even with continuous pneumatic sample operation. The air in the reactor roo is sampled continuously for particulate ' activity. Samples that do not decay promptly'and radioactive waste are transferred to the licensee's byproduct license for disposa No. violations or deviations were identifie H 1 License Event Reports (LERs) (92700)

Through direct observation, discussions with licensee personnel,.and  !

review of records, the following event reports were reviewed to determine- N that reportability requirements were fulfilled, immediate' corrective j action was accomplished, and corrective action to prevent recurrence had 7 been accomplished in accordance with Technical Specification j (Closed) LER 89-01 and LER 90-01r Failure of wide-range log channel. On - l

December ?O,1989, and January 16,.1990, the wide-range log channel failed while the reactor was being:taken to power (10 watts). In both--

j ;

cases -the reactor was manually scrammed and secured. Three similar j'

failures have occurred in the past; the most recent was in November 198 '

The'cause of the previous failures was determined to be a-poor connection ]

in. a rotary switch in the wide range log channel. As such. after the !

December failure ~, the switch was repaired in a similar fashion, tested,

-

l and the reactor returned to power. When the channel failed again in 1 January, the' licensed operator believed the cause'to be a poor contact '

in-the switch. Compressed air was used to clean the switch. -The channel '

was then tested and the reactor returned to power. The'~following day an l electronics technician investigating the problem, cleaned and examined .!

the switch revealing no signs of mechanical failur !

Subsequent conversations with the vendor (General Atomics) have- )

identified a' particular wafer in the calibration switch that is '

responsible for the failures. The wide-range log channel is a full range

.

channel that operates on pulse-counting circuitry at low power levels and }

on the ac component of the preamplifier signal at high power levels; the crossover is at approximately 12 watts. The failure indicates a loss of j

'the signal for high power level l-I The ROC has reviewed these events and has concluded that the reactor can be operated safely in its present condition. .The daily checkout of the-reactor would reveal if the switch had failed since the previous reactor operation. The licensee does not feel it is necesscry to replace the switch at this time since they will be replacing the entire control console later this yea i

,

__

. _ _ _ _

. - _ . _ . . _ . . _ .

• ,

. ....

.

-The 11censee's actionst in response to the-event'were proper in scramming the reactor and investigating-the cause of the failure prior to resuming reactor operations. The NRC was notified in a' timely manner and the licensee report' adequately described the event and'the actions taken.

.

The inspector does not have a concern with operating the reactor in--its

. present condition and with the . installation of the new digital control console,.this problem will be eliminate No violations or deviations were identified.-

15. Exit Interview (30703)

The inspector met with licensee and contractor representatives denoted in Paragraph I during and at the conclusion of the-inspection' on-July 11,.

1990. The inspector summarized the scope and results of the inspection-and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information. disclosed during the inspection could be considered proprietary in natur .

'

.