ML19210E572

IE Insp Rept 50-264/79-02 on 791002-03.Noncompliance Noted: Failure of Reactor Operations Committee to Meet Quarterly

ML19210E572
Person / Time
Site:	Dow Chemical Company
Issue date:	10/22/1979
From:	Fisher W, Hiatt J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19210E462	List: ML19210E461 ML19210E572
References
50-264-79-02, 50-264-79-2, NUDOCS 7912050315
Download: ML19210E572 (6)

See also: IR 05000264/1979002

Text

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-264/79-02

Docket No. 50-264

License No. R-108

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hicensee: Dow Chemical U.S.A.

1803 Building

Midland, MI 48640

Facility Name: TRIGA Reactor

Inspection At: TRIGA Reactor Site, Midland, MI

Inspection Cond eted: October 2-3, 1979

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Inspector

. W. Hiatt

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Approved By: W

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Fuel Facility Projects and

Radiation Support Section

Inspection Summarv

Inspection on October 2-3, 1979 (Report No. 50-264/79-02)

Areas Inspected: Routine, unannounced inspection of radiation protection

and radwaste management program, including: qualifications; audits;

training; procedures; instruments and equipment; exposure control; posting,

labeling, and centrol; surveys; notifications and reports; records of

effluents; effluent control instruments; solid radwaste; and previous

commitments. The inspection involved 11 inspector-hours on site by one

hTC inspector.

Results: Of the thirteen areas inspected, no items of noncottpliance or

deviations were found in twelve areas; one apparent item of noncompliance

was found in one area (infraction - failure of Reactor Operations

Committee to meet quarterly - Paragraph 5).

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DETAILS

1.

Persons Contacted

• 0.

Anders, Reactor Supervisor

• H. Gill, Research Manager, 1602 Building

• T.

Parsons, 3ealth Physicist

T. Quinn, Reactor Operator

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• Denotes those present at exit interview.

2.

General

This inspection, which began with visual observation of facilities

and equipment, posting, labeling, and access controls at 8:15 a.m.

on October 2,1979, was conducted to examine the routine operational

radiation protection and radwaste management program.

During this

and subsequent tours, the inspector used a licensee survey meter to

survey the reactor area. The highest radiation level, about 5

mR/hr, was found near a source storage area. At full power (100

kW) the radiation level at waist level above the reactor pool was

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about 4 mR/hr. The inspector also observed sample loading, irradia-

tion, and removal from the reactor; no problems were noted.

3.

Previous Inspection Findings

The following commitment listed in IE Report No. 50-264/78-02 was

reviewed:

(Closed) Formalizing wrltten procedures for the calibration of the

continuous air monitor and the water radiation monitor. The licensee

had formalized the above procedures (Paragraph 7).

4.

Organization

There were no changes in the reactor staff since the last radiation

protection inspection (May 1978) .

The staff consists of the reactor

supervisor, three full ti=e operators, and evo qualified " backup"

operators.

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The reactor health physicist is a member of the Industrial Hygiene

Office. In September 1979 the Reaccor Cperations Committee confirmed

the appointment of Mr. T. Parsons as the reactor health physicist.

Mr. Parsons, who has an M. S. degree in Health Physics, replaces

Mr. D. Barsten, who left in September 1978.

In the interim (between

September 1978 and Septe=ber 1979) the reactor health physics

position was rotated between other health phy=; cists in the Industrial

Hygiene Office.

No problems were noted.

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5.

Licensee Audits

Minutes of Reactor Operations Committee (ROC) and Radiation Safety

Committee (RSC) meetings held since May 1978 were reviewed. Membership

requirements for both _ammittees and meeting frequencies for the

RSC were as required in technical specifications I.2 and I.S.

However, the inspector noted that the ROC failed to meet in the

second quarter of 1979. This is an item of noncoopliance.

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6.

Training

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Outside of the reactor staff, no other individuals frequent the

The reactor staff receives radiation protection

reactor area.

training during annual requalification. Training required by 10 CFR 19.12 was also received.

No items of noncompliance were identified.

7.

Radiation Protection Procedures

As 'a result of a previous inspection,1/ the licensee formalized

procedures for calibrating the area radiation monitor (required by

T.S. I.7.a) and the water radiation monitor.

These procedures and

the continuous air monitor calibration procedure (required by T.S.

I. 7.a) are contained in th2 "' RIGA Operations Manual." The inspector

reviewsd the procedures; no problems were found.

No items of noncompliance were identified.

8.

Instruments and Equipment

a.

Portable Survev Instruments

Operable and calibrated instruments capable of detecting beta

and gamma radiation and neutrons were available at the reactor.

Additional instrumentation is available from the Industrial

Hygiene Office if needed. Records reviewed showed that the

instruments are calibrated either quarterly (ionization type

and neutron meters) or annually (Geiger-Mueller type meters).

b.

Area Radiation Monitors

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In May 1978 use of a new area radiation monitgy (ARM) was

approved by the Reactor Operations Cenmittee.--

Records

reviewed indicate that the monitor was calibrated in May 1978

and March and September 1979 (T.S. G.3 requires an annual

frequency).

During a facility tour the inspector verified

that the monitor's audible alarm was functional.

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IE Inspection Report No. 50-264/78-02.

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Ibid.

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c.

Continuous Air Monitor (CAM)

The inspector reviewed records of calibrations and alarm

setpoint checks since May 1978 and noted that the frequency

was as required by T.S. G.3.

The inspector also verified that

an audible alarm was initiated when the setpoint was exceeded.

No items of noncompliance were identified in the above areas.

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9.

Exposure Control

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a.

External Exposure

The vendor's film badge reports were reviewed for the period

May 1978 to date. The greatest whole body and extremity doses

received in CY 1978 vere 60 mress and 220 mrems, respectively.

No measurable whole body dose has been received in CY 1979 to

date; the highest extremity dose has been about 180 mrems.

Self-reading pocket dosimeters are available if needed. The

inspector noted that the dosimeters had not been calibrated by

the licensee. The licensee stated that calibration would be

considered. This item will be reviewed further during a

future inspection.

b.

Internal Exposure

The licensee has no routine bioassay or air sampling programs

and relies of the CAM, contamination swipe tests, and pool

water analysis to define any problem areas. Records of the

above indicators were reviewed; no problems were noted. The

inspector noted that pool water was last analyzed for tritium

in 1971. The licensee stated that the current tritium concen-

tration will be analyzed. This item will be reviewed further

during a future inspection.

No items of noncompliance were identified in the above areas.

10.

Posting and Labeling

The licensee's compliance with posting and labeling requirements

specified in 10 CFR 19.11 and 10 CFR 20.203 were reviewed. No

problems were noted.

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Materials

Radioactive material received at the Dow complex is surveyed by the

Industrial Hygiene Office. The SAcensee stated that no material

has been received under the TRIG 3 license since the last radiation

protection inspection (May 1978).

Radioactive Material produced in

tha TRIGA is used within the facility.

No items of noncompliance v .re identified.

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12.

Surveys

As a result of a new program instituted by the Industrial Hygiene

Of fice, in July 1979 the reactor staff began conducting and documenting

contamination and area surveys monthly.

The Industrial Hygiene

Office makes quarterly contamination surveys of the f acility.

Results of surveys performed by both groups were reviewed. Only

low-level, short-lived contamination was noted.

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No items of noncompliance were identifisi.

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13.

Notification and Reports

A review of records and discussions with licensee representatives

indicated no problems in the licensee's compliance with 10 CFR 19

end 10 CFR 20 requirements.

No items of noncompliance or deviations were identified.

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14.

Radwaste Management

a.

Liquid Radwaste

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The only liquid released from the facility is domestic water

used to rinse demineralizer resia during resin changes (performed

about once per 18 months). The water is drained into a drum,

stored for several months, gamma scanned, and, if no activity

is detected, released to the sanitary sewer. The licensee

stated that no activity had been detected. About ten to

twenty gallons of distilled water are added to the reactor

pool each week to replace water lost by evaporation. Liquid

samples are evaporated and the planchets disposed as solid

waste.

b.

Gaseous Radwaste

The licensee has no gaseous effluent monitor. At the inspector's

request the licensee calculated that the amount of Ar-41

released annually would be less than 0.1 curie. The inspector

reviewed this calculation and concurred with the method used

and the results.

Any potential particulate effluents would be detected by the

CAM. No significant particulate activity was noted,

c.

Solid Radwaste

Solid radwaste (gloves, paper, etc.) is cellected by the

Industrial Hygiene Office and transferred (under NRC Byproduct

Material License No. 21-00265-06) to a licensed disposal

agency. About one 55-gallon drum of waste is generated annually

by the reactor facility.

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The licensee does not plan to submit a quality assurance

program satisfying the criteria specified in 10 CFR 71, Appendix

E.

The licensee was aware that, until such a program is

submitted, no shipments of greater than Type A quantities of

radioactive material can be made.

No items of noncompliance were identified in the above areas.

15.

Exit Interview

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The inspector met with licensee representatives (denoted in Paragraph

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1) at the conclusion of the inspection on October 3, 1979. The

inspector sotmmarized the scope and findings of the inspection.

In

response to certain items discussed by the inspector, the licensee:

Acknowledged the noncompliance with Reactor Operations Committee

a.

meeting frequency (Paragraph 5).

b.

Stated that the calibration of self-reading pocket dosimeters

would be considered (Paragraph 9.a).

c.

Stated that the evaluation of tritium concentration in reactor

pool water would be considered (Paragraph 9.b).

d.

Acknowledged the inspector's comments concerning their lack of

a quality assurance program satisfying the criteria specified

in 10 CFR 71, Appendix E (Paragraph 14.c).

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