IR 05000264/2019201

Dow Chemical Company Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2019201

ML19294A090
Person / Time
Site:	Dow Chemical Company
Issue date:	10/30/2019
From:	Anthony Mendiola NRC/NRR/DANU/UNPO
To:	O'Connor P Dow Chemical Co
Michael Takacs, DANU/UNPO,415-2042
References
IR 2019201
Download: ML19294A090 (15)

Text

ber 30, 2019

SUBJECT:

DOW CHEMICAL COMPANY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000264/2019201

Dear Dr. OConnor:

From September 9 - 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Dow Chemical TRIGA Research Reactor. The enclosed report documents the inspection results which were discussed on September 13, 2019, with you, members of your staff, and Dr. Wayde Konze, Chair of the Reactor Operations Committee.

The inspection examined activities conducted under your license as they relate to public health and safety, compliance with the Commissions rules and regulations, and compliance with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance with NRC requirements were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Should you have any questions concerning this inspection, please contact Mr. Michael Takacs at (301) 415-2042 or by electronic mail at Michael.Takacs@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-264 License No. R-108 Enclosure:

As stated cc: See next page

Dow Chemical Docket No. 50-264 cc:

Office of the Mayor 333 West Ellsworth Midland, MI 48640 Office of the Governor Room 1 - Capitol Building Lansing, MI 48913 Mr. Scott Bemis, Chair Radiation Safety Committee The Dow Chemical Company Environmental Health and Safety Responsible Care Leader 1790 Building Midland, MI 48674 Dr. Wayde Konze Global Research and Development Director for Analytical Sciences Chair, Reactor Operations Committee The Dow Chemical Company 1897 Building Midland, MI 48667 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Radiological Protection Section Office of Waste Management and Radiological Protection Michigan Department of Environmental Quality 525 West Allegan Street P.O. Box 30473 Lansing MI 48909-7973

ML19294A090 *concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO/SS* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC NAME MTakacs NParker AMendiola DATE 10/24/19 10/21/19 10/30/19

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No. 50-264 License No. R-108 Report No. 05000264/2019201 Licensee: Dow Chemical Company Facility: Dow Chemical Training, Research, Isotopes, General Atomics Research Reactor Location: Midland, Michigan Dates: September 9 -13, 2019 Inspector: Michael Takacs Approved by: Anthony J. Mendiola, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Dow Chemical Company TRIGA Research Reactor Inspection Report No. 05000264/2019201 The primary focus of this routine safety inspection was the onsite review of selected aspects of the Dow Chemical Company (the licensees) 300 kilowatt, Class II research reactor safety programs including: (1) health physics; (2) design changes; (3) emergency planning; (4) maintenance logs and records; (5) experiments; (6) fuel handling logs and records; and (7) inspection of transportation activities. The licensees programs were acceptably directed toward the protection of public health and safety, and in compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements.

Health Physics

• Surveys were being completed and documented as required.

• Postings met regulatory requirements.

• Personnel dosimetry was being worn and recorded doses were within the NRCs regulatory limits.

• Radiation monitoring equipment was being maintained and calibrated as required.

• The radiation protection program satisfied regulatory requirements.

• The radiation protection training program was being administered as required.

• Environmental monitoring satisfied regulatory requirements.

Design Changes

• No changes, tests, or experiments, subject to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, were performed.

Emergency Planning

• The emergency preparedness program was conducted in accordance with the licensees emergency plan and regulatory requirements.

Maintenance Logs and Records

• Maintenance activities were conducted in accordance with licensee procedures.

Experiments

• Experiments were reviewed and approved as required by the technical specifications (TSs).

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Fuel Handling Logs and Records

• Fuel handling and inspection activities were completed and documented as required by the TS and licensee procedures.

Inspection of Transportation Activities

• The program for shipping radioactive material satisfied regulatory requirements.

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REPORT DETAILS Summary of Facility Status The Dow Chemical Company (Dow) 300 kilowatt, Training, Research, Isotopes, General Atomics (TRIGA), Mark I research reactor is operated in support of research, reactor operator training, and periodic equipment surveillances. During the inspection, the reactor was operated to support irradiation of research samples.

1. Health Physics a. Inspection Scope (Inspection Procedures (IP) 69001)

The inspector reviewed the following to verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection against Radiation, and the applicable TS requirements:

• Radiological signs and posting in various areas of the facility

• Area and personnel dosimetry results from 2018 to present

• Radiation safety training records

• Maintenance and calibration of radiation monitoring equipment, including the water radioactivity monitor, area radiation monitor, and the continuous air monitor

• Dow TRIGA research reactor (DTRR) operating procedure No. 4.2.2, Area Monitor Calibration, dated November 2006

• DTRR operating procedure No. 4.7.1, Wipe Tests and Radiation Surveys, dated December 2016

• DTRR operating procedure No. 4.7.2.a, Disposal of Waste Generated in the Neutron Activation Analysis Group, dated December 2012

• Semi-annual primary water radioactivity monitor calibration records from 2018 to the present

• Semi-annual continuous air monitor calibration records from 2018 to the present

• Semi-annual area radiation monitor calibration records from 2018 to the present b. Observations and Findings (1) Surveys The inspector reviewed monthly radiation and contamination surveys of the reactor building, which were conducted by the facility staff. The results were documented on the appropriate forms and evaluated as required. The number and location of survey points was adequate to characterize the radiological conditions. The inspector noted that the Radiation Safety Officer (RSO) reviews all the survey records. The RSO also conducts an annual independent contamination survey of the facility and has verified that all the readings are as expected.

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(2) Postings and Notices The inspector reviewed the postings required by 10 CFR Part 19 at the entrances to various controlled areas including the Reactor Bay, and radioactive material storage areas. The postings were acceptable and indicated the radiation and contamination hazards present. The facilitys radioactive material storage areas were found to be properly posted. No unmarked radioactive material was found in the facility.

(3) Dosimetry The licensee uses a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel dosimetry. Through direct observation, the inspector determined that dosimetry was used in an acceptable manner by facility personnel. An examination of the records for the inspection period showed that all exposures were well within NRC limits and within licensee action levels. All of the staff and researchers associated with the facility wear Optically Stimulated Luminescent Dosimeter (OSLD) badges.

(4) Radiation Monitoring Equipment The calibration records of portable survey meters, fixed radiation detectors, and air monitoring equipment in use at the facility were reviewed. Calibration frequencies met the requirements established in TS 4.6 and calibration records were being maintained as required. The inspector reviewed the licensees tracking system for ensuring the instrument calibrations are completed on time and found it to be appropriate.

(5) Radiation Protection Program The radiation protection program provides guidance for keeping doses as low as reasonably achievable and is consistent with the guidance in 10 CFR Part 20. The inspector verified that the radiation protection program was being reviewed annually as required by 10 CFR 20.1101, Radiation protection programs, paragraph (c). No issues related to the radiation protection program were identified in the review of the program.

The radiation protection program requires that all personnel who work with radioactive material, receive training in radiation protection, policies, procedures, requirements, and the facilities prior to having unescorted access at the facility. The RSO is responsible for conducting the training and all the training is typically conducted on a computer and a classroom presentation. A test is administered at the end of the training to verify that the individuals understood the material presented. The inspector reviewed the training materials and noted that the staff were instructed on the appropriate subjects.

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(6) Environmental Monitoring Several OSLDs were placed around the inside walls of the reactor facility and minimal doses were recorded. Records show that there was minimal radiation exposure to the environment from the reactor during the previous year. There was no liquid effluent discharged from the reactor facility. The licensee indicated that gaseous effluents from the reactor facility were less than 25 percent of the allowed or recommended maximum concentrations in 10 CFR Part 20.

c. Conclusion The inspector determined that: (1) surveys were being completed and documented as required, (2) postings met regulatory requirements, (3) personnel dosimetry was being worn and recorded doses were within the NRCs regulatory limits, (4) radiation monitoring equipment was being maintained and calibrated as required, (5) the radiation protection program satisfied regulatory requirements, (6) the radiation safety training program was being administered as required, and (7) environmental monitoring satisfied regulatory requirements.

2. Design Changes a. Inspection Scope (IP 69001)

To ensure that facility changes were reviewed and approved as required by TS Section 6.2 and 10 CFR 50.59(c)(2), the inspector reviewed selected aspects of:

Reactor operation logbooks 127 and 128 DTRR No. 4.5.3, Facility Maintenance and Modifications, dated June 2014 DTRR annual reports for 2018 and 2019 Reactor Operations Committee (ROC) meeting minutes for 2018 and 2019 b. Observations and Findings Through review of applicable records and interviews with licensee personnel, the inspector verified that no changes, tests, or experiments, subject to 10 CFR 50.59 requirements, were performed since the last inspection.

c. Conclusion No changes, tests, or experiments have occurred since the last inspection.

3. Emergency Planning a. Inspection Scope (IP 69001)

The inspector reviewed the implementation of selected portions of the emergency preparedness program including:

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DTRR emergency plan (E-Plan), dated December 4, 2012 Emergency planning drill conducted June 12, 2019 Emergency response facilities, supplies, equipment, and instrumentation Monthly inventories of emergency equipment Memorandum of Agreement, Office of Emergency Management, County of Midland Michigan, dated May 30, 2019 b. Observations and Findings The inspector reviewed the E-Plan in use at the DTRR and verified that it was being properly implemented at the facility. The inspector reviewed the emergency facilities, instrumentation, and equipment and verified that the emergency response equipment, in general, was as described in the E-Plan.

Through direct observation, records review, and interviews with emergency organization personnel, the inspector determined that they were capable to respond, and knowledgeable of the proper actions to take in case of an emergency. The facility staff is responsible for responding to an emergency during all hours. The responsibility and authority for directing and coordinating emergency response activities are assigned to either the Facility Director (FD) or the Reactor Supervisor (RS), to act as the emergency director. All facility personnel receive annual emergency response training. The inspector verified that the licensee has continually reviewed the E-Plan and conducted an inventory of the emergency response equipment.

Emergency drills had been conducted annually as required by the E-Plan. The drill for 2019 was a practical exercise and tested the notification and response of the Dow Emergency Services and Security (ES&S) personnel. The critique was written and discussed following the drill to document any issues identified during the exercise. The action items that resulted were incorporated into the lessons learned policy.

The inspector toured the Dow Medical Health Services Building, which contains the facility and equipment used to support a response to a contaminated and/or injured worker and found it to be properly maintained. The inspector interviewed the Senior Health Services Specialist and noted the individual to be knowledgeable of the facilitys emergency support mission and its capabilities.

The inspector also toured the ES&S headquarters (building 1105), which contains the emergency response equipment and vehicles, and the Dow ES&S Dispatch Center (building 2010), which is also the location of the Dow Emergency Operations Center. The inspector toured these facilities and discussed the functions and capabilities of these facilities with the ES&S Leader and the ES&S Operations Leader. The inspector found the ES&S personnel to be knowledgeable and both facilities to be properly staffed and well maintained.

During the tour of the Dispatch Center with the RS, the inspector observed an actual emergency being called into the Dispatch Center from the reactor building (building 1602). The emergency involved a steam leak from the building heating system in the basement of building 1602. The steam leak caused a smoke detector to alarm which led to the evacuation of building 1602. The inspector noted that the reactor staff followed proper emergency procedure for a building evacuation to ensure that: (1) the reactor was shutdown and secured, (2) all-7-

reactor staff were accounted for and had evacuated the building, and (3) the Dispatch Center and the RS were properly notified.

c. Conclusion The emergency preparedness program was conducted in accordance with the licensee E-Plan and regulatory requirements.

4. Maintenance Logs and Records a. Inspection Scope (IP 69001)

To ensure that maintenance activities were consistent with regulatory requirements, the inspector reviewed:

Reactor operation logbooks 127 and 128 DTRR No. 4.5.3, Facility Maintenance and Modification, dated June 2014 Completed maintenance forms 4.5.3.b, Maintenance Form, from 2018 to present b. Observations and Findings The inspector reviewed the maintenance records for preventive and corrective maintenance activities. Routine/preventive maintenance activities were controlled and documented on DTRR reactor maintenance forms, which are maintained in a binder at the reactor console and reviewed by the RS.

Implementation of changes to equipment, systems, tests, or experiments are generally performed by the reactor staff. After all maintenance items are completed, system operational checks are performed to ensure the affected systems function properly before returning them to service.

c. Conclusion Maintenance activities were conducted in accordance with licensee procedures.

5. Experiments a. Inspection Scope (IP 69001)

To ensure that the requirements of TS Sections 3.7 and 6.5 were being met concerning experimental programs, the inspector reviewed selected aspects of:

Experimental administrative controls and precautions Review and approval process for experiments Completed experimental request forms, TRIGA Activation Request Form, for 2018 to the present Completed Approval Sheet for Special Experiments, Annual Fuel Inspection, for 2018 to the present-8-

b. Observations and Findings The system used for the irradiation of various materials in the reactor core is the Pneumatic Tube Irradiation Facility in conjunction with the Lazy Susan system that surrounds the reactor core. Samples that have been irradiated include various materials that are produced or utilized at Dow. All experiments conducted are in accordance with approved authorization requests. The FD or RS review and approve all routine experiments to be irradiated in the reactor core in accordance with the TS limitations for each sample. No new experiments had been initiated since the previous inspection at the facility. In 2019, one special experiment was approved to conduct the annual fuel inspection and was approved by all members of the ROC.

c. Conclusion Experiments were reviewed and approved as required by TS.

6. Fuel Handling Logs and Records a. Inspection Scope (IP 69001)

To verify that TS and procedural requirements were being met, the inspector reviewed selected aspects of:

Reactor operation logbooks 127 and 128 DTRR No. 4.3.2, Movement of Fuel - General Requirements, dated December 2012 DTRR No. 4.3.3, Movement of Fuel - Approach to Criticality, dated December 2012 DTRR No. 4.3.4 a, Procedure for the Performance of the Annual Fuel Inspection, dated June 2014 b. Observations and Findings The inspector determined that the licensee was maintaining the required records of the various fuel movements that had been completed and verified that the movements were conducted and recorded in compliance with licensee procedure. All fuel movements were noted in the reactor operations logbook, as well as on the fuel element position indication map in the reactor bay. The fuel element inspections generally included all of the fuel elements every four years and inspection of the control rods on an annual frequency, which is more frequent then the TS requirements. Inspections of the fuel elements and control rods showed consistency with accepted values and did not indicate any deterioration of cladding. Data recorded for fuel handling was clear and cross-referenced in the operations logs and the fuel element position indication map. Log entries clearly identified, as required by procedure, that a minimum of three persons were present when fuel was being moved. The inspector determined that the procedures and the controls specified for these operations were acceptable.

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c. Conclusion Fuel handling and control rod inspection activities were completed and documented as required by TS and licensee procedures.

7. Inspection of Transportation Activities a. Inspection Scope (IP 86740)

To verify compliance with regulatory and procedural requirements for transferring or shipping licensed radioactive material, the inspector reviewed the following:

• Dow annual operating reports for 2017 and 2018 Reactor operation logbooks 127 and 128 b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee had not shipped any radioactive material since the previous inspection in this area under the reactor license. Transfer of radioactive material to other Dow facilities was under the Broad Scope License (21-00265-06) with guidance from the Radiation Safety Committee, the RSO and the Dow Radiation Protection Manual.

c. Conclusion No radioactive material shipments had been made under the auspices of the reactor license during the past year.

8. Exit Interview The inspection scope and results were summarized on September 13, 2019, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee W. Konze Director, Dow Analytical Sciences Facility Director S. Yusuf Reactor Supervisor B. Haskins Senior Reactor Operator N. Goodman Senior Reactor Operator Trainee R. Mabile Leader, Dow Emergency Services and Security M. Groendal Operation Leader, Dow Emergency Services and Security K. Wegener Radiation Safety Officer J. Cassiday Health Physics Technologist J. Morris Senior Health Service Specialist INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities (N/A for this inspection)

ITEMS OPENED, CLOSED, AND DISCUSSED Opened:

None Closed:

None Discussed:

None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations DTRR Dow TRIGA Research Reactor E-Plan Emergency Plan ES&S Emergency Services and Security FD Facility Director IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission OSLD Optically Stimulated Luminescent Dosimeter ROC Reactor Operations Committee RS Reactor Supervisor RSO Radiation Safety Officer TRIGA Training, Research, Isotopes, General Atomics TS Technical Specification Attachment