ML20137D322

Matls & Safeguards Insp Rept 50-264/76-01 on 760303-04.No Noncompliance Noted.Major Areas Inspected:Physical Inventory & Verification,Review of SNM Records,Depletion Calculations, Matl Transaction Forms & Matl Status Repts

ML20137D322
Person / Time
Site:	Dow Chemical Company
Issue date:	03/24/1976
From:	Finley A, Hind J, Holody D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137D185	List: IR 05000264/1976002 IR 05000264/1978004 IR 05000264/1983001 ML20137D178 ML20137D322
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 50-264-76-02, 50-264-76-2, NUDOCS 8508220452
Download: ML20137D322 (9)

See also: IR 05000264/1976001

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UNITED STATES Nt' CLEAR REGULATORY COMMIS510N

OTTICE OT INSPECTION AND ENTORCEMENT

REGION III

IE Inspection Report No. 050-264/76-02

Licensee: Dow Chemical Company

Building 47

Midland, Michigan 48640

TRIGA Reactor License No. E-105

Midland, Michigan Category: F

Type of Licensee: Research and Development Reactor

Type of Inspection: Materials, Safeguards - Unannounced

Dates of Inspection: March 3 and 4, 1 6

Principal Inspector *

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A. G. Finley

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Accompanying Inspector * D. . d 3

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Other Accompanying Personnel: None

Reviewed By: .A Hind, C 3 7h

Safeguards Branch (Date) ,

Attachment:

Findings (Part 2.790(d) Information)

S-F3-76-241

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Copy j of 6 Copies

9 Pages

! THIS DOCUMENT IS NOT TO BE

REPRODUCED WITHOUT SPECITIC

APPROVAL OF IE:III

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0508220452 850724

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Part 207D3(d) Infor:stio=

SUMMARY OF FINDINGS

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Inspection Summary

Inspection conducted March 3 and 4, (76-02): The inspection

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special nuclear material records, depletion calculations, material

transaction forms, and material status reports. No items of

noncompliance with NRC requirements were identified within the

-scope of this inspection.

Enforcement Items

None.

Licensee Action on Previously identified Enforcenent Items

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Not applicabic.

Other Significant Items

A. Systems and Components

None. .

B. Facility items (Plans and Procedures)

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On December 11, 1974, a timely request to renew License SSM-

1451, due to expire January 31, 1975, was initiated by the

Radiation Safety Officer to Directorate of Licensing. A

second inquiry was'made by teletex on February 26, 1976 to

Directorate of Licensing requesting the renewal notification.

As of the inspection date, renewal notification for License

SNM-1451 had not been received by the Dow Chemical Company.

C. Managerial items

L. C. Silverstein, Radiation Protection Officer, recently

left the facility and C. W. Engdahl is presently Radiation

Protection Officer at the Dow Chenical Company. Effective

January 1,1976 Mr. R. D. Deline replaced H. R. Hoyle as

Chairman of the Radiation Safety Committee.

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D. Noncompliance Identified and Corrected by Licensee

None.

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E. Deviations

None.

F. Status of Previously Reported Unresolved Itees

Not applicabic.

Manar<nent Interview -

A management interview was conducted by Messrs. Finicy and Holody

of the inspection tear with Mr. R. D. Deline, Chairear., Kadiation

Safety Committee and R. A. Olson, Health Physicist.

The licensee was inforncd that no iters of noncompliance with NRC

requirements were identified within the scope of this inspection.

It was also noted that as a result of NRC inspector depletion

calculations for thc past 6.5 years, a small amount of depletion

had occurred which would require reporting on the Material Status

Report. Since the recent Material Status Report for the period

ending December 31, 1975, had to be revised because of a

typographical error, it was suggested and agrewd, that the revised

Material Status Report should also reflect on line 73 the few

grams of depletion involved.

The licensee was also inf erred because they were not authorized to

possess at any one time SNM in a quantity exceeding one effective

kilogram they were exempt from the procedure requirements of 10

CFR 70.5) (c). The inspectors, however, did indicate that even

with thc lir.ited activity to date, it would appear to be good

administrative practice to initiate procedures for the control,

accountability and reporting of special nuclear material. The

chairman of the Reactor Saf ety Committee agreed to this and the

inspectors Icft a list of pertinent 10 CFR 70 requirements as they

pertain to a facility authorized to possess less than an effective

kilogram of SNM. The management interview terminated with the

understanding that accountability and SNM control procedures would

be established.

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Tart 2,733(3) Infor-Stloa

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Part 0.790(d) Infer:stice

• REPORT DETAILS

Licensee Personnel Supplying Information

Dr. O. U. Anders, Reactor Supervisor

G. W. Engdahl, Radiation Protection Officer

R. A. Olson, Health Physicist

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-Scone of Inspection

The inspection was made to determine the If censee's compliance

with the safeguards compliance of Title 10, Code of Federal

Regulations, Part 70, as they pertain to a research and

development reactor licensed ptrsuant to Part 50.

Facility Organization

The licensee is not authorized to possess an effective kilogram of

SNM and is exenpt from the 10 CFR 70.51(c) procedure requirement.

Annual serial , numbered physical _ inventorie,s are conduct,ed. All

fuel on hand u .is in the and the

only movement of SNM involves within movement andlis

documented in the reactor log book. ICA or internal transfer

movements are not applicable. An up-to-date core diagram is

maintained reflecting serial numbered fuel elements in each core

position. Physical annual inventories are maintained. The

Laboratory Director ackncwledges the receipt and shipment of all

SNM. The Reactor Supervisor is responsible for computation of

uranium depletion, the Reactor Operations Committee for custody of

SNM and investigation and reporting of accidental criticality.

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loss or theft of SNM. The Radiation Protection Officer in

, conjunction with Health Physics is responsible f or the preparation

of Forms NRC-741 and 742. .

Facility Operation

The primary use of the reactor is irradiating chemical samples for

purposes of elemental analysis. Percent element in sample is

determined for chemical purposes for Dow in-house use.

The reactor is under the direct control of the Reactor Supervisor

who is a licensed senior operator (LS0), with a staf f of one or

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more LSO's. Samples to be irradiated and all experiments are

defined in a written request for reactor operation to be approved

by the Reactor Supervisor. For the first time a specific or type

of experiment is conducted, approval by the Reactor Operations

Committee is required.

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Reactor Operations Committee:

1. Composed uf at least four menbers 'of the laboratory staff

including Reactor Supervisor and qualified Health Physicist.

2. Laboratory Director is Chairman.

3. Shall establish written procedures regarding quorums, use of

subcommittees, review of experiments and operations. The

commit tee will review: _

a. Experiments involving fissionable material.

b. Experiments involving a change of core configuration,

change in equipment or apparatus associated with the

reactor core or its irradiation facilities, or a new

piece of apparatus being mounted in the reactor well.

4. Any other experiment, of a type not previously approved by

the committee.

5. The committee will approve proposed changes in operating

procedures and be responsible for determining whether a

proposed change, test or experiment would constitute an

unreviewed safety question or a change in the specifications,

as required by 10 CTR part 50 (50.59).

6. The committee meets at least quarterly to review previous

quarter operations and approve operations for the coming

quarter. In addition, the committee is available for

determining safety or operational matters that are referred

by the Reactor Supervisor or required by specifications.

7. The Reactor Operations Committe; will report its operations

to the Radiation Hazards Committee, a subcommittee of the

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Executive Safety Coun'cil of the Dow Chemical Company.

The licensee has confined his possession and use of SNM to the

location and purposes authorized by license as required by 10 CFR

70.41.

Measurements and Statistical Controls

The licensee is operating the reactor at a maximum average of 10

• hours a week at full power (100 kilowatts). At such a rate, the

inspector determined that there was some U-235 depletion, since

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Part.2,790(d) Inforestion .

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the reactor has been in operation since July 6, 1967, a period of

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approximately 8.5 years. The licensee agreed to a determination of

the depiction over the last 8.5 years and has agreed to make the

adjustments on a revised Material Status Report for the period ending

December 31, 1975.

Shipping and Receiving

Shipping and receiving has been a very Ifmited function to date

and is accomplished by Radialf on protection in conjunction with

Health physics. The only receipts involvcJ the initial receipt of

fuel in 1967 plus the receipt of two fiSFlon CounterF in 1967 and

another in 1973. The only external shipnents involved the return

of 14 fuel assemblies not required in 1967 and one of the fission

counters.

Forms AEC-388 and NRC-741 involved in the limited receipt and -

shipment activity were' reviewed. The forms were prepared and

distributed as required by AEC-388 instructions and 10 CTR 70.54.

Storage and_ Internal Control

The licensee has no ICA's or any necessity to initiate internal

transfer documents. The;e is no spare fuel on hand and all fuel ,g

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core movements are documented by serial number and location in the

reactor log book which is utilized to update the core schematic

reflecting fuel element serial number and core locations.

Inventory and Inventory Verification

The core at the Dow Research Reactor is circular in dimension,

with 91 positions availabl.e for fuel elements. The core is

divided into 6 regions which consist of the center and the 5

cylindrical strips surrounding the center. The center has room

f or 1 fuel element and the cylindrical strips have room for 6(X)

elements, where X=1 for the strip closest to the center and X-5

for the strip furthest from the center. Thus, the six regions

have respectively 1, 16, 12, 18, 24, and 30 positions available.

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At present, there are fuel elements and *dumny elements

(these do not contain SNM) in the 91 core positions. All 91 of

• these elements are 1.47 inches in diameter and 28.44 inches in

length. The fuel elements are by weight eight percent uranium,

91 percent zirconium and I percent hydrogen, with an initial

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Part 2.730(d) Inforestitt

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uranium-235 enrichment of 19.88 percent. These fuel elenents are

clad either with aluminum or stainless steel which is 0.30 inches

thick, and they account for approximately 2.8 kilograms of uranium-235.

The dummy elements essentially are made of graphite. The inspector

verfiled the core by observing that all of the 91 posttions were filled

and also by a random serial number verification of .of the fuel

elements. This was achieved by having two Reactor Operators, under the

supervision of the Reactor Supervisor, manually withdraw the fuel element

from the core to a position about 5 or 6 feet below the surface of the

water. With the aid ol a, spotlight, the inspect 6r determined the

serial number. In all cases, the serial number and position matched

the serial numbtr indicated for that element on the large status board

in the reactor roon. The inventory also conristed of two fission

counters which the inspector verified as being in the core. This was

the extent of the licensee's possession under License R-108. The

licensee also possesses two 30 millicurie Pu-238 sources and one 120

millicurie Pu-236 source under License No. SNM-1451 f or testing purposes.

The 120 millicurie Pu-238 source was physically verified and the two 30

millicurie sources verified by purchase order records.

Records and Reports

The records review covered the period f rom the initial receipt of fuel

in June 1967 through March 4, 1976. There has been very limited activity

and Material Status Reports since December 31, 1967 have been essentially

unchanged. A revision to the Material Status Report for the period

ending December 31, 1975 was requested because of a typographical error

and to report the first minor depletion since the 8.5 years of reactor

operation as determined by the NRC inspectors.

The Dow Chemical Company has only a temporary storage rack utilized for

within core movements and with all fuel in the reactor core and no extra

fuel, ICA's and internal transfer documents are not established or

dnitiated. All within core movements are documented in the reactor log

book which was checked and agreed to the current core schematic by

serial number and location.

In June 1973 all material held under License No. R-108 was transferred

from Icase to private on Form NRC YFX-YrX No. 1.

All transfers of SNM were restricted to authorized receivers as required

by 10 CFR 70.42.

Forms NRC-741 and NRC-742 are prepared and distributed as required by 10

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CFR 70.54 and 10 CFR 70.53, respectively.

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The two 30 millicurie plutonium 238 sources and the one 120 millicurie

, plutonium 238 source authorized under License No. SNM-1451 are identified

by Dow Chemical Company purchase order numbers 910970-1, 911278-2 and

873018-1.

The 11censee's authorized limits and holdings as of March 5,1976 by

docket and license are as follows:

Authorized Possession

Docket Li c ens e ,

Linit 3/5/76

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50-264 R-108 3.4 kgs. U-235

70-1487 SNM-1451 270 millicuries Pu-238 gg[-

Exhibit A reficcts the activity for License R-108, Docket No. 50-264,

f or the period of inspection and supports the possession values as of

March 4, 1976.

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There was no apparent loss or theft of special nuclear material that

required reporting as required by 10 CTR 70.52.

The licensee's records system provides sufficient information to

comply with all record requirements of 10 CTR 70.

Attachment:

Exhibit A

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Part 2.7s0(:) Information

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Fort 2.790(d) Icfor:stio

Dow Chemical Cormany - YFX

Material Balance Statement - Privately Owned Enriched Uranium

For Period 6/1/67 - 3/4/76 R-108 i

No. of

Fuel Enriched Uranium

Elements U U-235

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Beginning Inventory 6/1/67

Receipts

Total to Account For

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Depletion

Ending Inventory 3/4/76

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Includes material transferred from lease to private as a receipt.

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2/ Includes material transferred from lease to private as a shipment.

Exhibit A

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Part 2.790ld) Inforration

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