ML20137D322
| 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: |
| 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
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Principal Inspector *
A. G. Finley
(Date)
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Accompanying Inspector *
D.
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Other Accompanying Personnel:
None
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Reviewed By:
.A
Hind, C
Safeguards Branch
(Date)
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Attachment:
Findings (Part 2.790(d) Information)
S-F3-76-241
Copy
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9
Pages
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THIS DOCUMENT IS NOT TO BE
REPRODUCED WITHOUT SPECITIC
APPROVAL OF IE:III
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0508220452 850724
MOHNB5-256
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Part 2 7D3(d) Infor:stio=
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SUMMARY OF FINDINGS
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Inspection Summary
Inspection conducted March 3 and 4, (76-02):
The inspection
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consisted of a physical inventory and verification, review of
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
Not applicabic.
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Other Significant Items
A.
Systems and Components
None.
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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.
D.
Noncompliance Identified and Corrected by Licensee
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None.
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Part 2.790(d) Infor:ation
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Port 2.7'0(') Infer-St!C
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Deviations
None.
F.
Status of Previously Reported Unresolved Itees
Not applicabic.
Manar<nent Interview
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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
and the
fuel on hand
.is in the
andlis
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only movement of SNM involves within
movement
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.
loss or theft of SNM. The Radiation Protection Officer in
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, conjunction with Health Physics is responsible f or the preparation
of Forms NRC-741 and 742.
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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
more LSO's.
Samples to be irradiated and all experiments are
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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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Ta'rt 0.790(d) Inforestion
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P;rt 2.790(d) Inf or .stion
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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:
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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
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to the Radiation Hazards Committee, a subcommittee of the
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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Port 3,790ld) .Inforest
the reactor has been in operation since July 6, 1967, a period of
approximately 8.5 years.
The licensee agreed to a determination of
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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
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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
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All within
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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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Part 2.790(d) Infor:2 tion
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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 CFR 70.54 and 10 CFR 70.53, respectively.
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Part 2.7J0(d) Inforestion
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Part 2.79D(d) Infor:aticn'*
The two 30 millicurie plutonium 238 sources and the one 120 millicurie
plutonium 238 source authorized under License No. SNM-1451 are identified
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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
270 millicuries Pu-238
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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
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No. of
Fuel
Enriched Uranium
Elements
U
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Beginning Inventory 6/1/67
Receipts
Total to Account For
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Shipments
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Depletion
Ending Inventory 3/4/76
Total Accounted For
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Includes material transferred from lease to private as a receipt.
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Includes material transferred from lease to private as a shipment.
Exhibit A
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Part 2.790ld) Inforration
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