ML20137G417

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Insp Rept 50-264/67-01 on 670620 & 21.Deviations Noted: Manually Operated Louvres Installed as Backup to Automatic Louvres in Ventilation Intake & Exhaust Ducts & Reactor Room Area Monitor Placed on East Wall Rather than CRD Platform
ML20137G417
Person / Time
Site: Dow Chemical Company, 05000000
Issue date: 06/26/1967
From: Condelos J
US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML20136D183 List: ... further results
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 50-264-67-01, 50-264-67-1, NUDOCS 8508270293
Download: ML20137G417 (24)
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U. S. ATOMIC ENERGY COMMISSION REGION III

. DIVISION OF COMPLIANCE

- < June 26, i967 CO REPORT NO. 264/67-1

Title:

DOW CHEMICAL COMPANY LICENSE NO. CPRR-94 m Dates of Visit: June 20 and 21,1967 By: John G. Condelos, Reactor Inspector

SUMMARY

The initial inspection of the TRIGA MARK I reactor at Midland, Michigan,

-was conducted on June 20 and 21,1967. The AEC regulatory program and the

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compliance inspector's role were discussed with the applicant. The status of construction and functional testing at the facility was reviewed, and it was determined that the facility could be ready for a final preoperational inspection by June 28 and fuel loading on June 29, 1967.

Substantially all construction work and equipment installation has been completed. Except for several deviations, which have no safety significance, the following portions of the facility appear to have been constructed in accordance with the application:

Reactor room and its ventilation system Reactor well Reactor core components, including control rods, neutron detectors and source.

Irradiation and laboratory facilities Reactor cooling and purification system Radiation monitoring equipment Radioactive storage facilities Reactor cortrol instrumentation The above mentioned deviations are listed in Appendix A. Reporting the deviations with accompanying supporting analyses has been discussed with the applicant.

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Functional testing of some of the systems remains to be completed. Che ck-out and calibration of the control console instrumentation was in progress.

The remaining functional testing data will be evaluated and the proper operation of all alarms, interlocks, and safety circuits will be determined during the final inspection. Appendix B gives a detailed listing of the 4 ,*Le items that have to be covered at that time.

The reactor fuel shipping casks have been received. Because the fuel had been previously irradiated at GA, a special program for initial fuel load-

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ing had to be developed. The general feasibility of this pecgram was reviewed. It appears that conceivable accidents occurring during shipping cask handling and unloading in the reactor pool would not increase the risk of an accidental criticality incident or of a radiation release (by mechantcal damage to fuel) in excess of the accidents analyzed in the application. Details for source / detector geometry were not yet available and will be evaluated during the final inspection.

The routine operating, emergency, and health physics procedures, and the facility administrative arrangements were reviewed and found to be generally adequate for the intended functions and in accordance with the application descriptions and the Tech Spec requirements. Additions are being made to the routine startup procedure and the radiation survey program for the initial reactor startup. These will be evaluated at the time of the final inspection.

DETAILS 4 1. Scope of Visit An announced visit was made to the site of the Dow Chemical Company TRIGA FMRK I reactor facility at Midland, Michigan. Since this was the initial visit to the facility, the purpose of the visit was twofold:

1. To acquaint the applicant with the AEC regulatory program and the role of the Division of Compliance, and
2. To determine the status of construction and preoperational testing of the facility.

The inspector was accompanied by Mr. G. Fiorelli who will assume inspec-tion responsibility following the reactor startup and who assisted in the writing of this report. The facility was toured, testing was observed, and discussions were held with the following people:

Dr. W.11. Beamer, Laboratory Director z;>(f m

7 Scope of Visit (Continued)

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Dr. O. U. Anders , , Reactor . Supervisor t' u. u . , . . , , ,

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  • c e J o.9 . o m m :n op. 6 Mr. D. H. Clarey,.. Senior Reactor Operator ; Trainee t ' . . .

,,,,, Mr. M. DeGroot , GA Electronics Engineer .

II. Results of Visit

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A. Status of Construction and Testing i

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1. Site The inspectors observed that the distance from the reactor to the exclusion boundary and the distance of the nearest residence from the facility appeared to be in accordance with information given in the application and the requirements of the technical specifications. . Ihe research. activities conducted in nadby laboratory buildings were discussed with the appli-cant and it was determined that by the nature of the experimental programs , there was no significant potential for damage to the reactor facility by means of explosions at the other facilities. >
2. Reactor Room The inspectors observed that the dimensions of the reactor room and the materials of constructions appeared to be as described in the application. The inspectors also observed that the locations and types of doors and their weather stripping were in accordance with the application.
3. Reactor Well The inspectors were advised that the as-built dinensions of the aluminum reactor tank were 6'4" OD by 21'10" deep with a h" wall. The tank was leak tested in position by vacuum box technique and hydrostatic test. No leakage was found. From discussions with the applicant, it was determined that the maximum height of water above the reactor upper grid plate would be 17'1". The normal water level would be maintained at about 16 '. The siphon break holes drilled in the reactor cooling inlet and outlet pipes in the tank are located at an elevation of 16'1" above the upper grid plate. No liquid level instrumen-tation is required nor installed. The applicant will assure proper level by a check prior to each startup.

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Results of Visit (Continued)

.: m e The applicant advised that for reasons relating to convenience of construction', thd' c' oncrete shell surrounding the reactor tank was made thicker. Ine wall thickness is actually 3'2" rather than the l' 'given in th'e Safety Analysis Report (SAR) and the .._

bottom thickness is 3'6" rather than the 2' stated. This

.---, deviation is to be reported to DRL. The inspectors determine'd from photographs that the steel liner surrounding the concrete shell was in place.

Except for the deviation noted above, the reactor well has been constructed in accordance with the application.

4. Hot Chemistry Area The inspectors observed that the installation of the labora-tory hood, the rabbit _ facility _ connection'to the hood, and the

, layout of the hot chemistry room were' in, ac'cordance with the description givedln the applica' tion'. The' rabbit exhaust, air

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r will pass through the absolute filters installed'in'the hood exhaust. The absolute filters'have'6een installed and the hood' is in operation. The air inflow is to be 1000 cfm. The experi-i menter will be responsibic for periodically checking the flow to determine that it is in accordance with the Dow Laboratory requirement s. The two portable GM monitors are yet to be supplied, but the applicant assured that these would be available at the time of startup.

~~-- , 5. Reactor Room Ventilation The ventilation system installation has been completed and initial tests run. The applicant elected to increase the air flows, thus the present flows are 1750 cfm out and 1500 cfm in.

This change from the values given in the SAR will be reported to DRL. The applicant has installed backup louvres which can be manually closed from outside the building. These have been provided as a means of assuring that tight closure can be made if the automatic dampers in the ventilation ducts fail to close properly. The inlet damper is pneumatically driven and is actuated by a relay in the fan control circuit. The outlet damper is held open by the exhaust fan discharge pressure and closes by gravity when the fan'is turned off. At the request of the inspectors, the automatic operation of the dampers was i demonstrated. It was observed that the exhaust damper closed, but the intake damper failed to operate. Since the applicant vn' d

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't Results of Visit (Continued) stated' that the inlet damper had previously operated properly, ,

this is considered to be a maintenance item. Proper operation will be checked during the final inspection.

wag;a The inspectors made smoke test measurements of the air flow into the reactor room as a function of the positions of the reactor room doors, the console room doors, and the hot chemistry area door. It was ' concluded that with all doors in their normal positions, air flow into the reactor room would be adequate. In response to the inspector's question, the applicant stated that the reactor would be shut down if the reactor room exhaust fan failed.

6. Radiation Monitoring
a. Area Radiation Monitor This monitor is a GM type. The meter and its alarm are located behind the console and are shared with the reactor water radioactivity monitor. The detector is mounted on the east wall of the reactor room, approximately 10 feet from the reactor center, rather than on the control rod drive plat-form as stated in the SAR. The applicant intends to report this departure from the SAR to DRL. It was originally intended that the alarm trip point be set -for 100 mr/hr.

After some discussion, it was decided that the alarm trip point would be set 10 mr/hr above background level during the initial fuel loading and startup and also during the first phase of routine operation. Based on experience with radiation background related to the routine operating con-ditions, the choice of trip point will be, altered so as to provide the best balance between maintaining maximum sensi-tivity to abnormal radiation levels and requiring the trip setting to be adjusted regularly because of variations in

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back' ground levels. The monitor will be calibrated by use of a known gamma source and the calibration data will be

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reviewed during the final inspection.

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b. Water' Radioactivity Monitor As noted above,,the console meter for the area monitor is shared with the water radioactivity monitor. In the normal mode of operation, the meter will indicate the sum of the two' activities, and the alarm will be based on this v ,

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, Results of Visit

, .( Continued) s total reading. A , selector switch is provided at the console which permits ei_ther of the two monitor activity indicat' ions to be, displayed ind.ividually. . The water monitor had not been installed yet. Its calibration data will also be reviewed during the final inspection.

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c. Continuous Air Particulate Monitor The applicant intends.to place the portable air particu-late monitor on the south wall of the reactor room beneath the exhaust system intake. The reading'on the monitor strip chart will be considered to be the record of the radioactivity discharged from the exhaust stack. The monitor is being operated now so as to determine the background levels prior to startup. Normal background levels during reactor operation will be established also. Any increases from this level will be cause for a special analysis of the filter paper to determine the specific nature of the radioactivity which caused . the increase. ,The_ amount of, activity. released from the stack will be estimated, recorded, and used as a basis for determinating compliance with 10 CFR 20. Initial cali-bration data and alarm settings will be reviewed during the final inspection.
7. Radioactive Storage
a. Small Sample Storage

.m The arrangement for storage of rabbit samples was examined and found to be in accordance with the application.

b. Fuel and Large Sample Storage Three fuel storage racks of ten element capacity each are to be a permanent part of the facility. The applicant stated that GA calculations indicate the keff of the rack to be less than 0.53. Three ten inch schedule 40 pipes, 12' long are also provided for fuel storage. Two pipes spaced on 3' centers are provided on the east side of the room and one pipe on the north side of the room. The pipes are encased in concrete of 12" wall thickness. The applicant stated that GA calculations show that with the amount of concrete stated, a separation of three feet would essentially decouple the holes. The applicant will limit the number of fuel elements in each storage hole to 19 and a minimum 5' water shield will be provided.

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".The ahh icant'mayl store large' irradiated samples and hot waste in:these holes. 'All wastes-from the reactor facility will be"tE3nsfeVred ici the 'Dow Health Physicist for his dis-posal.

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8. Reactor Core
a. Status of Installation Installation of the core internals including control rods, neutron source, neutron detectors, and' irradiation facilities have been completed. Based on discussions with the applicant and the inspectors' observations, it appears that the install-ation has been made in accordance with the application. There are several exceptions which will be discussed in the sections below. ',

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b. Fuel Elements - 4 "U "-

Seventy-s'ix previously irradiated stainless steel clad fuel elements and several new Al clad elements have been provided for this reactor. Any new elements remaining after loading to 1.5% kex will be returned to GA. No spares are to be available at the facility. Identification numbers and irradiation history of the stainless steel elements have been provided to DRL.

~ 4e.aved The fuel was shipped in four 7500 pound casks, each of which contained 19 elements. (GA has calculated the keff of each cask to be less than 0.8.) The total amount of U-235 in the casks is 2.9 kilograms. SNM License 990, issued 6-9-67, provides the Dow Chemical Company authorization to receive and store 3.4 kilograms U-235. Section 2.B. of the proposed facility operating license lists 3.0 kilograms as the authorized amount. By letter of 6-19-67 to DRL, Dow requested that the authorization be changed to 3.4 kilograms.

The following criteria were used by GA in the selection of fuel:

(1) the overall transverse bend is less than 1/16",

i- (2) the longitudinal elongation is less than 1/10", and (3) the clad is intact with no leaks or swelling.

. Results of V.isit m 2.

(Continued)

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The applicant stated that the criteria to be used for fuel replacement' Wh'e'n making the inspections required by Tech'

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Spec w'ill'be: ', ,'

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o (1) bowing geater than 1/16",

m.4wed (2) elongation greater than ", and (3) indications of significant clad attack or diffi-culty with fit in the lower or upper grid plate.

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c. Reactor Source GA was to provide a 7 curie sealed polonium-beryllium source and this curie strength was stated in the proposed license. However a' 10.79 curie source was provided. Con-sequently, in the June 19 letter to DRL, Dow also requested that Section '

2.C. of the license be revised to allow use of an 11 cur'ie' 's'dur'ce. The source ha s been received and has been installed in the reactor. Initial checks of the neutron detectors have been made. .

d. Control Rods and Drives The control rods have been installed and the drives connected. The poison section elevation with respect to the fuel has been set and initial testing begun. The con-

---+as trol rod core positions were selected in accordance with the GA Acceptance Test Procedure 116, Rev. A. (See Figures 1 and 2.) The control rod drive system appears to be con-structed and installed in accordance with tin application, except for a change in length of the poison section.

The SAR describes the poison length as approximately 20". GA supplied poison sections of 19". Based on data provided by the applicant, the inspectors determined that with the rods in the normal down position, the fueled length of the core would be covered by poison. It appears, however, that if the control rod extensions were to fail or if the rods were lowered to the bottom of their guide tubes (when the drives are disconnected) approximately 3/4" of the upper portion of the fuel would not be covered by poison. The reactivity effect of exposing 3/4" of the top of the core is expected to be very small. This effect will be evaluated af ter the control rod calibrations are made. The variation in shutdown margin will also be evaluated. The applicant Y?"b 4

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-Results of Visit (Continued)

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inte'nds t'o rey'oEt al'1 Ehis' inform' a 'tibn to DREsh'or'tly af ter '

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.s .The poison' material is a boron carbide and aluminum

?"*** oxide mixture compacted and sealed in aluminum. The inspec-

!" tors informed the applicant of problems at other facilities

% with boron carbide powder. rods. In this connection,.the b fabrication and inspecti6n"61 story' of 'the rode' was discussed.

The applicant believes that' leak tesiing was performed. The 2

applicant visually inspected them before installation and l found no surface defects. The applicant will attempt to

{. have the leak testing data and as-built dimensions of the rods available at-the time of'the final inspection.

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.CNo rod free-fall timing [instrdmentation is provided. The i; ,

2 Lapplicantiintends to"use's sfop watEh'for dtegnination e of' compliance with the l'second requirement of the Technical Specifications.'" The GAElsc'tronis's 'enirineer' 'has" timed several

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drops and ' estimates 'the 'tise'to be ieve,ral' hEAdred milli- '

seconds. fThe inspectors timed one drop and obtained about 500 milliseconds. The inspectors feel that this method.

probably yields a value greater than the actual time and is adequate for surveillance purposes.

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The official functional tests'for the drives are.yet to be made. The rod drive speeds, free-fall times for at 1 east ten drops, and experience with the operation of the limit switches will be reviewed during the final inspection.

e. Irradiation Facilities A small leak at a weld was found.in the rotary specimen

'. 0I rack during a leak test and was repaired successfully.

Rack rotation was briefly checked; a one-half to one hour rotational'run will be conducted prior to the final inspec-tion.

Preliminary testing of the rabbit system has been completed.

The applicant stated that at least ten successful rabbit injections and removals will have to be completed before they g will. accept the system as functional. The test data will be reviewed at ' the time of the final inspection. A " roughing" i

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-Results of Visit R ~.. ., ,.

S(Continued) alinuca) particulate filter is,provided on the suction side of the rabbit blower. The' dischatge side of the' blower is tied

'to the hot" chemistry area hood duct. The rabbit and hood effluent pass through absolute particulate filters before

,,,,, discharged from the s' tack.

The inspectors discussed the applicant's plans for keep-ing records of ' the ' rabbit exhaust efflue'nt in accordance Uith the req'uire'e6ts m i of'Snction'C.2. of'th'e proposed lic'ense.

The applicant noted that the analyses presented in the SAR indicated thad 10 CFR limits 'would not be ' exceeded if the rabbit was exhausted continuously. The values used in the analysis will be employed as an' upper limit for argon 41 discharged in the effluent. If a rabbit sample fails, it will be assumed that the amount of radioactive material missing was'discha'rged thro 6gh the 'itacks -The exact amounts

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discharged will be estimated 'on1thd basin of'the assumptions

'given in Section'J.'7.~of'the' proposed Technical Specifications.

A record will be made of the estimated amounts so that com-pliance with 10 CFR 20 can be shown.

9. Reactor Cooling and Purification System The system has been installed and has been in continuous operation for approximately two weeks. Because new water had to be added several times after entries into the reactor well, the conductivity was as high as 40 micromhos/cm. At the time of the inspection, the conductivity was less than 1 micromho, the pH was 6.6, and the water clarity was good. Laboratory measurements of water samples have given good agreement with the console conductivity cells.

No total primary system flow measuring equipment is required or provided, however, manufacturer's information on AP across the heat exchanger indicates that the design value of 80 gpm can be met. The design value for the bypass purification stream is 10 gpm; 7 gpm has been the maximum obtained. The applicant feels the lower flow-presents no difficulty. A twenty micron filter is

. installed in the purification bypass stream, satisfying the SAR requirement.

As described in the application, the secondary coolant pressure is higher than the primary coolant pressure, i.e; 50-60 psi and 10 psi, respectively. According to manufacturer's data, a 23 psi 4

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Results of Visit (Continued) drop on the secondary side is equivalent to 100 gpm, so adequate ,

cooling capacity is available. The applicant stated that a successful byd rotast of the heat exchanger was performed by the manufacturer. Also, the fact that the water quality is at the

. ,, ,4 present values indicates thatthere is no tube leakage. The inspectors inquired as to what hyd ro test pressures were used.

The applicant stated that he would obtain this data and make it available.

The secondary side effluent is run directly to the sewer (50 million gallons per day s'ewage water flow) and no monitoring of the effluent is provided. The inspectors noted that if the secon-dary side of the secondary cooling system were shut down for maintenance, and if the primary system were not shut down, a reverse pressure differential would exist. If there were tube leaks, then reactor water could go directly to the sewer. The applicant stated that appropriate additions would be made to the operations manual, which would require the primary system be turned off, if secondary side maintenance were to be performed.

The inspectors reviewed the system installation, including the console instrumentation and water monitor vessel, and noted' that the installation was in accordance with the application save in the following respects:

a. The water radioactivity monitor has not been installed.

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b. The resistence thermoneter has not been installed,
c. ~The " cooling system on" pilot light is mounted on the wall next to the console rather than in the console as stated in Section D.4. ll of the SAR.
d. No visible alarm is provided for the water radioactivity monitor and this monitor does not share a meter with the reactor water temperature monitor, as stated in Sections D.4. 7. . and D.4.9. of the SAR.

Items a and b will be installed and calibration data will be available at the time-of the final inspection. Items e and d will be reported to DRL with the other changes in the facility to be reported.

The' inspectors noted that the purification system filter and ion exchange column were not shielded. The water radioactivity 134

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Results of Visit (Continued))

monitor is.locatedtnearby, and.the only shielding provided is.

the approximately;6"l of, water in,the water monitor vessel. The inspectors noted that shielding is not_ required by the applica-tion, but stated'their belief the buildup of radioactivity in these units would make the water radioactivity monitor very insensitive to changes in the radioactivity content of the reactor water flowing through the monitor vessel. The applicant stated that .this problem would be evaluated and that radiation surveys would be made of these portions of the system once per week.

10. Reactor Control Instrumentation - -

The reactor control instrumentation has been installed in accordance with the provisions in the application, except for the items noted .in.Section II. A.O.. and . Appendix. A above.

Functional testing by the GA Electronics- Enginees is in progress.

The inspectors-will review .all.- ther test data.;and will request, a demonstration of all alarms, interlocks, and scram signals during the final inspection. ,, , ,

GA is supplying additional instrumentation for startup. These will consist of a scaler to be tied into the startup counter circuit and a reference Keithley microalcro ammeter, to be tied into the linear power circuit. The Keithley will provide meter indication during the startup, and will be used to calibrate the linear power recorder.

M The sensitivity to neutrons of the fission counter and compen-sated chamber for the linear power channel has been checked and calibration of these detectors has. begun. It was learned that the negative voltage for the compensated chambers is fixed by the manufacturer and that the voltage has been set to make the chambers slightly under compensated. The inspectors will review all calibration data prior to reactor startup.

B. Administrative Arrangement

1. Records Facility records were discussed with the applicant, and it was determined that his plans encompassed all record provisions described in the application or required by the proposed license.

At present, only one operations log is contemplated, and all information will be entered into it. Check lists will be appended to the log as executed. The log is presently being establised and all preoperational testing information will be entered.

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Results of Visit- (Con.t,inued) ,

2. Ornanization ,,- , ,

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a. Technical Staff ;,ac;. ,, ,g ,,$., ..

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The applicant stated;that the rea.ctor facility's supporting , ~

technical staff is as described in the application. The Dow Laboratory technicians who.are receiving training for Senior Operator Licenses will be added. The line organization has been established in.accordance with the description in Section F.1 of the application. Dr. Anders, who holds the only license (senior) for the Dow reactor has been appointed reactor super-visor and will be in charge of the startup. An organization chart will be obtained during the next visit.

b. Ooerator Licensing , ,,

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An extensive operator; training pr.ogram under the direction of Dr.3 4nd,e,rs,, has, been in progress. .,The instruction course includes the following:

(1) The TRIGA MARK I. reactor. _ ,

(2) The conso e (3) Administrative procedures (4) Operating procedures

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(5) Radiological safety (6) Reactor physics The organized material for this training program has been up-dated with respect to the various application documents and the proposed license, and has been made into the Operations Manual.

By letter of. June 15, 1967, application was made to DRL for Senior Reactor Operator examinations for the following:

W. H. Beamer D. W. Briden D. H. Clarey i

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Results of Visit (Continued)'

G.LL'. Jewett

.R. E.2, Madison

,,,,4 L. D. Nelson -

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The last three individuals on this list are the Dow technicians mentioned above. The applicant stated he would hope to have the examination conducted during the week of July 24.

c. Reactor Operations Committee The membership of this committee has been established and the first meeting was held June 14, 1967. Committee responsi-

. bilities and rules of procedures were outlined. The committee members are:

u n; .u.. ..ci. m . j: , . .us e u Dr. W. H.- Beamer, Chairman 2 t'

Dr. O. U. Anders, Reactor Supervisor

-Mr. D. W. Briden, Secretary Mr. L. G. Silverstein, Radiological Safety Officer Mr. D. H. Clarey

"""~4 Members are appointed by the laboratory director. The committee intends to meet prior to fuel loading, and review the facility readiness for 'tartup. A positive finding of readiness must be made before fuel loading will be authorized.

The inspectors reviewed the meeting minutes and the section of the operations manual dealing with administrative procedures.

It was found that the committee responsibilities and operation are as described in the application and meet the requirements of the proposed license.

d. Radiation Hazards Committee (RHC)

The inspectors' review of the administrative procedures section of the operations manual showed that the RHC's func-tions and responsibility are as described in the application and as required by the propoaed license. The present committee membership is as follows:

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-Resdits of' Visit (Con tin ~ue'd)

(Dr! BEamer, Chairman I

Drf B'.'B.' Older, Director, Medical Division rig 'Mr. A. W. Wilson, Industrial' Safety Mr. H. R. Hoyle,. Industrial Hygiene Mr. L. R.'S'ilve~rs$e~in, Radiological Safety Officer Mr.'R.'J. Snyder, Health Physicist Mr. D. H. Clarcy, Electrical Engineer This committee met in September 1966, and was given a pre-sentation of the analyses as outlined in the SAR, along with a discussion of the operational safety aspects of the proposed facility. Copies of the proposed license and technical specification have been given tha committee. The committee approved facility operation on the basis of the presentation.

e. Audit of Facility Operation Section I.5 of the proposed technical specification assigns responsibility to the RHC for" compliance of reactor operations and the radiation safety with the conditions of

'"*** the reactor license and the byproducts materials license..."

The inspectors asked if the RHC would make a regular inde-pendent review of. facility operations. The applicant stated that the RHC was primarily a policy making body and would discharge this responsibility through information obtained by reports from the Reactor Operations Committee and others. The applicant stated that independent reviews would effectively be carried out through the radiological safety officer's respon-sibility for periodic evaluation of the health physics practices at the facility and by Dr. Beamer's plans to review the reactor log on a regular basis trd nuiew all irradi-ations and experiments performed.

f. Reactor Suprvisor From discussions with the applicant and review of the operations manual, the inspectors determined that responsi-bilities and authorities assigned the reactor supervisor are in accordance with the descriptions in the application and the requirements of the proposed technical specifications.

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Results of Visit (Continued)

3. Procedures
a. Initial Loading to Criticality The original procedure proposed by GA contemplated unload-ing two fuel shipping casks (19 fuel elements each) into four

. , , , , 10 element fuel storage racks suspended in the reactor pool.

The third cask would be loaded directly into the core and multiplication data taken. The fourth cask also would be loaded directly into the core and appropriate data taken.

Loading thereafter would be from the storage racks to the core. The number of subsequent elements loaded would be less than or equal to half those predicted for criticality. The inspectors observed the three storage racks in the pool and noted that they were spaced at least one foot apart, which effectively decoupled them.

Because of original limitations in the reactor room monorail lifting capacity, GA proposed suspending the casks into the pool via an outside motor crane having access into the building through the roof hatch. This arrangement was rejected because of the possibility of uncontrolled release of radioactivity into the environs through this hatch in the event fuel was damaged during handling. The crane monorail supports were subsequently modified to give a minimum load bearing capability of at least 30,000 pounds. An 8,000 pound chain fall has been obtained and its capacity checked by lifting one of the storage casks. It is also planned to

,;,,, lif t a 9,000 pound weight before fuel loading begins. Two 4,000 pound chain falls will be tied to reactor roof beams and will be used as safety hoists during cask handling.

From data provided by GA regarding the fission product inventory in the irradiated fuel (copy available in Region III files), the inspectors concluded that even in the unlikely event of mechanical damage t- the clad of 38 fuel elements, the radiation release to the reactor room would be less than than resulting from the accidents described in Section 11.4 and H.10 of the SAR. From design and operating experience of other TRIGA cores, it appears impossible that any arrangement of fuel resulting from the dropping of a cask in the pool could result in accidental criticality.

The inspectors were given a demonstration of the operation of the fuel handling tool using a dummy fuel element. It appeared that a reliable and positive grip was obtained.

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. Results of Visit (Continued)

The only outstanding items with respect to the initial loading are details regarding lifting cables and the specifi-cation of the source / detector geometry. The items will be reviewed during the final inspection.

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b. Standard Operating Procedures The inspectors discussed operating procedures with the applicant and reviewed the operating procedures section of the operations manual. The check lists for startup, shut down, control rod installation and removal, and weekly and monthly equipment checks were reviewed. The development of the semi-annual and annual check lists was discussed. It was noted that a GA maintenance manual was available, which includes detailed procedures for normal maintenance activities.

On the basis of the information obtained, the inspectors con-cluded that except for the item discussed below, the standard

. operating procedures appeared to be adequate for the intended functions and to meet the requirements of the Section I.7 of the proposed technical specifications.

The inspectors noted that the startup check list was detailed and comprehensive and there was a check list to be completed when criticality was first reached and again when the reactor was leveled out at a specific power up to and including full power. However, there was no procedure which described the sequencing of control rod movement, minimum

'"**d allowable periods, etc. The reactor supervisor stated that such a procedure would be developed and would be available at the time of the final inspection.

The applicant stated that a system would be developed so that all operational checks, periodic checks, tests and calibrations required by the technical specifications would be performed on schedule. The applicant intends to develop a master schedule to facilitate conformance to these required frequencies.

The applicant inquired as to whether Section D.2 of the proposed technical specification contemplated that a water sample was to be taken weekly or whether the two in-line conductivity cell readings, which are taken each startup, would satisfy this requirement. This question was discussed with Mr. Flood of DRL who stated that weekly readings of the con-ductivity cell would satisfy the requirement and that regular N

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. Results of Visit (Continued)

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calibration of the cell would be required also. This question was discussed with the applicant who stated that the monthly check list required a laboratory sampling of the reactor water and ,tw

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woitid provide v... ivm: sw the calibration.

c. EmergenchPrNdedure's' The inspectors reviEwhd the emergency procedures'section

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of the operations manual and discussed the working of these procedures with the' applicant'. It was determined that the emergency procedure' details', the' evacuation rules and associated emergency equipment installations availability were in accor-dance with the descriptions given in the application. It was noted that trial evacuations are required to'be held quarterly and that the evacuation involved pa'rticipation by all personnel of the radio-chemistry building. The previous trial evacuation was held in April 1967. lThe inspectors observed an evacuation drill on June 21, 1967. 'It'.was noted that all personnel had_

gathe' red"alon[thefence'outside"the'bkildinginaccordan'ce

with the procedure, and that accountability. for^ personnel was

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completed in about two minu'te's after the siren was sounded.

It was also noted that the reactor room ventilation system was shutdown and the reactor room was sealed off in accordance with the description given in the application.

An emergency kit has been provided near the front entrance of the building. The kit contains a Jordan 10 r/hr radiation

, , , , , monitor, protective clothing, and respiratory equipment.

Additional monitoring and dosimetry equipment can be brought from other buildings in the Dow complex as necessary. A map identifying the locations of radioactivity in the building is also provided.

The inspectors inquired into Dow's plans for the handling of contaminated, personnel needing medical attention. It was learned that the Dow hospital is equivalent to a 16 bed hospital and has a hot room set aside for contaminated patients.

Procedures call for obtaining a health physicist for consulta-tion. The applicant stated that he believed it would be possible to perform surgery in this hospital if required, so that no arrangements with local hospitals are necessary.

The inspectors believe that the applicant's preparations for emergencies are adequate.

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. .' Results of Visit (Continued)

d. Health Physics Procedures

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.Disdussiond[werehe,1d,withltheapplicantconcerning.

radiation control at the facility. The radiological safety section of the operations manual was reviewed also. It was noted that the Dow policy concerning responsibility for radi-ation safety requires that the individual working with radiation be responsible for his own monitoring and safety.

" ^ ' '

This individual is given training by the radiological safety officer and is qualified specifically for those kind of radioisotopes or radioactivity involved in his experimental and reactor operation work. Accordingly, the reactor operations personnel will be responsible for monitoring during sample handling and for controlof contamination. They have been trained in the methods and instruments used in accomplishing this control. The radiological safety officer has been appointed responsibility by Dow for making periodic audits of the performance of individuals engaged in radiation work.

No special air sampling, in addition to that done by the continuous air monitor, is planned. The radiological safety officer will assist in identifying the causes of anomalous air sampling readings. The applicant noted that, if the continuous air monitor were to alarm and the cause could not be traced to direct gamma radiation from an exposed sample, the reactor would be shut down and the cause investi-gated.

The inspectors inquired about planned radiation surveys for theinitial ruel loading and rise to power. The applicant stated that shielding surveys and special air samples would

"*"~~ be taken during this phase. A check list would be originated which would specify the gamma, neutron, air and purification system monitoring requirements as a function of power. The radiological safety officer would be active in this program.

and would be requested to make an audit of the radiation safety practice effectiveness at the facility a short time af ter the reactor reached routine full power operation.

The applicant stated that Landauer film badges would be used and would be processed on a routine basis. Self reading dosimr eters will be issued for special jobs. The Landauer badge is a

" disaster" type which includes indium, gold and silver for neutron spectrum measurements and includes glass rods that can measure up to 5000 roentgens dose.

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Based on a review of the documents, disgussions _with the applicant and the applicant's specifig statement.that,the f -

Dow policy on responsibility for. radiation safety has been-demonstrated to work satisfactorily,'the inspectors believe that the health physics. program will be adequate.

4. Effluent Control
a. Gaseous Effluents ,,h ~ .. -

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The control of gaseous effluents is described in Section II.A.6.c. above. It appears that these arrangements will be -

satisfactory. However, the inspectors will review the effect-iveness and operation of this program during -subsequent inspections. . _. .

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b. -Liquid Effluentsoc, . p h ,ms. D. . rm . .%eal u ,

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t. ,, e, . .n It is planned that all radioactive liquid waste from the facility will be turned over to the radiological safety officer for disposal in accordance.with 10 CFR 20 require-ments.
c. Environmental Monitoring No monitoring directly related to the nuclear. reactor facility is planned. Dow has done environmental monitor-
    • ""* ing related to world-wide fall out.
5. Control of Experiments Discussions with the applicant and review of the administra-tive procedures indicated that all experiments to be set up at the reactor will be proposed in writing and approved by the reactor supervisor and/or. Reactor Operations Committee as defined in the Technical Specifications. Each run experiment which involves (a) fissionable material, (b) a change in core configuration, and (c) a type not previously approved will require approval by the Reactor Operations Committee.

The applicant stated that current reactor operation planning did not extend beyond small sample irradiation for byproduct material production and activation analysis work.

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- - 21 -

Results of Visit (Continued) it- t ..; i . o i _ nce .

" "C . ' Exit Interview An exit interview was sheld with .Dr., Beamer, Dr.~ Anders ,- and Mr.

  • Clarey. . .' u . i.y 12 n'- ,

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The inspe'ctors, outlined:the general results of their inspection review. The items which.. required . resolution prior to startup, in

  • the opinion of the inspectors, wre discussed with the above persons during the exit interview and later by phone.

In the case of the deviations from the proposed license, the applicant has already notified DRL in writing. In the case of the deviations from the application, the-licensee assured the inspectors that DRL would be notified in writing.

The inspectors emphasized the,importance of a careful review of all aspects of core loading and fuel cask handling with all personnel involved prior to startup.

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Attachnents:

1. Appendices A and B -
2. Figures 1 and 2 ,

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APPENDIX A i.

Deviations from descriptions of equipment installation given in the Safety Analysis Report (SAR) . (Information in parenthesis identify pertinent sections of the SAR.)

1. Concrete shield:3'2" thick on~ sides and 3'6" thick on bottom rather than l' and 2' thick respectively. (E.2) 2.. Reactor- room ventilation exhaust flow 1750 cfm and intake flow 1500

- cfm,' rathern than 500 cfm and 450 cfm, respectively. (Figure E.1.2) mananas

3. Manually operated louvres installed as backup to the automatic lou-vres in ventilation intake and exhaust ducts. (E.6)
4. Reactor room area monitor placed on east wall rather than on con-trol rod drive platform. (D.4.10 and E.7)
5. Control rod poison section lengths are 19" rather than the ~20" y stated. (D.2.6)
6. " Cooling system on" pilot light mounted on wall next-to console rather than on console. (D.4.11)
7. No visibic alarm installed for water radioactivity monitor and no meter sharing with reactor water temperature. (D.4.7)
8. Reactor water temperature monitor does not share meter with-the radioactivity monitor. (D.4.9)

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  • APPENDIX B Items requiring resolution during final inspection.
1. Review source / detector geometry to be used during initial fuel loading.

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2. Review additions to routine startup procedure.
3. Review manufacturer's data for control rod leak tests and review as-built dimensions.
4. Observe demonstration of all alarms, interlocks and scram inputs for proper operation.
5. Evaluate functional testing and/or checkoat and calibration data for:
a. Portable radiation monitors, b.--Reactor water radioactivity monitor,
c. Reactor-water temperature detector, d.. Area radiation monitor,
e. Continuous air particulate monitor and alarm settings.
f. Control rod drop -times, drive speed, and operation of limit switches.
g. . Ventilation system inlet and outlet dampers.
h. ~ Neutron detectors.
i. Rabbit system.

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.j. Rotary specimen _ irradiation rack.

6. Review additions to radiation survey program for reactor startup.
7. Review final details of initial fuel loading program.

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