ML20137G600

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Responds to NRC Re Violations Noted in Insp of License R-108 on 730920 & 21.Corrective Actions:Installation of Flux Controller Approved & Startup Procedure Reviewed & Modified on 711029
ML20137G600
Person / Time
Site: Dow Chemical Company, 05000000
Issue date: 11/09/1973
From: Hoyle H
DOW CHEMICAL CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20136D183 List: ... further results
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 NUDOCS 8508270347
Download: ML20137G600 (3)
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b. c c w 46gh DOW CHEMICAL U.S.A.

MIDLAND, MICHIGAN 48640 November 9, 1973 Mr. James G. Keppler Directorate of Regulatory Operations, Region III U. S. Atomic Energy Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Ocar Mr. Keppler:

This tetter is in reply to your report on the inspection of our Dow TRIGA reactor facilittj carried out by Messrs Fishbaugher and Brown of jt our of fice on September 20 and 21, 1973.

The Dow TRIGA reactor has been operated under License Number R-108, Docket Number 50-264, since 1967 at the Midland location of The Dow Chemical Compant) .

Item B consisted of "a change to an operating procedure which was inserted into the Operating Log for use on Jutt) 23, 1971, without formal review and approvat by the (Reactor Operations) Committee."

The incident occurred on July 23, 1971, during a major updating project for the safett) and control instrumentation of the reactor. The plans for such updating had been discussed by the Reactor Operations Committee at meetings earlier in 1971, and detailed information on these plans and the instrumentation involved, as well as an evaluation of the impact of the proposed modernization upon the technical specifications of our facility were communicated via our Radiation Saf ett) Committee to the AEC's Division of Licensing. The AEC informed us that the proposed changes were within our technical specifications and re-quired no special action by the Commission.

Three individuals involved with the instattation were also members of the five member Reactor Operations

committee and were thus intimately familiar with the i changes that had been effected bij the instattation of l

8508270347 850712 w PDR FOIA N f/0V KOHN85-256 PDR I 2 9 1973 -

l AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY k

>. . 3 ~ c c Mr. Keppler 2 November 9, 1973 the new equipment. The note placed into the~ reactor tog book on July 23, 1971, consisted of a description of the

. changes ef fected and the concomitant changes of procedure necessitated b] the absence of the old equipment and presence of new equipment having dif f erent controi switches.

This note constituted an instruction for the five reactor operators who att were intimately familiar with the instattation of the new equipment. A documented meeting of the three Reactor Operations Committee members present to approve the changes could have prevented the technscal violation.

Even after Jutt) 23, the installation had not been completed s atis f actorittj, as various " bugs" in the new circuitry had to be identified and cleared up. Onttj after a representative of the vendor had checked out the equipment with us during the second week of August, 1971, was the instattation completed and the changes of ficially discussed at the meeting of the Reactor Operations committee on August 18, 1971.

The corrective steps taken were:-

The instattation o'f'the then new'" Flux Contratter" (which necessitated the change to the operating procedures), was discussed bjt the Reactor Operations Committee on August 18, 1971, and the steps taken in connection with it were approved by the Committee.

The Reactor Operations Committee took up a review of the startup procedure during its session of October 29, 1971, after the dif ficulties with the flux controtter had been overcome with the help of a representative of the vendor.

The Committee further modified the procedure at that time and approved it.

Corrective steps which will be taken to avoid further violations:

An annual requalification program for operators of the facilittj was instituted in 1973. A review of Operating Procedures and Administrative Requirements has been incorporated to refamiliarize the staf f with the proper procedures to be followed for any change of operating procedures to become effective.

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Mr. Keppler 5 November 9, 1973

, review of'att exi}tinYoperat.ing pro edures will be carried out.by .the Reactor.0perat. ions Committke on an gnnual . basis and ' tite:kaiit.ts recorded ih:thk;m'inutes a f ,the Reactok^ Operations ; Committee.

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l The date when fatt,compL.iance will be achicUed:

., ,1 . , ,.

The violation occurred on July 25, 1971. Futt

>, compliance was achieved on August 18, 1971. The proper procedure for an addi.tional change .to the operating procedures was followed by.the. Reactor Operations Conmittee on October 29, 1971.,

of ant subsequent violation nor.Since hasfullone we beenare not identified aware by the) inspectors, we believe .that compliance was achieved at that time.

Vert) truttj yours, ksY - ~

H. R. o jt t , C tar %m'an '

Radiation Safettj Commi.ttee 01G Chemical Biologij Research 1707 Building sjt cc: Members of .the Radia. tion Saf et)t Commit. tee

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