IR 05000264/1999201

Insp Rept 50-264/99-201 on 990712-15.No Violations Noted. Major Areas Inspected:Operations Program,Organizational Structure & Functions Program,Design Control Program,Review & Audit Program & Radiation Protection Program

ML20210Q008
Person / Time
Site:	Dow Chemical Company
Issue date:	08/10/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20210P991	List: IR 05000264/1999201 ML20210P988
References
50-264-99-201, NUDOCS 9908130124
Download: ML20210Q008 (16)

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U. S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-264 License No: R-108 Report No: 50-264/99-201 Licensee: Dow Chemical Company Facilit Dow TRIGA Research Reactor

' Location: Midland, Michigan Date July 12-15,1999 Inspector Thomas Burdick Approved by- Ledyard B Marsh. Chief Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation 9908130124 PDR ADOCK 05000264 990810 0 pm ,

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• 4 ,l EXECUTIVE SUMMARY

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This routine, announced inspection included onsite review of selected aspects of the operations program, organizational structure and functions program, design control program, review and ;

audit program. radiation protection program, environmental protection program, operator requalification program, maintenance program, surveillance program, fuel handling program, experimental program, procedural control program, emergency preparedness program, material control program. security program, and transportation program since the last NRC inspection of these program The licensee's programs were acceptably directed toward the protection of public health and safety, and in compliance with NRC requirement ORGANIZATIONAL STRUCTURE AND FUNCTIONS Some position titles changed without any function changes. One new individual was hired to fill l a vacated positio j OPERATIONS Routine operations continued with occasional minor interruption DESIGN CONTROL i

An NRC approved change was made to remove the short period scra REVIEW AND AUDIT The licensee conducted all required reviews and audits RADIATION PROTECTION Employee doses were minimal ENVIRONMENTAL PROTECTION Environmental impact from reactor operation was insignifican OPERATOR REQUALIFICATION The licensee met all requirements for operator trainin MAINTENANCE The facility was maintained in good operating and materiel conditio ,

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SURVEILLANCE Reviewed surveillances were usually conducted as require FUEL HANDLING Routine fuel inspections were done according to procedure EXPERIMENTS The licensee conducted a large number of routine neutron activation irradiations without inciden PROCEDURES Reviewed procedures were clear and generally cunen EMERGENCY PREPAREDNESS Drills and training were conducted as require MATERIAL CONTROL Inventones of special nuclear materials were completed as require SECURITY The licensee's program requirements were normally me TRANSPORTATION The licensee nad not transported any materials since the last inspectio I

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l REPORT DETAILS

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i l Summary of Plant Status ,

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l During the inspection the reactor was operated several days a week to support experiment !

operator training, and surveillanc ;

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l ORGANIZATIONAL STRUCTURE AND FUNCTIONS i l ,

Scooe (69001)

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The inspector reviewed selected aspects of'

e organization and staffing e qualifications e management responsibilities e administrative controls Observations and Findinas The Dow reactor organizational structure and staffing had some minor title changes which did not affect individual functions. One person was recruited to fill a vacated position. The organizational structure and staffing at the facility and as reported in the Annual Report was as required by Technical Specification. Qualifications of the staff

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met Technical Specification requirements Review of records verified that management responsibilities were administered as required by Technical Specifications and applicable procedure c Conclusions The organizational structure and functions were consistent with Technical Specification requirement .0 OPERATIONS Scope (69001)

The inspector reviewed selected aspects of:

e operational logs and records staffing for operations l-e selected operational, startup, or shutdown activities Observations and Findinas The operating logs and records were clear and provided an indication of operational activities. This included documentation of events, and resolution or tracking of event l l

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The inspector noted log entries regarding rod interlock actuations on short periods The licensee stated that they had experienced a few since the short period scram had been removed. They believe the cause was operator error. Reactor scrams had been reduced since the last inspectio The logs and records indicated that shift staffing including on-call personnel was as l required by Technical Specifications. Logs and records also showed that operational conditions and parameters were consistent with license and Technical Specification requirements. Observation of operational activities further confirmed that these conditions and requirements were satisfie .c . ' Conclusions The operations program satisfied Technical Specification requirement .0 DESIGN CONTROL a .. Scoce (69001)-

The inspector reviewed selected aspects'o e facility design changes and records e facility configuration b Observations and Findinas Records and observations showed that changes at the facility were acceptably reviewed in accordance with 10 CFR 50.59 and applicable licensee administrative controls. The inspector verified that the short period scram removal that required a change to the Technical Specifications was reviewed and approved by the NRC prior to implementatio The licensee had concluded that the digital console was not vulnerable to the Year 2000 computer problem. They are, however, pursuing an upgraded hardware and software package offered by the vendor that they hope will reduce the number of inadvertent scrams caused by the original syste c Conclusions The design change program satisfied NRC requirement l l

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40 REVIEW AND AUDIT Scoce (69001)

The inspector reviewed selected aspects of:

e safety review records

e audit records e responses to safety reviews and audits e review and audit personnel qualifications

. Obsenfations and Findinas j Records showed that the safety reviews were conducted at the Technical Specification required frequency. Topics of these reviews were consistent with Technical

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Specification requirements. The reviews provide guidance, direction, and oversight. and l ensure acceptable use of the reacto '

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The audit records showed that audits had been completed in those areas outlined in the !

Technical Specifications and at the required fre'quenc l The inspector noted that the safety reviews and audits and the associated findings were acceptably detailed and that the licensee responded and took corrective actions as neede I The safety review and audit personnel qualifications satisfied Technical Specification requirements and licensee administrative controls. Further, the number of personnel J involved in the safety reviews and audits also satisfied Technical Specification and licensee procedural requirement ]

! Conclusions The review and audit program satisfied Technical Specification requirements j 50 RADIATION PROTECTION a Scope (69001)

The inspector reviewed selected aspects of; j l

e the Radiation Protection Program e radiological signs and posting a e routine surveys and monitonng e l dosimetry records '

e maintenance and calibration of radiation monitoring equipment e As Low As Reasonably Achievable (ALARA) reviews

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, Observations and F.ndinas' i The radiatior, protection program had not changed since the last inspection. The l

- licensee reviewed the radiation protection program at least annually in accordance with 10 CFR 20.1101(c). The review included all areas and no weaknesses were reporte The licensee showed that the air emissions of radioactive material to the environment met the 10 millirem constraint specified in 10 CFR 20.1101(d).

' NRC Form 3, " Notice to Employees," was posted in accordance with 10 CFR 19.1 Caution signs, postings and controls for radiation areas were as required in 10 CFR 2 Subpart J. Licensee personnel observed the indicated precautions for access to radiation areas Use of dosimeters and exit frisking practices were in accordance with radiation ,

protection requirements. The licensee used a National Voluntary Laboratory l Accreditation Program (NVLAP)-accredited vendor to process dosimetry. Radiologicai l exposure records showed that occupational doses and doses to the public were within 10 CFR Part 20 limitations. Training records showed that personnel were acceptably trained in radiation protection practice I Radiation monitoring and survey activities were as required. Equipment used for these

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activities were normally maintained calibrated and used acceptably. The inspector noted that one instrument used during the inspection had intermittent operating problems and another instrument was a few days overdue for calibration. The licensee corrected these problems within one da ;

ALARA reviews were acceptably performed as require The licensee did not require implementation of their respiratory protection program nor a planned special exposure progra c Conclusions -

The radiation protection program satisfied NRC requirement .0 ENVIRONMENTAL PROTECTION Scope (69001)

The inspector reviewed selected aspects o e the environmental monitoring program-e annual reports l e release records e counting and analysis program

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1 Observations and Findinas j

1 Laboratory equipment was maintained and calibrated acceptably. Data indicated that i there was no measurable dose above background. This was acceptably documented in I the Annual Reports. Observation of the facility found no new potential release path .

l The program for the monitoring and storage of radioactive liquid, gases and solids was consistent with applicable regulatory requirements. Radioactive material was monitored and released when below acceptable limits or was acceptably transferred to the broad- l scope license for disposition. The principles of As Low As Reasonably Achievable were acceptably implemented to minimize radioactive releases. Monitoring equipment was l acceptably maintained and calibrated. Records were current and acceptably maintaine l Conclusions '

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The environmental protection program satisfied NRC requirement .0 OPERATOR REQUAllFICATION a Scoce (69001)

The inspector reviewed selected aspects o e the Requalification Program e operator licenses e operator training records e- operator physical examination records e operator examination records e operator active duty status b Observations and Findinas The Requalification Program was kept up-to-date. Operator licenses were also curren Records showed that operator training was consistent with the Requalification Program requirements. Physical examinations of the operators were conducted as require Records showed that written examinations of the operators were acceptably implemented. Logs showed that operators maintained active duty status as require c Conclusions Operator requalification was conducted as required by the Requalification Progra w

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8.0' MAINTENANCE Scooe (69001)

The inspector reviewed selected aspects of:

o maintenance procedures e - equipment mairitenance records Observations and Findinas Logs. indicated that corrective maintenance activities and problems were addressed as l required by procedure. Records showed that routine maintenance activities were

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conducted at the required frequency and in accordance with the Technical l Specifications, applicable procedure or equipment manual. Maintenance activities ensured that equipment remained consistent with the Safety Analysis Report and Technical Specification requirements. Furtheri maintenance activities were consistent '

with the requirements of 10 CFR 50.5 Conclusions  !

The maintenance program satisfied NRC requirement :90 ' SURVEILLt.NCE a . Scope (69001)

The inspector reviewed selected aspects of:

e surveillance and calibration procedures e surveillance. calibration and test data sheets and records

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b .. ' Qbservations and Findinas  !

Surveillance. test and limiting conditions for operation (LCO) verifications and i calibrations were almost always completed on schedule and in accordance with licensee 1 procedure The licensee had identified two cases in the'last year where monthly surveillances were not L mpleted within the required six week interval. The licensee adopted a more structured scheduling and personnel assignment system making the monthly tasks more !

visible.' The inspector reviewed the overdue surveillance and verified that it had been I completed by the licensee and was not found out of-tolerance. The corrective action l should minimize recurrence of the oversight. This non-repetitive and licensee-identified

' violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the i I

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All the recorded results were within the TS and procedurally prescribed parameters The records and logs reviewed were complete and were being maintained as required Checks, tests. and calibrations were completed as required by T c Conclusions j i

The surveillance program satisfied Technical Specification requirement l 10.0 FUEL HANDLING Scoce (69001) l The inspector reviewed selected aspects of:

e fuel-handling procedures e fuel handling equipment and instrumentation e fuel handling and examination records Observations and Findinos Fuel-handling procedures provided a prescribed method to move and handle fuel consistent with the provision of the Technical Specifications and the licensee's safety analyses. Fuel movement and fuel examination records showed that the fuel was moved and examined as required. Records also show that fuel-handling and monitoring equipment and instrumentation was venfied operable prior to use. Personnel were knowledgeable of the procedural and equipment requirements for criticality control and assurance of fuelintegrity. Radiological and security precautions were also met in accordance with applicable procedure c Conclusions The fuel handling program satisfied licensee Technical Specification and procedural requirement .0 EXPERIMENTS Scope (69001)

The inspector reviewed selected aspects o e experimental program requirements e procedures e logs and records e experimental administrative controls and precautions

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t Observations and Findinos The experiments at the facility were routine procedures that had been in place for several years. No new or unknown-type experiments had been initiated. reviewed, or

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approved since the last inspection. The experiments were completed with the cognizance of the Reactor Supervisor and a Senior Reactor Operator and in accordance with Technical Specification requirements (e.g., reactivity limitations). The results of the experiments were documented in appropriate experimental logs, data sheets, or records. Engineering and radiation protection controls were implemented as required to limit exposure to radiatio The inspector noted that the licerises had operating problems with the pneumatic tube

. sample transfer system. Occasit .y

the blower tripped on thermal overload protection and more frequently, the samples became caught on the inlet of a "Y'. fitting in the sample line just above the laboratory sample station. The samples are generally not

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highly radioactive and no significant Argon 41 is generated. The failures caused irradiated materials to lodge in the pneumatic line and required dismantlement of the sample tubing to dislodge them. Although personnel doses have been low, the effort to dislodge samples may lead to more dose than is necessary and is inconsistent with ALARA. The licensee acknowledged the observatio Conclusions The program for experiments satisfied Technical Specification and procedural requirements 12 0 PROCEDURES a.- Scope (690011 The inspector reviewed selected aspects of:

e administrative controls e records for changes and temporary changes e proceduralimplementation e logs and records b. - Observations and Findinas

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Adrr istrative controls of changes and temporary changes to procedures, and associated review and approval processes were as required. Training of personnel on procedures and changes was acceptable. Personnel conducted activities in accordance with applicable procedures. Records showed that procedures for potential malfunctions (e.g., radioactive releases and contaminations, and reactor equipment problems) were implemented as required.

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4 The inspector noted that the continuous air monitor procedure had not been updated to account for an increase in the background count level caused by the exhaust emissions of a nearby gas turbine generating plant. This occurs when the wind comes from the direction of the power plant. The licensee acknowledged the oversigh Conclusions The procedural control and implementation program satisfied Technical Specification :

requirement .0 EMERGENCY PREPAREDNESS Scoce (69001) 4 The inspector reviewed selected aspects o e the Emergency Plan e implementing procedures e emergency response facilities, supplies, equipment and instrumentation e training records e offsite support e emergency drills and exercises b Observations and Findinos The Emergency Plan (E-Plan) in use at the reactor was the version most recently approved by the NRC. The E Plan was audited and reviewed as require Implementing procedures were reviewed and revised as needed to employ the E Plan effectuely Facilities. supplies. instrumentation and equipment were being maintaine controlled and inventoried as required in the E-Plan. Through records review and interviews with licensee personnel, emergency responders were determined to be knowiedgeable of the proper actions to take in case of an emergency. Agreements with outside response organizations had been updated and maintained as necessar Communications capabilities were acceptable with these support groups and had been tested as stipulated in the E Plan. Emergency drills had been conducted as required by the E-Plan. Off-site support organization participation was also as required by the E-Plan. Cntiques were held following the drills to discuss the strengths and weaknesses identified during the exercise and to develop possible solutions to any problems identified. The results of these critiques were documented and filed. Emergency preparedness and response training was being completed as required. Training for off-site and reactor staff personnel was conducted and documented as stipulated by the E-Pla Conclusions The emergency preparedness program was conducted in accordance with the Emergency Pla n ,

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1 MATERIAL CONTROLS Scorse (85102)

The inspector reviewed selected aspects of; e' nuclear material inventory and locations e accountability records : Observations and Findinos The inventory of material was verified. The material control and accountability program tracked locations and content of fuel and fission detectors under the research reactor license. The possession and use of special nuclear material (SNM) was limited to the locations and purposes authorized under the license. The material control and accountability forms (DOE /NRC Forms 741 and 742) were prepared and transmitted as require i Conclusions Special Nuclear Materials were acceptably controlled and inventorie !

1 SECURITY a Scope (81401/81431)

The inspector reviewed selected aspects of:

e the Physical Protection Plan

.e security systems. equipment and instrumentation e implementation of the Physical Protection Plan , Observations and Findinos

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The Physical Protection Plan in use was the latest revision approved by the NR Physical protection systems (barriers and alarms), equipment and instrumentation were as required by the Physical Protection Plan. Access control was as require In the early morning hours of June 23,1999, the licensee was alerted by Dow security about a failure of the telecommunications system that supports the reactor security system. The_ facility was not in operation and Dow security officers _ made additional rounds of the reactor facility until the problem was corrected a few hours later. No

' compensatory actions were required. This non-repetitive and licensee-identified violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforce., 2nt Policy.

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Implementing procedures were consistent with the Physical Protection Plan. Acceptable .

. security response and training was demonstrated through alarm response and drill response in accordance with procedure i

! Conclusions l Security activities and systems satisfied Physical Protection Plan requirement .0 TRANSPORTATION a Scoce (86740j The inspector reviewed selected aspects of:

o radioactive materials shipping procedures e radioactive materials transportation and transfer records b Observations and Findinos The Dow TRIGA reactor facility has not shipped any radioactive materials since the last inspection c Conclusions Dow has not shipped radioactive materia ls since the last inspection

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l Partial List of Persons Contacted

l W. Rigot Reactor Director DOW TRIGA 1 J. Grappin Radiation Safety Officer, DOW Chemical l The inspector also contacted other supervisory, technical and administrative staff personnel as wel Inspection Procedures Used l

IP 69001 Class 11 Non-Power Reactors IP 81401 Plans, Procedures, and Reviews IP 81431 Fixed Site Physical Protection of LSNM IP 85102 Material Control and Accounting IP 86740 Transportation of Radioactive Materials Items ODened and Closed )

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Closed l None List of Documents Reviewed Administrative Procedures Dosimetry Records Emergency Procedures Emergency Plan Maintenance and Surveillance Records Maintenance Procedures Operating Procedures and Records Reactor Operating License Safety Evaluation Report Safety Analysis Report Surveillance Procedures Technical Specifications Training Records Training Procram Various Rep ,rts l

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List of Acronyms Used

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ALARA As Low as Reasonably Achievable DOE Department of Energy LCO Limiting Conditions for Operation NRC Nuclear Regulatory Commission SAR Safety Analysis Report SNM Special Nuclear Material TS Technical Specifications l

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