IR 05000020/1991001
| ML18037A076 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor, 07000938 |
| Issue date: | 02/26/1991 |
| From: | Austin M, Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18037A074 | List: |
| References | |
| 50-020-91-01, 50-20-91-1, 70-0938-91-01, 70-938-91-1, NUDOCS 9103150456 | |
| Download: ML18037A076 (16) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-20/91-01 and 70-938/91-01 Docket Nos.
50-20 and 70-938 License Nos.
R-37 and SNM-986 Licensee:
Massachusetts Institute of Technolo 138 Alban Street and 77 Massachusetts Avenue Cambrid e
Massachusetts 02139 Facility Name:
MIT Research Reactor and Massachusetts Institute of Technolo Cam us Inspection At:
Cambrid e
Massachusetts Inspection Conducted:
Januar 14-17 1991 i 'i Inspector:
M. A. Austin, Radiation Specialist, Effluents Radiation Protection Section (ERPS),
Facilities Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Safety and feguards (DRSS)
date Approved by:
R. J.
res, Chief, Effluents Radiation Protection Section, FRSSB, DRSS 4A ~ ~p(
date Ins ection Summar:
Ins ection on Januar 14-17 1991 Re ort Nos.
50-20/91-01 and 70-938/91-01 Areas Ins ected:
Routine, unannounced inspection of licensed activities including: organization, management controls, radiological controls, transportation, and follow-up on. previously identified enforcement items.
Results:
Two apparent violations were identified relative to NRC License SNM-986: licensee did not perform or properly document quarterly inspections of radiation safety activities (paragraph 5.2)
and licensee did not perform or document annual refresher training for health physics technicians (paragraph 6.2).
Relative to NRC License R-37, a continuing violation was identified pertaining to characterization of radwaste for burial (paragraphs 2.0 and 7.2).
910315045b 91022b PDR ADOCK 05000020 O
DETAILS 1.0 Individuals Contacted
"J. Bernard, Director, Reactor Operations
- A. Ducatman, Director, Environmental Medical Service M. Galanek, Associate Campus Radiation Protection Officer
- 0. Harling, Director, Nuclear Reactor Laboratory
- K. Kwok, Superintendent, Reactor Operations
"F. Masse',
Campus Radiation Protection Officer
- F. McWilliams, Reactor Radiation Protection Officer
- Denotes those present at the exit interview.
The inspector also
'interviewed other licensee employees during the inspection.
"Dr. R. Bores, Chief of the Effluents Radiation Protection Section, NRC Region I accompanied on a portion of the inspection and attended the exit interview.
2.0 Licensee Action on Previousl Identified Items (Open) Inspector Followup Item (50-20/90-01-01)
Lack of written implementing procedures for radiological controls program.
The inspector reviewed a draft plan prepared by the Reactor Radiation Protection Officer (RRPO) that described the procedures that would be written.
A number of the procedures were drafted, but none had yet been implemented.
The RRPO stated that draft versions of all procedures would be completed by March 1991, and formal review of the procedures by the Reactor Safeguards Committee was expected by July 1991.
Based upon the current status of the licensee's actions, this item was kept open.
(Closed) Violation (938/87-01-01)
Failure to obtain NRC authorization to possess uranium-233 located on site
~
The inspector reviewed the licensee's request in a letter, dated November 4, 1987, and the NRC approval in a letter, dated December 2, 1987, to authorize the possession of 2.0 milligrams of U-233 at the licensee's facilities.
Therefore, this violation was. closed.
(Closed) Violation (938/87-01-02; 763/87-01-01)
Failure to post signs and label containers in compliance with 10 CFR 20.203.
The inspector observed that a holder containing a 10-curie strontium-90 source, which was observed during a previous inspection in a container without the proper label at the Lincoln Laboratory, was now stored in the Central Radioisotope Storage Facility and had been provided with the required "Caution - Radioactive Material" labe The inspector also observed that a 4.5 millicurie cobalt-60 source, which had been previously stored in a cabinet without proper posting in the Lincoln Laboratory, had been moved into the Central Radioisotope Storage Facility, which is properly posted.
Finally, the inspector observed that the entrance to the BTF Vault was properly posted with a "Caution High Radiation Area" sign.
The above mentioned items were the bases for this previous violation, and based upon the inspector's observations during the current inspection, this violation was closed.
3.0 (Open) Violation (938/87-01-03; 763/87-01-02)
Failure to provide all information required by 10 CFR 20.311(b).
Based upon discussions with the Reactor Radiation Protection Officer and other licensee representatives and a review of licensee records for a radioactive waste shipment made in December 1990, the inspector determined that the licensee had not yet completed the analysis of all radioactive waste streams.
Certain waste streams (e.g.,
some reactor spent resins) still required specific, additional further analyses (i.e., with radiochemical separation)
to properly characterize their specific radioisotopic content.
Until these analyses are completed, the licensee stated that shipments of only those waste streams that have been properly analyzed will be made.
Based upon the current status of the licensee's actions, this violation remains open.
(See Paragraph 7.2 for further details.)
(Since this violation pertains more to the reactor than to the SNM Licenses, the above items are administratively closed and a
new item (50-20/91-01-01) is opened.)
Or anization The facility management organization of the Massachusetts Institute of Technology Research Reactor (MITR) was as described in Technical Specification (TS) Figures 7.1.1 and 7.2.1 of NRC License No. R-37.
The facility management in the Building 20 Campus Radiation Protection Office in support of the NRC Special Nuclear Materials License No.
SNM-986 had not changed since the last inspections Based upon interviews with licensee representatives, the inspector determined that the Campus Radiation Pro-tection Officer in Building 20 met the minimum technical qualifications for the position as required by Condition No.
12 of the NRC License No.
SNM-986; the Director of Reactor Operations met the minimum qualifications for the Criticality Officer as required by Condition No.
17 of SNM-986; and the MIT professor who was a member of the Reactor Safeguards Committee and served as backup to the Criticality Officer met the minimum qualifi-cations for that position as required by Condition No.
18 of SNM-986, Based upon interviews with licensee management, the inspector determined that the radiation safety program for the reactor operations authorized by NRC License No. R-37 was the primary responsibility of the Reactor
Radiation Protection Officer (RRPO),
and the radiation safety program for the byproduct materials operations authorized by NRC License No.
20-01537-02 was the primary responsibility of the Campus Radiation Protection Officer (CRPO).
However, the radiation safety program in support of licensed activities authorized by NRC License No.
SNM-986 was apparently a
responsibility shared by both the RRPO and the CRPO.
Based upon certain findings in the current inspection (Sections 5.2 and 6.2), the inspector observed a lack of coordination between the,CRPO and RRPO to establish programs to address the radiation safety-related requirements of SNM-986
'he action taken by licensee management to ensure effective oversight and compliance with all SNM-986 requirements will be reviewed in a future inspection (Inspection Fol lowup Item 70-938/91-01-01).
4.0
'~F 4. 1 Central Radioisoto e Stora e Faci lit The inspector toured the Central Radioisotope Storage Facility (CRSF)
with the Associate CRPO.
The inspector examined a number of sources stored in the CRSF vault, some of which were related to items identified in a previous NRC inspection (See Paragraph 2.0).
Ap-propriate storage, posting and labelling were noted.'o violations or deficiencies were identified in this area.
The inspector toured the reactor facility with the Superintendent of Reactor Operations and the RRPO.
The inspector examined a locked safe used for the storage of reactor fuel in the Reactor Fuel Vault, which had been relocated within the containment of the Reactor Restricted Area.
The inspector examined the Blanket Test Facility (BTF) Vault and observed a container partially surrounded with movable lead shielding.
The RRPO stated that this container held radioactive wastes/components that were being stored for decay of the shorter-lived radioisotopes before packaging for shipment.
The inspector used a
licensee's portable instrument to perform a cursory radiation survey of the container.
Based upon measured dose rates near accessible portions of this container, the inspector determined that the "Caution High Radiation Area" sign on the door to the BTF Vault was still required.
The inspector observed that the housekeeping in the Waste Storage Area was improved since the last inspection and access to this area was now controlled with a locked gate.
The RRPO stated that the previously observed backlog of waste from the reactor facility had been reduced by a shipment of 26 drums in December 199 e During the examination of the Engineering Laboratory located in Room NW-12-139, the inspector observed that the ventilation system stack air sampling point was located in a turbulent region of the ductwork at an intersection of two ducts.
The inspector also observed that the sampling train that led from the sampling point in the duct to the collection point on a filter paper was comprised of a combination of rubber tubing and copper piping.
The inspector discussed with the licensee the representativeness of the stack measurements taken at that duct location and utilizing the above mentioned sample conduit materials.
More suitable materials were discussed which could be used to minimize the plateout of fission products before collection on the filter paper.
Alternate sampling points for collecting the stack sample were also discussed.
The RRPO stated that the single sampling point would be replaced with two sample probes, one after each of the two filter banks that service the three exhaust hoods and one glovebox in this area.
Actions taken by the licensee to upgrade this sampling system will be reviewed in the next inspection.
(Inspector Followup Item 50-20/91-01-02).
5.0 Mana During the tour of the reactor facility, the inspector held discussions with the RRPO regarding emergency preparedness and examined the contents of emergency equipment cabinets located inside and outside of the reactor restricted area.
During these discussions, some technical questions were raised by the inspector regarding calibration of emergency instruments, use of emergency respiratory protection equipment, and the training of security response personnel.
The functional area of emergency preparedness will be reviewed in more detail during the next inspection.
(Inspector Followup Item 50-20/91-01-03).
ement Controls 5.1 Procedures Review The inspector reviewed meeting minutes of the Radiation Protection Committee (RPC) to determine how the licensee prepares, reviews and approves operating procedures involving work with licensed material, as required by Condition No.'3 of NRC License No.
The inspector determined that the prospective user of a licensed material is required to describe the proposed use, quantity of material and location of the operation, using an application Form ¹RP-Ol.
This application is then submitted to the Campus Radiation Protection Office for technical review and administrative approval.
Following approval, the application and attachments become the authorized procedure.
This procedure then receives final review and formal approval by the RPC at their next-scheduled meeting.
The inspector examined RPC meeting minutes, dated July 11, 1989, which included the review and formal approval of Procedure
¹PFC-C-1 that had been administratively approved by the Associate CRPO on May 16, 1989.
Procedure
¹PFC-C-1 involved the use of a one-curie plutonium-beryllium source for testing some neutron shielding and calibrating a neutron detector.
No violations or deficiencies were identifie.2 Audits and Ins ections The inspector requested the licensee to provide the written procedure and other documentation related to the quarterly inspections of radiation safety activities at all work areas, as required by Condition No.
of NRC License No.
Condition No.
14 requires that these quarterly inspections be conducted in accordance with a written procedure, and that the findings of the inspection with needed corrective actions be transmitted in a timely fashion to the supervisor of the inspected area as well as the Radiation Protection Committee or the Reactor Safeguards Committee as appropriately Based upon interviews with the RRPO, CRPO and Associate CRPO, the inspector determined that there was no written procedure that described the conduct of these inspections; these inspections were not being routinely conducted on a quarterly frequency; and there was no evidence that the findings of any such inspections were being transmitted to the RPC or Reactor Safeguards Committee.
Failure to perform and document these inspections and have a related procedure is a violation of Condition No.
14 of NRC License No.
(Violation 70-938/91-01-02).
6.0 Radiolo ical Controls 6.1 6.2 Instrument Calibration The licensee has two calibration facilities for radiation detection instruments, one that is primarily used by the Campus Radiation Protection Office and another that is primarily used by the Reactor Radiation Protection Office.
The inspector was accompanied by the Associate CRPO and by the RRPO during tours of their respective cali-bration facilities.
During these tours, the inspector raised various technical questions regarding the adequacy of their calibration methods.
Both the RRPO and the Associate CRPO acknowledged that certain technical improvements were warranted and that the calibration activities would be reviewed and appropriate improvements would be made.
Action taken by the licensee to upgrade the technical adequacy of the calibration methods used at both facilities will be monitored in future inspections.
(Inspector Fol 1 owup Item 50-20/91-01-04; 70-938/91-01-03)
.
Health Ph sics Technician Trainin The inspector requested the licensee to provide the records that documented the annual refresher trai'ning for health physics (HP)
technicians, as required by Condition 15 of NRC License No.
Records of this training are required to be kept by the licensee for at least two years.
Licensee representatives explained that some
"training" was given to the HP technicians during st'aff meetings as a
normal part of supervising and implementing the radiation safety program,
however, no records of this "training" were kept.
The Associate CRPO and the RRPO stated that there was no established program to provide routine, annual refresher training to HP technicians.
In addition, no'icensee records were available for review by the inspector to demonstrate this training was provided.
The failure to provide annual HP technician refresher training and to maintain records is a violation of Condition No.
15 of NRC License No.
(Violation 70-938/91-01-04).
7.0 Radioactive Materials Trans ortation 7.1 ualit Assurance Pro ram On June 20, 1986, the NRC approved the "guality Assurance Program for Radioactive Material Packages" (71-0164, Revision 3) for implementation by the reactor facility.
The licensee incorporated this program into Chapter 11 of the "Safety Analysis Report for the MIT Research Reactor (MITR-II}". The inspector determined, through a review of records, that the licensee was conducting annual audits. of the procurement and use of NRC/DOT approved containers for the shipment of radioactive materials.
The inspector examined the latest report, prepared by the Director of Reactor Operations, of the audit conducted for 1990 and concluded that the required audits were performed and report/records prepared and maintained in accord with the requirements.
The records reviewed by the inspector were complete and well maintained.
No violations or deficiencies were identified in this area.
7.2 Radioactive Waste Shi ments The inspector reviewed the licensee's records for a radioactive waste shipment made on December 10, 1990.
Through an examination of the waste manifest for this shipment, the inspector determined that the licensee had not shown the total quantity of tr&ium, carbon-l4, technetium-99 and iodine-129 in the shipment, as required by 10 CFR 20.311(b).
The inspector identified only one drum, described on the manifest as containing "dewatered resin", which listed tritium as one of the radionuclides present in the waste package.
Other drums listed on the manifest, also identified as containing
"dewa'tered resin", did not indicate any tritium, carbon-14, technetium-99, or iodine-129 was present in the packages.
Through discussions with the RRPO, the in-spector determined that the licensee does not routinely analyze all waste streams in accordance with. the NRC-NMSS Waste Management Branch Technical Position paper to determine the quantity of those isotopes typically present.
The licensee stated that this information was provided on the manifest only if the licensee was specifically aware that those isotopes were being shipped, however, analyses to confirm the presence or absence of those isotopes in waste streams and to quantify them had not been performed with the exception of tritium
analysis.
Failure to provide this information on the waste manifest for the December 10, 1990 shipment was identified as a continuing violation (See paragraph 2.0) of 10 CFR 20.311(b).
(Violation 50-20/91-01-01).
8.0 Exit Interview The inspector met with the licensee representatives denoted in paragraph 1.0 at the conclusion of the inspection on January 17, 1991.
The inspector summarized the scope of the inspection'nd the findings.
On February 19, 1991, the inspector contacted Mr. Galanek regarding Violation 70-938/91-01-02 to provide the NRC position on this ite kt C