IR 05000020/2022201

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Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000020/2022201
ML23025A228
Person / Time
Site: MIT Nuclear Research Reactor
Issue date: 02/07/2023
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Foster J
Massachusetts Institute of Technology (MIT)
References
IR 2022201
Download: ML23025A228 (1)


Text

SUBJECT:

MASSACHUSETTS INSTITUTE OF TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000020/2022201

Dear Mr. Foster:

From October 24-27, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Massachusetts Institute of Technology (MIT) reactor. The enclosed report documents the inspection results which were discussed on October 27, 2022, with you and members of the MIT staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified.

No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

February 7, 2023 If you have any questions concerning this inspection, please contact Mr. Kevin Roche at 301-415-1554, or by email at Kevin.Roche@nrc.gov.

Sincerely, Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.50-020 License No. R-37 Enclosure:

As stated cc: See next page Signed by Tate, Travis on 02/07/23

Massachusetts Institute of Technology Docket No.50-020 cc:

City Manager City Hall Cambridge, MA 02139 Department of Environmental Protection One Winter Street Boston, MA 02108 Mr. Jack Priest, Director Radiation Control Program Department of Public Health 529 Main Street Schrafft Center, Suite 1M2A Charlestown, MA 02129 Ms. Samantha Phillips, Director Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Mr. Marshall B. Wade Reactor Superintendent Massachusetts Institute of Technology Nuclear Reactor Laboratory Research Reactor 138 Albany Street, MS NW12-116B Cambridge, MA 02139

ML23025A228 NRC-002 OFFICE NRR/DANU/UNPO/RSE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME KRoche JArellano NParker TTate DATE 1/25/2023 1/25/2023 1/25/2023 2/7/2023

Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:

50-020 License No.:

R-37 Report No.:

05000020/2022201 Licensee:

Massachusetts Institute of Technology Facility:

Massachusetts Institute of Technology Reactor Location:

Cambridge, Massachusetts Dates:

October 24-27, 2022 Inspector:

Kevin Roche Juan Arellano Approved by:

Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

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EXECUTIVE SUMMARY Massachusetts Institute of Technology Reactor Inspection Report No. 05000020/2022201 The primary focus of this routine, announced inspection was the onsite review of selected elements of the Massachusetts Institute of Technology (MIT, the licensee) research reactor safety program, including: (1) operator licenses, requalification, and medical examinations, (2) effluent and environmental monitoring, (3) experiments, (4) organization and operations and maintenance activities, (5) review audit and design change functions, (6) procedures, (7) fuel movement, (8) surveillance, (9) emergency preparedness, (10) radiation protection, and (11)

transportation activities. The U.S. Nuclear Regulatory commission (NRC) staff determined the licensees program was in compliance with NRC requirements.

Operator Licenses, Requalification, and Medical Examinations

Licensed operator licenses, requalification and medical examinations met technical specification (TS), administrative, and regulatory requirements.

Effluent and Environmental Monitoring

Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

Experiments

The program for reviewing, authorizing, and conducting experiments satisfied TS and procedural requirements.

Organization and Operations and Maintenance

Organizational structure and staffing were consistent with TS requirements.

Operational and maintenance activities were consistent with applicable TS and procedural requirements.

Review and Audit and Design Change Functions

The MIT Reactor Safeguards Committee (RSC) met as required and reviewed the topics outlined in the TS.

Annual audits of facility programs were conducted as required by TS.

Changes to the facility were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments.

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Procedures

The licensees procedural review, revision, and implementation program satisfied the requirements of TS.

Fuel Movement

Fuel movements and inspections were conducted in accordance with TS and procedural requirements.

Surveillance

The surveillance program was conducted in accordance with TS and licensee procedural requirements.

Emergency Preparedness

The emergency preparedness program was conducted in accordance with the Emergency Plan (E-Plan), including response equipment maintenance, emergency drills, and E-Plan training.

Radiation Protection

Surveys, postings, training, and personnel dose monitoring met regulatory requirements.

Radiation monitoring equipment was maintained and calibrated as required by TSs.

The radiation protection and the as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.

Transportation Activities

The program for transportation of radioactive material (RAM) satisfied U.S. Department of Transportation (DOT) and the NRC regulations.

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REPORT DETAILS Summary of Facility Status The MIT Nuclear Reactor Laboratory 6-megawatt research reactor is routinely operated in support of training, experiments, and maintenance. During this inspection, the inspector observed reactor operations.

1.

Operator Licenses, Requalification, and Medical Examinations a.

Inspection Scope (Inspection Procedure (IP) 69003)

To verify that the licensee complied with the requirements of 10 CFR Part 55, Operators Licenses, and TS section 7.1.5, the inspector reviewed selected aspects of the following:

reactor digital logbook for individual operators

procedure manual (PM) 1.16, "NRC License Training of Personnel," dated February 20, 2013

annual written examinations 2021 - present

annual operating examinations 2021 - present

medical examination records 2020 - present b.

Observations and Findings The inspector found that training was conducted in accordance with the licensees NRC-approved requalification and training program and was documented, and that requalification records were maintained. The inspector also found medical examinations for licensed operators were completed and documented as required by the regulations.

c.

Conclusion The inspector determined that operator requalification was conducted as required by the requalification program and licensed operators met regulatory requirements.

2.

Effluent and Environmental Monitoring a.

Inspection Scope (IP 69004)

To verify that the licensee complied with the requirements of 10 CFR Part 20, Standards for Protection against Radiation, and TS section 3.7, the inspector reviewed selected aspects of:

facility records of measurements and analysis of effluent samples

MIT annual operating report 2021

environmental release records

secondary water tritium sample records

effluent monitoring instrumentation maintenance records

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b.

Observations and Findings The inspector found that environmental radiation monitoring was accomplished by use of thermoluminescent dosimeters placed within a quarter mile of the reactor, and that doses were within regulatory limits. The inspector noted that gaseous releases from the containment exhaust stack are monitored, and release amounts are calculated and documented in the annual reports; and that the airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2.

The inspector found that the combined sources of all liquid effluent releases are within the monthly average concentration limits established in 10 CFR Part 20, Appendix B, Table 3.

c.

Conclusion The inspector determined that effluent release measurements, liquid and gas sampling analysis, and environmental monitoring measurements, demonstrated compliance with regulatory and TS limits.

3.

Experiments a.

Inspection Scope (IP 69005)

To verify compliance with the licensees procedures, TS Sections 6 and 7.5, the inspector reviewed the following:

reactor digital logbook

MIT annual operating report 2021

MIT irradiation request forms from October 2021 - present

special procedures for experiments October 2021 - present

in-core experiment review guides

PM 1.10, Experimental Review and Approval," dated August 17, 2018 b.

Observations and Findings The inspector reviewed selected safety review forms and irradiation request forms for experiments performed since the last inspection. The inspector verified that experiments were reviewed, evaluated, approved, and conducted in accordance with TS requirements.

c.

Conclusion The inspector determined that the licensees program for reviewing, authorizing, and conducting experiments satisfied the TS and procedural requirements.

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4. Organization and Operations and Maintenance Activities a.

Inspection Scope (IP 69006)

To verify that the licensee complied with the requirements for organization, operations, and maintenance activities, as specified in TS sections 2, 3, 7.1, and licensee procedural requirements, the inspector reviewed selected aspects of the following:

MIT nuclear reactor laboratory organization chart

reactor digital logbook

reactor job workbook

reactor digital daily operations schedule

"Annual Report for the MIT Research Reactor to the U.S. Nuclear Regulatory Commission for the period January 1, 2021 - December 31, 2021," dated March 31, 2021 b.

Observations and Findings The inspector found that the MIT reactor organization and shift staffing was consistent with that specified in the TS. The inspector also found that operations and maintenance activities were consistent with administrative procedures and TS, and equipment malfunctions were documented, and actions were taken in accordance with TS.

c.

Conclusion The inspector determined that the licensees organization and staffing complied with the requirements specified in TS section 7.1, and that operational and maintenance activities were also consistent with applicable TS and procedural requirements.

5.

Review and Audit and Design Change Functions a.

Inspection Scope (IP 69007)

To verify compliance with TS sections 7.2.1, 7.2.2, 7.2.3, and 10 CFR 50.59, the following documents were reviewed:

10 CFR 50.59 evaluations

"Annual Report for the MIT Research Reactor to the U.S. Nuclear Regulatory Commission for the period January 1, 2021 - December 31, 2021," dated March 31, 2021

"MIT Reactor (MITR) Annual Independent Audit Report for CY 2021," June 2022

Draft of "Minutes of the One Hundred Fourteenth Meeting of the MIT Reactor Safeguards Committee (MITRSC)," dated December 2, 2021

MIT Research Reactor Administrative Procedure, PM 1.13, Quality Assurance Program," dated August 11, 2016

MIT Research Reactor Administrative Procedure, PM 1.4, Review and Approval of Plans, Procedures, and Facility Equipment and Changes Thereto

quality assurance documentation for facility modifications

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audit response to independent audit for calendar year (CY) 2021

2020-25, "PM 3.2.1. Shutdown from Operation at Power," dated March 23, 2021, changes to the shutdown checklist were evaluated IAW with procedures and 50.59

2020-19, "Update of PM 3.1.12 in support of Nuclear Safety System upgrade," dated August 28, 2020

2020-0, "PM 3.5 Daily Surveillance Check and PM 3.8 Makeup Water System Checklists," dated March 30, 2020

2018-28, "PM 6.5.6.1C and PM 6.5.6.4B Calibration of Digital Test Gauge," dated December 4, 2018

2017-12, "Shim Blade Electromagnets," dated March 29, 2017 b.

Observations and Findings (1) Review and Audit Functions The inspector found that the MIT RSC meeting frequency and committee membership satisfied TS section 7.2.1, and that safety reviews and audits were completed at the required frequency for the functional areas specified by TS sections 7.2.2 and 7.2.3.

The inspector reviewed the results of the audits and determined that the audit findings, and licensee actions taken in response to the findings, were appropriate.

(2) Design Change Functions The inspector found that screening and safety review of changes, tests, and experiments was in accordance with regulatory requirements and facility procedures.

c.

Conclusion The inspector determined that the MIT review, audit, and design change programs were implemented in accordance with the TS requirements and NRC regulations.

6.

Procedures a.

Inspection Scope (IP 69008)

To verify that facility procedures were prepared, reviewed, revised, and implemented as required by TS section 7.4, the inspector reviewed selected aspects of:

MIT annual report for 2021

safety review (SR) form number (#) 2021-30, "MCODE Isotope Extract Package"

SR # 2021-15B, "PM 6.5.16.1A Regulating Rod Calibration by Period Measurement"

SR # 2021-15, "PM 6.5.16.2 Shim Blade Calibration Procedure"

SR # 2021-13, "PM 6.5.19 Calibration of Test Equipment and Tools"

SR # 2021-09, "PM 3.1.6 Restart Following an Unanticipated or a Brief-Duration Scheduled Shutdown"

SR # 2020-30, "PM 5.8.4 Loss of Normal Off-Site Electrical Power"

SR # 2020-29, "PM 6.4.17 Leak Alarm"

SR # 2020-26, "PM 3.2.2 Shutdown from Less than 100 kW Operation"

SR # 2020-23, "PM 3.1.1.3 Cooling Tower Operation and Full Power Checks"

SR # 2020-18, "PM 5.5.17 Low Pressure Instrument Air"

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SR # 2019-14, "PM 3.1.1.1 Two Loop Mechanical"

PM 6.5.16.1A, "Regulating Rod Calibration by Period Measurement," dated May 20, 2021

PM 6.5.16.2, "Shim Blade Calibration Procedure," dated May 2, 2022

PM 6.5.19, "Calibration of Test Equipment and Tools," dated April 29, 2021

PM 6.1.4.7, "Shim Blade Drop Time," dated March 28, 2021

PM 3.1.6, "Restart Following an Unanticipated or a Brief-Duration Scheduled Shutdown," dated March 1, 2021

PM 5.8.4, "Loss of Normal Off-Site Electrical Power," October 29, 2020

PM 6.4.17, "Leak Alarm," dated October 20, 2020

PM 3.2.2, "Shutdown from Less than 100 kW Operation," dated April 15, 2021

PM 3.1.1.3, "Cooling Tower Operation and Full Power Checks," dated March 12, 2021

PM 5.5.17, "Low Pressure Instrument Air," dated July 23, 2020

PM 3.1.1.1, "Two Loop Mechanical," dated March 28, 2021

PM 7.4.6.4, "SFP Fuel Storage Cadmium Degradation Monitoring," dated February 28, 2017 b.

Observations and Findings The inspector noted that procedure revisions were reviewed and approved by the Director of Reactor Operations and submitted to the MIT Reactor Safety Committee for review, and that all procedure changes were routinely routed to all licensed operators for review.

c.

Conclusion The inspector determined the procedural review, revision, and implementation process satisfied the TS requirements.

7.

Fuel Movement a.

Inspection Scope (IP 69009)

To ensure that the licensee followed the requirements of TS sections 3.1.4, 3.1.6, 4.1.5, and 5.4, the inspector reviewed selected aspects of the following:

SR # 2021-16, "Special Procedure for Dummy Element Transfer from the Spent Fuel Pool to the Core Tank"

"Special Procedure for Dummy Element Transfer from the Spent Fuel Pool to the Core Tank," dated May 3, 2021

PM 3.3.5, "Receipt and Acceptance of New Fuel," from October 2021 - present

PM 7.4.4.2, "In-Service Inspection of Primary Core Tank Fuel, and Spent Fuel Storage Pool," January 10, 2022

PM 3.3.1, "General Conduct of Refueling Operations," from 2022 - present

PM 3.3.2, "General Conduct for the Removal of Spent Fuel," from 2022 - present

PM 1.15, "Fuel Loading Permission," from October 2021 - present

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b.

Observations and Findings The inspector reviewed the fuel movement process and verified that fuel manipulations were conducted in accordance with established procedures. The inspector also reviewed records of selected fuel movements and interviewed MIT reactor personnel. The inspector noted that a plan for each series of fuel movements was developed prior to the activity and were used for core refueling, core rearrangement, and inspections of fuel elements.

c.

Conclusion The inspector determined that fuel movements were conducted in accordance with written procedures that met the TS requirements and fuel inspections were completed annually.

8.

Surveillance a.

Inspection Scope (IP 69010)

To verify that the licensee met the surveillance requirements specified in TS section 4, the inspector reviewed selected aspects of the following:

reactor job workbook

reactor digital daily operations schedule

reactor digital logbook

"Annual Report for the MIT Research Reactor to the U.S. Nuclear Regulatory Commission for the period January 1, 2021 - December 31, 2021," dated March 31, 2021

MIT logbook System Tests and Calibration Logbook (in the control room)

PM 3.1.1, Full Power Startup Checklist

6.1.3.9, "Quarterly Battery Surveillance," completed February 7. 2022

6.1.3.9 for August 1, 2022, showed 10 cells H.O.O.S. but then procedures signed off

6.1.3.6, "Reactor Building Overpressure Scram," completed June 30, 2022

6.1.6, "Monthly Technical Specifications Tests," completed August 5, 2022

6.1.3.3.B, "Primary Coolant Flow Scram Static Calibration (MF-1A, MF-1B)

(Procedure using the Transmation Model 190 Calibrator)," completed January 20, 2022

6.2.1, "Main Personnel Air Lock Gaskets Deflated Scram," completed December 23, 2021 b.

Observations and Findings The inspector found that surveillance tests and surveillances were completed as required by TS and licensee procedures, and that limiting conditions for operations were satisfied.

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c.

Conclusion The inspector determined that the surveillance program was conducted as specified by TS requirements.

9.

Emergency Preparedness a.

Inspection Scope (IP 69012)

The inspector reviewed selected aspects of the following to verify compliance with the licensees E-Plan and associated procedures:

PM 4.0, MITR Emergency Plan and Procedures," dated October 7, 2019

letter of agreement (LOA) with Massachusetts General Hospital, dated April 11, 2016

LOA with Mount Auburn Hospital, dated December 1, 2013

LOA with City of Cambridge Fire Department, dated August 6, 2018

LOA with City of Cambridge Police Department, dated February 12, 2016

LOA with Professional Ambulance company, dated February 10, 2019

memorandums detailing annual operator review of emergency plan and procedures 2020 - present

PM 3.7.1, "Weekly Security," 2022 - present

evacuation siren tests contained in PM 3.1.1.2, "Two Loop Instrumentation"

2021 combined medical/radiological emergency exercise documentation

personnel in the December 15, 2021 medical/radiological emergency drill documentation

City of Cambridge Fire Department training records

NW12 MIT Police training records

PM 6.6.2.4 Inventory of Emergency Supplies and Equipment, dated April 6, 2022 b.

Observations and Findings The inspector reviewed the MIT E-Plan and implementing procedures and verified, through discussions with the licensee, that no changes to the E-Plan were made since the last inspection in accordance with 10 CFR 50.54(q) Emergency plans. The inspector also reviewed the training records, E-Plan exercise records, staffing requirements, off-site support, emergency equipment maintenance, and observed the testing of a weekend alarm.

c.

Conclusion The inspector determined that the licensee maintained its emergency preparedness program in accordance with its E-Plan requirements.

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10. Radiation Protection a.

Inspection Scope (IP 69012)

To verify that the licensee followed the requirements of TS section 7.3, 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20 the inspector reviewed selected aspects of the following:

personnel dosimetry reports

facility areas, equipment, operations, and postings

"Annual Report for the MIT Research Reactor to the U.S. Nuclear Regulatory Commission for the period January 1, 2021 - December 31, 2021," dated March 31, 2021

MIT ALARA program reviews for 2021

MIT independent annual audits for 2021

instrument calibration records

employee radiological training records

MIT ALARA policy

radiological survey records b.

Observations and Findings (1) Surveys The inspector found that periodic contamination and radiation surveys were completed in accordance with radiation protection procedures, and that survey results were documented and posted so that facility personnel would be knowledgeable of the radiological conditions that existed in the controlled areas of the facility.

(2) Postings and Notices The inspector observed that NRC Form 3, Notice to Employees, was prominently posted as required by 10 CFR 19.11, Posting of notices to workers, and that radiological signs were also posted as required by 10 CFR 20.1902, Posting requirements.

(3) Dosimetry The inspector observed that dosimetry use was in accordance with facility procedures and dose limits to workers and the public were within 10 CFR Part 20 limits.

(4) Radiation Monitoring Equipment The inspector found that installed and portable radiation monitoring equipment was calibrated in accordance with TS and facility procedures.

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(5) Radiation Protection Training The inspector reviewed the general employee radiation protection training given to MIT staff members, to those authorized to use the experimental facilities of the reactor, to students, and to visitors, and that training was in accordance with facility procedures and regulatory requirements.

c.

Conclusion The inspector determined that: (1) surveys were completed and acceptably documented in accordance with radiation protection procedures to permit evaluation of the radiation hazards present, (2) postings and notices met regulatory requirements, (3) personnel dosimetry was worn as required by facility procedures and recorded doses were within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was maintained and calibrated as required by TS and facility procedures, (5) the radiation safety training program was implemented in accordance with procedures, and (6) the radiation protection and ALARA programs satisfied regulatory requirements.

11. Transportation Activities a.

Inspection Scope (IP 86740)

The inspector reviewed the following documents to verify compliance with NRC and DOT regulations governing the transportation of RAM as specified in 10 CFR Part 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and in 49 CFR Parts 171-178:

RAM shipping papers and related records

training records for individuals designated as shippers

annual DOT RAM shipping audits for 2021

"Annual Report for the MIT Research Reactor to the U.S. Nuclear Regulatory Commission for the period January 1, 2021 - December 31, 2021," dated March 31, 2021 b.

Observations and Findings The inspector found that the licensee shipped various types of RAM since the last inspection of this area. The inspector noted that shipping records were complete, and the shipping containers were labeled correctly.

The inspector verified that the licensee maintained copies of consignees RAM possession licenses, and that training for staff members involved in the shipment of RAM was performed.

c.

Conclusion The inspector determined that the program for transportation of RAM satisfied the DOT and NRC regulations.

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12.

Exit Interview The inspection scope and results were summarized on October 27, 2022, with members of licensee management. The inspector discussed the areas inspected and the inspection observations. The licensee acknowledged the results of the inspection and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

Attachment PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel T. Bork Reactor Utilization Manager D. Cormel Project Technician Director, Reactor Operations S. Hauptman Reactor Engineer E. Lau Associate Director, Reactor Operations W. McCarthy Deputy Director, Environment, Health, and Safety S. Tucker Quality Assurance Supervisor M. Wade Superintendent of Operations INSPECTION PROCEDURES USED IP 69003 Class I Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations IP 69004 Class l Research and Test Reactor Effluent and Environmental Monitoring IP 69005 Class I Research and Test Reactor Experiments IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69009 Class I Research and Test Reactor Fuel Movement IP 69010 Class I Research and Test Reactor Surveillance IP 69011 Class I Research and Test Reactor Emergency Preparedness IP 69012 Class I Research and Test Reactors Radiation Protection IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Open None Closed None