IR 05000020/2024202
| ML24348A139 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 12/30/2024 |
| From: | Tony Brown NRC/NRR/DANU/UNPO |
| To: | Foster J Massachusetts Institute of Technology (MIT) |
| References | |
| IR 2024202 | |
| Download: ML24348A139 (1) | |
Text
SUBJECT:
MASSACHUSETTS INSTITUTE OF TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000020/2024202 AND NOTICE OF VIOLATION
Dear Mr. Foster:
From October 21-24, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Massachusetts Institute of Technology reactor. The inspection results were discussed with you and members of your staff on October 24, 2024. The enclosed report documents the inspection results.
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 various activities, and interviewed personnel. Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred.
The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's website at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the enclosed inspection report. The violation is cited in the Notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the licensee failed to identify the violation.
The NRC has concluded that information regarding: (1) the reason for the violation(s); and (2) the corrective actions that were taken and the results achieved. Therefore, you are not required to respond to this letter unless the description herein does not reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
December 30, 2024 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 of 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).
Should you have any questions concerning this inspection, please contact Brian Lin at (301) 415-2923, or by email at Brian.Lin@nrc.gov.
Sincerely, Tony Brown, 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 w/enclosure: GovDelivery Subscribers Signed by Brown, Tony on 12/30/24
ML24348A139 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME BLin NParker TBrown DATE 12/17/2024 12/20/2024 12/30/2024
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:
50-020 License No.:
R-37 Report No.:
05000020/2024202 Licensee:
Massachusetts Institute of Technology Facility:
Massachusetts Institute of Technology Reactor Location:
Cambridge, Massachusetts Dates:
October 21-24, 2024 Inspector:
Brian Lin Approved by:
Tony Brown, 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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NOTICE OF VIOLATION Massachusetts Institute of Technology Reactor (MITR)
Docket No.: 50-020 Massachusetts Institute of Technology License No.: R-37 Consistent with the U.S. Nuclear Regulatory Commission (NRC) Enforcement Policy and Title 10 of the Code of Federal Regulations (10 CFR) Section 2.201, Notice of violation, the following violation identified in report (No. 05000020/2024202) is being cited:
Section 55.53(h), Condition of licenses, of 10 CFR states that each licensee, shall complete a requalification program as described by § 55.59.
Contrary to the above, the inspector identified that the facility failed to ensure two senior operator license holders were evaluated during the annual operating test period to the appropriate level of their license prior to performance of licensed activities at the conclusion of an extended maintenance period in 2023. Specifically, operators are required to complete plant manipulations in accordance with Section 55.59, Requalification, paragraph (c)(3)(i) of 10 CFR and section 12.10 of MITs Operator Training and Requalification plan. Operators were not able to complete the minimum number of reactivity control manipulations prior to refueling operations and reactor start up in January 2024.
In accordance with the NRC Enforcement Manual, multiple examples of the same violation during the period covered by the inspection should be included as one citation. This issue involves two examples of the same non-compliance and was determined to be a Severity Level IV violation (NRC Enforcement Policy section 6.4).
The NRC has concluded that information regarding the reason for the violation, and the corrective actions taken are adequate and addressed in this report. However, you are required to submit a written statement or explanation under 10 CFR 2.201 if the description on the docket does not reflect your corrective actions or your position. In that case, or if you choose to respond, please mark your reply Reply to a Notice of Violation and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, within 30 days of the date of the issuance of this Notice of Violation.
If you choose to respond, your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room consistent with 10 CFR 2.390. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).
Dated this 30th day of December 2024
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SUMMARY The NRC continued monitoring the licensees performance by conducting an inspection at the MIT Nuclear Reactor Laboratory, in accordance with the research and test reactor inspection program. This is the NRCs program for overseeing the safe operation of licensed research and test reactors. Refer to https://www.nrc.gov/reactors/non-power.html for more information.
List of Violations Violation of 10 CFR 55.53(h) for failure to meet requirements of the operator requalification plan prior to conducting licensed activities Severity Report Section Severity Level IV NOV 2024202-01 Closed 69003 The inspector identified a Severity Level IV violation of 10 CFR 55.53(h) for the facility permitting senior licensed operators to conduct licensed activities when they did not meet all requirements as described in 10 CFR 55.59(c)(3)(i) and MITRs operator requalification plan.
As a result, the licensee failed to ensure that senior licensed operators were properly evaluated during the annual operating test period.
Additional Tracking Items None
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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 reactor was not operated due to scheduled maintenance activities between experiments.
Inspection Scopes Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. The approved IPs with their attached revision histories are located on the public website at https://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2545, Research and Test Reactor Inspection Program. The inspector reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
69003 - Class I Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations This inspection included a review of selected documents and training records to verify the licensees operator requalification and training activities were conducted in accordance with the licensees approved requalification plan and 10 CFR Part 55, Operators Licenses.
Specifically, the inspection included a review of the following:
On-the-Job Training Tracking Sheet from fourth quarter 2022 - present
select lecture attendance records from 2023 - present
select medical examination records from 2022 - present
select written examinations performed 2023 - present
select procedure review forms from 2023 - present
reactor digital logbook 69005 - Class I Research and Test Reactor Experiments This inspection included a review of selected experiments and procedures to verify licensee experiments were reviewed, approved, and conducted in accordance with technical specification (TS) requirements, licensee procedures, and the requirements of 10 CFR 50.59, Changes, tests and experiments. Specifically, the inspection included a review of the following:
MIT annual report for 2023
part I irradiation request form 25-92,22-106, 44-10, 44-9, 25-93, 25-94, 25-95, 25-96 performed during the second and third quarter of 2024
select part II documents performed during the second and third quarter 2024
quality assurance document 2023-13, 2024-14, and 2024-05
in-core experiment review guide for HTWLF dated May 1, 2024, WHEP dated May 15, 2024, and XEN02 sigma experiment dated May 1, 2024
reactor digital logbook
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69006 - Class I Research and Test Reactor Organization and Operations and Maintenance Activities This inspection included a review of the licensees organizational and shift staffing records to verify compliance with TS requirements and licensee commitments. This inspection also included a review of the licensees logs and records to verify that operational and maintenance activities were conducted and controlled in accordance with regulatory and TS requirements.
Specifically, the inspection included a review of the following:
Safety Analysis Report for the MIT Research Reactor, dated November 2013
reactor digital logbook
organizational chart dated July 10, 2024
reactor digital daily operations schedule
MIT annual report for 2023
HTWL removal and associated quality assurance review form 69008 - Class I Research and Test Reactor Procedures This inspection included a review of selected licensee procedures to verify: that the administrative controls were in accordance with the TS, license requirements, and licensee commitments; the procedures in use were reviewed and approved; procedures were implemented as intended; and reactor personnel were observing administrative controls and TS requirements relative to procedural adherence. Specifically, the inspection included a review of the following:
MIT annual report for 2023
safety review form number 2020-22, dated September 2, 2020
safety review form number 2020-31, dated January 25, 2021
safety review form number 2022-09, dated April 6, 2022
safety review form number 2022-12, dated June 2, 2022 69009 - Class I Research and Test Reactor Fuel Movement This inspection included a review of the licensees fuel handling logs and records to verify compliance with TS and procedural requirements. Specifically, the inspection included a review of the following:
reactor digital logbook
PM 1.15, Fuel Loading Permission, performed for core configuration 251
PM 1.15, Fuel Loading Permission, performed for core configuration 251A
PM 1.15, Fuel Loading Permission, performed for core configuration 251B 69010 - Class I Research and Test Reactor Surveillance This inspection included a review of the licensees surveillance program to verify compliance with TS requirements and licensee commitments. This inspection also included a review of the licensees limiting conditions for operations to verify that operating conditions were maintained in accordance with the TS requirements. Specifically, the inspection included a review of the following:
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reactor digital logbook
MITR annual independent audit report for calendar year 2023 Inspection Results Violation of 10 CFR 55.53(h) for failure to meet requirements of the operator requalification plan prior to conducting licensed activities Severity Report Section Severity Level IV NOV 2024202-01 Closed 69003 The inspector identified a Severity Level IV violation of 10 CFR 55.53(h) for the facility permitting senior licensed operators to conduct licensed activities when they did not meet all requirements as described in 10 CFR 55.59(c)(3)(i) and MITRs operator requalification plan.
As a result, the licensee failed to ensure that senior licensed operators were properly evaluated during the annual operating test period.
Description: MITR was shutdown for an extended outage to complete leak repairs on the upper core tank. Repairs required the reactor to be shutdown and defueled for the majority of 2023. Operators are required to complete reactivity manipulations in accordance with 10 CFR 55.53(h), 55.59(c)(3)(i) and MITRs requalification plan. All licensed reactor operators were not able to complete the required manipulation prior to recommencing licensed activities in December 2023, and January 2024. Operations staffed two senior reactor operators to perform the startup and supervise the remaining licensed operators whose proficiency lapsed in 2023. Prior to reactor start up, several meetings were held with senior management and oversight committees to discuss risk mitigation and reactor restart planning. Topics included:
assigning MITRs most senior operators to perform the startup, observation by the Assistant Director of Operations in the control room, and staging additional personnel from operations, engineering, and health physics to respond to any abnormal condition.
Corrective Actions: The licensee will revise its procedure to clarify the requirements for the continuing training process that is a part of the requalification program to ensure implementation. This may include revisions to the operator requalification program requiring NRC approval. All licensed operators regained proficiency by completing the required written and operational examinations and performing reactivity manipulations as required by the MITR requalification plan.
Analysis: The violation was evaluated in accordance with the NRC Enforcement Policy. The violation is cited a Notice of Violation because it constitutes a failure to meet regulatory requirements that has a more than minor safety significance and the licensee failed to identify the violation.
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Enforcement:
Severity: The violation is normally categorized at Severity Level III in accordance with section 6.4.c of the NRC Enforcement Policy. However, the NRC staff determined the significance of this violation was a Severity Level IV because operators: 1) stood the minimal number of watches after the reactor was restarted, 2) did not cause any consequential errors while standing watch, and 3) complied with all other requirements (e.g., participated in requalification training, completed the required number of reactivity control manipulations, and stood all required proficiency watches).
Violation: Section 55.53(h) of 10 CFR states that the licensee, shall complete a requalification program as described by § 55.59.
Section 55.59(c)(3)(i) of 10 CFR states, in part, that the requalification program must include each licensed operator to manipulate the plant controls and each licensed senior operator either manipulate the controls or direct the activities of individuals during plant control manipulations. The licensee must contain a commitment that each individual shall perform or participate in a combination of reactivity control manipulations based on the availability of plant equipment and systems.
Contrary to the above, from December 2022, through December 2023, the licensee failed to complete its requalification program by not including the required reactivity manipulations. The licensee performed licensed activities at the conclusion of the extended maintenance outage and started the reactor in January 2024, without meeting the condition of their license as described in 10 CFR 55.53(h).
Enforcement Action: This violation is being cited as a Notice of Violation, consistent with sections 2.3.2 and 2.3.3 of the Enforcement Policy.
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Exit Meeting and Debriefs The inspector verified no proprietary information was retained or documented in this report.
- On October 24, 2024, the inspector presented the NRC inspection results to members of the licensee management and staff.
Documents Reviewed Inspection Procedure Type Designation Description or Title Revision or Date 69003 Procedure 1.16 NRC License Training of Personnel February 2013 1.6 Frequency of Surveillance Test and Calibration February 2013 1.7 Shift and Relief Turnover August 2019 1.8 Reactor Operating Logs August 2019 1.10 Experimental Program August 2018 3.3.1.1 Fuel Element Transfers:
Core/Storage Ring/Vault April 2016 3.3.1 Movement of Fuel April 2016 69006 Procedure 3.1.3 Startup for less than 100kW Operations June 2022 1.4 Review and Approval of Plans, Procedures, and Facility February 2013 69008 Procedure 1.5 Procedures Adherence and Temporary Change Method February 2013 69009 Procedure 1.15 Fuel Loading Permission June 2019 6.1.3.1A DWK 250 Detector Pulse Height Discriminator Calibration October 2017 6.1.3.1B DWK250 Detector Plateau Calibration October 2017 3.1.1.1 Startup Checklist" June 2023 6.1.6 Monthly Tech Spec Tests August 2021 69010 Procedure 6.2.1 Main Personnel Air Lock Gasket Deflated Scram September 2011