ML15159A403
| ML15159A403 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 05/28/2015 |
| From: | Lau E, Newton T Massachusetts Institute of Technology (MIT) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML15159A403 (5) | |
Text
NUCLEAR REACTOR LABORATORY AN INTERDEPARTMENTAL CENTER OF MASSACHUSETTS INSTITUTE OF TECHNOLOGY EDWARD S. LAU 138 Albany Street, Cambridge, MA 02139-4296 Facility Tours Assistant Director of Telefax No. (617) 324-0042 Education &Training Reactor Operations Tel. No. (617) 253-4211 Activation Analysis Coolant Chemistry Nuclear Medicine 28 May 2015 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn.: Document Control Desk
Subject:
License Amendment Request for DRO Qualification Tech Spec, Docket No. 50-20, License R-37 The Massachusetts Institute of Technology hereby submits a License Amendment Request (LAR) for its Facility Operating License No. R-37. The requested amendment is for a change in Technical Specification 7.1.4.1 modifying the qualification requirements for the position of Director of Reactor Operations. The reason for this request, as discussed in the enclosed analysis, is to provide the flexibility to fill this position with a highly qualified individual from a larger pool of candidates. The modified requirements will continue to meet or exceed all those expected of a Level 2 Facility Manager in ANSI/ANS-15.4-2007, Section 4.3.
This request has been reviewed and approved by the MIT Reactor Safeguards Committee.
Sincerely, Edward S. Lau, E omas Newton, Ph.D., P.E.
Assistant Director of Reactor Operations Director of Reactor Operations MIT Research Reactor MIT Research Reactor I declare under penalty of perjury that the foregoing is t and cor't.
Executed on I /
Date (grature EL/st
Enclosure:
As stated cc: USNRC - Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation USNRC - Senior Reactor Inspector Research and Test Reactors Oversight Branch Aau, Division of Policy and Rulemaking
- Office of Nuclear Reactor Regulation
PM 1.4 Pg 5 of 5 Safety Review Form No. 2015-11 Item: Technical Specification 7.1.4 Submitted by T. Newton Date 5/11/2015 Q/A number (required for all equipment changes) 2015-11 Yes* No Does the item change or contradict the Technical Specifications? E'_
Does the item contradict the SAR? F] []
- Attach explanation Description of Change (Attach extra pages if necessary):
See attached.
Safety Evaluation (Attach extra pages if necessary):
See attached.
Summary of Review:
a) Does the proposal: Yes No i) require a license amendment (IOCFR50.59(c)(2)) []J 11 ii) decrease scope of requalification program (IOCFR50.54(i-1)) 17 Z_
iii) decrease effectiveness of security plan (10CFR50.54(p)) E7 15 iv) decrease effectiveness of emergency plan (10CFR50.54(q)) El b) Reviewer's Comments:
Reviewer < Date 05: fA."of--
Reviewer " Date 162 .*z Reviewer 4 w{ (p4, . .-,-- Date /
7(Rcto Radi tion Protection Officer)
Approved Date /5/S (Director of Reactor Operations)
Date of MITRSC approval i1 Ir '!7.*/ O.& Date of NRC approval if List of Communications containing MITRSC additional conditions:
10 CFR 50.59 & 50.54 (p and q) changes included in Annual Report to NRC, Fiscal Year SR#11-0-12-5 FEB 20 2013
Page 1 of I Safety Review # 2015 Technical Specification 7.1.4 Description of Change Technical Specification 7.1.4.1, Director of Reactor Operations, is being amended to allow the equivalent of a senior operator's license at another facility as an alternative to holding a senior operator's license for the MIT Reactor. Wording is added to be consistent with ANSI/ANS-15.4-2007, "Selection and Training of Personnel for Research Reactors,"
Section 4.3.
Safety Evaluation The Technical Specifications as currently written 1) restrict the ability to hire a replacement for the Director of Reactor Operations from outside of the group of individuals holding senior reactor operator's licenses for the MIT Reactor and 2) could potentially reduce the focus on duties as Director of Reactor Operations in fulfilling initial or requalification licensing requirements, as operation of the reactor is not a key part of the duties of this position. Director of Reactor Operations is a senior management position responsible for overall reactor facility safety, regulatory compliance and organization. Safety is thus improved as this amendment will provide the flexibility to fill this position with a highly qualified individual from outside of MIT's Reactor Operations group and allow this individual to focus on the duties incumbent upon the Director of Reactor Operations.
The qualification requirements as stated in the Technical Specifications for the Director of Reactor Operations will continue to meet or exceed all requirements for a Level 2 Facility Manager in ANSI/ANS-15.4-2007, Section 4.3. Allowing the equivalent of a senior reactor operator's license at another facility provides the flexibility to fill this position with a highly qualified individual from a larger pool of candidates.
SR#-2015-11 19 MAY 2015
TS 7.1.4 Selection of Personnel, Specification #1 Current:
- 1. Director of Reactor Operations - The Director of Reactor Operations shall have a minimum of seven years of nuclear experience. The individual shall have a recognized baccalaureate or higher degree in an engineering or scientific field. Education or experience that is job-related may be substituted for a degree on a case-by-case basis. The degree may fulfill four years of the seven years of nuclear experience required on a one-for-one time basis. At least three years of experience shall be in a responsible position in reactor operations or a related field including at least one year's experience in reactor facility management or supervision. The Director of Reactor Operations shall hold a senior operator's license for the MIT Research Reactor, or have held such a license at the MIT Research Reactor.
Proposed:
- 1. Director of Reactor Operations - The Director of Reactor Operations shall have a minimum of seven years of nuclear experience. The individual shall have a recognized baccalaureate or higher degree in an engineering or scientific field. Education or experience that is job-related may be substituted for a degree on a case-by-case basis. The degree may fulfill four years of the seven years of nuclear experience required on a one-for-one time basis. At least three years of experience shall be in a responsible position in reactor operations or a related field including at least one year's experience in reactor facility management or supervision. The Director of Reactor Operations shall hold a senior operator's license for the MIT Research Reactor, or have held the equivalent at the MIT Research Reactor or another reactor facility.
In the case of the latter, the individual shall receive facility-specific training, based on the individual's background and abilities.
Basis:
The qualification requirements for the Director of Reactor Operations meet or exceed all requirements for a Level 2 Facility Manager in ANSI/ANS-l15.4-2007, Section 4.3. Allowing the equivalent of a senior operator's license at another facility provides the flexibility to fill this position with a highly qualified individual from a larger pool of candidates.
American National Standard ANSI/ANS-15.4-2007 3.5 Level 4 formal training may not be required. If this individual is also to be licensed, the individual Operating staff (i.e., senior reactor operators shall meet the licensing requirements of the and reactor operators). respective position and responsible authority.
3.6 Other technical personnel 4.4 Level 3 These are personnel not directly involved in the management and operation of the reactor At the time of appointment to the position, the individual shall have received sufficient but who provide technical support in areas in-training at the facility or elsewhere to satisfy volving the reactor. Examples are laboratory the requirements for licensing as a senior re-technicians, instrument technicians, and health actor operator. This individual shall also have physics personnel.
three years of nuclear experience. A maximum of two years equivalent full-time academic train-ing may be substituted for two years of the 4 Qualification three years of nuclear experience required. In-dividuals assigned to Level 3 positions should 4.1 General have a high-school diploma or have success-Research reactor personnel shall have that com- fully completed a General Education Develop-bination of academic training, job-related expe- ment (GED) test. Additional academic training rience, health, and skills commensurate with is highly recommended.
their level of responsibility that provides rea-4.5 Level 4 sonable assurance that decisions and actions during all normal and abnormal conditions will At the time of appointment to the position, the be such that the reactor is operated in a safe individual shall have received sufficient train-manner. ing at the facility or elsewhere to satisfy the requirements for licensing at the appropriate Nuclear experience acquired at a nuclear reac- level. Individuals assigned to Level 4 positions tor may qualify on a one-for-one time basis should have a high-school diploma or have suc-(i.e., one year of nuclear experience for one cessfully completed a General Education Devel-year of research reactor experience). opment (GED) test. Individuals who do not have 4.2 Level 1 a high-school diploma or GED should not be excluded. Previous job-related experience or ed-At the time of appointment to the position, the ucation should also be considered. An individu-Level 1 person shall receive briefings suffi- al's ability to successfully complete the training cient to provide an understanding of the gen- program for the Level 4 position and satisfy all eral operational and emergency aspects of the job performance requirements should be the reactor facility. determining factors for appointment to the 4.3 Level 2 position.
At the time of appointment to the position, the 4.6 Other technical personnel Level 2 person shall have a minimum of six Technical support personnel shall have a min-years of nuclear experience. The individual shall imum of one year of working experience in their have a recognized baccalaureate or higher de- specialty or craft and shall be qualified to per-gree in an engineering, or scientific field. The form the work for the position.
degree may fulfill up to four years of the six years of nuclear experience required. Educa-tion and/or experience that is job related may 5 Initial training and licensing be substituted for a degree on a case-by-case basis. The individual shall receive appropriate 5.1 General facility-specific training based upon a compar-ison of the individual's background and abili- All personnel requiring reactor operator or se-ties with the responsibilities and duties of the nior reactor operator licenses shall receive position. Because of the educational and expe- comprehensive training and meet licensing re-rience requirements of the position, continued quirements of qualification, training, medical 3