ML19225A954
| ML19225A954 | |
| Person / Time | |
|---|---|
| Site: | 07000938 |
| Issue date: | 04/13/1979 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19225A941 | List: |
| References | |
| 70-0938-79-01, 70-938-79-1, NUDOCS 7907230128 | |
| Download: ML19225A954 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECT:0N AND ENFORCEMENT Region I Report No.
70-938/79-01 Cocket No.70-938 License No. SNM-986 Priority II Category A
Licensee:
Massachusetts Institute of Technology 138 Albany Street Cambridge, Massachusetts 02'39 Facility Name:
MIT Research Reactor Inspection at:
Cambridge, Massachusetts Inspection conducted: March 13-15,1979 Inspectors:
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,' Euel Facility Inspector date signed dato signed -
date signed Approved by:-
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H. W. Crocker, Acting Chief, Fuel Facility date ' signed Projects Section, FF&MS Branch Inspection Summary:
Inspection on March 13-15, 1979 (Report No. 70-938/79-01 )
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the facility licensed SNM programs including:
scope of operation; licensee action on previously identified enforcement items; 10 CFR Part 21; organization; facility changes and modifications; internal review and audit; safety committees; review of operations; nuclear criticality safety; transportation program; routine use of packaging; nonroutine events followup; followup on regional requests; and independent inspection effort.
The inspection was initiated on the day shif t and involved 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> on site by one NRC regional based inspector.
Results: Of the 14 areas inspected, no apparent items of noncompliance were identified in 11 areas.
Four items of noncompliance were identified in 3 areas and an unresolved item was identified in facility and equipnent changes gew.
418 051 Region I Form 12 (Rev. April 77) qtf0W D
Inspection Sumary (Continued) 2 (Deficiency - Failure to include the SNM, byproduct and source licenses in 10 CFR Part 21 procedures (79-01-01), Paragrar' 6.a; Infraction -
Failure to post a high radiation area with Caution - High Radiation Area signs in the waste storage area (79-01-02), Paragraph d.d; Deficiency -
Failure to maintain recrods of 10 CFR 71.54 routine determinations on Stim shipping containers as required by 10 CFR 71.62(a)(10), (79-01-04),
Paragraph ll.a; Infraction - Failure to prepare written procedures to cover the loading and closing of shipping packages containing SNM as required by 10 CFR 71.54(i) (79-01-05), Paragraph ll.b).
Unresolved -
Question as to whether the licensee has a general authorization to cut open sealed UO2 pellet bearing fuel rods or if specific authorization must be obtained from flRC-flMSS (79-01-03), Paragraph 9.
418 052
DETAILS 1.
Persons Contacted
- L.
Clark, Jr., Director of Reactor Operations
- E.
Karaian, Reactor Radiation Protection Officer
- K. Collins, Reactor Superintendent
- P. Loggio, Radiation Protection Technician M. Bolton, Associate Radiation Protection Officer H. Bondar, Accountability Representative W. Fecych, Reactor Utilization Engineer
- denotes those present at the exit interview.
The inspector also interviewed several other licensee employees bring the course of this inspection.
2.
Scope of Operation Massachusetts Institute of Technology (MIT) uses special nuclear material in teaching and for research at the research reactor (MITR-II), other campus laboratories, at the Lincoln Laboratory in Lexington, Massachusetts and at the Accelerator Facility in Middleton, Massachusetts.
3.
Licensee Action on Previously Identified Enforcement Items (Closed) Deficiency (70-938/76 01-00):
Failure to maintain posting of Caution - Radioactive Materials signs on the Graphite Pile located in Room NW 12-133 of the Nuclear Engineering Building.
The inspector verified that proper signs had been replaced, as required, prior to the end of inspection 70-938/76-01.
The inspector verified during this inspection (70-938/79-01) that the licensee has established procedures for review of proper labeling and proper posting of radioactive materials during the taking of physical inventories and also during monthly contamination surveys conducted by radiation protection personnel.
4.
Oraanization a.
Following is the current organization of the MIT Radiation Protection Office as it applies to the Research Reactor facility and associated SNM licenses.
418 053
4 M. H. Rodnan, Director, Medical Department M. Chalfen, M.D., Physician in Charge, Environmental Medical Service S. Levin, MIT Radiation Protection Officer E. Karaian, MIT Reactor Radiation Protection Officer W. Caithness, Radiation Protection Technician P. Coggio, Radiation Protection Technician H. Scott, Radiation Protection Technician b.
The current organization responsible for activities conducted under the SNM licenses is as follows:
T. Jones, MIT Vice President, Research
- 0. V. Harling, Director, Nuclear Reactor Laboratory L. Clark, Director, Reactor Operations H. Bondar, Accountability Representative M. Driscoll, Supervisor, Contract Work 5.
SNM Material at the MIT Research Reactor The inspector examined licensee records and determined that the quantity of SNM located at the site was within the license limits specified for License SNM-986.
6.
Review of Ooerations The inspector examined ali areas of the Nuclear Engineering Build-ing to observe operations and activities in progress, to insoect the nuclear safety aspects of the facility and to check the general state of cleanliness, housekeeping and adherence to fire protection rules within the various areas.
a.
10 CFR Part 21 Reauirenents The inspector noted that the licensee had costed copies of the documents specified in 10 CFR 21.6 "Postir o.eq ui rements. "
The inspector also examined the procedures adopted pursuant to 10 CFR 21.21(a) concerning "Notif# ition of failure to comply or existence of a defect." However, it was noted that this procedure, SR No. 0-77-26 (PM 1.22) dated December 30, 1977,
" Procedures for Identifying, Evaluating, and Reporting Defects and Items of Noncompliance Pursuant to 10 CFR 21," in the
" Scope" stated that " procedures do not apply to the Institutes possession, use and/or transfer of byproduct, source and/or 418 054
5 special nuclear material authorized by NRC pursuant to licen-ses other than Reactor License No. R-37 " The inspector determined that nc other procedures had been written by the licensee to cover the possession, use and/or transfer of byproduct, source and/or special nuclear material authorized by NRC licenses.
This is contrary to Paragraph 21.2 " Scope" which states that "the regulations in this part apply..., to each individual... licensed pursuant to the regulations in this chapter to possess, use, and/or transfer within the United States source, byproduct, and/or special nuclear mate-rial..."
This item was identified to the licensee as an item of noncompliance (79-01-01).
b.
SNM Storage Facilities The inspector observed that nonirradiated special nuclear material was being stored in the "BTF Fuel Vault," the " Reactor Fuel Vault" and in two sates located in the " General Set-up Room."
Each area was properly posted with " Caution - Radio-active Material" signs and the two vaults were posted with adequate nuclear criticality safety information and/or criteria.
c.
Postings All areas of the Nuclear Engineering Cuilding were observed to be adequately ported with the croper " Caution" signs with the exception of tne " Waste Storage Area" as described in Paragraph 6.d below.
d.
Waste Storace Area The inspector noted that the Waste Storage Area in the con-trolled access area was posted with a " Caution - Radiation Area" sign and a " Caution - Radioactive "aterial" sign.
While examining this area the inspector observed a stack of lead bricks !ith a hand written sign which stated "400-800 mr/hr at the surface."
Licensee representatives stated that titanium cans used during the productior of Mo-99 by neutron capture were being stored in this loc:.cion and that the cans on contact read I to 1 1/2 R/hr.
The cans were surrounded by a stack of 6 inch lead bricks and high density concrete blocks extending about 11 inches off tne floor.
418 055
6 The cans covered an area of about 6" wide by 12" long within these lead bricks.
Radiation measurenents taken by the licen-see at the surface of this area confirmed that the radiation level was betwe q 400 to 800 mr/hr.
Measurements taken at about 22 inches from the surface (33 inches off the floor), at about gonad Might, indicated a radiation level of about 120-130 mr/hr.
There were no barricades around this area to restrict personnel access to this high radiation area nor was this area posted with Caution - High Radiation Area signs.
According to licensee representatives, this condition has apparently existed for about one and one-half weeks since the last shiprient of cans was received from the customer.
This item was identi fied to the licensee as an item of noncompli-ance (79-01-02).
The licensee immediately placed another tier of 2" thick le2d bricks on the top surface of the affected area which reduced the radiation level to about 40 to 60 mr/hr at about 22" above 'he original surface.
The radiation level at the surface of ti,e lead bricks was reduced to about 80 mr/hr.
However, signs cautioning workers from removing the lead bricks without first contacting the radiation protection office were not posted in the area.
7.
Nuc! ear C.iticality Safety a.
Criticality and Radiqtion '4onitor!
There are ten radiation monitors located throughout the facility, nine of which are connected :o remote readout meters located in the reactor control room.
The tenth unit is a bcal monitor used in connection with the Blanket test facility and was normally operated only during testing operations or while the rea: tor end/or blanket facility was down for repairs and/or modification.
All of the facility radiation monitoring devices appeared to be coerating properly.
Only one of these units is used spec'fically for criticality control and is located between the Reactor Fuel '/ault, Room iTJ 12-105A, and the BTF Fuel Vault, Room NW 12-103.
This monitor had the trip point set at 5 mr/hr and appeared to be working properly.
418 056
7 b.
Calibration of the Radiation Monitors The inspector examined licensee records which indicated that the radiatior monitors had been calibrated at least once each quarter and after repair for the time period June 12, 1976 through February 12, 1979.
Calibration was conducted as required by procedure QA No. 0-75-2 approved March 17, 1975, " Area and Fuel Vault (Crit) Monitor Calibration."
The Co-60 source used for the purposes of calibration was last calibrated on March 28, 1977 using a standard traceable to the National Bureau of Standards.
At this time, a Co-60 decay curve as a function of time was also establ!?hed.
c.
Internal Audit and Inspections The licensee has established a procedure for internal audits to assure that license conditions and federal regulations are followed. The radiation protection technicians have been required to examine all areas of the facility during the monthly facility contamination surveys and to record any information that should be brought to the attention of the Radiation Protection Officer on a special form titled,
" Radiation Survey Information." The inspector examined sam-ples of the results of these " surveys" conducted between April 11,1977 and March 8, 1979 and determined that each inadequacy identified had been corrected prior to this inspec-ti on.
8.
Safety Committees a.
Reactor Safeauards Committee All equipment and procedures involving the us_ of licensed materials in conjunction with the Research Reactor are required to be reviewed and approved by the Reactor Safe-guards Committee.
This committee meets at lease once annually and is responsible to the Administration of MIT.
The cammittee also reviews and approves, from the safety viewpoint, all operating procedures and proposed major modifications to the reactor and the use of the experimental facilities of the reactor and experiments that involve changes to prior com-mittee approvals.
08 057
8 Current members of the Reactor Safeguards Committee are:
N. C. Rasmussen, Chairnan, Head, Nuclear Engineering Department, MIT H. Brooks, Dean, Division of Engineering and Applied Physics, Harvard University M. Chalfen, Physician, Medical Department, MIT L. Clark, Jr., Director, MIT Reactor Operations M. J. Driscoll, Associate Professor, Nuclear Engineering Department, MIT J. Fresina, Director of Safety, MIT J. Gosnell, Nuclear Engineering, Boston Edison Co.
P. Griffith, Professor, Mechanical Engineering Depart-ment, MIT T. F. Jones, Vice President for Research, MIT S. Levin, Radiation Protection Officer, MIT C. J. Maletskas, Consultant Biophysicist, Gloucester, Mass.
O. K. Harling, Director, Nuclear Reactor Laboratory, MIT D. D. Lanning, Professor of Nuclear Engineering, MIT K. Collins, Reactor Superintendent J. Bernard, Secretary, Senior Shift Supervisor, MIT Reactor The inspector examined the records of two meetings of the Reactor Safeguards Committee held between July 12,1977 and September 6, 1978.
In each case, review actions and recom-mendations made by the committee were adequately documented.
Included in these records were supporting documents used by the committee to develop the recommendations made.
b.
Radiation Protection Committee The Radiation Protection Committee establishes and reviews the radiation protection program at the Institute and its off campus sites.
The committee also examines the Insti-tute's compliance with radiation protection regulations promulgated by State, Federal, and local agencies.
418 058
9 Current members of the MIT Radiation Protection Committee are:
A. J. Sinskey, Chairman, Professor Nutrition and Food Services S. Levin, Executive Secretary, Radiation Protection Officer M. D. Chalfen, Physician in charge, Medical A. Davison, Professor, Chemistry L. M. Hall, Professor Biology F. X. Masse, Bates Accelerator Radiation Protection Officer P. C. Powell, Assistant Director, Office of Sponsored Programs S. A. Rappaport, Professor, Physics H. S. Trop, Graduate Student, Chemistry P. Black, Assistant Radiation Protection Officer
'<. M. Bolton, Associate Radiation Protection Officer J. L. Jones, Assistant Radiation Protection Officer E. Karaian, Reactor Radiation Protection Officer J. L. Ryan, Staff, Lincoln Laboratory The inspector examined the records of three meetings of the Radiation Protection Committee held between January 10, 1978 and October 17, 1978.
In each case, review actions and recom-mendations made by thhe committee were adequately documented.
The next meeting of this committee has been scheduled for Februa ry 27, 1979.
9.
Facility Chances and Modifications The inspector determined through review of records, examination of the facility and through discussions with licensee representa-tives that the only facility modification relative to SNM handling within the scope of this inspection involved the removal of the sodium bonded simulated fast reactor blanket subassembly from the Blanket test Facility.
The subassembly was fabricated from 1.0999% enriched UO2 fuel pellets contained in 85 stainless steel fuel rods.
The fuel rods were fabricated into one subassembly and the subassembly was filled with sodium to simulate the coolant in an LMFBR subassembly as described in an approved license amend-ment application dated November 24, 1970.
418 059
10 The sodium bonded subassembly was cut at one end to remove the fuel pellets from the fuel rods since the licensee considered this operation safer than heating the sodium bonded subassembly to melt the sodium so that the fuel rods could be removed.
This work was accomplished during the time period September 28, 1978 through October 2,1978, and was conducted as required, according to licensee representatives, by a special procedure " Removal of UO2 Pellets from the BTF Sodium Subassembly," dated August 13, 1978.
This special procedure had been reviewed and approved by the Radiation Protection Officer.
The inspector questioned whether the licensee was authorized to cut open Uranium 0xide bearing fuel rods since there was no general approval to do so in the facility licerse Stim-986., Specific approval to reclad UO2 fuel pellets had been given to the licensee per the approved amendment application dated flovember 24, 1970.
This was identified as an unresolved item which will be transmitted to fiRC-f4 MSS for resolution (79-01-03).
10.
fionroutine Events The inspector determined through examination of licensee records and interviews of selected personnel that no nonroutine reportable or nonreportable events, within the scope of this inspection, took place at this facility since the last inspection (70-938/76-01).
11.
Packaging and Shioment of Special fluclear Material Licensee records relating to the packaging and shipment of special nuclear material for the time period August 23, 1977 through January 30, 1978, were examined by the inspector.
These records documented results of radiation surveys, container inspection results, labeling, marking, and placarding of vehicles and/or containers as required by license conditions and federal regu-lations except as follows:
a.
Routine Determination Results The inspector determined that the " Routine" determination results required by 10 CFR 71.54 " Routine deterninations" for shipment CCP-FZC-1 on August 23, 1977, had not been recorded and maintained as required by 10 CFR 71.62(a)(10).
Discussions with licensee representatives indicated that the container inspection had been performed but had not been recorded.
The inspector determined that the licensee has not established any formal means for documenting these results and thus for two shipments conducted during the time period reviewed, the required records were found for one shipment but not for the other.
This item was identi-fied as an item of noncompliance (79-01-04).
418 060
11 b.
Loading and Closing Procedures The inspector determined through an examination of licensee records and procedures and thraugh discussicos with licensee representatives, that the licensee has not established written procedures to cover the loading and closing of packages containing SNM as required by 10 CFR 71.54(i).
It was determined that the licensee has established specific written procedures to cover the loading and closing of packages of other types of radioactive material.
However, special nuclear material has not been addressed in these other procedures and the licensee indicated that written procedures have not been followed when packages which were to contain SNM have been loaded and/or closed.
This was identified as an item of noncompliance (79-01-05).
12.
Byoroduct Molybdenum-99 Production and Transfer The inspector noted through discussions with licensee representatives and review of licensee records, that the licensee was producing Molybdenum-99 by neutron activation techniques in multicurie quantities and that the licensee was shipping the unseparated Molybdenum-Molybdenum-99 mixture to an offsite vendor.
The inspector requested information from the licensee which would show that the licensee was authorized to conduct this type of operation since the MIT Byproduct License No. 20-01537-02 only allowed the possession of up to one curie of Molybdenum-99.
The licensee stated that they were authorized to produce and transfer multicurie quantities of Molybdenum-99 by the Reactor License R-37 but could not cite the specific authori ty.
Subsequent to this inspection, the inspector discussed this situation with representatives of NRC-NMSS, NRC-NRR, and NRC:I Re=: tor Operation and Nuclear Support Eranch.
It was determined that Anendment 10 to Reactor License No. R-37, in Paragraph 2.B(14),
authorized the licensee to possess, but not separate, such by-product material.. as may be produced by operation of the reactor.
Further, Paragraph 2.C incorporates Section 30.34 of 10 CFR Part 30 into the license.
Section 10 CFR 30.34(c) authorizes the licensee to prepare for shipment and transport byproduct in accordance with the provisions of 10 CFR Part 71.
Therefore, it was concluded that the licensee has been authorized to produce and transfer multicurie quantities of Molybdenum-99 by Amendment 10 to Reactor License No.
R-:7.
418 061
12 13.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptalbe items, items of noncompliance, or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph 9.
14.
Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) ;t the conclusion of the inspection at 11:30 a.m. on March 15,1979. The inspector summarized the scope and findings of the inspection.
The inspector also indicated that NRC-NMSS had requested answers to questions raised in a July 31, 1975 letter from NMSS to the licensee concerning the pending license renewal application.
The licensee stated that arrangements are being made to answer the July 31, 1975 letter as requested.
418 062