ML20005G847
| ML20005G847 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 01/09/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rogers K NRC COMMISSION (OCM) |
| Shared Package | |
| ML20005G848 | List: |
| References | |
| NUDOCS 9001230189 | |
| Download: ML20005G847 (10) | |
Text
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MEMORANDUM FOR: Comissioner Rogers I
l FROM:
James M. Taylor Executive Director for Operations l
SUBJECT:
STAFF VIEWS ON CONCERNS RAISED BY MIT This is in response to your memorandum of April 14, 1989, which unfortunately i
did not get routed for action. The staff has reviewed the concerns of the Massachusetts Institute of Technology (MIT) that were expressed in a letter you received during your visit to MIT. The staff's comments are numbered to match MIT's concerns:
1.
Procurement of Clean Heavy Water: The Defense Programs Office of the Department of Energy (DOE-DP) instituted a ban on shipment of heavy water to non-government facilities. This ban is the result of continuing problems at the Savannah River plant. The DOE Division of University and Industrial Programs (DOE-UP) has explored with no success the possibility of procuring clean heavy water from Canada in exchange for contaminated heavy water. The DOE-UP budget does not contain the necessary funds
($500,000) to acquire the heavy water MIT requested on the open market.
DOE-UP continues to work on this problem, but no solution is. anticipated in the near future. The MIT reactor uses heavy water as a reflector. MIT is currently performing preventive maintenance on its reflector cooling system to reduce the possibility of a coolant leak that could release i
tritium into the containment building. The reflector heavy water system contains approximately 3 curies of tritium per liter. The total system inventory is approximately 16,000 curies. The staff believes that this situation does not present undue risk to the health and safety of the public. The MIT emergency plan addresses facility response to loss of heavy water.
2.
Central Plutonium Collection Facility: Many universities have some special nuclear material (SNM) or source material that is not needed to support the current operation of their facilities. Although it is true that there are costs involved in the storage and safeguarding of this material, these
. costs represent a small part of the total cost of the accountability program of the university. Although the majority of this material is not owned by DOE and DOE has no obligation to accept it, DOE is actively developingplanstocollectthismaterial. DOE has requested funding in next year s budget to implement the program. MIT has recently returned a portion of its unwanted SNM to DOE. The staff believes that DOE is responding to this problem and that Comission action is not r.eeded.
3.
Shipment of Spent Fuel: There are problems concerning the shipment of spent fuel from MIT and the University of Missouri at Columbia (MURR).
The only shipping cask certified to transport the type of fuel used in l
these reactors has been withdrawn from use by its owner, the General 9001230189 900109
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. J Electric Company, for economic reasons. MURR anticipates submitting an i
application in January 1990 to the NRC to amend the BMI-1 cask license to add MURR and possibly MIT fuel. To allow continued operation, NRC has j
amended the MIT operating license authorizing increased fuel possession j
limits. MURR will require an increase in-its fuel possession limit in May 1990. MIT will exhaust fuel storage space in 1995 and MURR in December 1990. MIT's statement that NRC refuses to license casks for the shipment of spent fuel is not accurate. The NRC reviews and approves the i
design of spent fuel shipping casks. To obtain NRC approval of a shipping cask, an applicant must submit a safety analysis report that shows that the cask meets the requirements of 10 CFR Part 71. A cask design that meets -
these requirements is issued an NRC Certificate of Compliance. After a design has been approved,f will continue to monitor this situation.any number of cas cated and used. The staf i
4.
NRC Regionalization: As you are aware, problems cited by MIT with f
non-power reactor (NPR) regulation and inspection were addressed by the Commission decision that the Non-Power Reactor, Deconsnissioning, and EnvironmentalProjectDirectorate(PDNPRDE)willparticipatesignificantly in the NPR inspection program and take a strong leadership role in all matters affecting NPRs.
Sa. NPR Inspectors: This concern is addressed in Item 4.
l Sb. Availability of Operator Licensing Examinations: Because of the limited resources available to meet all licensing requests, it is not postible to schedule more than one trip per year to administer operator licensing examinations for NPRs.
In some cases, the NRC has been able to acconunodate additional examination requests from licensees of NPRs. This support will continue on a specific case basis according to competing needs at the time of such a request.
Sc. Limiting Corrective Actions: This comment refers to a unique situation that applied only to Cintichem. Cintichem representatives and the NRC l
I staff agreed on a procedure to allow NRC inspectors access to the facility.
This access was required because Cintichem produces isotopes from separated i
fission products on a 24-hour-a-day schedule.
The staff carefully. analyzes i
the need for generic action at NPRs and limits action only to those.
facilities directly affected by a particular issue. The success of this procedure is reflected in the small number of generic communications issued i
t exclusively for NPRs (the average is less than one per year).
5d. Region I Monthly Phone Calls: The Region I monthly phone call program to NPR licensees that has been conducted since April 1989 is proving success-ful. These calls have not been used as an opportunity to regulate but rather to exchange information, thus increasing understanding for the parties involved.
l 5e.
Information About NRC: The current NRC telephone directory and NRC l
organizational structure charts are provided to the Organization of Test, l
Research,andTrainingReactors(TRTR).
In addition, information on the i'
NRC organizational structure is provided as part of PDNPRDE's presentation at the annual TRTR meeting.
s 1
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5f.
Issuance of Operator License Certificates at License Renewal: The certificate is not the license but, as intended, an attractive visual acknowledgement of accomplishment for each candidate regarding the meeting l
of the rigorous requirements necessary for licensing by the NRC.
Renewal does not change the status of the license or the certificate, nor is there a time dimension to the certificate. Therefore, reissuing the certificate would not serve any purpose. Candidates who upgrade their status from j
operator to senior operator are issued new certificates as a result of the i
change in status. The cost and difficulty of tracking and issuing a l
renewal certificate are outside the bounds of the budget.
6.
NRC Knowledge of University Research: The NRC NPR project managers are generally aware of the research that is in progress at their facilities.
Information received by the MIT project manager on MIT's work on reactor i
control is provided to the NRR Instrumentation and Control System Branch to enhance awareness of current research. MIT hosted a visit at its facility for Region I staff to present the reactor end research programs in a non-inspection environment. This event was well attended and enhanced Region I's understanding of the MIT facility.
7.
Over-regulation: The staff's general response to over-regulation is addressed in Item 4.
MIT expressed concerns about our reouirement for copyright release on submittals to be reproduced and placed in the public document room. The particular article submitted by MIT was written by employees of EG&G Idaho and appeared in Nuclear. Technology which is copyrighted by the American Nuclear Society. Tnts requLrement for release is pursuant to NRC policy and copyright law.
Concerning NRC-administered requalification examinations as examples of over-regulation, a letter from Chairman Carr to Mr. A. Francis DiMeglio, Chairman of TRTR, addressed this issue as follows:
"It is recognized that the TRTR community has special needs and characteristics, and the staff has developed a proposal that incorporates the uniqueness of NPRs while still meeting regulatory requirements established in 10 CFR Part 55.
In addition, the staff is in the process of centralizing the NPR operator l
function to provide a unified and knowledgeable corps of examiners.
"The staff's plan for proceeding with requalification programs at NPR
[
facilities was discussed at your recent TRTR meetin9. A key factor in determining the extent and applicability of the NRC s requalification examination process is the relative risk to the public posed by NPRs. The staff's approach to NPR requalification examinations will parallel the i
inspection program in this regard.
If subsequent evaluations reveal a l
significantly lower level of risk associated with NPR operations, then i
both the inspection and the operator licensing programs will be appropriately modified. The Commission's goal is to ensure that NPR requalification programs are performance based and effective in maintaining
~
the level of operator skills and knowledge, particularly as they apply to areas pertinent to the protection of the public health and safety. The staff will provide the TRTR community the opportunity to participate in the i
l NPR requalification program development through pilot tests that will be t
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~4-conducted in 1990. An opportunity such as this was provided to the licensees of nuclear power reactors, and the licensees found that participation Worked well. The NRC is committed to conducting the NPR l
requalification program, but recogni:es that.it must be executed such that i
the fiscal and operational burden on NPRs is minimal. This necessity underscores the importance of your participating with the staff in developing the program through the pilot tests."
Additional Coments: MIT is an above-average NPR licensee that has a very good performance record and an ambitious research program in areas such as reactor control and PWR and BWR primary loop corrosion. The staff believes that it has been responsive in its dealings with and in addressing the concerns of the NPR community and MIT.
triginal Signed By:
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Ames M. Taylor James M. Taylor Executive Director for Operations cc: Chairman Carr Commissioner Roberts i
Commissioner Curtiss Commissioner Remick DGC SECY DISTRIBUTION
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. Russell, RI W
NRC PDR w/cy of incominig Local PDR w/cy of incoming JAmeta, IRM ED0f0004985 PDNP r/f i
EDO Reading GHolahan TMurley/JSniezek WTravers JPartlow OGC i
FMiraglia GPA/CA DCrutchfield SECY FGillespie DMossburg,PMAS(ED0f0004985) w/cy of incoming JTaylor MKrebs j
HThompson AAdams JBlaha EHylton EBeckjord,RES l
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- PREVIOUSLY CONCURRED
- PDNP:LA
- PDNP:PM
- PDNP:D
- Tech Editor
- AD:SP
- (A)D:DRSP EHylton AAdams:dmj SWeiss AAdams for WTravers GHolahan 12/22/89 12/22/89 12/22/89-12/22/89 12/26/89 12/26/89
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MEMORANDUM FOR:
Connissioner Rogers FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
STAFT VIEWS ON CONCERNS RAISED BY MIT In response to your memorandum of April 14, 1989, the staf has reviewed the concerns of the Massachusetts Institute of Technology (M)T) that were expressed in a letter you received during your visit to MIT. Th / staff's coments are numbered to match MIT's concerns:
1.
Procurement of Clean Heavy Water: The Defensp Programs Office of the Department of Energy (DOE-DP) instituted a b ti on shipment of heavy water to non-government f acilities. This ban is e result of continuing problems at the Savannah River plant. ThyDOEDivisionofUniversityand IndustrialPrograms(DOE-UP)hasexplorepwithnosuccessthepossibility of procuring clean heavy water from Canada in exchange for contaminated heavy water. The DOE-UP budget does t contain the necessary funds
($500,000) to acquire the_ heavy wate MIT requested on the open market.
DOE-UP continues to work on this pr lem, but no solution is anticipated I
in the naar future. The MIT reac r uses heavy water as a reflector. MIT is currently performing preventi maintenance on its reflector cooling l
system to reduce the possibilit of a coolant leak that could release l
tritium into the containment b 11 ding. The reflector heavy water system contains approximately 3 curids of tritium per liter. The total system inventory is approximately 4,000 curies. The staff believes that this situation does not present undue risk to the health and safety of the sublic. The MIT emergen plan addresses facility response to loss of
,1eavy water.
2.
Central Plutonium C -ection Facility: Many universities have some special l
nuclearmaterial(
) or source material that is not needed to su) port the current operation their facilities. Although it is true that t1ere are costs involved i the storage and safeguarding of this material, these costs represent small part of the total cost of the accountability program of the university. Although the majority of this material is not owned by DOE nd DOE has no obligation to accept it, DOE is actively l
developingybudgettoimplementtheprogram.
ans to collect this material. DOE has requested funding in next year'p MIT has recently returned a portion of its unwanted SNM to DOE. The staff believes that DOE is respondfgtothisproblemandthatCommissionactionisnotneeded.
3.
Ship nt-of Spent Fuel: There are problems concerning the shipment of spe fuel from MIT and the University of Missouri at Columbia (MURR).
T only shipping cask certified to transport the type of fuel used in these reactors has been withdrawn from use by its owner, the General l
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l i l Electric Company, for economic reasons. MURR anticipates submitting an application in January 1990 to the NRC to amend the BMI-1 cask licente to j
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add MURR and possibly MIT fuel. To allow continued operation, NRC Jias l
amended the MIT operating license authorizing increased fuel possession limits. MURR will require an increase in its fuel possession li t'in May 1990. MIT will exhaust fuel storage space in 1995 and MUR in December 1990. MIT's statement that NRC refuses to license cp ks for the L
shipment of spent fuel is not accurate. The NRC reviews and/ approves the design of spent fuel shipping casks. To obtain NRC approvp1 of a shipping i
cask, an applicant must submit a safety analysis report t)iat shows that the cask meets the requirements of 10 CFR Part 71. A cask design that meets
'i these requirements is issued an NRC Certificate of Compliance. After a design has been approved, any nunber of casks of that/ design can be fabri-i cated and used. Tie staff will continue to monitor his situation.
4 NRC Regionalization: As you are aware, problems ited by MIT with' I
non-powerreactor(NPR)regulationandinspecti were addressed by the Commission decision that the Non-Power Reactor Decommissioning, and Environmental Project Directorate (PDNPRDE) fil participate significantly in the NPR inspection program and take a st ng leadership role in all matters affecting NPRs.
5L-NPR Inspectors: This concern is addres d in Item 4.
l Sb. Availability of Operator Licensing E aminations:
Because of the limited resources available to meet all lic sing requests, it is not possible to schedule more than one trip per yep to administer operator licensing l
examinations for NPRs.
In some cases, the NRC has been able to accommodate additional examination requestsjfrom licensees of NPRs. This support will continue on a specific case bas'is according to competing needs at the time of such a request.
Sc. Limiting Corrective Action. This comment refers to a unique situation that applied only to Cin hem. Cintichem representatives and the NRC staff agreed on a proce re to allow NRC inspectors access to the facility.
-This access was require because Cintichem produces isotopes from separated fission products on /24-hour-a-day schedule. The staff carefully analyzes the need for generi action at NPRs and limits action only to those facilities direct 1 affected by a particular issue. The success of this l
procedure is ref eted in the small number of generic communications issued exclusively for prs ~ (the average is less than one per year).
5d.
Region 1 Mon hly Phone Calls: The Region I monthly phone call program to NPR licensee}s that has been conducted since April 1989 is proving success-ful. The calls have not been used as an opportunity to regulate but rather exchange information, thus increasing understanding for the partie involved.
Se, Inf tion About NRC: The current NRC telephone directory and NRC or anizational structure charts are provided to the Organization of Test, Rsearch,andTrainingReactors(TRTR).
In addition, information on the NRC organizational structure is provided as part of PDNPRDE's presentation at the annual TRTR meeting.
1
5f.
Issuance of Operator License Certificates at License Renewal: The certificate is not the license but, as intended, an attractive vis al acknowledgement of accomplishment for each candidate regarding thf meeting of the rigorous requirements necessary for licensing by the NRC/ Renewal does not change the status of the license or the certificate.joor is there a time dimension to the certificate. Therefore, reissuing t>e certificate would not serve any purpose. Candidates who upgrade their status from operator to senior operator are issued new certificates afa result of the change in status. The cost and difficulty of tracking apd issuing a renewal certificate are outside the bounds of the budget.
6.
NRC Knowledge of University Research: The NRC HPR p ject managers are generally aware of the research that is in progres t their facilities.
Information received by the MIT project manager o IT's work on reactor control is provided to the NRR Instrumentation a Control System Branch to enhance awareness of current research. MIT sted a visit at its facility for Region I staff to present the rea or and research programs in a non-inspection environment.
This event pas well attended and enhanced Region I's understanding of the MIT facility /.
7.
Over-regulation: The staff's general response to over-regulation is addressed in item 4.
MIT expressed concerns about our requirement for copyright release on submittals to be produced and placed in the public document room. The particular artic1 submitted by MIT was written by employees of EG&G Idaho and appeared n Nuclear Technology which is copyrighted by the American Nuclear Society. This requirement for release is pursuant to NRC policy nd copyright law.
Concerning NRC-administered re alification examinations as examples of over-regulation, a letter frop Chairman Carr to Mr. A. Francis DiMeglio, Chairman of TRTR, addressed Ahis issue as follows:
"It is recognized that the TRTR community has spe ial needs and characteristics, and the staff
(
has developed a proposal at incorporates the uniqueness of NPRs while still meeting regulatory requirements established in 10 CFR Part 55.
In addition, the staff is n the process of centralizing the NPR operator function to provide a nified and knowledgeable corps of examiners.
"Thestaff'splanJrproceedingwithrequalificationprogramsatNPR facilities was di cussed at your recent TRTR meeting. A key factor in determining the xtent and applicability of the NRC s requalification examination pr ess is the relative risk to the public posed by NPRs. The staff's appro h to NPR requalification examinations will parallel the j
inspection p ogram in this regard.
If subsequent evaluations reveal a significan y lower level of risk associated with NPR operations, then both the spection and the operator licensing programs will be approprijitely modified. The Connission's goal is to ensure that NPR requal fication programs are performance based and effective in maintaining the 1 el of operator skills and knowledge, particularly as they apply. to area pertinent to the protection of the public health and safety. The st will provide the TRTR connunity the opportunity to participate in the NP requalification program development through pilot tests that will be
.-.~
. conducted in 1990. An opportunity such as'this was provided to the licensees of nuclear power reactors, and the licentees found that 3
participation worked well. The NRC is comitted to conducting the PR i
requalification program,-but recognizes that it'must be executed ch that the fiscal and operational burden on NPRs is minimal. This necessity underscores the importance of your participating with the staf 'in developing the program through the pilot. tests."
i Additional Coments: MIT is an above-average NPR licensee tha,t has a very I
goodperformancerecordandanambitiousresearchprogramin/staffbelieves reas such as reactor control and PWR and BWR primary loop corrosion. The that it has been responsive in its dealings with and in addressing the concerns of the NPR comunity and MIT.
James M. TayAor Executive pirector for Opefations cc: Chairman Carr Comissioner Roberts Comissioner Curtiss Comissioner Remick l
OGC i
SECY DISTRIBUTION Central file Bernero, NMSS NRC PDR w/cy of incominig WRussell, RI Local PDR w/cy of incoming JAmeta, IRM ED0#0004985 PDNP r/f ED0 Reading CHolahan
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[GT4985)
- PREVI SLY CONCURRED
- PDNP:LA
- PDNP:PM
- PDNP:D
- Tech Editor
- AD:SP
- (A)D:DRSP EHylton AAdams:dmj SWeiss AAdams for WTravers GHolahan 12/22/89 12/22/89 12/22/89 12/22/89 12/26/89 12/26/89
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A MIT is an above-average NPR licensee that has a very
\\j'dditional Comments:ood performance record and an ambitious research p r6 actor control and PWR and BWR primary loop corrosion. The staff believes th44 it has been responsive in its dealings with and in addressing the conc rns of the NPR community and MIT.
James M. Taylor Executive Director cc: Chairman arr OGC for Operations Commissiongr Roberts SECY DISTR NRCPDRw/cyofin\\
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UNITED STATES D
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NUCLEAR CEEULATORY COMMISSION f
WASHINGTON, D. C. 20666 EDO Princioal Correspondence Control
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DUE: 12/ 22/89 EDO CONTROL: 0004985
'l DOC DTs' 04/14/09 FINAL REPLY:
Ccmnissioner Rogers
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~TO:
Victor Stello,.Jr.,
FOR SIGNATURE-OF
i ExCcutive Director
.DESC:
ROUTING:
REQUEST VIEWS ON PAPER FROM JOHN A.
BERNARD AND Taylor OTTO K. HARLING, MIT, ON ISSUES RE UNIVERSITY Thompson RESEARCH REACTORS Blaha Beckjord, RES DATE: 12/13/G9-Bernero, NMSS Russell, RI ASSIGNED TO:
CONTACT:
'SPECIAL INSTRUCTIONS OR REMARKS:
MEMO WAS NOT RECEIVED IN~EDO UNTIL 12/12/89.
NRR RECEIVED: DECEMBER 13, 1989 ACTION:
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