ML20005G850
| ML20005G850 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 04/14/1989 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20005G848 | List: |
| References | |
| NUDOCS 9001230192 | |
| Download: ML20005G850 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION j'
W ASHIN GT ON, D.C. 205$b
'+,......o April 14, 1989 OF FICE OF 1HE i
COMMi$SIONE R t
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l MEMORANDUM FOR:-
Victor Stello, Jr.
Executive Director for Operations 1
FROM:
Kenneth C. Rogers BUBJECT:
LETTER FRCM MIT RESEARCH REACTOR i
Attached is a letter I received during a recent visit to MIT.
I would like staff's views on the concerns raised in this
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1etter.
I am particularly interested in the issues which have generic significance.
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Kenneth C. Rogers Commissioner cc:
Chairman Zech Commissioner Roberts l
Commissioner Carr Commissioner Curtiss
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9001230192 900109
{DR ADOCK0500go 100---004985
POTENTIAL POSITIVE NRC ACTIVITIES CONCERNING UNIVERSITY RESEARCll REACTORS I
The activities listed below are examples of regulatory and/or administrative actions that would both funher reactor safety and facilitate the operation of university 'research reactors:
- l. Procurement of Clean D Q: In September 1988 the Depanment of Defense imposed a 2
ban on the shipment of D O to non DOD facilities. 'Ihe MIT Reactor nSeds to replace 2
its D 0 reflector because tritium levels in the D O are making required maintenance 2
2 very difficult. Also, all preventive maintenance is being deferred. DOE is making
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arrangements to procure clean D O from Canada in exchange for our contaminated 2
D 0. Anything that NRC could do to assist DOE in this process (simplify shipping 2
regulations, for example) would be of benefit. The longer the delay, the greater the likclihcal of a radiological release.
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- 2. Central Pluto.nipm Collection Facility.: Many universities have small (milligram) quantities of plutonium left from research perfonned decades ago. The universities must spend money inventorying and safeguarding it. NRC must spend money inspecung it. None of this is logical because the plutonium serves no Function. At l
MIT, we have been trying unsuccessfully to dispose of milligram quantities for years.
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The establishment of a central collection site, perhaps one of the DOE facilities, would save NRC and universities significant expense without, we believe, adding much to DOE costs.
- 3. Shioment of Spent Fuel: The United States and IAEA have expressed much concern about weapons proliferation. One means of enhancing nonproliferation would be to
. simplify the process for returning spent fuel to DOE-owned te processing centers. Yet, our society as a whole is making tlus extraordinarily difficult. Ln panicular, f
(a)
State and local ;;overnments issue restrictive regulations that make the shipment of spent fuel need essly difficult and therefore less safe.
(b) NRC refuses to license casks for the shipment of spent fuel.
Regulatory relief in this area would result in less fuel being present in the cycle at at t
any given time. [ NOTE: We believe that this problem is even worse in Europe and that particular attention should be given to facilitating the return of U.S. fuel sent l
abroad.)
- 4. NRC Regionalization: Overall, the decision to establish regional offices has been of benefit. liowever, conflicts sometimes arise between NRC IIcadquarters in 1
Washington and the Region. On three occasions, MIT has been told by the Region that a provision in our emergency or security plans was invalid even though NRC 11eadquaners had approved it. We spend many man months and,in the case of the emergency plan, more than a man year, on these plans. Once approved by 11eadquaners, we feel that the provisions in those plans should be accepted by the Region. (NOTE: The problems arise when the plan contains an exemption from a particular regulation.)
- 5. Regulation of Research Reactors as Power Reactors: Research reactors have a much smaller source term than do power reactors. Also, the performance of research requires
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2-i ficxibility. - Yet too often research reactons are being judged by power reactor standards.
. I Actions that would be of benefit include:
4 (a) Assign inspectors to research reactors who are familiar with research reactors.
Power p"lant inspectors should not be arbitrarily assigned a research reactor as an
" add-on responsibility..
(b) Make licensing exams more readily available. Currently NRC budgets only allow one exam per year. (NOTE: Region One has been helpful to us in getting more l
than one when absolutely necessary. But, that is not the same as knowing that ye; 91d have two exam dates per year.)
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Limit corrective action to the facilities that warrant it. For example, we 1
l understand that one facility unduly restricted access by NRC inspectors. As a result, NRC has now obtained keys to that facility and may be considering doing t
the same at other facilities. MIT has never restricted access to inspectors. We feel quite strongly that security would be decreased if operators and police knew that a total stranger might legitimately have direct access.
(d) Region One is desirous of establishing monthly phone calls to better inform itself of activities at MIT. We have agreed to try this. If the phone calls are for information exchange, they will be useful and perhaps even a very positive i
development. But we are concemed that these calls may ultimately add a layer of regulauon.
(e) Complementing the Region's desire to become more knowledgeable of university reactors, we'd hke to know more about the organization of the Region and also of the Headquarters. Providing each facility with an NRC phone book once a year would be of assistance. Also, more frequent distribution of organization chans would help.
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NRC's decision to issue printed license certificates to operators was a big morale l
booster. How about issumg a new certificate whenever a license is renewed?
- 6. @C Knowledge of University Researth: One of the difficulties in implementing new concepts on power plants is that regulatory authorities are often unfamiliar with the concept and therefore unwilling to approve it. For example, this is true of most recent progress in reactor control. NRC could benefit by having its inspectors become cognizant of new concepts as they are developed. For example, MIT has generic supervisory algorithms, predictive laws, and rule based controllers. We'd be delighted to discuss these with anyone who expresses interest. Perhaps the telephone exchange f
(item 5(d) above) will lead to this. (At present, all that gets discussed during on site
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inspections is 10 CFR 50.59 compliance.)
- 7. Over-regulatiQn: The Document Control Desk is requiring copyright releases on published papers submitted as part of safety evaluations. The release is required even on papers written by government employees. But, by law, these can't be copyrighted l
because the work was performed with federal tax dollars. The net result is a needless delay in processing the safety evaluation.
'i Another example is the NRC decision to have NRC examiners re-examine die operators of University Reactors every six years. We have operated for decades by admimstering our own requalification exams. Why regulate a problem that doesn't exist? (NOTE:
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t We understand that NRC may be reversing ~ this decision.1If so, it is a positive i
development.)
The above are some suggest!ans for improving both safety and case of operation.
i Please recognize that we do appreciate the dedication of the Staff of both Region One -
- i and NRC Headquarters. NRC personnel are far more professional than those of some other agencies with which we've dealt. However, also please recognize that University reactors are underfunded and that our' staffs have a wide variety of responsibilities.
New regulations, particularly unwarranted ones, can cause major perturbations that will decrease safet,y by taking the time of the most senior people. Also, in some areas such as cask licensing, the net effect of NRC regulations is to lessen the safety of the overall fuel cycle by needlessly prolonging the time that spent fuel is kept on site, i
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- We suggest that NRC fund research on the impact of new regulations: determine what
'i existed, what changes were actually inplemented (as opposed to merely occurring on paper), and at what cost. ' Also, was the impact on the overall safety of the facility or process in question positive?
l Sincerely,.
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John A. Bernard, Ph.D.
. Director of Reactor Operations-(617) 253-4 2
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Otto K. Harling, Ph.D.-
Director, MIT Nuclear R actor Laboratory (617) 253-4201'-
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