ML20008F053
| ML20008F053 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor, 07100164 |
| Issue date: | 02/26/1981 |
| From: | Lisa Clark MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20008F054 | List: |
| References | |
| NUDOCS 8103120142 | |
| Download: ML20008F053 (2) | |
Text
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NUCLEAR REACTOR '.ABORATORY i
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- 6 Feb ruary 26, 1981 U. S. Nuclear Regulatory Commission g8 I A h
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?E ATTN: Charles E. MacDonald, Chief
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Transportation Certification Branch O
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h-l' Quality Assurance Program undar,10CFR71l,.l5'!*,
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/O License R-37, Docket 50-20 b
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Dear Mr. MacDonald:
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UfN.ac This letter is in response t.) your letter of October 31, 1930 wh ch.
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requested additional information concerning MIT's quality assuranceE yggh7_
program for radioactive material shipping packages.
4 Ogg In order to comply with your request, further changes have been
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,,y made to Chapter 11, Quality Assurance, of the SAR (Safety Analysis Report for the MIT Research Reactor (MITR-II), Document MITNE-115, October 22, 1970, as amended).
Section 11.1, Organization, has been entirely rewritten to include the organization chart and other information requested in items lA-5A, f A and 9A.
It should be pointed out that SAR Chapter 11 was first pre-pa ad to comply with 10 CFR 50.34 and Appendix B, Part 50.
It has been our purpose to make the revisions in such a way as to respond to your requests for QA information pertinent to shipping packages without altering the intent of the chapter as it applies to QA for reactor opera-tion, maintenance, etc.
We have reviewed again items llA, 13A - 16A and 22A - 25A and the pertinent paragraphs of 10 CFR 71, including Appendix E.
These appear
.to relate to the design and procurement of special shipping containers for uhich licenses must be obtained pursuant to 10 CFR 71, Subpart B.
We foresee no such activities and, therefore, have inserted a statement in revised Section 11.2 to the effect that the program will be further revised in the future if any such activities are undertaken.
With regard to item 2SA, it is requested that you reconsider the need for repeating in Chapter 11 the requirements that already appear in DOT and NRC regulations, specifically 49 CFR 173.22(b), 10 CFR 20.205(a),
and 10 CFR 73.67(e).(3) and (g) (3).
If anything is required, a state-ment that we shall comply with DOT and NRC regulations.would appear more p,
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appropriate.
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. Charles E. MacDonald, Chief t
Finally, with regard to bypassing of required inspections, tests and other critical operations, we have a written procedure (#1.5 of the MIT Reactor Administrative Procedures) covering temporary changes to procedures.
Such changes must not alter the intent of the procedure, e
must be approved by two members of the reactor staff, at least one of whom must hold a Senior Reactor Operator License, and both must initial the change. The revision at the bottom of p.11.6-1, submitted with my letter of August 5, 1980, was intended to respond to this item; it has been further revised and is resubmitted herewith.
The first two pages of Chapter 11 should be replaced by the enclosed
. five pages no.11.1-1 through 11.2-2.
A revised page 11.6-1 is also enclosed, and Fig. 11.1-1 should be added at the end of Chapter 11.
If further information is desired in connection with the above, I shall~be pleased to discuss it with you or menbers of your staff.
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Sincerely, b
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Lincoln Clark, Jr.
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LC/sbs-MIT Reactor Safeguards Committee cc:
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7 copies of pp. 11.1-1 through 11.2-2,
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