ML20029D352
| ML20029D352 | |
| Person / Time | |
|---|---|
| Site: | 07000938 |
| Issue date: | 04/29/1994 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20029D349 | List: |
| References | |
| NUDOCS 9405050194 | |
| Download: ML20029D352 (16) | |
Text
...
s J.
- Rf CW
.7 t
UNITED STATES X
j NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 20665-0001
\\...+/
APR 2 91594 DOCKET:
70-938 LICENSEE:
Massachusetts Institute of Technology (MIT)
Cambridge, MA
SUBJECT:
SAFETY EVALUATION REPORT FOR LICENSE RENEWAL, SNM-986 1.
BACKGROUND Since~ 1966, MIT's Materials License SNM-986 has authorized possession and use of U-235 contained in enriched uranium fuel rods and foils for_ subcritical reactor lattice experimental research. The license was renewed in 1969 and 1985.
During the term of the 1985 renewed license, two amendments were issued.
The current license was due to expire on November 30, 1990; however, on October 25, 1990, MIT submitted an application for renewal. Accordingly, the license has remained in effect in accordance with the timely renewal provision of 10 CFR 70.33(b).
The renewal application references the 1984 renewal application and the two subsequent amendments and includes additional updates to the application.
Nuclear Regulatory Commission staff-reviewed the renewal application and issued a request for additional information on August 19, 1993.
MIT provided responses on October 12, 1993, and January 21, 1994. NRC staff also reviewed parts of MIT's Reactor License R-37 and Materials License 20-01537-02 for consistency with the provisions and conditions of SNM-986.
II. DISCUSSION A.
Scope of Review The safety review of MIT's renewal application included a review of the i
application dated October 25, 1990, and supplements dated October 12, 1993, and January 21, 1994, and the compliance history of the licensee. The topics of review included an evaluation of the applicant's organization and administration and radiation safety, nuclear criticality safety, and environmental protection programs.
The renewal application was discussed with NRC Region I Inspectors, and their comments are addressed in the review.
MIT's site was visited by licensing staff.
The site visit included both radiological safety and environmental protection concerns.
The following sections describe MIT's possession limits, authorized activities, organization, and safety programs, along with additional license conditions developed by the NRC staff, 9405050194 940429 PDR ADOCK 07000938 C
_.. ~.... _, - _.. - _
.s.
l AFB 2 91994 2
B.
Possession Limits The maximum quantity of special nuclear material (SNM) to be possessed and used is identified by isotope, enrichment, chemical and physical forms, and mass in grams.
MIT possesses the following special nuclear material:
BYPRODUCT, SOURCE, CHEMICAL AND/0R MAXIMUM AMOUNT THAT AND/0R SPECIAL NUCLEAR PHYSICAL FORM LICENSEE MAY POSSESS MATERIAL AT ANY ONE TIME UNDER THIS LICENSE A.
Uranium enriched to UO2 pellets, clad in 23,000 grams of U-235 less than 2.0 wt% in steel, aluminum, or the U-235 isotope zircaloy B.
Uranium enriched to Metal or U0, slugs,
- 9,000 grams of U-235 5 2.0 wt% in the foils, pellets and U-235 isotope other shapes, clad and unclad C.
Uranium enriched to Solid or solution 350 grams of U-235 less than 93 wt% in including material in the U-235 isotope fission chambers D.
Plutonium Pu-Be neutron source 197 grams and Pu-Al neutron filter E.
Plutonium Solid alpha source 80 micrograms F.
Plutonium Solid, foils, pellets
- 172.0 grams G.
Natural uranium Solid and solution 2,515 kilograms H.
Depleted uranium Any
- 238.2 kilograms 1.
Any byproduct Unseparated Quantities produced material unseparated during irradiation contained in any of the above J.
U-233 Solid
- 2 milligrams
.,m._
-..-....,u
,m....,,-~......-.m
.-...--r...-
- m....
for storage only 58.2 kilograms for storage only
APR 2 91994 3
MIT has tentative plans to transfer some of the fuel-type materials from the SNM license to the Reactor License R-37.
This material transfer would require an amendment to License R-37 to add these materials and to SNM-986 to delete them. As of the date of this renewal, MIT has not submitted an amendment request for either license, therefore, the possession limits are unchanged from the previous license.
Section 1.7.13 of the application stated that several of these materials were no longer needed and would be transferred to another licensed recipient.
Transfer was anticipated within a year of the 1984 renewal request. However, MIT has not been successful in transferring any of these materials and has requested that they remain in the license.
Staff recommends that a license condition be added that requires the licensee to provide for transfer or disposition of these materials within 6 months of the date of this license renewal.
Accordingly Condition 23 reads as follows:
The licensee shall submit a written plan for the transfer, disposition, or use of stored materials, within 6 months of the date of this renewal.
These materials are the following:
a.
9,000 grams of U-235 metal or U0, up to 2.0 weight percent, 2
in solid slugs, foils, pellets and other shapes, clad and unclad.
b.
12 grams of plutonium metal in solid and foils clad in aluminum.
c.
159 grams of plutonium, and 58 kilograms of depleted uranium, in co-precipitated Pu0 -U0, solid and pellets clad in 2
2 aluminum tubing, d.
5 milligrams of plutonium metal in solid foil accelerator
- targets, e.
200 grams of depleted uranium metal foils, f.
2 milligrams of U-233 i
C.
Authorized Activities and Place of Use MIT uses the material for research and teaching purposes at various campus l
locations.
To authorize these activities and places of use, the following conditions are recommerded:
I r
m
- m..
/
APR 2 919M 4
Authorized place of use:
The MIT Campus, Cambridge, Massachusetts; Bates Linear Accelerator, Middleton, Massachusetts; and the Lincoln Laboratory, Lexington, Massachusetts.
Authorized use:
For use in accordance with statements, representations, and conditions contained in the application dated October 25, 1990, and supplements dated October 12, 1993, and January 21, 1994.
The activities for which the licensed material is used are described in Section 1.7 of the July 1984 renewal application.
These activities include the following:
1.
Neutron flux conversion 2.
Experimental research on reactor lattices 3.
Neutron flux measurements 4.
Alpha sources for calibration of alpha detectors 5.
Reactivity measurement associated with fissile materials 6.
Fission chambers for detection and measurement of neutrons 7.
Plutonium-beryllium neutron sources 8.
Plutonium neutron filters 9.
Reactor physics training
- 10. Depleted uranium for neutron shielding
- 11. Electrical properties of insulators and semi-conductors
- 12. Uranium in laboratory solids and solutions
- 13. Possession for storage and disposal only
- 14. Depleted uranium plates for tritium adsorption Irradiation and experimental use of the licensed material at the MIT reactor is authorized under License R-37.
The construction permit for the reactor was issued on May 7, 1956, and the operating license was issued on June 9, 1958.
License R-37 is due to expire on May 7, 1996, but may be extended until June 1998, to recapture the construction period. Material handling before or after use in the reactor is in accordance with the conditions of SNM-986.
Accordingly, License Condition 11 reads as follows:
This license does not authorize the insertion of licensed material into a nuclear reactor.
Other than sealed sources, a limit of one ef fective kilogram exists for operations outside the research reactor.
~
/.
APR 2 91994 5
D.
Organization Figure I-2.1 of the application shows the lines of responsibility and authority for possession and use of radioactive materials under SNM-986.
The primary responsibility for safety is assigned to the department and laboratory heads and their supervisory personnel. Within the Environmental Medical l
Service of the Medical Department, the Campus Radiation Protection Officer (RPO) provides advisory and technical services necessary for the implementation of MIT's Radiation Protection Program.
The Reactor Radiation Protection Officer, who reports to the Director of Environmental Medical Service, is responsible for the radiation protection program at the reactor site.. The RRP0 does not report to the Director of Reactor Operations, indicating that the responsibility for radiation protection is separate from the responsibility for utilization of radioactive materials.
NRC staff requested that the authority of the Reactor or Campus RP0 to halt any operation, which is believed to threaten the health and safety of personnel, be explicitly stated.
In the October 12, 1993, response to this comment, MIT stated that the Campus RP0 has shutdown authority and delegates such to the Reactor RPO. NRC staff has determined that this response is sufficiently explicit.
Responsibility for criticality safety and material accountability is assigned to the officers under the Director of Reactor Operations.
The Nuclear Criticality Safety (NCS) program evaluation is discussed in Section J of this report.
The Campus RP0 is accountable for all byproduct material, except that held under the Reactor License R-37, which is the responsibility of the Director of Reactor Operations.
Two committees, the Reactor Safeguards Committee and the Radiation Protection Committee, have responsibility for the safety review of the utilization of SNM.
The members of both committees are appointed by the MIT President.
The Reactor Safeguards Committee is responsible for nuclear safety for the MIT Research Reactor. This Committee has responsibility for safety reviews of all utilization of materials-under the SNM license when the material is used on the reactor or its use or storage within the reactor restricted area presents safety considerations with regard to the reactor.
The Radiation Protection Committee is comprised of the Radiation Protection Officer and faculty members with technical backgrounds.
The Committee is responsible for establishing a radiation protection program, reviewing the program on an annual basis, assuring compliance with federal, state, and local regulations for radiation protection, and approving the use of licensed material by the experimenters.
/
l I
FR 2 91994 6
NRC staff requested an updated membership list for the Reactor Safeguards Committee that included education and experience statements for new members.
Also, the education and experience statement for the Director of Reactor Operations should be updated to show this new position.
By letter dated January 21, 1994, MIT provided the statements and a revised membership list for the Reactor Safeguards Committee.
NRC staff has determined that the cumulative qualifications of the Committee are sufficient to perform the Committee's functions.
Since most experiments with licensed material are conducted within the reactor area, the workers' radiation exposure and radioactive effluents data is reviewed by the Reactor Safeguards Committee, established under License R-37.
For workers outside the reactor area, exposure trends are reviewed by the MIT-
~
RP0.
E.
Technical Qualifications MIT has the necessary technical staff with the proper qualifications to administer an effective and safe radiological safety program.
Safety-related staff at the MIT reactor are appointed by the Director of the Nuclear Reactor Laboratory.
Staff in both the Campus and Reactor Radiation Protection Offices are appointed by the Director of the Medical Department.
Minimum technical qualifications for safety-related staff at the reactor, including the Director of Reactor Operations, Superintendent, RRP0, Shift Supervisor, and Reactor Operator, are specified in Technical Specification 7.3 of License R-37.
The collective qualifications of the Reactor Safety Committee are specified in Technical Specification 7.5.2(e) of License R-37.
The specified minimum qualifications are adequate to assure that staff are also qualified to perform their assigned functions with respect to materials used under SNM-986.
j The Radiation Protection Committee is comprised of faculty members who work with radioactive material, the Campus and the Reactor Radiation Protection Officers, Assistant RPGs, and a staff member.
Minimum technical qualifications for the RP0s are specified in Condition 12, which reads as follows:
The minimum technical qualifications for the position of Radiation Protection Officer shall be a bachelor's degree in science or engineering, completion of a basic radiation safety course, and at least 2 years of work experience in radiation protection.
MIT's current RP0 exceeds these minimum qualifications.
i APR 2 91994 7
F.
Operating Procedure MIT has committed to using a descriptive operating procedure in conducting work involving licensed material, as approved by the Radiation Protection Committee or the Reactor Safeguards Committee, as appropriate.
l According to this operating procedure, an experimenter makes a proposal for use of licensed material, in accordance with an authorization form and a l
written handling procedure. The proposal is then reviewed by the Radiation 1
Protection Committee. The committee can approve the proposal as prepared, approve with additional precautions / steps added, or disapprove it.
There are three SNM uses at MIT:
instrument test sources in the Bates Lab, fission chambers (for neutron flux), and the Californium source in the Fusion Center.
This review procedure complies with Condition 13, which reads as follows:
The licensee shall prepare and follow a descriptive operating procedure in conducting all work involving the licensed material. The procedure and its changes shall be approved bv the Radiation Protection Committee.
G.
Audits and Inspections MIT has committed to having th,
_,.iation protection program evaluated and reviewed by the Radiation Protection Committee on an annual basis.
MIT has also committed to conducting quarterly inspections in accordance with a written procedure, which includes provisions to provide ccrrective actions to the Radiation Safety Committee. Accordingly, Condition 14 reads as follows:
The licensee shall conduct quarterly inspections of radiation safety activities at all work areas.
The inspection shall be conducted in accordance with a written procedure, and the findings of the inspection with needel corrective actions shall be submitted in a timely fashion to the supervisor ti the inspected area, as well as the Radiation Safety Committee.
By letter dated August 19, 1993, NRC requestd that Section 2.8 of the application include a mechanism to assure tha.t any corrective actions identified during the quarterly inspections and annual audits are taken in a timely manner.
By letter dated January 21, 1994, Mll com.nitted to presenting audit results to the appropriate committees at their next meeting and reporting any deficiencies, with the corrective action taken or recommended.
The staff recommends that the following condition (Condition 20) be added to incorporate this commitment:
4 t
i AFP, 2 9 19M l
8 Quarterly administrative audits and annual independent audits shall be presented at the next meeting of the Radiation Protection Committee or the Reactor Safeguards Committee, as appropriate.
Any deficiencies shall be reported to the appropriate committee with the corrective action taken or recommended.
H.
Personnel Training Workers using radioactive material are required to participate in a radiation safety training course presented by the Radiation Protection Office.
In addi-tion, in accordance with Condition 15, Health Physics Technicians are required to participate in annual refres'er training, and the records of the training are to be maintained for 2 years.
During the July 1993 site visit, MIT stated that it would like to delete the condition. MIT was informed during the visit and by letter dated August 19, 1993, that an amendment request should be submitted to delete the condition.
By letter dated January 21, 1994, MIT stated that it will address this training issue when it amends License R-37.
Accordingly, Condition 15 will remain in the license and reads as follows.
The licensee shall provide refresher training to the Health Physics Technicians every 12 months. The records of the training shall be kept at least 2 years.
I.
Radiation Safety Control Control of Personnel Exposure Protective cladding of aluminum and steel encapsulation is used to preclude releases of uranium oxide formed on the surface of shielding.
External exposure of personnel is controlled and evaluated using personnel dosimeters as required by 10 CFR Part 20.
The dosimeters are read and evaluated on a monthly basis. The majority of the employees' exposures are contributed to work associated with the reactor license.
To protect workers from excessive internal exposure, work involving dispersible material is conducted in a ventilated hood; an air sampling program monitors airborne concentration of radioactivity; surveys are conducted to detect the presence and extent of radioactive contamination; i
protective clothing is issued; a bioassay program monitors and detects radionuclide deposition or buildup; and procedures, including action levels, are established for investigating and decontaminating contaminated surfaces.
A l
APR 2 9 1 M i
I 9
l Control of Contamination The laboratories that use licensed material are surveyed routinely by using an instrument which must be calibrated at least annually.
The survey frequency varies from daily to quarterly, depending on the potential hazard presented by the presence of surface contamination.
The decontamination action levels are in accordance with NRC " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," April 1993.
MIT has requested authorization for the possession and use of plutonium materials as sealed sources and committed to coaducting routine leak tests on the sources in accordance with the procedures that were developed by the NMSS staff.
l Criteria for the release of equipment and materials from the plant site or to l
clean areas onsite is specified in Condition 16, which reads as follows:
Release of equipment, facilities, or packages to the unrestricted area or to uncontrolled areas onsite shall be in accordance with the attached " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993.
J.
Nuclear Criticality Safety At the three MIT locations, with the exception of within the reactor restricted area at the Cambridge campus, quantities of SNM are administratively limited to those specified in 10 CFR 70.24(a) for which a nuclear criticality alarm is required. With this limitation on the j
distribution of SNM, the requested safety controls outside the reactor restricted area need only provide assurance that the 10 CFR 70.24(a) limits will not be exceeded.
Inside the reactor restricted area, administrative procedures and engineered controls are utilized to ensure NCS.
Additional information regarding the NCS within the reactor restricted area is provided in Section 1.C.
Nuclear Criticality Safety Proaram To ensure NCS both inside and outside the restricted area, MIT has established an NCS program that includes organization, administrative controls, technical specifications, audits, and personnel training.
i
d.
/PR 2 91994 10
- 1.
Organization i
The responsibility for the NCS of fuel handling and storage activities in the reactor restricted area resides with the Criticality Officer (CO).
The C0 provides advisory and technical services regarding the use, storage, and shipping of SNM where criticality considerations are involved. To ensure the adequacy of the NCS reviews within the reactor restricted area, the Reactor Safeguards Committee has the responsibility'to review and approve, prior to implementation, new operating plans and' policies, significant modifications to existing activities, and new experiments involving significant changes to procedures.
The application does not specify the minimum qualifications for the CO.
Therefore, to ensure that the NCS reviews are performed by qualified personnel, the staff recommends Condition 17 be continued as follows:
The minimum qualifications for the Criticality Officer or for the individual responsible for the nuclear criticality safety analyses, shall be an accredited college degree in physical sciences or engineering, plus a minimum of 3 years' nuclear safety experience.
The nuclear experience shall include 1. year in outside-of-reactor nuclear criticality safety.
.(
To ensure that the Reactor Safeguards Committee is qualified to review the NCS evaluations performed by the CO, the staff recommends the following condition:
)
~
At least one member of the Reactor Safeguards Committee, other than the Criticality Officer, shall be qualified to evaluate nuclear criticality safety when the initial evaluation was prepared by the Criticality Officer. This member shall meet the minimum qualifications of the Criticality Officer.
MIT has given the Radiation Protection Committee the responsibility to ensure that only deminimis quantities of SNM, less than those defined in 10 CFR 70.24 (a), are utilized outside the restricted area in any one of the three locations.
The organizational structure, in conjunction with the imposed license conditions, is 7.:ceptable from an NCS standpoint because (1) criticality evaluations are performed by a qualified reviewer to identify the hazards for all operations involving SNM, and.(2) the independent review of the criticality evaluations assures a necessary level of quality assurance.
I
)
- -.. -. -. -. -. _.... -. _.. ~,., -. _, -
4 APR 2 91994
{
1 11 2.
Audits To ensure that the license conditions, administrative conditions, technical i
specifications, and procedures are adhered to, MIT has established an audit program that provides assurance that outside-of-reactor NCS requirements are met. The program includes the following The quarterly administrative audit by the Director of Reactor Operations and/or Reactor Superintendent i
includes the NCS of SNM in use and in storage.
i The annual physical inventory of SNM includes an inspection to assure that labeling, posting, and criticality requirements are J
met.
l The annual independent audit, by one or more individuals who are not in the reactor operations chain of command, of the operating records includes an audit related to NCS.
The staff has reviewed the audit program and concludes that there is reasonable assurance that the program is adequate because elements of the NCS program are reviewed on a timely basis, thus identifying potential problematic areas before incidents occur.
3.
Technical Specifications To ensure an adequate level of NCS, MIT has committed to using the double contingency principle, which states that SNM storage and experiments j
incorporate sufficient factors of safety so that two unlikely, independent, and concurrent changes in conditions are required before a criticality accident is possible.
4.
Personnel Training To ensure that personnel utilizing SNM within the reactor restricted area are cognizant of NCS hazards, the staff recommends Condition 21. The condition shall read as follows:
i l
Personnel involved with special nuclear material activities within the reactor restricted area shall i
receive appropriate criticality safety instruction.
I l*.
APTs 2 91994 4
l 12 Nuclear Criticality Safety Analysis Below is a summary of the safety analysis presented in the application.
1.
Outside the Reactor Restricted Area l
NCS is provided outside the reactor restricted aret by limiting the quantity l
of SNM in any building outside the restricted area on the Cambridge Campus to less than the minimum required to form a critical mass independent of the i
degree of water moderation and/or water reflection.
The Accountability l
Officer has responsibility for ensuring that the quantity of SNM does.not exceed the limits specified in 10 CFR 70.24(a).
2.
Inside the Reactor Restricted Area inside the reactor restricted area, MIT conducts a number of activities, including storage of SNM, thermal-to-fast-flux convertors, thermal physics experiments, and laboratory activities involving solids and solutions. NCS for these activities is discussed below.
Thermal-to-Fast-Flux Convertor NCS for the 4-by 5-foot thermal-to-fast-flux convertor, that is used in the reactor thermal column, is provided by (1) maintaining a specified arrangement of rods such that the effective multiplication factor will remain less than 0.7 even in the event of flooding and (2) impiementing controls to preclude flooding (no sprinkler system present). These two controls ensure that the thermal-to-f ast flux convertor will remain subcritical.
Other flux convertors, such as the annular array of 30 rods,1.99 w/o U-235 (618 grams U-235), are protected against an inadvertent criticality by precluding flooding (no sprinkler system present) and limiting the fissile content of the U-235 to 618 grams.
In addition, a 12-inch spacing criterion is utilized to isolate adjacent flux convertors to assure nuclear isolation.
The staff has reviewed the safety analysis for the thermal-to-fast-flux convertors and concludes that adequate protection has been provided to ensure that the double contingency principle has been fulfilled and that these operations may be performed safely.
Laboratory Activities involving Solids and Solutions The total quantity of SNM possessed in the form of solid and liquid laboratory specimens, Item B of Table 1.1-1, does not exceed 350 grams of uranium anc',
therefore, does not constitute a criticality concern.
l
+
t l-FR 2 91994 l
13 l
Storage of SNM I
MIT has established NCS limits (Table 1.4-1) for the storage of low-enriched uranium and UO2 fuel rods (items A and A-1).
The limits specified in Table 1.4-1 are less than the minimum quantity of U-235 required for a criticality l'
j even assuming optimum moderation and full reflection.
The staff has reviewed the safety analysis for the storage of this material and concludes that the established limits in Table 1.4-1 are acceptable, and the double contingency l
principle has been fulfilled. Therefore, the staff concludes that this l
operation may be performed safely.
In addition, SNM, source, and byproduct materials may be stored in separate trays or shipping nd other containers in the vaults up to a limit of 350 grams U-235 per t':.y or container, provided that 12-inch spacing is maintained l
for such trays ac.a containers.
NCS for this material is provided by the mass limit and restricting water from entering the vault.
The staff has reviewed l
this operation and concludes that it may be performed safely due to adherence to the double contingency principle.
Finally, MIT stores SNM, possessed under this license, with unirradiated reactor fuel held under License R-37.
The safety of this operation has been shown to be subtritical, keff<.85, even under conditions of flooding.
The staff concludes that the double contingency principle has taen fulfilled and that this operation may be performed safely.
The staff concludes that there is reasonable assurance that MIT's NCS program, in conjunction with the imposed license conditions, is adequate to assure the safety of the requested SNM handling and storage activities.
L.
Environmental Protection j
Effluent Control All solid SNM wastes are retained and all liquid SNM wastes are converted to solids for disposal by transfer to an authorized recipient.
Solid and liquid source material wastes are disposed of as SNM waste, except for those small quantities of liquid wastes which are discharged to the sanitary sewer in accordance with 10 CFR 20.2003.
Appendix 4 of Attachment I to the renewal application for Byproduct Material License 20-01537-02 i
describes the laboratory disposal of radioactive wastes.
Radioactive wastes may be discharged into laboratory drains only under specd ied conditions that comply with 10 CFR Part 20.
Air effluent from the licensed material in the reactor area is controlled under License R-37.
Air effluent from nonreactor activities to unrestricted l
I
t pg 2 919%
14 areas is limited such that the 24-hour average concentration of radioactive material entering the ventilation duct of each laboratory does not exceed the limits of Appendix B, Table II, of 10 CFR Part 20.
In accordance with the.
operating procedure described in Section F of this Report, proposals from experimenters include provisions for effluent controls, and these provisions are reviewed by the Radiation Protection Committee or the Reactor Safeguards Committee. NRC staff has determined that this commitment to the control of gaseous effluents, and the provision for review in accordance with the operating procedure, is adequate to maintain effluents within regulatory limits.
Environmental Monitorina MIT performed environmental radiological monitoring before the start of reactor operations in 1958. This monitoring included measurements of radioactivity levels in reactor discharges to the air and to the sanitary
. Sewer discharges are monitored by maintaining records of the amount of sewer.
each radionuclide disposed into the laboratory drains and using forms posted near each drain.
Concentrations are limited to 10 times the value listed in 10 CFR Part 20, Appendix B, and no laboratory shall discharge more than 10 millicuries of total activity per calendar quarte'r.
Ambient air is measured at monitors sur!ounding the reactor. The monitors use recording end-window Geiger-Mueller counters as detectors and are very sensitive to increases above background.
These monitors have recorded an average increase of only 2 percent in annual background, essentially all of which is attributable to reactor operation.
The ventilation exhaust from the reactor building is nonitored for radioactivity levels under conditions of License R-37.
The staff has determined that this program is adequate to monitor environmental effluents from the use of SNM.
M.
Emergency Plan This license does not authorize MIT to possess the types and quantities of material specified in 10 CFR 70.22(i)(1); therefore, an Emergency Plan is not required under this license.
N.
Physical Security The staff has determined that the Physical Security Plan is adequate and meets the requirements of 10 CFR 73.67. Under the provisions of 10 CFR 70.32, MIT has made changes to the Plan that do not decrease the effectiveness.
y-y y
-r y,
y-wc*
m
,_w-4pp-
_+,w m-
- ge
- m u,mm--
--mwuv-A
-i-%.
e w
t V
APR 2 91994 15 Condition 19 ensures implementation of the Plan whenever SNM is received, used, or stored onsite.
This condition is continued in the reneweu license as follows:
The licensee shall maintain and fully implement all provisions of the NRC-approved Physical Security Plan, including changes made pursuant to the authority of 10 CFR 50.54(p) and 70.32(e).
The approved Physical Security Plan is contained in Revision 24 to the
" Safety Analysis Report for the MIT Research Reactor (MITR-II), Appendix 13.B," submitted by letter dated August 24, 1981.
O.
Compliance History The NRC Region I inspection reports of health and safety activities since the last renewal were reviewed and discussed with Region 1 Inspectors.
These reports covered 9 years (1985-1994).
Four minor violations were reported, in which two were equivalent to Severity Level V and two were equivalent to Severity Level IV.
Severity levels are defined in 10 CFR Part 2.
P.
Decommissioning Funding Plan (DFP)
MIT has developed a DFP for the reactor and included in the plan the costs for decommissioning the areas in which SNM is authorized.
The reactor DFP estimates the cost to decommission the reactor at $11 million, and the additional cost to decommission the SNM areas at $750,000.
MIT has entered into an Escrow Agreement with the Bank of Boston to provide financial assurance for decommissioning in the face value amount or $11.5 million
($11 million for the reactor, $750,000 for the byproduct materials license 20-01537-02, and $750,000 for License SNM-986).
Since the sum of these three costs is $12.5 million, MIT has corrected the amount of financial assurance in the escrow agreement to $12.5 million.
MIT has notified NRC that they plan to change the funding instrument from an Escrow Agreement to a self-guarantee, under the new provisions of 10 CFR 70.25(f)(2) promulgated on December 29, 1993 (58 FR 68731).
Condition 22 will apply to any mechanism MIT chooses.
Q.
License Application The license renewal application, dated October 25, 1990, is a letter that references the 1984 renewal application.
There have been two amendments, a number of other changes, and a number of conditions added during the term of the license.
Because of these changes, staff recommends that the 1984 renewal application be revised and updated to include changes made since 1984, as was requested in NRC's Request for Additional Information, dated August 19, 1993.
Staff recommends the following license condition:
e Y
L
~
APR 2 91994 l
16 The Licensee shall revise the license renewal application, dated July 13, 1984, to include the provisions of License Conditions 12-22 above, and additional commitments contained in the renewal application dated October 25, 1990, and supplements dated October 12, 1993, and January 21, 1994.
1; is revised application shall be submitted within 60 days of the date of this renewal.
III.
ENVIRONMENTAL PROTECTION The staff has determined that the renewal of this license will not adversely affect the public health and safety or the environment.
Therefore, in accordance with 10 CFR 51.22(c)(14)(v), which authorized categorical exclusion for the renewal of material licenses pursuant to 10 CFR Part 70 for the use of radioactive materials for research and development and for educational purposes, neither an environmental ~ assessment nor an environmental impact statement is warranted for this action.
IV.
CONCLUSION AND RECOMMENDATION Upon completion of the safety review of MIT's application and supplements and discussions with the Region I Inspectors regarding the licensee's compliance records, the staff has concluded that MIT has the necessary technical staff to administer an effective radiological safety program.
Conformance by the licensee to the license conditions is expected to ensure a safe operation, quick detection of unfavorable trends or effects, and appropriate and timely
(
corrective actions.
Based on the discussion above, it is recommended that the license be renewed for 5 years in accordance with the application and supplements and subject to the recommended conditions.
The Region I staff has no objection to this proposed action.
Principal Contributors Mary Adams Marc Klasky
-