ML20030E154

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Safety Evaluation Supporting Amend 7 to License SNM-986, Changing Expiration Date to 820831
ML20030E154
Person / Time
Site: 07000938
Issue date: 09/03/1981
From: Kosla B
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20030E151 List:
References
NUDOCS 8109180057
Download: ML20030E154 (3)


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Massachusetts Institute of Technology (MIT)

RErickson JRobertson FACILITY:

Cambridge, Massachusetts s

SUBJECT:

AMENDMENT TO EXTEND EXPIRATION DATE OF SNM-986 AND TO INCORPORATE EXPIRED SNM-171 I.

Background

The large quantity of S#1 which the Massachusetts Institute of Technology possesses is authorized through several licenses. The most significant, SNM-986, remains effective pursuant to the timely renewal provisions of 70.33(b),10 CFR 70.

It authorizes the possession and use of enriched uranium ir MIT's subcritical assembly. SNM-81, which has a termination date of August 31, 1983,' authorizes the possession and use of less than 180 grams of sealed plutonium neutron sources. Another license.

SNM-171, wh'ch authorizes the possession and use of plutonium a M uranium clad fission foils, expired September 30, 1980.

MIT was informed'of SNM-171's expiration by Mr. Claude Rowe, Region I, IE in May 1981, and at that time MIT expressed the desire to reactivate the license to continue use of the material.

In a telephone conversation on May 26, 1981 Mr. Lincoln Clark, Director of Reactor Operations at MIT, advised the staff that MIT was in the process of reducing their SNM inventory. He also stated that radiation safety and control of all special nuclear material is administered through the same department and asked that SNM use at MIT be sanctioned under cae license.

A letter dated uly ',1981, confimed the conversation and reiterated the request to consolidate the possession and use of all SNM under one itcense.

II. Scope of_ keview P

The saf'ety r diew of MIT's program includes a rev*ew of applications, correspondence,tsnd compliance history since January 1958. The compliance history involved both a review of prior inspections and a telephone conversation with Region -I inspector J. Roth. Findings are im:orporated in the dissussion and recomendation.

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III. Discussion The MIT Safety Program is maintained through administrative control and physical barriers, Since this facility began cperation in 1959, their safety history has been a good demonstration of the calibre and stability of MIT's ad:ninistrative staff.

Program weaknesses,. observed by this reviewer, appear to be in docu-mentation and communication. The items of noncompliance in the 1979 inspection centered around documentation of lab procedures for the subcritical assembly and maintenance of shipping reco:d6. The com-munication problem involves !!IT's long delay before they responded to questions submitted by NMSS concerning MII's renewal request, as well as the licensee's oversight in requesting renewal of SNM-171.

The consnunication problem may exist lacause each SNM license requires considerable correspondence, and is a burden in scheduling for MIT; therefore, the solution to the problem may lie in the licensee's con-solidation request. The consolidation would relfeve the redundancy of preparing similar applications for renewal at frequent intervals for MIT, and reduce staff time spent in review for NRC.

The individual? licenses-represent various components of the BIT operation, and the required information for renewal and consolidation is segmented throughout several applications and correspondences.

Tne current renewal practice requires alicensee to prepare an application which is complete in icielf with minimum references to previous applications. In order to supply information in one document MIT would have to submit a revised application, Draft Regulatory Guide,

" Standard Format and Content for the Health and 7afety Section of Re-newal Applications for Uraniw Fuel Fabrication Plants," will provide guidance in preparing the application.

IV.

Conclusion and Reconcendation Upon conpletion of the review of MIT's request for renewal and consoll-dation of their SD1 licenses, the staff reconsnends that a revised application for renewal be submitted to NRC in the new fonnat.

It is recognized that the prepara' ion of a consolidated application takes time; therefore, it is reconenended that SNM-986 be amended to extend the expiration date to August 31, 1982, and to increase the current possession limit to include the material formerly authorized by SNM-171.

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-3 SEP 3 1981 These steps were discussed with Region I, IE, and they agree that this action is appropriate.

original signedby B.M.Kosla+>'

B. M. Kosla Uranitan Process Licensing Section Uranium T al Licensing Branch Division of Fuel Cycin and Material Safety Original signed by,1 Approved by:

W. T. Crow W. T. Crow, Section Leader 6

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