ML20137D039
| ML20137D039 | |
| Person / Time | |
|---|---|
| Site: | 07000938 |
| Issue date: | 11/13/1985 |
| From: | Crow W, Ketzlach N, Soong A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20137D011 | List: |
| References | |
| NUDOCS 8511260689 | |
| Download: ML20137D039 (10) | |
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. l NOV 131985 DOCKET NO: 70-938 LICENSEE: Massachusetts Institute of Technology (MIT)
Cambridge, MA
SUBJECT:
REQUEST FOR LICENSE RENEWAL, SNM-986
Background
Since 1966, MIT's Materials License No. SNM-986 has authorized possession and use of 140.9 kg of U-235 contained in enriched uranium fuel rods and foils for subcritical reactor lattice experimental research. The license was subsequently renewed in 1969 and 1974 with expansion of their research program to include plutonium in the license. The current license is due to expire on August 31, 1982; however, or July 28, 1982, MIT submitted an application for renewal. Accordingly, the license has remained in effect in accordance with the timely renewal provi-sions of Subsection 70.33(b) of 10 CFR 70. During the period of this license, several amendments were issued concerning changes in possession limits.
In the renewal application, the licensee requested consolidation of their Materials License Nos. SNM-986, SNM-81, and 500-687. As a result of this licensing action, these three licenses will be incorporated into one (Materials License No. SNM-986).
Scope of Review The safety review of MIT's renewal application includes a review of the application dated July 28, 1982, a revision submitted on July 13, 1984, and the compliance history of the licensee.
The topics of review include an evaluation of the applicant's organization procedure, radiation safety, and nuclear criticality safety. The renewal application has been discussed with Mr. J. Roth, NRC Region I Inspector, and his comments are addressed in the review. As part of the review process, the applicant's site has been visited by staff members.
These site visits have included both radiological safety and environmental impact concerns.
Discussion of Review MIT's revised application has demonstrated that they have the basic necessary technical staff with the proper qualifications to administer an effective and safe radiological safety program. The following sections contain a description of the applicant's requested material, organization and safety programs, along with additional license conditions developed by the FCUP staff.
B511260689 851113 i PDR ADOCK 07000938 C PDR
NOV 131985 Massachusetts Institute of Technology 2 Possession limits: MIT has requested the following nuclear material for their activities:
Byproduct, source, Chemical and/or Maximum amount that and/or special physical form licensee may possess nuclear material at any one time under this license A. Uranium enriched to A. Solid (UO 2 ), clad A. *32,000 grams of U-235 less than 2.0 wt% and unciad in the U-235 isotope B. Uranium enriched to B. Solid or solution B. 350 grams of U-235 less than 93 wt% include material in in the U-235 isotope fission chambers C. Plutonium C. Pu-Be neutron source C. 197 grams and Pu-Al neutron filter D. Plutonium D. Solid alpha source D. 80 pg E. Plutonium E. Solid, foil E. **172.0 grams F. Natural Uranium F. Solid and solution F. 2515 kilograms G. Depleted Uranium G. Any G. ***238.2 kilograms H. Any byproduct material H. Unseparated H. Quantities produced unseparated contained during irradiation in any of the above The requested material will be used for research and teaching purposes at the following MIT locations:
- 1. MIT Campus, Cambridge, MA
- 2. Bates Linear Accelerator, Middletown, MA
- 3. Lincoln Laboratory, Lexington, MA Any irradiation in or experimental use of the licensed material on the MIT reactor shall be authorized under MIT's Facility Operating License No. R-37 which was issued by the NRC. Material handling before or after use in the reactor is in accordance with the conditions of this license; however, this license does not authorize insertion of fuel into a reactor. In order to clarify this point, the staff recommends that the following condition be added:
- 9000 grams for storage only
- for storage only
- 58.2 kilograms'for storage only 1
1 NOV 131985 Massachusetts Institute of Technology 3 Condition 11: This license does not authorize the insertion of licensed material into a nuclear reactor.
Organization The applicant has established a Radiation Protection Committee (RPC) comprised of a Radiation Protection Officer and faculty members with appropriate technical backgrounds. This Committee meets four times a year. The Committee is respon-sible for establishing a radiation protection program, reviewing the program on an annual basis, assuring the institute is in compliance with regulations for radiation protection, and approving the use of licensed material by the experimenters.
The MIT Radiation Protection Officer (RPO) is responsible for implementing the radiation safety program, for collecting data relative to the radiation exposure of employees, and providing support to the experimenters requiring radiation monitoring services.
Since most experiments with licensed material are conducted within the reactor area, the workers' radiation exposure and radioactive effluents data will be reviewed by the Reactor Safeguards Committee, established under Reactor License R-37. For workers outside the reactor area, exposure trends will be reviewed by the Radiation Protection Officer.
Technical Qualifications The licensee's present Radiation Protection Officer has sufficient academic training and experience in radiation protection. However, because this does not ensure that the future RP0 will be a qualified individual and because there is no license requirement specifying minimum technical qualifications, to ensure the individual holding this position is qualified, the following condition is recommended:
Condition 12: 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.
Operating Procedure The applicant has committed to the use of licensed material being approved by the Radiation Protection Committee. The applicant has not committed to having an approved descriptive written procedure in conducting the operation. Therefore, the staff recommends the following license condition to correct this deficiency:
Condition 13: 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 by l the Radiation Protection Committee.
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Massachusetts Institute of Technology 4 NOV 131985
. Audit and Inspection The applicant has committed to having the radiation protection program evaluated and reviewed by the Radiation Protection Committee on an annual basis. The applicant is not committed to a periodic audit by safety personnel. The NRC staff, therefore, recommends the following license condition:
Condition 14: 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 needed corrective actions shall be transmitted in a timely fashion to the supervisor of the inspected area as well as the Radiation Safety Committee.
Personnel Training All workers using radioactive material are required to participate in a radiation safety training course presented by the Radiation Protection Office. At the present time, there is no requirement for retraining Health Physics Technicians.
Accordingly, the following license condition is recommended:
Condition 15: 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.
Radiation Safety Control Control of Personnel Exposure A. External Exposure External exposure of personnel is controlled and evaluated using personnel dosimeters which must be used as required by 10 CFR 20. The dosimeters are read and evaluated on a monthly basis. The external exposure data submitted by the licensee for the period from 1980 through 1981 showed that 97 percent of the MIT employees received an annual external dose of less than 20 percent of the allowable exposure specified in 10 CFR 20.101 and 3 percent received a dose of less than 25 percent of the allowable exposure.
The employee's exposures described above include the exposure received from the work under MIT's reactor license as well as this license. The majority of the reported exposures are contributed by work under MIT's reactor license.
B. Internal Exposure Protection of workers from excessive internal exposure is provided by:
- 1. Carrying out work involving dispersible material in the ventilated hood.
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W Massachusetts Institute of Technology 5 NOV 131985
- 2. An air sampling program which monitors airborne concentration of radioactivity.
- 3. Surveying to detect the presence and extent of radioactive contamination.
- 4. Issuance of protective clothing.
- 5. A bioassay program which monitors and detects radionuclide deposition or buildup. '
- 6. Procedures, including action levels, for investigation and decon-tamination of contaminated surfaces.
r Control of Contamination The laboratories involved with the use of licensed material are surveyed on a
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routine basis by using an instrument which must be calibrated at least annually.
The frequency of the survey varies from daily to quarterly depending on the potential hazard presented by the presence of surface contamination. The decon-tamination action level is equivalent to the level of allowable contamination established by the NMSS staff for release of facilities for unrestricted use.
The applicant has requested authorization for plutonium materials as sealed sources. The applicant has committed to conducting a routine leak test on the sources in accordance with the procedures that were developed by the NMSS staff.
The staff has added a condition (Condition 16) which specifies criteria for the release of equipment and materials from the plant site or to clean areas onsite. The condition shall read as follows:
Condition 16: Release of equipment or mater'ials for unrestricted use or from contaminated to clean areas onsite shall be in accordance with the enclosed Annex A, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special l Nuclear Materials," dated July 1982.
Effluent Control All solid special nuclear material wastes are retained and all liquid SNM wastes are converted to a solid for disposal by transfer to an authorized recipient.
Solid and liquid source material wastes shall be disposed of as SNM waste except for those small quantities of liquid wastes which will be discharged to a sanitary sewer in accordance with 10 CFR 20.303.
Air effluent from the licensed material in the reactor area is controlled under i Reactor License R-37. Air effluent from nonreactor activities to unrestricted l areas is in compliance with 10 CFR 20.
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4 Massachusetts Institute of Technology 6 Nuclear Criticality Safety MIT has three Campuses in Massachusetts under Materials License No. SNM-986; namely, the principal Campus at Cambridge, the Bates Linear Accelerator at Middletown, and the Lincoln Laboratory. At all three, with the exception of within the reactor restricted area at the Cambridge campus, the quantities of SNM are limited to those specified in 10 CFR 70.24(a) for which a criticality alarm is required. With this limitation on the distribution of the requested i SNM possession limit, the nuclear criticality safety controls outside the restricted area need only provide assurance that the "10 CFR 70.24(a) limits" not be exceeded. The controls needed for the restricted area need to include MIT organization, administrative controls, and technical specifications.
At MIT, the Reactor Safeguards Committee (RSC) has the responsibility for safety reviews, including nuclear criticality safety, and for all utilization of SNM when used in the reactor or when its use or storage is within the restricted area outside the reactor. The Radiation Protection Committee is responsible j for the safety reviews in the use of the SNM outside the reactor restricted area at all three campuses. Outside the restricted area on the main campus, only subcritical quantities of SNM are authorized. The responsibility for the nuclear criticality safety of fuel handling and storage activities in the restricted area resides with the Criticality Officer (CO). The C0 provides j advisory and technical services regarding the use, storage, and shipping of SNM where criticality considerations are involved. The MIT Accountability Officer i
is responsible for assuring that quantities in excess Cf 10 CFR 70.24(a) limits are not possessed in any one of the three locations except within the restricted area. At MIT, the positions of Criticality Officer, Accountability Officer, and Director of Reactor Operations may be filled by the sare or by different individuals. In fact, the Criticality Officer, if a different individual than j the Director of Reactor Operations, reports to the latter.
The licensee specified the Criticality Officer shall have the educational and experience qualifications required of the MITR Superintendent. However, the latter may have no experience in evaluating nuclear criticality safety outside of reactors. Therefore, it is recommended Condition 17 be added requiring the necessary experience for the Criticality Officer or the person responsible for the initial nuclear criticality safety analysis.
l Condition 17: The minimum qualifications for the Criticality Officer or for
- the individual responsible for the initial nuclear criticality l
safety analysis, if other than the Criticality Officer, shall be an accredited college degree in the physical sciences or engineering plus a minimum of 3 years' applicable nuclear safety experience. The nuclear experience shall include 1 year in out-i side of reactor nuclear criticality safety.
This Condition would allow a student to perform the analysis provided it is i reviewed and approved by a person having the above minimum qualifications.
The licensee references its Technical Specifications in Research Reactor License No. R-37 for the responsibilities of the RSC. The technical specifications are directed primarily to the reactor operations. The responsibilities, particularly
NOV 13 885 Massachusetts Institute of Technology 7 related to the SNM-986 license, are expanded in the renewal application. The RSC reviews and approves SNM fuel handling and storage procedures in the restricted area. Although the licensee is committed to have the Criticality Officer participate in the review of procedures involving more than 350 g con-tained U-235 or 175 g of total Pu, the individual may be placed in the posi-tion of reviewing his own nuclear criticality safety analysis. Condition 18 is recommended to provide assurance of an independent review.
Condition 18: There shall be at least one member uf the RSC, other than the Criticality Officer, qualified to evaluate nuclear criticality safety when the initial evaluation under review involving the handling or storage of special nuclear material in the restricted area (e.g., procedure, audit, investigation of unusual event) was prepared by the Criticality Officer. This member shall meet the minimum qualifications of the Criticality Officer.
MIT has a system of audits that provides the administration with assurance that all outside-of-reactor nuclear criticality safety requirements are met. They include the following:
- 1. The quarterly administrative audit by the Director of Reactor Operations and/or Reactor Superintendent includes the criticality safety of SNM in use and in storage.
- 2. The annual physical inventory of all SNM includes an inspection to assure labeling, posting, and criticality requirements are met.
- 3. The annual independent audit, by one or more individuals who are not in the reactor operations chain of command, of the operating records includes that related to nuclear criticality safety.
MIT's approach to nuclear criticality safety is' based on the double contingency policy which states that SNM storage and experiments incorporate sufficient factors of safety so that two unlikely independent, and concurrent changes in conditions are required before a criticality accident is possible.
The quantity of SNM in any building outside the restricted area on the Cambridge Campus is less than the minimum required to form a critical mass independent of the degree of water moderation and/or water reflection.
A license conditions section specifies the maximum storage limits in the vaults.
The storage trays are safe by geometry for the 1.0 to 2.0 percent U-235 enriched materials they contain, independent of the degree of water moderation and i reflection. Each storage tray contains less than the minimum quantity of U-235 required for criticality independent of container geometry, water moderation, and water reflection. The licensee has imposed a further restriction on the maximum quantity of material in storage; namely, the k,ff will be 5,0.85.
The staff feels that the licensee's nuclear criticality safety program, together with the added license conditions, is adequate to assure the nuclear criticality l safety of the requested SNM handling and storage activities.
Massachusetts Institute of Technology 8 Environmental Protection The licensing of the MIT activities is in accordance with 10 CFR 51.22(c)(14)(v),
and therefore, an environmental impact statement or an environmental assessment
, is not warranted for this action.
Radiological Contingency Plan Because of the physical and storage conditions of the licensed material, the staff has determined that a Radiological Contingency Plan is not required under this license.
Physical Security The Division of Sr.?eguards has reviewed the Physical Security Plan and has determined that it is adequate and meets the requirements of 10 CFR 73.67.
The staff recommends that Condition No. 19 be added requiring the plan to be fully implemented whenever SNM is received, used, or stored onsite.
Condition 19: 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.
Compliance History and Region I Comments The NRC Region I inspection reports of health and safety activities since the last renewal were reviewed and discussed with Mr. J. Roth, Region I Inspector, on September 24, 1985. These reports covered an 8 year period (1974-1982).
Six minor violations were reported, in which 4 were equivalent to Severity Level V and 2 were equivalent to Severity Level IV. Severity levels are defined in 10 CFR Part 2. Mr. Roth feels the license, as written, addresses all of Region I's concerns from an inspection and enforcement perspective and
- he has no objection to the issuance of the renewal.
Conclusion and Recommendation Upon completion of the safety review of the licensee's uglication and discus-sions with the Region I Facility Inspector regarding the licensee's compliance records, the staff has concluded that the licensee has the necessary technical staff to administer an effective radiological safety program. Conformance by the licensee to their proposed conditions, as well as to those developed by
. the FCUF staff, should ensure a safe operation, a quick detection of unfavorable
! trends or effects, and result in corrective actions being taken.
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NOV 131985 Massachusetts Institute of Technology 9 Based on the discussion above, it is recommended that the license be renewed for a 5 year period in accordance with the application and subject to the following conditions:
Condition 11: This license does not authorize the insertion of licensed material into a nuclear reactor.
Condition 12: 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.
Condition 13: 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 by the Radiation Protection Committee.
Condition 14: The licensee chall 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 needed corrective actions shall be transmitted in a timely fashion to the supervisor of the inspected area as well as the Radiation Safety Committee.
1 Condition 15: 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.
Condition 16: Release of equipment or materials for unrestricted use or from contaminated to clean areas onsite shall be in accordance with the enclosed Annex A, " Guidelines for' Decontamination of Facil-ities and Equipment Prior to Release for Unrestricted Use or
. Termination of Licenses for Byproduct, Source or Special Nuclear Materials," dated July 1982.
Condition 17: The minimum qualifications for the Criticality Officer or for the individual responsible for the initial nuclear criticality safety analysis, if other than the Criticality Officer, shall i
be ali accredited college degree in the physical sciences or engineering plus a minimum of 3 years' applicable nuclear safety experience. The nuclear experience shall include 1 year in out-side of reactor nuclear criticality safety.
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NOV I 31985 Massachusetts Institute of Technology 10 Condition 18: There shall be at least one member of the RSC, other than the Criticality Officer, qualified to evaluate nuclear criticality safety when the initial evaluation under review involving the handling or storage of special nuclear material in the restricted area (e.g., procedure, audit, investigation of unusual event) was prepared by the Criticality Officer. This member shall meet the minimum qualifications of the Criticality Officer.
Condition 19: 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 Physic.al 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.
Orisical Sisnod By,A Orit:iral SICnod Dys N. Ec ts;lach , , - A. L. sow 3 Norman Ketzlach A. L. Soong Criticality Safety Project Manager Original Signed By:
Approved by W. T. Crow, Section Leader 0FC: FCU g :fCUP :FCUF
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NAME: ALSoong :NK t ach:VLT arpe :WTCrow : : :
DATE:11/1[/85 :11/*7 /85 :11/0/85 :11/ b/85 : : :
OFFICIAL RECORD CfPY
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