ML20161A334

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Massachusetts Institute of Technology - Issuance of Amendment NO.44 to Renewed Facility Operation License No. R-37 to Amend Technical Specifications Related to Level 1 Position Title Change
ML20161A334
Person / Time
Site: MIT Nuclear Research Reactor
Issue date: 07/24/2020
From: Patrick Boyle
NRC/NRR/DANU/UNPL
To: Foster J
Massachusetts Institute of Technology (MIT)
Boyle P
References
EPID L-2020-LLA-0054
Download: ML20161A334 (20)
v • d • e


Text

July 24, 2020 Mr. John P. Foster, Director of Reactor Operations Nuclear Reactor Laboratory Massachusetts Institute of Technology 138 Albany Street, MS NW12-116B Cambridge, MA 02139

SUBJECT:

MASSACHUSETTS INSTITUTE OF TECHNOLOGY - ISSUANCE OF AMENDMENT NO. 44 TO RENEWED FACILITY OPERATING LICENSE NO. R-37 FOR THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY REACTOR RE: AMENDING TECHNICAL SPECIFICATIONS RELATED TO LEVEL 1 POSITION TITLE CHANGE (EPID NO. L-2020-LLA-0054)

Dear Mr. Foster:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 44 to Renewed Facility Operating License No. R-37 for the Massachusetts Institute of Technology (MIT) Reactor. The amendment consists of changes to the technical specifications (TSs) in response to the MIT application dated March 12, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20078J485), as supplemented by letter dated June 30, 2020 (ADAMS Accession No. ML20192A076). Specifically, this amendment revises the title of the Level 1 manager from Director to Managing Director for Operations throughout the TSs.

A copy of the NRC staffs safety evaluation is also enclosed. If you have any questions, please contact me at 301-415-3936, or by electronic mail at Patrick.Boyle@nrc.gov.

Sincerely,

/RA/

Patrick G. Boyle, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.50-020 License No. R-37

Enclosures:

1. Amendment No. 44 to Renewed Facility Operating License No. R-37
2. Safety Evaluation cc: w/enclosure: See next page

Massachusetts Institute of Technology Docket No.50-020 cc:

City Manager City Hall Cambridge, MA 02139 Department of Environmental Protection One Winter Street Boston, MA 02108 Mr. Jack Priest, Director Radiation Control Program Department of Public Health 529 Main Street Schrafft Center, Suite 1M2A Charlestown, MA 02129 Ms. Samantha Phillips, Director Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Ms. Sarah M. Don, Reactor Superintendent Massachusetts Institute of Technology Nuclear Reactor Laboratory Research Reactor 138 Albany Street, MS NW12-116B Cambridge, MA 02139

ML20161A334 *concurred via email NRR-058 OFFICE NRR/DANU/UNPL/PM* NRR/DANU/UNPL/LA* OGC/NLO*

NAME PBoyle NParker JWachutka DATE 7/20/2020 7/13/2020 7/22/2020 OFFICE NRR/DANU/UNPL/BC* NRR/DANU/UNPL/PM*

NAME GCasto PBoyle DATE 7/24/2020 7/24/2020 MASSACHUSETTS INSTITUTE OF TECHNOLOGY DOCKET NO.50-020 MASSACHUSETTS INSTITUTE OF TECHNOLOGY REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 44 License No. R-37

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to Renewed Facility Operating License No. R-37, filed by the Massachusetts Institute of Technology (the licensee) on March 12, 2020, as supplemented by letter dated June 30, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, of the Commissions regulations and all applicable requirements have been satisfied; and F. Prior notice of this amendment was not required by 10 CFR 2.105, Notice of proposed action, and publication of notice of this amendment is not required by 10 CFR 2.106, Notice of issuance.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the Attachment 2 to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. R-37 is hereby amended to read as follows:

Technical Specifications

2. The Technical Specifications contained in Appendix A, as revised through Amendment 44, are hereby incorporated in the license. The Massachusetts Institute of Technology shall operate the facility in accordance with the Technical Specifications.
3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Greg A. Casto, Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Attachments:

1. Changes to Renewed Facility Operating License No. R-37
2. Changes to Appendix A, Technical Specifications Date of Issuance: July 24, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 44 RENEWED FACILITY OPERATING LICENSE NO. R-37 DOCKET NO.50-020 Replace the following page of Renewed Facility Operating License No. R-37 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Renewed Facility Operating License Remove Insert 3 3 Attachment 1

3. Pursuant to the Act and 10 CFR Part 30, to receive, possess, and use:
a. a 150-curie antimony-beryllium sealed neutron source in connection with operation of the facility;
b. such byproduct material as may be produced by operation of the facility, which, except for byproduct material produced in non-fueled experiments, shall not be separated; and
c. byproduct materials activated in reactors other than the MIT reactor (for use in the reactor hot cells) that are in solid form and have atomic numbers 3 through 83. The total inventory of this byproduct material shall not exceed 100,000 curies at any one time. This material may be irradiated in the reactor.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in Parts 20, Standards for Protection against Radiation, 30, 50, 51, 55, Operators Licenses, 70, and 73, Physical Protection of Plants and Materials, of the Commissions regulations; is subject to all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

Maximum Power Level

1. The licensee is authorized to operate the reactor at steady-state power levels not to exceed 6.0 megawatts (thermal).

Technical Specifications

2. The Technical Specifications contained in Appendix A, as revised through Amendment 44, are hereby incorporated in the license. The Massachusetts Institute of Technology shall operate the facility in accordance with the Technical Specifications.

Additional Conditions

3. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The approved physical security plan consists of a Massachusetts Institute of Technology Nuclear Reactor Laboratory document, withheld from public disclosure pursuant to 10 CFR 73.21, entitled, Physical Security Plan for the M.I.T. Research Reactor Facility, dated July 22, 2013, as revised.

Amendment No. 44 July 24, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 44 RENEWED FACILITY OPERATING LICENSE NO. R-37 DOCKET NO.50-020 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Technical Specifications Remove Insert 6-33 6-33 7-2 7-2 7-3 7-3 7-4 7-4 7-8 7-8 7-10 7-10 7-16 7-16 Attachment 2

(i) The review shall be performed by the Director of the MIT Radiation Protection Program or his designate.

(ii) The review shall be performed annually.

(iii) Patient administrations selected for review shall be audited to determine compliance with each of the requirements listed in paragraph (3) above.

(iv) The review shall be written and any items that require further action shall be so designated. Copies of the review shall be provided to the NRL Managing Director for Operations and to the MIT Reactor Safeguards Committee who will evaluate each review and, if required, recommend modifications in this quality management program to meet the requirements of paragraph (3) above. A copy of these reviews will also be provided to each medical use licensee.

c) Records of each review, including the evaluations and findings of the review, shall be retained in an auditable form for three years.

d) The licensee (MIT) shall reevaluate the Quality Management Program's policies and procedures after each annual review to determine whether the program is still effective or to identify actions required to make the program more effective.

5. Response to Recordable Event: Within thirty days after the discovery of a recordable event, the event shall be evaluated and a response made that includes:

a) Assembling the relevant facts, including the cause; b) Identifying what, if any, corrective action is required to prevent recurrence; and c) Retaining a record, in an auditable form, for three years, of the relevant facts and what corrective action, if any, was taken.

A copy of any recordable event shall be provided to the affected medical use licensee.

6. Records Retention: The following records shall be retained:

a) Each written directive for three years; and b) A record of each administered radiation therapy where a written directive is required in paragraph (3(a)) above, in an auditable form, for three years after the date of administration.

7. Program Modification: Modifications may be made to this quality management program to increase the program's efficiency provided that the program's effectiveness is not decreased. All medical use licensees shall be notified of any modifications and provided with a copy of the revised program. The licensee (MIT) shall furnish the modification to the NRC (Region I) within 30 days after the modification has been made.

6-33 Amendment No. 44 July 24, 2020

7.1 Organization 7.1.1 Structure The organization for the management and operation of the reactor facility is shown in Figure 7.1-1.

7.1.2 Responsibility

1. The Director of Reactor Operations is directly responsible for the safe operation of the facility.
2. In all matters pertaining to safe operation of the MIT Reactor (MITR-II) and to these Technical Specifications, the Director of Reactor Operations shall report to and be directly responsible to the Managing Director for Operations at the Nuclear Reactor Laboratory. The management organization is shown in Figure 7.1-1.
3. The MIT Reactor Radiation Protection Officer shall be responsible for radiation protection at the MITR-II. He shall advise the Director of Reactor Operations on all matters pertaining to radiation protection.
4. The MIT Reactor Radiation Protection Officer shall report to and be directly responsible to the Director of MIT Environment, Health, and Safety Office.
5. The MIT Reactor Radiation Protection Officer shall be a member of the MIT Reactor Safeguards Committee 7-2 Amendment No. 44 July 24, 2020

President MIT Executive Vice- Vice-President President and for Research Treasurer Managing Director Reactor Director Environment, for Operations Safeguards Health, and Safety Nuclear Reactor Laboratory Committee Level 1 Reactor Radiation Director of Review Audit Protection Officer Reactor Operations Level 2 Superintendent of Operations and Maintenance Level 3 Operating Staff Level 4 Reporting Lines Communication Lines Figure 7.1-1: Management Organization for Reactor Operations 7-3 Amendment No. 44 July 24, 2020

6. In the event of disagreement between the recommendations of the MIT Reactor Radiation Protection Officer and the Director of Reactor Operations or their alternates, on matters pertaining to radiation protection, the course determined by the Director of Reactor Operations or his designated alternate to be the more conservative shall be followed. Records of the disagreement shall be sent for review and possible reconsideration to the Director of MIT Environment, Health, and Safety Office, the Managing Director for Operations at the Nuclear Reactor Laboratory, and the Chairman of the MIT Reactor Safeguards Committee.
7. The responsibilities of any given level in the management organization chart may be assumed by designated alternates conditional upon appropriate qualifications. Such delegation of authority shall be documented in writing by the regularly assigned individual or that person's immediate supervisor.

7.1.3 Staffing The minimum reactor staff organization shall be as follows:

1. When the reactor is not shut down, the minimum crew complement for a shift shall be two licensed operators including at least one licensed senior reactor operator, one of whom shall be in the control room. In addition, the MITR-II Radiation Protection Officer or a designated alternate shall be onsite or on call. If on call, one of the licensed operators will have responsibility for implementing radiation protection procedures.
2. Whenever the reactor is not secured, two persons shall be onsite, one of whom shall be a licensed senior reactor operator. An operator or senior operator 7-4 Amendment No. 44 July 24, 2020

7.2 Review and Audit 7.2.1 MIT Reactor Safeguards Committee Overall direction on matters of reactor safety rests with the MIT Reactor Safeguards Committee or MITRSC. Approval of the MITRSC is necessary for all new operating plans and policies and all significant modifications thereto which may involve questions of nuclear safety.

The MITRSC is also responsible for auditing operation of the reactor. The Chairman of the MITRSC reports directly to the President of MIT. The MITRSC communicates directly with the Managing Director for Operations at the Nuclear Reactor Laboratory and with the Director of Reactor Operations, both of whom are members of the MITRSC.

1. Composition and Qualifications: The MITRSC shall be composed of a minimum of nine persons with not more than one-third of the total membership chosen from the reactor staff organization and a minimum of three members from outside MIT. All members and the Chairman shall be selected by the President of MIT. At least four voting members including participating alternates shall have a minimum of a Bachelor's Degree in Engineering or the Physical Sciences and have a minimum of three years of professional level experience in nuclear services, nuclear plant operation, or nuclear engineering, and the necessary overall nuclear background to determine when to contact consultants for analyses beyond the scope of the MITRSC's expertise. Ex-officio members shall include the MIT Radiation Protection Officer and a representative of the MIT Environment, Health, and Safety Office.
2. Charter and Rules a) Meeting Frequency: Meetings shall be held at least annually.

b) Quorum: A quorum shall consist of at least a majority of the Committees voting membership. In addition, either the Chairman or a 7-8 Amendment No. 44 July 24, 2020

7.2.3 MITRSC Audit Function

1. The MITRSC audit function may be performed by members of the MITRSC who do not have line responsibility for the reactor or by a consultant who has qualifications equivalent to those listed in Specification 7.2.1.1
2. Audits shall be performed at least annually.
3. The scope of the audit shall include, as a minimum, the following:

a) Facility operations for conformance to the technical specifications and license conditions.

b) The requalification program for the operating staff.

c) The results of action taken to correct those deficiencies that may occur in the reactor facility equipment, systems, structures, or methods of operation that affect reactor safety.

d) The reactor facility emergency plan and implementing procedures.

e) The physical security plan.

Deficiencies uncovered that affect reactor safety shall immediately be reported to the Managing Director for Operations at the Nuclear Reactor Laboratory.

A written report of the findings of the audit shall be submitted to the Managing Director for Operations at the Nuclear Reactor Laboratory and to all MITRSC members within three months after the audit has been completed.

7-10 Amendment No. 44 July 24, 2020

7.6 Required Action 7.6.1 Action to be Take in Case of Safety Limit Violation The following action shall be taken in the event of a safety limit violation:

a) The reactor shall be shut down, and reactor operation shall not be resumed until authorized by the U.S. Nuclear Regulatory Commission.

b) The safety limit violation shall be promptly reported to the Superintendent of Operations and Maintenance, the Director of Reactor Operations, the Managing Director for Operations at the Nuclear Reactor Laboratory, and the Chairman of the MITRSC.

c) The safety limit violation shall be reported to the U.S. Nuclear Regulatory Commission.

d) A safety limit violation report shall be prepared. The report shall describe the following:

(i) The time and date of the violation, reactor status at the time of the violation, and a description of the violation.

(ii) Applicable circumstances leading to the violation including, when known, the cause and contributing factors.

(iii) Effect of the violation upon reactor facility components, systems, or structures, and on the health and safety of personnel and the public.

(iv) Corrective action to be taken to prevent recurrence.

This report shall be reviewed by the MITRSC and submitted to the U.S.

Nuclear Regulatory Commission. Any follow-up report shall also be submitted to the U. S. Nuclear Regulatory Commission before authorization is sought to resume operation of the reactor.

7.6.2 Action to be Take in the Event of a Reportable Occurrence The following action shall be taken in the event of a reportable occurrence:

a) The reactor shall be shut down unless the cause for the occurrence has been identified and rectified immediately upon discovery or unless the occurrence has no immediate safety significance to the reactor, to the safety of reactor personnel, and to the safety of the public.

7-16 Amendment No. 44 July 24, 2020

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 44 RENEWED FACILITY OPERATING LICENSE NO. R-37 MASSACHUSETTS INSTITUTE OF TECHNOLOGY MASSACHUSETTS INSTITUTE OF TECHNOLOGY REACTOR DOCKET NO.50-020

1.0 INTRODUCTION

By application dated March 12, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20078J485), as supplemented by letter dated June 30, 2020 (ADAMS Accession No. ML20192A076), the Massachusetts Institute of Technology (MIT, the licensee) requested changes to the technical specifications (TSs) for the MIT Reactor (MITR-II).

The proposed changes would revise the title of the Level 1 manager to Managing Director for Operations in TSs 7.1.2.2, 7.1.2.6, 7.2.1, 7.2.3.3, and 7.6.1.b., in TS Figure 7.1-1, and in Requirement 4.b)(iv) of the Quality Management Program for Generation of MITR-II Medical Therapy Facility Beams for Human Therapy (TS page 6-33). The proposed changes would also revise the title of TS Figure 7.1-1 to Management Organization for Reactor Operations and make an editorial change to one block in TS Figure 7.1-1.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees license amendment request (LAR) and evaluated the proposed TS changes based on the regulations and guidance in:

  • The Atomic Energy Act of 1954, as amended, Section 182a, which requires that each utilization facility operating license include TSs. The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, provide the regulatory requirements for the licensing of non-power reactors, including Section 50.36, Technical specifications, which provides the requirements for TSs to be included in facility operating licenses, and Section 50.36(c)(5), Administrative controls, which requires that TSs include provisions relating to organization and management necessary to assure operation of the facility in a safe manner.

Enclosure 2

  • The regulations in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, which provide regulatory requirements for the protection of the environment. 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, identifies licensing, regulatory, and administrative actions eligible for categorical exclusion from the requirement to prepare an environmental assessment or environmental impact statement.
  • NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors, Section 6.1, Organization (ADAMS Accession No. ML042430055), which provides guidance to licensees preparing research reactor applications and TSs.
  • NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, Chapter 14, Technical Specifications (ADAMS Accession No. ML042430048), which provides guidance to the NRC staff for performing reviews of research reactor applications and TSs.
  • American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, Section 6.1, Organization, Section 6.1.1, Structure, and Section 6.1.2, Responsibility, which provide guidance on administrative controls that should be included in research reactor TSs. The 2007 version is a revision of the ANSI/ANS-15.1-1990 standard cited in NUREG-1537 that was issued in 1996.

Sections 6.1, 6.1.1, and 6.1.2 of the 2007 standard are not substantively different from the 1990 version. The NRC staff used the current version, ANSI/ANS-15.1-2007, to conduct its review since the licensee referenced the 2007 version of the standard in the LAR.

3.0 TECHNICAL EVALUATION

3.1 Background

The MITR-II, located on the MIT campus in Cambridge, Massachusetts, is a component of the MIT Nuclear Reactor Laboratory (NRL). MITR-II is owned and operated by MIT, a non-profit University.

In the application, MIT requested to change the title of the Level 1 position in the TSs in its Renewed Facility Operating License No. R-37 from Director of the Nuclear Reactor Laboratory to Managing Director for Operations at the Nuclear Reactor Laboratory. MIT also requested a change to the title of TS Figure 7.1-1 from Management Organization to Management Organization for Reactor Operations and an editorial change to one block in TS Figure 7.1-1.

MIT requested these changes to be consistent with NRL management restructuring.

3.2 Proposed Changes to TSs To support NRL management restructuring, MIT proposed the following changes to the TSs:

  • Change Requirement 4.b)(iv) of the Quality Management Program for Generation of MITR-II Medical Therapy Facility Beams for Human Therapy (TS page 6-33) text from NRL Director to NRL Managing Director for Operations
  • Change TSs 7.1.2.2, 7.1.2.6, 7.2.1, 7.2.3.3, and 7.6.1.b text from Director of the Nuclear Reactor Laboratory to Managing Director for Operations at the Nuclear Reactor Laboratory
  • Change TS Figure 7.1-1 block identifying the Level 1 position from Director to Managing Director for Operations
  • Change TS Figure 7.1-1 block identifying the Level 2 position by adding the word of after the word Director.
  • Change the title of TS Figure 7.1-1 from Management Organization to Management Organization for Reactor Operations The revised text that result from the licensees proposed changes to the TSs discussed above are in bold typeface where text has been inserted and deleted text is indicated by strikeout for each proposed TS below.

The proposed Requirement 4.b)(iv) of the Quality Management Program for Generation of MITR-II Medical Therapy Facility Beams for Human Therapy (TS page 6-33) will state:

The review shall be written and any items that require further action shall be so designated. Copies of the review shall be provided to the NRL Managing Director for Operations and to the MIT Reactor Safeguards Committee who will evaluate each review and, if required, recommend modifications in this quality management program to meet the requirements of paragraph (3) above. A copy of these reviews will also be provided to each medical use licensee.

The proposed TS 7.1.2.2 will state:

In all matters pertaining to safe operation of the MIT Reactor (MITR-II) and to these Technical Specifications, the Director of Reactor Operations shall report to and be directly responsible to the Managing Director for Operations at of the Nuclear Reactor Laboratory. The management organization is shown in Figure 7.1-1.

The proposed TS 7.1.2.6 will state:

In the event of a disagreement between the recommendations of the MIT Reactor Radiation Protection Officer and the Director of Reactor Operations or their alternates, on matters pertaining to radiation protection, the course determined by the Director of Reactor Operations or his designated alternate to be the more conservative shall be followed. Records of disagreement shall be sent for review and possible reconsideration to the Director of MIT Environment, Health, and Safety Office, the Managing Director for Operations at of the Nuclear Reactor Laboratory, and the Chairman of the MIT Reactor Safeguards Committee.

The proposed TS 7.2.1 will state:

MIT Reactor Safeguards Committee Overall direction on matters of reactor safety rests with the MIT Reactor Safeguards Committee or MITRSC. Approval of the MITRSC is necessary for all new operating plans and policies and all significant modifications thereto which may involve questions of nuclear safety. The MITRSC is also responsible for auditing operation of the reactor. The Chairman of the MITRSC reports directly to the President of MIT. The MITRSC communicates directly with the Managing Director for Operations at of the Nuclear Reactor Laboratory and with the Director of Reactor Operations, both of whom are members of the MITRSC.

The proposed TS 7.2.3.3 will state:

Deficiencies uncovered that affect reactor safety shall immediately be reported to the Managing Director for Operations at of the Nuclear Reactor Laboratory. A written report of the findings of the audit shall be submitted to the Managing Director for Operations at of the Nuclear Reactor Laboratory and to all MITRSC members within three months after the audit has been completed.

The proposed TS 7.6.1.b will state:

b) The safety limit violation shall be promptly reported to the Superintendent of Operations and Maintenance, the Director of Reactor Operations, the Managing Director for Operations at of the Nuclear Reactor Laboratory, and the Chairman of the MITRSC.

The proposed TS Figure 7.1-1 Level 1 block will state:

Managing Director for Operations Nuclear Reactor Laboratory Level 1 The proposed TS Figure 7.1-1 Level 2 block will state:

Director of Reactor Operations Level 2 The proposed TS Figure 7.1-1 title will state:

Figure 7.1-1: Management Organization for Reactor Operations In its application, MIT stated that the Managing Director for Operations at the Nuclear Reactor Laboratory will be responsible for reactor operations and will have the legal responsibility for holding the reactor license. MIT also stated that the Level 1 manager will continue to be the organizational head for reactor operations, consistent with the Level 1 position description in ANSI/ANS-15.1-2007.

The NRC staff reviewed the proposed title change of the Level 1 manager from Director of the Nuclear Reactor Laboratory to Managing Director for Operations at the Nuclear Reactor Laboratory using guidance in ANSI/ANS-15.1-2007, Section 6.1.1, which states that the organization for the management and operation of the facility should include an individual responsible for facility operation. The NRC staff finds that the revised title reflects the organizational structure at the MITR-II and that the responsibilities and reporting and communicating lines of the Managing Director for Operations at the Nuclear Reactor Laboratory specified in the MITR-II TSs remain unchanged. The NRC staff also finds that the proposed changes to the TSs of the position or title of an officer of the licensee is consistent with the guidance documents. The NRC staff compared the description of the Managing Director for Operations at the Nuclear Reactor Laboratory to the requirements in 10 CFR 50.36(c)(5) and finds that the provisions relating to Level 1 manager ensure that the licensee organization necessary to assure operation of the facility in a safe manner is satisfactorily described. Finally, the NRC staff finds that the proposed changes to the title of TS Figure 7.1-1 and the TS Figure 7.1-1 block identifying the Level 2 position are editorial in nature. The title change is consistent with NRL management restructuring and the change to the Level 2 position text better matches the text used in TS 7.1.2.1 and TS 7.1.4.1.

Therefore, based on the findings discussed above, the NRC staff concludes that the proposed changes are acceptable.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes recordkeeping, reporting, or administrative procedures or requirements; changes the name, position, or title of an officer of the licensee; or changes the format of the license or otherwise makes editorial, corrective, or other minor revisions.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: P. Boyle, NRR Date: July 24, 2020

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