ML20247H953
| ML20247H953 | |
| Person / Time | |
|---|---|
| Site: | 07000938, MIT Nuclear Research Reactor |
| Issue date: | 06/21/1989 |
| From: | Bernard J, Masse F MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE |
| To: | Della Ratta A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20247H941 | List: |
| References | |
| NUDOCS 8907310195 | |
| Download: ML20247H953 (3) | |
Text
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7' MASSACHUSETTS INSTITUTE OF TECHNOLOGY l
MEDICAL DEPARTMENT ENVIRONMENTAL MEDICAL SERVICE 77 M ASSACHUSETTE AVENUE, 209 238 CAMBRIDGE. M A88ACHUSETT6 02139 June 21, 1989
.US Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia PA 19406 Attention:
Mr. A. Della Ratta
Subject:
Further Response to Combined Inspection Numbers 50-20/89-01 and 70-938/89-01 Gentlemen:
Following the telephone conversation of 6/12/89, between A. Della Ratta and MIT personnel, MIT submits this further response to the above referenced inspection report.
The purpose of this further response is to clarify the misunderstanding on the status of inventory control and to emphasize the most significant step taken by MIT to correct the deficiency. The misunderstanding relates to the records maintained by MIT on sources possessed under License No. SNM-986.
While the findings of the inspection are correct in that the Accountability record at MIT has not listed a complete inventory of all sources possessed under this license, MIT Radiation Protection records have always been complete in this regard. The confusion apparently occurred when an earlier source material license was eliminated and the source material under that license was transferred to SNM-986, making that material now accountable under this license. The issue was further complicated by the existence of very small sources of.SNM that had been obtained commercially and had not been covered under the' Accountability listing.
As mentioned before, the existence of all such sources was well known to Radiation Protection personnel, but the information had not been coordinated through the Accountability of fice, which is operated under the Reactor Laboratory. The change in procedure that has been implemented to correct this coordination defect will now involve the Radiation Protection personnel in the physical inventory program. Since they are most knowledgeable in the routine use of these sources or in the storage of sources not in use, they are best suited to produce an accurate, complete list of physically inventoried sources as required. These field reports will be submitted to the Accountability Officer for compilation into the complete report required by the regulations.
8907310195 090720 PDR ADOCK 05000020 0
PNU
US Nuclear Regulatory Commission Inspections: 50-20/89-01 & 70-938/89-01
- Page 2 This change will go into effect with the next normal inventory cycle.
Meanwhile, proper Accountability reports have been submitted on all sources in MIT possession that were not properly listed in the accountability record.
'Hence we are in full compliance as of this writing.
Yours truly,
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/ Frank Masse, RPO Director of Radiation Protection ak John A. Bernard, PhD i
Director of Reactor Operations MIT Research Reactor FXM/nlj cc:
O. Harling, Director, Nuclear Reactor Laboratory F. McWilliams, MITR Radiation Protection Office MITRSC USNRC - Region I - Chief, Reactor Projects Section No. 3B USNRC - Region I - Project Engineer, Reactor Projects Section No. 3B USNRC - Senior Resident Inspector, Pilgrim Nuclear Station USNRC - Region I - Chief, Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards USNRC - Headquarters - Document Control Desk i
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<qQ.s NUCLEAR REACTOR LABORATORY idsfEff AN INTERDEPARTMENTAL CENTER OF MASSACHUSETTS INSTITUTE OF TECHNOLOGY O K. HARLING 138 Albany Street, Camondge. Mass. 02139 J A. BERNARD. JR.
Director Telefax No- (6171253-7300 Director of Reactor Operations Telex No. 92-1473 MIT-CAM Tel. No. (617)253-4202 June 2, 1989 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Document Control Desk Subj ec t: Further Response to Combined Inspection Numbers 50-20/89-01 and 70-938/89-01 l
Gentlemen:
The Massachusetts Institute of Technology Research Reactor (MITR) submitted by its letter of May 6,
1989 the required response to Appendix A cf Combined Inspection Report Numbers 50-20/89-01 and 70-938/89-01.
This letter provides supplemental information.
Subparagraph (a) of the letter dated May 6, 1989 noted that four fission chambers were at the reactor site but not on the inventory required by 10 CFR 70.51(d).
These chambers were obtained by an experimenter in 1976 from a government laboratory.
Specifically, the chambers were part of a large spectrometer that had been declared surplus.
They have been in storage at MIT from 1976 to 1989 and are now being used as part of a medical research project.
Subparagraph (b) of the letter dated May 6, 1989 noted that eight l
pieces of uranium metal had been identified as being at the reactor I
site but not on the inventory required by 10 CFR 70.51(d).
These
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pieces of metal are depleted uranium.
They have been in dead storage l
in a locked room since July 1969 when they were taken into custody by MIT rather than allowing them to fall into the hands of persons J7 11 A > ' n a ea/_
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USNRC Page 2 unfamiliar with. the health hazards.
MIT reported receipt of these materials to the United States Atomic Energy Commission on July 15, 1969 and was issued a license '(SUB-643, Amendment No. 1) by the U.S.
AEC for possession of the aforesaid materials.on July 23, 1969. These materials have been locked in the MIT Reactor's SNM storage f acility since'the issuance of that license.
They have now been added to the inventory required by 10 CFR 70.51(d).
In. summary, our response to Appendix A of Combined Inspection Report Numbers 50-20/89-01 and 70-938/89-01 is as follows:
(1) Corrective Actions Taken MIT's Central Radioisotope Stor-age Facility.'and storage facilities at the reactor site were reinventoried.
Lists of items stored in those facilities but not on.the inventory required by 10 CFR 70.51(d) were prepared and the items in question added to the inventory.
'(2) Corrective Actions Planned:
No specific further corrective actions are planned.
None are believed necessary because the material being identified as not on the ~ inventory are items acquired by MIT decades ago prior to the establishment of the present system of accountability.
It should be noted that there have been no deficiencies concerning materials acquired under the present accountability system.
We do recognize that there may possibly -be additional items obtained decades ago which are.in storage locations unknown to us.
At present, we do not believe this to.be the case.
However, should such items be identified, they will be sub-sequently added to the inventory.
(3) Date of Full Compliance:
Compliance has been achieved effective the date of this letter.
It shculd be noted that 10 CFR 70 does not identify depleted uranium or natural uranium as Special Nuclear Material and these materials should not rormally be subjected to the same restrictions and requirements as SNM.
However, at the request of the Commission, several licenses were consolidated and the source material license SUB-643 was eliminated.
As a result, the source material in question was - never picked up on the license changes and are now added to SNM-986.
We are now contemplating reestablishing a source material license since the requirements of SNM-986 are unduly restrictive to materials not defined as SNM but which are incorporated into this license.
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'Page 3 Please contact the undersigned if there are any further questions.
Sincerely, p.bW W S
Frederick F. McWilliams MITR Radiation Protection Officer
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g wan wok John A. Bernard, Ph.D.
Superintendent Director of Reactor Operations MIT Research Reactor MIT Research Reactor JAB /gw O. Harling, Director, Nuclear Reactor Laboratory cc F. Masse, MIT Radiation Protection Officer MITRSC USNRC - Region I - Chief, Reactor Projects Section No. 3B USNRC - Region I - Project Engineer, Reactor Projects Section No. 3B USNRC - Senior Resident Inspector, Pilgrim Nuclear Station sUSNRCLRegion'IM Chieff Facilities Radiological ~ Safety and Safeguards Branch
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Division of: Radiation" Safety'and: Safeguards-c 1
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g NUCLEAR REACTOR LABORATORY FM V AN INTERDEPARTMENTAL CENTER OF hig/
MASSACHUSETTS INSTITUTE OF TECHNO!.OGY
~ O K. HARLING '
138 Albany Street. Cambridge, Mass 02139 J A. BERNARD. JR.
Director Telefax No. (617)233 7300 Director of Reactor Operations Telex No. 92-1473 MIT-CAM Tel No (617)253-4202 f.3-yp G May 6, 1989 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Document Control Desk Subj ect:
Response to Combined Inspection Numbers 50-20/89-01 and 70-938/89-01 Gentlemen:
The Massachusetts Institute of Technology Research Reactor (MITR) is in, receipt of the above inspection report, dated April 6, 1989, and this letter is in response to Appendix A (of Docket 50-20) in accor-dance with 10 CFR 2.201.
The MITR acknowledges the Appendix A, Notice of Violation (Docket No. 50-20) and has taken corrective actions to comply with 10 CFR 70.51(d).
Specifically, the following actions were takens (a) SNM material stored in MIT's Central Radioisotope Storage Facility was reinventoried and a list of items not on the inventory required by 10 CFR 70.51(d) was prepared.
These items have now been added to that inventory.
(b) ShH material stored at the reactor site was reinventoried.
Four fission chambers which were not on the inventory and which were obtained for use in monitoring the neutron beams associated with spectrometers were identified.
Also, eight pieces of uranium metal were identified.
These will be added to the inventory required by 10 CFR 70.51(d).
(Action to be completed by 17 May 1989.)
The above actions fully address the issue raised in Appendix A of l
the Inspection Report and bring us into full compliance with regula-I
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USNRC Page 2 tivn 10 CFR 70.51(d). Please contact the undersigned if there are any further questions.
Sincerely,
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wok John A. Bernard, Ph.D.
w Superintendent Director of Reactor Operations
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MIT Research Reactor MIT Research Reactor JAB /gw cc O. Harling, Director, Nuclear Reactor Laboratory l
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'se, MIT Radiation Protection Officer F..
dilliams, MITR Radiation Protection Officer MITRSC (with enclosure)
USNRC' ?Regior. I 1 Chief, Reactor Proj ects Section No. 3B USNRC - Region I - Project Engineer, Reactor Projeev a Section No. 3B USNRC - Senior Resident Inspector, Pilgrim Nuclear Station