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| | issue date = 03/27/2014 | | | issue date = 03/27/2014 |
| | title = Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 | | | title = Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 |
| | author name = Moncton D E | | | author name = Moncton D |
| | author affiliation = MIT Nuclear Reactor Laboratory | | | author affiliation = MIT Nuclear Reactor Laboratory |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:MIT NUCLEAR REACTOR LABORATORY AN MIT INTERDEPARTMENTAL CENTERDavid E. Moncton Mail Stop: NW12-208a Phone: 617 253-8333Director 138 Albany Street Fax: 617 253-7300Cambridge, MA 02139 Email: dem@mit.edu March 27, 2014ATTN: Document Control DeskDirector, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 | | {{#Wiki_filter:MIT NUCLEAR REACTOR LABORATORY AN MIT INTERDEPARTMENTAL CENTER David E. Moncton Mail Stop: NW12-208a Phone: 617 253-8333 Director 138 Albany Street Fax: 617 253-7300 Cambridge, MA 02139 Email: dem@mit.edu March 27, 2014 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 |
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| ==Subject:== | | ==Subject:== |
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| Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 | | Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 |
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| ==References:== | | ==References:== |
| : 1. Letter from Dr. David Moncton, | | : 1. Letter from Dr. David Moncton, Director, MIT Nuclear Reactor Laboratory, to Director, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Feb. 21, 2014. |
| : Director, MIT Nuclear Reactor Laboratory, toDirector, Division of Spent Fuel Storage and Transportation, Office of NuclearMaterial Safety and Safeguards, U.S. Nuclear Regulatory Commission, Feb. 21,2014.2. Letter from Mark Lombard, Director Division of Spent Fuel Storage andTransportation, Office of Nuclear Material Safety and Safeguards, U.S. NuclearRegulatory Commission, to Dr. David E. Moncton,
| | : 2. Letter from Mark Lombard, Director Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, to Dr. David E. Moncton, Director, MIT Nuclear Reactor Laboratory, Jan. 24, 2014. |
| : Director, MIT NuclearReactor Laboratory, Jan. 24, 2014.
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| ==Dear Sir or Madam:== | | ==Dear Sir or Madam:== |
| It has come to our attention that a statement in MIT's letter dated February 21, 2014,Reference 1, could be interpreted in a way that was not intended. | | |
| By way of background, NRC'sletter to MIT dated January 24, 2014, Reference 2, notified MIT that based on an NRCinvestigation, an apparent violation of NRC regulations had been identified. | | It has come to our attention that a statement in MIT's letter dated February 21, 2014, Reference 1, could be interpreted in a way that was not intended. By way of background, NRC's letter to MIT dated January 24, 2014, Reference 2, notified MIT that based on an NRC investigation, an apparent violation of NRC regulations had been identified. NRC requested MIT to submit a written response, participate in a predecisional enforcement conference, utilize Alternative Dispute Resolution, or accept the violation as characterized in the letter. MIT prepared and submitted a written response, Reference 1. In that response, MIT described, among other things, the corrective steps that have been taken and the results those actions have achieved. With regard to the latter, MIT noted that "since the occurrence of the event that forms the basis for the NRC's issuance of the referenced apparent violation, one additional shipment has taken place in full compliance with the SAR [Battelle Energy Alliance Research Reactor (BRR) Safety Analysis Report]." |
| NRC requested MIT to submit a written response, participate in a predecisional enforcement conference, utilizeAlternative Dispute Resolution, or accept the violation as characterized in the letter. MITprepared and submitted a written response, Reference | | In order to avoid an unintended interpretation, MIT wishes to provide clarification of this sentence. In particular, that MIT made three shipments using the BRR package since the occurrence of the event that formed the basis for the NRC's issuance of the referenced apparent I7 |
| : 1. In that response, MIT described, amongother things, the corrective steps that have been taken and the results those actions haveachieved.
| | |
| With regard to the latter, MIT noted that "since the occurrence of the event that formsthe basis for the NRC's issuance of the referenced apparent violation, one additional shipmenthas taken place in full compliance with the SAR [Battelle Energy Alliance Research Reactor(BRR) Safety Analysis Report]." | | Document Control Desk March 27, 2014 Page 2 of 2 violation with the last of these shipments taking place after the completion of those particular corrective actions listed in Reference 1 designed to ensure that all components MIT replaced for use in the BRR package were those conforming to the BRR package SAR. However, the parts and components MIT replaced for use in all three shipments (April 23, 2012, October 24, 2012, and April 3, 2013) did conform to the BRR package SAR. The avoidance of a recurrence of the event that formed the basis for the apparent violation identified in Reference 2, namely installing and using a component that was not specified by the BRR package SAR, suggests that MIT's actions taken to date have been effective. |
| In order to avoid an unintended interpretation, MIT wishes to provide clarification of thissentence. | | Sincerely, David E. Moncton DEM}} |
| In particular, that MIT made three shipments using the BRR package since theoccurrence of the event that formed the basis for the NRC's issuance of the referenced apparentI7 Document Control DeskMarch 27, 2014Page 2 of 2violation with the last of these shipments taking place after the completion of those particular corrective actions listed in Reference 1 designed to ensure that all components MIT replaced foruse in the BRR package were those conforming to the BRR package SAR. However, the partsand components MIT replaced for use in all three shipments (April 23, 2012, October 24, 2012,and April 3, 2013) did conform to the BRR package SAR. The avoidance of a recurrence of theevent that formed the basis for the apparent violation identified in Reference 2, namely installing and using a component that was not specified by the BRR package SAR, suggests that MIT'sactions taken to date have been effective. | |
| Sincerely, David E. MonctonDEM}} | |
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Category:Letter
MONTHYEARML24220A1502024-10-0909 October 2024 Examination Report Letter No. 50-020/OL-24-02 Massachusetts Institute of Technology ML24220A1512024-10-0909 October 2024 Examination Result Letter No 50 020 OL 24 02 Massachusetts Institute of Technology IR 05000020/20242012024-09-12012 September 2024 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000020/2024201 ML24199A1082024-07-23023 July 2024 Examination Confirmation Letter No. 50-020/OL-24-02, Massachusetts Institute of Technology ML24052A2102024-06-0606 June 2024 Examination Result Letter No. 50-020/OL-24-01, Massachusetts Institute of Technology ML24127A1012024-04-26026 April 2024 Mit - Update of Professor Ian A. Waitz Named as Mit Vice President for Research ML24127A1002024-04-24024 April 2024 Mit - Proposal for Conversion to Low Enriched Uranium (Leu), Mit Research Reactor ML24094A0482024-03-29029 March 2024 Mit Nuclear Reactor Lab., Annual Report for 2023, Per Technical Specification 7.7.1 ML24081A1642024-03-11011 March 2024 Massachusetts Institute of Technology, NF-0343 & NW-0681 - Submittal of Rescinding Notice of Cancellation ML24022A0972024-01-22022 January 2024 Massachusetts Institute of Technology– Change of Facility Backup Project Manager ML23354A1442024-01-0505 January 2024 Examination Confirmation Letter No. 50-020/OL-24-01, Massachusetts Institute of Technology IR 05000020/20232032023-11-21021 November 2023 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000020/2023203 ML23242A3382023-11-0606 November 2023 Examination Report Letter No. 50-020/OL-23-01, Massachusetts Institute of Technology ML23242A3392023-11-0606 November 2023 Examination Result Letter No. 50-020/OL-23-01, Massachusetts Institute of Technology IR 05000020/20232012023-10-12012 October 2023 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000020/2023201 IR 05000020/20232022023-09-27027 September 2023 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000020/2023202 ML23194A0412023-07-11011 July 2023 Mit Research Reactor - Duties of Reactor Superintendent ML23103A2632023-05-10010 May 2023 Examination Confirmation Letter No. 50-020/OL-23-01 Massachusetts Institute of Technology ML23094A1102023-03-30030 March 2023 Massachusetts Institute of Technology (Mit), Submittal of Annual Report for 2022, Technical Specification 7.7.1 ML23072A0242023-03-0707 March 2023 Mit, Nuclear Reactor Lab., Proposal for Conversion to Low Enriched Uranium (Leu), Mit Research Reactor IR 05000020/20222012023-02-0707 February 2023 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000020/2022201 ML22189A0492022-07-25025 July 2022 Examination Confirmation Letter No.50-020/OL-22-02, Massachusetts Institute of Technology ML22095A2412022-03-31031 March 2022 Annual Report for the Mit Research Reactor for the Period from January 1, 2021, to December 31, 2021 ML22062B0422022-02-10010 February 2022 Proposal for Conversion to Low Enriched Uranium (Leu), Mit Research Reactor, Docket No. 50-20, 10 CFR 50.64 (c)(2)(ii) of That Paragraph ML21328A2342021-11-29029 November 2021 Examination Confirmation Letter No. 50-020/OL-22-01, Massachusetts Institute of Technology IR 05000020/20212032021-11-0909 November 2021 Massachusetts Institutes of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000020/2021203 IR 05000020/20212012021-09-30030 September 2021 Massachusetts Institute of Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report 05000020/2021201 ML21186A0032021-07-16016 July 2021 Examination Confirmation Letter No. 50-020/OL-21-02, Massachusetts Institute of Technology ML21165A1542021-05-28028 May 2021 Mit - Emergency Plan and Procedures, 10 CFR 50.54(q)(5) ML21140A3622021-05-17017 May 2021 Massachusetts Institute of Technology (Mit) - Supplement to Response to the Request for Additional Information for Battery Upgrade License Amendment Request (EPID: L-2021 -NFA-0000) ML21132A2512021-05-0606 May 2021 Massachusetts Institute of Technology, License No. R-37, Docket No. 50-20, Reportable Occurrence 50-20/2021-: Operation with Less than the Required Staffing on Site; NRC OPS Center Log EN 55212 ML21112A1672021-04-12012 April 2021 Massachusetts Institute of Technology - Physical Security Plan Revision Regarding Biometric Readers ML21105A3602021-04-0707 April 2021 Duties of Reactor Superintendent ML21099A1132021-03-31031 March 2021 Massachusetts Institute of Technology - Annual Report, Docket No. 50-20, License R-37, Technical Specification 7.7.1 ML21091A2082021-03-24024 March 2021 Mit Nuclear Reactor Lab - Response to Request for Additional Information for Battery Upgrade License Amendment Request ML21076A0232021-03-18018 March 2021 Requests for Additional Information - Related to License Amendment Request to Replace Emergency Power System Batteries ML21070A1852021-03-0202 March 2021 Mit Nuclear Reactor Laboratory, License Amendment Request Regarding Emergency Battery Surveillances in Technical Specification 4.6, Docket No. 50-20, License R-37 ML21063A2552021-02-25025 February 2021 Proposal for Conversion to Low Enriched Uranium (Leu), :Mit Research Reactor, Docket No. 50-20, 10 CFR 50.64 (c)(2)(ii) of That Paragraph ML21053A4372021-02-23023 February 2021 Examination Confirmation Letter No. 50-020/OL-21-01, Massachusetts Institute of Technology ML21036A0852021-02-19019 February 2021 Massachusetts Institute of Technology - Acceptance of License Amendment Request to Revise Surveillance Frequency During Extended Reactor Shutdown ML21035A2582021-01-29029 January 2021 Massachusetts Institute of Technology (Mit), Supplement to Technical Specifications Surveillance Frequency Definition Update for Improved Compliance Under 10 CPR 50.36(c)(3) ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20307A4202020-11-0505 November 2020 Granting of Extension Request to Supplement License Amendment to Revise Surveillance Requirement Frequency ML20304A1172020-10-19019 October 2020 Time Extension Request for LAR on Technical Specifications Surveillance Frequency Update for Improved Compliance Under 10 CFR 50.36(c)(3) for the Mit Research Reactor ML20248H5682020-09-22022 September 2020 Mit Research Reactor Routine Inspection Report with Enforcement Discretion (EA-20-109) - August 2020 ML20161A3342020-07-24024 July 2020 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 ML20182A7092020-07-0909 July 2020 Acceptance Review Amendment Request to Revise Surveillance Frequency - Opportunity to Supplement ML20192A0762020-06-30030 June 2020 Mit - Supplemental Information for License Amendment Request for Position Title Change in Technical Specifications for Level 1 Staff ML20070H2672020-06-0404 June 2020 Examination Report No. 50-020/OL-20-01, Massachusetts Institute of Technology ML20119A8272020-05-29029 May 2020 Massachusetts Institute of Technology - Issuance of Amendment No. 43 Extending Time to Implement License Amendment No. 42 to Facility Operating License No. R-37 2024-09-12
[Table view] Category:Licensee Response to Enforcement Action
MONTHYEARML14094A2462014-03-27027 March 2014 Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 2014-03-27
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARML14094A2462014-03-27027 March 2014 Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170 ML0802307202008-01-15015 January 2008 NRC Special Inspection Report No. 50-020-07-203 and Notice of Violation EA-06-113 ML0333606942003-11-25025 November 2003 Massachusetts Institute of Technology (Mit) - Response to a Notice of Violation, EA-03-155 ML0229603322002-10-15015 October 2002 Response to TAC No. MB3761, License No. R-37 Dated 10/15/2002 2014-03-27
[Table view] |
Text
MIT NUCLEAR REACTOR LABORATORY AN MIT INTERDEPARTMENTAL CENTER David E. Moncton Mail Stop: NW12-208a Phone: 617 253-8333 Director 138 Albany Street Fax: 617 253-7300 Cambridge, MA 02139 Email: dem@mit.edu March 27, 2014 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Response to Apparent Violation in NRC Investigation No. 1-2013-004; EA-13-170
References:
- 1. Letter from Dr. David Moncton, Director, MIT Nuclear Reactor Laboratory, to Director, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Feb. 21, 2014.
- 2. Letter from Mark Lombard, Director Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, to Dr. David E. Moncton, Director, MIT Nuclear Reactor Laboratory, Jan. 24, 2014.
Dear Sir or Madam:
It has come to our attention that a statement in MIT's letter dated February 21, 2014, Reference 1, could be interpreted in a way that was not intended. By way of background, NRC's letter to MIT dated January 24, 2014, Reference 2, notified MIT that based on an NRC investigation, an apparent violation of NRC regulations had been identified. NRC requested MIT to submit a written response, participate in a predecisional enforcement conference, utilize Alternative Dispute Resolution, or accept the violation as characterized in the letter. MIT prepared and submitted a written response, Reference 1. In that response, MIT described, among other things, the corrective steps that have been taken and the results those actions have achieved. With regard to the latter, MIT noted that "since the occurrence of the event that forms the basis for the NRC's issuance of the referenced apparent violation, one additional shipment has taken place in full compliance with the SAR [Battelle Energy Alliance Research Reactor (BRR) Safety Analysis Report]."
In order to avoid an unintended interpretation, MIT wishes to provide clarification of this sentence. In particular, that MIT made three shipments using the BRR package since the occurrence of the event that formed the basis for the NRC's issuance of the referenced apparent I7
Document Control Desk March 27, 2014 Page 2 of 2 violation with the last of these shipments taking place after the completion of those particular corrective actions listed in Reference 1 designed to ensure that all components MIT replaced for use in the BRR package were those conforming to the BRR package SAR. However, the parts and components MIT replaced for use in all three shipments (April 23, 2012, October 24, 2012, and April 3, 2013) did conform to the BRR package SAR. The avoidance of a recurrence of the event that formed the basis for the apparent violation identified in Reference 2, namely installing and using a component that was not specified by the BRR package SAR, suggests that MIT's actions taken to date have been effective.
Sincerely, David E. Moncton DEM