ML14056A564

Massachusetts Institute of Technology Reactor, Publicly Available Version Enclosure 3, Safety Evaluation Supporting Amendment No. 39 Regarding Changes to the Physical Security Plan

ML14056A564
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	05/12/2014
From:	William Schuster Research and Test Reactors Licensing Branch
To:
Schuster W
Shared Package
ML14056A565	List: ML14056A562 ML14056A564
References
TAC MF2770
Download: ML14056A564 (3)

Text

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 39 TO RENEWED FACILITY OPERATING LICENSE NO. R-37 MASSACHUSETTS INSTITUTE OF TECHNOLOGY MASSACHUSETTS INSTITUTE OF TECHNOLOGY REACTOR DOCKET NO. 50-20

1.0 INTRODUCTION

By letter dated September 10, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13262A129), the Massachusetts Institute of Technology (MIT or the licensee) submitted a license amendment request to the U.S. Nuclear Regulatory Commission (NRC) to revise the NRC-approved MIT physical security plan (PSP) and amend its Renewed Facility Operating License No. R-37, under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90. The proposed changes would revise how areas of the facility are monitored when unoccupied. The details of the proposed changes are considered Safeguards Information and, therefore, are withheld from public disclosure under 10 CFR 73.21, Protection of Safeguards Information: Performance requirements.

2.0 REGULATORY EVALUATION

This safety evaluation addresses the impact of the proposed changes to the PSP. The regulatory requirements and confirmatory action letter commitments, on which the NRC staff based this evaluation, are as follows:

2.1 Regulations The regulations at 10 CFR 73.67, Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance, set forth the physical security plan requirements for licensees using, possessing, or transporting special nuclear material of moderate or low strategic significance. These regulations at 10 CFR 73.67(a)(2) state, in part, that:

the physical protection system shall provide: (i) Early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area containing special nuclear material Section 73.67(d)(3) states that each licensee shall, Monitor with an intrusion alarm or other device or procedures the controlled access areas to detect unauthorized penetration or activities.

2.2 Commitments Between 2002 and 2004, the NRC gained commitments from non-power reactor licensees with nuclear fuel to implement additional security measures (ASMs), which enhanced protection against radiological sabotage or theft. The ASMs include measures to address vehicle threats (e.g., additional barriers and searches), insider threats (e.g., enhanced background checks),

and external land-based threats (e.g., heightened coordination with appropriate local, State, and Federal resources, visitor controls, search of packages). These additional measures, withheld from public disclosure under 10 CFR 73.21, were included as an attachment to a letter entitled, Site-Specific Interim Compensatory Measures for Physical Security in the Current Threat Environment at Research and Test Reactors Licensed to Operate at Power Levels Greater Than or Equal to 2.0 Megawatts (ADAMS Accession No. ML021440592).

2.3 Guidance Regulatory Guide (RG) 5.59, Revision 1, Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance, issued February 1983 (ADAMS Accession No. ML100341301), explains the various provisions and requirements with respect to the physical protection of licensed activities against theft or diversion of special nuclear material or radiological sabotage. RG 5.59 describes the capabilities of a monitoring system, and the various types of detection devices that could be used to meet the requirements of 10 CFR 73.67.

The RG also specifies that security procedures may also be used to protect against theft of special nuclear material, including random patrols by watchmen, in conjunction with detection devices. This defense in depth approach ensures early detection as required by 10 CFR 73.67, and described in RG 5.59.

3.0 TECHNICAL EVALUATION

3.1 Background The previous revision of the licensees NRC-approved PSP, dated October 29, 2003, was based on RG 5.59 and approved as part of license renewal (ADAMS Accession No. ML102310545).

The proposed changes to the PSP would revise the existing description regarding how the licensee will achieve early detection.

3.2 Evaluation The proposed new procedures meet the requirements in 10 CFR 73.67 for physical protection systems and the monitoring of controlled access areas. The proposed changes conform with the guidance for early detection as described in RG 5.59. The proposed new procedures also reduce the possibility that human error will be introduced by changing methodologies currently in place.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes to the NRC-approved PSP. The NRC staff has determined that this amendment involves no significant construction impact and is confined to organizational and procedural matters. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(12). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

5.0 CONCLUSION

Based on its review, the NRC staff has determined that, with the incorporation of the proposed changes, the licensees PSP continues to meet the standards of 10 CFR Part 73, Physical Protection of Plants and Materials.

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

6.0 REFERENCES

1. Massachusetts Institute of Technology letter to U.S. Nuclear Regulatory Commission, License Amendment Regarding MIT Police Inspection Routine, Docket No. 50-20, License R-37, dated September 10, 2013 (ADAMS Accession No. ML13262A129).

2. Massachusetts Institute of Technology, Physical Security Plan for the M.I.T. Research Reactor Facility, dated July 22, 2013.

3. U.S. Nuclear Regulatory Commission letter to Dr. John Bernard, Massachusetts Institute of Technology, et al., Site Specific Interim Compensatory Measures for Physical Security in the Current Threat Environment at Research and Test Reactors Licensed to Operate at Power Levels Greater Than or Equal to 2.0 Megawatts dated June 21, 2002 (ADAMS Accession No. ML021440592).

4. U.S. Nuclear Regulatory Commission, Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance, Regulatory Guide 5.59, Revision 1, February 1983 (ADAMS Accession No. ML100341301).

Principal Contributors: E. Reed W. Schuster IV Date: May 12, 2014