IR 05000020/1986001
| ML20203P536 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 04/23/1986 |
| From: | Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203P533 | List: |
| References | |
| 50-020-86-01, 50-20-86-1, NUDOCS 8605070410 | |
| Download: ML20203P536 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.: 86-01 Docket No.: 50-20 License No.: R-37 Licensee: : Massachusetts Institute of Technology 138 Albany Avenue Cambridge, Massachusetts 02139 Facility Name: MIT Nuclear Laboratories Inspection At: Cambridge, Massachusetts Inspection Conducted: February 25-28, 1986 Inspectors: T. Foley, Senior Resident Inspector, Calvert Cliffs C. Holden nior esident Inspector, Maine Yankee Approved by: . < &/
T. C. Elsasse @ ief, Reactor Projects Section 3C Date Summary: Inspection on February 25-28, 1986 (Report No. 50-20/86-01)
Areas Inspected: A routine unannounced on-site inspection of licensee activities including: Action taken on Previous Inspection Findings, Facility Tour, Facility Operations, Requalification Training, Surveillance, Experiments, Radiation Protec-tions, Audits and Committees, and verification of reduced on-site storage of High Enriched Uranium (HEU).
Results: Although no violations were identified, two concerns were identified regarding documentation of the licensee's bases for changes, test and experiments determined not to involve an unreviewed safety question (Paragraph 5.a), and cali-brations of dosimetry instruments (Paragraph 10). Stored quantities of HEU on site are minimal, and operation of the facility appears to be in conformance with ap-plicable requirement l l
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DETAILS 1. Key Persons Contacted
- J. Bernard, Superintendent, MIT Research Reactor Operations and Maintenance
- L. Clark, Jr. , Director of Reactor Operations
- 0. Harling, Director, Nuclear Reactor Laboratory
- K. Kwok, Assistant Superintendent, MIT Research Reactor
- E. Karaian, MIT Radiation Protection Officer
- Denotes those present at the exit intervie . Licensee Action on Previously Identified Enforcement Items (Closed) (82-01-01) The failure to maintain at least 12 inches edge-to-edge separation of packages containing SNM was corrected by moving the BTF sub-
-to a location not within 12 inches assembly containing edge-to-edge 1.1%
of any other enriched SNM. Addit UO,ionally, within each storage location signs are posted with instructions specifically prohibiting storage within 12 inches of other SN (Closed) (83-02-01) The corrective actions identified in Inspection Report 50-20/83-02, regarding the licensee's failure to adequately post the Hot Cell Area as a High Radiation Area, are still in place. The inspector verified
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the actions taken by the licensee identified in the above repor (Closed) (83-02-02) The inspector verified that the licensee no longer uses yellow and magenta ropes for barriers where radiation areas do not exist, and that Radiation Protection controls the use of radiation area barrier rope (Closed) Violation (85-01-01) The licensee's corrective _ actions to packaging 281 millicuries of Rhenium-186 and 824 millicuries of Rhenium-188 wire and incorrectly labeling the package as 8 millicuries of Chlorine-38 for shipment to Massachusetts General Hospital were as follows:
(1) a specific procedure for " Hot Cell" work was written, (2) the control of work was.re emphasized to Hot Cell workers, (3) specific references are now written on samples and pneumatic tube samples are identified, (4) specifically-shaped containers as indicated on Part II of the work form are used, (5) distinguishable markings on the samples are recorded on Part II of the work form, and (6) the gamma dose rate on the work form is verifie The inspector verified that these actions were performed and in effect during inspection of the facilit l j
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(Closed) (84-01-01) Procedure should be clearly labeled with the title of the individual responsible for its implementation. The licensee has placed the responsibility on the console operator for all immediate actions of Abnormal Operating Procedures (A0P) and Emergency Operating Procedures (E0P). The shift supervisor is responsible for review of the immediate actions and for follow up action. The inspector reviewed A0Ps and found the procedures con-tained the necessary direction to the licensed operator (Closed) (84-01-03) Incorporate Emergency Action Levels (EAL) into procedures such that classification of events is readily availabl The licensee has incorporated into procedures the EALs listed for non-radiological emergencie EALs for " Excess Radiation at the Site Boundary Resulting from a Contained Source" were incorporated into the appropriate procedure. EALs are covered in procedures either as a sub part of major radiological emergencies or emer-gency procedure (Closed) (84-01-04) Accuracy of Procedural Reference The licensee reviewed procedures and corrected the typographical errors which led to the inaccura-cle (Closed) (84-01-05) Provide high range dosimeters within the Containment building emergency lockers. The licensee located two high range dosimeters in the emergency locker in Containment. In addition, other high range dosi-meters are located outside of the Containment for use by other personnel as-sisting in emergency action (Closed) (84-01-06) Provide guidance on supplying dosimetry to medical per-sonne Dosimeters will be issued to responding medical personnel if the in-jury involves radiation exposure or contamination. This action has been pro-ceduralized for medical emergencie (0 pen) (84-01-02) Develop EALS based on specific instrument readings for each of the four classification levels specified in the Emergency Plan. The lic-ensee responded to this item in its reply to Inspection Report 84-01 dated July 25, 1984. This particular item was confusing since the licensee inter-preted the action necessary to close this item as being a rewrite of the Emergency Plan. The licensee listed the actions it would need to accomplish a rewrite of the Emergency Plan and requested additional guidance. NRC Region I responded on September 14, 1984 and forwarded this item to Headquarters for review. The inspector discussed the issue with Headquarters personnel and determined that resolution of this item does not require a rewrite of the Emergency Pla Additional discussions between the licensee and Headquarters j i
were conducte Documentation of the resolution of this item will be reviewed
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in subsequent inspection This item is ope . Facility Tour On February 25, 1986 at about 6:00 p.m. the inspector arrived on site. Ob- l servation of physical security controls appeared adequate. The inspector met the Assistant Superintendent and ascertained that shift staffing was in con-
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formance with Technical Specifications (TS). Subsequently a meeting was con-ducted with the Director of Reactor Operations regarding the scope and purpose of the inspection. A tour of the facility was conducted immediately there-after. General observations of security, health physics controls, housekeep-ing, staffing and back shift operations were noted. Control Room observations and Reactor Plant system parameters were monitored by the inspector and com-pared to Technical Specifications. No inadequacies were noted. Additional tours were made later during subsequent days of the inspection. Inspection tours included: Spent Fuel Pool, New Fuel Vault, Reactor Vessel Head area, Hot Cell, Rad Waste Storage areas, experimental laboratories, Blanket Testing Facility, and Administrative Offices. No inadequacies were identifie . Facility Operation Review The facility is used primarily by MIT graduate students for a variety of neu-tron activation experiments. The licensee continues to operate the reactor continuously from 8:00 a.m. Monday until Friday evening using a three shift schedule. During the inspection the licensee performed various control rod manipulations and demonstrated the " automatic control of reactor power and reactivity constraints" experiment. The licensee demonstrated various reac-tivity limiting controls and safeguards associated with the reactivity control syste The inspectors reviewed shift staffing, Control Room logs and ob-served the operators' performance. Reactor coolant system parameters and system annunciators were discussed with the plant operators. General condi-tions as they applied to fire prevention and radiological cleanliness were cbserved. Although no discrepancies were noted in the above areas, the in-spector had the following comments:
(a) A review of the reactor start up and shutdown checklists was conducte The inspector noted that several start up checklists were not complete since some instrumentation was not checked. The inspector was able to verify, through other documentation, the exact status of the equipmen The instrumentation in question did not impact on Technical Specification
requirements. The licensee agreed that a more thorough review of check-lists was necessar (b) The inspector reviewed the hourly calorimetric calculation performed by the operators. Additionally, the Estimated Critical Position (ECP) cal-culations were reviewed. The October 21, 1985 and February 18, 1986 ECPs did not have all blanks completed. However, the inspector determined that the blanks did not apply to those startups. The licensee agreed that the ECPs should be annotated to show they are complet (c) The inspector also compared Technical Specification surveillance require-ments with Operator Logs. The DF-1 flow recorder is bypassed during reactor start-up. The bypass is removed prior to increasing power above a pre-set leve The inspector reviewed the Bypass Log and determined that the operators were removing this bypass and signing for its removal,
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but the times and dates were not liste This made verification of the reinstatement of the flow recorder difficult. The licensee agreed to study the proble Other operating documentation reviewed included the Job Workbook, Fuel Loading Permission, Shutdown Margin Calculations, and Operators' Logs. In general the licensee's record keeping was acceptable. The filing of data in logs was orderly, and data were easily retrievabl . Audits and Committees A review of audit reports and committee activities was conducte Committees The committee charged with the oversight of reactor safe operation is the Reactor Safeguards Committe The committee meets at least once each year and is responsible to the Administration of MIT. The committee chairman establishes subcommittees to assist the committee in conducting its review functions. The committee or an active subcommittee reviews and approves all operating procedures, emergency plans, proposed modifi-cations to the reactor, the use of reactor related experimental facili-ties and experiments, and all equipment and procedures involving the use of licensed radioactive material in the reactor buildin Through a review of committee activities, the inspector attempted to ascertain that the committee reviews abnormal occurrence and unusual occurrence reports, violations, categories of particular tests and ex-periments, Technical Specification changes, potential unreviewed safety questions (URSQ), emergency plans and security plan The inspector reviewed several unusual occurrence reports and associated corrective actions related to licensee experiments, logs, and emergency plans, and determined that each was properly documented by the Safeguards Committee. It was noted, however, that only " categories" of experiments are reviewed by the Safeguards Committee in order to determine whether an unreviewed safety question exists. The inspector further noted that within a " category", there are experiments which have no safety analysi According to the licensee these other experiments do not require a review by the Safeguards Committee because they are considered " Class B" proce-dures, i.e., they are described in the Safety Analysis Report (SAR) and do not involve an URSQ. Instead, Class B procedures require a review by two licensed operators and the Director of Reactor Operations to de-termine, in part, whether a potential exists for an URSQ and consequently whether further review is required. The bases for this determination is not maintained. Similarly, bases are not maintained for other changes, ,
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tests and experiments, which have previously been reviewed, and deter- l mined not to involve a potential for an URS ,
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The inspector stated that 10 CFR 50.59 Paragraph (a) (1) is permissive in that it allows the licensee to make changes to the facility and its operation as described in the Safety Analysis Report (SAR) without prior approval, provided a change in Technical Specifications is not involved or an "unreviewed gafety question" does not exist. Paragraph (b) requires that the licensee maintain records of changes made under the authority of Paragraph (a) (1). These records must include a written safety evaluation which provides the basis for determining whether an unreviewed safety question exist The inspector stated that this meant that any proposed change to a system or procedure, as described in the SAR, either by test or drawings should be reviewed by the licensee to determine whether it involves an unre-viewed safety question, and in all cases, the safety evaluation must provide the basis for determination that the proposed change, test or experiment does not involve an unreviewed safety questio The inspector determined that the licensee complies with the above for those changes, tests and experiments which have been reviewed and deter-mined to have a potential for an URSQ, but not for those that have been determined not to involve an URSQ, in that the bases or reasoning for the " sorting out" (determination of why a potential for an URSQ does not exist) is not documente The licensee questioned the inspector as to what constituted "a change" and how other licensees resolve documenting the basis for changes which occur to system and procedures or drawings described in the SAR. The inspector discussed various acceptable alternatives and subsequently forwarded to the licensee the NRC Policy, Part 9800 of Inspection and Enforcement Manual "CFR Discussions" 10 CFR 50.5 The licensee agreed to further evaluate the requirement in light of the provided NRC interpretation / policy. This matter is unresolved pending the licensee's action to provide the documented bases or rational for those changes, tests or experiments which do not involve an unreviewed safety question (50-20/86-01-01).
b. Audits Audits of facility operations are performed primarily by the Reactor l Superintendent. These audits are quite thorough and comprehensiv l However, corrective action, recommendations and implementation are l largely the responsibility of the Reactor Superintendent. The Super-intendent completed audits of the following, during October through December 1985: 1 (1) Reactor Console Log Unusual or Abnormal Entries !
(2) Changes to procedures / checklists / manuals (3) Job Workbook Records (4) Test and calibrations
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(5) Radiation Surveys and Environmental Monitoring Radioactive Effluent Records (6) Refueling and Excess Reactivity (7) Recommendation of Reportable Occurrence Reports and Unusual Occur-rence Reports (8) Training Files
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(9) QA Program /Tagouts/ License R-3 The Reactor Superintendent performs these audits repetitively on three month cycles throughout the year in addition to his normal duties. The inspector reviewed the above audits for July through December 1985, and noted that there were no substantive finding However, the inspe'ctor questioned the lack of independence and organiza-
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tional frebdom provided by this method of auditing one's own work. The licensee had previously bem concerned about this matter and subsequently initiated an annual independent audit by Mr. W. Fecych, a licensee con-sultant. Audits by Mr. Fecych for the 1984 and 1985 period were reviewed by the inspector and found to encompass outstanding items, operating logs, and dosimetry calibration The inspector stated that although this independence provided more ob-jectivity, the scope and depth of the audits was limiting and should be more comprehensiv The licensee's Safety Analysis Report which described the Quality Assur-ance Plan, dated October 1970, provides justification for not requiring the independence and organizational freedom required by 10 CFR 50, Ap-pendix B; however, Section II.2.2 provides a list of activities which fall under the licensee's Quality Assurance Program, and as such should be included in a schedule to be audited on a periodic frequency. Al-though a clear requirement for audits addressing all aspects of the Quality Assurance Program is not evident, current regulations and indus- t
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try standards do place more emphasis in this area. The inspector recom-
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mended that the licensee consider evaluating current requirements and provide additional independence to those areas within the defined Quality Assurance Program.
6. Technical Specification Surveillance
The inspector ver_ified by review of plant surveillance and other records that i the following TS surveillance requirements-met frequency and acceptance cri- :
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TS N Requirement 6.4. Helium Gas Holder Alarm j 6.4. D2 0 Helium System Alarm-
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TS N Requirement 6.4.15 Reflector Tank D 20 Level Scram 6. Period Lev (1 Indication Off Scale Scram 6.1. Nuclear Safety System Response Time 6.1. D2 0 Reflector Dump Time 6.1. Primary Coolant Flow Scram Time No inadequacies were identifie . Emergency Planning The Massachusetts Institute of Technology Reactor Emergency Plan was reviewe Drills and lectures are periodically (at least annually) performed. Training records, changes in the plan and audits of emergency planning activities were reviewe The November 19, 1985 Emergency Plan Exercise consisted of MIT Reactor Operators, Radiation Protection Personnel and MIT campus polic Local police, hospital and fire department agreements were verified to be up-to-date. The Emergency Plan is up-to-date and being effectively implemented except as noted in paragraph 2, " Licensee Action on Previously Identified Items," Item 84-01-02, which remains ope No inadequacies were identifie . Experiments
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Experiments performed at the MIT Reactor are varie Currently, neutron ac-tivation and analysis and automatic reactivity control experiments are in progress. Experiments are divided into the following categories: reactor operation experiments, Beam Port experiments, incore experiments, thermal column experiments and medical therapy experiments. The licensee uses a
" Proposed Experiment Review and Approval Form" in order to control the appro-val process. The inspector reviewed the following experiments for approvals and safety analysis:
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Use of Dry Ice in Pneumatic Tubes
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Sodium metal filled subassembly in the Blanket Test Facility
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Closed Loop Control of Reactor Power using Shim Blades and Regulating Rods simultaneously The use-of-dry-ice experiment and use-of-sodium experiments were not accom-panied by safety evaluations, however, they were reviewed and approved. The acceptability of these experiments was based on similarity to_the other ex-periments which had previously been approved and which were accompanied by
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a written safety evaluatio The inspector verified that in addition to re-views, approvals, and safety evaluations, predicted parameters were determined and ascertained within tolerance, irradiated items were properly controlled, and individuals conducting the experimentr were trained prior to using the facility (see Training, paragraph 9.b).
No inadequacies were identifie . Training Review
, Requalification Training A review was conducted of licensed operator training, examinations and reactivity manipulation records. Schedules of lectures and samples of lesson plans were also reviewed. The inspector ascertained that required records were maintained and that the licensee requalification training program was current and fully implemente A review of the 1984 and 1985 records indicated that five senior reactor operators had passed their requalification examinations. One reactor operator was upgraded by virtue of passing the SR0 examination. One reactor operator's license duties were suspended by the licensee for failure to take the requalification examinatio No inadequacies were identifie Experiments and Student Training The inspector reviewed documents and discussed with various department staff the training of individuals who conduct experiment Personnel are trained in the following areas:
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Tables from 10 CFR Parts 20 and 30 !
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Procedures for Radiation Protection 1
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Facility Emergency Evaluation Procedure
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Film Badge Classification Procedure
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Radiation Exposure Record Application l
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Exclusion Area Entry Permit '
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Maximum Permissible Dose Each person is given approxima'.ely three days to read the above materia A one and one-half hour lectare is given on the same material followed by a question / answer session to determine students' knowledge of exposure limits and restrictions. Twenty hours of classroom instruction is pro-vided on the use and handling precautions associated with the experi-mental facility and equipment prior to allowing each person to work or attend classes in the buildin _ _
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Retraining is given annually to persons who handle or receive radioactive materials. This retraining includes but is not limited to the following topics:
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Permissible Radiation Doses
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Facility Organization
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Biological Effects of Radiation
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Facility Evacuation Plan No inadequacies were identifie . Radiation Protection Controls
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The inspector noted radiation postings and controls throughout the facilit Radiation instruments were noted to be calibrated and source checked regularl Reviews were conducted of radiation surveys, contamination surveys, exposure records of experiments and MIT staff. (Generally, the radiation levels are less than 5 mr/hr in most accessible areas.) Hot Cells were adequately posted as High Radiation areas. Some small areas around the Beam Ports had higher radiation intensities (as high as 15-25 mr/hr) whereas other areas around the Beam Ports were 1-2 mr/hr. The inspector indicated that 10 CFR 50, Appendix I provides guides for maintaining dose to individuals as low as reasonably achieuble. The licensee agreed to consider placing controls / signs in or around those areas where higher than normal (5 mr/hr) radiation levels could exist to make personnel aware of the potentially higher intensities and to aid personnel in minimizing their dos During review of dosimetry records and calibrations of instruments, the in-spector determined that personnel pocket dosimeters were not being calibrate ;
The inspector noted that 10 CFR 50, Appendix B requires that all devices used to ensure quality should be properly calibrated. The licensee provided a
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i quality assurance audit that previously had identified this same issue. The 1 i
licensee stated that programs would be established to calibrate all dosimetr The inspector indicated that pending licensee action on the Quality Assurance Audit, dated November 18, 1985, this item is unresolved (86-01-02).
11. Stored Quantities of High Enriched Uranium (HEU) On Site In accordance with NRC Inspection and Enforcement Temporary Instruction 2545/1, the inspector examined the quantity, storage and controls associated with HEU on sit The inspector observed the new fuel vault contents to physically ascertain what new fuel was accessible. Only one fuel element and a few miscellaneous components totalling less than 1 kg of HEU were in the new fuel vault. Safe-guard controls associated with the vault are described in Safeguard Inspection Report (50-20/84-02).
Through discussions with the licensee, review of operation history, a1d ob-servation of the Spent Fuel Pool, the inspector determined that the quantity of material exempt from the licensee's inventory of accessible HEU was greater
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than 100 Rem /hr at three feet. The current inventory of accessible fuel is of Low Strategic Significance. ThecurrentMITpolicyistomaintain" hun-dreds" of grams of accessible HEU on site versus the ' thousands" of grams permitted, excluding the self protecting fuel, except just prior to fuel transfer. This was documented in a letter to the Secretary of the Commission from L. Clark, October 19, 198 The licensee is currently awaiting a fuel cask from DOE in order to reduce its inventory of spent fue . Exit Interview At the conclusion of the inspection on February 28, 1986 the inspector met with the director of the facility and reviewed the scope and findings (i.e.,
unresolved items in paragraphs 5 and 10). The inspector noted the licensee's candor and good cooperation. At no time during this inspection was written material provided to the licensee by the inspector.