IR 05000020/2018201
| ML18324A858 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 12/07/2018 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Projects Branch |
| To: | Queirolo A Massachusetts Institute of Technology (MIT) |
| Takacs M, NRR/DLP 415-2042 | |
| References | |
| IR 2018201 | |
| Download: ML18324A858 (16) | |
Text
December 7, 2018
SUBJECT:
MASSACHUSETTS INSTITUTE OF TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000020/2018201
Dear Mr. Queirolo:
From November 6-8, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted a routine announced inspection at the Massachusetts Institute of Technology Research Reactor.
The inspection included a review of activities authorized for this facility. The enclosed report presents the results of that inspection, which were discussed on November 8, 2018, with members of your staff.
The inspection examined activities conducted under your license as they relate to public health and safety to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Mr. Michael Takacs at (301) 415-2042 or electronic mail at Michael.Takacs@nrc.gov.
Sincerely,
/RA/
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
Docket No.50-020 License No. R-37
Enclosure:
As stated
cc: 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
Mr. John Giarrusso, Chief Planning and Preparedness Division Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611-8300
Ms. Sarah M. Don, Reactor Superintendent Massachusetts Institute of Technology Nuclear Reactor Laboratory Research Reactor 138 Albany Street, MS NW12-116B Cambridge, MA 02139
ML18324A858 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/SS*
NRR/DLP/PROB/LA*
NRR/DLP/PROB/BC NAME MTakacs NParker AMendiola DATE 11/26/2018 11/23/2018 12/7/2018
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.: 50-020
License No.:
R-37
Report No.:
05000020/2018201
Licensee:
Massachusetts Institute of Technology
Facility:
Nuclear Reactor Laboratory
Location:
Cambridge, Massachusetts
Dates:
November 6-8, 2018
Inspector:
Approved by:
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
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EXECUTIVE SUMMARY
Massachusetts Institute of Technology Nuclear Reactor Laboratory NRC Inspection Report No. 05000020/2018201
The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Massachusetts Institute of Technology (MIT or the licensee) Class I, 6 megawatt research reactor safety program, including: (1) organization and staffing, (2) review and audit and design change functions, (3) radiation protection, (4) effluent and environmental monitoring, and (5) transportation of radioactive materials since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and was in compliance with NRC requirements.
One inspection follow-up item (IFI) was discussed and closed.
Organization and Staffing
- Organizational structure and staffing were consistent with technical specification (TS)
requirements.
Review and Audit and Design Change Functions
- The MIT Reactor Safeguards Committee (RSC) was meeting as required and reviewing the topics outlined in the TS.
- Annual audits of facility programs were generally conducted as required.
- The design change program satisfied NRC requirements.
Radiation Protection
- Surveys were completed and documented as required.
- Postings and notices met regulatory requirements.
- Staff personnel were wearing dosimetry as required and recorded doses were within the NRCs regulatory limits.
- Radiation survey and monitoring equipment was being maintained and calibrated as required.
- Radiation protection training was being conducted as required and was acceptable.
- The radiation protection and as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.
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Effluent and Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
Transportation of Radioactive Materials
- The licensee continued to ship radioactive material in accordance with regulatory requirements.
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REPORT DETAILS
Summary of Facility Status
The MIT Nuclear Reactor Laboratory (NRL) 6 megawatt research reactor is typically operated for 8 continous weeks followed by a 2 week shutdown in support of facility maintenance and repairs. During the operating period, the reactor is operated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week in support of educational experiments, research and service irradiations, and reactor operator training. The licensees programs were acceptably directed toward the protection of public health and safety, and were in compliance with NRC requirements.
1.
Organization and Staffing
a.
Inspection Scope (Inspection Procedure (IP) 69006)
The inspector reviewed the following regarding the MIT Reactor (designated as MITR-II) organization, staffing, and management responsibilities to ensure that the requirements of TS Section 7, Revision (Rev.) 6, dated November 1, 2010, were being met:
- Management responsibilities
Qualifications of facility radiation protection personnel
The MIT NRL organization chart, dated November 7, 2018
Staffing requirements for operation of the research reactor
The MIT annual report for the period January 1, 2017 to December 31, 2017
Selected portions of the digital console log
b.
Observations and Findings
The inspector reviewed the facility organization and staffing. It was noted that the organizational structure and the responsibilities of the reactor staff had not changed since the last inspection. The Director of Reactor Operations was responsible for the safe operation of the facility and reported to the Director of the MIT NRL. The Director, of MIT NRL in turn reported to the President of the University through the Vice President for Research. This organization was consistent with that specified in the TS.
The radiation protection organization staffing levels at the facility remained consistent with those noted during the last inspection of this facility. The inspector noted that the Deputy Director of Environment, Health, and Safety (EH&S) for the Reactor Radiation Protection Program was responsible for radiation protection for the facility and advised the Director of Reactor Operations in all matters pertaining to radiation protection. The current reactor radiation protection organization consisted of the Deputy Director of EH&S, two Radiation Protection Program Officers (RPPOs), a project technician, three part-time EH&S technicians and an administrative assistant. The Deputy Director was also a member of the facility RSC. It was noted that the reactor radiation protection personnel provided assistance and job coverage for work done by Operations Group personnel.
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c.
Conclusion
The organizational structure, staffing, and staff responsibilities were in accordance with TS requirements.
2.
Review and Audit and Design Change Functions
a.
Inspection Scope (IP 69007)
To verify compliance with TS Sections 7.2.1, 7.2.2, 7.2.3, and Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments, the following documents were reviewed:
- Minutes of the MIT RSC, Meeting No. 111, held October 2, 2018
10 CFR Section 50.59 evaluations completed since the last inspection in December 2017
The MIT annual report for the period January 1, 2017, to December 31, 2017
b.
Observations and Findings
(1)
Review and Audit Functions
The inspector reviewed the revised MIT RSC charter, dated January 23, 2018, and the minutes from the annual RSC meeting held on October 2, 2018, as well as the minutes from a security subcommittee meeting held on May 16, 2018, to verify compliance with TS requirements. Members were appointed and designated in writing as stipulated in the TS. Two new members had been appointed to the RSC since the last inspection. The inspector verified that the new members had met the minimum education requirement, along with the minimum number of years of related nuclear experience, as stipulated in the TS.
The security subcommittee chairman was also verified to be a full RSC member as specified in the RSC charter. A quorum was present for the various meetings and the meeting minutes indicated that a thorough review of the appropriate topics was conducted. The RSC appeared to be appropriately focused on performing both routine reviews and attending to non-routine emerging issues.
As part of its safety oversight program, the licensee had an outside contractor perform an audit of the Records, Requalification, and Maintenance programs. The inspector reviewed the reports of recent internal audits and the audit report provided by the contractor. No significant problems were identified, although various findings and recommendations were noted in the contractor audit. The licensees response to the findings and recommendations appeared to be appropriate.
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(2)
Design Change Functions
The licensee has an established design change review function. It includes the screening and safety review of changes, tests, or experiments to determine if, pursuant to 10 CFR Section 50.59, a change required NRC approval prior to being implemented. The inspector found procedures in place to control the review process and evidence of adherence to the procedures.
The inspector reviewed 10 CFR Section 50.59 evaluations completed since the last inspection in December of 2017. The majority of licensees 10 CFR Section 50.59 reviews concluded that the changes could be implemented at the facility without prior NRC approval. One 10 CFR 50.59 review, regarding the internal review of procedures for experiments not having safety significance, resulted in a TS change which was ultimately approved by the NRC. In all cases, the required safety review forms were completed and approved in accordance with facility procedures.
c.
Conclusion
The review and audit program was being conducted in compliance with the TS.
The design change evaluation program was being implemented in accordance with the TS requirements and NRC regulations.
3.
Radiation Protection
a.
Inspection Scope (IP 69012)
To ensure that the licensee was following the requirements of TS Section 7.3 and 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, the inspector reviewed selected aspects of the following:
- Quarterly Landauer dosimetry reports since the last inspection
Observations of facility areas, equipment, operations, and postings during facility tours
Reportable Occurrence Reports, Unusual Occurrence Reports, and Operator Lessons Learned Reports related to radiation protection for the past year
MIT EH&S Reactor Radiation Protection Procedure 3001, Radiological Surveys, Rev. 8, dated August 2016
The MIT annual report for the period January 1, 2017, to December 31, 2017
b.
Observations and Findings
(1)
Surveys
Daily, weekly, monthly, and other periodic contamination and radiation surveys, outlined in the licensees procedures, were generally completed in a timely manner by radiation protection staff members. Results of the
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surveys were acceptably documented and posted. Any contamination detected in concentrations above established action levels was noted and the area or item was decontaminated.
The inspector accompanied the facility radiation project technician during the routine daily radiation and contamination surveys of both the inside and outside of the facility containment. The inspector noted that the techniques used by the radiation project technician during the surveys were properly performed.
(2)
Postings and Notices
The inspector observed that NRC Form 3, Notice to Employees, was the latest issue and was prominently posted as required by 10 CFR Section 19.11, Posting of notices to workers. The forms were posted on the bulletin board in the main hallway and at the entrance to the reactor building. The inspector determined that radiological signs and survey maps, as noted above, were typically posted at the entrances to controlled areas. Other postings also showed the industrial hazards that were present in various areas as well.
(3)
Dosimetry Use and Results
The inspector observed that dosimetry was acceptably used by facility and contractor personnel. The inspector noted that the licensee used optically stimulated luminescent (OSL) dosimetry for whole body monitoring and thermoluminescent dosimeters (TLD) in the form of finger rings for extremity monitoring. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor (Landauer).
An examination of the OSL results indicating radiological exposures at the facility for the past year showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limits.
(4)
Radiation Monitoring Equipment
Examination of selected radiation monitoring equipment indicated that the instruments had current calibration stickers attached. The instrument calibration records indicated that the calibration of certain portable survey meters was typically completed by licensee staff personnel. In the event that an instrument could not be calibrated by the licensee, it was taken out of service. Calibration frequency met procedural requirements and records were maintained as required. Licensee records for calibration and tracking were comprehensive and well maintained.
The inspector observed the calibration of a portable ion chamber by an RPPO and found that this individual utilized the proper procedure to successfully complete the calibration of the instrument.
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(5)
Radiation Protection Training
The inspector reviewed the general employee radiation protection training given to MIT staff members, to those authorized to use the experimental facilities of the reactor, to students, and to visitors. It was noted that the training was available online through the EH&S website and reinforced with hands on, practical training. The training satisfied the requirements of 10 CFR Part 19 and the training program was acceptable. The inspector also noted that any specialized training, including Radiation Worker I and Radiation Worker II training, was provided on an individual basis by the RPPO for those who needed it. No problems were noted.
The refresher training given included topics such as the facility ALARA program results, safety culture, emergency response, and the importance of understanding the self-reading pocket dosimeter indications.
(6)
ALARA Program
The MIT management ALARA efforts were well organized and continued to produce dose reduction results. ALARA goals were set and performance indicators were established. Each group in the MIT organization had an established ALARA goal for the year and the facility dose was tracked by group, as well as for each individual. The facility is proactively taking action to reduce doses to workers through job planning and equipment improvements.
(7)
Facility Tours
The inspector toured the reactor containment, the reactor control room, and selected support laboratories and maintenance areas with licensee representatives on various occasions. The inspector noted that facility radioactive material storage areas were properly posted. Radiation and high radiation areas were posted as required and properly controlled.
c.
Conclusion
The inspector determined that the Radiation Protection and ALARA Programs, as implemented by the licensee, satisfied regulatory requirements. Specifically, (1) surveys were completed and documented acceptably to permit evaluation of the radiation hazards present, (2) postings and signs met regulatory requirements, (3) personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, and (5) the radiation safety training program was acceptable.
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4.
Effluent and Environmental Monitoring
a.
Inspection Scope (IP 69004)
The inspector interviewed licensee representatives and reviewed the following to verify compliance with the requirements pertaining to discharges from the facility and environmental surveys pursuant to TS 3.7.1 and 3.7.2:
- Facility records of measurements and analysis of effluent samples
MIT EH&S reactor radiation protection procedure 3010, Conduct of Environmental Radiological Surveys, Rev. 1, dated May 2000
The MIT annual report for the period January 1, 2017, to December 31, 2017
b.
Observations and Findings
Environmental radiation monitoring was accomplished by use of TLDs placed at five different monitoring stations within a quarter mile of the reactor. All doses were well within all regulatory limits. The TLDs are in place continously throughout the year and are exchanged on a quarterly basis.
The inspector noted that gaseous releases are discharged to the atmosphere from the containment exhaust stack and continued to be monitored as required, calculated according to procedure, and acceptably documented in the annual report. The predominant environmental release from the facility was due to Argon-41. The airborne concentrations of the gaseous releases were well within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2.
The licensee reported the total annual activity of liquid effluent released from the facility to the sanitary sewer. The combined sources of liquid effluent release are determined to be from the cooling tower, liquid waste storage tanks, and a sink in a restricted area lab. The total activity was reported in terms of two groups: one for tritium and the other for the combined activity of the remaining radionuclides.
The releases were well within the monthly average concentration limits established in 10 CFR Part 20, Appendix B, Table 3.
c.
Conclusion
Effluent release measurements and analyses, and environmental monitoring measurements, demonstrated compliance within regulatory limits.
5.
Transportation of Radioactive Materials
a.
Inspection Scope (IP 86740)
The inspector reviewed the following documents to determine compliance with NRC and Department of Transportation (DOT) regulations governing the transportation of radioactive material (RAM) as specified in 10 CFR Part 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and in 49 CFR Parts 171-178:
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- RAM shipping papers and related records
QA Program for Spent Fuel Shipments, dated May 30, 1991
Training records for individuals designated as shippers
2017 DOT RAM shipping audit completed by the EH&S Deputy Director
The MIT annual report for the period January 1, 2017, to December 31, 2017
b.
Observations and Findings
Through records review and discussions with licensee personnel, the inspector determined that the licensee had shipped radioactive waste and other types of radioactive material since the previous inspection in this area. The records of these shipments indicated that the radioisotope types and quantities were calculated and dose rates measured as required. The radioactive material shipment records of these materials had been completed in accordance with DOT and NRC regulations.
The inspector reviewed the certificate of compliance, dated June 23, 2014, for the current inventory of Type A packages (55 gallon steel drums). The inspector also noted that two spent fuel shipments, each utilizing the Type B(U) package, had occurred since the last inspection. The inspector reviewed the shipping paper records (Bill of Lading) for both spent fuel shipments and observed that these records included all the required information as specified under 49 CFR Parts 172 and 173.
c.
Conclusion
The licensee continued to ship radioactive material in accordance with regulatory requirements.
6.
Exit Interview
The inspection scope and results were summarized on November 8, 2018, with members of licensee management. The inspector described the areas inspected and discussed the preliminary inspection findings. The licensee acknowledged the inspection findings and did not identify any information to be withheld from public disclosure.
Attachment PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
T. Bork
Utilization Manager D. Cormier
Radiation Project Technician S. Don
Superintendent of Reactor Operations E. Lau
Associate Director, Reactor Operations M. Mahowald Radiation Protection Program Officer, EH&S W. McCarthy Deputy Director, Environment, Health, and Safety Office D. Moncton
Director, Nuclear Reactor Laboratory Director, Reactor Operations S. Tucker
Quality Assurance Supervisor
INSPECTION PROCEDURES USED
IP 69004 Class l Research and Test Reactor Effluent and Environmental Monitoring IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69012 Class I Research and Test Reactors Radiation Protection IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened:
None
Discussed:
IFI 05000020/2018201-01 During the week of October 9, 2018, an NRC administered operator licensing examination resulted in an IFI, identifying that two of the three candidates did not adhere to the containment entrance procedure.
Closed:
IFI 05000020/2018201-01 Discussed with licensee management with reference made to MITR-II Administrative Procedure 1.2.5, Visitor Control.
Licensee Training Coordinator also informed of this issue.
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LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable DOT
Department of Transportation EH&S Environmental Health and Safety IP
Inspection Procedure MIT
Massachusetts Institute of Technology MITR Massachusetts Institute of Technology Reactor NRC
U.S. Nuclear Regulatory Commission NRL
Nuclear Reactor Laboratory OSL
Optically Stimulated Luminescent Rev.
Revision RPPO Radiation Protection Program Officer RSC
Reactor Safeguards Committee TLD
Thermoluminescent Dosimeters TS
Technical Specification