ML071130003

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NRC Inspection Report No. 50-223/2007-201 on March 26-29, 2007 for Univ. of Massachusetts - Lowell Research Reactor Facility and Notice of Violation
ML071130003
Person / Time
Site: University of Lowell
Issue date: 04/23/2007
From: Michael Case
NRC/NRR/ADRA/DPR
To: Kegel G
Univ of Massachusetts - Lowell
Eads J, NRR/ADRA/DPR/PRTB, 415-1471
References
IR-07-201
Download: ML071130003 (20)


See also: IR 05000223/2007201

Text

April 23, 2007

Dr. Gunter Kegel

Director - Radiation Laboratory

University of Massachusetts - Lowell

One University Avenue

Lowell, MA 01854

SUBJECT: NRC INSPECTION REPORT NO. 50-223/2007-201

Dear Dr. Kegel:

This letter refers to the inspection conducted on March 26-29, 2007, at your Research Reactor

Facility. The inspection included a review of activities authorized for your facility. The enclosed

report documents the inspection results, which were discussed on March 29, 2007, with you,

Dr. John Wooding, Provost, and other members of your staff.

Areas examined during the inspection are identified in the report. Within these areas, the

inspection consisted of selective examinations of procedures and representative records,

interviews with personnel, and observations of activities in progress. Based on the results of

this inspection, the NRC has identified a violation of NRC requirements. The violation is cited in

the enclosed Notice of Violation (Notice). The circumstances surrounding it are described in

detail in the subject inspection report. The violation is of concern because it indicates a lack of

attention to detail. In addition, one unresolved item and one inspector follow-up item were

identified which will be revisited in a future inspection.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response in

accordance with its policies to determine whether further enforcement action is necessary to

ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its

enclosures, and your response (if any) will be made available electronically for public inspection

in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this inspection, please contact Marcus H. Voth at

301-415-1210.

Sincerely,

/RA/Jennifer Golder for

Michael J. Case, Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

Docket No. 50-223

License No. R-125

Enclosures:

1. Notice of Violation

2. NRC Inspection Report No. 50-223/2007-201

cc w/enclosures: See next page

University of Massachusetts - Lowell Docket No. 50-223

cc:

Mayor of Lowell

City Hall

Lowell, MA 01852

Mr. Leo Bobek

Reactor Supervisor

University of Massachusetts - Lowell

One University Avenue

Lowell, MA 01854

Office of the Attorney General

Environmental Protection Division

19th Floor

One Ashburton Place

Boston, MA 02108

Department of Environmental Protection

One Winter Street

Boston, MA 02108

Director

Radiation Control Program

Department of Public Health

90 Washington Street

Dorchester, MA 02121

Nuclear Preparedness Manager

Massachusetts Emergency Management Agency

40 Worcester Road

Framingham, MA 01702-5399

Test, Research, and Training

Reactor Newsletter

University of Florida

202 Nuclear Sciences Center

Gainesville, FL 32611

ML071130003

OFFICE PRTB:RI PRTB:LA PRTB:BC DPR:DIR

NAME MVoth:cah EHylton JEads MCase

DATE 4/23/07 4/23/07

ENCLOSURE 1

NOTICE OF VIOLATION

Radiation Laboratory Docket No.: 50-223

University of Massachusetts - Lowell License No.: R-125

During an NRC inspection conducted on March 26-29, 2007, a violation of NRC requirements

was identified. In accordance with the General Statement of Policy and Procedure for NRC

Enforcement Actions, NUREG-1600, the violation is listed below:

10 CFR 55.53 Conditions of licenses, states Each license contains and is subject to the

following conditions whether stated in the license or not:. 55.53(h) states The licensee shall

complete a requalification program as described by 55.59. 55.59 Requalification, states (a)

Requalification requirements. Each licensee shall - (1) Successfully complete a requalification

program ..... conducted for a continuous period not to exceed 24 months in duration. (2) Pass

a comprehensive requalification written examination and an annual operating test. .... (c)

Requalification program requirements. .... (1) Schedule. The requalification program must be

conducted for a continuous period not to exceed two years, and upon conclusion must be

promptly followed, pursuant to a continuous schedule, by successive requalification programs.

Contrary to the above, one licensed senior reactor operator did not take requalification written

examinations or annual operating tests between 1998 and 2004.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, the University of Massachusetts - Lowell is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the

responsible inspector, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice). This reply should be clearly marked as a Reply to a Notice of Violation and should

include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or

severity level, (2) the corrective steps that have been taken and the results achieved, (3) the

corrective steps that will be taken to avoid further violations, and (4) the date when full

compliance will be achieved. Your response may reference or include previous docketed

correspondence, if the correspondence adequately addresses the required response. If an

adequate reply is not received within the time specified in this Notice, an Order or Demand for

Information may be issued as to why the facility license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, D.C. 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the Publicly Available Records (PARS) component of the

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NRCs document system (ADAMS), to the extent possible, it should not include any personal

privacy, proprietary, or safeguards information so that it can be made available to the public

without redaction. ADAMS is accessible from the NRC Web site at (the Public Electronic

Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal privacy or proprietary

information is necessary to provide an acceptable response, then please provide a bracketed

copy of your response that identifies the information that should be protected and a redacted

copy of your response that deletes such information. If you request withholding of such

material, you must specifically identify the portions of your response that you seek to have

withheld and provide in detail the bases for your claim of withholding (e.g., explain why the

disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential

commercial or financial information). If safeguards information is necessary to provide an

acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days.

Dated at Rockville, Maryland

this 23rd day of April, 2007

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

Docket No: 50-223

License No: R-125

Report No: 50-223/2007-201

Licensee: University of Massachusetts

Facility: Research Reactor at the University of Massachusetts - Lowell

Location: Lowell, Massachusetts

Dates: March 26-29, 2007

Inspectors: Marcus H. Voth

Phillip T. Young

Approved by: Johnny Eads, Branch Chief

Research and Test Reactors Branch B

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY

University of Massachusetts - Lowell

Research Reactor Facility

NRC Inspection Report No.: 50-223/2007-201

This routine, announced inspection included on-site review of the licensees programs

concerning organization and staffing; operations, maintenance, and fuel handling logs and

records; procedures; reactor operator requalification training; surveillance and limiting

conditions for operation; experiments; design changes; oversight committee reviews;

emergency planning; and transportation. Specific findings in each of these areas include:

Organization and Staffing

! The organization and staffing were consistent with Technical Specification requirements.

Operations Logs and Records

! The logs and records of operation provided adequate documentation of operations and

indication that Technical Specification requirements were being met.

Procedures

! The existing facility procedures and the procedure review and upgrade project were

found to be in accordance with Technical Specification requirements.

Requalification Training

! An unresolved item was identified concerning documentation of how ANSI/ANS

Standard 15.4 had been applied in medical examinations for licensed reactor operators.

! An apparent violation was identified for the failure of one licensed senior reactor

operator to complete requalification written examinations and annual operating tests

which were a condition of the operators license.

! The licensee was found to be in compliance with other requirements of the regulations

and requalification program.

Surveillance and Limiting Conditions of Operations

! The inspector found proper compliance with limiting conditions for operation and

completion of surveillance requirements in accordance with the licensees Technical

Specifications.

Experiments

! The inspector did not identify any failure to meet Technical Specification requirements

but did identify need for better documentation of the approval process for minor

variations of routine experiments which will be reviewed in a subsequent inspection.

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Design Changes

! The licensee had demonstrated the ability to implement design changes in accordance

with regulations.

Committees, Audits and Reviews

! Review and oversight functions were being executed in accordance with Technical

Specification requirements.

Emergency Planning

! The emergency preparedness program was maintained in accordance with the

Emergency Plan and the emergency procedures.

Maintenance Logs and Records

! Maintenance required by Technical Specifications was being performed under the

surveillance program.

Fuel Handling Logs and Records

! Fuel inspection was performed and fuel movements were logged in accordance with

Technical Specification requirements.

Transportation

! Regulatory and license requirements were met in the shipment reviewed.

REPORT DETAILS

Summary of Plant Status

The licensees one megawatt research reactor had been operated in support of educational

experiments and demonstrations, research and service irradiations, reactor operator training,

and periodic equipment surveillances. The licensee reported annual operation of 117 critical

hours and 55 megawatt hours of operation in the most recent annual report. The inspector

observed a reactor checkout and startup during the inspection.

1. Organization and Staffing

a. Inspection Scope (Inspection Procedure [IP] 69001)

The inspector reviewed the following to verify compliance with the staffing

requirements in Technical Specifications (TS) Section 6.1, Organization and

Management:

organization chart, Rev. May 2006

  • Reactor Console Logbook #28 covering the period from February 28,

2005 to present

b. Observations and Findings

The reactor staff included three staff members with Senior Reactor Operator

(SRO) licenses and five licensed student operators, three with SROs and two

with ROs. Reactor logbook entries that were reviewed identified personnel at the

controls and on call in compliance with TS requirements. Through discussion

with personnel the inspector verified that the licensees organizational structure

was consistent with TS Figure 6.1.

c. Conclusion

The organization and staffing were consistent with TS requirements.

2. Operations Logs and Records

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with regulatory and

license requirements:

  • Reactor Console Logbook #28 covering the period from February 28,

2005 to present

  • Operating Procedure RF-RO-9A, Reactor Operator Instruction Form,

Rev. August 30, 2001

  • Operating records from the following 2006 files:

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RF-4, Daily Routine Check Sheet

RF-5, Radiation Monitoring System Daily Checks

RF-RO-7B, Pre-Startup Checksheet (Forced Convection)

RF-RO-6A, Critical Hourly Readings

RF-RO-6B, Radiation Monitoring Critical Hourly Readings

RF-RO-6C, Reactor Shutdown Sheet

b. Observations and Findings

The inspector observed a reactor checkout, startup, increase to full power and

shut down. While the operator was thoroughly familiar with the procedures and

had committed them to memory, he was methodical in following them and

documenting readings. He followed the written instruction RF-RO-9A, Reactor

Operator Instruction Form, and completed Forms RF-4, RF-5, RF-RO-6A/B/C,

and RF-RO-7B. The inspector reviewed selected reactor console logbook

entries and checklists performed over the past year and found them complete.

c. Conclusion

The logs and records of operation provided adequate documentation of

operations and indication that TS requirements were being met.

3. Procedures

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify that the licensee was complying

with the requirements of TS Section 6.3, Operating Procedures:

Procedure Manual

  • Master matrix of procedure changes in process
  • Reactor Safety Subcommittee (RSSC) minutes for 2006
  • Administrative Procedure AP-1, Procedure Control and Distribution
  • Administrative Procedure AP-2, Procedure Development

b. Observations and Findings

The inspector reviewed the licensees system of procedures which addressed

each of the TS requirements. The licensee was three years into a methodical

procedure review and upgrade project, reportedly about half done. Priority was

being given to those procedures in greatest need of revision. The review policy

was that major changes with potential for safety significance were reviewed by

the RSSC and signed by the RSSC chairman. Changes of lesser potential for

safety significance were reviewed and signed by two staff members and

summarized in a report for discussion at the next RSSC meeting. Minor changes

of an editorial nature were processed by the author only. The inspector reviewed

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RSSC records and procedure changes, concluding that the review being given to

procedure changes was appropriately commensurate with the safety significance

of changes.

c. Conclusions

The existing facility procedures and the procedure review and upgrade project

were found to be in accordance with TS requirements.

4. Requalification Training

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements

of 10 CFR Part 55 and the licensees NRC-approved requalification program:

  • Requalification Program for Licensed Reactor Operators and Licensed

Senior Reactor Operators, License No. R-125, June 22, 1978

Reactors

  • UMLRR Reactor Operator Medical Evaluations Records
  • UMLRR Reactor Operator Requalification Training Records

b. Observations and Findings

The inspector reviewed records of five randomly selected licensed reactor

operators. Compliance with requirements was verified with the following

exceptions.

In all cases physical examinations were performed within the required time

periods. However, it was not clear from records that medical examinations were

performed in accordance with the ANSI standard as was certified by the facility

on NRC Forms 396. While the inspector did not observe any indication that

operators may not meet these criteria, documentation did not consistently

indicate that tests were performed to substantiate conclusions regarding

ANSI/ANS 15.4-1988 Section 7.2.3, Disqualifying Conditions, and 7.2.4, Specific

Minimum Capacities Required for Medical Qualification, or whether special

consideration was given under 7.3, Waiver or Specifically Limited Approval. This

matter is identified as an Unresolved Item (URI) and will be reviewed during a

future inspection (URI 50-223/2007-201-01).

Records indicated that one NRC licensed SRO did not take requalification written

examinations or annual operating tests between 1998 and 2004. During this

time the operator was considered inactive and did not perform duties that

required an SRO. However, 10 CFR 55.53 requires that as a condition of an

operator license the licensee must participate in a requalification program

meeting the requirements of 10 CFR 55.59. The facility licensee was informed

that failure to administer the written examination or annual operating test to the

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SRO in question was an apparent violation (VIO) of 10 CFR 55.53 (VIO 50-

223/2007-201-02).

c. Conclusions

An unresolved item was identified concerning documentation of how ANSI/ANS

Standard 15.4 had been applied in medical examinations for licensed reactor

operators.

An apparent violation was identified for the failure of one licensed SRO to

complete requalification written examinations and annual operating tests which

were a condition of the operators license.

The licensee was found to be in compliance with other requirements of the

regulations and requalification program.

5. Surveillance and Limiting Conditions for Operation

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with surveillance

requirements and limiting conditions stated in the TS:

  • Reactor Console Logbook #28 covering the period from February 28,

2005, to present

  • Surveillance Master Schedule
  • Operating records from the following 2006 files:

RF-4, Daily Routine Check Sheet

RF-5, Radiation Monitoring System Daily Checks

RF-RO-7B, Pre-Startup Checksheet (Forced Convection)

RF-RO-6A, Critical Hourly Readings

RF-RO-6B, Radiation Monitoring Critical Hourly Readings

RF-RO-6C, Reactor Shutdown Sheet

b. Observations and Findings

The inspector selected for detailed review a sample of limiting conditions for

operation (LCO) and surveillance requirements from Sections 3.0 and 4.0,

respectively, of the facility TS. He proceeded to verify that each selected LCO or

surveillance was incorporated in facility procedures, performed on the required

frequency, performed in a manner that adequately met the intent of the TS, and

documented appropriately. The inspector found that each of these

characteristics were being implemented appropriately.

c. Conclusions

The inspector found proper compliance with LCOs and completion of

surveillance requirements in accordance with the licensees TS.

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6. Experiments

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with Section 6.8,

Approval of Experiments, of the licensees TS:

  • Irradiation Request Forms (IRF) for January 2005 to February 2007

b. Observations and Findings

The TS consider two types of experiments. New experiments require evaluation

by the Reactor Safety Subcommittee (RSSC). Performing an experiment having

prior RSSC approval or a minor variation of a routine experiment requires

approval of the Reactor Supervisor (RS) and Radiation Safety Officer (RSO) or

their respective designee.

The inspector found that new experiments were evaluated and documented by

the RSSC over the life of the facility with relatively few new experiments

evaluated in recent year. Most experiments currently performed are considered

minor variations of routine experiments. While the initial experiments considered

reactivity worth, effects of pressure and temperature buildup, radiation inventory,

etc., the approval process for minor variations was intended to conclude that the

variations fell within an umbrella of conditions approved for the initial experiment.

This conclusion was supposedly being documented on IRFs signed by the RS

and RSO.

The inspector found that some experiments were considered to be identical to

others and were therefore performed without RS and RSO approvals on the IRF.

The IRFs did not reference the original approved experiment under which a

minor variation was being considered nor the umbrella considered to exist for

approved experiment. While the inspector did not identify a safety issue or non-

compliance, he noted that the IRF as presently used did not document

compliance with the TS. The licensee indicated that the IRF usage would be

reviewed in light of the inspectors comments. This matter is identified as an

Inspector Followup Item (IFI) and will be reviewed during a future inspection (IFI

50-223/2007-201-03).

c. Conclusions

The inspector did not identify any failure to meet TS requirements but did identify

need for better documentation of the approval process for minor variations of

routine experiments which will be reviewed in a subsequent inspection.

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7. Design Changes

a. Inspection Scope (IP 69001)

In order to verify that any modifications to the facility were consistent with

10 CFR 50.59, the inspector reviewed selected aspects of:

  • 50.59 Guidance File
  • Safety Evaluation Determination for UMLRR Drives Control System,

February 2003

b. Observations and Findings

The Licensee stated that they did not have a specific procedure for making

changes to the facility, procedures or experiments but rather worked directly

from NRC regulation 10 CFR 50.59 and TS 6.2.2 [RSSC review and audit

responsibilities] on the few occasions that facility changes were made. The most

recent change that reached the threshold for notification of the NRC via the

annual report for the facility, but not prior NRC approval, was the 2003 change

cited above. The inspector reviewed this file which consisted of the 50.59

review, design and installation notes, pre-operational test procedures and

records of training on the changes.

c. Conclusions

The licensee has demonstrated the ability to implement design changes in

accordance with regulations.

8. Committees, Audits, and Reviews

a. Inspection Scope (IP 69001)

The inspector reviewed the following to ensure that TS Section 6.2, Review and

Audit, was being properly implemented:

  • UML Radiation Safety Guide, August 2005
  • Minutes of the RSSC meetings for December of 2005 and March, June,

September and December of 2006

b. Observations and Findings

The inspector verified that the TS 6.2 requirements for the RSSC were being

met. In particular, the Radiation Safety Guide included a charter for the

Radiation Safety Committee (RSC), showing the RSSC reporting the RSC and

the RSC reporting to the Chancellor. RSSC minutes document meeting

frequency, quorums, and matters considered that demonstrate TS compliance.

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c. Conclusions

Review and oversight functions were being executed in accordance with TS

requirements.

9. Emergency Planning

a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify that the emergency preparedness

was being maintained:

Lowell Research Reactor, Revision 5

  • Letters of Agreement with the City of Lowell Fire Department, City of

Lowell Police Department, Saints Memorial Medical Center, and Trinity

Ambulance Service

  • results of quarterly inventory of emergency supplies
  • results of table top drill conducted February 20, 2007, including the

referenced facility emergency procedures

b. Observations and Findings

The inspector reviewed the table top drill conducted on February 22, 2007. The

drill scenarios were realistic and challenging. The drill was well attended by

facility staff and campus police. The post drill critique identified three program

improvements to enhance campus police response.

Letters of agreement for off-site support were renewed in February and March of

2007. Interviews with the ambulance service, campus police, and Lowell Fire

Department indicated a co-operative and effective relationship.

Emergency response supplies were inventoried quarterly.

c. Conclusions

The emergency preparedness program was maintained in accordance with the

Emergency Plan and the emergency procedures.

10. Maintenance Logs and Records

a. Inspection Scope (IP 69001)

To verify compliance with TS requirements the inspector reviewed selected

aspects of:

  • Reactor Console Logbook #28 covering the period from February 28,

2005 to present

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b. Observations and Findings

Maintenance that is specified as TS surveillance requirements was treated as

part of the licensees surveillance program. Such maintenance is therefore

addressed in Section 5 of this report along with other surveillance requirements.

c. Conclusions

Maintenance required by TS was being performed under the surveillance

program.

11. Fuel Handling Logs and Records

a. Inspection Scope (IP 69001)

The inspector reviewed the following to assure compliance with TS 6.3.2:

  • UMLRR Procedure RO-2, Unloading and Reloading the Core to a Known

Configuration, Rev.5, Issued April 1, 2005

  • UMLRR Procedure RO-8, Handling of Irradiated Fuel, Rev.2, Issued

May 22, 1991

  • UMLRR Procedure RO-10, Receipt and Storage of New Fuel Elements,

Rev.1, Issued February 16, 1984

  • Core Loading Maps file, 1994 to present

b. Observations and Findings

The licensee reported that other than fuel moves in and out of the core for

inspection, the last fuel moves were made January 3, 2003. TS 4.7 requires that

a representative sample of reactor fuel elements must be inspected visually

every two years. Documents were reviewed for the inspection of five elements

on January 23, 2007. The previous inspection was done in December of 2004.

c. Conclusions

Fuel inspection was performed and fuel movements were logged in accordance

with TS requirements.

12. Transportation

a. Inspection Scope (IP 86740)

The inspector reviewed the following records to verify compliance with regulatory

requirements for the shipment of radioactive material:

  • Shipping records for an Imaging and Sensing Technology detector,

shipped July 14, 2006

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b. Observations and Findings

The licensee reported that most shipments had been done under the campus

broad byproduct material license; relatively few shipments were performed under

the reactor license which was being inspected. Only one shipment of radioactive

material was made under the reactor license since 2004 when some unirradiated

highly enriched uranium fuel plates were shipped. The recent shipment

identified above was a radiation detector that was subjected to a neutron

radiograph, making it slightly radioactive.

c. Conclusion

Regulatory and license requirements were met in the shipment reviewed.

13. Exit Meeting

The inspector presented the inspection results to licensee representatives at the

conclusion of the inspection on March 29, 2007. The inspector discussed the

observations for each area reviewed and the apparent violation, follow-up item and

unresolved item. The licensee acknowledged the findings and did not identify as

proprietary any of the material provided to or reviewed by the inspector during the

routine inspection.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

L. Bobek Reactor Supervisor

G. Kegel Radiation Laboratory Directory

D. Medich Radiation Safety Officer

M. Montesalvo Radiation Services Manager

J. Nelson Senior Reactor Operator

N. Rashidifard Senior Reactor Operator

T. Regan Chief Reactor Operator

S. Snay Health Physics Technician

J. White Professor of Chemical Engineering and Radiation Safety Subcommittee

Chairman

L. Winnett Administrative Assistant

J. Wooding Provost and Vice-Chancellor for Academic Affairs

Others

John Vail City of Lowell Fire Department

John Chemaly Trinity Ambulance Service

Gus Savastano Massachusetts Department of Public Health Radiation Control Program

INSPECTION PROCEDURES USED

IP 69001 Class II Non-Power Reactors

IP 86740 Transportation

ITEMS OPENED, CLOSED, AND DISCUSSED

OPENED:

50-223/2007-201-01 URI Documentation of the application of ANSI/ANS-15.4-1988 in

reactor operator medical examinations

50-223/2007-201-02 VIO Failure of SRO to take requalification written examinations and

annual operating tests

50-223/2007-201-03 IFI Documentation of TS compliance when approving minor

variations of routine experiments

CLOSED:

None

DISCUSSED:

None

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access and Management System

CFR Code of Federal Regulations

HEU Highly Enriched Uranium

IFI Inspector Followup Item

IP Inspection Procedure

IRF Irradiation Request Form

LCO Limiting condition for Operation

NRC Nuclear Regulatory Commission

PARS Publically Available Records

PSP Physical Security Plan

RO Reactor Operator

RS Reactor Supervisor

RSC Reactor Safety Committee

RSO Radiation Safety Officer

RSSC Reactor Safety Subcommittee

Rev Revision

SNM Special Nuclear Material

SRO Senior Reactor Operator

TS Technical Specification

UML University of Massachusetts - Lowell

UMLRR University of Massachusetts - Lowell Research Reactor

URI Unresolved Item

VIO Violation