ML20151A950
| ML20151A950 | |
| Person / Time | |
|---|---|
| Site: | University of Lowell |
| Issue date: | 07/11/1988 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Beghian L MASSACHUSETTS, UNIV. OF, LOWELL, MA (FORMERLY LOWELL |
| Shared Package | |
| ML20151A952 | List: |
| References | |
| NUDOCS 8807200174 | |
| Download: ML20151A950 (6) | |
See also: IR 05000223/1988001
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N 11198g
Docket No. 50-223
University of Low 311
ATTN: Dr. Leon E. Beghian
Associate Vice President
for Research
1 University Avenue
Lowell, Massachusetts 01854
Gentlemen:
Subject: Notice of Violation and Enforcement Conference Report
(Inspection No. 50-223/88-01)
This refers to the routine safety inspection conducted on March 14-16, 1988,
at the University of Lowell Research Reactor.
The inspection report was sent
to you on April 18, 1988.
During the inspection, three violations. of NRC
requirements were identified. On April 29, 1988, an Enforcement Conference was
conducted with you and members of your staff to discuss the violations, their
causes, and your corrective actions.
The violations are described in the enclosed Notice of Violation, and involve:
(1) failure to perform or to maintain records of performing three surveillance
activities at the
frequency
required by your Technical
Specifications;
(2) failure by the Reactor Safety Subcommittee (P.SS) to perform certain over-
sight functions required by the Technical Specifications; and (3) failtre of
the Reactor Safety Subcommittee to review and approve changes to certain facil-
ity operating procedures prior to their implementation.
The NRC is concerned that although the safety significance of each violation
individually is minor, collectively these violations indicate a need for
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greater management oversight of, and attention to, licensed activities.
It
appears that your actions subsequent to the inspection have addressed this
concern. Specifically, it is our understanding that you have: (1) implemented
a formal tracking and review process for all Technical Specification required
surveillances; (2) committed to reinstitute the management level position of
thief Reactor Operator; (3) prepared a detailed draft charter for the Reactor
3afety Subcommittee (RSS); and (4) established an external audit program with
the University of Michigan and the Rhode Island Nuclear Science Center.
Notwithstanding these actions, the NRC emphasizes the need for, and importance
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of, clearly delineating responsibilities to your employees, and periodically
monitoring your employee's performance, to assure activities are conducted
safely and in accordance with the terms of your license.
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Therefore, although the violations described in the enclosed. Notice of Viola-
tion have been classified as Severity Level IV in accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (Enforcement Policy) (1987), any similar violations in the future
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indicating an inappropriate level of management oversignt of your program may
result in additional and escalated enforcement action.
You are required to respond to the enclosed Notice of Violation and, in prepar-
ing your response, you should follow the instructions specified in the Notice.
In your response, you should document the actiont taken or planned to prevent
recurrence. We have reviewed your letter of May 19, 1988, and in your response
to the Notice of Violation, it is acceptable to refer to it. After reviewing
your response to the Notice of Violation, including your proposed corrective
actions and the results of future inspections, the NRC will determine whether
further enforcement action
is necessary
to ensure compliance with NRC
regulatory requirements.
In the interim, we have two comments concerning your May 19, 1988 letter.
First, regarding the requirement for the RSS to meet at a quarterly frequency
(Violation B.1), we acknowledge that you recognized that the RSS had not met
for seven months. However, based on the fact that there were several periods
where the RSS did not meet at the -equired quarterly frequency between
July 1986 and January 1988, including one occurrence after the one identified
by you, self-identification does not provide sufficient mitigation for NRC not
to issue a violation since your identification did not result in lasting cor-
rective action.
Second, the NRC agrees that Technical Specifications do not
explicitly require that the RSS minutes be signed.
However, the Technical
Specifications do require that some formal method be provided to document the
mandated review functions of the RSS (Violation B.2).
Contrary to the state-
ment in your letter, the enforcement action in this matter is related to the
lack of formal documentation attesting to the required review functions of the
RSS, rather than as a result of the meeting minutes not being signed. We note
that your commitment, as described during the Enforcement Conference and in
your May 19, 1988 letter, to sign the RSS meeting minutes should provide the
approp". ate level of assurance that the integrity of the RSS function is
achieved.
If you should decide to alter this commitment, please notify us in
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your reply to the violation.
In accordance with 10 CFR 2.790, a copy of this letter and its enclosure will
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be placed in the NRC Public Document Room.
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0FFICIAL RECORD COPY KAUCHER 239 5/25/88 - 0002.0.0
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University of Lowell
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The responses directed by this letter and the enclosed Notice of Violation
are not subject to the clearance procedures of the Office of Management' and
Budget, otherwise required by the Paperwork Reduction Act of 1980, PL
No.96-511.
Sincerely,
gc .,g r,ated M4
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William F. Kane, Director
Division of Reactor Projects
Enclosures:
1.
Notice of Violation and Enforcement Conference Report No. 50-223/88-01
2.
University of Lowell Letter dated May.19,1988 from L. Beghian to W. Kane
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cc w/encis:
Dr.- J. Phelps, Program Director for Nuclear Engineering
Dr. G, Kegel, Director, Radiation Laboratory
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T. Wallace, Reactor Supervisor
Public Document Room (PDR)
local Public Document Room (LPDR)
NuclearSafetyInformationCenter(NSIC)
CommonwealthofMassachusetts(2)
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bec w/encis:
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encis)
W. Russell, RA
J. Gutierrez, RC
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D. Holody, EC
W. Kane, DRP
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S. Collins, DRP
J. Wiggins, DRP
D. Haverkamp, DRP
J. Kaucher, DRP
A. Cerne, SRI - Seabrook
R. Gallo, DRS
R. Bores, DRSS
L. Rubenstein, NRR
T. Michaels, NRR
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F. Miraglia, NRR
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J. Lieberman, OE
L. Chandler, OGC
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The responses directed by this letter and the enclosed Notice of Violation
are not subject to the clearance procedures of the Office of Management and
Budget, otherwise required by the Paperwork Reduction .Act of 1980, PL
No.96-511.
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Sincerely,
t .,4
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William F.
ne, Director
Division of Reactor Projects
Enclosures:
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1.
Notice of Violation and Enforcement Conference Report No. 50-223/88-01
2.
University of-Lowell Letter dated May 19, 1988 from L. Beghian to W. Kane
cc w/encis:
Dr. J. Phelps, Program Director for Nuclear Engineering
Dr. G. Kegel, Director, Radiation Laboratory
T. Wallace, Reactor Supervisor
Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
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Commonwealth of Massachusetts (2)
bec w/encis:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encis)
W. Russell, RA
J. Gutierrez, RC
D. Holody, EC
W. Xane, ORP
S. Collins, DRP
J. Wiggins, DRP
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D. Haverkamp, DRP
J. Kaucher, DRP
A. Cerne, SRI - Seabrook
R. Gallo, DRS
R. Bores, DRSS
L. Rubenstein, NRR
T. Michaels, NRR
F. Miraglia, NRR
J. Lieberman, OE
L. Chandler, 0GC
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