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Forwards Safety Insp Rept 50-223/88-01 on 880314-16 & Notice of Violation.Concern Noted That Violation Need Greater Mgt Oversight & Attention to Licensed Activities
	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: ML20151A950; ML20151A954; ML20151A957;
References
	NUDOCS 8807200174
	Download: ML20151A950 (6)
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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 l

individually is minor, collectively these violations indicate a need for 1

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 l

a formal tracking and review process for all Technical Specification required I

surveillances; (2) committed to reinstitute the management level position of ;

thief Reactor Operator; (3) prepared a detailed draft charter for the Reactor l

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 i

of, clearly delineating responsibilities to your employees, and periodically l

monitoring your employee's performance, to assure activities are conducted l

safely and in accordance with the terms of your license. !

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0FFICIAL RECORD COPY KAUCHER 239 5/25/88 - 0001.0.0

07/02/88 i l

8807200174 880711 ,

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ADOCK 0500 3 p .

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University of~Lowell 2 M j 11888

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 <

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 ,

your reply to the violation.

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In accordance with 10 CFR 2.790, a copy of this letter and its enclosure will I

be placed in the NRC Public Document Room. l

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0FFICIAL RECORD COPY KAUCHER 239 5/25/88 - 0002.0.0 l

07/02/88

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University of Lowell j I f fygg

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.,g r,ated M4

William F. Kane, Director

Division of Reactor Projects

Enclosures:

1. Notice of Violation and Enforcement Conference Report No. 50-223/88-01

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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 '

T. Wallace, Reactor Supervisor

Public Document Room (PDR)

local Public Document Room (LPDR)

NuclearSafetyInformationCenter(NSIC)

CommonwealthofMassachusetts(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. Kane, DRP ,

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

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T. Michaels, NRR

F. Miraglia, NRR

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J. Lieberman, OE

L. Chandler, OGC

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0FFICIAL RECORD COPY KAUCHER 239 5/25/88 - 0003.0.0 l

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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,

t .,4

fD'

William F. ne, 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

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 .

D. Haverkamp, DRP

J. Kaucher, DRP

A. Cerne, SRI - Seabrook

R. Gallo, DRS

R. Bores, DRSS

L. Rubenstein, NRR l

T. Michaels, NRR

F. Miraglia, NRR

J. Lieberman, OE

L. Chandler, 0GC

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OFFICIAL RECORD COPY KAUCHER 239 5/25/88 - 0003.0.0

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0FFICIAL RECORD COPY KAUC}lER 239 5/25/88 - 0004.0.0'

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ML20151A950

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