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Insp Rept 50-223/88-01 on 880429.Violations Noted.Findings Documented in Rept Discussed.Licensee Described Corrective Actions Taken or Planned & NRC Enforcement Policy Explained
	ML20151A957
Person / Time
Site:	University of Lowell
Issue date:	07/05/1988
From:	Haverkamp D, Kaucher J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20151A952	List: ML20151A950; ML20151A954; ML20151A957;
References
	50-223-88-01-01, 50-223-88-1-1, NUDOCS 8807200177
	Download: ML20151A957 (2)
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U.S. Nuclear Ragulatory Commission

Region I

Enforcement

Conference

Report for

Inspection No.: 50-223/88-01

Docket No.: 50-223

License No.: R-125

Licensee: University of Lowell

1 University Avenue

Lowell, Massachusetts 01854

Enforcement

Con.~erence At: University of Lowell

Enforcement

Conference Conducted: April 29, 1988

Prepered By: [b ,f/J" M/

__ames Kaucher, Project Engineer Date

Approved By: .

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Du.nald R. Haverkamp, Chief G,/ Date

Reactor Projects Section No. 3C

Summary:

The f1.mdings documented in Inspection Report No. 50-223/88-01 were discussed.

The licensee described corrective actions taken or pl e.nned . The NRC's

enfo--ament policy was explained.

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DETAILS '

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1. Persons Attf . ding

University of Lowell

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Dr. Leon E. Beghian, Associate Vice President for Research

l. Dr. Gunther Kegel, Director, Radiation Laboratory

Dr. James Phelps, Chairman, Radiation Safety Subcommittee

Mr. Thomas Wallace, Nuclear Reactor Supervisor

Mr. Teorge Chabot, Radiation Safety Officer (Former)

Mr. Warren Church, Radiation Safety Officer (Curreat) -;

US Nuclear Regulatory Commission

William F. Kane, Director, Division of Reactor Projects (DRP)

Sonald-R. Haverkamp, Chief, Reactor Projects Section'No. 3C,-ORP

Laniel J. Holody, Enforcement Officer

James E. Kaucher, Project Engineer, RPS 3C, DRP

Antone C. Cerne, Senior Resident Inspector - Seabrook

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2. Conference Summary

The NRC explained the enforcement policy and summarized the following

violations of regulatory requirements:

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Three ter.' aical specification required surveillances were not per- I

formed. 4t the require'J frequency. '

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The failure of the Reactor Safety Subcommittee (RSS) to perform cer- [

tain technical specification required activities.

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A lack of effective management oversight.

The licensee then discussed mitigating circumstances and the following

corrective actions:

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A new charter for the RSS will be written which will clearly deline--

ate responsibilities of members, j

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The institution of an annual audit by the University of Michigan 'and

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[ Rhode Island Nuciear Service Center.

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To augment the staf f by filling the vacant position of Chief Reactor

Operator.

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To implement a more active role ir, the operation of the reactor

facility by upper level management,

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To institute clearly defined checks and balances in the review

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process for activities conducted at the reactor facility.

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ENCLOSURE 2

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OFFICE OF

ACADEMIC AFFAIRS

May 19, 1988

William F. Kan e , Directo r

Division of Reactor Projects

United States tJuclear Regulatory Commission

Region 1, 475 Allendale Road

King of Prussia, PA 19406

Ge ntlemen :

To summarize our response to the concerns raised in tiRC .egion I

In s pect ion Report No . 50-223/88-01 and during the Enforcement Ac tion

Meetine held at the University of Lowell on April 29, 1988, I would

first like to address three apparent violations concerning (1) failures

to meet Technical Specification required activities, (2) degradation in

the performance of the Reactor Safety Sub-Committee and (3) inadequate

review and approval of procedures as required by Technical Specifications.

Se apparent violations involving surveillence (50-213/88-01-01)

were discussed in detail at the enforcement meeting. Th e third listed

(primary flow rate calibration) was performed, however the documentation

of the calibration is missing. The Reactor Operating log book does have

an entry, dated 3-27-8 6, indicating that this item was in fact performed.

Ho we ve r, these missing documents for all three tests indicate the need

for a more rigorous review of all surveillance including activities

required by Technical Specifications, routine maintenance activities and

unscheduled maintenance activities,

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ps ab y

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. We Reactor Supervisor- has instituted ' a f ormal monthly meeting with

the Chief Reactor Operato r. At this monthly meeting, they will review-

all maintenance activities and surveillance requirements _and records

for the previous nonth. At this - meeting, they will review this data

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for completeness, proper frequency, for determination - if results are

consistent with previous records and if they indicate any trends which

may predict potential future problems or equipment f ailutes or inade-

quacies. In addition, we will. review the up coming requirements for the

next month and determine who is responsible f or the test. This meeting, ,

implemented by the Reactor Supervisor, will be the. mechanism for deter-

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mining responsibility f or the perf ormance of the test or procedure and

will provide for confirmation of performance and review of resalta at two

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levels (CRO and Reactor Supervisor); ep to now this has not been f ormally

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done. In addition, the Reactor Supervisor is maintaining a master ' record

of these activities so that they can be easily reviewed by myself, the

Reactor Safety Sub-Committee or others. t

me apparent violations (50-223/88-01-03). concerning the activities j

of the Reactor Safety Sub-Committee (RSS) were addressed individually at

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, the Enforcement Meeting and are summarized as f ollows:

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1) 'Iha t the RSS has not met at the frequency internal

j required by Technical Specifications, i .e., specifically I

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the RSS did not meet between October 1986 and May 198 7. I

i We f eel there are mitigating circumstances since it was

we who identified the lapse.

1 2) On one occasion, the T.S. requirement of at least one

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member from outside the reactor facility line organi .

J zation was not met. We have identified a meeting at 4

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{ which only three members were present and the permanent

chairman was absent. It is, however, our interpretation

, that the RSO, who was present, is outside the reactor

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f acility line organization.

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3) On -the question of' issuance of > minutes without review

signatures- of the attendees, this: omission will be

rectified. by including a sign-of f . sheet .with the

minutes. Howeve r , it should be pointed out that,_up

to the present, this issue has never been brought'up

in prior inspections and is not specifically required

by Technical Specifications, and consequently we view ,

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it as a new requirement .

A' number of other concerns were also brought out:by this' inspection

and Enforcement meeting.

Without restating each concern,: separately, the following steps ~have

been taken by myself and/or the Reactor. Safety.Sub-Committee.

1) A new charter has been draf ted for the RSS and after

review by the RSS will by submitted to the Universit y

of Lowell Radiation Sa fety , Committee. mis charter

includes sections requiring specific membership review

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and signature and delineates responsibility for

maintaining minutes and review and to follow up on any

actions the RSS requires. he charter is to be amended

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to define the independent status of the Radiation

Safety Officer and clarify the line f unction of this

positio n . ,

i 2) Th e RSS has appr oved a proposal by the Reactor

Supervisor to have a yearly review and audit of reactor

operatf.ons by the manager of another research reaccor.

7ne Reactor Supervisor has arranged for the mar.ager of l

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the Rhode Is land 11u clea r . Science Ce nter and the

University of.Michise.n Ford Reactor to perform an audit

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on a yearly basis. Wis audit will be reviewed by the

RSS when it is submitted.

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3)' I have received permission' from the President of the

University to fill the position of Chief Reactor

Ope rator. We job has been posted according to the

procedures agreed to with the appropriate ~ union, the

candidate f or . the position has been selected and will

be submitted to the Board of Trustees for final.

a ppe oval.

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4) As the person in overall charge of the Research Reactor

and other research facilities, _ I ' am making frequent

visits (a t least weekly) for survey purposes and for

the purpose of communications with the reactor

personnel. In addition, I plan to s it-i n on the

Reactor Supervisor's weekly staff meeting and/or the

monthly surveillance review meeting. I plan to have

full staf f meetings at least 6 times a year.

5) I have already designated the RSO as responsible for

the scheduling of RSS meetings, assuring membe r

l affirmation of sub-committee minutes and to follow up

l on sub-committee action items and to report back to the

sub-committee on such items. I have also asked the RSO

and Reactor Supervisor to review all licensed activities

of the facility and to recommend to me those persons

who should be responsible for each required activity so

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that I can insure that responsibility and authority are

clearly delineated.

6) ne Reactor Safety Sub-committee has requested that the

Reactor Supervisor submit a proposal for the implemen-

tation of non-substantive changes in reactor operating

procedures. We Reactor bupervisor has submitted a

letter outlining what constitutes substantive changes

in procedure and proposes that the RSS must review any

procedural changes made this way at the next quarterly

meeting. Se RSS will review the letter at its next

meeting.

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I feel that the steps outlined above, namely, 1) the formalized

review by the CRO and Reactor Supervisor of surveillance activities, 2)

the more active and dc amented role of the Radiation Safety Sub-committee

and 3) my increased management oversite role will result the prope r

adjustments necessary for us to insure that the facility is safely

operated and meets the requirements of our license.

Sincerely yours,

Leon E. Beghian

Associate Vice President f or Research

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ML20151A957

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