ML20151A957
| 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: |
| References | |
| 50-223-88-01-01, 50-223-88-1-1, NUDOCS 8807200177 | |
| Download: ML20151A957 (2) | |
See also: IR 05000223/1988001
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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
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Prepered By:
__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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ADOCK 04i000223
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DETAILS
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Persons Attf . ding
University of Lowell
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Dr. Leon E. Beghian, Associate Vice President for Research
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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)
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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-
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formed. 4t the require'J frequency.
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The failure of the Reactor Safety Subcommittee (RSS) to perform cer-
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tain technical specification required activities.
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A lack of effective management oversight.
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The licensee then discussed mitigating circumstances and the following
corrective actions:
A new charter for the RSS will be written which will clearly deline--
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ate responsibilities of members,
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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
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Operator.
To implement a more active role ir, the operation of the reactor
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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
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We Reactor Supervisor- has instituted ' a f ormal monthly meeting with
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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,
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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.
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me apparent violations (50-223/88-01-03). concerning the activities
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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
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required by Technical Specifications, i .e., specifically
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the RSS did not meet between October 1986 and May 198 7.
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We f eel there are mitigating circumstances since it was
we who identified the lapse.
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2) On one occasion, the T.S.
requirement of at least one
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member from outside the reactor facility line organi .
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zation was not met. We have identified a meeting at
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which only three members were present and the permanent
chairman was absent.
It is, however, our interpretation
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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
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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 .
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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
to define the independent status of the Radiation
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Safety Officer and clarify the line f unction of this
positio n .
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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
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.
4) As the person in overall charge of the Research Reactor
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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
meetings,
assuring
membe r
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affirmation of sub-committee minutes and to follow up
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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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