ML20151M502

Responds to NRC Re Violations Noted in Insp 50-223/88-01 on 880314-16 & 22.Corrective Actions:Formal Tracking & Review Process for All Required Surveillance Activities Implemented

ML20151M502
Person / Time
Site:	University of Lowell
Issue date:	07/27/1988
From:	Beghian L MASSACHUSETTS, UNIV. OF, LOWELL, MA (FORMERLY LOWELL
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
EA-88-108, NUDOCS 8808050198
Download: ML20151M502 (3)

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fM t' /JJr/r //JrNJ NdW (617) 452 5000 JUL 2 71988 Dockett No. 50-223 U.S. Nuclear Regulatory Commission Attn: Documerc Control Desk Washington, D.C. 20555 Subject - Rep 1v to a Notice of Violation (EA-88-108)

Gentlemen, i This refers to your "Notice of Violation" dated July 11,1988 as a result of your inspection on hfarch 14-16 and 22,1988. I would like to address each violation seperately.

A. Violation A.I. A.2. and A.3 Failure to perform or maintain records of performing three surveillance activities at the frequency required by Technical Specification.

Response

It is unclear whether these requirements were or were not actually performed. Ilowever, the cause of the violation can be tied j to an inadequate review of the documentation of the surveillance l activity. As discussed in our letter of hiay 19, 1988 to hir. William l Kane, we have implemented a formal tracking and review process for l all required surveillance activities. This tracking and review process has already been implemented and seems to provide the necessary I

mechanism to assure that this review as described in the hiay 19 l letter will provide for full compliance of our required surveillance activities.

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B. Violation B Failure of Reactor Safety Subcommittee (RSS) to meet at a quarterly frequency and failure to provide certain oversite functions required by Technical Specifications.

Response

This violation is the result of our failure to adequately define the person or persons responsible for insuring the proper meeting fr.,quency and to follow through and assure proper actions as a result of RSS dicisions. As described in our letter of May 19, we have proposed a new charter for the RSS which will clearly determine responsibilities of members. This will include the responsibility of the Secretary to ensure meeting frequency and for proper review and signatures by all members of the minutes. The charter review is still in progress. It is expected the RSS and the Radiation Safety Committee will review and approve the charter sometime in the Autumn of 1988. (Some key members of these committees are not available until the beginning of the School year).

C Violation C Failure of the Reactor Safety Subcommittee to review and approve changes to certain facility operating procedures prior to implementation.

Resnonse Our failure to have administrative guide lines outlining 1) what constitutes substantive or non substantive changes to procedures, 2) setting a time frame for non-substantive change review is the basic cause for this violation. The RSS has reviewed all procedures and at the present time we are in compliance on this item. In addition, the Reactor Supervisor has submitted a letter to the RSS outlining what constitutes substantive changes in procedure and proposed that the RSS must review and approve procedural changes at the next scheduled meeting.

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A more detailed outline of our actions in response to these violations is included in the May 19, 1988 letter to Mr. Kane ~(copy enclosed). If you need further explanation or clarification please let me know.

Sincerely yours, Leon Beghian Associated Vice President for Research l

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. 1H?NONw&1 ) LIG ldCl0' Wilt't:CMlly l$DfCCN 2Y 01ec W)!it:cMl'{y JltteitUP forcelf uffasJacbcaefis 0/854 OFFICE OF ACADEMIC AFFAIRS May 19,19 88 William F. Kane, Di recto r Division of Reactor Projects United States Nuclear Regulatory Commission Region 1, 475 Allendale Road King of Prussia, PA 19406 Ge ntleme n :

To summarize our response to the concerns raised in N RC Region I ,

Inspection Report No. 50-223/88-01 and during the Enf o rcement Action Meeting held at the University of Lowell on / p r i l .2 9, 1988, I would first like to address three apparent violations concerning (1) f ailure s to meet Technical Specification required activities, (2) degradation in the pe rformance of the Reactor Saf ety Sub-Committee and (3) inadequate review and approval of procedures as required by Technical Specifications.

Th e apparent violations involving surveillence (50-223/88-01-01) 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 f act performed.

Ho weve 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, h

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iA2 3 l . S e R2cctor Supervisor has institutsd c f ormal monthly mssting with the Chief Reactor Operato r. At this monthly meeting, they will review all maintenance activities and surveillance requirements and records L

for the previous month. At this meeting, they will review this data 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 failures or inade-quacies. In addition, we will review the up coming requirements for the l

next month and determine who is responsible f or the test. 21s meeting, implemented by the Reactor Supervisor, will be the mechanism for deter-mining responsibility f or the perf ormance of the test or pr ocedure and will provide for confirmation of perforinance and review of results at two

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levels (CFO and Reactor Supervispr); up to now this has not been f ormally 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.

l 2e apparent violations (50-223/88-01-03) concerning the activities of the Reactor Safety Sub-Committee (RSS) were addressed individually at the Enf orcement Meeting and are summarized as f ollows:

1) ':ba t the RSS has not met at the frequency internal required by Technical Specifications, i.e., specifically the RSS did not meet between October 1986 and May 1987.  ;

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 member from outside the reactor facility line o rgan i-zation was not met. We have identified a meeting at 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 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-off sheet with the minutes. Ibwever, it should be pointed out that, up to the present, this issue has never been brought up in prior inspections and is not specifically require d by Technical Specifications, and consequently we view 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 f ollowing steps have been taken by myself and/or the Reactor Safety Sub-Committee.

1) A new charter has been drafted for the RSS and after review by the RSS will by submitted to the Univer sit y of Lowell Radiation Safety Co mmi t t ee. 21s charter includes sections requiring specific membership review and signature and delineates responsibility for maintaining minutes and review an'd to follow up on any actions the RSS requires. We' charter is to be amended to define the independent status of the Radiation Safety Officer and clarify the line f unction of this position.

2) Th e RSS has appr oved a proposal by the Reactor Supervisor to have a yearly review and audit of reactor operations by the manager of another research reactor.

We Reactor Supervisor has arranged for the manager of the Rhode Is land Nu clea r Science Ce nt e r and the University of Michigan l'ord Reactor to perform an audit on a yearly basis. mis 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 Univer sity to fill the position of Chief Rcacto r Ope ra t or. he job has been posted according to the procedures agreed to with the appropriate union, the candidate for the position has been selected and will be submitted to the Board of Trustees for final a ppr oval .

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 p urposee and for the purpose of communications with the reactor personnel. In addition, I plan to s i t-i n on the Reactor Supe r viso r 's weekly 'staf f meeting and/or the monthly surveillance review meeting. I plan to have ,

full staf f meetings at least 6 times a yea r.

5) I have already designated the RSO as r espctnsible for the scheduling of RSS meetings, assuring member a f fi rraation of sub-committee minutes and to follow up 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 f acility and to recommend to me those persons who should be responsible for each required activity so 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 Supervisor 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. %e 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 documented role of the Radiation Safety Sub-committee and 3) my increased management oversite role will result the pr ope 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 L EB/m b

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