ML20154J314

Responds to Concerns Raised in Insp Rept 50-223/88-01 & During 880429 Enforcement Conference.Corrective Actions:New Charter Drafted for Reactor Safety Subcommittee to Include Sections Requiring Specific Membership Review & Signature

ML20154J314
Person / Time
Site:	University of Lowell
Issue date:	05/19/1988
From:	Beghian L MASSACHUSETTS, UNIV. OF, LOWELL, MA (FORMERLY LOWELL
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8805260295
Download: ML20154J314 (5)

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? Ono %iir:cuMy de:enue ha: elf vllussuchusens oiwi OFFICE OF ACADEMIC AFFAIRS May 19, 1988 William F. Kane, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region 1, 475 Allendale Road King of Prussia, PA 19406 Gentlemen:

To summarize our response to the concerns raised in NRC Region I Inspection Report No. 50-223/88-01 and during the Enf o rcement Action Meeting 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 pe rformance of the Reactor Safety Sub-Committee and (3) inadequat e review and approval of procedures as required by Technical Specifications.

The 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 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 maint< nance activities and unscheduled maintenance activities.

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Th e Reactor Supervisor has instituted a formal 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 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 i n ad e-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-mining responsibility for the perf ormance of the test or procedure and will provide for confirmation of performance and review of results at two levels (CRO and Reactor Supervisor); 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-Cbmmittee or others.

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

1) Wat 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 feel there are mitigating circumstances since it was we who identified the lapse.

2) On one occasion, the T.S. r eq ui rement of at least one member from outside the reactor facility li r.e 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 reacto r 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 s ign-o f f 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 University of Lowell Radiation Safety Co mmi t t ee . mis charter includes sections requiring specific membership review and signature and delineates responsibility for maintaining minutes and review and to follow up on any actions the RSS requires. Se charter is to be amended to define the independent status of the Radiation Safety Officer and clarify the line function 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.

Me Reactor Supervisor has arranged for the manager of the Rh od e Is la nd Nu clea r Science Ce nt er and the University of Michigan Ford 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 Reactor Ope ra tor. %e 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 approval.

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 t.he 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 member affirmation of s ub-c ommit t ee minutes and to f ollow 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 t h. 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) The Reactor Safety Sub-committee has requested that the Reactor Supervisor submit a proposal for the implemen-tation of non-s ubstantive 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. Se RSS will review the letter at its next meeting.

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.', o a 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 proper 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/mb l

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