IR 05000223/2007201

NRC Inspection Report No. 50-223/2007-201 on March 26-29, 2007 for Univ. of Massachusetts - Lowell Research Reactor Facility and Notice of Violation

ML071130003
Person / Time
Site:	University of Lowell
Issue date:	04/23/2007
From:	Case M J NRC/NRR/ADRA/DPR
To:	Kegel G H Univ of Massachusetts - Lowell
Eads J H, NRR/ADRA/DPR/PRTB, 415-1471
References
IR-07-201
Preceding documents:	ML071380252 (21 May 2007)
Download: ML071130003 (20)

Text

April 23, 2007

Dr. Gunter KegelDirector - Radiation Laboratory University of Massachusetts - Lowell One University Avenue Lowell, MA 01854

SUBJECT: NRC INSPECTION REPORT NO. 50-223/2007-201

Dear Dr. Kegel:

This letter refers to the inspection conducted on March 26-29, 2007, at your Research ReactorFacility. The inspection included a review of activities authorized for your facility. The enclosed report documents the inspection results, which were discussed on March 29, 2007, with you, Dr. John Wooding, Provost, and other members of your staff.Areas examined during the inspection are identified in the report. Within these areas, theinspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, the NRC has identified a violation of NRC requirements. The violation is cited in the enclosed Notice of Violation (Notice). The circumstances surrounding it are described in detail in the subject inspection report. The violation is of concern because it indicates a lack of attention to detail. In addition, one unresolved item and one inspector follow-up item were identified which will be revisited in a future inspection. You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response. The NRC will use your response in accordance with its policies to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.Should you have any questions concerning this inspection, please contact Marcus H. Voth at301-415-1210.

Sincerely,/RA/Jennifer Golder forMichael J. Case, DirectorDivision of Policy and Rulemaking Office of Nuclear Reactor RegulationDocket No. 50-223License No. R-125

Enclosures:

1. Notice of Violation 2. NRC Inspection Report No. 50-223/2007-201 cc w/enclosures: See next page University of Massachusetts - LowellDocket No. 50-223 cc:

Mayor of LowellCity Hall Lowell, MA 01852Mr. Leo BobekReactor Supervisor University of Massachusetts - Lowell One University Avenue Lowell, MA 01854Office of the Attorney GeneralEnvironmental Protection Division

19 th FloorOne Ashburton Place Boston, MA 02108Department of Environmental ProtectionOne Winter Street Boston, MA 02108Director Radiation Control Program Department of Public Health 90 Washington Street Dorchester, MA 02121Nuclear Preparedness ManagerMassachusetts Emergency Management Agency 40 Worcester Road Framingham, MA 01702-5399Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML071130003OFFICEPRTB:RIPRTB:LAPRTB:BCDPR:DIRNAMEMVoth:cahEHyltonJEadsMCase DATE4/23/074/23/07 ENCLOSURE 1NOTICE OF VIOLATIONRadiation LaboratoryDocket No.: 50-223University of Massachusetts - LowellLicense No.: R-125During an NRC inspection conducted on March 26-29, 2007, a violation of NRC requirementswas identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:10 CFR 55.53 Conditions of licenses, states "Each license contains and is subject to thefollowing conditions whether stated in the license or not:." 55.53(h) states "The licensee shallcomplete a requalification program as described by 55.59." 55.59 Requalification, states "(a)

Requalification requirements. Each licensee shall - (1) Successfully complete a requalification program ..... conducted for a continuous period not to exceed 24 months in duration. (2) Passa comprehensive requalification written examination and an annual operating test. .... (c) Requalification program requirements. .... (1) Schedule. The requalification program must beconducted for a continuous period not to exceed two years, and upon conclusion must be promptly followed, pursuant to a continuous schedule, by successive requalification programs."Contrary to the above, one licensed senior reactor operator did not take requalification writtenexaminations or annual operating tests between 1998 and 2004.This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, the University of Massachusetts - Lowell is herebyrequired to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the responsible inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and shouldinclude: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an Order or Demand for Information may be issued as to why the facility license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.If you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the Publicly Available Records (PARS) component of the

-2-NRC's document system (ADAMS), to the extent possible, it should not include any personalprivacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal privacy or proprietaryinformation is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.In accordance with 10 CFR 19.11, you may be required to post this Notice within two workingdays.Dated at Rockville, Marylandthis 23 rd day of April, 2007 U. S. NUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONDocket No:50-223License No:R-125 Report No:50-223/2007-201 Licensee:University of Massachusetts Facility:Research Reactor at the University of Massachusetts - Lowell Location:Lowell, Massachusetts Dates:March 26-29, 2007 Inspectors:Marcus H. VothPhillip T. YoungApproved by:Johnny Eads, Branch ChiefResearch and Test Reactors Branch B Division of Policy and Rulemaking Office of Nuclear Reactor Regulation EXECUTIVE SUMMARYUniversity of Massachusetts - LowellResearch Reactor FacilityNRC Inspection Report No.: 50-223/2007-201This routine, announced inspection included on-site review of the licensee's programsconcerning organization and staffing; operations, maintenance, and fuel handling logs and records; procedures; reactor operator requalification training; surveillance and limiting conditions for operation; experiments; design changes; oversight committee reviews; emergency planning; and transportation. Specific findings in each of these areas include:Organization and Staffing

!The organization and staffing were consistent with Technical Specification requirements.Operations Logs and Records

!The logs and records of operation provided adequate documentation of operations andindication that Technical Specification requirements were being met.Procedures

!The existing facility procedures and the procedure review and upgrade project werefound to be in accordance with Technical Specification requirements.Requalification Training

!An unresolved item was identified concerning documentation of how ANSI/ANSStandard 15.4 had been applied in medical examinations for licensed reactor operators.

!An apparent violation was identified for the failure of one licensed senior reactoroperator to complete requalification written examinations and annual operating tests which were a condition of the operator's license.

!The licensee was found to be in compliance with other requirements of the regulationsand requalification program.Surveillance and Limiting Conditions of Operations

!The inspector found proper compliance with limiting conditions for operation andcompletion of surveillance requirements in accordance with the licensee's Technical Specifications.Experiments

!The inspector did not identify any failure to meet Technical Specification requirementsbut did identify need for better documentation of the approval process for minor variations of routine experiments which will be reviewed in a subsequent inspection.

-2-Design Changes

!The licensee had demonstrated the ability to implement design changes in accordancewith regulations.Committees, Audits and Reviews

!Review and oversight functions were being executed in accordance with TechnicalSpecification requirements.Emergency Planning

!The emergency preparedness program was maintained in accordance with theEmergency Plan and the emergency procedures.Maintenance Logs and Records

!Maintenance required by Technical Specifications was being performed under thesurveillance program. Fuel Handling Logs and Records

!Fuel inspection was performed and fuel movements were logged in accordance withTechnical Specification requirements.Transportation

!Regulatory and license requirements were met in the shipment reviewed.

REPORT DETAILSSummary of Plant StatusThe licensee's one megawatt research reactor had been operated in support of educationalexperiments and demonstrations, research and service irradiations, reactor operator training, and periodic equipment surveillances. The licensee reported annual operation of 117 critical hours and 55 megawatt hours of operation in the most recent annual report. The inspector observed a reactor checkout and startup during the inspection. 1.Organization and Staffinga.Inspection Scope (Inspection Procedure [IP] 69001)The inspector reviewed the following to verify compliance with the staffingrequirements in Technical Specifications (TS) Section 6.1, Organization and Management:*University of Massachusetts - Lowell (UML) Radiation Laboratory organization chart, Rev. May 2006*Reactor Console Logbook #28 covering the period from February 28,2005 to presentb.Observations and Findings The reactor staff included three staff members with Senior Reactor Operator(SRO) licenses and five licensed student operators, three with SROs and two with ROs. Reactor logbook entries that were reviewed identified personnel at the controls and on call in compliance with TS requirements. Through discussion with personnel the inspector verified that the licensee's organizational structure was consistent with TS Figure 6.1. c.ConclusionThe organization and staffing were consistent with TS requirements.2.Operations Logs and Recordsa.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with regulatory andlicense requirements:*Reactor Console Logbook #28 covering the period from February 28,2005 to present*Operating Procedure RF-RO-9A, Reactor Operator Instruction Form,Rev. August 30, 2001*Operating records from the following 2006 files:

-2-RF-4, Daily Routine Check SheetRF-5, Radiation Monitoring System Daily Checks RF-RO-7B, Pre-Startup Checksheet (Forced Convection)

RF-RO-6A, Critical Hourly Readings RF-RO-6B, Radiation Monitoring Critical Hourly Readings RF-RO-6C, Reactor Shutdown Sheetb.Observations and FindingsThe inspector observed a reactor checkout, startup, increase to full power andshut down. While the operator was thoroughly familiar with the procedures and had committed them to memory, he was methodical in following them and documenting readings. He followed the written instruction RF-RO-9A, Reactor Operator Instruction Form, and completed Forms RF-4, RF-5, RF-RO-6A/B/C, and RF-RO-7B. The inspector reviewed selected reactor console logbook entries and checklists performed over the past year and found them complete. c.ConclusionThe logs and records of operation provided adequate documentation ofoperations and indication that TS requirements were being met.3.Proceduresa.Inspection Scope (IP 69001)The inspector reviewed the following to verify that the licensee was complyingwith the requirements of TS Section 6.3, Operating Procedures:*University of Massachusetts - Lowell Research Reactor (UMLRR)Procedure Manual*Master matrix of procedure changes in process

• Reactor Safety Subcommittee (RSSC) minutes for 2006

• Administrative Procedure AP-1, Procedure Control and Distribution

• Administrative Procedure AP-2, Procedure Developmentb.Observations and FindingsThe inspector reviewed the licensee's system of procedures which addressedeach of the TS requirements. The licensee was three years into a methodical procedure review and upgrade project, reportedly about half done. Priority was being given to those procedures in greatest need of revision. The review policy was that major changes with potential for safety significance were reviewed by the RSSC and signed by the RSSC chairman. Changes of lesser potential for safety significance were reviewed and signed by two staff members and summarized in a report for discussion at the next RSSC meeting. Minor changes of an editorial nature were processed by the author only. The inspector reviewed

-3-RSSC records and procedure changes, concluding that the review being given toprocedure changes was appropriately commensurate with the safety significance of changes. c.ConclusionsThe existing facility procedures and the procedure review and upgrade projectwere found to be in accordance with TS requirements.4.Requalification Traininga.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with the requirementsof 10 CFR Part 55 and the licensee's NRC-approved requalification program:*Requalification Program for Licensed Reactor Operators and LicensedSenior Reactor Operators, License No. R-125, June 22, 1978*ANSI/ANS-15.4-1988, Selection and Training of Personnel for ResearchReactors*UMLRR Reactor Operator Medical Evaluations Records

• UMLRR Reactor Operator Requalification Training Recordsb.Observations and FindingsThe inspector reviewed records of five randomly selected licensed reactoroperators. Compliance with requirements was verified with the following exceptions. In all cases physical examinations were performed within the required timeperiods. However, it was not clear from records that medical examinations were performed in accordance with the ANSI standard as was certified by the facility on NRC Forms 396. While the inspector did not observe any indication that operators may not meet these criteria, documentation did not consistently indicate that tests were performed to substantiate conclusions regarding ANSI/ANS 15.4-1988 Section 7.2.3, Disqualifying Conditions, and 7.2.4, Specific Minimum Capacities Required for Medical Qualification, or whether special consideration was given under 7.3, Waiver or Specifically Limited Approval. This matter is identified as an Unresolved Item (URI) and will be reviewed during a future inspection (URI 50-223/2007-201-01).Records indicated that one NRC licensed SRO did not take requalification writtenexaminations or annual operating tests between 1998 and 2004. During this time the operator was considered "inactive" and did not perform duties that required an SRO. However, 10 CFR 55.53 requires that as a condition of an operator license the licensee must participate in a requalification program meeting the requirements of 10 CFR 55.59. The facility licensee was informed that failure to administer the written examination or annual operating test to the

-4-SRO in question was an apparent violation (VIO) of 10 CFR 55.53 (VIO 50-223/2007-201-02). c.ConclusionsAn unresolved item was identified concerning documentation of how ANSI/ANSStandard 15.4 had been applied in medical examinations for licensed reactor operators.An apparent violation was identified for the failure of one licensed SRO tocomplete requalification written examinations and annual operating tests which were a condition of the operator's license.The licensee was found to be in compliance with other requirements of theregulations and requalification program.5.Surveillance and Limiting Conditions for Operationa.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with surveillancerequirements and limiting conditions stated in the TS:*Reactor Console Logbook #28 covering the period from February 28,2005, to present*Surveillance Master Schedule

• Operating records from the following 2006 files:RF-4, Daily Routine Check Sheet RF-5, Radiation Monitoring System Daily Checks RF-RO-7B, Pre-Startup Checksheet (Forced Convection)

RF-RO-6A, Critical Hourly Readings RF-RO-6B, Radiation Monitoring Critical Hourly Readings RF-RO-6C, Reactor Shutdown Sheetb.Observations and FindingsThe inspector selected for detailed review a sample of limiting conditions foroperation (LCO) and surveillance requirements from Sections 3.0 and 4.0, respectively, of the facility TS. He proceeded to verify that each selected LCO or surveillance was incorporated in facility procedures, performed on the required frequency, performed in a manner that adequately met the intent of the TS, and documented appropriately. The inspector found that each of these characteristics were being implemented appropriately.c.ConclusionsThe inspector found proper compliance with LCOs and completion ofsurveillance requirements in accordance with the licensee's TS.

-5-6.Experimentsa.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with Section 6.8,Approval of Experiments, of the licensee's TS:*Irradiation Request Forms (IRF) for January 2005 to February 2007b.Observations and FindingsThe TS consider two types of experiments. New experiments require evaluationby the Reactor Safety Subcommittee (RSSC). Performing an experiment having prior RSSC approval or a minor variation of a routine experiment requires approval of the Reactor Supervisor (RS) and Radiation Safety Officer (RSO) or their respective designee. The inspector found that new experiments were evaluated and documented bythe RSSC over the life of the facility with relatively few new experiments evaluated in recent year. Most experiments currently performed are considered minor variations of routine experiments. While the initial experiments considered reactivity worth, effects of pressure and temperature buildup, radiation inventory, etc., the approval process for minor variations was intended to conclude that the variations fell within an umbrella of conditions approved for the initial experiment.

This conclusion was supposedly being documented on IRFs signed by the RS and RSO.The inspector found that some experiments were considered to be identical toothers and were therefore performed without RS and RSO approvals on the IRF.

The IRFs did not reference the original approved experiment under which a minor variation was being considered nor the umbrella considered to exist for approved experiment. While the inspector did not identify a safety issue or non-

compliance, he noted that the IRF as presently used did not document compliance with the TS. The licensee indicated that the IRF usage would be reviewed in light of the inspector's comments. This matter is identified as an Inspector Followup Item (IFI) and will be reviewed during a future inspection (IFI 50-223/2007-201-03).c.ConclusionsThe inspector did not identify any failure to meet TS requirements but did identifyneed for better documentation of the approval process for minor variations of routine experiments which will be reviewed in a subsequent inspection.

-6-7.Design Changesa.Inspection Scope (IP 69001)In order to verify that any modifications to the facility were consistent with10 CFR 50.59, the inspector reviewed selected aspects of:*50.59 Guidance File*Safety Evaluation Determination for UMLRR Drives Control System,February 2003b.Observations and FindingsThe Licensee stated that they did not have a specific procedure for makingchanges to the facility, procedures or experiments but rather worked directly from NRC regulation 10 CFR 50.59 and TS 6.2.2 [RSSC review and audit responsibilities] on the few occasions that facility changes were made. The most recent change that reached the threshold for notification of the NRC via the annual report for the facility, but not prior NRC approval, was the 2003 change cited above. The inspector reviewed this file which consisted of the 50.59 review, design and installation notes, pre-operational test procedures and records of training on the changes. c.ConclusionsThe licensee has demonstrated the ability to implement design changes inaccordance with regulations.8.Committees, Audits, and Reviewsa.Inspection Scope (IP 69001)The inspector reviewed the following to ensure that TS Section 6.2, Review andAudit, was being properly implemented:*UML Radiation Safety Guide, August 2005*Minutes of the RSSC meetings for December of 2005 and March, June,September and December of 2006b.Observations and FindingsThe inspector verified that the TS 6.2 requirements for the RSSC were beingmet. In particular, the Radiation Safety Guide included a charter for the Radiation Safety Committee (RSC), showing the RSSC reporting the RSC and the RSC reporting to the Chancellor. RSSC minutes document meeting frequency, quorums, and matters considered that demonstrate TS compliance.

-7-c.ConclusionsReview and oversight functions were being executed in accordance with TSrequirements.9.Emergency Planninga.Inspection Scope (IP 69001)The inspector reviewed the following to verify that the emergency preparednesswas being maintained:*Emergency Preparedness Plan for the University of MassachusettsLowell Research Reactor, Revision 5*Letters of Agreement with the City of Lowell Fire Department, City ofLowell Police Department, Saints Memorial Medical Center, and Trinity Ambulance Service*results of quarterly inventory of emergency supplies

• results of table top drill conducted February 20, 2007, including thereferenced facility emergency proceduresb.Observations and FindingsThe inspector reviewed the table top drill conducted on February 22, 2007. Thedrill scenarios were realistic and challenging. The drill was well attended by facility staff and campus police. The post drill critique identified three program improvements to enhance campus police response. Letters of agreement for off-site support were renewed in February and March of2007. Interviews with the ambulance service, campus police, and Lowell Fire Department indicated a co-operative and effective relationship.Emergency response supplies were inventoried quarterly. c.ConclusionsThe emergency preparedness program was maintained in accordance with theEmergency Plan and the emergency procedures.10.Maintenance Logs and Recordsa.Inspection Scope (IP 69001)To verify compliance with TS requirements the inspector reviewed selectedaspects of:*Reactor Console Logbook #28 covering the period from February 28,2005 to present

-8-b.Observations and Findings Maintenance that is specified as TS surveillance requirements was treated aspart of the licensee's surveillance program. Such maintenance is therefore addressed in Section 5 of this report along with other surveillance requirements. c.ConclusionsMaintenance required by TS was being performed under the surveillanceprogram. 11.Fuel Handling Logs and Recordsa.Inspection Scope (IP 69001)The inspector reviewed the following to assure compliance with TS 6.3.2:*UMLRR Procedure RO-2, Unloading and Reloading the Core to a KnownConfiguration, Rev.5, Issued April 1, 2005*UMLRR Procedure RO-8, Handling of Irradiated Fuel, Rev.2, IssuedMay 22, 1991*UMLRR Procedure RO-10, Receipt and Storage of New Fuel Elements,Rev.1, Issued February 16, 1984*Core Loading Maps file, 1994 to presentb.Observations and FindingsThe licensee reported that other than fuel moves in and out of the core forinspection, the last fuel moves were made January 3, 2003. TS 4.7 requires that a representative sample of reactor fuel elements must be inspected visually every two years. Documents were reviewed for the inspection of five elements on January 23, 2007. The previous inspection was done in December of 2004. c.ConclusionsFuel inspection was performed and fuel movements were logged in accordancewith TS requirements.12.Transportationa.Inspection Scope (IP 86740)The inspector reviewed the following records to verify compliance with regulatoryrequirements for the shipment of radioactive material:*Shipping records for an Imaging and Sensing Technology detector,shipped July 14, 2006

-9-b.Observations and FindingsThe licensee reported that most shipments had been done under the campusbroad byproduct material license; relatively few shipments were performed under the reactor license which was being inspected. Only one shipment of radioactive material was made under the reactor license since 2004 when some unirradiated highly enriched uranium fuel plates were shipped. The recent shipment identified above was a radiation detector that was subjected to a neutron radiograph, making it slightly radioactive. c.ConclusionRegulatory and license requirements were met in the shipment reviewed.13.Exit MeetingThe inspector presented the inspection results to licensee representatives at theconclusion of the inspection on March 29, 2007. The inspector discussed the observations for each area reviewed and the apparent violation, follow-up item and unresolved item. The licensee acknowledged the findings and did not identify as proprietary any of the material provided to or reviewed by the inspector during the routine inspection.

PARTIAL LIST OF PERSONS CONTACTED LicenseeL. BobekReactor SupervisorG. KegelRadiation Laboratory Directory D. MedichRadiation Safety Officer M. MontesalvoRadiation Services Manager J. NelsonSenior Reactor Operator N. RashidifardSenior Reactor Operator T. ReganChief Reactor Operator S. SnayHealth Physics Technician J. WhiteProfessor of Chemical Engineering and Radiation Safety SubcommitteeChairmanL. WinnettAdministrative Assistant J. WoodingProvost and Vice-Chancellor for Academic AffairsOthersJohn VailCity of Lowell Fire DepartmentJohn ChemalyTrinity Ambulance Service Gus SavastanoMassachusetts Department of Public Health Radiation Control ProgramINSPECTION PROCEDURES USEDIP 69001Class II Non-Power ReactorsIP 86740TransportationITEMS OPENED, CLOSED, AND DISCUSSEDOPENED:50-223/2007-201-01URI Documentation of the application of ANSI/ANS-15.4-1988 in reactor operator medical examinations50-223/2007-201-02VIOFailure of SRO to take requalification written examinations andannual operating tests 50-223/2007-201-03IFIDocumentation of TS compliance when approving minorvariations of routine experimentsCLOSED: None DISCUSSED: None LIST OF ACRONYMS USEDADAMSAgencywide Document Access and Management SystemCFRCode of Federal Regulations HEUHighly Enriched Uranium IFIInspector Followup Item IPInspection Procedure IRFIrradiation Request Form LCOLimiting condition for Operation NRCNuclear Regulatory Commission PARSPublically Available Records PSPPhysical Security Plan ROReactor Operator RSReactor Supervisor RSCReactor Safety Committee RSORadiation Safety Officer RSSCReactor Safety Subcommittee RevRevision SNMSpecial Nuclear Material SROSenior Reactor Operator TSTechnical Specification UMLUniversity of Massachusetts - Lowell UMLRRUniversity of Massachusetts - Lowell Research Reactor URIUnresolved Item VIOViolation