IR 05000228/1998201
| ML20196F909 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 12/02/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20196F862 | List: |
| References | |
| 50-228-98-201, NUDOCS 9812070155 | |
| Download: ML20196F909 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
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. Docket No:
50-228
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> License No:
R-98
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Report No:
50-228/98-201
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Licensee:
Aerotest Operations, Inc.
i Facility:
Aerotest Radiography and Research Reactor Facility
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' Location:
3455 Fostoria Way
San Ramon, CA 94583
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Dates:
November 2-5,1998 l
- Inspector:
C. H. Bassett
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Senior Non-Power Reactor inspector i
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_ Approved by:
Seymour H. Weiss, Director Non-Power Reactor and Decommissioning l
Project Directorate i
Division of Reactor Program Management Office of Nuclear Reactor Regulation j
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9812070155 9812d2 M
PDR ADOCK 05000228 G
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i EXECUTIVE SUMMARY i
Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor (ARRR)
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Report No: 50-228/98-201 The primary focus of this routine, announced inspection was the on-site review of selects d aspects of the licensee's Class 11 non-power reactor operation including: organization and
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staffing; review and audit functions; procedures; radiation protection and ALARA programs;
effluent and environmental monitoring; the shipment of radioactive material; the safeguards and security program; and the material control and accounting program.
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Changes, Organization, and Staffing
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The licensee's organization and staffing remain in compliance with the requirements f
specified in the Technical Specifications.
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Review and Audit Functions
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Audits were being conducted by the Reactor Safeguards Committee (RSC) in
e compliance with the requirements specified in the Technical Specifications (TS).
Procedures Facility procedures were acceptable and satisfied TS and administrative procedure e
requirements for being revised by the licensee, and reviewed and approved by the RSC.
Radiation Protection Program Surveys were generally completed and documented acceptably to permit evaluation of e
the radiation hazards that might exist.
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l e Notices and postings at entrances to work areas met the regulatory requirements.
Personnel dosimetry was being wom as required and doses were within the licensee's e
procedural action levels and NRC's regulatory limits.
e Radiation monitoring equipment was being maintained and calibrated as required.
e The Radiation Protection and ALARA Programs satisfied regulatory requirements.
e The challenges faced by the licensee in maintaining worker doses ALARA will continue to be reviewed by the NRC.
e Although training was being provided as required, one Inspector Follow-up item was identified to review the development of a formal training plan covering the topics outlined in 10 CFR 19.12
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Effluent and Environmental Monitoring Effluent monitoring satisfied license and regulatory requirements and releases were e
within the specified regulatory and TS limits.
Transportation of Radioactive Mater'als An apparent violation was noted for failure to include all the information required to be e
listed on shipping papers for various shipments of radioactive material.
Safeguards and Security The NRC-approved security program at the facility was acceptably carried out.
e Material Control and Accountability The licensee's program for control and accountability of special nuclear material was e
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REPORT DETAILS Summary of Plant Status The licensee's TRIGA research reactor continues to be operated in support of laboratory
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experiments, reactor operator training, and neutron radiography. During the inspection, the
reactor was being started up and operated several hours per day at one hundred and eighty kilowatts (180 kW) to complete neutron radiographic operations. The maximum authorized power level is 250 kW but the licensee typically operates the reactor at reduced power
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levels to reduce personnel radiation exposures.
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1. Changes, Organization, and Staffing (69001)
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a. Inspection Scope l
i The inspector reviewed the following regarding the licensee's organization and l
staffing to ensure that the requirements of Technical Specifications (TS) Sections i
10.0 and 12.1 were being met:
the organizational structure,
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management responsibilities, and l
a staffing for safe operation of the Reactor Facility.
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b. Observations and Findings
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Through discussions with licensee representatives the inspector determined that
management responsibilities and the organization at the facility had not changed i
since the previous NRC inspection in June 1997 (Inspection Report No. 50-228/97-l 201). The inspector determined that the Reactor Supervisor retained direct control
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and overall responsibility for management of the facility as specified in the TS. The l
. Reactor Supervisor reported to the President, Aerotest Operations, Inc. (AO). It was i
also noted that AO is a wholly-owned subsidiary of Explosive Technology, Inc.
Through review of records and logs and discussions with licensee personnel, the
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inspector determined that the staffing at the facility was acceptable to support the
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work and ongoing activities and met the requirements of the TS. It was noted that
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one Senior Reactor Operator (SRO) had left the company for another job but this did i
not affect the safe operation of tha reactor. The licensee is currently seeking a
person to replace the SRO who resigned.
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c. Conclusions
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The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specifications,
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2. Review and Audit Functions (69001)
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a. Inspection Scope
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' The inspector reviewed the following to ensure that the audits and reviews j
stipulated in the requirements of TS Section 12.3 were being completed:
Reactor Safeguards Committee (RSC) meeting minutes,
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ARRR Procedures, and.
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the TS duties specified for the RSC including the committee's review and audit
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The inspector alco toured the licensee's facility to note any changes that may have l
been made and reviewed the program established by the licensee to ensure that activities at the facility were reviewed and audited as required.
b. Observations and Findings i
Section 12.3 of the TS requires that the Reactor Safeguards Committee meet at f
least once yearly to review safety aspects of facility operation. The inspector reviewed the'RSC's meeting minutes from January 1996 to the present. These
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meeting minutes showed that the RSC had met annually as required and had l
considered the types of topics outlined by the TS, including ALARA challenges
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faced by the facility.
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.The inspector noted that committee personnel had completed audits of different but complimentary aspects of the reactor facility operations and programs. During the l
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period reviewed, audits had been completed by the RSC i i those areas outlined in l
the TS. The latest audit concluded that the facility procedures were not being
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reviewed every two years as required. The audits and the resulting findings were detailed and that the licensee's responses and corrective actions were acceptable.
The inspector toured the control room, sample preparation area, and various support areas at the facility. No changes from the facility descriptions or annual report
. description of changes were noted.
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c. Conclusions
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' Audits were being conducted by the RSC according to the requirements specified in
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the Technical Specifications.
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i 3. Procedures (69001)
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a. Inspection Scope
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The inspector reviewed the following to ensure that the requirements of TS Section 12.2 were being met concerning written procedures.
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i selected operations procedures,
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the process used by the licensee to revise, review, and approve all facility
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procedures.
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b. Observations and Findings
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The inspector verified that procedures had been developed for reactor operations i
and safety. As noted above, the last RSC audit of the facility determined that
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procedures were not being reviewed as required. The licensee indicated that this i
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was an oversight and that reviews were in progress. It was noted that revisions to l
procedures were presented by the licensee to the RSC for review and approval. The
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revisions were acceptable and in accordance with 10 CFR 20, TS,'and ARRR l
Administrative Procedures. No problems, other than those identified and corrected.
i l-by the bcensee m the RSC audit process, were noted.
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l C. ' Conclusions j
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Facility procedures were acceptable and satisfied TS and administrative procedure l
requirements for being revised by the licensee, and reviewed and approved by the
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RSC.
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4. Radiation Protection Program (69001)
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a. inspection Scope
I The inspector reviewed the following to verify compliance with 10 CFR 20 and the l
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applicable licensee TS requirements and procedures:
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L health physics (HP) and reactor surveillance survey records,
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radiological signs and posting,
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dosimetry records,
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calibration records and_ periodic check records for radiation monitoring l
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instruments, i
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. the Radiation Protection and ALARA Programs, and
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training records.
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The inspector also observed the use of dosimetry and radiation monitonng
equipment during tours of the facility. Licensee personnel were interviewed as well.
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b. Observations and Findings (1) Surveys and Air Sampling ARRR Radiological Safety Procedures require in Sections D.2 and D.5 that radiation and contamination surveys are taken at least once per quarter in areas where radioactive materials are routinely handled. Guarterly swipe sample spot checks are also to be made in areas in which radioactive material is not handled.
Daily air sampling with weekly analysis is required by Section D.3.
The inspector noted, through records review, that quarterly contamination and radiation surveys, and daily air sampling, were completed by the ARRR staff as required by TS and licensee procedures. Results were evaluated and corrective actions taken when readings or results exceeded set action levels. It was also noted that radiation surveys were generally completed on a monthly basis (more frequently than required by TS) and that general radiation levels inside the radiation areas of the f acility were from 1-20 millirem per hour (mr/hr) beta-gamma radiation and from.3-10 mr/hr neutron radiation.
Contamination surveys were completed monthly during the first half of 1997 and then completed at the quarterly frequency during the remainder of the period reviewed. No activity above the licensee's action levels was noted. However, it was noted that the spot checks of the swipe surveys appeared to be in the same locations from survey to survey. The inspector informed the licensee that, if the survey locations were varied from quarter to quarter, this would provide them with a better indication of whether or not contamination was being inadvertently spread. The licensee stated that they would consider changing their practice.
Air sample analyses indicated that there was no activity above the licensee's action level detected during the period reviewed. The inspector did note that some of the air sample analysis results were not reviewed expeditiously. At times the results were not reviewed until nearly six months later. The licensee acknowledged that this had occurred but stated that renewed emphasis was being placed in this area. The licensee also stated that, had any air sample result been above the action level, the problem would have been brought to the attention of management immediately and the situation reviewed and corrected.
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Interviews with licensee personnel indicated that this was the practice.
(2) Postings and Notices 10 CFR 19.11 requires the licensee to post current copies of various documents including the regulations in 10 CFR 20, the f acility license, procedures, and any notice of violation as applicable. If posting such documents is not practicable, the licensee may post a notice that describes the document and states where it may be examined. The licensee is also required to post a current copy of NRC Form __
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Copies of current notices to workers required by 10 CFR Part 19 were posted in appropriate areas in the facility. Copies of NRC Form-3 were also posted.
Postings, such as Radiation Area postings, etc., at the entrances to the controlled areas, including the Reactor room, were acceptable for the hazards present. The facility's radioactive material storage areas were properly posted.
No unmarked radioactive material was noted.
(3) Dosimetry The licensee used a National Voluntary Laboratory Accreditation Program (NVLAP)-accredited vendor to process personnel thermoluminescent, film badge, and/or finger ring dosimetry. An exarr...ation of the records for the past two years through the date of the inspection showed that all exposures were within NRC limits and licensee action levels. During 1997, the maximum dose received by an employee at the facility was received by a radiographer. The whole body dose was 3.99 rem and the extremity dose was 17.54 rem. To date in 1998 (through August), the maximum whole body dose received was 3.37 rem and the extremity dose was 9.58 rem, again by a radiographer.
The issue of limiting exposures was discussed with licensee personnel. They indicated that this was an ongoing area of concern and that new studies were being conducted into such improvements as possibly installing additional shielding for the reactor and rotating workers so that the doses received would be distributed more uniformly throughout the workforce. The issue of ALARA
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improvements will continue to be reviewed by the NRC during future inspections.
(4) Radiation Monitoring Equipment Selected radiation monitoring equipment had the acceptable up-to-date calibration sticker attached. The calibration of portable survey meters was typically completed by the Radiological Safety Officer. Calibration frequencies of the instruments checked by the inspector met procedural requirements and records were maintained as required.
(5) Radiation Protection Program The licensee's Radiation Protection Program was established through the TS and the ARRR Radiological Safety Procedures. The program included requirements that all personnel who had unescorted access to the ARRR receive training in radiation protection, policies, procedures, requirements, and facilities. The program appeared to be acceptabl.
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It was also noted that Section F.2 of the ARRR Radiological Safety Procedures stipulated that a Special Work Permit (SWP) be required for all maintenance and other support personnel performing jobs in radiation areas to which they are not regularly assigned.
The inspector reviewed the SWPs that had been written and used during the past three years. The SWPs appeared to be adequate for'the work that had been completed and contained the appropriate precautions and necessary radiological control requirements.
Further, tours of the facility showed that control of radioactive material and control of access to radiation areas were acceptable.
(6) ALARA Program The ALARA Program was also outlined and established in the licensee's TS and ARRR Radiological Safety Procedures. The ALARA program provided guidance for keeping doses as low as reasonably achievable and was consistent with the guidance in 10 CFR 20. As noted previously, the issue of maintaining doses ALARA will continue to be reviewed by the NRC during future inspections.
No Respiratory Protection Program had been developed or implemented by the licensee. A review of the work performed by licensee personnel showed that no such program was required.
(7) Training Training was given to all new employees and a briefing was provided to all contractors who worked on such items as the heating, ventilation, and air
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conditioning (HVAC) systems. Tests were given to demonstrate that the material covered was understood. The inspector noted that there was no formal
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training plan used for training and thus it was not readily apparent that all the subjects mentioned in 10 CFR 19.12 were covered. However, interviews and records' review confirmed that employees had been trained and did understand j
the issues involved with working with radioactive material.
The licensee was informed that the issue of developing a formal training plan which explicitly covers all the topics listed in 10 CFR 19.12 would be an Inspector Follow-up Item (IFI) and would be reviewed by the NRC during future inspections (IFl 50-228/98-201-01).
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c. Conclusions
4 Surveys were generally completed and documented acceptably to permit evaluation
of the radiation hazards that might exist. Notices and postings at entrances to work areas met regulatory requirements. Personnel dosimetry was being worn as required and doses were within the licensee's procedural action levels and the NRC's
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regulatory limits. Radiation monitoring equipment was being maintained and calibrated as required. The Radiation Protection Program and the ALARA Program satisfied regulatory requirements. The challenges faced by the licensee in
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maintaining worker doses ALARA will continue to be reviewed by the NRC.
Although training is being provided, an IFl was identified to review the development of a formallesson plan.
5. Effluent and Environmental Monitoring (69001)
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Inspection Scope The inspector reviewed the following to verify compliance with the requirements of 10 CFR 20 and TS Sections C.2, D.2, and H:
the licensee's environmental monitoring program, a
dosimetry records, e
release records, and a
counting and analysis records.
a b. Observation and Findings
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Gaseous releases were calculated as required, were acceptably documented, and were well within Appendix B concentrations, and TS limits. To demonstrate compliance with the annual dose constraints of 10 CFR 20.1101(d), the licensee u:ed the COMPLY computer code. The highest dose calculated being possibly received as a result of gaseous emissions from reactor operations was 0.5 millirem per yr (mr/yr) for 1996 and 0.6 mr/yr for 1997. These doses are well below the limit set in 10 CFR 20.1101(d) of 10 mr/yr.
Only one liquid release had occurred during the past twc years. The release was reviewed and approved by the Radiological Safety Officer after analyses proved that the release would meet regulatory requirements for discharge into the sanitary sewer.
c. Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
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6. Transportation (86'i401 a. Inspection Scope The inspector interviewed licensee personnel and reviewed shipping records for the period from 1997 through the present to verify compliance with the requirements of
~ 10 CFR 71.5 for shipments of licensed material.
b. Observations and Findings 10 CFR 71.5(a) requires that a licensee, who delivers licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 171-189.
49 CFR 171.2(a) prohibits any person from offering hazardous material for transportation unless, among other requirements, the hazardous materialis properly classified, described, packaged, marked, labeled, and in condition for shipment required or authorized under the Hazardous Material Regulations (49 CFR 171-177).
49 CFR 172.201(d) requires that shipping papers must contain an emergency response telephone number.
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49 CFR 172.202(a)(2) requires that the hazard class or division prescribed for the material in Column 3 of the 172.101 Table be included on the shipping papers.
49 CFR 172.202(a)(5) requires that the total quantity (by net or gross mass, capacity, or as appropriate) of material being shipped, including the unit of measurement, be included on the shipping papers.
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49 CFR 172.203(d)(3) requires that a description'of the physical and chemical form of the material being shipped be included on the shipping papers.
49 CFR 172.203(d)(4) requires that the activity contained in each package of the shipment be listed on the shipping papers in terms of the appropriate SI units (e.g.,
Becquerel, Terabecquerel, etc.). The activity may be listed in terms of the appropriate SI units followed by the customary units (e.g., Curies, millicuries, etc.) if the licensee prefers.
49 CFR 172.203(d)(5) requires that the category of label applied to each package in the. shipment be listed on the shipping papers.
49 CFR 172.203(d)(7)(i) requires that the words " Fissile Excepted" be listed on the shipping papers if the package is excepted.
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i 49 CFR 172.203(d)(10) requires that, for a shipment required by the regulations to be consigned as exclusive use, the words " Exclusive Use Shipment" be listed on the shipping papers.
49 CFR 172.203(d)(11) requires that, for shipments of low specific activity, the appropriate group notation of LSA-1, LSA-II, or LSA-Ill be included on the shipping papers.
Through records reviews and discussions with licensee personnel, the inspector determined that various shipments of licensed material had been made since the last inspection. Shipment records had been completed and were being maintained as required. The records showed that, in general, the material had been properly described and classified, that the correct labeling had been provided, and that the contamination and radiation levels of the packages shipped had been recorded acceptably. However, some discrepancies were noted on the shipping papers as follows:
(1) Of the shipping papers filled out by the licensee for approximately 12 shipments made to one client (TRU-TEC) during the past two years, at least one set or more did not list: a) an emergency response telephone number, b) the hazard class of the material shipped, c) the total quantity of material being shipped, d)ihe chemical and physical form of the material being shipped, e) the activity in
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Si units, f) the category of label required to be on the shipping package, and g) the words " Exclusive Use Shipment " for shipments that weri required to be shipped as exclusive use.
(2) None of the shipping papers completed by the licensee for approximately 24 shipments made to a second client (McClellan AFB) during the past two years listed the activity in SI units nor the appropriate group designation for low specific activity shipments (e.g., LSA-1, LSA-II, or LSA-lll). Also, the shipping papers included the words " Fissile Class I" which was not the valid designation.
The material must be classified and the shipping papers must indicate that the shipment is either " Fissile Excepted" or " Warning - Fissile Material... "
The licensee was informed that failure to fill out the shipping papers according to the regulations was an apparent violation of 10 CFR 71.5(a) (VIO 50-??8/98-201-02).
c. C_cnclusions One apparent violation was noted for f ailure properly to complete the required shipping papers for various shipments of radioactive materia _
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7. Physical Security (81401, 81402, 81421)
a. Inspection Scope To verify compliance with the licensee's NRC-approved Physical Security Plan (PSP)
and to assure that changes, if any, to the plan had not reduced its overall effectiveness, the inspector reviewed:
logs, records, and reports,
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intruder detection and physical barriers,
access controls, and a
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b. Observations and Findings The inspector determined that the licensee's physical protection program conformed to NRC requirements, the PSP, and the implementing procedures.
c. Conclusion The NRC-approved security program at the facility was being acceptably carried out.
8. Material Control and Accounting (85102)
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Inspection Scope To verify compliance with 10 CFR 70, the inspector reviewed:
storage areas,
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procedures for tracking the quantity, identity, and location of Special Nuclear e
Material (SNM),
annual inventory results, and e
associated records and reports,
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b. Observations and Findings The licensee's item control areas ensured that physical and administrative control of SNM would be maintained. Licensee procedures for tracking SNM were acceptably implemented. Records showed that physicalinventories were conducted at least annually as required by 10 CFR 70.51(d). The inspector also determined that the licensee submitted Nuclear Material Transaction Reports (DOE /NRC Form 741) and Material Status Reports (DOE /NRC Form 742) at the frequency and as required by 10 CFR 74.13(a)(1).
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c. Conclusion No deficiencies were identified in the licensee's Material Control and Accounting program.
9. Exit Interview The inspection scope and results were summarized on November 5,1998, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to ar reviewed by the inspector.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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8. Anderson, Assistant Manager, Neutron Radiography l
A.'Meren, Manager, Neutron Radiography j
l. Molina, Neutron Radiographer
l C. Schmidt, Office Manager
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, R. Tsukimura, President, Aero:est Operations, Inc.
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S. Warren, Radiological Safety Officer
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INSPECTION PROCEDURES USED
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IP 69001:
Class 11 Non-Power Reactors
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l-IP 81401:
Plans, Procedures, and Reviews
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IP 81402:
Reports of Safeguards Events
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IP 81421:
Fixed Site Physical Protection of Special Nuclear Material of Low Strategic j
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ll IP 85102:
Material Control and Accounting - Reactors l
lP 86740:
Inspection of Transportation Activities
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ITEMS OPENED, CLOSED, AND DISCUSSED i
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50-228/98-201-01 IFl Follow-up on the development of a formallesson plan covering the l
topics listed in 10 CFR 19.12.
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50-228/98 201-02 ' VIO - Failure to include all of the information required to be listed on l
l various shipping papers according to the 49 CFR 171-189 as
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j-required by 10 CFR 71.5(a).
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LIST OF ACRONYMS USED ALARA As low as reasonably achievable ARRR Aerotest Radiography and Research Reactor CFR Code of Federal Regulations HP Health Physics HVAC Heating, ventilation, and air conditioning IFl inspector Follow-up Item IP inspection Procedure kW kilowatt mr/hr Millirem per hour mr/yr Millirem per year NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program PDR Public Document Room PSP Physical Security Plan RSC Reactor Safeguards Committee SNM Special Nuclear Material SWP Special Work Permit
TS Technical Specification VIO Violation i
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