IR 05000228/1999201
| ML20211K356 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 09/02/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20211K344 | List: |
| References | |
| 50-228-99-201, NUDOCS 9909070198 | |
| Download: ML20211K356 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
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Docket No:
50-228 License No:
R 98 Report No:
50-228/99-201 Licensee:
Aerotest Operations, Inc.
Facility:
Aerotest Radiography and Research Reactor (ARRR)
Location:
3455 Fostoria Way San Ramon, CA 94583 Dates:
August 16-19,1999 Inspector:
C. H. Bassett Senior Non-Power Reactor inspector j
Approved by: Ledyard B. Marsh, Director Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
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9909070198 990902 PDR ADOCK 05000228 G
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EXECUTIVE SUMMARY Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor (ARRR)
Report No: 50-228/99-201 The primary focus of this routine, announced inspection was the on-site review of selected aspects of the licensee's Class ll non-power reactor operation including: operations program, organizational structure and functions program, design control program, review and audit program, operater requal;fication program, maintenance program, surveillance program, fuel handling program, experimental program, procedural control program, and emergency preparedness program since the last NRC inspection in these areas.
Changes, Organization and Staffing The organization and staffing were consistent with Technical Specification requirements.
Review and Audit Functions Audits were being conducted by the Reactor Safeguards Committee according to the requirements specified in the Technical Specifications.
Procedures Facility procedures were acceptable and satisfied Technical Specification and administrative procedure requirements for being revised by the licensee and reviewed and approved by the Reactor Safeguards Committee.
Operations The operations program satisfied Technical Specification requirements.
Design Control The design change program satisfied NRC requirements.
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Operator Requalification Program I
I Operator requalification was conducted as required by the Requalification Program.
Maintenance The maintenance program satisfied NRC requirements.
Surveillance i
The surveillance program was in compliance with Technical Specification * quirements.
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Fuel Handling Fuel movements and inspections were completed and documented in accordance with the requirements specified by procedure and the Technical Specifications.
Experiments The program for conducting experiments satisfied Technical Specification and procedural requirements.
l Year 2000 Concerns No problems had been identified concerning reactor operations with respect to Year 2000 concerns.
Emergency Preparedness The emergency preparedness program was conducted in accordance with the Emergency Plan.
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REPORT DETAILS Summary of Plant Status
The licensee's TRIGA-conversion research reactor continues to be operated in support of
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laboratory 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
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reduced power levels to reduce personnel radiation exposures.
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I 1.
Changes, Organization, and Staffing (69001)
a.
Insoection Scope The inspector reviewed the following regarding the licensee's organization and staffing to ensure that the requirements of Technical Specifications (TS) Sections 10.0 and 12.1 were being met:
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e the organizational structure, management responsibilities, and e
e-staffing for safe operation of the ARRR.
b.'
Observations and Findinas
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Through discussions with licensee representatives, the inspector determined that management responsibilities and the organization at the facility had not changed since the previous NRC inspection in November 1998 (Inspection Report No. 50-228/98-201).
The inspector concluded that the Reactor Supervisor retained direct control and overall responsibmty for management of the facility as specified in the TS. The Reactor Supervisor continued to report to the President, Aerotest Operations, Inc. (AO). It was
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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 inspector determined that the current staffing at the facility was acceptable to support the work and ongoing activities and met the requirements of the TS.
c.
Conclusions The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specification.
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2.
Review and Audit Functions (69001)
a.
Inspection Scooe The inspector reviewed the following to ensure that the audits and reviews stipulated in the requirements of TS Section 12.3 were being completed:
ARRR Procedures, Reactor Safeguards Committee (RSC) meeting minutes, and o
Duties specified for the RSC by the TS including the committee's review and
audit functions.
The inspector also toured the licensee's facility to note any changes or modifications that may have been made since the last inspection.
b.
Qbservations and Findinos The inspector reviewed the RSC's meeting minutes from July 1997 to the present.
These meeting minutes showed that the RSC had met annually as required and had considered the types of topics outlined by the TS. The meetings were typically attended by all members of the committee.
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The inspector noted that committee personnel had completed audits of the reactor facility operations and programs on a rotating basis such that all aspects of the program
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were audited every two years. During the period reviewed, audits had been completed by the RSC as outlined in the TS. One of the previous audits concluded that the facility
procedures were not being reviewed every two years as required. The most recent audit found that the latest biennial physical examination of one of the SROs was not completed in a timely manner. As a result of these audit findings, the licensee had taken actions and the problems had been corrected. The inspector determined that the l
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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
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areas at the facility. No changes from the previously submitted facility descriptions were
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Conclusions Audits were being conducted by the RSC according to the requirements specified in the Technical Specification.
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Procedures (69001)
a-Insoection Scooe The inspector reviewed the following to ensure that the requirements of TS Section 12.2 were being met concerning written procedures:
e selected operations procedures, e
selected safety procedures, and the process used by the licensee tn revise, review, and approve all facility a
procedures.
b.
Observations and Findinat The inspector verified that procedures had been developed for reactor operations and safety. As noted above, one RSC audit found that procedures were not being reviewed biennially as required. The licensee indicated that this was an oversight and that the
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reviews had been completed after the problem had been identified. The inspector verified that the reviews had been completed and that no further examples of failure to review procedures in a timely manner existed.
It was noted that revisions to procedures were presented by the licensee to the RSC for review and approval. The revisions were acceptable and in accordance with 10 CFR 20,
TS, and ARRR Administrative Procedures. No problems, other than those identified and corrected by the licensee in the RSC audit process, were ncted.
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Conclusions Facility procedures were acceptable and satisfied TS and administrative procedure requirements for being revised by the licensee, and reviewed and approved by the RSC.
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Operations (69001)
a.
Scope
' The inspector reviewed selected aspects of:
e operational logs and records,.
e staffing for operations, and e
reactor operational, startup, and shutdown activities.
b.
~ Observations and Findinas The operating logs and records were clear and provided an acceptable indication of
. operational activities. This included documentation of events that occurred and measures taken to resolve or track the events. Logs and records also showed that operational conditions and parameters were consistent with license and TS
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Conclusions
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The operations program satisfied Technical Specification requirements.
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Design Control (69001)
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Scope
. The inspector reviewed selected aspects of the following to verify compliance with 10 CFR 50.59:
facility design changes and records, and e
facility configuration and control.
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Observations and Findinos Records and observations showed that no changes had been initiated at the facility since the last inspection.' The inspector noted that there were applicable administrative procedures and controls in place for reviewing changes in accordance with the requirements stipulated in 10 CFR 50.59.
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Conclusions The design change program satisfied NRC requirements.
6.
Operator Requalification (69001)
a.
Scope
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To verify compliance with the Requalification Program, the inspector reviewed:
e operator examination records, operator licenses, e
e operator physical examination records, and operator active duty status.
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Observations and Findinas The Requalification Program was being maintained up to date. Operator licenses were also current. Records showed that operators were given an annual requalification examination as required and operations reviews were conducted. Logs indicated that operators maintained active duty status as required.
Physical examinations of the operators were conducted as required with one exception.
As noted during an independent audit, one of the SROs had not had a biennial physical
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examination within the time period allowed. The licensee stated that this occurred during a time when the Reactor Supervisor had been on medicalleave and that the problem was rectified as soon as the supervisor returned to work and noted the situation. The inspector verified that the physical examination had been completed and that all operators had received a physical examination within the past two years.
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There are currently f;ve SROs employed at the facility. Two of the SROs are part-time j
contractor personnel who maintain their iicenses current by operating the reactor the
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required number of hours quarterly and by taking the annual examinations. The inspector also noted that three employees, currently working as radiographers, are in training to become Reactor Operators (ROs). The licensee is also seeking another experienced person to replace a Senior Reactor Operator (SRO) who resigned some time ago.
During the inspection, the inspector determined that the Requalification Plan was somewhat inconsistent in that, in one part of the plan, it required individuals who scored less than eighty percent (80%) in any category on the annual written examination to be tutored to bring their performance up to a minimum of 80%. In another portion of the plan, operators who scored less than 70% overall on the annual written examination'
would be required to participate in an accelerated training program and would be prohibited from performing licensed duties. The licensee was aware of the situation and was in the process of revising the Requalification Plan. The licensee was informed that the issue of making the Requalification Plan requirements consistent with respect to what training was needed following annual examinations would be an Inspector Follow-up item (IFI) and would be reviewed by the NRC during a future inspection (IFl 50-228/99-201-01).
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Conclusions Operator requalification was conducted as required by the Requalification Program.
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Maintenance (69001)
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Scope The inspector reviewed selected portions and aspects of:
o maintenance procedures, e
equipment manuals, and o
equipment maintenance records.
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Observations and Findinos l
Logs indicated that corrective maintenance activities and problems were addressed and I
preventive maintenance operations completed as required by procedure. Records showed that routine maintenance activities were conducted at the required frequency and in accordance with the TS and/or the applicable procedure or equipment manual.
Maintenance activities ensured that equipment remained consistent with the Safety l
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Analysis Report and TS requirements. Further, maintenance activities were consistent with the requirements of 10 CFR 50.59.
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Conclusions-The maintenance program satisfied NRC requirements.
8.
Surveillance (69001)
a.
Scope To determine that survei!!ance activities and calibrations were being completed as required by TS Sections 4, 5, 6, and 10, the inspector reviewed:
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e surveillance and calibration procedures, e
surveillance, calibration, test data sheets, and operationallogs and records.
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Observations and Findinas
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Surveillance, test and Limiting Conditions for Operation (LCO) verifications and calibrations were completed on schedule and in accordance with licensee procedures.
All the recorded results were within the TS and procedurally prescribed parameters or adjustments were made to the equipment as needed. The records and logs reviewed were complete and were being maintained acceptably. Checks, tests, and calibrations were completed as required by TS.
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Conclusions The surveillance program satisfied Technical Specification requirements.
9.
Fuel Handling (69001)
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Scope The inspector reviewed selected aspects of the following to verify that fuel handling was being conducted as required by TS:
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e fuel handling procedures,
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e fuel handling equipment and instrumentation, and j
applicable fuel movement logs and records.
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Observations and Findinas The inspector determined that the licensee was maintaining the required records of the various fuel movements that had been completed and verified that the movements were conducted in compliance with procedure. Reactor fuel was being inspected as needed.
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The procedure used was acceptable and the radiological control requirements specified for these operations were adequate.
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Conclusions Fuel movements and inspections were completed and documented in accordance with the requirements specified by procedure and TS.
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Experiments (69001)
a.
S.p.gpjlt The inspector reviewed selected aspects of:
o experimental program requirements, e
procedures, logs, and records, and e
experimental administrative controls and precautions.
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' Observations and Findinas The experiments at the facility were routine procedures that had been in place for several years. No new or unknown-type experiments had been initiated, reviewed, or approved since the last inspection. If any experiments were to be initiated, they would be completed with the cognizance of the Reactor Supervisor and in accordance with T3 requirements (e.g., reactivity limitations, explosive material restrictions, etc.). The results of the experiments were documented in appropriate logs or records.
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Conclusions r
The program for conducting experiments satisfied Technical Specification and procedural requirements.
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Year 2000 Concerns Review a.
Insoection Scope The inspector reviewed the status of the licensee's preparations to deal with potential computer problems caused by the upcoming Year 2000 (Y2K) by reviewing selected aspects of:
e operating system, e
security system, and e
the general approach to the problem.
b.
Observations and Findinca The licensee had completed a review / analysis of the various types of equipment and computer-based applications supporting activities at the facility and the TS requirements
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for the ARRR, They had concluded that the only problem concerning Y2K might exist with oome of the radiation monitoring at the site.- This situation had been addressed by the installation of new software that would alleviate the problem. In their review of the
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current status of the ARRR facility, the licensee had not identified anything that would pose a problem to the reactor operations and no instances were identified that could l
pose a threat to public healtn and safety.
l The licensee determined that the security system was Y2K compliant. This was verified by the security system vendor who issued a letter stating that the licensee did not have a system that included date sensitive systems for software in use.
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Conclusions No problems had been identified concerning reactor operations with respect to Y2K concerns.
12.
Emergency Preparedness (69001)
a.
Scope The inspector reviewed selected aspects of:
e the Emergency Plan and implementing procedures, e
emergency response facilities, supplies, equipment and instrumentation, e
training and emergency drill records, and, e
offsite support.
b.
Observations and Findinas The Emergency Plen (E-Plan) in use at the facility was the same as the version most recently approved by the NRC. The E-Plan was audited and reviewed as required.
Implementing procedures were reviewed and revised as needed to employ the E-Plan effectively. The inspector noted that a stretcher specified in the E-Plan was not available for use. When this was brought to the attention of the licensee, it was determined that the "old" stretcher had become worn out and was discarded. The licensee immediately ordered a new stretcher to replace the one that was discarded.
Through records review and through interviews with licensee personnel, emergency responders were determined to be knowledgeable of the proper actions to take in case of an emergency An agreement with a hospitalin nearby Livermore to treat potential victims of a radiological event had been updated and maintained as necessary.
Communications capabilities were acceptable with the support groups. Off-site support organizations visited the facility on an infrequent basis but were familiar with the facility and what would be required during a response.
Evacuation drills had been conducted twice a year as required by the E-Plan.
Emergency preparedness and response training was being completed as required.
Training for reactor staff personnel was conducted and documented as stipulated by the l
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E-Plan. The licensee was encouraged to conduct more challenging drills in order to test communications procedures and check on the response of facility personnel to a simulated radiological or industrial hazards problem.
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Conclusions j
The emergency preparedness program was conducted in accordance with the Emergency Plan.
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Follow-Up On Previous Open items (69001)
a.
Inspection Scope The inspector reviewed the actions taken by the licensee following identification of a violation (VIO) during a previous inspection..
b.
Observations and Findinos VIO - 50-228/98-201-02 - Failure to include all of the information required to be listed on various shipping papers according to 49 CFR 171-189 as required by 10 CFR 71.5(a).
NRC Inspection Report No. 50-228/98-201 and Notice of Violation (NOV), dated December 2,1998, outlined the problem. During this inspection, the inspector reviewed the actions taken by the licensee to correct the problem concerning the previous lack of information that needed to be included on shipping papers and verified that corrective actions had been completed. These corrective actions were documented in the licensee's response to the NOV dated December 28,1998. The corrective actions were determined to be acceptable. This item is considered closed.
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Conclusions Acceptable actions were taken by the licensee regarding the previously identified problem and this issue is considered closed.
14.
Exit Interview The,nspection scope and results were summarized on August 19,1999, 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 or reviewed by the inspector.
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EARTIAL LIST OF PERSONS CONTACTED Licensee B. Anderson, Assistant Manager, Neutron Radiography A.- Meren, Reactor Supervisor and Manager, Neutron Radiography
C. Schmidt, Office Manager R. Tsukimura, President and Chief Executive Officer, Aerotest Operations, Inc.
S. Warren, Radiological Safety Officer and Manager, Quality Assurance i
i INSPECTION PROCEDURE USED IP 69001:
Class ll Non-Power Reactors
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ITEMS OPENED. CLOSED. AND DISCUSSED i
poened 50-228/99-201-01 IFl Follow-up on the licensee's efforts to ensure that the requirements of the Requalification Plan are consistent concerning training of operators if they receive less than a specific score on the annual written examinations.
Closed 50-228/98-201-02 VIO Failure to include all of the information required to be listed on various shipping papers according to 49 CFR 171-189 as required by 10 CFR 71.5(a).
LIST OF ACRONYMS USED AO Aerotest Operations, Inc.
ARRR Aerotest Radiography and Research Reactor CFR Code of Federal Regulations E-Plan Emergency Plan IFl inspector Follow-up Item
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kW kilowatt LCO Limiting Conditions for Operation
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NOV Notice of Violation NRC Nuclear Regulatory Commission
- RO Reactor Operator RSC Reactor Safeguards Committee SRO Senior Reactor Operator TS Technical Specification VIO Violation l
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