IR 05000228/2020201

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U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000228/2020201 and Notice of Violation
ML20240A252
Person / Time
Site: Aerotest
Issue date: 10/15/2020
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Slaughter D
Aerotest
Bassett C,NRR/DANU/UNPO,2405351842
References
IR 2020201
Download: ML20240A252 (18)
v • d • e


Text

October 15, 2020

SUBJECT:

AEROTEST OPERATIONS, INC. - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000228/2020201 AND NOTICE OF VIOLATION

Dear Dr. Slaughter:

From August 10-12, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff completed an inspection at your Aerotest Radiography and Research Reactor facility. The enclosed report documents the inspection results, which were discussed with you on August 12, 2020.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed various activities, and interviewed personnel.

Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the licensee failed to identify the violation.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, and requests for withholding, a copy of this letter, its enclosures, and your response will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy or proprietary information, so that it can be made available to the Public without redaction.

Should you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-228 License No. R-98 Enclosures:

As stated cc: w/enclosures:

California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 Radiologic Health Branch P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML20240A252 concurrence *via e-mail NRC-002 OFFICE NRR/DANU/UNPO/I* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC*

NAME CBassett NParker TTate DATE 8/28/2020 8/27/2020 10/15/2020

NOTICE OF VIOLATION Aerotest Operations, Inc. Docket No. 50-228 Aerotest Radiography and Research Reactor License No. R-98 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted August 10-12, 2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Aerotest Operations, Inc. Technical Specifications Section 12.1.5 require that [t]he Radiological Safety Officer shall have a Bachelors degree in Biological or Physical Science and shall have a minimum of 2 years experience in personnel and environmental radiation monitoring programs at a nuclear facility. Certification as a Health Physicist by the Health Physics Society is acceptable in lieu of the education and experience requirements given above.

Contrary to the above, from January 22, 2019, to the present, the licensee has not had a Radiological Safety Officer who has a Bachelors degree in Biological or Physical Science or who is a Certified Health Physicist. The individual appointed to the position does not have the required educational background and is not a Certified Health Physicist.

This has been determined to be a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Notice of violation, Aerotest Operations, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, 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 should include: (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, 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 a Demand for Information may be issued as to why the 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, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information 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.

Enclosure 1

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, Protection of Safeguards Information: Performance Requirements.

In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post this Notice within two working days of receipt.

Dated this 15th day of 2020

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No. 50-228 License No. R-98 Report No. 05000228/2020201 Licensee: Aerotest Operation, Inc.

Facility: Aerotest Radiography and Research Reactor Location: San Ramon, CA Dates: August 10 - 12, 2020 Inspector: Craig Bassett Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure 2

EXECUTIVE SUMMARY Aerotest Operations, Inc.

Aerotest Radiography and Research Reactor Inspection Report No. 05000228/2020201 The primary focus of this routine, announced inspection was the on-site review of selected aspects of the Aerotest Operations, Inc. (Aerotest, licensee) Class III research and test reactor safety program including: (1) staffing and audits, (2) operator requalification and active license status, (3) radiological surveys, (4) surveillance, and (5) emergency preparedness, since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff determined the licensee's program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements except in the area of staffing.

Staffing and Audits

  • Staffing was maintained as outlined in technical specifications (TS) Section 12.1 except for the position of the Radiological Safety Officer as noted in paragraph 1.b(1)(b) below.
  • Audits were conducted by the Reactor Safeguards Committee (RSC) in accordance with TS requirements in Section 12.1.3.

Operator Requalification and Active License Status

  • Requalification records were maintained at the facility as required even though there are no longer any licensed reactor operators (ROs) or senior reactor operators (SROs) employed there.
  • The licensee is seeking to establish a Certified Fuel Handler program at the facility in lieu of having NRC-licensed ROs. A license amendment request for the Certified Fuel Handler program is currently under NRC review.

Radiological Surveys

  • The licensee conducted surveys in accordance with regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection against Radiation, and the limits specified in TS Sections 6.2, 7.0, and 12.1.2.

Surveillance

  • Limited surveillance activity was completed in accordance with TSs and procedural requirements.

Emergency Preparedness

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REPORT DETAILS Summary of Facility Status The Aerotest 250 kilowatt Training, Research, Isotopes, General Atomics [TRIGA] conversion research reactor, known as the Aerotest Radiography and Research Reactor (ARRR), was operated in the past in support of neutron radiography of various items and RO training. The licensee voluntarily ceased to operate the research reactor in 2010 and has not resumed operations since. During this inspection, the reactor remained defueled and shut down.

1. Staffing and Audits a. Inspection Scope (Inspection Procedure [IP] 69002, Section 02.01)

The inspector reviewed the following regarding the licensee's staffing and audits to ensure that the requirements of TS Sections 12.1 were met:

  • current staffing of the ARRR
  • completed audits for 2017 to the present
  • RSC meeting minutes for 2017 to the present
  • duties of the RSC detailed in TSs Section 12.3
  • charter of the RSC outlined in Section I of the Aerotest Operations Facility Operating Procedures entitled, Administrative Procedures
  • management responsibilities and organizational structure indicated in Section 12.0 of the TSs, as implemented through the latest revision to the Facility Operating License Number (No.) 98, Amendment No. 5, dated July 17, 2017
  • annual summary of changes, tests, and experiments at ARRR for the following periods: July 1, 2017, to June 30, 2018, issued July 16, 2018; July 1, 2018, to June 30, 2019, issued July 12, 2019; and, July 1, 2019, to June 30, 2020, issued July 1, 2020 b. Observations and Findings (1) Staffing (a) General Staffing Level Through discussions with licensee representatives, the inspector determined that management responsibilities at the facility was not changed since the previous routine NRC inspection conducted in June 2017 (NRC Inspection Report No. 50-228/2017-201). The inspector noted that the President of Aerotest (who was also the Manager) was the head of the company. The Certified Fuel Handler Supervisor was responsible for day-to-day activities at the reactor facility and reported to the Aerotest President. The Radiological Safety Officer (RSO) was responsible for enforcing rules, regulations, and procedures relating to radiological safety and reported to the Aerotest President. The Aerotest President, reported to the Board of Directors of Aerotest.

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The inspector noted that the facility license was transferred to a new parent company called Nuclear Labyrinth, LLC, as was the ownership of Aerotest The inspector determined that the licensee submitted a possession-only license amendment request (LAR) that is being reviewed by the NRC staff.

Through review of records and discussions with licensee personnel, the inspector confirmed that the current staffing at the ARRR included the Aerotest President, a Certified Fuel Handler Supervisor, the RSO, and a Nuclear Analyst. The employees were monitoring the facility and completed maintenance and surveillance duties as required by the TSs.

(b) Radiological Safety Officer The TS Section 12.1.5 require that [t]he Radiological Safety Officer shall have a Bachelors degree in Biological or Physical Science and shall have a minimum of 2 years experience in personnel and environmental radiation monitoring programs at a nuclear facility. Certification as a Health Physicist by the Health Physics Society is acceptable in lieu of the education and experience requirements given above.

The inspector inquired about the background and qualifications of the current RSO. Through an interview with the RSO the inspector learned that the person was appointed to that position on January 22, 2019, following departure of the individual who previously held that job. The inspector inquired about the RSOs background and qualifications and was given a copy of the persons resume. The inspector determined that the individual had not received a Bachelors degree in Biological or Physical Science and had not received a Health Physicist Certification.

The inspector also noted that the individual had attended a course in radiation safety, and was a designated shipper of radioactive material and a neutron radiographer at the facility for many years. The person had also helped the previous RSO perform duties involving personnel and environmental radiation monitoring and protection.

The licensee was informed that, although the current RSO had a great deal of experience in radiation protection, the TS specified that the person was required to have a Bachelors degree in Biological or Physical Science or be a Certified Health Physicist (CHP). Because the RSO did not have such a degree and was not a CHP, this would be noted as a violation (VIO) of TS Section 12.1.5 (VIO 05000228/2020201-01) and would be reviewed during a future inspection.

(2) Audits The inspector determined that the RSC met at least once per year in accordance with TS requirements with the last two meetings held on December 5, 2018, and on December 19, 2019. The inspector reviewed the RSC's meeting minutes for these meetings which showed that the RSC had considered the types of topics stipulated by the TSs. Review of the minutes-4-

confirmed that the committee provided guidance and direction for facility functions.

The inspector verified that the periodic audits specified by TS Section 12.1.3 were completed as required. The RSC minutes and audit records indicated that the Chair of the RSC conducted unannounced audits of facility operations annually and submitted the results to the Aerotest President. The inspector determined that there were no significant issues discovered during the audits and the licensee took appropriate corrective actions in response to the audit findings or recommendations that were noted.

c. Conclusion The inspector determined that the staffing was consistent with the requirements specified in TS Section 12.1, except as noted above, and audits were conducted by the RSC as required by TS Section 12.1.3.

2. Operator Requalification and Active License Status a. Inspection Scope (IP 69002, Section 02.02)

The inspector reviewed selected aspects of the licensees former requalification program which was submitted to the NRC on July 13, 2000:

  • records of former operators who previously worked at the facility documenting completion of requalification requirements
  • Aerotest letter to the NRC, Subject: License and TS Amendments. dated March 21, 2019
  • NRC letter to the licensee, Aerotest Operatioins, Inc. - Request for Additional Information Re: Possession-Only License Amendment To Use Certified Fuel Handlers For The Aerotest Radiography and Research Reactor Facility Operating License No. R-98, (EPID NO. L-2019-LLA-0065), dated July 27, 2020 b. Observations and Findings The inspector determined that there were no ROs or SROs who held NRC licenses to operate the reactor working at the facility. The last two previous operators licenses were terminated on December 18, 2018, and October 1, 2019. The licensee is maintaining files and requalification records of the licensed operators who worked there in the past as required.

The inspector noted that the licensee had submitted a LAR to the NRC by letter dated March 21, 2019, to modify the existing operating license to a possession-only license in support of the licensees decision to permanently cease operation of the ARRR. Within the LAR was a request to incorporate the use of Certified Fuel Handlers in lieu of NRC-licensed ROs and SROs. The NRC addressed the licensees request in a letter dated July 27, 2020, and identified additional information needed to continue its review of the LAR.

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c. Conclusion The inspector determined that operator requalification records were maintained at the facility as required even though there are no longer any licensed ROs or SROs employed there. The licensee is seeking to establish a Certified Fuel Handler program at the facility instead of having a Operator Requalification Program.

3. Radiological Surveys a. Inspection Scope (IP 69002, Section 02.03)

The inspector reviewed the following to verify compliance with 10 CFR Part 20 and the requirements in TS Sections 6.2, 7.0, and 12.1.2:

  • radiological signs and posting at the entrances to controlled or restricted areas
  • calibration and periodic check records for portable and fixed radiation monitoring instruments
  • radiation protection and surveillance and survey data from 2017 to the present
  • Aerotest Operations Facility Operating Procedures,Section VI entitled, Radiological Safety Procedures
  • Aerotest Operations Facility Operating Procedures,Section VIII entitled, Maintenance Procedures
  • personnel and environmental dosimetry records for the past 2 years
  • radioactive liquid waste holding tank release records, and
  • results of the analyses of air filters for the past 2 years b. Observations and Findings The inspector reviewed selected monthly, quarterly, and semi-annual general area radiation and contamination surveys of various areas in the facility from 2018 to the present. The inspector confirmed that the licensee completed surveys as required by procedure, documented the results on the appropriate forms, and evaluated the results as required.

During the inspection the inspector, accompanied staff members, toured the facility and determined radiation readings found were comparable to those listed on survey maps that were completed by the licensee. No anomalies were noted.

The inspector reviewed the calibration verification records of various equipment including survey meters, as well as the area, water, and stack monitoring systems. The inspector determined that calibration of the area monitoring systems were completed annually in accordance with procedure. The water and stack monitoring systems were operationally checked daily. If they failed verification, a full calibration was conducted. The inspector also reviewed the records documenting the fact that, because the reactor had not operated since-6-

2010, there were no liquid and airborne releases to the environment for that period.

The inspector confirmed that personnel, as well as, on-site and off-site gamma exposure and radiation monitoring was completed using thermoluminescent dosimeters in accordance with the applicable procedures. Dosimetry results reviewed by the inspector indicated doses to facility personnel was minimal. The environmental data indicated that there were no measurable doses above any regulatory limits. Through observation of the facility, the inspector did not identify any new potential release paths c. Conclusion The inspector determined that the licensee conducted operations in accordance with regulatory requirements in 10 CFR Part 20 and the limits specified in TS Sections 6.2, 7.0, and 12.1.2.

4. Surveillance a. Inspection Scope (IP 69002, Section 02.04)

The inspector reviewed the following to verify compliance with TS Sections 3.0, 4.0, 5.0, 6.0, and 7.0,:

  • various surveillance and maintenance forms from 2018 and to the present including: Operations Request Forms; Monthly Alarm Check Lists; Instrument Calibration; List of Aerotest Operations Surveillances; Aerotest Operations, Inc. Quarterly Maintenance Check Lists; and ARRR Pool Water and pH Analysis sheets
  • Aerotest Operations Facility Operating Procedures,Section VIII entitled, Maintenance Procedures b. Observations and Findings The inspector determined that the licensees TSs did not contain a specific section stipulating what surveillances needed to be performed at the facility.

However, the TSs did contain some requirements for certain checks and tests mostly dealing with experiments and radiation protection.

The inspector noted that, after the reactor was shutdown in October 2010, the licensee continued to complete the various monthly, quarterly, and annual tests and calibrations as required. The majority of the semiannual and annual surveillance items were not completed because they required a functioning reactor. One annual surveillance involving fuel inspection continued to be completed as required.

The inspector determined that the licensee had developed various checklists and forms to ensure that appropriate oversight was maintained over the various maintenance and surveillance items and other activities. These included items such as pool water pH and temperature levels, air filter change out, cycling the pumps, and limited reactor console checkouts. The console checkouts was-7-

eliminated since the licensee submitted a possession only LAR. The remaining items are checked and/or completed on a periodic basis even though this was not required because the reactor is shut down and not operating.

c. Conclusion The inspector determined that a limited program for surveillance checks, tests, verifications, and calibrations was implemented in accordance with TSs and procedural requirements.

5. Emergency Preparedness a. Inspection Scope (IP 69002, Section 02.05)

The inspector reviewed selected portions of the material mentioned below to determine that the licensee conducted exercises and drills and trained personnel in accordance with the facility E-Plan:

  • List of Aerotest Operations Surveillances forms for 2018 to the present
  • emergency response facilities, supplies, and instrumentation
  • quarterly maintenance checklists for 2018 and to date in 2020
  • emergency drill records for 2018 and to date in 2020 documented in the monthly alarm check lists
  • emergency response training for 2018 and to date in 2020 documented in the training log
  • offsite support as indicated in the current letter of agreement (LOA) with Stanford Health Care - ValleyCare
  • Aerotest Operations Facility Operating Procedures,Section III entitled, General Emergency Procedures, including E-Plan implementing procedures
  • Aerotest letter to the NRC, Updated Emergency Plan, dated March 26, 2020 b. Observations and Findings The E-Plan for the ARRR in use at the facility was the same as the version most recently submitted to the NRC by letter dated March 26, 2020, in accordance with 10 CFR 50.54, Conditions of licenses, paragraph (q)(3). The inspector compared the previous version of the E-Plan with the March 2020 version and found that they were very comparable. However, the newer version did not include three Appendices that appeared in the earlier version. The inspector verified that the E-Plan was audited and reviewed biennially as required. The E-Plan implementing procedures were incorporated into the licensees General Emergency Procedures. The inspector determined that the procedures were reviewed annually and revised as needed to implement the E-Plan effectively.

Through records review and interviews with staff personnel, the inspector confirmed emergency response personnel were knowledgeable of the proper actions to take in case of an emergency. The inspector confirmed that emergency response equipment was maintained and calibrated and alarms were tested at the frequency stipulated in the E-Plan. The inspector determined that communications capabilities with the various offsite support groups were-8-

available and functioning. A Notification List was maintained up-to-date and verified annually by the licensee.

The inspector verified that emergency preparedness and response training for staff personnel was completed annually as required. Evacuation drills were conducted twice a year as required by the E-Plan.

The inspector reviewed the LOA that was signed with Stanford Health Care -

ValleyCare which operated a hospital in nearby Pleasanton, CA. The LOA stated that the hospital would treat potential victims of a radiological event if such were to occur at the ARRR facility. The inspector verified that the LOA continued to be updated to confirm that the agreement remained in effect. The San Ramon Valley Fire Protection District was also contacted annually to review emergency interface requirements as required. It was noted that Fire Department personnel visited the facility as time permitted for training and a tour.

c. Conclusion The inspector determined that the licensee reviewed the E-Plan and completed emergency exercises, drills, and training in accordance with the E-Plan requirements.

6. Follow-up (Previously Identified Items)

a. Inspection Scope (IP 92701)

The inspector reviewed the actions taken by the licensee to address three previously identified Inspector Follow-up Items (IFIs) concerning a 10 CFR 50.59 evaluation, a Root Cause Analysis, and a licensee commitment as mentioned in the following:

  • licensees 10 CFR 50.59 evaluation of a new mechanism for attaching the upper grid plate to the core support structure
  • Aerotest Operation, Inc. Root Cause Analysis for the Damaged Aluminum Cladded Fuel
  • operator requalification program for the ARRR, which was submitted to the NRC on July 13, 2000
  • SRO licensed activities log documenting completion of maintenance and surveillance activities and operator supervisory and related functions for 2018 and 2019 b. Observation and Findings (1) IFI 50-228/2012-204-03 - Review the licensees 10 CFR 50.59 evaluation and review of the proposed new mechanism for attaching the upper grid plate to support structure.

During the summer of 2012, the licensee initiated a program to remove the fuel elements from the core structure so that a thorough examination of each could be made. One of the obstacles encountered by the licensee was-9-

raising the upper grid plate to allow the elements to be removed. When the licensee tried to loosen the four bolts attaching the upper grid plate to the core support structure, three bolts would not turn. Eventually the three bolts snapped off in place while the fourth bolt was loosened and unscrewed about two inches. In order to re-attach the upper grid plate to the core support structure in the future, several methods were discussed. Contractor personnel who were assisting in this project indicated that they might be able to develop a clamping mechanism that could be used instead of the bolts.

This would eliminate the necessity of redrilling the upper grid plate and drilling and tapping the core support structure. Because this would be a change to the current structure, the licensee needed to perform a 10 CFR 50.59 evaluation and review of the proposed new attachment mechanism. The NRC issued an IFI to review this issue.

During this inspection the inspector reviewed the 10 CFR 50.59 evaluation of the proposed new attachment mechanism. (This evaluation was acquired previous to the inspection.) The inspector also reviewed a summary of this issue written by the Aerotest President. The modification consisted of the design and manufacture of 3 clamps to help attach the upper grid plate to the core structure (to be used along with the one bolt that did not shear off during removal). The inspector determined that the 10 CFR 50.59 evaluation had addressed all the issues raised by the licensee and followed the guidance in 10 CFR 50.59. The evaluation was reviewed and ultimately approved by the RSC as required. Following the purchase of Aerotest by the current owner, problems with attaching the clamps as initially proposed were noted.

Modifications to the clamps were proposed which would not change their functioning as described in the 10 CFR 50.59 evaluation. The licensee indicated that the modifications would not reintroduce any old or raise any new safety issues.

However, the licensee has submitted a LAR to the NRC by letter dated March 21, 2019, to modify the existing operating license to a possession-only license in support of the licensees decision to permanently cease operation of the ARRR. This will preclude the necessity of the reassemblying the core structure. This issue is considered closed.

(2) IFI 50-228/2012-205-01 - Review the licensees actions to complete a Root Cause or fault tree analysis concerning the fuel element cracked cladding problem.

During an inspection in 2012, the inspector observed the removal of the fuel elements from the core that could not be removed until the core structure was disassembled. When the core was defueled, the licensee indicated that they were planning on conducting a Root Cause or fault tree analysis concerning what might have caused the cladding to crack. The licensee was informed that the completion of a Root Cause or fault tree analysis concerning the cladding cracks would be tracked by the NRC as an IFI.

During this inspection the inspector reviewed the Root Cause analysis which was conducted by the current owner of Aerotest. The analysis reviewed various aspects of the problem including personnel, the type of TRIGA fuel

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used, and the fuel dynamics. After a review of all these factors, the licensee concluded that limited fuel management and lack of fuel movement was the likely contributor to the severity of the damage to the individual fuel elements.

With the completion of the Root Cause analysis, this issue is considered closed.

(3) IFI 50-228/2017-201-01 - Follow-up on a commitment made by the licensee to have lectures for 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per quarter for the ROs on staff.

During a routine inspection in June 2017, it was noted in Section II of the licensees Operator Requalification Program that lectures were mentioned.

Lectures were not given for a variety of reasons. The inspector indicated that lectures should be given at some frequency despite the fact that the operators had passed all prior examinations and the reactor was not operating at that time. The licensee proposed that, on a quarterly basis, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of lecture would be given to all the SROs at the facility. The licensee was informed that the commitment to complete 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of lecture per quarter as part of their Operator Requalification Program would be considered an IFI.

During this inspection this issue of operator requalification was reviewed.

The inspector determined through a review of the licensees records, including the training log and SRO files, that this commitment was met. The inspector also noted that all the SROs had since left their employment at the facility and there were no longer any licensed operators at the facility, hence there was no longer any need for training lectures. This issue is considered closed.

c. Conclusion The inspector determined the three IFIs were reviewed and are now closed.

7. Exit Interview The inspection scope and results were summarized on August 12, 2020, with the Aerotest President. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee disagreed with the violation that was discussed.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel M. McCarthy Nuclear Analyst T. Richey Radiation Safety Officer and Training Coordinator President and Reactor Manager M. Wilkinson Certified Fuel Handler Supervisor and Facility Manager INSPECTION PROCEDURES USED IP 69002 Class III Research and Test Reactors IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000228/2020201-01 VIO The current RSO did not have a Bachelors degree in Biological or Physical Science and was not a CHP as required by TS Section 12.1.5.

Closed 50-228/2012-204-03 IFI Review the licensees 10 CFR 50.59 evaluation and review of the proposed new mechanism for attaching the upper grid plate to support structure 50-228/2012-205-01 IFI Review the licensees actions to complete a Root Cause or fault tree analysis concerning the fuel element cracked cladding problem.

50-228/2017-201-01 IFI Followup on 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per quarter lecture commitment by the licensee.

PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations Aerotest Aerotest Operations, Inc.

ARRR Aerotest Radiography and Research Reactor CHP Certified Health Physicist E-Plan Emergency Plan IFI Inspector Follow-up Item IP Inspection Procedure LAR License Amendment Request LOA Letter of Agreement No. Number NRC U.S. Nuclear Regulatory Commission Attachment

RO Reactor Operator RSC Reactor Safeguards Committee SRO Senior Reactor Operator TRIGA Training, Research, Isotopes, General Atomics TSs Technical Specifications VIO Violation-2-

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