ML061730163
| ML061730163 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 06/26/2006 |
| From: | Johnny Eads NRC/NRR/ADRA/DPR/PRTB |
| To: | Tsukimura R Aerotest |
| Bassett C | |
| References | |
| IR-06-201 | |
| Download: ML061730163 (15) | |
See also: IR 05000228/2006201
Text
June 26, 2006
Mr. Ray Tsukimura, President
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT: NRC INSPECTION REPORT NO. 50-228/2006-201
Dear Mr. Tsukimura:
On June 5 - 8, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Aerotest Radiography and Research Reactor facility. The enclosed report documents
the inspection results, which were discussed on June 8, 2006, with you and other members of
your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the NRCs rules and regulations and with the conditions of your license. The
inspector reviewed selected procedures and records, observed activities, and interviewed
personnel. Based on the results of this inspection, no findings of significance were identified.
In accordance with Section 2.390, Public inspections, exemptions, and requests for
withholding, of Title 10 of the Code of Federal Regulations, a copy of this letter, its enclosure,
and your response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records component of NRCs 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).
Sincerely,
/RA/
Johnny H. Eads, Jr., Branch Chief
Research and Test Reactors Branch B
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosure: NRC Inspection Report
cc w/encl: See next page
Aerotest Operations, Inc. Docket No. 50-228
cc w/encl:
Director, Energy Facilities Siting Division
Energy Resources Conservation & Development Commission
1516 9th Street
Sacramento, CA 95814
California Department of Health
ATTN: Chief, Environmental Radiation Control Unit
Radiologic Health Section
714 P Street, Room 498
Sacramento, CA 95814
Mr. Chris Bauman, Reactor Supervisor
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
Test, Research and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
June 26, 2006
Mr. Ray Tsukimura, President
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT: NRC INSPECTION REPORT NO. 50-228/2006-201
Dear Mr. Tsukimura:
On June 5 - 8, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Aerotest Radiography and Research Reactor facility. The enclosed report documents
the inspection results, which were discussed on June 8, 2006, with you and other members of
your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the NRCs rules and regulations and with the conditions of your license. The
inspector reviewed selected procedures and records, observed activities, and interviewed
personnel. Based on the results of this inspection, no findings of significance were identified.
In accordance with Section 2.390, Public inspections, exemptions, and requests for
withholding, of Title 10 of the Code of Federal Regulations, a copy of this letter, its enclosure,
and your response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records component of NRCs 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).
Sincerely,
/RA/
Johnny H. Eads, Jr., Branch Chief
Research and Test Reactors Branch B
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosure: NRC Inspection Report
cc w/encl: See next page
DISTRIBUTION:
PUBLIC PRTA r/f AAdams CBassett
PDoyle TDragoun JEads DHughes
EHylton PIsaac WKennedy KWitt
MMendonca JQuichocho WSchuster RidsNrrDprPrta
MVoth PYoung DBarss (MS O6-H2)
BDavis (Ltr only O5-A4) NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML061730163
OFFICE PRT:RI PRT:LA PRTB:BC
NAME CBassett:tls EHylton JEads
DATE 06/23/2006 06/23/2006 06/26/2006
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-228
License No: R-98
Report No: 50-228/2006-201
Licensee: Aerotest Operations, Inc.
Facility: Aerotest Radiography and Research Reactor
Location: 3455 Fostoria Way
San Ramon, CA 94583
Dates: June 5-8, 2006
Inspector: Craig Bassett
Approved by: Johnny H. Eads, Jr., Branch Chief
Research and Test Reactors Branch B
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor
Report No: 50-228/2006-201
The primary focus of this routine, announced inspection was the on-site review of selected
aspects of the licensees Class II research reactor administrative and safety programs
including: organizational structure and staffing, review and audit and design change functions,
procedures, radiation protection, environmental protection, and shipment of radioactive material
since the last NRC inspection of this facility. The licensees programs were acceptably directed
toward the protection of public health and safety and in compliance with NRC requirements.
Organizational Structure and Staffing
! The Aerotest Radiography and Research Reactor organization and staffing met the
requirements specified in the Technical Specifications (TSs).
Review and Audit and Design Change Functions
! The Reactor Safeguards Committee conducted reviews and audits in compliance with
the requirements specified in the TSs.
! No changes had been made at the facility since the last NRC inspection but the 50.59
process of Title 10 of the Code of Federal Regulations (10 CFR) for design change at
the facility was in place and would be followed as required if changes were initiated.
Procedures
! Facility procedural review, revision, control, and implementation satisfied TS
requirements.
Radiation Protection Program
! Surveys and associated checks were completed and documented acceptably to permit
evaluation of the radiological conditions present in the facility.
! Notices and postings at entrances to work areas met the regulatory requirements.
! Personnel dosimetry was worn as required and doses were within the licensees
procedural action levels and NRCs regulatory limits.
! Radiation monitoring equipment was maintained and calibrated as required.
! Training was provided as required covering the topics outlined in 10 CFR 19.12.
! The Radiation Protection and As Low As Reasonably Achievable (ALARA) Programs
satisfied regulatory requirements.
-2-
Environmental Monitoring
! Effluent monitoring satisfied license and regulatory requirements, and releases were
within the specified regulatory and TS limits.
Transportation of Radioactive Materials
! The program for transportation of radioactive materials satisfied NRC requirements.
REPORT DETAILS
Summary of Plant Status
The Aerotest two hundred and fifty kilowatt (250 kW) TRIGA research reactor continued to be
operated in support of neutron radiography, surveillance, and reactor operator training. During
this inspection, the reactor was started up and operated several hours per day at 132 kW to
complete neutron radiographic operations. Although the maximum authorized power level was
250 kW, the licensee opted to reduce the operating power of the reactor to achieve several
goals including the reduction of personnel radiation exposures.
1. Organizational Structure and Staffing
a. Inspection Scope (Inspection Procedure (IP) 69001)
The inspector reviewed the following regarding the licensee's organization and staffing
to ensure that the requirements of Sections 10.0 and 12.1 of Technical Specifications
(TSs), Change No. 8, dated October 22, 1974, were met:
C management and staff responsibilities
C staffing for safe operation of the reactor facility
C Aerotest Operations, Inc. organizational structure and staffing
C Annual Summary of Changes, Tests, and Experiments at Aerotest Radiography
and Research Reactor (ARRR) for the periods from July 1, 2003, to June 30,
2004, and from July 1, 2004, to June 30, 2005
b. Observations and Findings
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 of radiation protection in August 2004 (NRC Inspection
Report Number 50-228/2004-201). The inspector determined that the Reactor
Supervisor retained direct control and overall responsibility for management of the
facility as specified in the TS. The Reactor Supervisor reported to the President,
Aerotest Operations, Inc. Also, the Radiological Safety Officer (RSO) reviewed and
approved all procedures and experiments involving radiological safety as required.
Through review of records and logs, as well as discussions with licensee personnel,
the inspector determined that the current staffing at the facility was acceptable to
support the workload and ongoing activities. Staff personnel also met the qualification
requirements of the TS for effective reactor operations and radiation protection.
c. Conclusions
The licensee's organization and staffing met the requirements specified in the TS.
-2-
2. Review and Audit Functions
a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the audits and reviews stipulated
in the requirements of TS Section 12.1.3, and the design change functions, also
outlined in that Section, were completed:
C Operations Request Forms file
C Reactor Safeguards Committee (RSC) Charter dated March 17, 1978
C TS defined duties of the RSC including the review and audit functions
C RSC meeting minutes for the past two years
C Section I of the ARRR Procedures Manual entitled, Administrative Procedures,
Procedure Change Notice (PCN) Number (No.) 2, RSC approval dated June 28,
1990, and last reviewed May 15, 2006
b. Observations and Findings
(1) Review and Audit Functions
The inspector determined that the RSC membership satisfied the TS
requirements and the Charter stipulations. The inspector reviewed the RSC's
meeting minutes from November 2004 through present. The minutes showed
that the RSC met annually as required and considered the types of topics outlined
by the TS, including as low as reasonably achievable (ALARA) challenges faced
by the facility.
The inspector noted that the RSC Chairman had completed annual audits of
various aspects of the reactor facility operations and programs as stipulated in the
TS. The audits, as well as the resulting findings, were appropriate and the
licensee's response and corrective actions, if needed, were acceptable.
(2) Design Changes
Through review of applicable records, which included the latest Operations
Request Forms and interviews with licensee personnel, the inspector determined
that no changes had been initiated and/or completed at the facility since the last
NRC inspection. However, the inspector verified that changes or modifications to
the facility would be analyzed by the staff and the results of the analyses would
be presented to and reviewed by the RSC, and approved as required if the
changes were determined to be acceptable.
c. Conclusions
Audits and reviews were being conducted acceptably by the RSC according to the
requirements specified in the TS. No changes had been made at the facility since the
last inspection but the process was in place so that changes or modifications would be
reviewed and approved by the RSC as required.
-3-
3. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the requirements of TS
Section 12.2 were met concerning written procedures:
C Procedure Approval Sheets
C PCN forms
C Section I of the ARRR Procedures Manual entitled, Administrative Procedures,
PCN No. 2, RSC approval dated June 28, 1990, and last reviewed May 15, 2006,
which detailed the process used to review, revise, and approve all facility
procedures
C Section II of the ARRR Procedures Manual entitled, Operating Procedures,
PCN No. 2, RSC approval dated June 28, 1990, and last reviewed May 15, 2006
C Section III of the ARRR Procedures Manual entitled, General Emergency
Procedures, PCN No. 4, RSC approval dated January 28, 2005, and last
reviewed May 15, 2006
C Section VI of the ARRR Procedures Manual entitled, Radiological Safety
Procedures, PCN No. 3, RSC approval dated April 29, 1996, and last reviewed
May 15, 2006
b. Observations and Findings
The inspector verified that procedures had been developed and were implemented for
reactor operations and radiation safety. Procedures were being reviewed biennially
and revised as needed. The latest review had been completed May 15, 2006.
Procedure Approval Sheets were maintained and PCN forms were completed when
changes were made as required. The inspector also noted that, when procedures
were revised, the revisions were presented to the RSC for review and approval. The
current facility procedures were acceptable for the current operation.
c. Conclusions
Facility procedural review, revision, control, and implementation satisfied TS
requirements.
4. Radiation Protection Program
a. Inspection Scope (IP 69001)
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:
C Special Work Permits - Numbers 2004-1 through 2005-5
C dosimetry records for facility personnel for the past two years
C radiological signs and posting at the entrances and barriers for restricted areas
-4-
C calibration and periodic check records for portable and fixed radiation monitoring
instruments
C Training Log records documenting radiological safety training for facility personnel
from 2004 to the present
C radiation protection and reactor surveillance and survey data from 2004 to the
present recorded on:
- Swipe Count Sheet forms
- ARRR Pool Water Analysis forms
- Neutron Instrument Calibration forms
- Air Filter Paper Counting Sheet forms
- Aerotest Operations, Inc. Monthly Radiation Survey forms
- Aerotest Operations, Inc. Quarterly Instrument Calibration forms
- Aerotest Operations, Inc. Quarterly Maintenance Check List forms
C Section VI of the ARRR Procedures Manual entitled, Radiological Safety
Procedures, PCN No. 3, RSC approval dated April 29, 1996, and last reviewed
May 15, 2006
C Section VIII of the ARRR Procedures Manual entitled, Maintenance Procedures,
PCN No. 2, RSC approval dated January 14, 1993, and last reviewed May 15,
2006
The inspector also observed the use of dosimetry and radiation monitoring equipment
during tours of the facility and conducted a radiation survey of various offices, support
areas, and the Reactor Bay using an NRC instrument.
b. Observations and Findings
(1) Surveys
Quarterly radiation and contamination survey results indicated that licensed
activities were being conducted in accordance with operating procedures. The
results were documented on the applicable forms and were evaluated as
required. When contamination survey results were noted that exceeded set
action levels, corrective actions were taken and the area re-surveyed to
demonstrate that there was no longer any contamination present. The inspector
noted that these quarterly surveys were often conducted every month which was
more frequently than required.
(2) Postings and Notices
During tours of the facility, the inspector observed that caution signs, postings,
and controls in the controlled areas were acceptable for the hazards involving
radiation, high radiation, and contamination and were posted as required by
10 CFR Part 20, Subpart J. Through observations of and interviews with licensee
staff, the inspector confirmed that personnel complied with the signs, postings,
and controls. The facilitys radioactive material storage areas were noted to be
properly posted. No unmarked radioactive material was detected in the facility.
Copies of current notices to workers were posted in various areas in the facility.
Radiological signs were typically posted at the entrances to controlled areas.
-5-
Other postings also characterized the industrial hygiene hazards that were
present in the areas as well. During one facility tour, the inspector noted that the
copy of NRC Form-3, Notice to Employees, that was posted at the facility, as
required by 10 CFR Part 19.11, was not the current version. This issue was
brought to the attention of the licensee and a copy of the correct version was
immediately retrieved from the Internet. The copy was then posted on the Bulletin
Board by the main entrance to the Reactor Bay. Caution signs, postings, and
controls for radiation areas were as required in 10 CFR Part 20.
(3) Dosimetry
The licensee used dosimetry that was supplied by a National Voluntary
Laboratory Accreditation Program accredited vendor, Radiation Detection
Company. The dosimetry was used to measure whole body and extremity
exposures of facility personnel. Through direct observation, the inspector
determined that dosimetry was acceptably used by facility personnel.
An examination of the records for the past two years, through April of 2006,
showed that all whole body exposures were within NRC limits and within licensee
action levels. Extremity monitoring, accomplished through the use of finger ring
thermoluminescent dosimeters (TLDs), also showed doses to the hands of staff
members which were within the established limits. The highest annual whole
body exposure received by a single individual for 2004 was 3,270 millirem (mrem)
deep dose equivalent (DDE). The highest annual extremity exposure for 2004
was 16,398 mrem shallow dose equivalent (SDE). The highest annual whole
body exposure received by a single individual for 2005 was 1,825 mrem DDE and
the highest annual extremity exposure for 2005 was 9,659 mrem SDE.
The inspector verified that NRC Form-5 reports had been completed and provided
to each employee who had received exposure at the facility during 2004 and
2005.
(4) Radiation Monitoring Equipment
Examination of selected survey meters indicated that the instruments had the
acceptable up-to-date calibration sticker attached. The instrument calibration
records indicated calibration of portable survey meters was typically completed by
licensee personnel and occasionally by a contractor. The inspector verified that
portable instruments were being checked and calibrated quarterly as required by
procedure. Calibration records were being maintained as required.
(5) Training
Training records showed that personnel were acceptably trained in radiation
protection practices. Annual refresher training was provided to all staff members
by the facility RSO. The most recent refresher training was completed March 31,
2006.
(6) Documentation of the Radiation Protection and ALARA Programs
-6-
The Radiation Protection Program was established and described in the ARRR
Procedures Manual,Section VI, entitled Radiological Safety Procedures, and in
the ARRR Reactor Operator Training Manual, Volume 5, entitled Radiological
Safety. The program had not changed since the last inspection. The licensee
reviewed the Radiation Protection Program at least annually in accordance with
10 CFR 20.1101(c). The last review, which was completed August 3, 2005,
included all areas of the program and no weaknesses were reported. The ALARA
Program was outlined in a licensee document entitled, ALARA Program for
Aerotest Operations, Inc. The latest review of the ALARA Program was also
completed on August 3, 2005.
The licensee did not have or require a Respiratory Protection Program or Planned
Special Exposure Program.
(7) Radiation Work Permit Program
Special Work Permits (SWPs) were required to be prepared for special
operations typically performed by non-Aerotest maintenance and other support
personnel performing who were required to work in radiation areas. The
inspector verified that SWPs were being prepared and used in accordance with
the requirements specified in the licensees Radiological Safety Procedures.
The controls and safety precautions specified were appropriate for the work
conducted under the SWPs.
(8) Facility Tours
As noted above, during a tour of the facility the inspector conducted a radiation
survey of various offices, support areas, the Reactor Bay, and mezzanine area
and compared the readings noted with those found by the licensee. The results
detected by the inspector were comparable to those found by the licensee. No
anomalies or discrepancies were noted.
c. Conclusions
The inspector determined that the Radiation Protection and ALARA Programs, as
implemented by the licensee, satisfied regulatory requirements because: 1) surveys
and associated checks were completed and documented acceptably to permit
evaluation of the radiation hazards present; 2) postings met regulatory requirements;
3) personnel dosimetry was being worn as required and recorded doses were within
the NRCs regulatory limits; 4) radiation survey and monitoring equipment was being
maintained and calibrated as required; and 5) radiation protection training was being
conducted for facility personnel.
-7-
5. Effluent and Environmental Monitoring
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of
10 CFR Part 20 and TS Sections 3.1, 7.2, and 7.3:
C Air Filter Paper Counting Sheets for the past two years
C environmental dosimetry records for the past two years
C Radioactive Liquid Waste Holding Tank release records
C selected ARRR Operations Log Sheets for the past two years
C Section VI of the ARRR Procedures Manual entitled, Radiological Safety
Procedures, PCN No. 3, RSC approval dated April 29, 1996, and last reviewed
May 15, 2006, outlining the licensees environmental monitoring program
b. Observation and Findings
The inspector reviewed the calibration records of the area, water, and stack
monitoring systems. These systems had been calibrated semiannually in accordance
with procedure. The inspector also reviewed the records documenting liquid and
airborne releases to the environment for the past two years. Gaseous releases were
monitored as required by TS. The results indicated that the releases were within
10 CFR, Appendix B, Table 2 concentrations, and TS limits. To demonstrate
compliance with the annual dose constraints of 10 CFR 20.1101(d), the licensee used
the COMPLY computer code. The highest calculated dose that could be received by a
member of the public as a result of gaseous emissions from reactor operations was
1.7 E-3 millirem per year (mr/yr) for 2004 and 1.4 E-3 mr/yr for 2005. These doses
were well below the 10 mr/yr limit set in 10 CFR 20.1101(d).
The licensee had released one tank of wastewater from the Radioactive Liquid Waste
Holding Tank during the past two years in accordance with procedure. The RSO
reviewed and approved the release after analyses, which were reviewed and verified
by the Central Contra Costa Sanitary District, State of California, indicated that the
release met regulatory requirements for discharge into the sanitary sewer.
On-site and off-site gamma radiation monitoring was completed using environmental
TLDs in accordance with the applicable procedures. The 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
Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and TS limits.
-8-
6. Transportation
a. Inspection Scope (IP 86740)
In order to verify compliance with the requirements of 10 CFR 71.5 for shipments of
licensed material, the inspector reviewed the following:
C shipping records for the facility
C selected operations records from 2004 through the present
C Training Log records documenting transportation safety training for facility
personnel from 2004 to the present
The inspector also interviewed licensee personnel regarding shipments of radioactive
material.
b. Observations and Findings
Staff interviews and record reviews showed that the licensee had not completed any
radioactive material shipments since the last inspection. The inspector reviewed the
licensees program for transportation of radioactive material and determined that it
was adequate. The inspector noted that three staff members had completed the
training for shipping hazardous materials and one person had completed the Shipping
Dangerous Goods training.
c. Conclusions
The program for transportation of radioactive materials satisfied NRC requirements.
7. Exit Interview
The inspection scope and results were summarized on June 8, 2006, with members of
licensee management. The inspector described the areas inspected and discussed the
inspection findings. No dissenting comments were received from the licensee. Although
proprietary information was reviewed during the inspection, no such material is included in
this report.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
C. Bauman, Reactor Supervisor
A. Meren, Manager, Neutron Radiography
R. Tsukimura, President and Chief Operating Officer, Aerotest Operations, Inc.
S. Warren, Radiological Safety Officer and Manager, Quality Assurance
INSPECTION PROCEDURES USED
IP 69001 Class II Non-Power Reactors
IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
LIST OF ACRONYMS USED
ALARA As low as reasonably achievable
ARRR Aerotest Radiography and Research Reactor
10 CFR Title 10 of the Code of Federal Regulations
IP Inspection Procedure
kW kilowatt
mr/yr millirem per year
mrem millirem
No. Number
NRC Nuclear Regulatory Commission
PCN Procedure Change Notice
RSC Reactor Safeguards Committee
RSO Radiological Safety Officer
SDE Shallow dose equivalent
SWP Special Work Permit
TLD Thermoluminescent dosimeter
TS Technical Specification