ML14164A748
| ML14164A748 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 01/07/2013 |
| From: | NRC/OGC |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 26039, ASLBP 14-931-01-LT-BD01, 50-228-LT | |
| Download: ML14164A748 (20) | |
See also: IR 05000228/2012206
Text
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January 7, 2013
Ms. Sandra Warren, General Manager
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT: AEROTEST OPERATIONS, INC. - NRC NON-ROUTINE INSPECTION
REPORT NO. 50-228/2012-206
Dear Ms. Warren:
From December 10 to 13, 2012, the U.S. Nuclear Regulatory Commission (NRC or the
Commission) completed an inspection at your Aerotest Radiography and Research Reactor
facility (Inspection Report No. 50-228/2012-206). The enclosed report documents the
inspection results, which were discussed on December 13, 2012, 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 Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records and interviewed personnel. Based on
the results of this inspection, no findings of significance were identified. No response to this
letter is required.
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 enclosure, and
your response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the 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).
Should you have any questions concerning this inspection, please contact Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosure: NRC Inspection Report No. 50-228/2012-206
cc w/encl: See next page
Aerotest Operations, Inc. Docket No. 50-228
cc w/encl:
Dario Brisighella, President
Aerotest Operations, Inc.
Autoliv
3350 Airport Road
Ogden, UT 84405
Fred Meren, Reactor Supervisor
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
California Energy Commission
1516 Ninth Street, MS-34
Sacramento, CA 95814
Radiological Health Branch
P.O. Box 997414, MS 7610
Sacramento, CA 95899-7414
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
January 7, 2013
Ms. Sandra Warren, General Manager
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT: AEROTEST OPERATIONS, INC. - NRC NON-ROUTINE INSPECTION
REPORT NO. 50-228/2012-206
Dear Ms. Warren:
From December 10 to 13, 2012, the U.S. Nuclear Regulatory Commission (NRC or the
Commission) completed an inspection at your Aerotest Radiography and Research Reactor
facility (Inspection Report No. 50-228/2012-206). The enclosed report documents the
inspection results, which were discussed on December 13, 2012, 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 Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records and interviewed personnel. Based on
the results of this inspection, no findings of significance were identified. No response to this
letter is required.
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 enclosure, and
your response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the 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).
Should you have any questions concerning this inspection, please contact Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosure: NRC Inspection Report No. 50-228/2012-206
cc w/encl: See next page
DISTRIBUTION:
PUBLIC RidsNrrDprPrta Resource RidsNrrDprPrtb Resource PROB r/f
MNorris (MS T3B46M) MCompton (Ltr only O5-A4) GLappert, NRR CBassett, NRR
STraiforos, NRR CMontgomery, NRR
ACCESSION NO.: ML12361A147 *concurrence via e-mail TEMPLATE #: NRC-002
OFFICE PROB:RI * PROB:LA PROB:BC
NAME CBassett GLappert GBowman
DATE 12/16/2012 12/26/2012 1/7/2013
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-228
License No: R-98
Report No: 50-228/2012-206
Licensee: Aerotest Operations, Inc.
Facility: Aerotest Radiography and Research Reactor
Location: 3455 Fostoria Way
San Ramon, CA 94583
Dates: December 10-13, 2012
Inspector: Craig Bassett
Approved by: Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor
Report No: 50-228/2012-206
The primary focus of this non-routine, announced inspection was the onsite review and
observation of Aerotest Operations, Inc. (the licensees) fuel handling and containerization
activities. The inspection included review of selected aspects of the licensees safety program,
including: (1) organizational structure and staffing, (2) review and audit functions,
(3) procedures, (4) radiation protection, and (5) conformance to security plan requirements. The
licensees program was acceptably directed toward the protection of public health and safety
and was in compliance with U.S. Nuclear Regulatory Commission requirements.
Fuel Handling and Containerization
- Adequate preparations were made for damaged fuel to be placed into canisters.
- A testing station was developed by the licensees contractor, which allowed the
containerization work to be completed underwater, saving a great deal of personnel
dose.
- All the damaged fuel elements were placed in canisters and then transferred to storage
in a fuel rack in a timely manner without incident.
Organizational Structure and Staffing
- The licensees organization and staffing met the requirements specified in the Technical
Specifications.
Review and Audit Functions
- The Reactor Safeguards Committee conducted reviews and audits in compliance with
the requirements specified in the Technical Specifications.
Procedures
- Facility procedural review, revision, and control satisfied Technical Specifications
requirements.
Radiation Protection
- Surveys during work evolutions were completed and documented acceptably to permit
evaluation of the radiological conditions present in the facility.
- Notices and postings at the facility met regulatory requirements.
- Personnel dosimetry was being worn and doses were within the regulatory limits.
- Radiation monitoring equipment was maintained and calibrated as required.
- Training was provided covering the topics outlined in Title 10 of the Code of Federal
Regulations Section 19.12, as required.
Conformance to the Security Plan Requirements
- Security facilities, equipment, and procedures satisfied security plan requirements.
REPORT DETAILS
Summary of Plant Status
Aerotest Operations, Inc. (AO or the licensee) ceased operation of their TRIGA conversion
research and test reactor on October 15, 2010. Prior to that time, the reactor had been
operated for neutron radiography, to complete surveillance requirements, and for reactor
operator training. During this inspection the reactor remained shut down and all the fuel was in
storage racks which were located along the wall or at the bottom of the reactor pool. Fuel
elements with cracked cladding were placed in canisters.
1. Background Information
In December 2011 the licensee began an inspection of all their fuel elements in an effort
to comply with their commitment to the U.S. Nuclear Regulatory Commission (NRC) to
inspect all the fuel elements every 5 years. After removing all the elements that they
could, the licensee found that there were 27 aluminum clad fuel elements and 11
graphite elements that were stuck in place and could not be removed through core upper
grid plate (none of the stainless steel clad elements were found to be stuck). The
licensee then used their underwater video camera to conduct an inspection of those fuel
elements. The licensee found that, of those elements that remained in the core, four
had signs of cracks in the cladding. Previously, in 2007, a fifth aluminum clad fuel
element had been removed from service and placed in a storage rack due to cracked
cladding.
On January 9, 2012, the licensee notified the NRC of the cracked fuel elements. The
licensee submitted a letter documenting the problem the same day. From January 17-
18, 2012, the NRC completed an inspection at the Aerotest Radiography and Research
Reactor (ARRR) (see NRC Inspection Report No. 50-228/2012-201).
The licensee subsequently made the decision to remove the stuck fuel elements from
the core and they hired a contractor, Secured Transportation Services (STS), to assist in
the project. STS developed a project plan proposal for removing all the elements and
submitted it to the licensee. The proposal was found to be acceptable and preparations
for the actual removal work began. The contractor developed reactor work instructions
(RWIs) for the project to ensure that all those who worked on the project understood
their respective roles. When all the elements had been removed from the core, it was
the intention of the licensee to place the fuel elements with cracked cladding in specially
designed and fabricated canisters. Before beginning removal of the fuel with damaged
cladding, the licensee anticipated that four to five more elements would be found with
cracks in the cladding, in addition to the ones already noted. Therefore, a total of ten
canisters were ordered and fabricated and a storage rack was designed and fabricated
to hold up to twelve canisters in the reactor pool.
During the period of July 16-26, 2012, licensee and contractor personnel were able to
remove all the stuck fuel elements from the core and conduct an initial examination of
the elements. The licensee then proceeded to examine all the remaining aluminum clad
elements and all of the stainless steel clad elements that were stored in the pool.
Initially, two elements with cracked cladding were placed into the specially designed
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canisters (i.e., canned) and placed in the new storage rack. However, after examining
all the fuel elements, the licensee determined that there were substantially more fuel
elements with cladding problems than had originally been anticipated. The licensee then
contracted to have more canisters and a larger storage rack fabricated. At that point the
fuel element work was stopped and all the elements were placed in appropriate storage.
This was done because the STS personnel had other commitments and could not return
until a later date to assist in the canning of the rest of the fuel elements with damaged
cladding. During the period when the stuck fuel was being removed from the core, the
NRC completed a non-routine inspection at the ARRR (see NRC Inspection Report No.
50-228/2012-204).
On August 10, 2012, the licensee submitted a letter to the NRC documenting the fact
that the inspection of the fuel elements at the facility indicated that there were a total of
22 fuel elements with cracks in the cladding. Also, further review of the video
documentation of the entire inventory of elements was scheduled to be conducted during
the week of September 10, 2012. The NRC conducted another non-routine inspection
during that period to review the actual status of the fuel elements (see NRC Inspection
Report No. 50-228/2012-205). Plans were made to have STS personnel return to the
ARRR facility on December 10, 2012, to complete the containerization process.
During this inspection, the inspector observed as the remaining fuel elements with
cladding degradation were placed in the canisters. A lid was then installed on each
canister and it was sealed, drained, and then backfilled with helium gas. Finally, the
canisters were positioned in a new storage rack at the bottom of the reactor pool.
2. Organizational Structure and Staffing
a. Inspection Scope (Inspection Procedure (IP) 69001)
The inspector reviewed the following regarding the licensees organization and
staffing to ensure that the requirements of Technical Specification (TS) Section
10.0 and TS 12.1 were met:
- Management and staff responsibilities
- Staffing for safe maintenance of the reactor facility
- Aerotest Operations, Inc. organizational structure
- Annual Summary of Changes, Tests, and Experiments at ARRR for the
period from July 1, 2010, through June 30, 2011, issued July 28, 2011
- Annual Summary of Changes, Tests, and Experiments at ARRR for the
period from July 1, 2011, through June 30, 2012, issued July 31, 2012
b. Observations and Findings
Through discussions with licensee representatives, the inspector determined that
management responsibilities at the facility had not changed since the previous
routine NRC inspection in June 2012 (NRC Inspection Report No. 50-228/2012-
202). The inspector noted that the General Manager was the local official in
charge of day-to-day operations at the facility. The Reactor Supervisor/Reactor
Operations Manager retained direct control over, and overall responsibility for,
-3-
management of the reactor as specified in the TS. The General Manager and
the Reactor Supervisor reported to the President, Aerotest Operations, Inc.
Through review of records and discussions with licensee personnel, the inspector
determined that staffing at the facility had been reduced because the reactor was
no longer in operation. During the fuel containerization work, staffing was
sufficient for the tasks performed and was augmented by two contractor
personnel to facilitate timely completion of the project.
c. Conclusion
The licensees organization and staffing met the requirements specified in the
TS. During the containerization project, licensee staff was augmented by two
contractor personnel and staffing was sufficient for the tasks performed.
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 12.1.3 were being completed:
- Reactor Safeguards Committee (RSC) meeting minutes for the most
recent meetings held on November 22, 2011, July 11, 2012, and
November 6, 2012
- TS-defined duties of the RSC, including the review and audit functions
- Section I of the ARRR Procedures Manual, Administrative Procedures,
Procedure Change Notice (PCN) No. 2, RSC approval dated June 28,
1990, and last reviewed May 16, 2011
b. Observations and Findings
Review and Audit Functions
The inspector reviewed the RSC meeting minutes from November 2011 through
the present. The minutes showed that the RSC met annually as required and
considered the types of topics outlined by the TS. An additional meeting had
been held in July to discuss the fuel containerization project. The inspector
determined that the review functions required by the TS were being completed by
the RSC. Through records review the inspector noted that the RSC membership
satisfied the TS requirements and RSC charter stipulations.
The inspector noted that the chairman of the RSC had completed an annual
unannounced audit of various aspects of the reactor facility operations and
programs as stipulated in the TS. The most recent audit was completed on
August 20, 2012. The audits, as well as the resulting findings, were appropriate
and the licensees response and corrective actions, if needed, were acceptable.
-4-
c. Conclusion
Audits and reviews were being conducted acceptably by the RSC in accordance
with the requirements specified in the TS.
3. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the requirements of TS
Section 12 were met concerning written procedures:
- Procedure approval sheets
- PCN forms
- Section I of the ARRR Procedures Manual, Administrative Procedures,
PCN No. 2, RSC approval dated June 28, 1990, and last reviewed
May 16, 2011, which detailed the process used to review, revise, and
approve all facility procedures
- Section IV of the ARRR Procedures Manual, Critical Assembly and
Power Calibration Procedures, PCN No. 9, RSC approval dated
November 6, 2012
- AO RWI No. 101, Aerotest - Canister Handling, Loading, Drying, and
Conditioning, Rev. 1, dated November 28, 2012
b. Observations and Findings
The inspector verified that procedures had been developed and were available
for fuel handling operations and were being implemented at the facility as
required. Procedures were being reviewed biennially and revised as needed.
The last review had been completed on May 16, 2011. Procedure approval
sheets were maintained and PCN forms were completed as required when
changes were made. The inspector also noted that, when procedures were
revised, the revisions were presented to the RSC for review and approval. The
last procedure revision was reviewed and approved by the RSC during the most
recent meeting of the committee on November 6, 2012.
During a previous inspection, it was noted that the contractor who had been hired
to help with the damaged fuel containerization had also written various RWIs for
the project. These instructions were not considered facility procedures, and thus
were not required to be reviewed and approved by the RSC. Nevertheless, the
inspector verified that the instructions had been reviewed by the RSC chairman
and that he did not have any concerns about their use at the facility. The
inspector reviewed AO RWI No. 101, Aerotest - Canister Handling, Loading,
Drying, and Conditioning. It was noted that this instruction had been revised
and changed by the contractor because they had developed a different method
for canning the fuel. The newly revised instruction had been reviewed and
approved by the facility General Manager.
-5-
c. Conclusion
Facility procedural review, revision, and control satisfied TS requirements.
4. Fuel Handling and Containerization Operations
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify that fuel
handling was being conducted as required by TS 5.1.1, TS Section 11, and by
procedure:
- Current fuel element storage location map
- Various current records and data sheets related to fuel movement
- Listing of the cracked fuel elements, including the location of each
- Schematics of the canister draining, drying, and inert gas fill rig/setup
- Fuel inspection and examination records, including video of fuel
inspections
- Detailed drawings of the base ring and testing station to be used during
the fuel element canning/containerization process
- AO RWI No. 101, Aerotest - Canister Handling, Loading, Drying, and
Conditioning, Rev. 1, dated November 28, 2012
- AO RWI No. 102, Aerotest - Fuel Handling Procedure, Rev. 0, dated
June 25, 2012
- Project Plan Aero-PP-01, Aerotest Operations Fuel Removal, Inspection,
and Canning, Rev. 0, dated June 25, 2012
In addition, as noted above, the inspector observed the planning, discussions,
and actions of licensee and contractor personnel as the remaining fuel elements
with damaged cladding were sealed in canisters and the canisters positioned in
the new storage rack in the reactor pool.
b. Observations and Findings
(1) Preparations for Fuel Containerization
As discussed above, after the licensee found that numerous fuel
elements had cracks or other problems with their cladding, the licensee
decided to place them all in canisters to provide for safe storage. STS
originally designed and fabricated enough specialized canisters for eight
regular and two instrumented fuel elements. Two regular elements had
been placed in the canisters in July (see NRC Inspection Report No. 50-
228/2012-204). Because of the number of damaged fuel elements found,
STS was asked to fabricate more canisters and return to help with the
containerization process. More canisters were subsequently fabricated, a
new storage rack was completed, and the containerization or canning
operation for the remainder of the elements with cracked cladding
-6-
occurred during the week of December 10, 2012. As noted above, STS
contractor personnel were on site to assist the licensee.
In order to provide the maximum shielding possible for those performing
the canning work, the licensee and contractor personnel developed a
testing station to be used in the containerization process. The testing
station allowed work to be performed on a canister loaded with fuel (i.e.,
attaching the lid to the canister with bolts and then sealing, backfilling,
and testing the sealed container) under four feet of water. During the
previous canning operation in July, once a canister was loaded with an
element, it had to be brought to the surface of the pool so the lid could be
installed. One person would then have to hold the canister and lid while
another person tightened the bolts in the lid with a torque wrench. This
resulted in a moderate dose to both individuals involved. The new design
for a canister and lid working area using water as shielding resulted in
significant dose reduction.
(2) Use of the Testing Station/Canister Loading and Testing Apparatus
With the testing station securely installed, the licensee then fastened an
underwater camera in place to record the operations that would take
place below the surface. After loading an element in a submerged
canister, the container was then raised to within approximately three and
one half feet of the pool surface and lowered into place in the testing
station. The lid, with extension fill and drain tubes attached to the vent
and drain valves, was then lowered onto the canister and the lid bolts
were tightened with a torque wrench to the appropriate predetermined
value by using an extension with a hex head attached. With the lid
installed, the extension fill and drain tubes were attached to the vacuum
and pressurization system. It was then possible to drain/dewater the
canister using pressurized gas, draw a vacuum on the canister with a
vacuum pump, and then backfill it with helium gas. Once this was
completed and verified, the canister and enclosed fuel element were
removed from the testing station, weighed, and placed in a designated
storage location in the new storage rack.
The inspector observed as each of the elements with damaged cladding
was placed into a canister and the canister was closed, dried, tested, and
backfilled with the cover gas. The canisters were then placed into pre-
designated locations in the new storage rack on the reactor pool floor.
c. Conclusion
Adequate preparations were made for the damaged fuel to be placed into
canisters. A testing station was developed by the contractor, which allowed the
containerization work to be completed underwater, resulting in a reduction in
dose to workers. All the damaged fuel elements were placed in canisters and
then transferred to storage in a fuel rack without incident.
-7-
3. Radiation Protection Program
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with Title 10 of the
Code of Federal Regulations (10 CFR) Part 20 and the requirements in TS 6.2,
TS Section 7.0, and TS 12.1.2:
- Special Work Permits (SWPs) 2012-01 through 2012-03
- Radiological signs and posting at the entrances to controlled or restricted
areas
- Calibration records for the electronic dosimeters provided by the
contractor
- Radiation protection surveillance and survey data for the defueling project
- Section VI of the ARRR Procedures Manual, Radiological Safety
Procedures, PCN No. 3, RSC approval dated April 29, 1996
- Section VIII of the ARRR Procedures Manual, Maintenance Procedures,
PCN No. 2, RSC approval dated January 14, 1993
- ALARA [As Low as Reasonably Achievable] and Radiation Protection
Program for Aerotest Operations, Inc., updated August 14, 2004
The inspector also observed the use of dosimetry and radiation monitoring
equipment during the inspection.
b. Observations and Findings
(1) Surveys
Appropriate radiation surveys were conducted during all phases of the
containerization project. The survey results indicated that fuel canning
activities were being conducted in accordance with applicable
procedures. The results of the surveys were documented on the
applicable forms and continually evaluated as required. Surveys in the
area where people were working directly on the canning activities (i.e.,
at pool side) indicated a general area radiation level of less than one
millirem per hour during all aspects of the operation (i.e., lifting the loaded
canisters into position on the testing station and working on the draining
and conditioning of the canisters).
The inspector noted that licensee and contractor personnel were using
the appropriate monitoring equipment during the various work evolutions.
Those directly involved in the canning monitored themselves after
handling the canning equipment or items that might have been
contaminated.
-8-
(2) Postings and Notices
During tours of the facility, the inspector observed that caution signs,
postings, and controls in the restricted or controlled areas were
acceptable for hazards involving radiation, high radiation, and
contamination, and were posted as required by 10 CFR Part 20,
Subpart J. Radiological signs were typically posted at the entrances to
controlled areas.
Copies of current notices to workers were posted in various areas in the
facility including the hallway in the reactor bay outside the control room.
Other postings also characterized the industrial hygiene hazards that
were present in the areas. The inspector noted that the copies of
NRC Form 3, Notice to Employees, posted at the facility as required by
10 CFR 19.11, were the current version.
(3) Dosimetry
The inspector determined that the licensee used thermoluminescent
dosimeters (TLDs) for whole body monitoring of beta and gamma
radiation exposure (with an additional component to measure neutron
radiation). The licensee also used TLD finger rings for extremity
monitoring. The dosimetry was supplied and processed by Radiation
Detection Company, a company that was a National Voluntary Laboratory
Accreditation Program accredited vendor. The licensee also issued
dosimeters and finger rings to contractor personnel to be used for the job
and issued pocket ion chambers each day to track daily exposure.
STS also provided electronic dosimeters for everyone to use during the
project. Similar to the pocket ion chambers issued by the licensee, the
electronic dosimeters were also used to track daily exposure. During the
entire project, the highest dose received by any one individual was
approximately 5 millirem.
(4) Radiation Monitoring Equipment
During the inspection the inspector determined that licensee survey
meters were appropriately calibrated. The inspector noted that the
calibration of portable instruments was being verified quarterly as
required by procedure.
(5) Training
During a previous inspection, the inspector verified that the training given
to contractor personnel, including training on radiation protection
practices, satisfied NRC requirements. Contractor personnel did not
require any further training for the work performed during this period. The
inspector had also received training concerning the SWP issued for the
fuel element inspection and canning project. The training provided
-9-
satisfied the requirements and covered the topics outlined in
(7) Radiation Work Permit Program
SWPs were required to be prepared for special operations typically
performed by non-Aerotest maintenance and other support personnel
who were required to work in radiation areas. The inspector noted that
SWPs had been written and issued for the contractor personnel, as well
as for the inspector. The SWPs had been prepared and implemented 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 SWP.
c. Conclusion
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, (4) radiation
survey and monitoring equipment were being maintained and calibrated as
required, and (5) radiation protection training had been conducted relative to the
fuel element containerization work that was done.
4. Conformance to Security Plan Requirements
a. Inspection Scope (IPs 81401, 81402, 81431, 81810)
The inspector reviewed the following to verify that fuel containerization activities
were conducted in compliance with TS 3.2 and the licensees NRC-approved
physical security plan (PSP), Aerotest Radiography and Research Reactor
Security Plan, last revised January 7, 2005:
- Access controls currently in effect
- Alarm checklist forms for 2012
- Emergency detection devices and physical barriers
- Emergency Plan for the Aerotest Radiography and Research Reactor,
last revised January 14, 2005, and last reviewed May 16, 2011
- Section III of the ARRR Procedures Manual, General Emergency
Procedures, PCN No. 4, RSC approval dated January 28, 2005
No. 3, RSC approval dated February 11, 2005
b. Observations and Findings
The inspector previously conducted an inspection of the PSP in June 2012 (see
NRC transmittal letter for Inspection Report No. 50-228/2012-203). During that
- 10 -
inspection the inspector verified that the licensee was maintaining adequate
security and control over the facility.
During this inspection the inspector verified that the physical protection system
remained in place and was as stipulated in the PSP. The system was being
maintained and tested as required by procedure. The inspector verified that the
required control continued to be maintained over access to the facility, the
reactor pool, and over fuel handling equipment.
c. Conclusion
Security facilities, equipment, and procedures satisfied PSP requirements.
5. Follow-up on Previously Identified Issues
a. Inspection Scope
The inspector reviewed the licensees actions taken in response to previously
identified items in various NRC inspection reports, including four previously
opened inspector follow-up items (IFIs).
b. Observation and Findings
(1) IFI 50-228/2012-201-02 - Follow-up on the issue of cracks in the fuel
elements.
During a previous inspection, various factors that may have led to the fuel
elements developing cracks in the cladding were reviewed. These
included reviews of operations, maintenance, and surveillance records,
and fuel element history records. At that time the licensee was unable to
conclusively determine a probable cause for the cracks in the fuel. The
NRC indicated that this issue would continue to be reviewed, to include a
review of the videos produced by the licensee of the cracks and the
condition of the stuck fuel elements.
The inspector continued to evaluate IFI 50-228/2012-201-02 during this
inspection. Previous inspections had been conducted to review this
issue, including inspections in July and September 2012 which involved
observing the removal of the stuck fuel elements from the core and
reviewing the videos of those elements. It was noted that the licensee
had committed to conduct a root cause analysis of the problem and IFI
50-228/2012-205-01 was opened to follow the completion of that analysis.
Because of the prior inspections that had been completed and the
commitment by the licensee to conduct a thorough analysis, IFI 50-
228/2012-201-02 is closed. Review of the licensees causal analysis will
be tracked under IFI 50-228/2012-205-01.
(2) IFI 50-228/2012-204-01 - Review the licensees actions to ensure that all
the cracked fuel elements are placed in canisters.
- 11 -
As noted above, during this inspection all the elements with cracked or
damaged cladding were successfully placed in canisters and no issues of
significance were identified. As such, IFI 50-228/2012-204-01 is closed.
(3) 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 a previous inspection, the process of removing the stuck fuel
elements from the core was reviewed. One of the obstacles encountered
by the licensee was raising the upper grid plate to allow the elements to
be removed from underneath. When the licensee tried to loosen the four
bolts holding 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
reattach the upper grid plate to the core support structure in the future,
several methods were discussed. STS contractor personnel indicated
that they could 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 was
aware that they would need to perform a 10 CFR 50.59 evaluation and
review of the proposed new attachment mechanism.
During this inspection the inspector reviewed this issue. It was noted that
STS had developed a clamping device for the upper grid plate and that
they were in the process of conducting and documenting a 10 CFR 50.59
evaluation to determine if NRC approval would be required prior to
installation. Therefore, this issue remains open.
(4) 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 a previous inspection, the licensee indicated that they were
planning to conduct a root cause or fault tree analysis concerning what
might have caused the cladding of the various fuel elements to crack.
During this inspection the inspector reviewed this issue. It was noted that
the licensee had made the decision to postpone completion of a root
cause analysis of the cladding degradation until after all the elements with
damaged cladding were placed in canisters and stored properly. Since
this activity was only just completed during this inspection, this issue
remains open.
c. Conclusion
Four inspector follow-up items were reviewed and two were closed.
- 12 -
6. Exit Interview
The inspection scope and results were summarized on December 13, 2012, with
members of licensee management. The inspector described the areas inspected and
discussed the inspection findings. Proprietary information was reviewed during the
inspection; however, no material is included in this report.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
C. Bauman Research and Development Manager
A. Meren Reactor Supervisor and Reactor Operations Manager
T. Richey Neutron Radiography Manager
S. Warren General Manager and Radiological Safety Officer
M. Wilkinson Quality Assurance Manager
Other Personnel
R. Boyd Vice President, Secured Transportation Services
B. Williams President, Secured Transportation Services
INSPECTION PROCEDURES USED
IP 69001 Class II Non-Power Reactors
IP 81401 Plans, Procedures, and Reviews
IP 81402 Reports of Safeguards Events
IP 81431 Fixed Site Physical Protection of Special Nuclear Material of Low Strategic
Significance
IP 81810 Protection of Safeguards Information
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
50-228/2012-201-02 IFI Follow-up on the issue of cracks in the fuel elements.
50-228/2012-204-01 IFI Review the licensees actions to ensure that all the cracked fuel
elements are placed in canisters.
Discussed
50-228/2012-201-01 URI Operating the reactor with possible defective fuel was identified
as a potential TS violation.
50-228/2012-204-02 URI Review the issue of fuel verification at the Aerotest facility.
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.
PARTIAL LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
ADAMS Agencywide Documents Access and Management System
ALARA As Low as Reasonably Achievable
AO Aerotest Operations
ARRR Aerotest Radiography and Research Reactor
IFI Inspector Follow-up Item
IP Inspection Procedure
NRC U.S. Nuclear Regulatory Commission
PCN Procedure Change Notice
PSP Physical Security Plan
RSC Reactor Safeguards Committee
RWI Reactor Work Instruction
STS Secured Transportation Services
SWP Special Work Permit
TLD Thermoluminescent Dosimeter
TS Technical Specification