ML14164A752
| ML14164A752 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 08/14/2012 |
| 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: ML14164A752 (18) | |
See also: IR 05000228/2012204
Text
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6XEPLWWHG -XQH
August 14, 2012
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. 50-228/2012-204
Dear Ms. Warren:
On July 16 - 23, 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. 50-228/2012-204). The enclosed report documents the inspection
results which were discussed on July 23, 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,
/JNguyen for 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. 50-228/2012-204
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
August 14, 2012
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. 50-228/2012-204
Dear Ms. Warren:
On July 16 - 23, 2012, the U.S. Nuclear Regulatory Commission (NRC, the Commission)
completed an inspection at your Aerotest Radiography and Research Reactor facility
(Inspection Report No. 50-228/2012-204). The enclosed report documents the inspection
results which were discussed on July 23, 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,
/JNguyen for 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. 50-228/2012-204
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
ACCESSION NO.: ML12213A001 *concurrence via e-mail TEMPLATE #: NRC-002
OFFICE PROB:RI * PRPB:LA PROB:BC
NAME CBassett GLappert GBowman
DATE 7/26/2012 7/31/2012 8/14/2012
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-228
License No: R-98
Report No: 50-228/2012-204
Licensee: Aerotest Operations, Inc.
Facility: Aerotest Radiography and Research Reactor
Location: 3455 Fostoria Way
San Ramon, CA 94583
Dates: July 16-23, 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: 50-228/2012-204
The primary focus of this non-routine, announced inspection was the onsite review of selected
aspects of the Aerotest Operations, Inc. (the licensees) 250 Kilowatt (kW) Class II research
reactor safety program including: 1) fuel handling and inspection including defueling activities,
2) radiation protection, 3) conformance to the Security Plan, and 4) Design Change Functions.
The licensees program was acceptably directed toward the protection of public health and
safety, and in compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements.
Fuel Handling and Defueling
Once various obstacles were overcome, the fuel and graphite elements were removed
from the core.
Fuel movements and inspections were completed and documented in accordance with
the requirements specified by procedure.
Following inspection of all the fuel elements, 21 aluminum clad elements were noted to
have cracks in them.
One unresolved item was noted regarding the licensees method of fuel element serial
number verification.
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 the facility met the 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 as required covering the topics outlined in Title 10 of the Code of
Federal Regulations Section 19.12.
Conformance to the Security Plan Requirements
Security facilities, equipment, and procedures satisfied the Physical Security Plan
requirements.
Design Change Functions
A change is being considered in the method of attaching the upper grid plate to the core
support structure which will need to be reviewed and approved.
REPORT DETAILS
Summary of Plant Status
Aerotest Operations, Inc. (Aerotest or the licensee) had ceased to operate their TRIGA
Conversion research 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 of the fuel and
graphite elements were removed from the core and placed in storage racks. All the fuel
elements were inspected for damage to the cladding.
1. Background Information
During December 5-12, 2011, the licensee attempted to complete an inspection of all the
fuel to comply with their commitment to the NRC of inspecting all the fuel elements every
five years. As in previous inspections, those elements that could be removed were
placed in storage along the side of the reactor tank, in storage baskets on the floor of the
pool, or in storage holes in the thermal column. After those elements were removed, the
licensee found that there were 27 aluminum (Al) elements and 11 graphite elements that
could not be removed from the core. (One of the stainless steel (SS) elements and one
of the graphite elements were left in the core because they could not be removed due to
their respective locations.)
The licensee then used their underwater video camera to conduct an inspection of those
elements that could not be removed. The licensee found that, of those elements that
remained in the core, there were four that had signs of cracks in the cladding. (The
licensee then had 5 Al fuel elements that had cracks in the cladding, including one found
previously in 2007). Because of the cracking problem noted in some of the stuck
elements, the elements that had been removed from the core were not returned to the
core but left in their respective storage locations. No cause for the cracking could be
determined but the licensee surmised that it may have been caused from age and the
environment in which the elements were maintained (neutron flux, thermal cycling, and
immersed in water for almost 50 years).
On January 9, 2012, the licensee notified the NRC about the cracks that had been noted
in the fuel elements. The licensee submitted a letter documenting the problems that
same day. (The NRC had been notified of the cracked element removed from the core
in 2007 by a phone conversation between the licensee and Project Manager on
September 19, 2011.)
On January 17-18, 2012, the NRC completed an inspection at the Aerotest Radiography
and Research Reactor (see NRC Inspection Report No. 50-228/2012-201). During that
inspection one unresolved item was identified for possibly operating the reactor with
damaged fuel elements.
The licensee subsequently made the decision to remove all the fuel elements from the
core. It was decided to hire a contractor who would develop a plan to remove all the
-2-
stuck elements and submit a proposed project plan and reactor work instructions (RWIs)
to the licensee. A company, Secured Transportation Services (STS), was chosen for the
work.
2. Fuel Handling and Inspection Including Defueling Operations
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify that fuel
movement and handling was being conducted as required by Technical
Specifications (TS) Section 5.1.1 and Section 11:
Current Core Configuration Map
Current Fuel Element Storage Location Map
Fuel handling equipment and reactor instrumentation
Selected Operational Log Sheets for the past three months
Core Configuration Map for the period prior to December 2011
Fuel Element Storage Location Map prior to December 2012
Various current records and data sheets related to fuel movement
Reactor Safeguards Committee (RSC) meeting minutes for 2011 and to
date in 2012
Fuel movement and examination records including video of fuel
inspection
Listing of the Stuck Fuel Elements and Graphite Elements including a
description of each
Section IV of the ARRR Procedures Manual entitled, Critical Assembly
and Power Calibration, PCN No. 6, RSC approval dated November 2,
2005, with the latest Temporary Change (PCN No. 6A) dated
December 12, 2011
Aerotest Operations (AO) RWI No. AO RWI 101, Aerotest - Canister
Handling, Loading, Drying, and Conditioning, Rev. 0, dated June 25,
2012
RWI No. AO RWI 102, Aerotest - Fuel Handling Procedure, Rev. 0,
dated June 25, 2012
RWI No. AO RWI 103, Aerotest - Fuel Inspection Procedure, Rev. 0,
dated June 25, 2012
RWI No. AO RWI 104, Aerotest - Instrumented Fuel Element Cropping
Procedure, Rev. 0, dated June 26, 2012
RWI No. AO RWI 105, Aerotest - Upper Grid Plate Relocation, Rev. 0,
dated June 26, 2012
Project Plan, Aerotest Operations Fuel Removal, Inspection, and
Canning, Document (Doc.) No. Aero-PP-01, Rev. 0, dated June 25, 2012
In addition, the inspector observed the planning, discussions, and actions of the
licensee and contractor personnel during removal of the stuck fuel and graphite
elements from the core.
-3-
b. Observations and Findings
(1) Plan for Removing the Remaining Elements from the Core
As indicated above, a project plan was developed by the contractor which
provided guidance and instructions on the process to be used for
removing the elements that remained in the core. Procedures had been
developed outlining the various steps that were involved. The inspector
verified that the plan and procedures had been reviewed and approved by
the RSC before the work started.
The project plan included various steps in order to remove the stuck fuel
and graphite elements from the core and accomplish complete defueling
of the core. The plan included the following work evolutions:
a) Assembling of the extension tools necessary for the job of working
in the reactor pool including an articulating grapple arm on the end
of a pole, a tool to rotate the elements in the inspection stand, and
a canister holding tool that could be fastened on the end of a pole.
(It was noted that eight storage canisters with special lids
containing drain and vent ports and a pintal on top, with which to
grapple onto the canister using a fuel handling tool, were also
fabricated, leak tested, and shipped to the facility to be used to
contain the cracked elements.)
b) Placing the newly constructed inspection stand and canister
storage rack in the pool.
c) Raising the upper grid plate to allow removal of the elements from
underneath using the articulating grapple tool.
d) Removing all the fuel and graphite elements that were previously
stuck and could not be removed out through the top of the grid
plate.
e) Cutting the wires and top tube off (or cropping) the two
instrumented fuel elements (IFEs) so that they could be placed in
a storage location and so the one that was damaged could be
placed in a storage canister.
f) Inspecting all the fuel elements including the ones that were not
damaged or stuck.
g) Placing the damaged elements in storage canisters (or canning
the elements).
(2) Plan of the Day and Problem Resolution
Prior to starting work each day, the licensee and contractor personnel met
-4-
and discussed in detail what would be attempted during that days
activities. Safety precautions and the applicable procedure(s) were
reviewed. Everyone was allowed the opportunity to voice any concerns
they might have and the course of action for the day was agreed upon.
Although various setbacks and problems arose during the project,
everyones input was considered before proceeding. After a consensus
was reached, the project work began again.
At one point, following the problem with an upper grid plate bolt shearing,
a conference call was held with the licensee staff, the contractor
personnel, and the Chair of the RSC. After the problem and possible
course of action was explained, the RSC Chair requested that certain
measures be taken and the next course of action was discussed and
agreed upon.
(3) Removal of the Remaining Fuel Elements
As noted above, various problems occurred during the project. In an
effort to raise the upper grid plate, three of the four bolts holding the plate
in place sheared off as they were being removed (the fourth bolt was
loosened without incident). When licensee and contractor personnel tried
to raise upper grid plate, it became bound. It was thought that the Control
Rod Guide Tubes (CRGTs) were potentially causing the grid plate to bind
so the licensee attempted to remove the three CRTGs. That effort proved
unsuccessful and the focus of attention turned again on other methods to
move the upper grid plate. Eventually, after mechanical agitation, it was
raised about one inch. The IFE cropping operation required extra effort
but the top tube and wires were successfully removed.
Once the various obstacles to removal of the elements were overcome,
the fuel removal proceeded with the elements being lifted slightly with the
articulating grapple tool, tipped slightly and worked out from under the
grid plate through an opening in the core support structure. All the fuel
and graphite elements were eventually removed and the core was
completely defueled without further problems. The elements were
removed as stipulated by RWIs.
(4) Fuel Inspection
As noted previously, the inspection stand was placed in the pool to
facilitate element inspection. Fuel element inspection was accomplished
by placing each element in the inspection stand and, using an underwater
camera, observing the length of the element. The element was then
rotated one quarter turn and the length was again observed. Those that
were noted to be cracked were designated to be placed in a canister for
canning. All the observations of the fuel elements were documented
and videotaped so that a closer examination could be conducted at a later
time if necessary. The inspections were completed in accordance with
the appropriate RWI.
-5-
After the element inspection was complete, the licensee found that there
were 21 Al clad fuel elements which exhibited some type of cracks - most
had longitudinal crack but at least two had circumferential cracks toward
the upper portion of the elements. One other fuel element appeared to
have the beginning of a crack. No cracks were noted in any of the SS
clad elements. The licensee made the decision to place all the cracked
elements in canisters for storage.
Because the licensee originally knew of four cracked elements and it was
anticipated that there would only be a few others found, the licensee
directed the contractor to manufacture eight canisters (one other was
manufactured as a test canister). A storage rack with 12 positions was
also designed and fabricated to hold the canisters. In light of the fact that
21 cracked elements were found, the licensee ordered more canisters
and a larger storage rack. These will not be ready for at least five weeks.
Also, the licensee made the decision to have the contractor personnel
assist in placing all the cracked elements in canisters. However, due to
other commitments, the contractor personnel will not be able to return to
Aerotest until October 2012. It was agreed that leaving the cracked fuel
elements in storage racks until October would not pose any greater risk
than having them in the core (as they had been in the past). The licensee
was informed that the issue of ensuring that all the cracked fuel elements
were placed in canisters would be followed by the NRC as an Inspector
Follow-up Item (IFI) and will be reviewed during a future inspection (IFI
50-228/2012-204-01).
(5) Placing Cracked Element in Canisters
One portion of the inspection stand contained a position where a canister
could be placed. The method that the licensee planned to use for placing
an element in a canister consisted of the following steps. After the
inspection of a damaged element was completed, it would be placed in
the canister (which had been positioned in the rack) so that the
configuration control of the element would be maintained (i.e., all of the
element would be contained inside the canister even if the element were
to fall apart). The canister would then be brought to the surface of the
pool and the lid attached. The canister would then be drained/dewatered
using compressed helium gas and a vacuum drawn on the canister.
Finally, the canister would be backfilled with helium gas to complete the
operation. During the inspection two cracked elements were successfully
placed in canisters using the above steps.
(6) Maintaining Control of the Elements and Records
The inspector reviewed the records being maintained for the defueling
operation and fuel transfers. The appropriate records were being filled
out by one person designed as the recorder as required. It was noted
that positive control was maintained over the fuel and graphite element
-6-
transfers. During this inspection, the inspector verified that the fuel
movements were conducted in compliance with procedure and pre-
planned fuel moves. It was noted that the licensee was documenting the
various movements that had been completed and maintaining the
required records.
During the inspection it was also noted that the serial numbers on many
of the older AL clad elements could not be read. It appeared that some of
the numbers may have been obliterated over the years by the use of the
fuel handling tool. The licensee indicated that they did not necessarily
track or visually identify the fuel elements by serial number but typically
by the position in the core or storage rack. This location tracking
method had been used for years to identify and verify the elements.
Because this method of fuel and serial number verification appeared to be
somewhat less rigorous than usual, the licensee was informed that the
issue of fuel verification would be considered by the NRC as an
Unresolved Item (URI) and would be reviewed during a future inspection
(URI 50-228/2012-204-02).
(7) TS Section 11 - Fuel Storage and Transfer
TS Section 11 required that the licensee store fuel in specific locations
and transfer fuel only under certain conditions.
Through direct observation the inspector verified that the licensee was not
storing fuel in the floor of the Reactor Room although such storage was
allowed. All fuel was stored in a locked vault or in the reactor pool/tank.
Not more than one fuel element was allowed in the facility which was not
in storage or in the core lattice.
c. Conclusion
Fuel movements and inspections and defueling operations were completed and
documented in accordance with the requirements specified by standard
procedure and by the Reactor Work Instructions that had been developed for the
defueling project. Twenty-one Al clad elements were found with cracked
cladding. One URI was noted concerning fuel element serial number verification.
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 Sections 6.2, 7.0, and 12.1.2:
- Special Work Permits (SWPs) - Numbers 2012-01 through
2012-03
-7-
- Radiological signs and posting at the entrances to controlled or restricted
areas
- Calibration records for portable monitoring instruments provided by the
contractor
- Training provided to the contractor personnel and NRC inspector
- Radiation protection surveillance and survey data for the defueling project
recorded on:
- Instrument Calibration forms
- Air Filter Paper Counting Sheet forms
- Aerotest Operations, Inc. Monthly Radiation Survey forms
- Aerotest Operations, Inc. Quarterly Maintenance Check List forms
- Section VI of the ARRR Procedures Manual entitled, Radiological Safety
Procedures, PCN No. 3, RSC approval dated April 29, 1996
- Section VIII of the ARRR Procedures Manual entitled, Maintenance
Procedures, PCN No. 2, RSC approval dated January 14, 1993
- ALARA 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 and conducted radiation surveys of various
items and during various work evolutions using an NRC survey meter.
b. Observations and Findings
(1) Surveys
Radiation and contamination survey results indicated that defueling
project activities were being conducted in accordance with applicable
procedures. The results of the surveys were documented on the
applicable forms and were evaluated as required. No surveys showed
any contamination above established limits.
During the inspection the inspector conducted radiation surveys during
work evolutions. The radiation levels noted by the inspector, using an
NRC survey meter, were similar to those detected by the licensee. No
anomalies were noted.
The inspector noted that licensee and contractor personnel were using
the appropriate monitoring equipment during and following the various
work evolutions. Everyone monitored after handling any equipment or
items that might have been contaminated.
(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 the hazards involving radiation, high radiation, and
contamination and were posted as required by 10 CFR Part 20,
-8-
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 just outside the Control
Room. Other postings also characterized the industrial hygiene hazards
that were present in the areas as well. The inspector noted that the
copies of NRC Form-3, Notice to Employees, posted at the facility as
required by 10 CFR Part 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 issued also
contractor personnel dosimeters and finger rings to be used for the job
and issued pocket ion chambers each day to track daily exposure.
(4) Radiation Monitoring Equipment
During a previous inspection in June 2012, the inspector determined that
licensee survey meters had the acceptable up-to-date calibration sticker
attached. The inspector noted that the calibration of portable instruments
was being verified quarterly as required by procedure. Calibration of
survey meters and equipment supplied by the contractor was also
reviewed. Those instruments were found to be properly calibrated as
required.
(5) Training
The inspector observed the training given to the contractor personnel.
Those individuals were acceptably trained in radiation protection
practices. The inspector also received training concerning the Special
Work Permit issued for the defueling project.
(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.
-9-
(8) Facility Tours
The inspector toured the facility on various occasions and observed
activities in offices, support areas, the Reactor Bay, and the mezzanine
area. 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.
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 was being maintained and calibrated as
required; and, 5) radiation protection training was being conducted for contractor
personnel as required.
4. Conformance to Security Plan Requirements
a. Inspection Scope (IPs 81401, 81402, 81431, 81810)
The inspector reviewed the following to verify compliance with Section 3.2 of the
TS and with the licensees NRC-approved Physical Security Plan (PSP) entitled,
Aerotest Radiography and Research Reactor Security Plan, last revised
January 7, 2005:
- Access controls currently in effect
- Monthly Alarm Check List 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 entitled, General Emergency
Procedures, Permanent Change Notice (PCN) Number (No.) 4, RSC
approval dated January 28, 2005
- Section V of the ARRR Procedures Manual entitled, Security
Procedures, PCN No. 3, RSC approval dated February 11, 2005
b. Observations and Findings
The inspector conducted an inspection of the Security Plan and response in June
2012 (refer to NRC Inspection Report No. 50-228/2012-203). During that
inspection the inspector verified that the licensee was maintaining adequate
security and control over the facility. As noted during the June 2012 inspection,
- 10 -
the PSP in use by the licensee was the same as the version approved by the
NRC. That version was dated January 7, 2005, and had last been reviewed on
May 16, 2011. The PSP was being reviewed biennially as required and annual
security training was completed as stipulated by the PSP. Implementing
procedures were consistent with the PSP.
During this inspection the inspector verified that the physical protection system,
consisting of barriers, alarms, equipment, and instrumentation, remained in place
and was as stipulated in the PSP. The system was being maintained and tested
periodically as required by procedure. Access controls were implemented as
required and keys to the various facility doors were controlled and held only by
designated personnel. It was noted that the licensee had verified that the
background investigations and clearances of the contractor personnel were
current.
c. Conclusion
Security facilities, equipment, training, and procedures satisfied PSP
requirements.
5. Design Change Functions
a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the design change functions
outlined in TS Section 12.1.3 were completed:
- RSC meeting minutes for July 11, 2012
- Section I of the ARRR Procedures Manual entitled, Administrative
Procedures, PCN No. 2, RSC approval dated June 28, 1990
b. Observations and Findings
The inspector verified that the licensee was aware that changes or modifications
to the facility were required to be analyzed by the staff and the results of the
analyses presented to the RSC. Following a review, the RSC would then
approve them if the changes or modifications were determined to be acceptable.
If necessary the change would be submitted to the NRC for review and approval.
As noted in Paragraph 2 above, one off 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. The
contractor personnel 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
- 11 -
support structure. Because this would be a change to the current structure, the
licensee would need to perform a 10 CFR 50.59 evaluation and review of the
proposed new attachment mechanism. The licensee was informed that the issue
of reviewing any changes made will be considered an IFI and will be reviewed
during a future inspection (IFI 50-228/2012-204-03).
c. Conclusion
Audits and reviews were being conducted acceptably by the RSC in accordance
with the requirements specified in the TS. No changes had been made at the
facility since the last inspection but the process remained in place such that
changes or modifications would be reviewed and approved by the RSC as
required.
6. Exit Interview
The inspection scope and results were summarized on July 23, 2012, 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.
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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 (STS)
B. Williams President, Secured Transportation Services (STS)
INSPECTION PROCEDURES USED
IP 69001 Class II Non-Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-228/2012-204-01 IFI Review the licensees actions to ensure that all the cracked fuel
elements are placed in canisters.
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.
Closed
None
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PARTIAL LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
ADAMS Agencywide Documents Access and Management System
Al Aluminum
ARRR Aerotest Radiography and Research Reactor
CRGT Control Rod Guide Tube
IFI Inspector Follow-up Item
IP Inspection Procedure
kW kilowatt
No. Number
NRC U.S. Nuclear Regulatory Commission
PCN Procedure Change Notice
PSP Physical Security Plan
RSC Reactor Safeguards Committee
RWI Reactor Work Instruction
SS Stainless steel
SWP Special Work Permit
TS Technical Specification
URI Unresolved Item