ML14351A262
| ML14351A262 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 12/19/2014 |
| From: | Kevin Hsueh Division of Policy and Rulemaking |
| To: | Warren S Aerotest |
| C Bassett | |
| References | |
| IR 2014201 | |
| Download: ML14351A262 (13) | |
See also: IR 05000228/2014201
Text
December 19, 2014
Ms. Sandra Warren, General Manager
Aerotest Operations, Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT: AEROTEST OPERATIONS, INC. - NRC ROUTINE INSPECTION REPORT
NO. 50-228/2014-201 AND NOTICE OF VIOLATION
Dear Ms. Warren:
On November 17-19, 2014, the U.S. Nuclear Regulatory Commission (NRC, the Commission)
completed an inspection at the Aerotest Radiography and Research Reactor facility (Inspection
Report No. 50-228/2014-201). The enclosed report documents the inspection results which
were discussed on November 19, 2014, with you and Mr. Alfredo Meren, Manager of Reactor
Operations.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, the NRC has determined that a Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in
the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in
detail in the subject inspection report. The violation is being cited in the Notice because it
constitutes a failure to meet regulatory requirements that has more than minor safety
significance and the violation was identified by the NRC.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
S. Warren -2-
In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRCs
Agency Rules of Practice and Procedure, 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. To the extent possible, your response should not
include any personal privacy or proprietary information so that it can be made available to the
public without redaction.
Should you have any questions concerning this inspection, please contact Mr. Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Kevin Hsueh, 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
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-228/2014-201
cc: See next page
Aerotest Operations, Inc. Docket No. 50-228
cc:
Mr. Michael Anderson, President
Aerotest Operations, Inc.
Autoliv ASP, Inc.
1320 Pacific Drive
Auburn Hills, MI 48326
Mr. Alfredo Meren, Manager of Reactor Operations
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
S. Warren -2-
In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRCs
Agency Rules of Practice and Procedure, 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. To the extent possible, your response should not
include any personal privacy or proprietary information so that it can be made available to the
public without redaction.
Should you have any questions concerning this inspection, please contact Mr. Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Kevin Hsueh, 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
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-228/2014-201
cc: See next page
DISTRIBUTION:
PUBLIC PROB r/f RidsNrrDprPrta Resource
RidsNrrDprPrtb Resource CBassett, NRR STraiforos, NRR
ACCESSION NO.: ML14351A262 *concurred via e-mail NRC-002
OFFICE NRR/DPR/PROB* NRR/DPR/PROB
NAME CBassett KHsueh
DATE 12/18/2014 12/19/2014
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
Aerotest Operations, Inc. Docket No. 50-228
Aerotest Radiography and Research Reactor License No. R-98
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted on
November 17-19, 2014, a violation of NRC requirements was identified. In accordance with the
NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations Part 55.21, Medical Examination, states that a
licensee shall have a medical examination by a physician every two years.
Contrary to the above, a Senior Reactor Operator at the Aerotest Radiography and Research
Reactor facility had a medical examination on November 12, 2010, but did not have another
medical examination until September 18, 2013, a period greater than two years and a period
greater than 30 months which includes a grace period of 6 months typically allowed for licensed
operators at Research and Test Reactor facilities.
This has been determined to be a Severity Level IV violation (Section 6.4.d.1(c)).
Pursuant to the provisions of 10 CFR 2.201, Aerotest Operations, Inc. is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555-0001 with a copy to the responsible
inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should
include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or
severity level, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response,
with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records component of the NRCs
Agencywide Documents Access and Management System (ADAMS), to the extent possible, it
should not include any personal privacy, proprietary, or safeguards information so that it can be
made available to the public without redaction. ADAMS is accessible from the NRC Web site at
(the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal
privacy or proprietary information is necessary to provide an acceptable response, then please
provide a bracketed copy of your response that identifies the information that should be
protected and a redacted copy of your response that deletes such information. If you request
Enclosure 1
-2-
withholding of such material, you must specifically identify the portions of your response that
you seek to have withheld and provide in detail the bases for your claim of withholding
(e.g., explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 19th day of December, 2014
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-228
License No: R-98
Report No: 50-228/2014-201
Licensee: Aerotest Operations, Inc.
Facility: Aerotest Radiography and Research Reactor
Location: 3455 Fostoria Way
San Ramon, CA 94583
Dates: November 17-19, 2014
Inspector: Craig Bassett
Accompanied by: Kevin Hsueh, Chief
Research and Test Reactors Oversight Branch
William Schuster, Project Manager
Research and Test Reactors Oversight Branch
Approved by: Kevin Hsueh, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Enclosure 2
EXECUTIVE SUMMARY
Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor
Report No: 50-228/2014-201
The primary focus of this routine, announced inspection was the on-site review of selected
aspects of the Aerotest Operations, Inc. (the licensees) Class II research and test reactor safety
program including: 1) organization and staffing, 2) review and audit and design change
functions, 3) facility operations, 4) procedures, 5) operator requalification, 6) maintenance and
surveillance, 7) fuel handling, and 8) experiments since the last U.S. Nuclear Regulatory
Commission (NRC) inspection of these areas.
Organization and Staffing
The licensee's organization and staffing were in compliance with the requirements
specified in Section 12 of the facility Technical Specifications.
Review and Audit and Design Change Functions
Review and oversight functions required by Technical Specifications Section 12.1.3 were
acceptably completed by the Reactor Safeguards Committee.
No changes had been made at the facility since the last NRC inspection but a process
for design change was in place and would be followed if changes were initiated.
Reactor Operations
Reactor operations had ceased in 2010.
Procedures
Facility procedures were being reviewed by the licensee and reviewed and approved by
the Reactor Safeguards Committee as required by Technical Specifications and
administrative procedures.
Operator Requalification
Operator requalification was being conducted and completed as required by the
Operator Requalification Program.
One violation was noted for failure to have an operator with an active license complete a
medical examination biennially as required.
-2-
Maintenance and Surveillance
Maintenance was being completed in accordance with Technical Specifications and
procedural requirements.
The program for completing surveillance checks, tests, verifications, and calibrations
was being implemented in accordance with Technical Specifications requirements.
Fuel Handling
Following a fuel inspection in 2013, the total number of fuel elements with cracked or
damaged cladding has been determined.
Fuel movements and weighing of those elements in canisters were completed and
documented in accordance with the requirements specified by procedure.
Experiments
No experiments or irradiations have been conducted since October 15, 2010.
REPORT DETAILS
Summary of Facility Status
Aerotest Operations, Inc. (Aerotest, the licensee) 250 kilowatt (kW) TRIGA conversion research
reactor, known as the Aerotest Radiography and Research Reactor (ARRR), had been operated
in the past in support of neutron radiography experiments and reactor operator training.
However, the licensee had voluntarily ceased to operate the research reactor on October 15,
2010, because of foreign ownership issues. During this inspection, the reactor remained shut
down and was not operated.
1. Organization 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 Technical Specifications (TS) Sections
10.1 and 12.1 were being met:
Current staffing of the ARRR
Management responsibilities and organizational structure indicated in
Section 12 of the TS, as implemented through the latest revision to the
Facility License Number (No.) 98, Amendment No. 4, dated January 28,
1981
Section II of the ARRR Procedures Manual entitled, Operating
Procedures, Procedure Change Notice (PCN) No. 2, RSC approval
dated June 28, 1990
Annual Summary of Changes, Tests, and Experiments at Aerotest
Radiography and Research Reactor (ARRR) for the period from July 1,
2012, to June 30, 2013, issued July 30, 2013, and for the period from
July 1, 2013, to June 30, 2014, issued July 8, 2014 (the facility annual
reports)
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 conducted in December 2012 (NRC Inspection Report
No. 50-228/2012-206). The inspector noted that the General Manager remained
the local official in charge of day-to-day activities at the facility. The Reactor
Supervisor (who was also assigned the duties of the Reactor Operations
Manager) retained direct control over, and overall responsibility for, 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 the staffing at the facility had been cut in 2010 due to issues
involving foreign ownership. The current staffing at the ARRR consisted of the
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General Manager (who was also the Security Officer, the Radiation Safety
Officer, and a Senior Reactor Operator), the Reactor Supervisor (who was also
the Manager of Reactor Operations and a Senior Reactor Operator), a Nuclear
Engineer (who was also a Senior Reactor Operator), the Manager of Nuclear
Radiography, and the Manager of Quality Assurance. The employees were
monitoring the facility and conducting maintenance and surveillance duties as
required by the TS.
c. Conclusion
The licensee's organization was as specified in the TS. The employees were
monitoring the facility and conducting maintenance and surveillance duties as
required by the TS.
2. Review and Audit and Design Change Functions
a. Inspection Scope (IP 69001)
In order to ensure that the audits and reviews were being completed as required
by TS Section 12.1.3 and to verify that any modifications to the facility were
consistent with 10 CFR 50.59, the inspector reviewed the following:
Completed audits for 2013 and 2014
Changes made under the licensees 10 CFR 50.59 change process
Reactor Safeguards Committee meeting minutes for 2013 and 2014
Duties of the Reactor Safeguards Committee detailed in TS Section 12
Charter of the Reactor Safeguards Committee outlined in Section I of the
ARRR Procedures Manual entitled, Administrative Procedures, PCN
No. 2, RSC approval dated June 28, 1990
The last two ARRR annual reports
b. Observations and Findings
(1) Review and Audits Functions
The Reactor Safeguards Committee (RSC) met at least once per year in
accordance with TS requirements with the last two meetings held on
November 19, 2013, and on November 5, 2014. The inspector reviewed
the RSC's meeting minutes for these meetings. The meeting minutes
showed that the RSC had considered the types of topics stipulated by the
TS. It was noted that the meetings were attended by all members of the
committee. Review of the minutes also indicated that the committee
provided guidance and direction to ensure suitable oversight of the
facility.
The inspector verified that the periodic audits specified by TS Section
12.1.3 were being completed as required. The RSC minutes and audit
records indicated that the Chair of the RSC and generally another RSC
-3-
member conducted unannounced audits of facility operations annually
and submitted the results to the President, Aerotest Operations, Inc. The
inspector noted that current issues and the facility status were reviewed
and that the licensee took appropriate corrective actions in response to
those audit findings or recommendations as needed.
(2) Design Change Functions
Through review of applicable records and interviews with licensee
personnel, the inspector determined that some design changes had been
considered at the facility but that none had actually been initiated or
completed since the last NRC inspection. It was noted that TS and
procedural requirements were in place to ensure that changes, if
proposed, would be reviewed by the RSC and in accordance with 10 CFR
50.59 as required.
c. Conclusion
Review and oversight functions required by TS Section 12.1.3 were acceptably
completed by the RSC. No changes had been made at the facility since the last
NRC inspection but a process for design change was in place and would be
followed if changes were initiated.
3. Operations
a. Inspection Scope (IP 69001)
The inspector reviewed selected portions and/or aspects of the following to
ensure compliance with TS Sections 10 and 12:
ARRR Operational Log Sheets and ARRR Startup/Shutdown Sheets for
2013 and to date in 2014
Section II of the ARRR Procedures Manual entitled, Operating
Procedures, PCN No. 2, RSC approval dated June 28, 1990
The last two ARRR annual reports
b. Observations and Findings
The inspector reviewed ARRR Startup/Shutdown Sheets and Operational Log
Sheets for reactor-related checks and activities dating from January 2013
through October 2014. Since October 2010, the reactor had not been operated
but Startup/Shutdown Sheets and Operational Log Sheets had been filled out to
document the completion of various activities including quarterly maintenance,
control rod inspection, fuel handling, and other checks and calibrations.
The operating logs appeared to be complete and provided an acceptable
indication of facility activities. The Annual Summaries of Changes, Tests, and
-4-
Experiments (the licensees annual reports to the NRC) documented the fact that
no operations had occurred during the past two years.
c. Conclusions
Reactor operations had ceased in 2010. The operating logs appeared to be
complete and provided an acceptable indication of facility activities.
4. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the requirements of TS
Section 12.2 were being met concerning written procedures:
Varioius ARRR procedures
Procedure Approval Sheets
Procedure Change Notice forms
ARRR procedure review sign-off forms
Section I of the ARRR Procedures Manual entitled, Administrative
Procedures, which detailed the process used to review, revise, and
approve all facility procedures
b. Observations and Findings
The inspector noted that procedures had been developed for reactor operations
and safety as required by the TS. The licensees procedures were found to be
acceptable even though no operations were currently in progress. The inspector
noted that the administrative procedure specified the responsibilities of the RSC.
The inspector verified that a designated member of the RSC had completed
biennial reviews of the facility procedures as required. It was noted that the last
review of all procedures had occurred on May 15, 2013. The licensee verified
that any substantive revisions to procedures would be presented to the RSC for
review and approval as required by TS.
c. Conclusion
Facility procedures satisfied TS and administrative procedure requirements
which included being reviewed by the licensee and reviewed and approved by
the RSC.
5. Operator Requalification Program
a. Inspection Scope (IP 69001)
To verify compliance with the Operator Requalification Program for the ARRR,
which was submitted to the NRC on July 13, 2000, the inspector reviewed:
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Status of all qualified operators licenses
Operator physical examination records for 2012 and 2014
Selected ARRR Operational Log Sheets documenting reactivity
manipulations for 2013 and 2014
SRO Licensed Activities Log documenting active operator supervisory
and related functions for 2013 and 2014
2014 Senior Reactor Operator Biennial Written Examinations and related
records
2013 and 2014 Senior Reactor Operator Annual Operating test results
and related records
b. Observations and Findings
(1) Active Duty Status
There were three people who maintained an SRO license at the facility.
The inspector verified that the SROs licenses were current. It was noted
that the paperwork for one individual had been submitted in a timely
manner for a license renewal. Records showed that operators were given
biennial requalification examinations and annual operations tests as
required. Logs indicated that operators maintained active duty status as
required by performing the required maintenance and inspections of
reactor components or by completing supervisory and related licensed
operator duties. The Operator Requalification Program was being
maintained up to date. The inspector also verified that the operators were
reviewing the contents of all abnormal and emergency procedures on a
regularly scheduled basis as indicated by a sign off sheet located in the
emergency procedures folder.
(2) Medical Examinations
10 CFR Part 55.21 states that a licensee shall have a medical
examination by a physician every two years.
The inspector examined medical records to verify that each operator had
received a biennial physical examination as required. It was noted that
two of the Senior Reactor Operators had received a medical examination
every two years as required by 10 CFR 55.21. The third SRO had had an
examination on November 12, 2010, but had not had another examination
until September 18, 2013.
The inspector noted that the third SRO and the other two SROs had been
actively engaged in completing maintenance and surveillance activities
associated with the reactor, conducting periodic security tests, and
performing SRO-related functions such as supervising others during the
entire period from November 2010 through September 2013. This
included the period from May 2013 to September 2013 which was the
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time period in excess of the 30 months allowed for Research and Test
Reactor (RTR) operators to receive a medical examination.
The licensee was informed that failure to have an operator with an active
license complete a medical examination every two years and within the
30 month time period normally allowed for RTR operator licensees was a
violation of 10 CFR 55.21 (VIO 50-228/2014-201-01).
c. Conclusion
Operator requalification was being conducted and completed as required by the
Operator Requalification Program. One violation was noted for failure to have an
operator with an active license complete a medical examination biennially as
required.
6. Maintenance and Surveillance
a. Inspection Scope (IP 69001)
To determine that maintenance and surveillance activities were being completed
as required by TS Sections 3, 4, 5, 6, and 7, the inspector reviewed:
ARRR Repair Folders for various instruments
Operations Request Forms for 2013 and to date in 2014 which document
the completion of inspections, fuel movement, and instrument repair and
calibration
Monthly Alarm Check Lists for 2013 and to date in 2014
ARRR Pool Water Analysis sheets for 2013 and to date in 2014
Quarterly Maintenance Check Lists for 2013 and to date in 2014
Selected ARRR Startup/Shutdown Sheets for 2013 and to date in 2014
Section VIII of the ARRR Procedures Manual entitled, Maintenance
Procedures, PCN No. 2, RSC approval dated January 14, 1993
b. Observations and Findings
(1) Maintenance
The various Repair Folders and Operations Request Forms maintained
by the licensee indicated that emergent problems were addressed by
appropriate corrective maintenance as needed. If electrical components
for the nuclear instrumentation were replaced, the maintenance protocol
stipulated that calibrations and voltage checks occur prior to the
instrumentation being placed back into service. The inspector verified
that these tests were completed as required. Records showed that
routine maintenance activities were conducted at the required frequency
and in accordance with the TS and/or the applicable procedure.
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(2) Surveillance
After suspending reactor operations in October 2010, the licensee
continued to complete various monthly, quarterly, semiannual, and annual
checks, tests, and calibrations as required. It was noted that the licensee
had developed a modified checklist to ensure that appropriate oversight
was maintained over various other items. These included such items as
pool water temperature, air filter changeout, water conductivity, and cycling
the pumps. These items were checked on a daily or weekly basis even
though this was not required because the reactor was shut down and not
operating.
c. Conclusion
Maintenance was being completed in accordance with TS and procedural
requirements. The modified program for surveillance checks, tests, verifications,
and calibrations was being implemented in accordance with TS requirements that
were still applicable with the reactor shutdown.
7. Fuel Handling
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 TS Section 5.1.1
and Section 11:
Revised Fuel Weighing Procedure
Fuel movement and examination records
Fuel handling equipment and reactor instrumentation
Various records and data sheets related to fuel movement
Selected ARRR Operational Log Sheets for 2013 and 2014
Data Sheets for Fuel and Graphite Transfer forms for 2013 and 2014
Letter from NRC to Licensee, Aerotest Radiography and Research
Reactor (ARRR) Fuel Examination, letter dated July 29, 1992
Section IV of the ARRR Procedures Manual entitled, Critical Assembly
and Power Calibration
b. Observations and Findings
(1) Fuel Elements With Damaged Cladding
The licensee has experienced various problems with their fuel. As
documented in IR Nos. 50-228/2012-201 through 50-228/2012-206, the
licensee took various measures to deal with the problems. These are
briefly described below.
-8-
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. 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.
The licensee subsequently made the decision to remove the stuck fuel
elements from the core and they hired a contractor to assist in the project.
A project plan was subsequently developed for removing all the elements
and submitted it to the licensee. 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 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. 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. Plans were made to have
contractor personnel return to the ARRR facility on December 10, 2012,
to complete the containerization process.
The NRC staff observed as each of the elements with damaged cladding
was placed into a canister and the canister was closed, dried, tested,
backfilled with a cover gas, and weighed. The canisters were then placed
into pre-designated locations in the new storage rack on the reactor pool
floor.
-9-
During a fuel inspection conducted in July 2013, the licensee found that 8
fuel element serial numbers from the July 2012 inspection had been
misidentified. Many of the serial numbers were very hard to read and
only with a different camera was the licensee able to correctly identify all
the proper numbers. The licensee also found two more elements with
cracks in the cladding. In addition, one element was found to have
bubbles leaking from the cladding. The bubbles were observed to stop
after just a few minutes. This brings the number of fuel elements with
cracked or damaged cladding to 25.
(2) Fuel Weighing Problems
During their fuel inspection earlier this year, the licensee attempted to
weigh the cans containing damaged fuel, for the purpose of comparing
2014 weights with 2012 weights. They planned to verify that none of the
fuel cans had allowed any water to enter the canisters, which would
allow the fuel elements inside to continue to corrode. Canisters that
were heavier than their 2012 weights would be assumed to have had
water leaked into them. After beginning the weighing process, the
licensee was unable to match the previous weights of the first four
canisters. Also, there were problems with the strain gage which showed
fluctuating weights if the canisters were moved even one inch. When
the licensee and the Chairman of the Reactor Safeguards Committee
reviewed the videotape of previous weighing operations, several points
of potential error in the weighing operation were noted, especially with
the depth of water over the weighed element. Therefore, it was noted
that buoyancy affected the weights observed. The licensee then halted
the weighing operation and re-worked the Reactor Work Instruction
(RWI) and included an appendix for the weighing procedure, which was
not previously described in the RWI. The new RWI required the entire
assembly to hang vertically in one line from the crane hook, instead of
being run through an I-bolt which added frictional forces, to ensure that
each weighing was done in the exact same manner. The licensee also
took care to make sure that the cans were all weighed at the same depth
of the pool, which was near the bottom so it was easily reproducible.
The licensee re-weighed all of the canisters during the week of
September 29, 2014. Using the new procedure, the weights were much
more uniform. The cropped instrumented fuel element (IFE) with the new
swage top was different than the other elements and weighed 8.1
pounds. All of the other 21 canisters weighed 7.7 pounds, +/- 0.1 pound.
The weighing data was sent via email to the RSC. After reviewing the
data, the RSC was satisfied that none of the cans had any water
intrusion.
- 10 -
The inspector reviewed the RWI and the weighing data. It appeared that
the procedure used to weigh the canisters was appropriate and that there
had been no water leakage into the canisters.
c. Conclusion
Following a fuel inspection in 2013, the total number of fuel elements with
cracked or damaged cladding has been determined to be 25. Fuel movements
and weighing of those elements in canisters were completed and documented in
accordance with the requirements specified by procedure.
8. Experiments
a. Inspection Scope (IP 69001)
To ensure that the requirements of TS Sections 8 and 9 were being met
concerning experimental programs, the inspector reviewed selected aspects
and/or portions of:
Aerotest Experiment Type Review forms (previously designated as
AGNIR Operation Request Forms) documenting experiments approved
by the RSC
Section VII of the ARRR Procedures Manual entitled, Experiment Review
and Approval, stipulating experimental program requirements
The last two ARRR annual reports
b. Observations and Findings
There were six basic types of experiments that had been approved to be
conducted at the ARRR facility. The one most commonly used was No. 114 -
neutron radiography performed in the radiography facilities. Based on records
review, observations of the facility, and radiation surveys, the inspector verified
that no experiments had been conducted since October 2010.
c. Conclusion
No experiments had been conducted since October 2010.
10. Follow-up on Previously Identified Item
a. Inspection Scope (IP 92701)
The inspector reviewed the licensee's actions taken in response to a previously
identified Inspector Follow-up Item.
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b. Observation and Findings
(1) Inspector Follow-up Item (IFI) - 50-228/2007-201-01 - Follow-up on the
completion of the Autoliv, Inc. divestiture and negation plans involving
Aerotest Operations, Inc.
During an inspection in 2007, the inspector discussed the issue of the
apparent indirect or ultimate transfer of the license. This had occurred
when the ownership of the Aerotest Radiography and Research Reactor
(ARRR) was transferred in substantial part to Autoliv, Inc., through an
indirect transfer. This issue had been under review by both the licensee
and the NRC for several years. During the inspection it was noted that
the pathway to a resolution had apparently been established. The
resolution of this issue never materialized and has been the subject of
continuing discussions between the licensee and the NRC.
The original issue concerning foreign ownership and divestiture is closed.
(2) IFI - 50-228/2010-201-01 - Follow-up on the licensees corrective actions
to instruct workers in the proper use of extremity dosimetry - finger rings.
During an inspection in 2010, an issue was noted concerning the
positioning of workers extremity monitoring devices, i.e., their finger
rings. Workers at the facility are issued ring dosimeters that are used
whenever they handle radioactive materials. The dosimeter is in the form
of a plastic ring containing one thermoluminescent chip enclosed in a
protective cover. The dosimeter is intended to be worn on the finger
closest to the source of the radiation, with the TLD chip facing the palm
side of the hand. Through Interviews with licensee personnel it was
noted that workers were wearing their ring dosimeter during work
activities, but that sometimes the dosimeter was worn on the thumb or
small finger because it would not fit properly on any of the other fingers.
The rings were also being worn with the TLD chip facing the back of the
hand. In this configuration, the dosimeter monitored the general area
radiation in the vicinity of the hand rather than the dose to the hand. The
licensee was cautioned that workers should be instructed to wear their
extremity monitors - finger rings properly in order to provide an accurate
assessment of the dose to the hands.
During this inspection it was noted that no work was being performed and
no extremity monitoring was needed or being used. This issue is
considered closed.
c. Conclusion
Two IFIs were reviewed and closed.
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14. Exit Meeting Summary
The inspector reviewed the inspection results with members of licensee management at
the conclusion of the inspection on November 19, 2014. The licensee acknowledged the
findings presented and did not identify as proprietary any of the material provided to or
reviewed by the inspector during the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
C. Bauman Nuclear Engineer and Senior Reactor Operator
F. 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
INSPECTION PROCEDURE USED
IP 69001 Class II Non-Power Reactors
IP 92701 Review of Previously Identified Items
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
50-228/2007-201-01 IFI Follow-up on the completion of the Autoliv, Inc. divestiture and
negation plans involving Aerotest Operations, Inc.
50-228/2010-201-01 IFI Follow-up on the licensees corrective actions to instruct workers
in the proper use of extremity dosimetry - finger rings.
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
AO Aerotest Operations, Inc.
ARRR Aerotest Radiography and Research Reactor
CFR Code of Federal Regulations
IFI Inspector Follow-up Item
kW kilowatt
LOA Letter of Agreement
N-Ray neutron radiography
NRC Nuclear Regulatory Commission
OEA OEA Aerospace, Inc.
ORF Operations Request Form
PCN Procedure Change Notice
RSC Reactor Safeguards Committee
SRO Senior Reactor Operator
SRV San Ramon Valley
TS Technical Specification