ML20049A040

ML20017A278; Audit Report December 11, 2019 Regarding the License Amendment for a Possession-Only Facility License

ML20049A040
Person / Time
Site:	Aerotest
Issue date:	02/12/2020
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20049A040 (2)

Text

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.. i AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

• SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 February 12, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 License No. R-98/Docket: 50-228; ML20017A278; Audit Report December 11, 2019 Regarding the License Amendment for a Possession-Only Facility License Ladies and Gentlemen While we are in general agreement with the audit report issued February 3, 2020 for the audit conducted on December 11, 2019, there are some concerns.

Response to Audit Activities item I .Entrance Meeting. "gaining a better understanding of the storage locations of the NRC title 10 ... Part 50" ... .licensed materials. We feel the NRC should have had a good understanding of where the licensed materials were stored as Craig Basset from the NRC was on-site when the fuel elements were being evaluated and stored. The fuel elements locations have not changed position for more than 6 (routine/nonroutine) NRC inspections. In addition, a NRC security inspection (June 13 to 14, 2012) provided the SNM locations and reviewed the security elements/barriers.

Response to Audit Activities item 4.1. "The NRC staff plans to further evaluate these containers." The NRC auditors did not discuss any concerns with fuel storage canisters during the audit; If they had, we could have shown them the detailed NRC and AO generated documents that describe the canister design, canning process, and surveillances. We believe the NRC has reviewed, audited and evaluated the crack fuel elements, the cans, the canning operation, and the storage of the fuel elements. We also believe we've met the NRC requirements on these elements and are following the safe storage and monitoring of these fuel elements. The following are a partial list of documents that support our understanding.

A. Craig Basset was onsite December 10 to 13, 2012 to review and observation of the fuel handling and containerization of the fuel elements ML12361A147 NRC Non-Routine Inspection Report NO 50-228-2012-206.

B. Reactor Safeguards Committee Meeting on July 11, 2012. (Special meeting on Fuel Elements)

C. STS Fuel work binder with technical plans, 50.59 review, and procedures.

D. Craig Bassett and Gregory T Bowman were onsite September 10 to 12, 2012 to review of fuel handing and inspection program and viewed DVD videos documentation of the entire inventory of fuel elements. ML12264AOOO Non-Routine Inspection Report NO 50-228-2012-205.

E. Craig Basset was onsite July 16-23, 2012, 2012 to review and observe the stuck fuel elements being removed from our core by our contractor STS and then placed in canisters and in storage rack. ML12213A001 Non-Routine Inspection Report NO 50-228-2012-204.

F. Emails between Aerotest and the following employees at the NRC through 2012.

Craig Bassett, Al Adams, Patrick Isaac, Spyros Traiforos and Johnny Eads.

I declare under penalty of perjury that the statements above are correct and truthful. Should you have any questions or require any additional information regarding this submission, please contact AO President and Reactor Administrator David M. Slaughter, PhD at (80) 631-5919 or dmsraven@gmail.com David M Slaughter, PhD President, Reactor Administrator, General Manager and Manager Aerotest Operations, Inc.