ML20240A252
| ML20240A252 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 10/15/2020 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Slaughter D Aerotest |
| Bassett C,NRR/DANU/UNPO,2405351842 | |
| References | |
| IR 2020201 | |
| Download: ML20240A252 (18) | |
See also: IR 05000228/2020201
Text
October 15, 2020
Dr. David M. Slaughter, President
Aerotest Operations Inc.
3455 Fostoria Way
San Ramon, CA 94583
SUBJECT:
AEROTEST OPERATIONS, INC. - U.S. NUCLEAR REGULATORY
COMMISSION ROUTINE INSPECTION REPORT NO. 05000228/2020201 AND
Dear Dr. Slaughter:
From August 10-12, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff completed an
inspection at your Aerotest Radiography and Research Reactor facility. The enclosed report
documents the inspection results, which were discussed with you on August 12, 2020.
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 various 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 NRCs Web site at
https://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 licensee failed to identify the violation.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRC
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
D. Slaughter
2
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 enclosures, and
your response will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of 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). 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 Craig Bassett at
(240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Travis L. Tate, Chief
Non-Power Production and Utilization
Facility Oversight Branch
Division of Advanced Reactors and Non-Power
Production and Utilization Facilities
Office of Nuclear Reactor Regulation
Docket No. 50-228
License No. R-98
Enclosures:
As stated
cc: w/enclosures:
California Energy Commission
1516 Ninth Street, MS-34
Sacramento, CA 95814
Radiologic Health Branch
P.O. Box 997414, MS 7610
Sacramento, CA 95899-7414
Test, Research and Training
Reactor Newsletter
Attention: Amber Johnson
Dept of Materials Science and Engineering
University of Maryland
4418 Stadium Drive
College Park, MD 20742-2115
concurrence *via e-mail
OFFICE
NRR/DANU/UNPO/I*
NRR/DANU/UNPO/LA*
NRR/DANU/UNPO/BC*
NAME
CBassett
NParker
TTate
DATE
8/28/2020
8/27/2020
10/15/2020
Enclosure 1
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 August 10-12,
2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement
Policy, the violation is listed below:
Aerotest Operations, Inc. Technical Specifications Section 12.1.5 require that [t]he Radiological
Safety Officer shall have a Bachelors degree in Biological or Physical Science and shall have a
minimum of 2 years experience in personnel and environmental radiation monitoring programs
at a nuclear facility. Certification as a Health Physicist by the Health Physics Society is
acceptable in lieu of the education and experience requirements given above.
Contrary to the above, from January 22, 2019, to the present, the licensee has not had a
Radiological Safety Officer who has a Bachelors degree in Biological or Physical Science or
who is a Certified Health Physicist. The individual appointed to the position does not have the
required educational background and is not a Certified Health Physicist.
This has been determined to be a Severity Level IV violation (Section 6.1).
Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201,
Notice of violation, 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, DC 20555-0001, 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, 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 a 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, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (Agencywide Documents Access
and Management System), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html, 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. 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.
2
If you request 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, Protection of Safeguards Information: Performance Requirements.
In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post
this Notice within two working days of receipt.
Dated this 15th day of 2020
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.
50-228
License No.
R-98
Report No.
Licensee:
Aerotest Operation, Inc.
Facility:
Aerotest Radiography and Research Reactor
Location:
San Ramon, CA
Dates:
August 10 - 12, 2020
Inspector:
Craig Bassett
Approved by:
Travis L. Tate, Chief
Non-Power Production and Utilization
Facility Oversight Branch
Division of Advanced Reactors and Non-Power
Production and Utilization Facilities
Office of Nuclear Reactor Regulation
- 2 -
EXECUTIVE SUMMARY
Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor
Inspection Report No. 05000228/2020201
The primary focus of this routine, announced inspection was the on-site review of selected
aspects of the Aerotest Operations, Inc. (Aerotest, licensee) Class III research and test reactor
safety program including: (1) staffing and audits, (2) operator requalification and active license
status, (3) radiological surveys, (4) surveillance, and (5) emergency preparedness, since the
last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff
determined the licensee's program was acceptably directed toward the protection of public
health and safety and in compliance with NRC requirements except in the area of staffing.
Staffing and Audits
Staffing was maintained as outlined in technical specifications (TS) Section 12.1 except for
the position of the Radiological Safety Officer as noted in paragraph 1.b(1)(b) below.
Audits were conducted by the Reactor Safeguards Committee (RSC) in accordance with TS
requirements in Section 12.1.3.
Operator Requalification and Active License Status
Requalification records were maintained at the facility as required even though there are no
longer any licensed reactor operators (ROs) or senior reactor operators (SROs) employed
there.
The licensee is seeking to establish a Certified Fuel Handler program at the facility in lieu of
having NRC-licensed ROs. A license amendment request for the Certified Fuel Handler
program is currently under NRC review.
Radiological Surveys
The licensee conducted surveys in accordance with regulatory requirements in Title 10 of
the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection against
Radiation, and the limits specified in TS Sections 6.2, 7.0, and 12.1.2.
Surveillance
Limited surveillance activity was completed in accordance with TSs and procedural
requirements.
The licensee completed emergency preparedness exercises and drills as required by the
The licensee has completed emergency preparedness training in accordance with E-Plan
commitments.
- 3 -
REPORT DETAILS
Summary of Facility Status
The Aerotest 250 kilowatt Training, Research, Isotopes, General Atomics [TRIGA] conversion
research reactor, known as the Aerotest Radiography and Research Reactor (ARRR), was
operated in the past in support of neutron radiography of various items and RO training. The
licensee voluntarily ceased to operate the research reactor in 2010 and has not resumed
operations since. During this inspection, the reactor remained defueled and shut down.
1.
Staffing and Audits
a.
Inspection Scope (Inspection Procedure [IP] 69002, Section 02.01)
The inspector reviewed the following regarding the licensee's staffing and audits
to ensure that the requirements of TS Sections 12.1 were met:
current staffing of the ARRR
completed audits for 2017 to the present
RSC meeting minutes for 2017 to the present
duties of the RSC detailed in TSs Section 12.3
charter of the RSC outlined in Section I of the Aerotest Operations Facility
Operating Procedures entitled, Administrative Procedures
management responsibilities and organizational structure indicated in
Section 12.0 of the TSs, as implemented through the latest revision to the
Facility Operating License Number (No.) 98, Amendment No. 5, dated
July 17, 2017
annual summary of changes, tests, and experiments at ARRR for the
following periods: July 1, 2017, to June 30, 2018, issued July 16, 2018;
July 1, 2018, to June 30, 2019, issued July 12, 2019; and, July 1, 2019, to
June 30, 2020, issued July 1, 2020
b.
Observations and Findings
(1) Staffing
(a) General Staffing Level
Through discussions with licensee representatives, the inspector
determined that management responsibilities at the facility was not
changed since the previous routine NRC inspection conducted in
June 2017 (NRC Inspection Report No. 50-228/2017-201). The inspector
noted that the President of Aerotest (who was also the Manager) was the
head of the company. The Certified Fuel Handler Supervisor was
responsible for day-to-day activities at the reactor facility and reported to
the Aerotest President. The Radiological Safety Officer (RSO) was
responsible for enforcing rules, regulations, and procedures relating to
radiological safety and reported to the Aerotest President. The Aerotest
President, reported to the Board of Directors of Aerotest.
- 4 -
The inspector noted that the facility license was transferred to a new
parent company called Nuclear Labyrinth, LLC, as was the ownership of
Aerotest The inspector determined that the licensee submitted a
possession-only license amendment request (LAR) that is being reviewed
by the NRC staff.
Through review of records and discussions with licensee personnel, the
inspector confirmed that the current staffing at the ARRR included the
Aerotest President, a Certified Fuel Handler Supervisor, the RSO, and a
Nuclear Analyst. The employees were monitoring the facility and
completed maintenance and surveillance duties as required by the TSs.
(b) Radiological Safety Officer
The TS Section 12.1.5 require that [t]he Radiological Safety Officer shall
have a Bachelors degree in Biological or Physical Science and shall have
a minimum of 2 years experience in personnel and environmental
radiation monitoring programs at a nuclear facility. Certification as a
Health Physicist by the Health Physics Society is acceptable in lieu of the
education and experience requirements given above.
The inspector inquired about the background and qualifications of the
current RSO. Through an interview with the RSO the inspector learned
that the person was appointed to that position on January 22, 2019,
following departure of the individual who previously held that job. The
inspector inquired about the RSOs background and qualifications and
was given a copy of the persons resume. The inspector determined that
the individual had not received a Bachelors degree in Biological or
Physical Science and had not received a Health Physicist Certification.
The inspector also noted that the individual had attended a course in
radiation safety, and was a designated shipper of radioactive material and
a neutron radiographer at the facility for many years. The person had
also helped the previous RSO perform duties involving personnel and
environmental radiation monitoring and protection.
The licensee was informed that, although the current RSO had a great
deal of experience in radiation protection, the TS specified that the person
was required to have a Bachelors degree in Biological or Physical
Science or be a Certified Health Physicist (CHP). Because the RSO did
not have such a degree and was not a CHP, this would be noted as a
violation (VIO) of TS Section 12.1.5 (VIO 05000228/2020201-01) and
would be reviewed during a future inspection.
(2) Audits
The inspector determined that the RSC met at least once per year in
accordance with TS requirements with the last two meetings held on
December 5, 2018, and on December 19, 2019. The inspector reviewed the
RSC's meeting minutes for these meetings which showed that the RSC had
considered the types of topics stipulated by the TSs. Review of the minutes
- 5 -
confirmed that the committee provided guidance and direction for facility
functions.
The inspector verified that the periodic audits specified by TS Section 12.1.3
were completed as required. The RSC minutes and audit records indicated
that the Chair of the RSC conducted unannounced audits of facility
operations annually and submitted the results to the Aerotest President. The
inspector determined that there were no significant issues discovered during
the audits and the licensee took appropriate corrective actions in response to
the audit findings or recommendations that were noted.
c.
Conclusion
The inspector determined that the staffing was consistent with the requirements
specified in TS Section 12.1, except as noted above, and audits were conducted
by the RSC as required by TS Section 12.1.3.
2.
Operator Requalification and Active License Status
a.
Inspection Scope (IP 69002, Section 02.02)
The inspector reviewed selected aspects of the licensees former requalification
program which was submitted to the NRC on July 13, 2000:
records of former operators who previously worked at the facility documenting
completion of requalification requirements
Aerotest letter to the NRC, Subject: License and TS Amendments. dated
March 21, 2019
NRC letter to the licensee, Aerotest Operatioins, Inc. - Request for
Additional Information Re: Possession-Only License Amendment To Use
Certified Fuel Handlers For The Aerotest Radiography and Research Reactor
Facility Operating License No. R-98, (EPID NO. L-2019-LLA-0065), dated
July 27, 2020
b.
Observations and Findings
The inspector determined that there were no ROs or SROs who held NRC
licenses to operate the reactor working at the facility. The last two previous
operators licenses were terminated on December 18, 2018, and October 1,
2019. The licensee is maintaining files and requalification records of the licensed
operators who worked there in the past as required.
The inspector noted that the licensee had submitted a LAR to the NRC by letter
dated March 21, 2019, to modify the existing operating license to a
possession-only license in support of the licensees decision to permanently
cease operation of the ARRR. Within the LAR was a request to incorporate the
use of Certified Fuel Handlers in lieu of NRC-licensed ROs and SROs. The NRC
addressed the licensees request in a letter dated July 27, 2020, and identified
additional information needed to continue its review of the LAR.
- 6 -
c.
Conclusion
The inspector determined that operator requalification records were maintained
at the facility as required even though there are no longer any licensed ROs or
SROs employed there. The licensee is seeking to establish a Certified Fuel
Handler program at the facility instead of having a Operator Requalification
Program.
3.
Radiological Surveys
a.
Inspection Scope (IP 69002, Section 02.03)
The inspector reviewed the following to verify compliance with 10 CFR Part 20
and the requirements in TS Sections 6.2, 7.0, and 12.1.2:
radiological signs and posting at the entrances to controlled or restricted
areas
calibration and periodic check records for portable and fixed radiation
monitoring instruments
radiation protection and surveillance and survey data from 2017 to the
present
Aerotest Operations Facility Operating Procedures,Section VI entitled,
Radiological Safety Procedures
Aerotest Operations Facility Operating Procedures,Section VIII entitled,
Maintenance Procedures
personnel and environmental dosimetry records for the past 2 years
radioactive liquid waste holding tank release records, and
results of the analyses of air filters for the past 2 years
b.
Observations and Findings
The inspector reviewed selected monthly, quarterly, and semi-annual general
area radiation and contamination surveys of various areas in the facility from
2018 to the present. The inspector confirmed that the licensee completed
surveys as required by procedure, documented the results on the appropriate
forms, and evaluated the results as required.
During the inspection the inspector, accompanied staff members, toured the
facility and determined radiation readings found were comparable to those listed
on survey maps that were completed by the licensee. No anomalies were noted.
The inspector reviewed the calibration verification records of various equipment
including survey meters, as well as the area, water, and stack monitoring
systems. The inspector determined that calibration of the area monitoring
systems were completed annually in accordance with procedure. The water and
stack monitoring systems were operationally checked daily. If they failed
verification, a full calibration was conducted. The inspector also reviewed the
records documenting the fact that, because the reactor had not operated since
- 7 -
2010, there were no liquid and airborne releases to the environment for that
period.
The inspector confirmed that personnel, as well as, on-site and off-site gamma
exposure and radiation monitoring was completed using thermoluminescent
dosimeters in accordance with the applicable procedures. Dosimetry results
reviewed by the inspector indicated doses to facility personnel was minimal. The
environmental data indicated that there were no measurable doses above any
regulatory limits. Through observation of the facility, the inspector did not identify
any new potential release paths
c.
Conclusion
The inspector determined that the licensee conducted operations in accordance
with regulatory requirements in 10 CFR Part 20 and the limits specified in TS Sections 6.2, 7.0, and 12.1.2.
4.
Surveillance
a.
Inspection Scope (IP 69002, Section 02.04)
The inspector reviewed the following to verify compliance with TS Sections 3.0,
4.0, 5.0, 6.0, and 7.0,:
various surveillance and maintenance forms from 2018 and to the present
including: Operations Request Forms; Monthly Alarm Check Lists;
Instrument Calibration; List of Aerotest Operations Surveillances; Aerotest
Operations, Inc. Quarterly Maintenance Check Lists; and ARRR Pool Water
and pH Analysis sheets
Aerotest Operations Facility Operating Procedures,Section VIII entitled,
Maintenance Procedures
b.
Observations and Findings
The inspector determined that the licensees TSs did not contain a specific
section stipulating what surveillances needed to be performed at the facility.
However, the TSs did contain some requirements for certain checks and tests
mostly dealing with experiments and radiation protection.
The inspector noted that, after the reactor was shutdown in October 2010, the
licensee continued to complete the various monthly, quarterly, and annual tests
and calibrations as required. The majority of the semiannual and annual
surveillance items were not completed because they required a functioning
reactor. One annual surveillance involving fuel inspection continued to be
completed as required.
The inspector determined that the licensee had developed various checklists and
forms to ensure that appropriate oversight was maintained over the various
maintenance and surveillance items and other activities. These included items
such as pool water pH and temperature levels, air filter change out, cycling the
pumps, and limited reactor console checkouts. The console checkouts was
- 8 -
eliminated since the licensee submitted a possession only LAR. The remaining
items are checked and/or completed on a periodic basis even though this was
not required because the reactor is shut down and not operating.
c.
Conclusion
The inspector determined that a limited program for surveillance checks, tests,
verifications, and calibrations was implemented in accordance with TSs and
procedural requirements.
5.
a.
Inspection Scope (IP 69002, Section 02.05)
The inspector reviewed selected portions of the material mentioned below to
determine that the licensee conducted exercises and drills and trained personnel
in accordance with the facility E-Plan:
List of Aerotest Operations Surveillances forms for 2018 to the present
emergency response facilities, supplies, and instrumentation
quarterly maintenance checklists for 2018 and to date in 2020
emergency drill records for 2018 and to date in 2020 documented in the
monthly alarm check lists
emergency response training for 2018 and to date in 2020 documented in the
training log
offsite support as indicated in the current letter of agreement (LOA) with
Stanford Health Care - ValleyCare
Aerotest Operations Facility Operating Procedures,Section III entitled,
General Emergency Procedures, including E-Plan implementing procedures
Aerotest letter to the NRC, Updated Emergency Plan, dated March 26, 2020
b.
Observations and Findings
The E-Plan for the ARRR in use at the facility was the same as the version most
recently submitted to the NRC by letter dated March 26, 2020, in accordance
with 10 CFR 50.54, Conditions of licenses, paragraph (q)(3). The inspector
compared the previous version of the E-Plan with the March 2020 version and
found that they were very comparable. However, the newer version did not
include three Appendices that appeared in the earlier version. The inspector
verified that the E-Plan was audited and reviewed biennially as required. The E-
Plan implementing procedures were incorporated into the licensees General
Emergency Procedures. The inspector determined that the procedures were
reviewed annually and revised as needed to implement the E-Plan effectively.
Through records review and interviews with staff personnel, the inspector
confirmed emergency response personnel were knowledgeable of the proper
actions to take in case of an emergency. The inspector confirmed that
emergency response equipment was maintained and calibrated and alarms were
tested at the frequency stipulated in the E-Plan. The inspector determined that
communications capabilities with the various offsite support groups were
- 9 -
available and functioning. A Notification List was maintained up-to-date and
verified annually by the licensee.
The inspector verified that emergency preparedness and response training for
staff personnel was completed annually as required. Evacuation drills were
conducted twice a year as required by the E-Plan.
The inspector reviewed the LOA that was signed with Stanford Health Care -
ValleyCare which operated a hospital in nearby Pleasanton, CA. The LOA stated
that the hospital would treat potential victims of a radiological event if such were
to occur at the ARRR facility. The inspector verified that the LOA continued to be
updated to confirm that the agreement remained in effect. The San Ramon
Valley Fire Protection District was also contacted annually to review emergency
interface requirements as required. It was noted that Fire Department personnel
visited the facility as time permitted for training and a tour.
c.
Conclusion
The inspector determined that the licensee reviewed the E-Plan and completed
emergency exercises, drills, and training in accordance with the E-Plan
requirements.
6.
Follow-up (Previously Identified Items)
a.
Inspection Scope (IP 92701)
The inspector reviewed the actions taken by the licensee to address three
previously identified Inspector Follow-up Items (IFIs) concerning a 10 CFR 50.59
evaluation, a Root Cause Analysis, and a licensee commitment as mentioned in
the following:
licensees 10 CFR 50.59 evaluation of a new mechanism for attaching the
upper grid plate to the core support structure
Aerotest Operation, Inc. Root Cause Analysis for the Damaged Aluminum
Cladded Fuel
operator requalification program for the ARRR, which was submitted to the
NRC on July 13, 2000
SRO licensed activities log documenting completion of maintenance and
surveillance activities and operator supervisory and related functions for 2018
and 2019
b.
Observation and Findings
(1) 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 the summer of 2012, the licensee initiated a program to remove the
fuel elements from the core structure so that a thorough examination of each
could be made. One of the obstacles encountered by the licensee was
- 10 -
raising the upper grid plate to allow the elements to be removed. When the
licensee tried to loosen the four bolts attaching 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 re-attach the upper grid plate to the core support
structure in the future, several methods were discussed. Contractor
personnel who were assisting in this project 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 support structure. Because this would be a change to
the current structure, the licensee needed to perform a 10 CFR 50.59
evaluation and review of the proposed new attachment mechanism. The
NRC issued an IFI to review this issue.
During this inspection the inspector reviewed the 10 CFR 50.59 evaluation of
the proposed new attachment mechanism. (This evaluation was acquired
previous to the inspection.) The inspector also reviewed a summary of this
issue written by the Aerotest President. The modification consisted of the
design and manufacture of 3 clamps to help attach the upper grid plate to the
core structure (to be used along with the one bolt that did not shear off during
removal). The inspector determined that the 10 CFR 50.59 evaluation had
addressed all the issues raised by the licensee and followed the guidance in
10 CFR 50.59. The evaluation was reviewed and ultimately approved by the
RSC as required. Following the purchase of Aerotest by the current owner,
problems with attaching the clamps as initially proposed were noted.
Modifications to the clamps were proposed which would not change their
functioning as described in the 10 CFR 50.59 evaluation. The licensee
indicated that the modifications would not reintroduce any old or raise any
new safety issues.
However, the licensee has submitted a LAR to the NRC by letter dated
March 21, 2019, to modify the existing operating license to a possession-only
license in support of the licensees decision to permanently cease operation
of the ARRR. This will preclude the necessity of the reassemblying the core
structure. This issue is considered closed.
(2) 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 an inspection in 2012, the inspector observed the removal of the fuel
elements from the core that could not be removed until the core structure was
disassembled. When the core was defueled, the licensee indicated that they
were planning on conducting a Root Cause or fault tree analysis concerning
what might have caused the cladding to crack. The licensee was informed
that the completion of a Root Cause or fault tree analysis concerning the
cladding cracks would be tracked by the NRC as an IFI.
During this inspection the inspector reviewed the Root Cause analysis which
was conducted by the current owner of Aerotest. The analysis reviewed
various aspects of the problem including personnel, the type of TRIGA fuel
- 11 -
used, and the fuel dynamics. After a review of all these factors, the licensee
concluded that limited fuel management and lack of fuel movement was the
likely contributor to the severity of the damage to the individual fuel elements.
With the completion of the Root Cause analysis, this issue is considered
closed.
(3) IFI 50-228/2017-201-01 - Follow-up on a commitment made by the licensee
to have lectures for 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per quarter for the ROs on staff.
During a routine inspection in June 2017, it was noted in Section II of the
licensees Operator Requalification Program that lectures were mentioned.
Lectures were not given for a variety of reasons. The inspector indicated that
lectures should be given at some frequency despite the fact that the
operators had passed all prior examinations and the reactor was not
operating at that time. The licensee proposed that, on a quarterly basis,
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of lecture would be given to all the SROs at the facility. The licensee
was informed that the commitment to complete 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of lecture per quarter
as part of their Operator Requalification Program would be considered an IFI.
During this inspection this issue of operator requalification was reviewed.
The inspector determined through a review of the licensees records,
including the training log and SRO files, that this commitment was met. The
inspector also noted that all the SROs had since left their employment at the
facility and there were no longer any licensed operators at the facility, hence
there was no longer any need for training lectures. This issue is considered
closed.
c.
Conclusion
The inspector determined the three IFIs were reviewed and are now closed.
7.
Exit Interview
The inspection scope and results were summarized on August 12, 2020, with the
Aerotest President. The inspector described the areas inspected and discussed in detail
the inspection findings. The licensee disagreed with the violation that was discussed.
Attachment
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
M. McCarthy
Nuclear Analyst
T. Richey
Radiation Safety Officer and Training Coordinator
D. Slaughter
President and Reactor Manager
M. Wilkinson
Certified Fuel Handler Supervisor and Facility Manager
INSPECTION PROCEDURES USED
Class III Research and Test Reactors
Follow-up
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 05000228/2020201-01 VIO The current RSO did not have a Bachelors degree in Biological or
Physical Science and was not a CHP as required by
TS Section 12.1.5.
Closed
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.
50-228/2017-201-01
IFI
Followup on 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per quarter lecture commitment by the
licensee.
PARTIAL LIST OF ACRONYMS USED
10 CFR
Title 10 of the Code of Federal Regulations
Aerotest
Aerotest Operations, Inc.
ARRR
Aerotest Radiography and Research Reactor
CHP
Certified Health Physicist
IFI
Inspector Follow-up Item
IP
Inspection Procedure
License Amendment Request
LOA
Letter of Agreement
No.
Number
NRC
U.S. Nuclear Regulatory Commission
- 2 -
Reactor Operator
Reactor Safeguards Committee
Senior Reactor Operator
Training, Research, Isotopes, General Atomics
TSs
Technical Specifications
Violation