ML21361A047
| ML21361A047 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 12/21/2021 |
| From: | Slaughter D Aerotest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EPID L- 2019-LLA-0065 | |
| Download: ML21361A047 (12) | |
Text
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY* SAN RAMON , CA 94583 * (925) 866-1212
- FAX (925) 866-1716 December 21, 2021 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.
ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Response to December 6, 2021 , NRC POL Issuance; The licensee and its Reactor Safeguard Committee request a reasonable opportunity to review and address short comings of the draft Licensee and Technical Specifications along with the Draft Safety Evaluation before issuance of the POL license.
Ladies and Gentlemen:
The licensee and its Reactor Safeguard Committee request a reasonable opportunity to review and address short comings of the draft Licensee and Technical Specifications along with the Draft Safety Evaluation before issuance of the POL license. The LAR process resulting in the December 6, 2021, issuance of LAR Amendment No. 6 (ML21242A463) reenforces my belief that the NRC staff and it process requirements and practices are flawed resulting in an incompetent performance.
A final review by Aerotest administrative staff and by my Reactor Safeguards Committee was not given.
In part, a reason provided was having to meet the December 8, 2021 , deadline. I have been and continue to be critical of the NRC Staff performance on this LAR (and other regulatory activities).
This POL document is a cumulation of effort that spanned from March 23 , 2019, to December 6, 2021 .
Over 30 months (2.5 years) to complete a license amendment for a facility with an operating TRIGA reactor to one that simply stores TRIGA fuel. The cost to the Licensee for NRC staff time will approach
$200,000 for this task alone; the last quarter billing for 2021 will not be available until January 2022. See attached entitled Part 50 Possession Only LAR NRC Cost summary. The licensee was concerned with the lack of progress by the NRC staff as expressed in two recent letters dated July 20, 2021 (ML21209A5 l 9) and October 28, 2021 (addressed to the NRC CFO which is not on ADAMS). The October 28, 2021 , communication is attached for completeness.
The final communications leading to the December 6, 2021 , issuance of LAR Amendment No. 6 (ML2 l 242A463) reenforces my belief that the NRC staff are struggling to accomplish their task and provide effective regulatory oversight It is not clear if it is a lack of workforce, ill served systemic administrative processes, lack of technical competency or a combination of these factors are to be blamed.
The recent emails communications demonstrate my concern:
11/23/21 Email from Geoffrey Wertz (NRC) to Dr. Slaughter. The licensee received an email with an attached document labeled DRAFT of ARRR POL LC and TS change Pages. In the email, it stated that NRC staff amended LCs and TSs and they are issuing a partial approval and partial denial. The email included a summary list ofNRC staff changes. It continues by stating the reasons for the changes will be detailed in the safety evaluation that will be issued with the POL. While the staff did encourage licensee to discuss the partial denial and NRC changes per a telephone conference. The attachment contained only the Draft LAR 15 pages, without a draft safety evaluation (ML21328A192) 11/23/21 Response to Geoffrey Wertz (ML21328A195) The Licensee did respond having received the Draft LC and TS and indicated that the Licensee would reach out after thanksgiving holiday to a schedule meeting.
[Unfortunately, when the reply to the email was sent, a number automatic out of office messages from the email addresses indicating various dates of availability. This was not a surprise given that the licensee reply was sent the same day NRC email was received , two days before the Thanksgiving holiday.]
12/1/21 email to Geoffrey Wertz (NRC) (ML21337A330) not sure of who would be involved in the meeting and their availability given the number NRC staff addressees. To expedite the discussion, the Licensee suggested changes that were needed to clarity TS 11.1 as it is confusing; the use of plural word "pits" when the technical specification was for a single pit. Also, the draft TS amendment numbers were confusing. The Licensee also mentioned that the draft document would be submitted for review to the Reactor Safety Committee (RSC).
[Interesting, reviewing the list of actions made by the NRC staff in the email dated 11/23/2021 included punctuations, clerical, and clarification changes.]
12/2/21 email from Edward Helvenston (NRC) (ML21337A330) summarized that no changes to the document will be allowed including to TS 11.1. He goes on the say that The Licensee can submit a separate amendment request following the POL amendment. Mr. Helvenston indicated that if a call is requested, it needed to be conducted in the next couple of days to meet the December 8, 2021 , completion date.
12/2/21 email to Edward Helvenston (NRC) (ML21337A330) The licensee responded if no changes can be made, Geoffrey must have erroneously sent the document with a draft label.
Based on the document being finalized on 11/23/2021, a follow up phone meeting before the December 8th, 2021, would not been beneficial and/or cost effective.
[The licensee and its RSC were not given the opportunity to make changes in the final review of the draft document or review the draft safety evaluation report to understand NRC staff decisions.
Based on the Table of communications associated with the LAR attached, the NRC staff approximately 150 days from our last RAJ response 6/22/2021 to produce a final document delivered on 11/23/2021 (Without providing the licensee with a draft/final safety evaluation, the NRC staff's offer for teleconference would not be productive. Why was the licensee not given a draft safety evaluation on 1 l /23/2021 ?]
12/6/21 Letter (Email) to Dr. Slaughter issuing FOL (ML21242A463) was received with associated attachments
We need the NRC to response to: The licensee and its Reactor Safeguard Committee request a reasonable opportunity to review and address short comings of the draft Licensee and Technical Specifications along with the Draft Safety Evaluation before issuance of the POL license.
Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com.
I declare under penalty of perjury that the statements above are correct and truthful.
Sincerely yours, David M. Slaughter, Ph.D.
President, Reactor Administrator, Manager Aerotest Operations, Inc.
Enclosures:
October 28, 2021 Letter to Cherish J Johnson (NRC) CFO Proof of Delivery for October 28, 2021 Letter to Cherish J Johnson (NRC) CFO Table 1 ARRR Part 50 License Review (LAR) - Time Line Table 2 Aerotest Certified Fuel Handler - Time Line Cc US NRC OIG, Denise Hannigan (Emailed)
US NRC, Edward Helvenston (Emailed)
AEROTEST OPERATIONS, INC.
3455 FOSTOR iA WAY
- SAN RAMON , CA 94583 * (925) 866-1212
- FAX (925) 866-1716 October 28, 2021 herish J. John on U.. Nuclear Ref,rulatory omm1s 1011 Office of the Chief Financial Officer Division of the Comptroller Labor Adminjstration and Fee Billing Branch Mail Stop T9 850 Wa hington, DC 20555-0001
Dear Cherish J. Johnson ,
I am confused what specific activities remain to achieve the license amendment from operational to only storage of fuel. NRC bill lacks transparency in describing the perform ance and the co ts that was promised in EIMA 2019. The lack of detail of activities not provide d in the NRC bill hinders the effective evaluation of charges as well to assess progress. Trackin g the charges as per pay period, the NRC staff contributions were substantial completed on or before August 14th pay period with little effort reported in the pay periods that followed. When I notice staff is charging a few hours (e.g., l , or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) per pay period (spanning 2 weeks) I cannot imagine that is productive in completing the license amendment other than putting their time in without valuable effort. It is not clear if this is a report of single entry of time or a summation of short, reported times during that pay period. Either way the ability of the Staffer to be product ive is questionable. This quarterly NRC billing represents 45 percent of my total burdene d per onnel costs over the same period of time. I have no measure of accomplishment toward the completion of the license amendment.
In addition, r ha e charge of Jack Parr tt under th A rote t Po
- i n-only LAR... . with no cl ar und rstanding why. I se on my p rvious NR bill und r thi acti ity Mr. Jack Parrott wa not included. Why th inclusion n w and th hour p r pay period i very low uggesting no significant technical impact. Could you provide me a description of his effort und r the charge reported under the "Aerotest Possession-only LAR .... " section? (I understand Mr. Parrott' s inclusion on charges associated with "Aerotest Decommissioning Plan Review
. ')
My last communication (AO Letter dated 7/20/202 1, ML21209A519) questio ned RC staff explanation and need for additional 6-month extension (NRC Letter dated 7/ 12/2021 ML2 l I 88A391 ). This extension pushed back the scheduled completion of the LAR to December 8 2021. This activity should have taken much less than the required two years and now to include an additional 6 months is unreasonable. After 98 days, I have not receive d a response to that communication or status of the license amendment. I did receive an email dated the same date of this letter, 10/28/2021 from Ed Helvenston (NRC staff) stating that "NRR is continwng to work on the POL LAR and should have a separate update on that soon. Given the reduced
hourly effort by R taffrenected in th laner p rtion f th N , bill, ne might prem tu~ I conclude the taffi near d ne. Howev r i.f additional RA ar reque t d, most lik ly will fore a later completion date beyond December 8, 2021 . f it p ible to hold the R staff accountable for poor pe1forrnance of duty? When I exp ri nee sub-performance from my taff, r evaluate if it is a systemic problem related to the company's approach or a personnel issue that needs to be remediated The research reactor, licensed for 250 KW has an operational licen e for over 55 years. The R involvement is well documented from the reactor initial conception to the present The LAR for changing the status from operation to storage should be straight forward. This raises a broader concern that the current NRC approach to oversight will allow the repeat of catastrophic failures of safety such a that occurred at Aerotest Operations. NRC failed their obligations along with the licensee that resulted in twenty-two fuel elements with cracked cladding. The TRIGA fuel design is inherently safe which prevented a radiation release. Under the cun-ent circumstances of a NRC staff struggling to perform rudimentary regulatory oversight, the potential of nuclear accidents with advanced reactors for power and non-power applications (with less forgiving operational circumstances) will be more frequent and resulting damage more severe. lt is my belief that technology rarely fai Is if operated within it de ign parameters and is pr pedy maintained. Mo t failures are a result of li censee's (and/or regulator's) negligent decisions and actions.
I declare under penalty of perjury that th
- tatemcnt made in th cnclo ur s arc corr t and truthful to the best of my knowledge. hould ou have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter; Ph.D. at (801) 631 5919 or dm raven@ gmail.com espe tfully, ~ ~
Da id M Slaughter, PhD Pre ident, Reactor Adminjstrator, General Manager and Manager
Enclosures:
July-Sept NRC quarterly bill cc ( *-mail) enator ynthia Lummi ( , llow up to letter dated Augu t 18 202 I enator Ale Padilla (Fo llow up to letter dat ed August 18, 20 1 en t r John Barra ( ' Ollow up pr ntative ric v alw 11 ( ollo up to I tt r dated Aui:,l~ t 19, 2021 d Helvenston -mail)
Billin g Detail s:
Docke t#: 05000 228 Docke t Name: Licens e#: R- 98 AEROTEST EPID #: L- 2019-L LA-006 5 EPID Name: Aerote st Posses sion-o nly LAR and associ ated ORP revisio n CAC#: 000955 CAC Name: FB-OR-N,on-Power Prod-Utilization Review NRC Staff Name Pay Period End Dale Hourly Rate Hours Hourly Cost Helvens ton,Edw ard M Jul 3,. 202:t $279.00 9.25 $2,580.7 5 Torres. Paulette A Jul 3, 2021 $279.00 1.00 $279.00 Wertz,G eoffrey A Jul 3, 2.02.l $279.00 9.00 $2,511.0 0 Helvens ton,Eclw ard M Jul 17, 2.021 $279.00 4.50 $1,255.5 0 Wertz,G eoffrey A Jul. 17. 2.021 $279.00 16.00 $4,464.0 0 Helvens to11,Edward M Jul 31,, 2.021 $279.00 7.7 5 $2,162.2 5 Wertz,Geoffrey A JuP 31, 2.021 $279.00 24.00 $6,696.0 0 Helv:enston,Edward M Aug 14, 2.02.l $279.00 14.75 $4,115.2 5 Wertz.G eoffrey A Aug 14, 2.02.1 $2.79.00 14.00 $3,906.0 0 Helvens ton,Edw ard M Aug 28, 2.021 $288.00 4.75 $1,368.0 0 Parrott, Jack D Aug 28, 202:1 $288.00 2.00 $576.00 Reed,.Sara E. Aug 28, 2021 $2.88.00 1.00 $288.00 Wertz,G eoffrey A Aug 2-8, 2.021 $288.00 5. 00 $1,440.0 0 Helvens ton,Edward M Sep 11, 2.021 $288.00 5 .00 $1,440.0 0 Parrott,Jac.k D Sep 11, 2021 $288.00 2 .00 $576.00 Wertz,G eoffrey A Sep 11, 2:021 $288.00 2 .00 $576.00 Parrott,Jaclc D Sep 2.5, 2021 $288.00 1.50 $432.00 Wertz,G eoffrey A Sep 2.5, 2.02.1 $288.00 3 . 00 $864.00 CAC Total: 126.50 $.35,52 9.75 EPID Total::
$35,52 9.751 G:() 4io ~
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Billing Details :
Docket# : OS0.0022 8 Docket Name: license #: R-98 AE.RQTE ST EPID #: l-2021-U .N-0004 EPID Name: Aerotes t Decomm issionin g* Plan Re.v iew CAC #: 0.00955 CAC Name: FB-OR-N on-Powe r Prod-Util ization Review NRC Staff' Name Pay Period End Date Hourly Rate Hours Hourly Cost Helvenston,Edwa.rd M Aug 28, 2021 $288.00 1.75 $504.00 Panrott,Jack D Aug 28, 2021 $288.00 3.00 $864.00 Helvensto .Edward M Sep 11, 202 1 $288.00 0 .75 $216.00 Parrott.Jade D Sep 11, 2021 $288.00 4.50 $1,296.00 Parrott,J'ack I) Sep 25, 2021 $288.00 4.00 $1,152.00 CAC otal: 14.00 $4,032 ..00 EP*l!D To,taf<:: $4,032.0 01 Docke t Total: 05000 228
$39,561 .75 14 .()C) l~O of 249
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Table 1 ARRR Part 50 License Review (LAR) Page lof 3 Days Document Title Accession Number Date Added Document Date Who Sent What between Possision Only LAR 04/02/2019 License and TS Aerotest Operations, Inc. - License and TS Amendments. ML19084A051 08:31 AM EDT 3/21/2019 Aerotest submitted n/a Aerotest Operations, Inc. - Supplemental Information Needed for Acceptance of Requested Licensing Application Re : License Amendment Request to Prepare for Fuel Storage and Decommissioning Activities for the Aerotest Radiography and 06/06/2019 Request for Research Reactor. ML19108A478 09:25 AM EDT 5/29/2019 NRC Supplemental Info 69.00 Possision Only LAR 07/12/2019 License and TS Aerotest Operations, Inc. - License and TS Amendments ML19184A112 09:23 AM EDT 6/28/2019 Aerotest submitted 30.00 Aerotest Operations, Inc. - Acceptance Review and Milestone Date for Completion of the Review of License Amendment Request Related to Permanent Cessation of Operation of the Aerotest Radiography and Research Reactor, Facility 08/07/2019 Acceptance of Operating License No. R-98 ML19193A077 08 :32 AM EDT 7/30/2019 NRC Possision only LAR 32.00 Aerotest Operations, Inc. - Supplemental to License and TS 08/27/2019 License and TS Amendments. ML19231A127 08 :35 AM EDT 8/14/2019 Aerotest Amendment 15.00 Aerotest Operations, Inc. - Regulatory Audit Re : License Amendment Request for Possession Only Status of the Aerotest Radiography and Research Reactor(EPID L-2019-LLA- 11/04/2019 0065) ML19255F932 01:12 PM EST 10/31/2019 NRC Audit Request Aerotest Operations, Inc. - Report On The Regulatory Audit Conducted December 11, 2019 Re : License Amendment Request For Possession Only Status Of The Aerotest Radiography And Research Reactor (EPID No. L-2019-LLA- 02/05/2020 0065) ML20017A278 08 :35 AM EST 2/3/2020 NRC Audit Report 95.00 Aerotest Operations, Inc., ML20017A278; Audit Report December 11, 2019 Regarding the License Amendment for a 02/26/2020 Possession-Only Facility License ML20049A040 08:30 AM EST 2/12/2020 Aerotest Audit Reponse 9.00
Table 1 ARRR Part 50 License Review (LAR)
Page 2of 3 Days Document Title Accession Number Date Added Document Date Who Sent What between Aerotest Operations, Inc. - Request For Additional Information Re: Amendment Request For Possession Only License For The Aerotest Radiography And Research Reactor Operating 02/18/2020 license No. R-98 (EPID NO. L-2019-LLA-0065) M L20034G445 08 :39 AM EST 2/13/2020 NRC RAI 183.00 Aerotest Operations, Inc. Aerotest Radiography and Research Reactor, Response to NRC staff Request for Additional 04/17/2020 Information (redacted version) March 26, 2020 ML20098D415 08 :32 AM EDT 3/26/2020 Aerotest RAI Response 42.00 Aerotest Operations, Inc. - Request for Clarification Re: Amenc ML20112F489 05/11/2020 08:~ 4/30/2020 NRC RAI 35.00 Aerotest Operations, Inc. - Response to NRC Request for Clarification RE : Amendment Request for Possession Only License for the Aerotest Radiography and Research Reactor 07/06/2020 Facility Operating License No. R-98 (EPID No. L-2019-LLA-0065) ML20175A676 08 :52 AM EDT 6/8/2020 Aerotest RAI Response 39.00 Aerotest Operations, Inc. - Request for Additional Information Re : Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating 03/30/2021 License No. R-98 (EPID No. L-2019-LLA-0065) ML21047A468 03 :13 PM EDT 3/30/2021 NRC RAI 295.00 Aerotest Operations, Inc. License and TS Amendments ML21126A150 05/14/2021 09 :1 4/28/2021 Aerotest RAI Response 29.00 06/04/2021 Aerotest Operations, Inc., Response to RAI 28 and 29 ML21147A060 08:31 AM EDT 5/19/2021 Aerotest RAI Response 21.00 Email from Geoffy A Wertz* None 6/3/2021 NRC RAI 15.00 Draft RAI Questions
- ML21201A364 7/22/2021 6/3/2021 NRC RAI 0.00 07/09/2021 Aerotest Operations, Inc. - License and TS Amendments** ML21181A123 08 :22 AM EDT 6/22/2021 RAI Response 19.00 Aerotest Operations, INC. - Revised Completion Date RE : Possession Only License Amendment Request for the Aerotest Radiography and 07/20/2021 08:35 Research Reactor Facility Operating License ML21188A391 AM EDT 7/12/2021 NRC More Time 8/5/21 Response to more time need by NRC ML21209A519 8.27 AM EDT 7/20/2021 Aerotest Response 8.00
Table 1 ARRR Part 50 License Review (LAR)
Page 3of 3 Days Document Title Accession Number Date Added Document Date Who Sent What between 12/21 /21 Draft LAR/Phone Meeting ML21328A192 8:30AM EDT 11/23/2021 NRC Draft 154.00 12/2/2021 Email to Set meeting on Draft LAR after Thanksgiving ML21328A195 8:32 AM EDT 11/23/2021 Aerotest Response 0.00 12/6/2021 Possission only LAR Emails ML21337A330 9:58AM EDT 12/2/2021 NRC Draft not a draft 9.00 12/14/2021 Final License LAR License Amentment 6 issued ML21242A463 9:58AM EDT 12/6/2021 NRC Amendment Aerotest Average Response Days 22.10 NRC Average Response Days 98.56
- Never received the NRC offical RAI Request.
"** AO Response to NRC Draft Request as Official request never received
Table 2 Aerotest Certified Fuel Handler Days Document Title Accession Number Date Added Document Date Who Sent What between 04/02/2019 Aerotest Operations, Inc. - License and TS Amendments. Ml19084A051 08:31 AM EDT 3/21/2019 Aerotest Plan Aerotest Operations, Inc. - Request for Additional Information Re : Possession-Only License Amendment Request to Use Certified Fuel handlers for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 (EPID No. 08/06/2020 L-2019-LLA-0065) ML20177A203 08:34 AM EDT 7/27/2020 NRC RAI 494.00 Aerotest Operations, Inc - List of Explanations, Changes, and 09/15/2020 Justifications for RAJ CFH Training and Requalification Program ML20248H460 08:24 AM EDT 8/28/2020 Aerotest RAI Response 32.00 Aerotest Operations, Inc. - Request For Additional Information Re : Possession-Only License Amendment Request For The Aerotest Radiography And Research Reactor Facility Operating 03/25/2021 License No. R-098 (EPID NO. L-2019-LLA-0065) ML21034A626 04:15 PM EDT 3/12/2021 NRC RAI 196.00 Aerotest Operations, Inc. - Request for Additional Information Re : Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating 03/30/2021 Same as License No. R-98 (EPID No. L-2019-LLA-0065) ML21047A468 03 :13 PM EDT 3/30/2021 NRC RAI 3/12 Aerotest Operations, Inc., Response to RAI CFH Training and 04/09/2021 Requalification Program- 3/30/21 ML21098A157 10:31 AM EDT 3/31/2021 Aerotest RAI Response 19.00 Heard it was Draft LAR ML21328A192 12/3/2021 11/23/2021 NRC Approved 237.00 Aerotest Average Response Days 25.50 NRC Average Response Days 309.00