ML23195A037
| ML23195A037 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 06/29/2023 |
| From: | Slaughter D Aerotest |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML23195A037 (1) | |
Text
June 29, 2023, AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY.
- SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 Memorandum Subjects: Additional Information Associated with 6/27/2023 Inspection From: David M. Slau.
r resident, Reactor Administrator, etc.
J declare under) alty of perjury that the content is true and correct.
This is the response to the notes generated from NRC staff's scheduled decommissioning inspection on 6/27/2023. This is not a comprehensive summary of all elements discussed by NRC staff but a response where there may be a differing viewpoint. The inspection areas include Administration Control (Stephanie Anderson), Radiation Protection (Michael LaFranzo), and Emergency Response (Jack Parrott). In general, the decommissioning inspection appeared organized resulting in NRC staff achieving its goal in a time sufficient manner. Please provide dates and times for the exit interview.
Emergency Response: There is a collective agreement between the Inspector and AO staff.
Administration Control:
AC. I The Inspector suggests a violation may have occurred when AO held a meeting December 8, 2020, and then January 21, 2022. The inspector mentioned the need to be within the "calendar" year; however, the calendar year requirement is not specifically stated in the TS 12.1.6 "...... The committee shall meet on call of the chairman and they shall meet at least annually..... " The inspector asked for an explanation for the delay in the meeting from December 2021 to January 2022. A O's initial response was the availability of members and the belief that there was limited flexibility in scheduling. Here are the details, AO has lately used December as the meeting month. Examining the details, all the required audits i.e., RSC and RSO audits were performed in December or earlier as usual. The Chair Henry Moeller asked for a delay to include the participation of outside member Melinda Krahenbuhl, who performed the security audit on December 17, 2021. (Melinda Krahenbuhl was recently reinstated to the committee.) Given the circumstances, AO believes this does not rise to a violation, but a reminder should suffice if AO is found in error.
AC.2 The Inspector identified inconsistencies in A O's administrative procedw-es associated with the makeup and operation paran1eters of the ARRR safeguard committee compared to those found in the technical specifications. AO agreed with the inspector's assessment and made the appropriate corrections to the administrative procedures to ensure compatibility with our technical specifications.
AC.3 The Inspector does not believe AO complies with TS 12.1.3 and TS 12.1.5. AO believes no violations have occurred. AO believes it has compiled; based on the education and experience as described in TS 12.1.3 for the Certified Fuel Handler Supervisor, there are two individuals that meet the qualifications, David Slaughter and Malcolm McCarthy. (Both also meet the lessor TS requirement detailed in TS 12.3.5) Here are the details. Malcolm McCarthy is listed for the supervisory position ( organizational chart, April 27, 2023). ln addition, David Slaughter has been involved with fuel movement and inspection at Aerotest Operations (i.e., 2017); he has also handled the movement of fuel using a single element shielded cask.
Information concerning CFHS and two other Fuel handlers was provided in ARRR CFH Revision 3/30/21 lists the three fuel handlers on the "Checklist for CFH Training
/Requalification Program" and the "Certified Fuel Handlers' Health Questionnaire". While the confusion may be the meaning of "Certified," the identified fuel handlers meet our TS obligations and have been assigned to those positions. Also, the required presence of fuel handlers on site is defined in Technical Specification 11.6 "CFH or CFH Supervisor does not need to be at the facility on a daily basis." They are only required when there is a transfer/movement of fuel." There is not an "emergency situation" that would have AO move fuel from its current location; the safest and secure location for the fuel is the subterranean subcritical storage racks in the lower portion of the tank (wet or dry.)
Radiation Protection:
RP.1 When the Inspector evaluated the procedure regarding calibration of Victoreen 190N portable neutron survey meter (6/27/2023) NRC staff observed over a 20 percent error (relative to a reference calibration.) AO agrees with the measured result and the NRC staff's observation. To better understand the situation, AO reviewed cw-rent calibration procedures and the past documentation of the previous calibrations. A calibration study was perfo1med (6/28/2023) which evaluated the instrument performance under varying meter orientations (flat front end, rear power supply end and perpendicular or sideways). Careful measurements at four distances (contact, 5", 20", 70") where the reference readings were 102, 31, 5, 0.6 mR/hr taken at each position listed above. Results of this calibration were reproducible to the recent and 6/27/2023 calibrations and not to the reference calibrations. It is not clear if AO were duplicating orientation and procedures used in the reference calibrations. (Reference calculations may be incorrect.) AO believes our current results are correct and reproducible and an application of a correction factor will suffice if the reference numbers are used; however, due to the uncertainty, AO is sending the instrument to a licensed calibration company to validate its proper function and adjust the instrument settings if necessary. There are no calibrations or adjustments to be made to the detector assembly; calibrations and adjustments are made to the electronic Model 190 reader. AO will obtain guidance and instruction from this third party to ensure our calibration technique/procedw-es are optimum resulting in the best performance. Due to our response and remedial action to the issue, AO does not believe a violation is warranted.
RP.2 The Inspector observed A O's water analysis method but was uncertain in some of the elements of the technical process. In the discussion, it was not clear if a violation was under consideration; if so, AO believes a violation did not occur. AO staff believes that the method and procedure are adequate for its purpose. The details of AO's water analysis are attached.
T his is a quick summary of the quarterly water analysis to clarif_v the water sample counting procedure. and belt.er explain how background is subtracted.
Tn the case of counting water samples, t he Nal syst.cm is not operated as a spectrometer. bnt rather as a sensitive sciut,illatiou detector iuside of a well-shiehle<l cuclosure. vVhile the sigual processing circuit rloP.s bin counts hy thPir energies. due to the low activity of t he ;:;,11nples and the rcla,tively coa.rse energy resolution afforded hy Naf. only the tot.a l counts are considered fur t lwse analy:,ws. Neither the J)(~ak fi tting.
radiouuclide <lat a. nor ellicienc.v calibration within the Gamma Visiou program are use<l for these aual:vses.
The procedure for COU11ting pool water is Mi follows:
- 1. Firsl. the ~ 0.00G µ Ci (1 l Bq, 10.SGO DPM) Cs-137 source is counted for a period of 100 minutes. In April of 2023 this yiclde<l 122.019 total counts. This cow1t is pcrfonuc<l first so that it cau also serve as ch0rk of th!' <ktr.ctor*s ahiHty to provklr a rnclfation-in<lur*0.d mra,mrl'mr.nt.
- 2. A 100 minute baekgrow1d count is taken with no sources or samples in U1e detection chamber. ln April of 2023 this _yielded 65,-l26 cou11ts.
- 3. 100 min11Le count,; are then t.,,ken of (.he 11Mkcup w;it.er and puol water sample;:;. In April of 2023 t he,;e
_Yielded 64.459 and 65. 768 counls rPspectively.
-l. In order to obtain the dctcctor*s efficiency. the detected count rate is compared to the Cs-137 sample*s actual disint ('gm Lion rat.e. The diffcrencf; C:c;-137 counts and background count.~ is d ivided by the count duration in order to yield t II<:' net count rat.e. ln April of 2023, the mP.asurecl Pfficiencv was found to lie:
122,019 Counts - G5,-12G CoLU1t~
, g* CP'[
Effi.
5G5.93 CP M
()~*)
507
=,'it,!'!. 3 11
+ '
cicncy = ----- ::::: 0. ::i _ ~ 10 100 minutes c,...137 10,860 DPM
- 5. T he pool water',; mea:;urc<l activity relative to the measured lmckground i:; nse<l to compute the activity concentrat.ion in the 250 mL,;ample by mulLiplying the counL rate per volume by the efficiency ~
calculated in step -!. LJsin~ the numbers from April of 2023:
- 05. i(i8 C\\Jlllll:,
100 mi 1tt1t,*:-
li5A2ti C,.tmtt>
100 11,iuut,*$ = 657.68 CP!\\1 !.26 CPM 250 rnL 250 mL 3.-!2 CP !\\l U.01368 CPM
= ------
250 mL mL 0.000228 CPS mL 0.000221:1 ~ P S/1uL = 0.0U-l5(i Bq/ rnL ~ 1.23 x 10- 1:1 Ci/ mL ::::: 1.23 x 10- 1 µCi/ lllL 5 0 Th.is number if-well bdow th<' lt) CFR 20 Append ix B maximum permissible Cs-137 concentrations for sewer clischargP and watf*r effluent of 10- n µ Ci/ mL and 10- 1; µCi/ mL respectively.
- 6. T he pool water's measured,icLivit_v is also co111parc<l t.o that. of the makeup water. This calculaLiou can hr don0. without rxplicitly i11c-l11<ling th!' mr:asur0.<l har:kground. a:,; thc background is t.br,;amr: for both the pool ctrtd m,Lkeup waler. and would lw cancdled out in the :rnbt.racti<>TL Moreover. in the April of 2023 case, t he background count. was slightly higher than t hat. of the makeup watPr. Using the 1m111bcrs from April 2023 auJ followiug tht* s,t111c process~ iu step 5:
n:,, 708 Coll!ltS l*hl. J!'",H C ou11LS 100 1ui11ut.t'ti 100 111i11utes 2GO m L G57.Ci8 CPM 1.59 CPM 250 mL 1:3.09 CPM 0.052:Hi CPivI 2GO mL
~
mL 0 000873 CPS/mL o/c
~ 0.017--15 Bq/mL ~ --1.72 x 10-13 Ci/mL ::::: 4.72 x 10- 7 ~tCi/ mL 5 0 0.00087:3 CP S mL