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
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY.
- SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 June 29, 2023, Memorandum
Subjects: Additional Information Associated with 6/27/2023 Inspection
From : David M. S lau. r resident, Reactor Administrator, etc.
J declare under) a lty 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 E mergency Response (Jack Parrott). In general, the decommis sion ing inspection appeared organized resu lting in NRC staff achieving its goal in a time sufficient manner. Please provide dates and times for the exit interview.
Emergency Respon se: 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 "ca lendar " year; however, the calendar year requirement is not specifically s tated in the TS
- 12. 1.6 "...... The committee shall meet on call of the chairman and they s hall meet at least annually..... " The inspector asked for an exp lanat ion 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 ha s latel y used December as the meeting month. Examining the detai ls, all the required audits i.e., RSC and RSO audits were performed in December or earlier as usual. The Chair Henr y Moeller asked for a de lay to include the participation of outside member Melinda Krahenbuhl, who performed the security audit on December 17, 2021. (Melinda Krahenbuhl was recently rein s tated 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 incon sistencie s in A O ' s administrative procedw-es associated with the makeup and operation paran1eters of the ARRR safeg uard committee compared to those found in the t echnical s pecifications. 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 deta il s. Malcolm McCarthy is listed for the supe rvisory position ( organ iz ational chart, April 27, 2023). ln addition, David Slaughter has been involved with fuel movement and inspection at Aerotest Operation s ( i.e., 2017); he has also handled the movement of fuel using a sing le e lement shielded cask.
Information concerning CFHS and two other F uel handler s was provided in ARRR CFH Revi s ion 3/30/21 li sts the three fuel handlers on the "Checklist for CFH Training
/Requalification Program " and the "Ce rtified Fuel Handlers' Health Questionnaire ". While the confusion may be the meaning of "Ce rtified," the identified fuel handlers meet our TS obligations and have been assigned to those positions. Also, the required presence of fuel handler s on site is defined in Technical Specification 11.6 "CFH or CFH Supervisor doe s not need to be at the faci lity on a daily basis." They are only required when there is a transfer /movement of fuel." There is not an "emergency situation" that wou ld have AO move fuel from its current location; the s afest and secure location for the fuel is the subterranean subcritical storage racks in the lower portion of the tank (we t or dry.)
Radiation Protection:
RP.1 When the Inspector evaluated the procedure r egar ding calibration of Victoreen 190N portable neutron survey meter (6/27/2023) NRC staff obser ve d over a 20 percent error (relative to a reference calibrat ion.) AO agrees with the measured result and the NRC staff's observation. To better understand the s ituation, AO revi ewe d cw-rent calibration procedures and the past documentation of the previous calibrations. A calibration study was perfo1med (6/28/2023) which evaluat ed the instrument performance under varying meter orientations (flat front end, rear power s upply end and perpendicular or s ideway s). Careful m easu rem e nts a t four distances (contact, 5", 20", 70") where the refer e nce readings were 102, 31, 5, 0.6 mR/hr taken at each position lis ted above. Result s of this cal i bration wer e reproducible to the recent and 6/27/2023 calibrat ions and not to the refe re nc e calibrat ion s. It is n o t clear if AO were duplicatin g orientation and procedures used in the refe renc e ca lib rat ions. (Reference calcu lations ma y be incorrect.) AO believ es our current r esult s are correct and reproducible and an a pplication of a correction factor will s uffice if the refere nce numbers are used; howev er, due to the uncertain ty, AO is sending the instrument to a licensed calibration company to validate its proper function and adjust the instrum e nt settin gs if necessa ry. There are no calibrations or adjustments to be made to the detector a sse mbl y; ca librations and adjustments are m a d e to the electronic Model 190 reader. AO will obtain guidance a nd instruction from thi s third party to e n s ure o ur calibration technique /procedw-es are optimum res ultin g in the best performanc e. 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 m e thod but was uncerta in in some of the e le m e nts of the te chnical proces s. In th e di scuss ion, it was not clear if a violation was und er consideration ; if so, AO b elieves a violation did not occur. AO staff believes that the method and procedure are adequate for its purpose. The deta il s of AO ' s water analysis are attached.
T hi s is a quick s umm a ry o f t h e quart e rly water analysis to clarif_v the wat er sampl e count ing pro cedur e. and belt.e r explain how background is subt racted.
Tn the case of countin g water sampl es, t he Nal syst.c m is not o p e rat ed a s a s p ectro m ete r. bnt rather as a sen s it ive sci ut,illa tiou detector iusid e of a well-s h ie hle<l cu clos ure. vVhil e the sig u a l p rocess ing circuit rlo P.s bin cou n t s h y thPir e n e r gies. du e to th e low act ivity of t he ;:;,11nples and t h e r cl a,tive ly coa.rse energy resol u tion afford e d hy Naf. o nly the tot.a l cou n ts are considered fu r t lwse a n a ly:,ws. Neither th e J)(~ak fi t tin g.
radi o uuclid e <la t a. n o r e lli c ie n c.v cal ibrat ion within the Gamma Visio u pro g ram are use<l fo r these a ual :vses.
The pro ced ure for COU11ting pool water is Mi fo llows :
- 1. Firsl. the ~ 0.00G µ Ci ( 1 l Bq, 10.SG O DPM ) Cs-137 so urce is count e d fo r a period o f 100 minu tes. I n April of 2023 thi s yic lde <l 122.019 to tal co un ts. Thi s cow 1t is pcr fonuc<l first so that i t cau also serve a s ch0rk of th!' <ktr.ctor*s ah iH ty to provkl r a rnclfat io n-in<lur*0.d mra,mr l' m r. n t.
2. A 100 minut e baekgrow1d count is ta ken with no sources o r sa mpl es in U1e detection chamb er. l n Apr il of 2023 this _y ie lded 65,-l26 co u11ts.
- 3. 100 min11Le coun t,; are t h en t.,,ke n of (.he 11Mkc up w;it.er and puol water sa mpl e;:;. I n April of 2023 t he,;e
_Yie ld ed 64.459 a nd 65. 768 co unl s rPspectively.
-l. In o rd e r to obtain t h e dctcctor*s e ffi c ien cy. the detected coun t rate is compar ed to the Cs-137 sam ple *s act ua l dis int ('gm Lion r at.e. The d iffcre n cf; C:c;-137 coun ts and backg roun d cou nt.~ is d ivided b y th e count durati on in o r der to y ie ld t II<:' n et co u nt r at.e. l n April o f 2023, the mP.asurecl Pffi cie ncv was found to li e:
122,019 Co unts - G5,-12 G CoLU1t~, g* CP'[ Effi. 5G5. 93 C P M ()~*) 5 07
------- = 100 minut es c,... 137 10,860 DP M,'it,!'!. 3 11 -------+ ' cicncy = --- -- ::::: 0. ::i_ ~ 10
5. T h e pool wat e r ',; m ea:; urc<l ac tivi ty r elat ive to t h e measured lmckground i:; n se<l to comp ut e the activ i ty con centr a t.io n in th e 25 0 mL,;ample by mulLi p ly in g the cou n L r ate p er volume by the effic iency ~
ca lcul a t ed in s t ep -!. LJs in~ t h e number s from April o f 2023 :
05. i(i8 C\\J lllll :, li5A2 t i C,.tmtt> 3.-!2 C P !\\ l U.0136 8 CPM 100 mi 1tt1t,*:- 100 11,iuut,*$ = 6 5 7.6 8 CP!\\1 - 65-!.2 6 C PM ---- = ------ 0.00022 8 CPS 250 rnL 250 mL 2 50 m L m L mL
0.00022 1:1 ~ P S/5 0 1uL = 0.0U-l5(i Bq /rnL ~ 1.23 x 10 - 1:1 C i/mL ::::: 1.23 x 10 - 1 µ C i /lllL
Th.is number if-we ll bdow th<' lt) CFR 20 App e n d ix B ma xi mum p e rm iss ibl e Cs-137 conce n trations for sewe r clisch argP and wa tf*r effluent o f 10 - n µ C i/mL a nd 10 - 1; µ Ci /m L respectively.
- 6. T h e pool wa t er's me as ured,icLivit_v is a lso co111parc<l t.o that. of the makeup water. Th is calcu la Lio u can h r don0. w i thout rxplicitly i11c-l11<ling th!' mr:a sur 0.<l h ar:kgro u n d. a :,; t h c b a ckgro un d is t.b r,;amr: for both th e poo l ctrtd m,Lkeu p wale r. a nd would lw c an c dl ed ou t in th e :rnbt.ract i<>TL M oreover. in the April o f 2023 c a se, t he backgro u nd co u nt. was s lightly higher t h a n t h at. of th e makeup watPr. Using t he 1m111bcr s fro m April 2 0 23 auJ fo llowiu g t ht* s,t111c process~ iu ste p 5:
n:,, 708 C o ll!ltS l*hl. J!'",H C o u11 LS G57. Ci8 CPM - 64-1.59 C PM 1:3.09 CPM 0.052:Hi CPiv I 0.00087:3 C P S 100 1ui11ut.t'ti 100 111i11utes 2GO m L 250 mL 2GO mL ---- -- ~ 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 ~t C i/mL 5 0