ML23255A034

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Response to Violation 050-00228/2023-001-00lA
ML23255A034
Person / Time
Site: Aerotest
Issue date: 09/09/2023
From: Slaughter D
Aerotest
To:
Document Control Desk, Office of Nuclear Reactor Regulation, NRC/OE
References
Download: ML23255A034 (1)
v • d • e


Text

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

  • SAN RAMON, CA 94583 * (925) 866-1212
  • FAX (925) 866-1716 9/9/2023 ATTENTION: Director, Office of Enforcement, US Regulatory Commission, Washington DC 20555-0001 AT ENTION: Document Control Des U.S . N uclear Regulatory Commission White Flint NQrth 11 555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

Subject:

AO Response to Violation 050-00228/2023-001-00lA Sir/Madam, Aerotest Operations (AO) denies the Violation 050-00228/2023-001-00lA. AO did not violate any Technical Specifications or the "ARRR CFH Training/Requalification Program," dated March 30, 2021, between December 6, 2021, to June 27, 2023. Violation 050-00228/2023-001-00JA should be rescinded.

This is in response to NRC violation 050-00228/2023-001-00lA thatAerotest Operations, Inc.

(AO) from December 6, 2021, to June 27, 2023, failed maintain in effect and fully implement all provisions of the NRC-approved Certified Fuel Handler Training and Requalification Program when in possession of TRIGA fuel elements pursuant to license condition 2.B.(2). Specifically, the licensee failed to have a qualified Certified Fuel Handler and a qualified Certified Fuel Handler Supervisor and implement the approved program consistent with the document entitled "ARRR CFH Training/Requalification Program," dated March 30, 2021.

The following AO discussion supports that no violation occurred.

  • There is no need to move 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.)
  • Since October 2019, AO has employed employees that meet the experience/qualifications as outlined in "ARRR CFH Training/Requalification Program," dated March 30, 2021 , 2.

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  • Aq was not aware of the "AR.RR CFH Training/Requalification Program," dated March 30, 2021,was approved or acceptable by the NRC until we received the NRC letter dated December 6, 2021. It would be impossible to have implemented and completed the training program on the December_6, 2021 date.
  • TheARRR CFH Training/Requalification Program," dated March 30, 2021, "4. Initial Training Program" does not express a specific time for the initial training program to be completed. After initial CFH training, the requalification program would be biennial.
  • In an October 1, 2019, letter to the NRC, AO informed the NRC that Christopher E.

Baum.an was no longer employed by AO and requested that his Senior Operator License be terminated. It also stated that under David M Slaughter's supervision, Fuel handling after the adaptation of the new license and tech spec would be handled by Mitch Wilkerson; He has over 20 years of experience using AO fuel handling tools.

  • AO's April 27, 2023, organizational chart shows that Malcolm McCarthy is listed as the Fuel Handling Supervisor. The organizational chart was shown to the NRC lead inspector.
  • 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."
  • Technical Specification 11.4 "The transfer of irradiated fuel in the reactor tank, storage pits and facility shall be conducted by a minimum staff of two; a Certified Fuel Handler (CFH) and an additional person trained in radiation safety."
  • The "ARRR CFH Training/Requalifi.cation Program," dated March 30, 2021. "3 .1. CFH Supervisor - The CFH Supervisor is a non-licensed operator whp has qualified fn accordance with a fuel handler training program approved by the NRC. They will supervise other CFHs and perform CFH duties." Since the CFH Supervisor can perform CFH duties, and 1 CFH is required per technical 11. 4, we don t necessarily need an additional employee as a CFH
  • AO has not moved any fuel since October 1, 2019; AO will complete the initial training before any fuel is moved.

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.

,§incerely yours,

\~fl-A david M. Sl~ter, P~---..

President, Reactor Administrator, Manager Aerotest Operations, Inc.

Enclosure:

AO letter dated 10/1/2019 (w/confirmation delivery)

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

  • SAN RAMON. CA 94583 * (925) 866-1*212
  • FAX (925) 866-1716 October I. 20 19 ATTENTION: Document Control Desk U.S. Nuclear Regulator} Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/UCENSE NO. R-98.

Termination of Senior Operator License SOP-70322-3 Ladies and Gentlemen:

Mr. Christopher E. Bauman is no longer employed by Aerotest Operations (nc. Thus, Aerotest requests the tennination of his Senior Operator License SOP-70322-3/Docket number 55-70461. His service to this company is no longer needed. David M. Slaughter (Retired NRC license No. SOP-70052), will be temporarily assigned Reactor Supervisor position until the completion of license amendment review.

No disruptions of required obligations will result.

I. Radiation and water monito~ing are already handled by Toni Richy. Radiation Safety Officer,

2. Physical security is the responsibility of David M. Slaughter, President and Reactor Administrator,
3. Facility emergency equipment and surveillances are conducted by Mitch Wilkerson, Facility Manager
4. Fuel cladding surveillance activities are not due until 4 years later based on NUREG 1537 requirements (The next fuel cladding surveillance will not be necessary until well after the estimated LAR completion.)
5. Under David M. Slaughter's supervision, Fuel handling after the adaptation of the new license and technical specifications will be handled by Mitch Wilkerson; he has over 20 years.of experience using Aerotest Operations fuel handling tools.

I have also hired Malcom McCarthy, (Retired NRC licenses SOP-70814, OP-71220; Docket# 55-71297) to enhance our MCNP,'RELAP-3D modeling and simulation capabilities in addition to our knowledge of current NRC regulatory requirements for RTRs.

Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (80 I.) 631 5919 or dmsraven@gmail.com. I declare under penalty of perjury that the statements made in the enclosures art! correct and truthful to the best of my knowledge.

\Sincerely yours, J..

'I ' ., . \--______

~-...:,.;. .~ (,\..-

Divid M. Slaughter. Ph.D.

President, Reactor Administrator, Manager, Reactor Supervisor Aerotest Operations, rnc.

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  • Distance Based Pricing, Zone 8

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Automation SSFO Sender Recipient Tracking ID 810776827943 David M Slaughter DocumentControlDesk Service Type FedEx Standard Overnight Aerotest Operations U,S Nuclear Regulator Commissi Package Type FedEx Tube 3455 FOSTORIA WAY White Flint North Zone 08 SAN RAMON CA 94583 US ROCKVILLE MO 20852 US Packages 1 Actual Weight 1.0 lbs, 0,5 kgs Rated Weight 9.0 lbs, 4.1 kgs Transportation Charge Delivered Oct 02, 201909:58 lli,count Svc Area Al Fu el Surcharge Signed by C.C/\STILLO ~ire ct Signature FedEx Use 000000000/1415/_ Total Charge USG Third Party Subtotal USD 1~.$J!

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