ML23279A106
| ML23279A106 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 10/02/2023 |
| From: | Slaughter D Aerotest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk, NRC/OE |
| References | |
| IR 2023001 | |
| Download: ML23279A106 (1) | |
Text
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AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY
- SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 10/02/2023 ATTENTION: Director, Office of Enforcement, US Regulatory Commission, Washington DC 20555-0001 ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-9R.
Subject:
AO Response to Violation 050-00228/2023-001-001B Sir/Madam, Aerotest Operations (AO) accepts the Violation 050-00228/2023-001-00JB. Technical Specification 12.2.1.2, states, in part, detailed written procedures shall be provided and followed/or normal operating of all systems and components involving nuclear safety at Aerotest Radiography and Research Reactor facility. Technical Specifications Table 1 defines a Portable Neutron Survey Instrument as a system. Due to our response and remedial action to the issue on June 29, 2023 (ADAMS ML23195A037) before the August 13, 2023, exit interview, the response should have been noted in the inspection report and violation notification.
This is in response to NRC violation 050-00228/2023-001-001B thatAerotest Operations, Inc.
(AO) Procedure "Instrument Calibration Instruction - Safety Procedures," dated January 5, 2021, section 3.c.II.4 titled "Neutron Monitor" states, in part, that if the meter is more than 20 percent off expected readings, route the survey meter to the electronics shop for adjustment and/or repair.
Contrary to the above, on January 11, 2023, the licensee failed to route the survey meter to the electronics shop for adjustment and/or repair when a meter was more than 20 percent off expected readings. Specifically, the licensee noted during a calibration of a neutron monitor that the surface reading was expected to be 102 mrem/hr but rather was 150 mrem/hr, more than 20 percent of expected readings, and the survey meter was not routed to the electronics shop for adjustment and/or repair. The neutron meter is a component involving nuclear safety at Aerotest ~
i>ZD o£~i Radiography and Research Reactor facility.
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- v!!-t_/ OE
On June 29, 2023, I wrote a Memorandum (ADAMS ML23195A037) in response to the notes generated from NRC staffs scheduled decommissioning inspection on 6/27/2023. (The AO/NRC inspection exit interview was conducted August 13, 2023.)
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 reading.) AO agrees with the measured result and the NRC staffs observation. To better understand the situation, AO reviewed current calibration procedures and the past documentation of the previous calibrations. A calibration study was performed (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 other recent and 6/27/2023 calibrations. (Reference readings are believed to be in error due to different instrument orientation.) AO believes our current results are correct and reproducible well within the 20 percent obligation and an application of a correction factor will not be needed. 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 adj11 tm t are made to the electronic !vfodel 190 reader. AO will obtain guidance and instruction from this third party to ensure our calibration technique/procedures are optimum resulting in the best performance.
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.
Sin~y y:urs,'t->- ~'----
David M. Slaughter, Ph.D.
President, Reactor Administrator, Manager Aerotest Operations, Inc.