ML18303A291

Aerotest Radiography and Research Reactor Response to RAI-ORP-7

ML18303A291
Person / Time
Site:	Aerotest
Issue date:	10/24/2018
From:	Slaughter D M Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18303A291 (2)

Text

AEROTEST OPERATIONS, INC. 3455 FOSTORIA WAY

• SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 October 24, 2018 ATTENTION:

Document Control Desk (per 10 CFR 50.4) 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-98. RESPONSE TO RAI-ORP-7 Ladies and Gentlemen:

The response concerning the request for additional information, RAI-ORP-7, obtained in NRC letter dated October 15, 2018 is provided in this document.

The response is governed by the cited NRC regulations and July 27, 2000 ARRR Requalification program on the subject. (The new ARRR requalification program submitted in 2017 remains under review for approval and therefore is not relevant.)

ARRR SROs have maintained active status according to 10 CFR 55.53(e).

Each Senior Reactor Operator has performed SRO activities for more than the minimum 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per calendar quarter and is documented in the SRO's activity log. This regulation.does not specify a composition or percentage of an acceptable SRO workload.

While the ARRR SROs have maintained active status, if an operator did not, a remedial program including, at a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of supervised SRO work as detailed in 10 CFR 55.53{f) (and reinforced with similar verbiage found in ANSI/ANS 15.4-2016.)

Again, required tasks and composition of SRO activities are not specified in these regulations and standards.

Simply, providing specificity for SRO duties is difficult due to varying circumstances surrounding each test or research reactor. Examining the 10 CFR 55.59 requalification requirements, the ARRR SROs are also in compliance.

Section ( c )(3)(i) requires that " .... the requalification programs must contain a commitment that each individual shall perform or participate in a combination of reactivity manipulations based on the availability of plant equipment and systems." (It also states that "senior operators are credited with these activities if they direct control manipulations as they are performed.")

The NRC ordered the ARRR shutdown on July 24 2013, thus eliminating the availability of the plant equipment and systems for the compliance with this obligation.

The order was lifted shortly after the license transfer on July 17 2017. The plant equipment and systems needed to satisfy (c)(3)(i) (control manipulations) remain unavailable due to evaluation and preventive/corrective maintenance before the ARRR restart. Based on the NRC regulations cited, the NRC staff conclusion "none of the Aerotest's licensed personnel currently hold an active status" is in error.

As part of the ARRR restart plan two activities were performed to re-familiarize with the control console instruments/systems and their function.

1. The TRIGA reactor response to the insertion of reactivity approach to criticality, low-power, and high power operations (including tthe impact of the fuel's negative temperature coefficient).

The licensed ARRR SRO, Chris Bauman completed SRO training activities on September 20, 2018 at Reed Research Reactor under the auspices of Director Melinda Krahenbuhl, PhD. Below are the activities performed include 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of operation with a minimum of 10 reactivity manipulations of the control rods. 1. Briefed on security and safety for entrance.

2. Toured the control room, reactor, and related ancillary equipment.

3. Reviewed the console layout operation limits (scram settings), the start-up, normal shutdown, and emergency shutdown procedures.

4. ARRR SRO brought the reactor to 5 Watt, stabilized and recorded the power level. (The Reed SRO noted the actions and instrument responses while the ARRR SRO initially withdrew the control rods.) Mr. Bauman was instructed to perform "power steps" at his discretion.

5. Starting from 5 Watts power, the ARRR SRO performed a series of reactivity manipulations by altering the position of the control rod to increase/decrease the power level. At each level (step), the power was stabilized and recorded before moving to the next requested power. The Reed SRO monitored the chosen power levels based on his/her understanding of equipment and instrument capabilities.

6. The Reed SRO discussed the shutdown process while Mr. Bauman performed that task. 7. A debriefing of the training session occurred shortly thereafter to ensure meeting the regulatory obligations.

An objective and performance of the activities are summarized in fulfilment of Section VI of the ARRR Start Plan. The activity was recorded in the SRO activity logbook with activity summaries placed in Chris Bauman SRO's file. 2. ARRR 's unique layout of instruments and familiarity of switching sequences and the eye and hand coordination needed to successfully bring the reactor to criticality and sustain power operation.

The licensed ARRR SRO and Reactor Supervisor, A. Meren provided lectures and practicums of the ARRR checkout, Startup and Shutdown procedures to re-familiarize the operators with the reactor console. Lectures were held on dates 5-30-18 (checkout), 6-5-18 (start-up), and 6-13-18 (shutdown) with individual practicums performed with Mr. Meren shortly after each lecture. An objective of the activities performed are summarized in fulfilment of Section VI of the ARRR Re-Start Plan. The activity is documented in SRO activity logbook and operators file. I declare under penalty of perjury that the statements above are correct and truthful.

Should you have any questions or require additional information regarding this submission, please contact AO President and Reactor Administrator David M. Slaughter, Ph.D. at (801) 631-5919 or dmsraven@gmail.com ~t--'r'~~~--~

David M. Slaughter, Ph.D. President and Reactor Administrator Aerotest Operations, Inc.