IR 05000228/2015201
| ML15273A428 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 09/30/2015 |
| From: | Kevin Hsueh Research and Test Reactors Branch B |
| To: | Warren S Aerotest |
| Bassett C | |
| References | |
| IR 2015201 | |
| Download: ML15273A428 (20) | |
Text
September 30, 2015
SUBJECT:
AEROTEST OPERATIONS, INC. - NRC ROUTINE INSPECTION REPORT NO. 50-228/2015-201
Dear Ms. Warren:
On August 17-19, 2015, the U.S. Nuclear Regulatory Commission (NRC, the Commission)
conducted an inspection at your Aerotest Radiography and Research Reactor facility (Inspection Report No. 50-228/2015-201). The enclosed report documents the inspection results which were discussed on August 19, 2015, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of noncompliance were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, "Public inspections, exemptions, and requests for withholding", a copy of this letter, its enclosure, and
your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Mr. Craig Bassett at (301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/ Kevin Hsueh, Chief Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-228 License No. R-98
Enclosure:
NRC Inspection Report No. 50-228/2015-201 cc w/encl: See next page
Aerotest Operations, Inc. Docket No. 50-228
cc w/encl:
Mr. Michael Anderson, President
Aerotest Operations, Inc.
Autoliv ASP, Inc.
26545 American Drive Southfield, MI 48034 California Energy Commission
1516 Ninth Street, MS-34
Sacramento, CA 95814
Radiologic Health Branch P.O. Box 997414, MS 7610
Sacramento, CA 95899-7414
Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center
Gainesville, FL 32611
Kimberly A. Harshaw Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW Washington, DC 20036-3006
Jay E. Silberg Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW Washington, DC 20036-3006
Anthony Nellis, Vice President
Legal Americas Autoliv, Inc 1320 Pacific Drive
Auburn Hills, MI 48326
ML15273A428; *via e-mail NRC-002 OFFICE PROB:RI* PROB:BC NAME CBassett KHsueh DATE 09/29/2015 09/30/2015 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-228
License No: R-98
Report No: 50-228/2015-201
Licensee: Aerotest Operations, Inc.
Facility: Aerotest Radiography and Research Reactor
Location: San Ramon, CA 94583
Dates: August 17-19, 2015
Inspector: Craig Bassett
Approved by: Kevin Hsueh, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY Aerotest Operations, Inc.
Aerotest Radiography and Research Reactor Report No: 50-228/2015-201
The primary focus of this routine, announced inspection was the on-site review of selected aspects of the Aerotest Operations, Inc. (the licensee's) Class II research and test reactor safety program including: 1) organization and staffing, 2) review and audit and design change functions, 3) procedures, 4) operator requalification, 5) maintenance and surveillance, 6) emergency preparedness, 7) radiation protection, 8) environmental monitoring, and 9) transportation since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensee's program was acceptably directed toward the protection of public health
and safety and in compliance with NRC requirements.
Organization and Staffing
The licensee's organization and staffing were in compliance with the Technical Specifications requirements.
Review and Audit and Design Change Functions
Review and oversight functions required by Technical Specifications Section 12.1.3 were acceptably completed by the Reactor Safeguards Committee.
One change had been made at the facility since the last NRC inspection which had been reviewed and approved by the Reactor Safeguards Committee as required.
Procedures Facility procedures were being reviewed by the licensee and reviewed and approved by the Reactor Safeguards Committee as required by Technical Specifications and
administrative procedures.
Operator Requalification Operator requalification was being conducted and completed as required by the Operator Requalification Program.
Medical examinations were being completed as required.
Maintenance and Surveillance
Maintenance was being completed in accordance with Technical Specifications and procedural requirements.
The program for completing surveillance checks, tests, verifications, and calibrations was being implemented in accordance with Technical Specifications requirements.
- 2 - Emergency Preparedness The current facility Emergency Plan was being reviewed biennially as required and updated as needed.
Emergency response equipment was being maintained and alarms were being tested monthly as required.
The Letter of Agreement with the local hospital was being verified annually as required.
Evacuation drills were being conducted twice each year as required by the Emergency Plan. Emergency preparedness training for staff personnel was being completed as required.
Radiation Protection Surveys and associated checks were completed and documented acceptably to permit evaluation of the radiological conditions present in the facility.
Notices and postings at the facility met the regulatory requirements.
Personnel dosimetry was being worn and doses were within the regulatory limits.
Radiation monitoring equipment was maintained and calibrated as required.
Training was provided as required covering the topics outlined in Title 10 of the Code of Federal Regulations Section 19.12.
The Radiation Protection and As Low As Reasonably Achievable (ALARA) Programs satisfied regulatory requirements.
Environmental Monitoring Effluent monitoring satisfied license and regulatory requirements, and releases were within the specified regulatory and Technical Specifications limits.
Transportation The program for transportation of radioactive materials satisfied NRC requirements.
REPORT DETAILS
Summary of Plant Status Aerotest Operations, Inc. (Aerotest, the licensee) 250 kilowatt (kW) TRIGA conversion research reactor, known as the Aerotest Radiography and Research Reactor (ARRR), had been operated in the past in support of neutron radiography experiments and reactor operator training. However, the licensee had voluntarily ceased to operate the research reactor on October 15, 2010, because of foreign ownership issues. During this inspection, the reactor remained shut down.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001)
The inspector reviewed the following regarding the licensee's organization and staffing to ensure that the requirements of Technical Specifications (TS) Sections 10.1 and 12.1 were being met:
Current staffing of the ARRR Management responsibilities and organi zational structure indicated in Section 12 of the TS, as implemented through the latest revision to the Facility License Number (No.) 98, Amendment No. 4, dated January 28, 1981 Section II of the ARRR Procedures Manual entitled, "Operating Procedures," Procedure Change Notice (PCN) No. 2, RSC approval dated June 28, 1990 Annual Summary of Changes, Tests, and Experiments at Aerotest Radiography and Research Reactor (ARRR) for the period from July 1, 2013, to June 30, 2014, issued July 8, 2014, and for the period from July 1, 2014, to June 30, 2015, issued July 27, 2015 (the facility annual
reports) b. Observations and Findings Through discussions with licensee representatives, the inspector determined that management responsibilities at the facility had not changed since the previous routine NRC inspection conducted in November 2014 (NRC Inspection Report No. 50-228/2014-201). The inspector noted that the General Manager was the local official in charge of day-to-day activities at the facility. The Reactor Supervisor (who was also assigned the duties of the Reactor Operations Manager) retained direct control over, and overall responsibility for, management of the reactor as specified in the TS. The General Manager and the Reactor Supervisor reported to the President, Aerotest Operations, Inc.
Through review of records and discussions with licensee personnel, the inspector noted that staffing at the ARRR included of the General Manager, the Reactor Supervisor, a Nuclear Engineer, the Manager of Nuclear Radiography, and the
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Manager of Quality Assurance. The employees were monitoring the facility and conducting maintenance and surveillance duties as required by the TS.
c. Conclusion The licensee's organization and staffing were in compliance with the TS
requirements.
2. Review and Audit and Design Change Functions a. Inspection Scope (IP 69001)
In order to ensure that the audits and reviews were being completed as required by TS Section 12.1.3 and to verify that any modifications to the facility were consistent with 10 CFR 50.59, the inspector reviewed the following:
Completed audits for 2013 and 2014 Changes made under the licensee's 10 CFR 50.59 change process Reactor Safeguards Committee meeting minutes for 2013 and 2014 Duties of the Reactor Safeguards Committee detailed in TS Section 12 Charter of the Reactor Safeguards Committee outlined in Section I of the ARRR Procedures Manual entitled, "Administrative Procedures," PCN No. 2, RSC approval dated June 28, 1990 The last two ARRR annual reports b. Observations and Findings (1) Review and Audits Functions The Reactor Safeguards Committee (RSC) met at least once per year in accordance with TS requirements with the last two meetings held on November 19, 2013, and on November 5, 2014. The inspector reviewed the RSC's meeting minutes for these meetings. The meeting minutes showed that the RSC had considered the types of topics stipulated by the TS. It was noted that the meetings were attended by all members of the committee. Review of the minutes also indicated that the committee provided guidance and direction to ensure suitable oversight of reactor
operations.
The inspector verified that the periodic audits specified by TS Section 12.1.3 were being completed as required. The RSC minutes and audit records indicated that the Chair of the RSC and another RSC member conducted unannounced audits of facility operations annually and submitted the results to the President, Aerotest Operations, Inc. The inspector noted that there were no significant issues discovered and that the licensee took appropriate corrective actions in response to those audit findings or recommendations that were noted.
- 3 - (2) Design Change Functions Through review of applicable records and interviews with licensee personnel, the inspector determined that one change had been initiated
and completed since the last NRC inspection. The change involved replacing the two waste Hold-up Tanks at the facility. It was noted that the change had been reviewed and approved by the RSC as required.
c. Conclusion Review and oversight functions required by TS Section 12.1.3 were acceptably completed by the RSC. One change had been made at the facility since the last NRC inspection.
3. Procedures a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the requirements of TS Section 12.2 were being met concerning written procedures:
Various ARRR procedures Procedure Approval Sheets Procedure Change Notice forms ARRR procedure review sign-off formsSection I of the ARRR Procedures Manual entitled, "Administrative Procedures," PCN No. 2, RSC approval dated June 28, 1990, which detailed the process used to review, revise, and approve all facility proceduresSection VI of the ARRR Procedures Manual entitled, "Radiological Safety Procedures," PCN No. 4, pending RSC approval Section VII of the ARRR Procedures Manual entitled, "Experiment and Approval," PCN No. 2, RSC approval dated June 28, 1990 b. Observations and Findings The inspector noted that procedures had been developed for reactor operations and safety as required by the TS. The licensee's procedures were found to be acceptable even though no operations were currently in progress. The inspector noted that the administrative procedure specified the responsibilities of the RSC. The inspector verified that a designated member of the RSC had completed biennial reviews of the facility procedures as required. It was noted that the last review of all procedures had occurred on May 14, 2015. The inspector verified that although no substantive revisions had been made to the Radiological Safety Procedures, because it had been converted to a digital format, it would be presented to the RSC for review and approval.
c. Conclusion
- 4 - Facility procedures satisfied TS and administrative procedure requirements for being reviewed by the licensee and reviewed and approved by the RSC.
4. Operator Requalification a. Inspection Scope (IP 69001)
To verify compliance with the Operator Requalification Program for the ARRR, which was submitted to the NRC on July 13, 2000, the inspector reviewed:
Status of all qualified operators' licenses Operator physical examination records for 2012 through 2014 SRO Licensed Activities Log documenting active operator supervisory and related functions for 2014 and to date in 2015 2014 Senior Reactor Operator Biennial Written Examinations and related records 2013 and 2014 Senior Reactor Operator Annual Operating test results and related records b. Observations and Findings There were three employees who maintained an SRO license at the facility. The inspector verified that the SROs' licenses were current. Records showed that operators were given biennial requalification examinations and annual operations tests as required. Logs indicated that operators maintained active duty status as required by performing the required calibrations of reactor components or by completing supervisory and related licensed operator duties. The Operator Requalification Program was being maintained up to date. The inspector also verified that the operators were reviewing the contents of all abnormal and emergency procedures on a regularly scheduled basis (annually) as indicated by a sign off sheet located in the emergency procedures folder.
The inspector further verified that each operator had received a biennial physical examination as required.
c. Conclusion Operator requalification was being conducted and completed as required by the Operator Requalification Program. Medical examinations for each operator were being completed biennially as required.
5. Maintenance and Surveillance a. Inspection Scope (IP 69001)
To determine that maintenance and surveillance activities were being completed as required by TS Sections 3, 4, 5, 6, and 7, the inspector reviewed:
- 5 - ARRR Repair Folders for various instruments Operations Request Forms for 2014 and to date in 2015 Monthly Alarm Check Lists for 2014 and to date in 2015 ARRR Pool Water Analysis sheets for 2014 and to date in 2015 Quarterly Instrument Calibration forms for 2014 and to date in 2015 Quarterly Maintenance Check Lists for 2014 and to date in 2015 Section VIII of the ARRR Procedures Manual entitled, "Maintenance Procedures," PCN No. 2, RSC approval dated January 14, 1993 b. Observations and Findings (1) Maintenance The various Repair Folders and Operations Request Forms maintained by the licensee indicated that em ergent problems were addressed by appropriate corrective maintenance as needed. If electrical components for the nuclear instrumentation were replaced, the maintenance procedures required that calibrations and voltage checks occur prior to the instrumentation being placed back into service. The inspector verified that these tests were completed as required. Records showed that routine maintenance activities were conducted at the required frequency and in accordance with the TS and/or the applicable procedure.
(2) Surveillance After the reactor was shutdown in October 2010, the licensee continued to complete the various monthly, quarterly, semiannual, and annual tests and calibrations as required. It was noted that the licensee had developed a checklist to ensure that appropriate oversight was maintained over the required items and other activities as well. These included items such as pool water pH and temperature, air filter changeout, and cycling the pumps. These items were checked/completed on a periodic basis even though this was not required because the reactor was shut down and not operating.
c. Conclusion Maintenance was being completed in accordance with TS and procedural requirements. The program for surveillance checks, tests, verifications, and calibrations was being implemented in accordance with TS requirements.
6. Emergency Preparedness a. Inspection Scope (IP 69001)
To verify compliance with the facility Emergency Plan, the inspector reviewed selected aspects of:
- 6 - Emergency response facilities, supplies, and instrumentation Quarterly Maintenance Check Lists for 2014 and to date in 2015 Emergency drill records for 2014 and to date in 2015 documented in the Monthly Alarm Check Lists Emergency response training for 2014 and to date in 2015 documented in the Training Log Offsite support as indicated in the current Letter of Agreement with the ValleyCare Health System Emergency Plan implementing procedures,Section III of the ARRR Procedures Manual entitled, "General Emergency Procedures," PCN No.
4, last revised January 28, 2005 Emergency response requirements stipulated in ANSI/ANS 15.16 - 1982 (R1988), "Emergency Planning for Research Reactors" b. Observations and Findings The Emergency Plan (E-Plan) for the Aerotest Radiography and Research Reactor in use at the facility was the same as the version most recently approved by the NRC with the last revision dated January 14, 2005. The inspector verified that the Emergency Plan was audited and reviewed biennially as required. The licensee's General Emergency Procedures were being reviewed annually by all licensed operators and revised as needed to implement the Plan effectively.
Through records review and interviews with staff personnel, emergency responders were determined to be knowledgeable of the proper actions to take in case of an emergency. Emergency response equipment was being maintained and calibrated and alarms were being tested at the frequency stipulated in the E-Plan. Communications capabilities with the various offsite support groups were acceptable. The Notification List was maintained up to date by an alarm contractor, and verified by the licensee.
The inspector verified that emergency preparedness and response training for staff personnel was being completed annually as required. Evacuation drills had been conducted twice a year as required by the E-Plan.
The inspector reviewed the Letter of Agreement (LOA) that had been signed with the ValleyCare Health System which operated a hospital in nearby Pleasanton, CA. The LOA stated that the hospital would treat potential victims of a radiological event if such were to occur at the ARRR facility. The inspector verified that the hospital had been contacted recently and an updated LOA was being signed to verify that the agreement remained in effect. The Fire Department was also being contacted annually to review emergency interface requirements as required. It was noted that Fire Department personnel had visited the facility on June 30, 2015, for training and a tour.
- 7 - c. Conclusion The inspector concluded that the emergency preparedness program was conducted in accordance with the E-Plan. Specifically, 1) the E-Plan and procedures were being reviewed as required and updated as needed, 2) emergency response equipment was being maintained and alarms were being tested monthly as required, 3) the Letter of Agreement with the local hospital was in the process of being signed, 4) evacuation drills were being conducted twice a year as required, and 5) emergency preparedness training for staff personnel was being completed as required.
7. Radiation Protection a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with Title 10 of the
Code of Federal Regulations (10 CFR) Part 20 and the requirements in TS Sections 6.2, 7.0, and 12.1.2:
- Dosimetry records for facility personnel for the past two years
- Radiological signs and posting at the entrances to controlled or restricted areas * Calibration and periodic check records for portable and fixed radiation monitoring instruments
- Training Log records documenting radiological safety training for facility personnel from 2014 to the present
- Radiation protection and reactor surveillance and survey data from 2014 to the present recorded on: - Neutron Instrument Calibration forms
- Swipe Count Sheet forms completed quarterly
- ARRR Pool Water Analysis forms completed monthly
- Air Filter Paper Counting Sheet forms completed weekly - Aerotest Operations, Inc. Monthly Radiation Survey forms - Aerotest Operations, Inc. Quarterly Instrument Calibration forms
- Aerotest Operations, Inc. Quarterly Maintenance Check List forms
- Section VI of the ARRR Procedures Manual entitled, "Radiological Safety Procedures," PCN No. 3, RSC approval dated April 29, 1996
- Section VIII of the ARRR Procedures Manual entitled, "Maintenance Procedures," PCN No. 2, RSC approval dated January 14, 1993
- "ALARA and Radiation Protection Program for Aerotest Operations, Inc.," updated August 14, 2004 The inspector also observed the use of dosimetry and radiation monitoring equipment during tours of the facility including various offices, support areas, and the Reactor Bay.
a. Observations and Findings
- 8 - (1) Surveys Radiation and contamination survey results indicated that licensed activities were being conducted in accordance with operating procedures.
The inspector noted that the quarterly radiation surveys were completed
more frequently than required, i.e., typi cally every month. The results of the surveys were documented on the applicable forms and were evaluated as required.
During the inspection, the inspector accompanied the RSO during a tour of the facility. The radiation levels were checked in various areas throughout the facility. The radiation levels detected during the tour were similar to those noted during previous surveys which had been documented on facility survey maps. No anomalies were noted.
(2) Postings and Notices During tours of the facility, the inspector observed that caution signs, postings, and controls in the restricted or controlled areas were acceptable for the hazards involving radiation, high radiation, and radioactive material storage areas and were posted as required by 10 CFR Part 20, Subpart J. Radiological signs were typically posted at the entrances to controlled areas.
Copies of current notices to workers were posted in various areas in the facility including the hallway in the Reactor Bay just outside the Control Room. Other postings also characterized the industrial hygiene hazards that were present in the areas as well. The inspector noted that the copies of NRC Form-3, "Notice to Employees," posted at the facility as required by 10 CFR Part 19.11, were the current version.
(3) Dosimetry The inspector determined that the licensee used thermoluminescent dosimeters (TLDs) for whole body monitoring of beta and gamma radiation exposure (with an additional component to measure neutron radiation). The licensee also used TLD finger rings for extremity
monitoring. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. An examination of the TLD results indicating radiological exposures at the facility for the past two years showed that everyone's occupational doses were well within 10 CFR Part 20 limitations.
The inspector verified that NRC Form-5 reports had been completed and provided to each employee who had received exposure at the facility during 2013 and 2014.
(4) Radiation Monitoring Equipment
- 9 - Examination of selected survey meters indicated that the instruments had the acceptable up-to-date calibration sticker attached. The instrument calibration records indicated calibration of portable survey meters was typically completed by licensee personnel and occasionally by a contractor. The inspector verified that the calibration of portable instruments was being verified quarterly as required by procedure.
Calibration records were being maintained as required.
(5) Training Training records showed that personnel were acceptably trained in radiation protection practices. Newly hired personnel were given individual training to acquaint them with radiation terminology, health risks, natural and work-related sources of radiation, and allowable limits.
A test was given following the training to demonstrate that the individuals understood the material. Annual refresher training was provided to all staff members by the facility RSO. The most recent refresher training sessions had been conducted on May 20, 2014, and May 26, 2015. It was noted that, in 2015, each radiation worker at the facility had completed on-line training and had completed a quiz following the training. A review of the topics covered during the training indicated that
the appropriate material had been used.
(6) Radiation Work Permit Program
The inspector noted that the licensee had initiated a more extensive
Radiation Work Permit (RWP) program than they had had in the past at the facility. All visitors entering a Radiation Area at the facility were required to sign in on a specific RWP. Also, persons entering those areas received a Visitor Orientation and signed a form acknowledging the training.
(7) Documentation of the Radiation Protection and ALARA Programs The Radiation Protection Program was established and described in the ARRR Procedures Manual,Section VI, entitled "Radiological Safety Procedures," and in the ARRR Reactor Operator Training Manual, Volume 5, entitled "Radiological Safety." The program had not changed since the last inspection. The licensee reviewed the Radiation Protection Program at least annually in accordance with 10 CFR 20.1101(c). The last review, which was completed August 13, 2015, included all areas of
the program.
The ALARA Program was outlined in a licensee document entitled, "ALARA and Radiation Protection Program for Aerotest Operations, Inc." The program appeared to be adequate for the facility. The latest review of the ALARA Program was also completed on August 13, 2015.
- 10 - (8) Facility Tours As noted above, the inspector toured the facility on various occasions and observed activities in offices, support areas, the Reactor Bay, and the mezzanine area. Through observations of, and interviews with, licensee staff, the inspector confirmed that personnel complied with the signs, postings, and controls. The facility's radioactive material storage areas were noted to be properly posted. No unmarked radioactive material was detected in the facility.
c. Conclusion The inspector determined that the Radiation Protection and ALARA Programs, as implemented by the licensee, satisfied regulatory requirements. Specifically, 1) surveys and associated checks were completed and documented acceptably to permit evaluation of the radiation hazards present; 2) postings met regulatory requirements; 3) personnel dosimetry was being worn and recorded doses were within the NRC's regulatory limits; 4) radiation survey and monitoring equipment was being maintained and calibrated as required; and, 5) radiation protection training was being conducted for facility personnel.
8. Environmental Monitoring a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and TS Sections 3.1, 7.2, and 7.3:
- Air Filter Paper Counting Sheets for the past two years
- Environmental dosimetry records for the past two years
- Radioactive Liquid Waste Holding Tank release records
- Section VI of the ARRR Procedures Manual entitled, "Radiological Safety Procedures," PCN No. 3, RSC approval dated April 29, 1996, outlining the licensee's environmental monitoring program b. Observation and Findings The inspector reviewed the calibration verification records of the area, water, and stack monitoring systems. The calibration of these systems had been checked semiannually in accordance with procedure. If a system failed verification, a full calibration was then conducted. The inspector also reviewed the records documenting the fact that, because the reactor had not been operated since 2010, there had been no liquid and airborne releases to the environment for the
past several years.
Through records review and interviews with licensee personnel, the inspector noted that the last time the licensee had released any waste water was in 2009.
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This was done under the controls specified by procedure and in accordance with the regulations. It was also noted that the galvanized steel Waste Water Hold-up Tanks used in the past were old and rusted in some places. This condition could have eventually led to a possible unmonitored release to the environment.
However, this problem was resolved when the licensee installed two new polyethylene Waste Hold-up Tanks in March of this year (2015) with the capacity of 2,000 gallons. A secondary containment was also installed surrounding the tanks. It consisted of interlocking fiberglass berms with a thick plastic fabric liner. The system is currently functional. A radiation detector will be installed adjacent to the tanks to detect any radiation level increase from any waste water added.
On-site and off-site gamma radiation monitoring was completed using environmental TLDs in accordance with the applicable procedures. These data indicated that there were no measurable doses above any regulatory limits.
Through observation of the facility, the inspector did not identify any new potential release paths.
c. Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
9. Transportation a. Inspection Scope (IP 86740)
In order to verify compliance with the requirements of 10 CFR 71.5 for shipments of licensed material, the inspector reviewed the following:
- Personnel training records
- Shipping records for the facility
- Selected facility records from 2010 through the present The inspector also interviewed licensee personnel regarding shipments of radioactive material.
b. Observations and Findings Staff interviews and records reviews showed that the licensee had not completed any radioactive material shipments since the last inspection. The inspector reviewed the licensee's program for transportation of radioactive material and determined that it was adequate. The inspector noted that three staff members had received the training for shipping radioactive material and/or dangerous goods as required.
- 12 - c. Conclusion The program for transportation of radioactive materials satisfied NRC
requirements.
10. Exit Meeting Summary The inspector reviewed the inspection results with members of licensee management at the conclusion of the inspection on August 19, 2015. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Bauman Nuclear Engineer and Senior Reactor Operator F. Meren Reactor Supervisor and Reactor Operations Manager T. Richey Neutron Radiography Manager General Manager and Radiological Safety Officer M. Wilkinson Quality Assurance Manager Other Personnel
P. Peterson Chair, Department of Nuclear Engineering, University of California-Berkley, and Chair, Reactor Safeguards Committee, Aerotest Operations, Inc. R. Varosh Consultant and member, Reactor Safeguards Committee
INSPECTION PROCEDURE USED
IP 69001 Class II Non-Power Reactors IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened None
Closed None LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System ALARA As Low As Reasonably Achievable ARRR Aerotest Radiography and Research Reactor CFR Code of Federal Regulations E-Plan Emergency Plan kW kilowatt LOA Letter of Agreement N-Ray neutron radiography NRC U.S. Nuclear Regulatory Commission PCN Procedure Change Notice RSC Reactor Safeguards Committee SRO Senior Reactor Operator TS Technical Specifications