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Category:Letter
MONTHYEARML24324A3472024-11-14014 November 2024 $300,000.00 Cash Secured Irrevocable Standby by Letter of Credit as Required in Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML16333A448 ML24270A2422024-09-26026 September 2024 OIG Case 21-012 Response to OIG Letter Dated September 4, 2024 Regarding NRC-OIG Decision to Carry Over Case 21-012 Investigation Findings to Report for Case 21-016 ML24235A5122024-08-22022 August 2024 NRC-OIG_Failure_8-22-24_final ML24220A0532024-08-12012 August 2024 Response to Dr. Slaughter on Final Denial of Claims ML24197A1112024-07-10010 July 2024 Letter Regarding Denying Reimbursement for Service the NRC Did Not Perform in a Satisfactory Manner ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24134A2072024-05-13013 May 2024 Aerotest - NRC Acknowledgment Letter for CFH Program NOV EA-23-118 ML24108A0762024-05-0606 May 2024 Missing Documents on Agencywide Documents Access and Management System ML24085A2662024-03-20020 March 2024 Requesting a Comprehensive Congressional Review Be Conducted of the NRCs Performance Concerning Their Actions Associated with Aerotest Operations Inc (AO) as Outlined in NRC-OIG Investigation 021-012 and 021-016 ML24073A2182024-03-18018 March 2024 Inc. - NRC Inspection Report 050 00228/2023001, Response to Disputed Minor Violation ML23310A1122024-03-0606 March 2024 Aerotest - Letter, License Amendment 7 and SE Approving the Decommissioning Plan for the Radiography and Research Reactor ML24061A0232024-02-27027 February 2024 EA-23-118, Violation 050-00228/203-001-00lA ML24057A0102024-02-21021 February 2024 Inc - Minor Violation (TS 12.6.1) 050-00228/2023-001 and NRCs Definition of Annually ML24057A0112024-02-21021 February 2024 Inc - Response to Notice of Violation No 05000228/2020201 IR 05000228/20202012024-02-20020 February 2024 NRC Inspection Report 05000228/2020201, and Disputed Cited Violation Closed ML24054A0542024-02-16016 February 2024 Missing Documents on Agencywide Documents Access and Management System (ADAMS) ML24039A0382024-02-0808 February 2024 NRC Inspection Report 050-00228/2023-001 (Revised), and Notice of Violation ML24025A1672024-02-0505 February 2024 NRC Inspection Report 050-00228/2023-001, Disputed Cited Violation and Minor Violation Revised, EA-23-118 ML24026A0572024-01-23023 January 2024 EA-23-118 - Missing NRCs 90-day Written Response to Aerotest Operations, Inc., Response to NRC Inspection Report 05000228/2023001 and Dispute of Violation ML24011A2242023-11-10010 November 2023 Letter Informing That New Information Is Available to Show Inadequate Oversight by NRC Caused Damage to Other Non-Power Nuclear Facilities ML23279A1062023-10-0202 October 2023 Response to Violation 05000228/2023001-001B ML23255A0362023-09-0909 September 2023 Response to Inspection Report 050-00228/2023-001 ML23255A0342023-09-0909 September 2023 Response to Violation 050-00228/2023-001-00lA IR 05000228/20230012023-08-24024 August 2023 NRC Inspection Report 05000228/2023001, and Notice of Violation ML23187A0562023-07-0101 July 2023 Radiation Safety Officer Change Update ML23187A0582023-07-0101 July 2023 July 1, 2022 Thru June 30, 2023 Summary of Changes, Tests, and Experiments ML23157A0662023-05-24024 May 2023 Letter from David Slaughter, Aerotest Operations, Inc. Inadequate Oversight of Non-Power Reactor OIG Case No. 21-012 and Requested Payment for Damages Caused by the NRCs Inadequate Oversight ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22340A0062022-11-16016 November 2022 Reference Documents from Decommissioning Plan ML22215A1522022-07-21021 July 2022 Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan ML22187A0852022-07-0101 July 2022 Inc - July 1, 2021 Thru June 30, 2022 Summary of Changes, Tests, and Experiments ML22152A2522022-06-28028 June 2022 Request for Additional Information on Review of Request for Amendment to Approve Decommissioning Plan, Arrr (License No. R-98, Docket No. 50-228) ML22060A2602022-03-21021 March 2022 Change in NRC Staff Project Management Responsibility for the Aerotest Radiography and Research Reactor ML22040A1992022-03-0909 March 2022 Examination Confirmation Letter No. 50-288/OL-22-03, Reed College ML22025A2002022-01-20020 January 2022 Amendment to AO Decommissioning Plan Submittal Letter Dated July 20, 2021, Agencywide Documents Access, and Management System (ADAMS) Accession No. ML21230A304 ML21307A3242022-01-12012 January 2022 Request for Supplemental Information for Decommissioning Plan, Arrr (License R-98, Docket 50-228) ML21344A0332022-01-0303 January 2022 Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346 ML21361A0472021-12-21021 December 2021 Response to December 6, 2021 NRC Pol Issuance; the Licensee and Its Reactor Safeguard Committee Request a Reasonable Opportunity to Review and Address Short Comings of the Draft Licensee and Technical Specifications Along with the Draft Sa ML21242A4632021-12-0606 December 2021 Issuance of License Amendment No. 6 to Facility Operating License No. R-98 for the Aerotest Radiography and Research Reactor with Partial Denial of Amendment Request ML21307A1252021-10-28028 October 2021 Letter Regarding Charges Billed ML21209A5192021-07-20020 July 2021 Aerotest Radiography and Research Reactor, Response to NRC Letter Dated July 12, 2021 (ML21188A391) ML21230A3042021-07-20020 July 2021 Decommissioning Plan Submittal (Redacted) ML21147A3732021-07-19019 July 2021 Correction of Letters Regarding Closure of Confirmatory Action Letter No. NRR-04-003 and Review of Physical Security Plan ML21188A3912021-07-12012 July 2021 Inc. - Revised Completion Date Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License ML21188A2162021-07-0101 July 2021 July 1, 2020 Through June 30, 2021 Summary of Changes, Tests, and Experiments ML21193A0892021-07-0101 July 2021 Emergency Plan (Redacted) ML21181A1232021-06-22022 June 2021 License and TS Amendments ML21147A0602021-05-19019 May 2021 Response to RAI 28 and 29 ML21056A3172021-04-30030 April 2021 CFO Response to Aerotest November 11 2020 Letter ML21126A1502021-04-28028 April 2021 License and TS Amendments 2024-09-26
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AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY
- SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 August 15, 2013 Mr. Spyros Traiforos Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Mr. Traiforos:
As per my telephone conversation with you earlier today, we are reporting that during our annual fuel inspection from July 24-26, 2013, we discovered two more aluminum fuel elements with non-displaced cracks, S/N 612E and 630E. The cracks are both longitudinal cracks at about 22" from the bottom of the element, in the non-fuel area near the fuel boundary.
We are obligated to inspect 20% of our fuel elements every year, and 100% after 5 years.
Even though we did a 100% inspection in 2012, we chose to inspect all of the uncanned aluminum elements this year (55 of 104 elements in the pool) because we wanted to be aware of any possible changes that may have occurred. We compared the video from the 2012 inspection with the 2013 inspection, with the following results:
S/N 612E: This element had been removed from the core in 2005 and had been stored in the wall storage rack since then. The visible separation was not apparent in the 2012 innsnectinn A subsidiary of Autoliv ASP, INC.
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NRC, page 2 It is clearly visible now in 2013 in the same position:
Please note that the elements are mounted in our inspection fixture which we have been using since 2012. The two different inspections have the camera (which is on a pole that we move up and down) in a somewhat different angle position for each inspection effort, so the view is not precisely the same for the four still shots taken off of the video. We attempted to get the best still shot we could to show the worst view of the crack for each year. On the full video, the crack can appear longer in 2013 when the light hits it right.
S/N 630E: This element was previously one of the elements that would not fit through the upper grid plate prior to the fuel removal work done in 2012. There was a vertical line on the elements in 2012 which evidently caused much discussion among the fuel inspection crew at the time. Also present poolside was Craig Bassett of the NRC. The 2012 video (which has no audio discussion since the camera is underwater) lingers for a long time on the area in question. After shining the light around in different areas, it was decided that there was no depth for light to go into, and therefore because of the straightness of the line, it was probably just a vertical scrape caused by rubbing the element against the storage rack or grid plate while lifting it upward. All of our previous cracks were more jagged than this:
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NRC, page 3 In 2013, the vertical line appears wider, and there is now some depth similar to a groove.
Please note that the last picture is upside down from the others; we paused the video shot and took the pictures with an iPhone. For some reason, the computer flipped the image when I converted it from an iPhone to a jpeg image, but you can see the mark right down the middle. It is obvious there has been a change that has developed over the year. There is also a little pea of material in the center of the crack in two places, perhaps just an area where the clad did not open up:
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NRC, Page 4 Both of these elements still appear to have very good structural integrity. There is no obvious evidence that either of these cracks has gone all the way through the clad.
Moving the lighting around does not appear to show a deep area where light penetrates only when directly in front of the crack, therefore it seems to us that the crack is not as deep yet as some others we have seen. Since July of 2012, these elements have been stored in subcritical assembly storage racks. Therefore, these elements have not received any kilowatt hours or even been in close proximity to other elements or a neutron source while these changes have been occurring. The pool water chemistry is still extremely good, less than 2 micromhos of conductivity.
As you know, in December of 2012, we canned all of our elements that had any cracks in them, for a total of 22 canned elements so far. We do have 2 additional cans available right now, but unless the NRC would like us to consider otherwise, we would prefer not to can these elements at this time. If we can these elements, we will not be able to inspect them again without removing them from the conditioned cans. Putting them in the cans where they are in a dry environment will change the conditions for these elements. We would like to observe these elements over the next year in the same environment to see how the areas might change. This is a good opportunity to get information about cracking in aluminum elements while the elements are clearly still structurally sound. Our pool water counts remain low as they have since we canned up the other elements, so we don't believe that they are leaking any significant isotopes.
We currently own a total of 77 aluminum elements at the ARRR. There are 22 Al elements canned, conditioned, and stored at the bottom of the pool. There are 55 Al elements exposed to water in the pool storage racks. We also have 27 stainless-steel used elements that are exposed to water in the pool storage racks, and 12 unused new elements in storage.
We can make copies of the videos in question which we can send to the NRC if desired.
Kind Regards, Sandra L. Warren General Manager A subsidiary of Autoliv ASP, INC.