Are those bubbles right at the very edge of the film, on the rebate? It's hard to tell from the scan. If so, it's possible the edge of the film "stuck" to the rim of the reel - especially possible if the reel was even slightly damp. This would prevent the developer from uniformly coating the area and could lead to these bubbles. (no dev occurs, then the agitation caused by dumping out dev and fix in changes film location on reel and "dislodges" the film enough to let in fixer, hence clear areas...)
Just a thought...