ML14164A726

From kanterella
Jump to navigation Jump to search
NRC-018 - Letter from Jay Silberg, Counsel, Aerotest Operations, Inc., to NRC Document Control Desk, Response to Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC to Supplement the License Transfer (Redacted)..
ML14164A726
Person / Time
Site: Aerotest
Issue date: 07/19/2012
From:
NRC/OGC
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 26038, ASLBP 14-931-01-LT-BD01, 50-228-LT
Download: ML14164A726 (31)
v • d • e


Text

NRC-018 Submitted: June 13, 2014 NOTE: Attachments to this document contain confidential information submitted under 10 CFR 2.390. This information is Business Confidential to Aerotest and Nuclear Labyrinth and is identified with brackets as such [] or in the case of attachments in their entirety.

July 19,2012 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-98.

RESPONSE TO REQUEST TO AEROTEST OPERATIONS, INC. AND NUCLEAR LABYRINTH LLC TO SUPPLEMENT THE LICENSE TRANSFER APPLICATION (T AC NO. ME8811)

Ladies and Gentlemen:

Enclosed please tind the response of Aerotest Operations, Inc. ("Aerotest")

and Nuclear Labyrinth LLC ("Nuclear Labyrinth") to the U.S. Nuclear Regulatory Commission's Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC to Supplement the License Transfer Application dated July 5, 2012 including supporting affidavits on behalf of both Aerotest and Nuclear Labyrinth. Also enclosed are a request to withhold confidential information from public disclosure and a copy of the response redacting the confidential information.

Should you have any questions or require additional information regarding this submission, please contact Jay Silberg, counsel to Aerotest at 202-663-8063 or jay.silberg@pillsburylaw.com.

n:elyz:u,

~{jSi{berg Counsel for Aerotest Operations, Inc.

Enclosures July 19,2012 Page 2 STATE OF MICHIGAN

TOWIT:

COUNTY OF OAKLAND I, Michael S. Anderson, state that I am the Secretary of Aerotest Operations, Inc., and that I am duly authorized to execute and file this supplemental information on behalf of Aerotest Operations, Inc. To the best of my knowledge and belief, the statements contained in this document with respect to Aerotest Operations, Inc. are true and correct.

C/1 -

tb, ill~ ?il(pf~

Subscribed and swo_m before me, a Notary Public in and for the State of Michigan and County of Oakland, this /~;;(day of July 2012.

WITNESS my Hand and Notarial Seal:

c:~~~~

... Notary P lie ..

My Commission Expires: CANDACE MIERZWINSKI Notary Public, State of Michigan County of Oakland

~~mmlssioo ~*-** f'l'o/'i6d

. Acting! t~f_q,~iif:- (JaA/. ',

403572395vl July 19, 2012 Page 3 STATE OF UTAH

TOWIT:

COUNTY OF SALT LAKE COUNTY I, Dr. David Michael Slaughter, state that I am the Chief Executive Officer ofNuclear Labyrinth LLC, and that I am duly authorized to execute and file this supplemental information on behalf ofNuclear Labyrinth LLC. To the best of my knowledge and belief, the statements contained in this document with respect to Nuclear Labyrinth LL re true and correct.

--'1--------~-h_

Subscribed and sworn before me, a Notary Public in and for the State of Utah and County of Salt Lake, this 1r day of July 2012.

WITNESS my Hand and Notarial Seal: h=iJ~ NotafYlltiljlic ~

My Commission Expires: ~sad4Date "- l1l1 6 NOTARY PUBLIC DOWEL KING 652053 COMMISSION EXPIRES FEBRUARY 01, 2016 STATE OF UTAH 403572400vl July 19, 2012 Page 4 Enclosures

1. Response to Request to Supplement License Transfer Application-proprietary copy
2. Response to Request to Supplement License Transfer Application- non-proprietary copy
3. Request to Withhold From Public Disclosure cc: U.S. NRC Office ofNuclear Reactor Regulation!NRLPO U.S. NRC Region IV, Regional Administrator NRC, NRR (Traiforos)

NRC, OGC (Uttal)

NRC, OGC (SatTord)

Aerotest Radiography and Research Reactor Docket No. 50-228 Enclosure 2 Non-proprietary Copy July 19, 2012

1. Provide all of the general information for any Nuclear Labyrinth-owned entities in the ownership chain that may not have been included in the application, including the names, addresses and citizenship of the principal officers.

There are no additional Nuclear Labyrinth-owned entities in the proposed ownership chain ofAerotest Operations, Inc. ("Aerotest"). As stated in the Application for Approval of Indirect Transfer ofControl ofthe License Pursuant to 10 C.FR. § 50.80 dated May 30, 2012

(Application), Nuclear Labyrinth LLC (Nuclear Labyrinth") will become the owner of all shares ofAerotest. Nuclear Labyrinth was created to purchase the shares ofAerotest and is managed by its Chief Executive Officer ('CEO) and sole owner, Dr. David M Slaughter, PhD. to the Application provides the post-transfer organization chart demonstrating the ownership chain ofAerotest. Attachment 4 to the Application provides the names, addresses, and citizenship of directors and principal officers of both Nuclear Labyrinth and Aerotest as of the effective date of the transaction. In simplified form the ownership chain vvillbe as follows:

2. Since there were no sources of funds identified in the application, provide the source(s) of funds to cover the projected operating costs identified in the Projected Income Statement included in Attachment 7 of the application, pursuant to 10 CFR 50.33(f)(2). Specifically, state ifthere are any committed sources of funds (e.g., commercial, government, educational) for operations of the Aerotest Radiography and Research Reactor (ARRR) facility, and provide any applicable commitments, letters of intent, or contracts with these sources of funds.

PROPRIETARY- BUSINESS CONFIDENTIAL TRADE SECRET Confidential information submitted under 10 C.P.R. § 2.390 Withhold from public disclosure under 10 C.F.R. § 2.39 403575635vl

3. State if there are any contracts between Autoliv and Nuclear Labyrinth to provide twelve months of operating expenses as well as the initial decommissioning trust fund contribution of $3,285,800.

PROPRIETARY- BUSINESS CONFIDENTIAL TRADE SECRET Confidential information submitted under 10 C.F.R. § 2.390 Withhold from public disclosure under 10 C.F.R. § 2.39

4. Provide Nuclear Labyrinth's latest annual financial statements.

Nuclear Labyrinth was created for the purpose ofpurchasing the shares ofAerotest. As a newly created entity, it has no financial statements to submit.

5. Since future funding is expected to be provided from decommissioning fees charged to users of the ARRR for the first five years of operation, state if there are any commitments, letters of intents, or contracts entered into with potential users of the ARRR and, if applicable, provide these documents for review, pursuant to 50.75(d)(2)(iii). In addition, state the method of providing decommissioning funding assurance after the first five years of the projected license transfer.

As discussed in the response to request 2, there are no commitments, letters of intent, or contracts entered into with potential users of the ARRR. As provided in the Funding Agreement, a decommissioning trust fund will be established at the closing of the transaction and vvill be funded according to the current estimate of decommissioning costs, $3,285,800. In order to assure the adequacy of the decommissioning trust, it is Nuclear Labyrinth 's intention to implement a fee structure that can easi~v accommodate changes in decommissioning cost estimates. In the initial five years of new ownership, a fee consisting offive percent of the unadjusted cost will be assessed to work that uses the ARRR. After five years, the assigned decommissioning fees applied to the use of the reactor will be evaluated for adequacy. These fees may continue to be assessed at the current level, or be changed (increased or reduced) in accordance with updated decommissioning cost estimates. A nel-t' decommissioning cost estimate will be prepared as part of the recurring biannual review and update of the study provided in of the Application.

6. Attachment 10, Conforming Amendments, is based on a previous application for license transfer that was never approved. Submit Attachment 10 using the current license and technical specifications, marked up to clearly show all insertions, deletions and revisions.

Attachment 2 to this response provides conforming markups of the current ARRR license and technical specifications. These marlrups also include correction of historical typographical errors.

2 403575635vl Attachments:

1. Funding Agreement
2. Conforming Amendments 3

403575635vl ATTACHMENT (1)

PROPRIETARY- BUSINESS CONFIDENTIAL TRADE SECRET Confidential information submitted under 10 C.F.R. § 2.390 Withhold from public disclosure under 10 C.F.R. § 2.390 FUNDING AGREEMENT 403575635vl ATTACHMENT (2)

Conforming Amendments 403575635vl UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON, .c.c. 20545 AEROTE~_T OPERATIONS, INC.

DOCKET NO. 50-228 AEROTEST RADIOGR.~PRY AND RESEARCH P..EACTOR (AP-RR)

  • .AHENDHENT 'IO FACILITY OPEF.ATING LICENSE

. 'L Amendment No. ~

Nu.Wn.;r ~~ u.kl:k'l'"'f Licen.se No. R-98

1. The irtaud .c Eae:tg:r Commission (the .Commission) has fotm.d that:

. \'1'.(.\\(e(...t . . . ~

1

,, ~,

a.nd IJ{).f)..Ro-V J.V<PII1 u1

    • 'tYI

/

LLL A. Tlie apnlicntion for 1--tr.ansfer of ]icense le-d bv. OEb I;:A~ .. for Aarotest Operations, Inc. (the licensee) compli~s with the stc.r..:l.ards e.nd rcqui::e&:::ents cf the Atomic Er.e.rgy Act. of 1~5:4, c.s ame.r.ded *(the *Act)," and the* Conunission 1 s rules and -regulations set. forth in 10 CFR Chapter I; .

B. Construction of the facility has been substantially complet&d in coaformity with Construction Permit No. CPRR-86, and the application, as amended, the provisions of the Act and the rules and regulations of the Commission; /.

c. The facility will. operate in conformity with the applicat:im\, as amended, th~ provisions of the Act, and the rules and regulations of the Commission; .

D. There.is ~easonable assurance: {i) that the activities authorized by this operating license can be conducted without ~ndangering the health_and safety of the public, and (ii) that such activities will be conducted in.compliance with the rules and regulations of the Commission; E. Aer.otes~ Operations, Inc. is technically and financially qualified to possess, use, and operate the facility in accordance wit:h the rules and regulations of the Commis~ion;

--~

'\~J F. The issuance of this operating license will not be inimical to the common defense and security or to the health and safety of th.e public, and does not involve a *significant hazards con-sideration; G. The *receipt,. possession, and use of byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in '10 CFR Parts 30 and 70, including Sections 30.33>> 70.23, and 70.31; H. The licensee is qualified to be the holder of the license; and I. The transfer of the license*is otherwise consistent with applicable provisions of law, regulat~ons, and orders issued by the Commission pursuant thereto.

2. Facility Operating License No. R-98, ~e,.ioaJ<ssued to Aerojet: General:

.f:orfl:'rraeion, +/-s hereby traa~ferrsd t;e' erotest Operations, Inc. aad tb:e

~iee:ask_is :aissmed in its entirety:~o .read as follows* 15 he:/e.b'f 1nd1Yec+l)'

+-re..;..'"JS w-ed *t-c !..Juc..lecul* 1-ct.byn nt"h L..LC..

A. This license applies to'the Aerotes~~diography and Research Reactor .

(ARRR}, preyiously called the Aerojel: Gen:era~ Nuclear ;I:ndustri~ Ae!"cfr~.

Reactor (AGNIR), a pool-type nucl~~ reactor owned byu the* rJEA"'I Inc. 0 t:et~b~

The facility is located at th~ Aerotest Operati~ns site near San . ~VJG..J Wh1&;

Ramon, California, and is described in the application dated 1S owned September 14, 1964 (the application), and in supplements thereto, 1c1 Nu.<!.lc'llr including the application. fa~ tr~nsfer of license dated April 24, \...O.bl'VInth 1974,: ~VICl*+-k. i.<.pp li~hc.Yn fZrf lt1tl.tret.-1-' -h-ay;s(-.r- do.tecl Mo.)' 3D 12.Dl2., u...c B. Subject to the-conditions and requirements incorporated herein, the Commission hereby licenses Aerotest Operations, Inc.: *

(1) Pursuant to Section 104c of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Faciliti.es11 , to possess, use, and operate the reactor at the designated location in San Ramon, California, in accordance with the procedures and limitations set forth in this license; (2) Pursuant to the Act and 10 CFR Part 70, 11 Spec.ial Nuclear Material11 , to receive, possess, and use up to 5.0 kilograms of contained uranium 235 in connection with operation* of the reactor; . and

. _ (3) Pursuant to the Act: and 10 *cFR Part 30, 11 Licensing of Byproduct Mater:l.al .. , (1) to receive, possess, and use a 2 curie americium-beryllium neutron startup source, and (2) to possess, but not to separate, such byproduct material

  • as may be produced by operation of the reactor.

\.*

-I' J--'-__.:_ __ _

-(~

~~J

c. This license shall be deemed to contain and is subject to the condi.tion:;o specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subj~ct to all applicable provisions of the Act and to the rules~ regulations~

and orders of the Commission now or hereafter in effect; and is subject to the additional conditions* specified or incorporated below:

(1) . 1-ia.x.imum "Pot-~er Level The licensee is authorized to operate the facility at steady state power levels not in excess of 250 ld.lmvatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised, are hereby incorporated in the license. The license.e shnil *operate the facility in accordance with the Technical Specifications, as revised by issued changes thereto through Change No. 8.

() D. Rcpo1*ts In addition to reports otherwise required under this license and applicable regulations:

(1) The licensee shall report in writing to the Commission uithin 10 days of its observl*d occurrence any incident or condition relating to the operation of the facility which prevented *or could have prevented a nuclear system from performing its safety function as described in the Technical Specifications or in the Hazards Summary Report.

1 (2) The l_icensee shall report to the Commission in writing within 30 d~ys of its observed occurrence any *substantial variance disclosed by operation of the facility from performance speci-fications contained in the Hazards Summary Report or the Technical Specifications.

(3) The licensee shall report to the Commission in writing within 30 days of its occurrence any significant change in transient or accident analysis, as described in the Hazards Summary Report.

E. Records

'\

  • .:J In addition to those otherwise required under this license and appli-cable regulations, the licensee shall keep the following:

4-(1) Reactor operating records, including power levels.

(2) Records of in-pile irradiations.

(3) Records showing radioactivity released or discharged into the air _or water beyond the effective control of the licensee*as measured at the*point of such release or discharge.

(4) Records of emergency reactor scrams, including reasons for emerge.IJ.cy shutdowns.

F. This amended license is effective as of the date of issuance and shall expire at midnight April 16, 2005.

, Nt.te.lecu' D~. J_ L, r'-.Q_gu~LLI0"" v 1

FOR THE .M'OMIG ENER~ COMMISSION

/J£G~

Karl R. Goller, Assistant Director for Operating Reactors Directorate of Licensing Attaebment:

Change Ng. S te the Technical Sped fica.tieas Date. of Issuance: October 22, 1974 APPENDIX A

-~__j,..,..,...., LICENSE NO. R-98"

~*

TECHNICAL SPECIFICATIONS FOR THE AEROTEST RADIOGRAPHY AND RESEARCH REACTOR(ARRR)

  • 1. 0 Definitions l.l Shutdown The reactor~ With fixed experiments in plac~. shall be considered to be shut down (not in operation) whenever all of the following cond~tions have been met: (a) the console key is in the* "of£ 11 position and the key is removed from the console and under* *the control of a licensed operator (or stored in a locked storage area); (b) sufficient control rQds are insertea so as to assure the reactor is subcritical by a margin greater than 0.7% delta k/k cold, clean critical condition; (c) no work is in progress involving refueling operations or maintenance of its control rod mechanisms.

1.2 Reactor Operation Reactor operation shall mean any condition ~herein the reactor is not shut

  • ' *')

'\,,,_..i_*-

  • , . down.

1.3 Operable A system or co~ponent shall be considered operable when it is capable of performing its required function in its normal manner.

1.4 Operating A component or system is operating if it is performing its required function in its normal manner.

1.5 Experiment Experiment shall mean any apparatus, device, or material installed in the core or experimental facilities (except for underwater. lights, fuel storage _racks and the like) which is not a noDilB.l part of these facilities*.

1.6 Experimental'Facilities Bxperimental.facil~ties shall mean Glory Hole, vertical tubes, pneumatic transfer .~ystems, central thimble. beam tubes, thermal column, and in-pbol irradiation facilities.

1.7 Reactor Safety Circuits

~ Reactor safety circuits shall mean those circuts, including their associated*

'-**** ***-*****----*****-***-----*-***-**- -~------- *---**--------***-----*---

.~

t**.<*

~

input circuits, which a~e designed to -initiate a reactor** scram.

2.0 Reactor Site 2.1 The reactor and associated equipment is located within an exclusitin area.

2.2 A steel,. locked perimeter fence shall surround th~ ARRR faciltty, forming an exclusion area~ The minimum distance from' the center of th~ reactor poo~ to the boundary of the.exclus1on area fencing shall.be 50 feet. The restricted-area, as defined-in 10 CFR 20,

  • shall consist of the entire exclusion area. .

2.3 The principal ~ctivites carried on within the exclusion area*shall be those associated with the operation of the ARRR reactor and the use of a hot cell ~d chemistry-laboratory.

3.Q *aeactor*iuilding 3.1 The reactor shall be housed in a steel building capable of meetin~.

the *fallowing functional requirements:

3.1. all circulating fans and air conditioning systems except the system which supplies air to the control room shall have the capability to be ~hut off from a single control in the' control' room.

3.1.2 ventilation shall be achieved by gravity ventilators'located on the roof of the building, and 3.1.3 a positive air-pressure shall be maintained in the control room with respect to the reactor*room.

3.2 An a~arm system'shall be installed to detect unauthorized ~ntry into the reactor building. The alarm system shall be *monitored constantly and its annunciation shall be tested monthly.

4.0 Reactor Popl (Primary System) 4.1 The minimum depth of water above the top of the active core shaU be 16 ft. The maxim~ bulk water temperature .shall be 130°F and

  • the minimum 60°F.

4.2 The pH and conductiv~ty of* the p~imary coolant shall .be measured at least once each month. Corrective action shall be taken to avoid exceeding a pH of 7.5*or a conductivity of 5 umno/cm.

l 1 ..

. \..:'"-..

~ -*** -------* ~--** -------*. *-* ----*-** *******------------------------------------------******--**------ ....*...*.. ----------------------*--*--***-******-----------------

i.

5.0 Reactor Core 5.1 Fu.el Elements 5.1.1 The reactor shall contain no more than 90 TRIGA type fuel elements. The co~e shall be loaded with not more* than 3.30 kg of U-235.

5.1.2 The maximum excess reiictivity above cold, clean criti.ca1~

with or without experiments in place, shall be 3 dollars.

5.1.3 The bath temperature coefficient and the prqmpt fuel temp-eraturlf*'*C"oefficient shall be negative at all operating *temp-e~atures an4. the minim'I;IDl r~ctivity decrement at full .power shall be 80 cents when measured with respect to source power level.

5.1.4 The coolant void coefficient shall be negative across the active core. Maximum ~-core operating void shall be 10%

of tQe coolant core volume as defined by a cylinder bounded by the grid plates.

5.2 Reflector Elements 5.2.1 ~e overall reflector elements' dimensions shall be the sa~e as

~

':J--

{ .

  • -- the fuel elements.

5.3 Control Elements 5.3.1 The reactor shall be subcritieal by a minimum margin of 0.50 dollar when .the maximum* worth rod is fully withdrawn from the core.

5.3.2 The maximum rate of reactivity addition for the control rods shall be 11 cents/second. There shall be a min~ of three operable control elements.

5.3.3 The total time for insertion of the control rods following receipt of a scram signal by the safety system *shall be a maximum of' 600 milliseconds.

6.0 Reactor Safety Systems 6.1 '.The reactor. safety system shall include sensing qevices and associated circuits which automatically actuate visual and audible alarms and, when certain pre-set li.pdts are exceeded, scram the reactor.. The systems shall be fall-safe(de-energizing shall ca~se a scram) Tab'!e 1 describes the minimum requirements of the safety system.

    • J*-*

(~ ...

\:

~

\"*

6.2 The nuclear, process and radiation monitoring instrumentation shall provide the functions and have the set point ranges and associated annunciations listed in Table-2 of these specifications.

  • 6.3 The.safety system shall be designed such that no single component failure or circuit fault shall e~~o~s~' disable both the auto-matie and manual scram circuits. .Slm~\+ctr"\e..Ot.t~kt 6.4 Reactor sequence, interlocks and safety.circuits shall remain operabl~

while fual is in the core except that one chP~el may be removed for maintenance purposes when the reactor i.s. shut* down..

6.5 Interlocks shall prevent safety rod withdrawal unless all of the following conditions exist:

  • 6.5.1 The master switch is in the ON position; 6.5.2 The safety system has been reset; 6.5.3 All four nucle~r instruments channels are in the OPERATE mode; 6.5.4 Th~ startup channel count rate is greater than 2 cps.

---} ~.5. S It sliall not be possible to withdraw more t;han the s~ety*.rod .until it has reached the upper limit iOterlock, at which time either the shim or regulating* rod may be moved~ but only one at a t~e.

6.6 During a critical experiment ~ subcritical multiplicatio~ plots shall be obtained from at least three .instrumentation channels.

These ~hannels may be*u~ed in addition to the.normal operating.

instrumentation in Tabl~ 1.

6.7 Pro~ess instrumentation with readout in the control room sha1l be

. operating to permit continous indication of pool water temperature and conductivity. Alarms shall be operable to indicate low water flow, law. pool water and improper location of the crane bridge, 7.0 Radiation MOnitoring 7.1 A fixed gamma monitor employing Geiger tube detectors shall be ~

located on the wall connecting the control room and the reactor room. This monitor shall serve as both an area *radiation *monitor and a criticaljty alarm and will ~unciate through an automatic monitoring system to the San.Ramon, California, Fire Department and actuate a siren within the reactor building on high radiation level. The monitor shall have a min:il!Ium range of 0 to* 20 mr/hr.

The annunciation and the siren actuation shall be tested monthly.

t~

I :

\...;.;

---~----

- ----* .. ---*- ...... -*----------. - ***--**********- ****----~*****--* --*- ---*-------*-**---*-~*-****-*-**--------

/}_

! *2)'* . . *.-

7.2 During reactor operation, a gas sample shall be continuously withdrawn from the *roof vent above ~he re_actor, or from. the .*Ar.f.~tj' of the re-actor core, and pumped through a r~dioactive gas detector chamber. The

  • gas chamber ..shall be titonitored by *a. beta-gamma qetector whi~ch shall have a continuous readout in the control room. An annunciato_r shall indicate when the gas exceeds 4 mr/hr.

7.3 A f-ission product* water mOnitor shall be *attached to ._,the process water cleanup system !oop 1:!-djacent to.the'demin~raJ.;izer ~d shall: provide con-tinuous indication in the *control room. High _radiation :1~ve1s within .

the demineralizer or pool water shall annunciate an audible alarm on the reactor console. The range of the mo~itor shall be from 0.1 to 100 mr/hr.

7.4 Portable survey instruments for mea~uring beta~gamma dose rates in the iange of 0.01 mr/hr *'to 50 r/hr shall be available to the fa,cility.

7. 5 Portabl_e instruments for measuring fast and. thermal neutron dose rates fr~m*O.l mrem/hr-to* 1.0 rem/hr shall be available at the facili~Y*

7*.6 Radiation detector packets contaui:tng_ a series 'of threshold detectors-

' _,-) .

\ ,. . . . -4 shall be placed *at several 'loca-tions within the rea.cto1: building for post-accident radiation *.an~sis:

8.0 Experimental Facilities 8.1 Large-Componerit Irradiation Box 8.1.1 A large-component irradiation box s~all have a maximum volume of 20 cu *.'.:f.eet *. *,The box shall _enco~pass. not mo~e ~ban 120° arc of the core _and shall be designed so that it can be placed no close~ than 5 em to the outer row of active fu~l elements.

8.1.2 The platform sha11 be positioned r~tely relative to the reactor core by a positive drive and shall be cap-tive to the stand which is bolted to the floor of the tank. Positive

. . I ' . .

mecha~cal stops shal~ prov~n~ moving the ~pe~iment box into the active reactor core. co2 shall be used for purging and to mainta~~-a slight po~itive pressur~ in the box relative t9 the

  • pool wat.~r p~ess~e.

I .

~;--* _..

8.1.3. ~o remove._or -i~stall the. experiment box, the piatform shall be mpved two or more feet away from the reactor core.. The box shall then be lowered onto ~h~ platform and bolted in place wit~ remote handling equipment. The voided box shall be purged of air prior to exposure to neutrons. *

,~ 8.2 Pneumatic'Transfer Facility

.~

f. ..

\.._J 8.2.1 A pneumatic transf~r facility may be loc.ated in any reactor core position. . The facility shall be operated ~itb dry C02 and. ex-hausted through a filter ventilatign system, which is monitored for radioactivity.

  • 8.2.2 The in-core portion of the transfer facility shall have a max-imum void volume of 34 cu. in. in the active fuel region. A manual control shall be provided which is capabl~ of over~iding the automatic-timer control.

8.3 Glory Hole Facility 8.3.1 A dry glory hole facility may be located in any reactor core position.

The glory bole shall accept capsules to a maximum of 1.35 in. in diameter.

8.3.2 The glory hole shall.be purged with CO to prevent f'ormafti.On. of ex-cessive amounts of argon-41. Gas samples sh~ll be taken near the pool wben the glory hole facili~y *is' operated without' a shield plug to insure adeq~ate monitoring of radioact~ve gases. J-=--:oo.

( .

8.4* 'Neutron'Radiogtaphy Facility -

8.4.1 The beam tube shall consist of a two-section tapered tube having a rectangular cross section. The upper and lower sections of .the tube shall be equip~ed with a fill and drai~ line.

  • 8.4.2 All components contacting the pool water.shall be fabricated from aluminum or stainless steel.

8~4.3 The beam catcher shield shall consist of a*movable radiation shield.

8.5 Thermal Column 8.5.1 The thermal column shall be positioned remotely on st~el*Iocating pins immediately adjacent to the rea.ctor c~re.

8. 5. 2 . The thermal column shall be composed. of a three-foot cube of grap-hite encased in aluminum containg five rows of 1.5 in. diameter' irradiation holes. The rows shall be.placed 6 inches apart and co~ain seven holes per row. Slotted beams shall be provided to allow experiments to be attached directly to the thermal column.

8.6 Vertical Tube 8.6.1 Vertical irradiation tubes, having diameters up to 6 in ** may b.e attached to the thermal column.

....'* *') 8.6.2 The ~ertical tube shall be purged with co 2 to prevent the formation of excess amounts of ~rgon-41.

8.7 Other Irradiation Facilities 8.7.1 The central 7 fuel elements of the reactor may be removed from the core and a ._central 'irradiation facility installed ~ravided the cross-section area of the.facility does not exceed 16 in ~

  • 8.7.2 Two triangular exposure facilities are available which shall allow the insertion of circular experiemnts to a maximum. of 2.35 in. dia-*

met;er or triangular experiments* ~o a maximum of 3.0 in. on_ a side.

8.7.3. Irradiation capsules in the shape of dummy fuel elements shall have a maximum *inner void volume of 34 cu. in. in the active fu.el region.

9.0 Experiment Limitations 9.* 1 Experiments shall be evaluated in* the most reactive condition.

9.2 The documentation of experiments, which shall be reviewed and app-roved prior to* in*sertion in the reactor, .sha11 include at least; 9.2.1 The purpose of the experiment; 9.2.2 A description of the experiment; and 9.2.3 An analysis'of the possible hazards associated with the per-formance of the experiment *

.9.3 The value of the react~vity worth of any single independent experiment shall not exceed 2 dollars. If sucb_experfments are connected-or other-wise related so that their combined reactivity could be added to the core simultaneously, their combined reactivity shall not exceed 2 dollars.

9.4 The reactivity worth of any single independent expe~ent not rigidly fixed in place shall not exceed 1 dollar. If such experiments are*

connected or otherwise related so that their combined reactivity could

  • be* added to the core simultaneously t their combined reactivity wQr~h shall not exceed 1 dollar.

9.5 No experiment shall be installed in the reactor' in such a manner that it could shadow the nuclear instrumentation sys~em monitors~

.J

l7

.~;.::,;-
9. 6 No experiment shall be installed in the reactor in such a manner that a failure could interfere with the insertion of a reactor control <<lement.
  • 9. 7 No experiment shall be performed involving materials which could:

9.7.1 Contaminate the reactor pool causing corrosive action on the reactor components or experiments; 9.7.2 Cause excessive production of airborne radioactivity; or 9.7.3 Produce an uncontained violent chemical reaction.

  • * . 1nvolvin~

9.8 Experiments shall not be performed -i~*eleu*a equipment whose failure could result in fuel element damage.

9.9 *The amount of special nuclear material contained iri an experi-ment shall be limited to 5 grams in the form of solid samples or 3 grams in the form of liquid. Liquid. special nuclear*materials shall be doubly encapsulated. -

9.10 Experiments having moving parts shall be"designed.to have reactivity

  • insertion rates less than 10 cent"s/ sec except tbat moving* parts worth less than 5 cents may be.oscillated or removed at higher frequencies.

9.11 Solid explosive materials may be brought into the facility for the purpose of*being radiographed in the neutron radiography facilities located above the pool; pravided that the following conditions are met; 9.11.1 Individual explosive devices shall be limited to 1000 grains equivalent TNT encased in metallic sheath~g.

9.11.2 The maximum quantity of explosive material that.may be possessed at one time shall be"lfmited to 50 pounds equivalent TNT.

9.11.3 Explosive material shall be stored in designated areas within the reactor facility.

9.11.3.1 Ollly the explosive devices. to be radiographed within 4 hrs. not to Eritce~d a maximum of ten pounds equivalent TNT~ may be removed from the storage area at one time for radiographing, in-cluding prepa~ation but excluding packaged

  • shipments.

I

  • J

-9.11.3.2 An accountability log shall be maintained to show the amount of explosive material in the reactor facility at all times, and shall contain a description of the explosive, and the location within the faci~1ty(e.g.,storage, radiographing facility, or shipping dock).

9.11.4 The maximum amount of explosive material con-*

tained in devices that may be placed in the radiography facilities at a tim~ shall be limited_to five pounds equivalent TNT.

9.11.4.1 Explosive material in the radiation field at one time shall be limited to 1 pound equivalent TNT.

9*11.4.2 Explosive material contained in long device(s) shall be limited to 0.5 pound equivalent TNT per foot.

9.12 Personnel handling the explosive devices shall be -trained and familiar with the devi~es being radiographe-d.

9.12*.1 Personnel handling the explosive devices shall use special equipment, such as nonsparking-tools and shoes, protective clothing, safety shields and grounded benches as required for the explosives being handled.

9.12.2 Unshielded high frequency generating equipment shall not be operated within 50 feet of any explosive device.

9.12.3 The explosive device shall be*subjected to a total ex-posure not to exceed 3 x loll neutrons/cm2 and 3 x 103 roentgens of gammas.

9.12.4 Explosive devices that, upon ignition~ have or provide a thrust in a definite direction shall be positioned so as to be aimed away from the reactor and components.

10.0 General Operating Limitations 10.1 Reactor operation shall be permitted o~ly when two or more personnel are in the reactor building~ at least one of whom is a licensed Operator.

10.2 The reactor shall not be operated wherever there ~re significant defects in fuel elements, control rods or control circuitry.

10.3 Upon occurrence of abnormal .operation of the reactor, including its controls, safe'ty'syste~s and auX+/-liary systems, action shall be taken immediately to secure the safety of the facility and determine the cause of the abnormal behavior.-

c.-****-*--~--------*

,....._~.

(

  • ,.__./

11.0 Fuel Storage *nd ~tansfet.

11.1 The fuel storage pits Ioc"ated in the floor of the reactor ro.om .

shiill accommodate a maximum of 19 fuel elements(700 gm u-235)in storage racks dry or flooded with water~. The fuel storage pits shall be secured with a lock and chain except during fuel transfer' ope:rations.

11.2 Additional. fuel storage racks may be located in the reactor tank, Each of these storage facilities shall be so* designed that for all conditions of moderation k eff shall not excee(i a value of o.a.

t 11.3 A fuel ~andling tool shall be **u$ed in :transferting fuel e];ements of _

I low radioactivity petween the* storage pits and the reactor; a shielded fuel transfer cask shall be used for the transfer of highly radio-'

active fuel elements. The fuel handling tool shall remain in a.locked cabinet under the cognizance of the Reactor Superv:isor when not author-bed ~or .use. people 11.4 All fuel transfersV:n the reactor tank shall be conducted by a minimum I staff :of .three~ and shall include a licensed Senior Operator and

! a li"censedOperator. The stafflllembers shall monitor the operation i using* appropriate radiation monitoring instrumentation. Fuel i transfers outside .the* reactor tarik but within the facility shall-be I

I supervised by a 'licensed Operator.

  • 11.5 Not more than one fuel element shall be allowed in the fac;ility which is not in storage or in the i::ore lattice.

12.0 Administrative Requirements

! 12.1 OrganiZation Ii

! 12.1;.1 The Reactor Supervisor shall have responsibility of the reactor facility. In all matters pertaining to reactor operations and to these Technical Specifications, the Reactor Superiisor shall be responsible to the President, Aerotest Op-erations, Inc. **

ta&ftnet'o:!n"';,""'fl~:'""' "The President, Aerotes t Operations, Inc *.
  • shall report to the Board of D:Lrectors of Aerotest O~erations, Inc. Wbi edt iReltt~es the Pz esiaeftl!:! of 'Ss ~'h: 9:SA 1 I!le: art4
  • 12.1. 2 The Radiological Safety Officer shall review and approve all procedures and experiments involving radiological safety.. He shall enforce rules, regulations and procedures relating to radiological safety~- conduct routine radiation surveys and is responsible to the Manager, Aerotest Operations,  ;"'-

~ . .

12.1. 3 The Reactor ~afeguards Commit.tee shall be composed of not* \2:*

less than five members, of whom no more than three are members of the operating organization. The commit.tee

/.**_,

shall meet on call of the chairman and they shall meet at least annually. The committee shall be responsible for, but not limited to the following:

12.1.3.1 Reviewing and approving nuclear safety.standarde associated ~th the use of the facility; 12.1.3.2 Reviewing and approving all proposed experiments and procedures and changes thereto, and modifications to the reactor and its associated components.

12.1.3.3 Determining whether proposed experiments, procedures or modifica~ions involve _unreviewed safety questions, as defined in '10 CFR 50~ Part 50.59(c), and are in accordance ~th these. Technical Specifications; 12.1.3.4 Conducting periodic audits of procedures, reacto~

.operations and maintenance>> equipment performance, and records; 12.1.3.5 Reviewing all reported abnormal occurrences and violations of these Technical Specifications, e~aluating the cause of such events and the

,-~

corrective action ~aken and recommending measures

=** J to prevent reoccurre.nce and; 12.1.3.6 Reporting their findings and.recommendations con-cerning the above to the Manager, Aerotest Operations.

12 .1. 4 The Reactor Supervisor shall have a Bachelor 1 s degree in Engineering or Physical Science and shall have a minimum of 4 years experience in the operation of a nuclear facility during which he shall have*

demonstrated competence in supervision and reactor operations. He shall hold a Senior Reactor Operator License for the facility.

12.1.5 The Radiolog'ical Safety Officer shall have a Bachelor's d~gree in Biological or Physical Science and shall have a minimum of 2 years experience in personnel and environmental radiation monitoring programs. at a nuclear facility. Certification as a Health Physicist by the Health Physics Society is acceptable in lieu of the education and experience requirements given above.

12.2 Procedures 12.2*.1 Detailed written procedures shall be provided and followed for the following reactor operations:

12.2.1.1. Normal startup, operation and shutdown of the complete

.. .J- facil-ity and of all systems and components involving

' nuclear safety of the facility.

12.2.1.2.

  • Refueling operat~ons.

12.2.1.3 Actions to be taken to correct specific and foreseen potential malfunctions of systems or components, in-cluding responses to alarms, suspected primary system leaks and abnormal reactivity changes.

12. 2.1.4 Paragraph omitted.

12.2.1.5 Preventive or corrective maintenance operations which could have an effect on the safety of the reactor.

12.2.2 Temporary procedures which do not change the intent of previously approved procedures*may be utilized on approval by a licensed Senior Reactor Operator and one other qualified individual. Such procedures shall.be subsequently reviewed by the Reactor Safe-guards C~ittee.

12.3 Records In addition to those records required under the facility license and applicable regulations, the following records shall be kept when explo-sive materials are to be irradiated or radiographed:

( -~:

12.3.1 The type and quantity of ~aterial irradiated. I .

12."3.2 Date, time of day, and length of exposure.

12.*3.3 Total neutron and gamma exposure level.

  • * *. u u Li '

TM3I.E 1 NUCLUX INST&tlMEN"l'A TION Ch:.liil'!l t De te c to.r * ...-. Mini::l:Jm

  • i II
  • Infoi:::ation Min iuu:n P.a_nge
  • lnforos tio*l t~

(Ho.) *

. S,t:n~!tiv ty Logic ~la~~nt:

  • _(_S.cr az) .

~ . Period* scrara; (a)

Startup DF3 4."5 counts/s'ec* .per Neutron flux. source level to (1) Prap:>rtional n/crJ2-se.c * *period 1 :Yatt to-.t count rate Counter . scrE.IJ Log .H Cor.Ji?en sa ted* 4 x to-14 ~p/n/ l'm..er level, to-2 Yatts to Feriod screra *

(2) ion ch11::1ber cm2 -sec period* . 1207. full power

  • .Linear Unco::1pensated 4.4 ¥ to-14 s.rnp/* PoP1~r level 30 -.;atts to* High end loY Level ion chs.:nber . n/cm-sec 1201. f~ll pow2X: le:vel-(!>) scru::ils Safety -.

(3).

Linear Colilpensated 4.4 X lo-1 4 ampi l'ower level

  • ro-1 -1.7~tts to High and low .

Level . ion chamber n/c:n2-sec* 120'7. full power level scram Safety (4) *.

(a) Sera~ on channel 1 are by-passed when sign~t on Channel .2 e~ceeds a fixed.setting similarly the high voltage ls recoved from the detecto~ and the detecto~ is shorted.

(b) Low ll:vel sermn is. b!passed on Channel 3 and 4 ~hen Channel 2 is below a fixed setting *.

T.t\Dr~F. f SAFETY SYRT!Dl FUNCTIONS No. of Switchoo *Annunciator and . "Annunciator Bnd

~ansor or Trt Pcvice or Sensor~ Sc:rom.Sct Pni t Alarm ~et Point:

Short Pcliiod j C'hs. l. 2 2* .2: 3 soc.*

. H,igh Neutron Flux '. . .

  • 1 Leve 1 : ~ns. 3, 4 . : 2 S 98'!. of* full scale and not s1:'eat:o.r than i 1207. .

fuH *power ....

. High TcmpcrDturo of '** ..

Coolant 'Water .. 1 .* .. .'

Low Pool Yater I I .

Laval.*

1 <

- 1* ft ..

tDaX decrottoo

  • Seismic' Dioturbanca* *. * -1 *: IV on modifie~

Merc:nlli Scala  : .  :

Bric;o C_rnt\0 Loct1tio111 . 1 l.fuen located off

. ' . atorasa poeition*

Lot' :.:~u tron t>a l:ec tOr .. *

\~oltago.;* Chs. 2, 3, 4 3 ~ 500 volta*

Lo~ Source* Level;. -ch. l 1 ~ 2 cps-.

Los~ of *Instrument Power; Ch. 2 l X I.ow*l:cu tron Flux; Ch~ 3 * ~5'7. o.f full

& 4, *.. 2 scnle*

1 . .* ..S 10 mr/hr .

Area. Radi.oti~n l'lonil;o~

l~ater ltadioactiv'ity. 1" .S20 mr/hF-

. }!4 Demineralizcr. W~~er Fl~Y 1 gpm * *

  • Buildins Gas Effluont Monitor l 1 . . *.
  • Not 011 ON"'
  • positi~n 1 ~utto~. ~-cr~csscd

. 'l '*

Enclosure 3 License No. R-98 July 19, 2012 Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Aerotest Radiography and Research Reactor Docket No. 50-228 Request for Withholding of Proprietary Information related to Aerotest Radiography and Research Reactor Ladies and Gentlemen:

Pursuant to 10 CFR 2.390. Public Exemptions, Request for Withholding, Aerotest Operations, Inc. (Aerotest) and Nuclear Labyrinth LLC (Nuclear Labyrinth) hereby request that certain information contained in their Response to Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC to Supplement the License Transfer Application (the "Response") be withheld from public disclosure as such information contains trade secrets, commercial information, and financial information which is Business Proprietary.

In support of our request we state the following:

1. The information sought to be withheld from public disclosure are sections of the Response to Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC to Supplement the License Transfer Application dated July 19, 2012 submitted by Aerotest Operations Inc. and Nuclear Labyrinth marked as Business Confidential including Attachment (1 ).
2. The persons making this request are Michael S. Anderson of Aerotest and Dr.

David M. Slaughter of Nuclear Labyrinth.

3. The basis for proposing that the information be withheld from public disclosure is that the information marked as Business Confidential contained in the Response is confidential business and financial information of Aerotest and Nuclear Labyrinth, which information has been held in confidence by Aerotest and Nuclear Labyrinth, is a type customarily held in confidence, is not available in public sources, and if publicly disclosed would be likely to cause substantial harm to the competitive position of Aerotest and Nuclear Labyrinth taking into account the value of the information, the amount of effort and money expended by PROPruETARY-TRADESECRET Confidential information submitted under 10 C.F.R. § 2.390.

Withhold from public disclosure under 10 C.F.R. § 2.390 Aerotest and Nuclear Labyrinth in developing the information and the difficultly with which the information could be acquired or duplicated by others;

4. If such information were disclosed to the public, Aerotest and Nuclear Labyrinth believe that competitive harm would result;
5. The Response has been marked to show locations of the information sought to be withheld.

2 PROPRIETARY- TRADE SECRET Confidential information submitted under 10 C.F.R. § 2.390.

Withhold from public disclosure under 10 C.F.R. § 2.390 Michael S. Anderson, being dully sworn, states that he is Secretary of Aerotest, that he is authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this request for the Aerotest Radiography and Research Reactor, and that all the matter and facts set forth herein are true and correct to the best of his knowledge.

~/ky~

1chael S. Anderson Secretary Subscribed and sworn to before me, a Notary Public, in and for the State of Michigan and County of Oakland, this ....J2_ day of July 2012.

.: Notary Public in and for th My CDmmission Expires:

CANDACE MIERZWINSKJ Notary Public, State of Michigan County of Oakland

. ~ ~onmission Expires May 26 2013 Actrng 111 the County of

  • 3 PROPRIETARY- TRADE SECRET Confidential information submitted under 10 C.F.R. § 2.390.

Withhold from public disclosure under 10 C.F.R. § 2.390 David M. Slaughter, PhD, being dully sworn, states that he is Chief Executive Officer, that he is authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this request for Nuclear Labyrinth, and that all the matter and f cts set forth herein are true and correct to the best of his knowledge.

Da *d M. Slaughter, PhD Chief Executive Officer Subscribed and sworn to before me, a Notary Public, in and for the State of Utah and County of Salt Lake, this I I day of July 2012.

\

Notary Public in and for the State of Utah My Commission Expires: 1cl 1 l~

NOTARY PUBLIC DOWEL KING 652053 COMMISSION EXPIRES FEBRUARY 01, 2016 STATE OF UTAH 4

Retrieved from "https://kanterella.com/w/index.php?title=ML14164A726&oldid=2511385"