ML14229A087

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Official Exhibit - NRC-018-00-BD01 - Letter from Jay Silberg, Counsel, Aerotest Operations, Inc., to NRC DCD, Response to Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC to Supplement the License Transfer (Redacted) . .
ML14229A087
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: ML14229A087 (31)
v • d • e


Text

NRC-018 Submitted: June 13, 2014 1iisOur 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.

United States Nuclear Regulatory Commission O f ficial Hearing Exhibit AEROTEST OPERATIONS, INC.

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In the Matter of:

(Aerotest Radiography and Research Reactor)

July 19,2012 r.;"t}>of\ REG(I(.qJo. ASL8P#: 14-931-01-L T-8001 Docket#: 05000228 0 Exhibit#: NRC-018-00-8001 Identified: 8/12/2014 ATTENTION: Document Control Desk Admitted: 8/12/2014 Withdrawn:

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'</.,.?. o' Rejected: Stricken:

U.S. Nuclear Regulatory Commission Other:

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 (TAC 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 n:

jay.silberg@pillsburylaw.com.

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Si berg Counsel for Aerotest Operations,Inc.

Enclosures July 1 9,20 1 2 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.

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tb, il l ?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 20 1 2.

WITNESS my Hand and Notarial Seal:

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Notary P lie ..

My Commission Expires: CANDACE MIERZWINSKI Notary Public, State of Michigan County of Oakland mmlssioo *-** f'l'o/'i6d

. Acting! tf_q,iif:- (JaA/. ',

403572395vl July 1 9, 20 1 2 Page 3 STATE OF UTAH

TOWIT:

COUNTY OF SALT LAKE COUNTY I, Dr. David Michael Slaughter, state that I am the Chief Executive Officer of Nuclear Labyrinth LLC, and that I am duly authorized to execute and file this supplemental information on behalf of Nuclear 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.

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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 20 1 2 .

WITNESS my Hand and Notarial Seal: L=fJ No tafYl'tib L

lic My Commission Expires:

Date "- l1l1 6 sadi NOTARY PU BLIC DOWEL KIN G 652053 CO MMIS SION EXPI RES FEBRUARY 01, 2016 STATE OF UTA H 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, 20 1 2

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 of Aerotest Operations, Inc. ("Aerotest"). As stated in the Application for Approval of Indirect Transfer of Control of the 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 of Aerotest. Nuclear Labyrinth was created to purchase the shares of Aerotest and is managed by its Chief Executive Officer ('CEO) and sole owner, Dr. DavidM Slaughter, PhD. to the Application provides the post-transfer organization chart demonstrating the ownership chain of Aerotest. 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 i n 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 1 0 CFR 50.33(f)(2). Specifically, state if there 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 of purchasing the shares of Aerotest. As a newly created entity, it has nofinancial 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 easiv accommodate changes in decommissioning cost estimates. In the initialfive years of new ownership, a fee consisting offive percent of the unadjusted cost will be assessed to work that uses the ARRR. Afterfive 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,t*'f Licen.se No. R-98

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1. The irtaud.c Eae:g:r Commission (the .Commission) has f o tm.d that:

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IJ{).f)..Ro-V J.V<PII LLL A. Tlie apnlicntion for 1--tr.ansfer of ] icense le-d bv. OJ::b I;:A ..for Aarotest Operations, Inc. (the l ic ensee ) compli s with the stc.r..:l.ards e.nd rcqui::e&:::ents cf the Atomic Er.e.rgy Act. of 15:4, c.s ame.r.ded *(the *Act)," and the* Conunission 1 s rules and -regulations se t . 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 pro vi s ions of the Act and the rules and regulations of the Commiss ion ; /.

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

D. There.is easonable assurance: {i) that the activities authorized by this operating li cens e can be cond uct ed without ndangering the health_and safety of the public, and (ii) that such a c t iviti e s 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 reg ul a t ions of the C ommis i on ;

'\J F. The issuance of this operating license will not be in imical to the common defense and security or to the health and safety of th.e public, and does not involve a *significant haz ard s 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 C ommis sion ' s regulations in 10 CFR Parts 30 and 70, includ ing Sections 30.33>> 70.23, and 70.31; H. The li cens ee is qualified to be the holder of the license; and I. The transfer of the license

  • is otherwise consistent with applicable p rovi s ions of law, regulatons, and orders issued by the Commission p ursuan t thereto.
2. Facility Operating License No. R-98, enioae+/-yssued to ojet: General:

Gorfl:<n;aeion, +/-s hereby traaferred e ro t es t Operations, Inc. aad tb:e ieeRsk_is :aissmed in its entirety:o .read as follows

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A. This license applies to'the Aerotesdiography and Research R acto r e .

(ARRR}, preyiously called the Aeroj el: Gen:era Nuclear ;I: ndus tr i Ae""df.

Reactor (AGNIR), a pool-type nucl r eac t or owned byu the* Q&A7 Inc. 0t:etb The fac i lity is lo cat ed at th Aerote s t Operatins site near San . VJG..J Wh1c¥;

Ramon, California, and is described in the application dated 1S owned Sep temb er 14, 1964 (the application), and in sup p lement s thereto, 1c1 Nu.<!.lc'llr i ncluding the application fa t rnsfer of license dated April 24, \...O.bl'VI

. nth 1974,: VICl +h. i.lpp lihc.Y-n fZrf lt1tl.tret.-1-' -h-ay;s(-.r- tAo.!-ecl Mo.)' 3D12.Dl2., u...c B. Subject to the-conditions and requirements incorporated herein, the i

Commi ssion hereby l c en se s 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 o p era te the reactor at the designated location in San Ramon, California, in accord ance with the p r oc e dures and l imi ta tions set forth in this license; (2) Pursuant to the Act and 10 CFR Part 70, 11Spec.ial Nuclear Material11, to receive, possess, and use up to 5.0 kilograms of contained uranium 235 in conne c ti on with operation* of th e reactor;. and (3) P u rs u an t to the Act: and 10 *cFR Part 30, 11Licensing of Byproduct Mat.er:l.al .. , (1) to receive, possess, and use a 2 curie americium-beryllium neu tron startup source, and (2) to possess, but not to s eparat e, such byproduct material

  • as may be produced by operation of the reactor.

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c. This license shall be deeme d to contain and is su b j ec t to the condi.tion:;o specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Se c t io n 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and S ect i on 70.32 of Part 70; is subjct t o 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 conditi o ns specified or incorporated below:

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

(2) Technical Specifications The Technical Specifications c ont a in e d in Appendix A, as revised, are hereby incorporated in the license. The license.e shnil op er a te the facility in accordance with the Technical Specifications, as rev i sed by issued changes thereto th ro u gh Change No. 8.

() D. Rcpo1*ts In a d di tion to reports o th e rwi s e required under this license and applicable regulations:

(1) The li ce nsee shall report in writing to the Commission uithin 10 days of its obs ervl*d occurrence any i n c i d ent or condition relating to the op e r a tion of the facility which prevented *or cou ld have prevented a nuclear system from performing its sa fety function as described in the Technical Specifications or in the Hazards Summary Report.

1 (2 ) The l_icensee sh al l report to the Commission in writing within 30 dys of its ob serve d

  • 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 C omm i s sio n in writing within 30 days of its occurrence any significant change in transient or accident analysis, as described in the Hazards Summary Report.

E. Re cord s

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'\ In add ition to th os e otherwise required u n d e r this license and appli cable regulations, the licensee s hall keep the f ol l ow ing :

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(1) Reactor operating records, including power levels.

(2) Records of in-pile irradiations.

(3) Records showing radi oactivity released or dischar ged 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 emergen cy reactor scrams, including reasons for emerge.IJ.cy shutdowns.

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

D. J_ L, 1

, Nt.te.lecu' r'-.Q_guLIL 0"" v 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 S pedfica.tieas Date. of Issuan ce: October 22, 1974 APPENDIX A

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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 th e following condtions have been met: (a) the console key is in the* "of£11 position and the key is r emoved from the co n sole and under* *the control of a licensed operator

( o r stored in a l ocked storage area); (b) sufficient control rQds are insertea so as to a ssure 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 react or is not shut

. down.

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1.3 Operable A sys t em or coponent shall be considered operable when it is c apable of performing its re qui red function in its normal manner.

1.4 Op erating A co mponent or system is operating if it is performing its required f unction in its normal manner.

1.5 Experiment Experiment shall mean any appar atus , device, or material installed in the core or experimental f a ciliti es (except for underwater. li gh ts , fuel storage _ racks and the like) which i s not a noDilB.l part of these facilities*.

1.6 Experimental'Facilities Bxperimental.facilties shall mean Glory Hole, vertical tubes, pneumatic transfer .ystems, central thimb l e . beam tubes, thermal column, and in pbol irradiation facilities.

1.7 Reactor Safety Circuits

Reac t or safety circuits shall mean those circuts, including their associated*

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  • input circuits, which ae designed to - initiate a r eac tor ** scram.

2.0 Reactor Site 2.1 The reactor and associated equipment is loca t e d within an exclusitin area.

2.2 A steel,. locked perimeter fen c e shall surround th ARRR faciltty, forming an exc lusion area The minimum distan c e 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 co n si st of the entire exclusion area .

2.3 The principal ctivites carried on within the exclusion area

  • shall be thos e associated with the operation of the ARRR reactor and the use of a hot cell d c hemistry-laboratory.

3.Q *aeactor*iuilding

3. 1 The reactor shall be ho u sed 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 bu ildi n g , and 3.1.3 a p o sitive air pressure shall be maintained in the control room with respect to t he reactor*room.

3.2 An aarm system'shall be installed to detect unauthorized ntry into the reactor buil din g . The alarm syst em shall be *monitored constantly and i ts 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 conductivty o f* the pimary coolant shall .be measured at l e a s t once each month. Corrective ac tion shall be taken to avoid exceeding a pH of 7.5*or a conductivity of 5 umno/cm.

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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 coe 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 ba th temperature coefficient and the prqmpt fuel temp eraturlf*'*C"oefficient shall be negative at all operating *temp eatures an4. the minim'I;IDl rct ivity decrement at full power shall be 80 cents when measured with respect to sourc e 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 sae as

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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 case a scram) Tab'!e 1 describes the minimum requirements of the safety system.

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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 eos' di sable both the auto-matie and manual scram circuits. .Slm\+ctr"\e..Ot.tkt 6.4 Reactor sequence, interlocks and safety.circuits shall remain operab l while fual is in the core except that one chPel may be removed for maintenance purposes when the reactor i.s shut* down.

6.5 In terlocks shall p reven t safety rod withdrawal unless all of the following conditions exist:

6.5.1 The master switch is in the ON p osition; 6.5.2 The safety system has been reset; 6.5.3 All four nucler instruments channels are in the OPERATE mode; 6.5.4 Th startup channel count ra t e is greater than 2 cps.

---} .5. S It sliall not be possible to withdr aw more t;han the sety*.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 te.

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

These hannels t may be*ued in addi ion to the normal o p er ating .

instrumentation in Tabl 1.

6.7 i Pro ess instrumentat on 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 c onnecting 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 radiat ion 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.

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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 thr oug h a rdioactive gas de te ctor chamber. The

  • gas chamber .. shall be titonitored by *a. beta -gamma qetector which shall have a co n t inuous readout in the control ro om. An annunciato_r shall ind icate when the gas exceeds 4 mr/hr.

7.3 A f-is sion pr o duct

  • water mOnitor shall be *attached to ,_the process water cleanup system !oop 1:!-djacent to.the'deminraJ.;izer d shall: provide con t inuous indication in the *control room. High _ rad iatio n :1ve1s within .

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

7.4 Portable survey instruments for meauring betagamma dose rates in the iange of 0.01 mr/hr *'to 50 r/hr shall be available to the facility , .

7. 5 Portabl_e instruments for measuring fast and. thermal neutron dose rates frm O.l mrem/hr-to* 1.0 rem/hr shal l be available at the faciliY*

7*.6 Radiation detector packets cont a ui:tng_ a series 'of threshold .

detectors shall be placed *at several 'loca-tions within the reacto1: building for

_,-) post-accident radiation *.ansis:

\,. ...-4 8.0 Experimental Facilities 8.1 g ri Lar e-Compone t Ir radi a tio n Box 8.1.1 A large-component irradiation box sall hav e a maximum volume of 20 cu .' :f.eet ,The box shall _encopass. not moe ban 120° arc of the core _and shall be de signed so that it can be placed no close than 5 em to the outer row of active ful elements.

8.1.2 The platform sha11 be positioned rtely relative to the reactor core by a positive drive and shall be cap-tive to the st. and which is b olted to the floor of the . tank. Positive

. I mechacal stops shal provn moving the peiment. box into the active reactor core. co2 shall be used for purging and to mainta-a slight poitive pressur in th e box relative t9 the

  • pool wat.r pesse.

I 8.1.3. o remove. _ or -istall the experiment box, the piatform shall be mpv ed two or more feet away from the reactor core.. The box sha ll then be lowered onto h platform and bolted in p lace wit remote handling equipment. The voided box shall be purged of air pr ior to exposure to neutrons.

, 8.2 Pneumatic'Transfer Facility

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\.._J 8.2.1 A pneumatic transfr fa c il ity 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 tran sfer 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 overiding the automatic-timer control.

8.3 Glory Hole Facility 8.3.1 A dry glory hole facility may be l ocated 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 preve nt f'ormafti.On. of ex cessive amounts of argon-41. l Gas samp es shll be taken near the pool wben the glory hole faciliy

  • i s operated without' a shield plug to insure adeqate monitoring of radioactve gases.

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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 equiped with a fil l and drai line.

8.4.2 All component s contacting the pool water.shall be fabricated from aluminum or stainless steel.

84.3 The beam catcher shield shall consist of a*movable radiation shield.

8.5 Thermal Column 8.5.1 The thermal column shal l be positioned remotely on stel*Iocating pins immediately adjacent to the rea.ctor cre.

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' 1rradiation holes. The rows shall be . placed 6 inches apart and coain 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.

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8.6.2 The ertical tube shall be purged with co2 to prevent the formation of excess amounts of rg on 41 - .

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

8. 7.2 Two triangular ex po sure facilities are available which shall allow the insert ion of circular experiemnts to a maximum. of 2.35 in. dia-*

met;er or triangular exp e riments

  • 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 th e active fu.el region.

9.0 Experiment Limitations 9 1

.* Experiments shall be evaluat ed in* the most reactive condition.

9.2 The documentation of experiments, which shall be reviewed an d 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 a ss ociated with the per f orman ce of the exper iment *

. 9.3 The value of the reactivity worth of any singl e independent experiment shall not exceed 2 dollars. If sucb_experfments are connected-or other wis e related so th at their combined reactivity could be add ed to the core simultaneously, their combined reactivity shall not exc eed 2 dollars.

9.4 The reactivity worth of any single independent expeent 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 cor e s imultaneous ly t their comb ined reactivity wQrh shall not exceed 1 dollar.

9.5 No experiment shall be installed in th e 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 su ch a manne r 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 reac tor 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 viol ent chemical reaction .

1nvolvin Experiments shall no t be p erf ormed -nr.eleu*a 9.8 equipment whose failure could result in fuel element damage.

9.9 *The amount of special nuclear material contained iri an experi ment shall b e 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 h aving moving parts shal l b e " designed . to have reactivity

  • ins ert ion rates less than 10 cent"s/ s ec except tbat moving
  • parts worth l es s than 5 cen ts may be . oscillated or removed at h igher 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 f o llowing conditions are met ;

9 . 11 . 1 Individual exp losiv e devices shall b e limi t ed to 1000 grains equivalent TNT encased in meta ll ic sheathg .

9 . 11 . 2 Th e maximum quantity of exp losive material that . may be p o s s es s ed at one time shall b e " lfmited to 50 p ounds equiva lent TNT .

9 . 11 . 3 Explosive material shall b e s t o r e d in de signated areas wi th in the reactor facility .

9 . 11 . 3 . 1 Ollly the explosive devices. to be radiographed within 4 hrs . not to Eritced a maximum of ten pounds equiva l ent TNT may b e removed from the storag e area at one time f or radiographing , in cluding prepaation but excluding packaged

  • shipment s .
  • ' J I

-9. 11.3.2 An accountability log shall b e 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 faci1ty (e . g . , storage ,

radiographing facility , or shipping dock) .

9. 11 . 4 The maximum amount of explosive material con-
  • t a ined in devices that may be place d in the radiography facilities at a tim shall be limited _ to f ive 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 explos ive devices shall be -trained and familiar with the devies being radiographe-d .

9 . 1 2 *. 1 Personnel handling the explo sive devices shall use special equipment , such as nonsparking - tools and shoes ,

pro tective 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

  • subj ected to a to tal ex posure not to exceed 3 x l o l l neutrons/cm2 and 3 x 103 roentgens of gammas .

9 . 12 . 4 Explosive devices that , upon ignition have or provide a thrust in a d efinit e direc t ion 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 p ermitted oly when two or more personnel are in the reactor building at leas t one of whom is a licensed Operator .

10 . 2 The reactor shall not be operated wherever there re significant defe cts in fuel elements , control rods or control circuitry.

10 . 3 Upon occurrence of abnormal .operation of the reactor , including i t s controls , safe'ty 'systes and auX+/-liary syst ems , action shall be taken immediately to secure the safety of the facility and determine the caus e of the abnormal behavior .-

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

(

  • ,.__./

11.0 Fuel Storage *nd tansfet.

11. 1 The fuel s t orage pits Ioc"a ted in th e floor of the r e act or ro.om .

shiill a cc ommo date a maximum of 19 fuel elements (700 gm u-235) in s t o r ag e racks dry or flooded with water . The fuel storage pits shall be s ecured with a lock and chain except during fuel transfer' ope:rations .

11. 2 Addi t i o nal . fuel storage racks may be loc a t e d in the reactor tank, Each of t he s e storage facilities shall be so* d es igne d that for all condit ions of moderation k e f f sha l l not exc e e(i a value of o . a .

t 11.3 A fuel and l ing tool shall b e * *u$ed in : tr ans f e rt ing fuel e];ements of I

low radioactivity petween t he

  • s torage pits and the r eactor ; a s h iel d ed fuel transfer cask shal l be used f or the transfer of hi ghly radio-'

active fuel e lements . The fuel handling tool shall remain in a . lo cked c ab ine t under the cognizance of the Reactor Superv:isor when not author-b e d or .us e .

peopl e I

11.4 All fuel trans fer s V:n the reactor tank shall be conducted by a minimum staf f :of . t h ree and shall include a licensed Senior Operator and a li"c ensed Operator . The s t af f lllemb e rs shall moni t o r the o perati o n i

using* appropriate radiation monitoring instrumen tation . Fue l i transfers o u t s id e .the* reactor tarik but within the facility* shall -be I

supervised by a 'licensed Operator .

I 1 1 .5 Not more than one fuel element shall be allowed in the f ac; i lity which i s not in s t o r a g e or in the i:: o re lat t ice .

12 . 0 Admini s tra tiv e Requirements

! 12. 1 OrganiZation I

i

! 1 2 . 1 ;. 1 The Re ac t or Supervisor shall have responsib ility of the reactor facility. In all mat ters p e r taining to rea ctor operations and to these Technical Specifications , the Rea c t o r Superiisor shall be r es pon s ib l e to the Pr e s id en t , Aerotes t Op erations, Inc.

ta.aftmrm,rn,rl:tre "The President , Aerotes t Opera tions , Inc * * .

shall report to the Bo ar d of D:Lrectors of Aerotest O e ra t ions ,

Inc . rrliiedt i=Re;l:ttes the Pte*d:aeftl!:! of 'Ssh 9EtJ:1 l::!!e: anl!l

  • 12. 1 . 2 The Radiological Safety Officer shall review and ap p r ove all procedures and experiments involving r adi ol o g ica l safety.. He shall enforce rules , regulations and procedures relating to radiological sa f e ty conduct rou t ine radiation surveys and is resp o ns ib le to the Manager , Aerotest Operations ,  ;"'-
12. 1 . 3 The Reactor afeguards Commit.tee shall be composed of not* \2:
  • less than five member s , of whom no more than three are memb ers of the ope ra t in g organization. The commit.tee

/. *_,*

- 1 1-shall meet on call o f the chairman and they shall meet at lea s t annually . The c ommittee s hall be responsible for, bu t not limited to the following :

12. 1 .3. 1 Reviewing and approving nuclear safety . standarde asso ciated th the use of the f acility;
12. 1 . 3 . 2 Reviewing and approving all prop o s ed experiments and procedures and changes thereto , and modifications to the reactor and its associated components .
12. 1 . 3 . 3 Determining whether p ropo sed experiments , procedures or modificaions involve _unreviewed safety questions ,

as defined in ' 10 CFR 50 Part 50 . 5 9(c) , and are in ac cordanc e th these. Technical S p ecifications ;

12. 1 . 3 . 4 Conduc t ing p eriodic audit s of pr ocedures , reacto

.operations and maint enance >> equipment performance, and records ;

12. 1 . 3. 5 Reviewing all reported abnormal o ccurrences and violations o f these Technical Specifications ,

ealuating the cause of such events and the

,- correc t ive 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 Man ager , Aerotest Operations .

12 . 1 . 4 The Reactor Supervisor shall have a Bachelor1 s degree in Engineering or Phy s ical Science and shall have a minimum of 4 years experience in the operation of a nuclear facility during which he shall have

  • demons trated competence in supervision and reactor operati ons . He shall hold a Senior Reactor Operator Lic ens e for the facility .

12 . 1 . 5 The Radiolog'ic:al Saf e ty Officer shall have a Bachelor ' s dgree in Biological or Physical Science and shall have a minimum o f 2 years experience in personnel and environmental radiat ion monitoring programs. at a nuclear facility. Certification as a Health Physic i st by the Health Physics Society is acceptable in lieu of the education and exp erience requirements given above .

12 . 2 Procedures 12 . 2*. 1 Detailed written procedures shall be provided and f ollowed for the following reactor operations :

12.2. 1 . 1 . Normal s tartup , op eration and shutdown of the complete

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

.J

- nuclear safety of the facility .

12. 2 . 1 . 2. Refueling operatons .

12 . 2 . 1 . 3 Act ions to be taken to corr ect specific and fores een p otent ial malfunctions of sys t ems or components , in cluding responses to alarms , suspec ted pr imary system leaks and abnormal reac tivity changes .

12 . 2 . 1 . 4 Paragraph omitted .

12 . 2 . 1 . 5 Preventive or corrective maintenance ope rat i ons which c ould have an effect on the sa fe ty of the r eactor .

12 . 2 . 2 Temporary procedures which do not change the int ent of previously approv e d procedures

  • may be utilized on approval by a licens e d Senior Reactor Operator and one other qualified individual . Such procedures shall . be subsequently reviewed by the Reactor Safe guards Cittee .

12 . 3 R e c o rd s In addition to those records required under the f ac ility license and applicable regu lat ions , the following record s shall be kept when explo sive materials are to be irradiated or rad iographed :

( .:

12 . 3 . 1 The type and qu ant i ty of aterial irradiated . I 12 . "3 . 2 D at e , time of day , and length of exposure .

12 . *3 . 3 Total neutron and gamma e xp osur e level.

    • * * . .**'"").

Ci '

0 u TMJI.!:; 1 NUCLUX INSTlt'MEN"l'ATION ChliOl'!l (Ho . )

{ De te c to.r **.. .

Mioi<>;>m S,Gn:; ! tivity

" . *I In.f oC,tion Min im::n. P.a.nge

  • In fortls tio*l t Logic r:l e."":.nt:

(S.craz)

S tilrtup nF3 4;5 Neu tron flux. source level 'P' e riod s crara; (a) coun ts/s'e c* per to *

(1) n/cw2 -se.c

  • period 1 :-wa t t count P rap:>r tional lo";l rate Coun ter . scr£I:l Log .H Cor.Ji?en sa ted
  • 4 x to-14 p/n/ l'mJer l evel , t o -2 Ya t ts to .
  • F eriod screra *

( 2) ion ch11::1b er cm2 -s ec period* .

1 207. ful l power

. 3

  • . Linear Unco::1pens ated 4.4 ¥ to -14 &ro/
  • l' oilr l evel 0 .,;atts to
  • High end lev Leel ion chs.:nber . n/cm -see 1 201. fll powx: level-(!>) s cru::;:as S a fety * . .....

\.oJ (3).

i Linear Colilpensated 4. 4 X lo-1 4 ampi Power 1 e.vel

  • ro -1
  • 1.7 t ts to lU&b and low .

Level ion chamber n/cm2 -sec* 1201. ful l power l evel scram Safety (4)

- . _f.___ -

(a) S era on Chennel 1 are by-pass e d when s ignt on Channel .2 exceeds a fixed . s e tt in& s imilarly the hi gh vol ta ge l s r ecoved from the detecto and the detecto is s hor ted.

(b) Low level s er mn is . b!pas sed on Channel 3 and 4 .When Channel 2 is below a fixed s e tting * .

/... ",

i I, .*

T.t\D rF. f SAFETY SYRT!Dl FUNCTIONS No. of Swi t choo

  • Annunc iator and . "Annunc iator Bnd ansor or Tr t Pcv i c e or Sensor Sc: rom . Sc t Pni t Al arm e t Po i n t:

Shor t Pcliiod j C'hs . l . 2 2* .2: 3 s o c.*

. H,igh Neutron Flux '. . .

  • 1 Leve 1 : ns . 3 , 4 .  : 2 S 98'!. o f
  • full s ca l e and not s1:'ea t:o.r than i 1 207. .

fuH

  • powe r . .. .

. High TcmpcrD turo o f ' ** .

C oolant 'Wa ter .. 1 .* . .

Low Pool Ya ter Laval . .

  • 1 < 1* f t tDaX decrottoo I I .
  • S e i s mic' D i o turban c a * * -1 *: IV on mod i fie Merc:nl l i S ca l a Br ic;o C rnt\0 Loc t1 tio111 . 1 l.fuen located off

_ . a torasa poe ition*

Lot' :.:u tron t>a l:ec tOr 500

\ol tago. ;* Chs . 2 , 3, 4 3 vol ta Lo Source* Level ;. -ch. l 1 2 cps -.

Los of *Ins trument Power ;

Ch. 2 l X I.ow* l:cu tron Flux; Ch 3

  • 5'7. o.f full
& 4, *. . 2 s cnle*

Area. Rad i.o t i n l'lonil;o 1

..S 10 mr/hr .

later ltadioactiv'i ty. 1 " .S20 mr/hF

}! 4 gpm Dem ineral izcr. Wer Fl Y 1 * *

  • Bu ild ins Gas Effluont Mo nitor l 1 . No t 011 ON"'

pos i tin 1 utto . -crcsscd

' l '*

Enclosure 3 License No. R-98 J uly 1 9, 20 1 2 Document Control Desk U . S . Nuclear Reg ulatory Comm ission 1 1 55 5 Rockvi l le Pike Rockvi lle, 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 Lad ies and G entlemen:

Pursuant to 1 0 CFR 2 . 390. Public Exemptions, Request for Withho lding, Aerotest Operations, I nc. (Aerotest) and N uclear Labyrinth LLC ( N uclear Labyrinth ) hereby request that certa in information contained in their Response to Request to Aerotest Operations, I nc. and N uclear Labyrinth LLC to S u pplement the License Transfer Appl ication (the "Response") be withheld from public disclosure as such information contains trade secrets, commercial i nformatio n , and financial i nformation which is Business P roprietary.

In support of o u r req uest we state the fol lowing:

1 . The i nformation sought to be withheld from public d isclosure a re sections of the Respon se to Request to Aerotest Operations, I nc. and Nuclear Labyrinth LLC to S u pplement the License Transfer Application d ated J u ly 1 9 , 20 1 2 submitted by Aerotest Operatio ns I nc. and N uclear Labyrinth marked as B u si ness Confidential including Attachment (1 ) .

2. The persons making this req uest a re M ichael S . Anderson of Aerotest and Dr.

David M. S laughter of N uclear Labyrinth.

3. The basis for proposing that the i nformation be withheld from public d isclosure is that the i nformation marked as Business Confidential conta i n ed in the Response is confid ential business and financial i nformation of Aerotest and N uclear Labyri nth , which information has been held in confidence by Aerotest and N uclear Labyrinth, is a type customarily held in confidence , is not available in public so urces, and if publicly disclosed wo uld be l i kely to ca use substantial harm to the com petitive position of Aerotest and N uclear Labyrinth taking into account the va lue of the informatio n , the amo u nt of effort and m o ney expended by PROPruETARY - TRADE SECRET Confid ential 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 i nformatio n and the d ifficultly with which the i nfo rmation cou ld be acquired or d u plicated by others;

4. If such i nformation were d isclosed to the public, Ae rotest and N uclear Labyrinth believe that com petitive harm would resu lt;
5. The Response has been marked to show locations of the i nformation 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 M ichael S . Anderson , being d u lly sworn , states that he is Secretary of Aerotest, that he is a uthorized on the part of said Company to sign and file with the U . S. N u clea r Reg u latory Comm ission this request for the Aerotest Rad iography and Research Reactor, and that a l l the matter and facts set forth herein are true and correct to the best of h is knowledge.

--;}A<v 1chael S . Anderson Secretary Subscri bed and sworn to before me, a Notary Public, in and for the State of Michigan and Cou nty of Oakland , this ....J2_ day of J u ly 20 1 2 .

.: Notary Public i n and for th My CD m m ission Expi res:

CANDACE MIERZW Notary Public, State of Michigan INSKJ County of Oakland

. onmission Expires May 26 2013 Actrn g 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 d u lly sworn, states that he is Ch ief Executive Officer, that he is a uthorized on the part of said Company to sign a nd file with the U. S. N uclear Reg ulatory Comm ission this request for Nuclea r Labyrinth , and that all the matter and f cts set forth herein a re true and correct to the best of his knowledge.

Da *d M. Slaughter, PhD Ch ief Executive Officer S ubscribed and sworn to before me, a Notary Public, in and for the State of Utah and Cou nty of Salt Lake, this I I day of J u ly 20 1 2 .

\

Notary Public in and for the State of Utah My Comm ission Exp ires: 1c l ll NOTARY PUBLIC DOWEL KIN G 6520 53 COMMISSION EXPIR ES FEBRUARY 01, 2016 STATE OF UTAH 4

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