ML19184A112

License and TS Amendments

ML19184A112
Person / Time
Site:	Aerotest
Issue date:	06/28/2019
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19184A112 (31)

Text

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 June 28, 2019 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50.-228/LICENSE NO. R-98.

ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738.

Subject:

License and TS Amendments Ladies and Gentlemen:

This letter and attachments are a follow up from the December 6, 2018 communication that declared the permanent cessation of operation for the ARRR (R-98), the March 21, 2019 submission of License R-98 and TS amendments, and the request for supplemental information, NRC letter May 29, 2019.

This document presents relevant changes to the License and Technical Specifications needed to prepare for fuel storage and decommissioning activities. The Licensee proposes relevant text alterations and omissions that are needed to ensure the cessation and prevention of operation. The requested supplemental information is provided in Enclosure 1. A more extensive proposed amendments are shown in a "penciled" markup of the current License and TS (Enclosure 2) with the list of changes and reasons provided in Enclosure 3.

Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com.

I declare under penalty of perjury that the statements above are correct and truthful.

, ' cere]yyour~

vid M. Slaughter, Ph.D.

President, Reactor Administrator, Manager Aerotest Operations, Inc.

Enclosures:

1. Supplemental Information

2. Mark-up of License and TS of Record

3. List of Changes with Justifications

Enclosure 1 AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 June 28, 2019 Supplemental Information Needed for License Amendment (NRC letter dated May 29th 2019)

Proposed changes to the facility license are consistent with possession-only license amendment including the elimination of authority to operate the reactor. Aerotest Operations will pursue this amendment and thus will follow relevant guidance in section 17.2 NUREG 1537.

The following information responds to a request for supplemental information found in NRC letter dated May 29th 2019.

1. I declared reactor shut down on December 6, 2018. The stated language in the letter "to amend the ARRR license to possession-only as a prelude to decommissioning the ARRR." The statement is clear to my intent. The following subsequent statements found in the letter on future activities define and support a single path. No other options were stated or suggested.

During informal discussions with the NRC PM after the December submission, he expressed a concern that the NRC's upper administration was looking for the words "permanent cessation of operation". I indicated that my letter provided that message when taken in its entirety. In the March 21, 2019 communication, the wording "permanent cessation of operation" was written to briefly summarize the content of December 6, 2018 letter.

It is interesting to note, after the December 6, 2018 was posted on ADAMS and before the NRC's response (January 25th, 2019), I was contacted by a number of parties including representatives ofTRTR, NEI, Radiography producers, etc. in all of those contacts no further explanation of my December 6, 2018 letter was necessary. (While their reasons for contacting me were different, their understanding of my declaration were the same.)

2. Mark-up Document of Current License and TS is Enclosed.

3. List of License and TS Changes with Justifications is Enclosed.

4. There are four general circumstances defining the new NRC facility license and Technical Specifications for R-98. These include the reactor shall not be operated for any reason, the fuel shall be stored in storage racks that maintain a criticality of equal to or less than 0.8 keff, there shall be no fuel and/or reflector elements in the reactor core lattice, and control rods shall be disabled and fully inserted.

1

Enclosure 1 Given these conditions, reactor sequences, interlock and safety control systems are no longer necessary according to allowances for possession-only license amendment and thus no longer operable. (Until the amended license and TS are accepted, the current TS 6.4 allows for this circumstance.)

Fuel transfers are restricted to a single movement consisting of one element at a time and stored in storage racks that maintain a criticality of equal to or less than 0.8 keff. No storage of fuel or reflector elements shall be allowed in the core lattice. Given the fuel handling and storage restrictions criticality accidents are not possible. However, an area monitor that measures the possibility of criticality event as described in TS 7.1 will remain active to monitor for this unlikely event. (TS 7.1 is present in the proposed amended documents as well)

This result of these conditions, no manipulation of controls, no reactivity changes and/or no core alterations, reactor operators ( i.e., SRO, RO and Limited SRO) as described in 10 CPR 55 and clarified in IE Circular No 80-21 are not needed. NEI 15-04, Guidelines for a Certified Fuel-Handler Training and Retraining Program, provide relevant guidance when focused on fuel handling and storage activities in fuel storage pools (outside the reactor vessel).

10 CPR 55. Regulations and subsequent programs are focused on the safe control and operation of the reactor. This includes understanding the nucleonics, thermal hydraulics, control instrumentation (reactor operation sequences, safety interlock system, and operation limits), auxiliary support systems, etc. The content of the SRO and RO requalification program heavily supports that obligation with specific technical and performance requirements.

By simply twisting the current operators training and certification program to meet this new circumstance results in a hodge-podge of customized duties with no meaningful performance standard and/or means of evaluation. There is also uncertainty concerning how the NRC staff evaluates compliance with 10 CFR 55 (and associated ANSI standard 15 .4) especially when the scope of duties is significantly reduced and refocused on non-operational obligations. Illustrating this point in a communication dated October 15, 2018 section RAI ORP-7. NRC staff stated that Aerotest Operations' SROs were not "active" since 2012 suggesting AO SROs were not qualified to perform SRO duties since that date. This relatively new NRC staff conclusion is not supported by past documented communications from the NRC (i.e., annual NRC staff inspections, cited violations, etc.) or by my interpretation of 10 CFR 55 regulations as presented in AO letter October 24, 2018. It is interesting to note that while AO operating staff met the requirements in 10 CFR 55, in my opinion, they were not technically qualified to operate the reactor well before 2012; their documented decisions and cited reactor circumstances (related to control instruments, fuel, operation procedures, etc.) support my conclusion.

In the past at Aerotest Operations, fuel handling training was the result of transfer of knowledge through practices handed down and not necessarily documented. This is especially true for inspection practices of single fuel elements. The inspection methodology for the fuel cladding evaluation and damage criteria were not standardized and memorialized in a procedure; modification of actions occurred as the circumstances presented themselves; those modifications were not always documented. The recorded observations of fuel cladding condition are related to the method and inspection protocol used; in many instances, this information is not present. (I believe, the absence of formal procedures partially contributed to the lack of removal criteria needed for effective implementation of TS 10.2.)

2

Enclosure 1 The obligation remains for the facility licensee to provide an adequately trained crew to handle fuel for inspection purposes, understand fuel and water chemistry, perform radiological activities; the ARRR CFH training and requalification program 3/6/2019 serves that purpose. Required biannual performance metrics for training and requalification are documented and will be available during NRC inspections.

Currently, The Radiation Safety Officer is not an SRO/RO and will not be a CFH. In the past this was not the case, the decisions by the RSO were compromised by commercial considerations and not focused on radiation safety. (The same could be said for the past decisions of the Reactor Supervisor concerning reactor operation and safety.)

To ensure consistency with the fuel possession only using CFHs, Aerotest Operations Security Plan, Emergency Plan, and Facility Operating Procedures have been updated to reflect the new status and authority. All members of the Reactor Safeguards Committee have reviewed the changes and the documents were accepted April 23, 2019. There is no conflict with the new direction and authority concerning the existing SAR (Aerojet-General Nucleonics Industrial Reactor -Hazards Summary report, AN-1193, September 1964); thus changes are not needed or proposed. Upon adoption of the changes to the license and Technical Specifications, the Security and Emergency Plans will be submitted under regulations 10 CFR 54 (p) and (q). The Facility Operating Procedures will be implemented in their entirety. Some facilities procedures not requiring the approved NRC changes to the Technical Specification (e.g. Radiological Safety Procedures) are currently implemented. Also implemented is section lX Fuel Handling and Fuel Inspection Procedures. The processes documented in this section were not memorialized in writing in prior versions of Aerotest Operations Facility Operating Procedures.

3

Enclosure 2 AEROTEST OPERATIONS, INC.

DOCKET NO. 50-228 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (ARRR)

AMENDMENT TO FACILITY OPERATING LICENSE Co Amendment No.¥ License No. R-98

1. The Nuclear Regulatory Commission (NRG or the Commission). having previously made the findings set forth in Amended Facility Operating License No. R-98 issued on January 28 , 1981 , has now found that:

A. The application for indirect transfer of license and conforming amendments to Amended Facility Operating License No. R-98, filed by Aerotest Operations. Inc.,

and Nuclear Labyrinth , LLC , dated May 30, 2012, and supplemented on July 19 and October 15, 2012 ; January 10, 2013 ; and April 21, June 16, August 22, and October 10, 2016, complies with the standards and requ irements of the Atomic Energy Act of 1954 (the Act), as amended, and the rules and regulations of the Commission as stated in Title 10, Chapter I, "Nuclear Regulatory Commission,"

of the Code of Federal Regulations (10 CFR Chapter I).

B. Construction of the facility has been substantially completed in conformity 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 application. as amended, the provisions of the Act. and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering 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. Aerotest Operations, Inc. is technically and financially qualified to possess , use, and operate the facility in accordance with the rules and regulations of the Commission; Amendment No. 5

F. The issuance of this operating license will not be inimical to the common defense and security or to the health and safety of the public , and does not involve a significant hazards consideration ;

G. The receipt , possession , and use of byproduct and special nuclear material as authorizea 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, regulations, and orders issued by the Commission pursuant thereto.

2. Facility Operating License No. R-98, issued to Aerotest Operations, Inc., is hereby indirectly transferred to Nuclear Labyrinth , LLC , and the license is amended to read as follows :

A. This license applies to the Aerotest Radiography and Research Reactor (ARRR) ,

a pool-type nuclear reactor owned by Aerotest Operations , Inc. The facility is located at the Aerotest Operations site near San Ramon , California, and is described in the application dated September 14, 1964 (the application), and in supplements thereto , including the application for transfer of license dated April 24 , 1974, and the application for indirect transfer dated May 30, 2012.

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 Facilities," to possess, l!lso , and opOFate 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 , "Special Nuclear Material," to resoiYe , possess , eAel tise 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, "Licensing of Byproduct Material," (1) to rosoi.,.e , possess, enEI 1!180 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.

Amendment No. 5

C. This license shall be deemed to contain and is subject to the conditions 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 subject 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) Maximum Power Level Nu"I' A 1'/f/ ?hr~

The licensee i¥authorized to operate the facility at stea~tate~

~ls-Agt-iR-e*eess-of..-2 ~ilew~hermaij.

(2) Technical Specifications h

The Technical Spe~~contained in Appendix A, as revised through Amendment No:*5f are hereby incorporated in the license. The licensee shall oi,erete the facility in accordance with the Technical Specifications .

~r,,,;+..., oJ (3) Physical Security Plan The licensee shall maintain in effect and fully implement all provisions of the NRG-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR Section 50.54(p) . The approved security plan consists of the document withheld from public disclosure pursuant to 10 CFR 2.790(d) , entitled "Aerotest Operations ,

Inc. Security Plan" dated August 10, 1976, submitted by letter dated October 4, 1976, as revised January 16, 1979.

D. Reports In addition to reports otherwise required under the license and applicable regulations :

( 1) The licensee shall report in writing to the Commission within 10 days of its observed 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.

(2) The licensee shall report to the Commission in writing within 30 days of its observed occurrence any substantial variance disclosed by operation of the facility from performance specifications 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.

Amendment No. 5

-* **. E. Records

( \

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

,Z. -*-- - -*- ' .... j '*._.*-* ** - **

(l)* Reactor opera ting records, including power levels.

(2) Records of in-pile irradiations.

(3) Records showing radioactivity released or discharged -into t _h e .air or wa ter beyond the effective control of t he licensee as measured at~the point of such release or discharge *.

(4) Records *of emergency reactor s crams, . *including reasons for emergency shutdowns.

F.

This amended license is effecti~e as o.f the date of issuance and shall expire at midn{ght April 16, 2005.

FOR THE' ATO:-rrc E~ERGY CO~fHISSio:~

(. .;*~:,* - / *.: *.

Karl R. Goller, Assistant Director

. for Operating Reactors Directorate of Lic~nsing

Attachment:

-Change No. 8 to the Technical Specifications Da*te of_ Issuance: October 22, 1974

/

,. - -- "\

t - )*'i

Trans. W/ Ch~nge No. 4 Dated 8-15-68 Du Not

/

?

• APPENDIX A LICENSE NO. R-98 TECHNICAL SPECI1ICATIONS FOR THE

. /ifttg:iifY-1~ /fl!/C/IJF/rMI!rJ$' /JMIN~ IIM!ldJ/dB! l</!l.drtIIIl:I Name Changed to: Aerotest Radiography and Research Reactor (ARRR) 10-22-74

1. 0 Definitions 1

• 1 ~,tde~-?-e t<,.tMWb'VI .S:1'tth:low~

• The-r~ae-tor, with fiueii-e*f>e!:-4:meftff ift . pla~, *eaall he eal'l:-

..side:i;:ed, t o he shut dpwn (nnt...in: riperation)..whenever al J of the (1111 nm hie.

• owU t:l-on*1: h=,a_h,,,..,." ~ +- * ' *-' ~'-

• 0 The reactor is pe rma nently sh ut dow n w hen the reactor is maintain ed in permanent shut down confi g uration with th e f ue l el ements stored in storage racks tha maintain a criticality of equal to or less than 0.8 keff,

.JL)t- a maxgin_gr.eate r than D-1.7.-deJ.ta.-kt,lt-c~.d,- e,1 ean-c r-i-ti-G&l'

-eGR<litieaJ (e~~k-J.s-i~~~ing-:..1:'e.f.uel-ing-

-e~atieae a~ maiatenaM~8---Geat~el .1:eEt. mee,haru:.sm9::

1. 2 * .&eae.~1---0peHti.gn ' r ~ ~ Sh~--tdo~ ~t*::"$ '-'-nr1'~

Il~ae-i':6ll"-8Det!'ll£!:0ft S&&tl *mean &n*>-A4U>~-:i#:inr uho-- 0 ,I- ._,__

Co re latti ce containi ng ~o fuel'br refle ctor elements and control rods disabled fully inserted .

1.3 Operab1 e A system or component .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

• Exoeriment Experiment shall mean any apparatus, device, or material installed in the core or experimental facilities (exce1;>t for underwater lights, fuel storage racks and the like) which is not a normal part of these ;facilities .*

1.8 Core Lattice he array of machined positions for fue or reflector elements in the grid plates.

1. 9 Core Structure

- 7. -

f he upper and lower grid plates connected by structura l members 1.6 Ex periment a l Facilities

. Experimentai facilities shall me.a n Glory Hole, vertical tubes, pneumatic transfer systems, central thimble, beam tubes, thermal column, and in-pool irradiation facilities.

Reactor S~fety Circui ts

.R~a~ tor-_safety circuits shall mean those circuits, including their associated input circuits, which are designed to initiate a reactor scram.

2.1 The reac.tor and associated equipment is

• located within an exclusion area, at the A~ffiiiiie:T-a-f-..Ge:i~t:-f 0ii,-S.an-=Ri!ID~n-

• ~ Q.J,1..'f/,. 8~ Io -.9-ol, - 7 '( 1' f\ R RR} ~ g;,

2.2 A steel, locked perimeter fence shall surround the Mlli:'t:R-facili ty, forming an exclusion area. The minimum distance from the center of the reactor . pool to the boundar:y of the exclus*ion area fencing shall be 50 feet, Th~ restricted area,

,. as defined in 10 CFR 20, shall consist of the entir~ *exclusion area.

cJ-e.c CSW'\IV\ ;'~S*~\\iV\

2.3 *The . principal activities carried on wi~mhl the exclusion area ..- _/

shall be those associated with the Sfle~en of the *~ A R R R"'

reactor a~d the use of~,? L ecH:" and chemistry laboratory .

M ACh*vlf .s:h>Jp, f - ~* ~..fh J-,,

3.0 Reactor Building 3.1 The reactor shall be housed in a steel building capable of meeting the following functional requirements:

3 . 1.1 all circulating fans and air *conditioning systems except the system which supplies air to the control room shal l 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 pressur e shall be mai ntained in the coLtrol room with respect to the reactor room .

"3. 2 An alarm syst em shall be installed to de tect unau- (2 liu1vc;c ;r:1-_s-thorized entry *into t he reactor building . The alarm J;t:-tl ..y'-.2 cj .] 0.

_system shall be moni t ored cons t an t ly and its annun-ciati on sha ll be tes t ed monthl y ."

(. 4.0 Reactor Pool (P:dmary System) 4.1 The minimum depth of water above the top of the aeUwe- core ST~~t1 shall be i6 ft. The maximum bulk water temperature shall be 130°F and the minimum 66"F.

• .:fO .

4.2 The_pll aad conductivity of the prima.r y coolant shall be measured at l ea s : ~ - Corrective ac*tion shall be taken to avoi~!~':;!~""~R-ot 7 ~ *. ~~ a conductivity of 5 umho/crn, 5.0 Reactor Core 1_*. , .

i *. *, * . ~.

5.1 . Fuel Elements:: "'. ~No *Fuel Elements shall be allowed in core lattice

5. l J The reaQ tor shall~enta.i~R\001~-,f.tha.n.; .:, :': 90-'.F-R+/-GA t3*pe *fuel elalll8at.s '£ha-G~e sk_a l :&: be ha4eti wi.t:h not more;:, tliaa J,30---ks e,f *:u 23.S.

I : **

5 2 Tbe *roa;dmum excess teaGJ;.iJd..ty above ee-1,d r e.lraa~l."-~1, with..or. witbout..expen1m@n~l-aee, s k a - ~ '

• 5.1.~'.l!he-bata'*' tampeHtlalH eeefUei6M-&Rd--ehe p1?8&1J1t fuel-*

temperatnre...coeffic1ent shaJJ be..negat.,;L.ne at all

.:......_op.ex;at:in~ temperatures

• and tbe roinirouw reectiuit:y decremenLat,_ful J powe:r:...,shal L he BO_centa when meas.w:.ed..

~i-t~e~peat-t--0 smu:c&spowe:r;,,,J emal.

~~r 4 ~he-eoo-Hin-e.-ve4:.d-Goemc;:ieat sb.all ha 11agative across

...;u1Z.ee~cJ..lo.,ri;.t:e_ _M1aa.ii;x,.i~~11,1D1111Wi.-'-..ian*='-C~Q,.JF~il-SfJf>'4ii&>iiiX'1i&""t..i,.ll~Sr--'t'**~g~ie4a.,*-.1eH&ioa,..,lt..li.--- - - -.. .

Lthu.e.e-'*aacc.i;;ti.1.

--1l.e...J.O.% of the cool::aot cf Pre 1101 nmes -as dei;i ned hy -a

---C-y.l.in4ei...hounded-a-h.Y=th~~d-plate,5cr~ - --

5. 2 Reflector Elements -No Reflector elements shall be allowed in core Lattice*

5 2, l

• The AHereJ J reUac.c:e1=e:J.-sements' d i m ~-1-be

-&ae-Balll8 as t.nlil fue.J. ~lemfiRts

).:

5*3 Control Elemen~~ '_ Control Eleme.nts shall be disabled and fully inserted in core lattice

• I ~

5 3 J . The reactor ahaL1

• be subcritical by a minimu~g,in

• ef 0.50 aellar.

• when=t;h ~ ~ ~ & 1 - - f . u-l -ly

- w J a . . £ ~ b e care

.!i..1..2 The maximJJw rate of reac.t.iMit¥ addi.tion....roi:.._t:be contr.ol

--1:0ds shall be J J cents/second Toere wbal J. be a lll.i.mi-

-mum-e~aea-eperablce ea~J.ement:s--,

I 1-,,

5.3.3 '£he total time for insettion of the conLLol tods fol=

lewiag reeei~of a . aerfflB sig1utl by the s ~

sae.11 e e - a - m ~ ~ a e e e m l s . -

6. 0 Reac tor Safety' ~ya tems -

Reactor operations sequences, Interlock and safety systems need not be operable since no fu el and/or reflector elements shall be allowed in the core lattice."

. ....aruLaudihl e...al arma-and.,-when-&e'l'-&a-iaft-pT*e ~t: H:mit:s are-ex-

_peedlil~, ~c~ thfi reaoter, .Tl:te systems shall be fail*safe

(-ee-en~4-a4:ng-saal1 ea.use a &eMDt-), 'lle&.J:.e-1 describes .the--

minimum ~eqili.emfiRt& g~

• the-eMe~ s-ystem.

6,2 Ib.e nucJ ear, pr-0ce~n-mon.i-tor4ag--J.a~antation

-shall p r o \ ' 4 , d ~ & - i u ~ v e the set point ranges---

and-aa.s.ociated...annunciatJ.on&-J.J.stad in Tael:e 2 ef these

., &.pe~GaUoas-r-e, J

• The-:-&a:£ety sy&tam-ahall be--desi,g~ea taat Re eiagle

.eompeaeat fa:UuE'e or Gireuit fau*lt;. shall si1Jt1:Jltanee~i, ...~-- ---

. disable both-the au.toma-G-ic-and--maaual ee~am ehe1:1i~s *

• .1 6 . 4 ~ r sequeo,ces, interlocks and safety circuits aha))

.. ,.: 1rQlllain_ operable wbi J e fuel ; s in-the co:i;e~xGept-that--one-ehaaalill *may ba .-emoved fer maiateaaaee p11rpes,es when the 11aa'1tar is shut down

6. 5 late:rleaks shall _prav~at saflilty :i.:od withdrawa-1-un-l-es-s--a-1 of tRlil fQlloWiDg QORdit4:aa&-e-*i:*.:le'a;~!;;.?!--- -- -

6. 5 .1 The H1astel" s,w.i..te-lhi,.s-i-.n-;.tae-Q~

6 * .§,2 The sahty system-bas....b.ean-t:es;'4iie>1at,.-;- ..;..*___......,:.:.....

• . ..:***: '* '*  : *. . ! . ..... .; . ~ . :: : .

6,§,J All fou:i; nuc;:lear i,nst:r.nments channe.l.s-are in the Q.PERA,.'l;i.....mooe; .

-6.5.4 Tai. startup channel count rate is greater than 2 cps ri: shall not be possible to withdraw more tbatt tae eafeey red. YRtil it Ras rlilaG-he~he-upp * ,

t4me--f=ither tha saim or i;egulaUn~od-may ea-movcad,- but--

only ene at a time, I

i )

I i

• I I

e.e DuriRg a eritieal eltp~ent., suberit:ieal: mtttt:i-rrH:eat:ien

-P-lots....shalJ be o b ~ l e . a ~ ns-~i;.umenta-tJ.on-.

ei:.hai:mel.a---1.'hes.e:_channeLs-majr-.b~sad in add.tt-i.Gn tG tha aaml operating iastFument:aeion in Table 1.

Process instrumentation with readout in the control room shall be operating to permit continuous indication of pool water tem~erature and conductivity. Alarms shall be 9per-abted . to indicate low water flow, low pool water and improp 77 .

lor,ation of the crane bridge, 1/Jbc..1& / <l.,.,.-/1.t,~ ~ S.&Pf"- &

1. I(. ~SO'-'~

• 7.0 -~diation Monitoring "7 .1 A fixed ganuna monitor employing Geiger tube detectors 'i shall be located on the wall connecting the control r oom and the reactor room. This monitor shall .serve .

as both an area radiation monitor and a criticality

• alarm and will annunciate through an automatic monitorinir system to th.e San Ramoff, California, Fire Department and actuate a siren within the reactor

.. / building on high radiation level. The monitor shall

• r:)... '. have a minimum range of Oto 20* mr/hr. The annun-ciation and the siren actuation shall be tested I ,, , c1~r~>...f-ao.i-l4-t:y-may--be:-:.1ocat~ny

- - l!'eaet8li' 881'8 pedti~R, 'l)l\Q- ;ia&i-1,,:b~y 8881: J: Be O!'e'l!'e.ted w;L.tn drj* CO2 and-e~~gh-a-41,,l.~:., .: . :: * . ,: .,::

~ntilatJ.OD ayate111,.r :wbich-j s...-moni.to~ed foo;: radiaaeth*it,-.

~ - - e 0 c i : e po~~oB o~ t.he &H&He~eo:i:'1--ky sha-H lteve a maui1Bwm ;Jeid .YelY1Be ei 34 eu. ia. in the active

---*""llW""""*4M~B..-- ....A-1ma-aua-l e eat!'&l shaH-be-prov+/-ded-wh+/-c'h

,a o..1.&-.e.--Oli~~Wl§-l~~~m~-eo~.

• I 1*

\

8. 3 Glory Hole Facility -No t in po ol an d shall not be authori ze d for use.'

8..-1.J A dry g]or::;,; hole fad] jty may; ha lo-.:a-iaad- ii.n any r-e.-a-O-tl>UceP'1F=-

core pos.i ti au The gJ ory n&~l.s iiliall a~ep-t-eapsules tea ma:ia,mli~,a.,-..a.-a-d-:i..am.e...t ...a..r ....,-L___ _

43.3,2 . The gLgry J;i,gls s a a J . - . 1 ~ ~

• * * ,ve ama1,n1:ee af a ~ l . Ga~s

-ErEWw,.J--'~-oN~ra,..n;;~::-t,he-paeJ-wheo-the-glm::y hole fad 11 ty is opeJ;a.t.ed u it:hout a eMel4 phtg te iael:lre a ~

--fil&fri.~i:ad4ea~e gases,

8. 4 Neutron .Radiography*: Facility - shall not be authorized for use :

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 equipped with a fill and drain line.

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

~ ~ = - - - - - - - - - - - - - - - - - - - - - : : ,7.*lo TH-e beam catch e::- shield shall consist of a movable

• fi,1e* O 11 I 8. 4. 3 ractiation shield." C, 1,'1

= 1'

~~~- ~-- ~===::;:::;,::.=-==,=-=---------=-=======~

• 8. 5 Thermal Column * '-Shall be authorized for reflector element storage only. I 8.5.l The thermal column shall be positioned remotely on steel locating pins immediately adjacent to the r eactor

• core .

8, 5, 2 'l'ti-e thermal colnam shall be composed of a tht ee foot

~ube of grapbi te.-e.ru::.asf;'d hi aJ.uminum containing five ,

rows of l 5 itt, diametei;; inaciiation aoles. The rows snall be placed 6 j nches-ap.art and-coR.t-.aJ.a- &e¥&A-lwles per roo.

Slotted beams sbal l

• be prouillea t:e alleu enf'erimeats

~--t~o- he-~Gha~he-&h~rma-1--eolumn-;

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

8.6 Vertical Tube '- Shall not be authorized tor Use.'

a~6. 1 Ve ~ ea-l ~ir~adiat.--i--0n=t:u0esy=hav--fa1g ,uamet:ars Hf' te G ia .

• 2 Dt&Y be-a-t..i:;aa-aaa* &~ae~mal eoll:iffift,

~ ,2 TaQ-.>;e*~i,g a~ube=Slta*l-l- ~ -urg-etl-w-i:-tfi~---8--p-reveft-t- **

--tl 1 e - f . a - a n ~ ~ £ - a - : - g en-~

I I

L

\

8.7 Other Irradiation Facilities -Shall not be autnomed for Use.'

-8.-7-~1 The eeatral 7 f-l!e-l--e-l-emea-ts- o-~t-be-r,4ac.to.r- ma.¥-b..---

r ~ d £rem the eere efte 8 central irra~iation facility i.nliltalled prouided ,t he cro&lil*&!e-ti.ona.-l-a.-~a.-of~

£.acUity doe.a-not &xceed 16 ia *

• 8~7.2 !fwe triaag1:1lar enpee1:1re feeiliHes-are available whieh shall allau the iasert-wa af circul&i;:-e*f>eamen.t-s-w-

• a maKiewm af 2 ..H .fa.. di.am~r trian~pedmeut:.s to a ma:ic:imum of J.* O in, oo a side, i,7.J Irradiatioa capsules--1a-tbe shape e ~ u ~ e l elmests shall ft8VC e fflSJtilll\iffl iRRer Vai~mQ Qi; 34 CU, iti----

ia the aet:iTJe :l;uel, *Hg.ion - . -

9. 0 Experiment Lirni tations -No experiments shall be authorized .

9, i!: . '1§te &eettl!Mt&'~l.'li-me&&Ery--Wh4eh-sha-U be ri.miewed ~nd

~r-e~e'1 p..iar te ias,ui'&iea i.a tae reaeter, shall inclttde at least~

9.2.2 t, euel!i:PHert ef the experiment, and 9 2, 3 Aa-aoa1¥&J s AF the pesdhJ-e haza1"ds-assoeia~

the l'etferme.nee e£ ehe experiment.

9 3 Tbe naJ ue of tbe x:a*a ct;hd ty w->.-th-of aay single iR<<iepeftdeftt 9.Xpe:g,me:nt sl;iall-not excaad 2 d~Hare. I:£ ooe-h-e:itpe!'iment$

a-Fe-&eftfteeeeEi eP eeaeA1iee l;'elateEi se l!ha-t----t:h:eir eomoined

• reaetiviey ee~la ee aesea te eke eere s i i m H : - t - ~

~ba.Riid nae6ii.vJ.ty s4a.J.l nat;.,~o-eed- d ~ ~ -

...9... 4  :,Che ;r;eac.ti¥it:¥ wm;.th.,o f __a,ny...single,....inde.pendent.-exp.etimemr net* r:i:~icH-y Huea iH tileee eaaH ftel! eneeed 1 dollar: If

-&U&a-8*f>~111eate an eeaaeQteEl-,.gr 0&ltei1~r~tied-se t:ha.t t:ihei:l" eem&i-O&d a:e~.vity c911J,d be added-to-the c.o:z:a...slmu.1 -

~ou&ly, taeb* e0mbi1uad Feaeti¥ity- ~1eHe

• eaall not exceed 1--doJJar

l 9 .s N6-e*PeFiment eaall ae iaetaUed-:i:ft-1:he-,_-e-ae-e-~ t:teh-a

--m.i,nna;J;,,,,,tha t i-t-Gou.l-0 eaadsu the Ftue-l:-e a-r--+/-tts-t1: umenta1+/-on

&y&ee1Tt-m6ftie6rs.

9,6 No experiment_shall be ins.talled=in the reactor in such a 111aaaer taa-t a faihn*e e~~He-Fe-w4.-e--h-t-ae-ias~ -

• ff-a-l?ea~~-e.1-&lement.

9,7 No experiment sba_J.l.Jie-per-£~ed-:i.IWO-l-¥-i..ag-ma-t-6-r-ia.ls wni-Gh

--eeYlfi; .,

• 9 7 J Contam:im1ti. tblil *"eat;to1; p-00-l---4aus4-a~~on on t;he reactor coropone.o.t-S-O.r-0x.pe:rimeats; 9, 7, 3 Produce an uocantaioed 3.1.:i.ole,n.t-G-ae~al reaction, 9,8 Experiments shall not *be perforined invo]vjng eqµiprneot whose

£ai.1.u;i;e could x:*,un1lt :i.a-fulill el..emen-t-~damage.

,*.i( ,.-- ~ 9,9 The amount of special oucJear roateriaJ con.t.ained-.i-~ri-roent sh.all be lim;ltQd tQ 5 grams in the form ef solid samples

. or 3 ~ s in the £arm 0£ liquid

• T,jqujd *spec-;aJ *nuclear

~~i-.-l-s-&h.all be deublJ-eRG-ap-s~.

9,.J.D...:.Expe;r;in *nts ,ha,vJ.o.g~-IDQlring,:p;;u:t,S-Shall be designed ta h~e*

reacH*~-sei.2-t:ien rat:es ress tlran--i*o cents/sec except

~at mEr iag parts

• werta l.!iss t.h.aR 5 seats ma~s-e-4-l-lated or temoted at hi~hex ireq~eneies, II Individual explosive devices shall be limite:i:I to 1000 ~rains equLvaleut TNT encas.ed-.:.itn rne.t:aJHc sh_eath.iue- *!--

Ulil (!uaat;i ty gf .ixploi;.J. ne materi cil I

\

- --t.BMl~~o&s.esiied=8t one droe sha] 1 he Jiro1ted to 50 prnmds

• eqrduaJen-t WT.

9.11.}  :-::xi,loshe nratetial shall be stared in . I

• l

. l

,r'---...

,...~~:l:'T-:!1-:-:1:--~tbl,.y--&li~~ ~

- -'l:'ad4:e-g-rirphe'ti-w-l:' l:'l°t!t!'l}~d~.. t 't't""""'-R<~..,......&e-E-, ,1 *

-a* e.eae.-...a-~-wm-G.1.-a.t.an...µ.i:um..a._

0

j{ I *

~EfU-i-valcae !!!NT, may ~s rem0uerl. f.Qm J_1,rl * .()1.I tbe s m~giil :a.i::raa at sae- Mme fer Cr'/\ * (ej?-11 * .

_ _ _..,r._.a.._a_i.e. . . _g~r..>.a.U.p.U.lii.J.4=.a.l.J.l:,g, -,~i.i.;a~~~

b11 L excJuding _packaged s,hiproents,

-u;ate:.i.ii..n..i;gw...l.,j~~,l,l,IQIU;});;,l,a,1.....

l~ 82..tL.-* o

-:i: _n_ __,,.._j

~

~if .

9,ll,3 2 An acccu.n;it!ilhilHy log sh!illd be

~ - -maJntaj ned to sh.axL.th.,.e......,a.,.m...0..,71..,p.,.f.......,o,i.,if_ _ _ _ _ __ _ __

e:.x:pJos;lne n.a.t.&r..;b.a.J. in taa X'QiiGtor.

facility it all times I and sha] Leon tain a description af the explosive and d~a locat;i..;ii.1. witbiu the fad] i ~

e-.g s s.t&r:ag-~.acli.o.g.rapb i u g £ aci J1 t~-- - - --

- e -r - s . ~->> <+-- - -- - - - -

9,...J,J....-4 *.-..4'l 1 ~ amount-a£ ex.pJ,,osilte mated al.

contained i~~

n the radiog.raphtfaciJities at,.,a time shall

-be l :Jmi.ted t~G f.;l.;,re-~rui-6 e~aleH:t 'Hf'!'.

• 9-ril.....4-. - Exp-l-0s-i¥G-m&t-&rail.a~~a'8-1?-a-a-i~n field at one time sbaJJ he Jirniud--*

• te 1 pe-,:miil eEtl:l.i*. aleR!: '.liw;E, 9.11.4.2 Explosive material cru tait1ed ;l,n 1cm..gd:e:v ft* e=Gs ) -:-s=.:a U e 1 limH:e d

. fggt.;.,"

________-_*-----==-----------,------:-------------*-----*.

9, J 2 1

~~h ii1aei~11~e,aae:rstiug

• ec_,JifHilfWt sha-31 f t e t ; - 1 , - ~ ~ £ : : a f l o / ea~esi*ze _

f -- "\ '

z )

i' ...a,

'I c--

I )rf:c*

I .

- 11

.I

~ ~

E>t1)-1-0aS-i..o.,e-d.e-v-i.-ees ek ei, l:l!'en i e;n:l. ti-orr, hn 11e or pr.av;! de a thrus,.t; c.,_... .....a,-':1~4.js @-lrieR shall be positioned *so as

• o be_ajmed awa ji fi:-om-t.he reaeeor 11 and cam.p.nnents '

• _, i

10. 0- General Qpera ting Limitations '-No reactor operation shall be authorized .==========~

fta-H ..be pel:' ..,itted eaidy wheu two or more

_.p.e.;r.s.i;uu:i.e.l.a...a:t:t!i\=::;o;rn:0;

.:n:aii:::.i:i;~e~a~ i-l4i.nth - a,t--J:.e..aa~

1 ; a J i c onsad Ope.1;a..t ar,

] 0-2 the t;ii-a-Gat.A-I' s-na-W ao-t-he,..0:pc~ aa. WEH3-r;e>>-e.-r~ l;l.w-..e=,3.r-o-~ n t detects HA £1101 elemen-t-Ss,-CQAL..Go.l=.-i;Ad i-s-sA'G sen-t-r4be ?reuit~.

l 1.0. J Ppei.. ecc11x::c:si:gce gf ab5l01"!1lal Qf i -~ti,_o ~ o ~e:--t=,GaG-t;G.r..,:..-41'.lcluding its 89RU"lills I safar.y syu,eui1r=;;..:i.d a ~.:J..i, a r y sy~t.ems, ac t1 AA shall 'ee talcen i.lftl'fteeii.11tel;i *te s eQw.;e t-lle-s-a-f~f~he facil~y

-a&e Elate.mlna tRe eawse o-f-'-tiR-ca fteMal oeha;*i.er. (

11.0 Fuel S~orage and Transfer 11.1 The fuel storage pits located *.n the floor of .the reactor room shall accommodate a rnaxir:. *m of 19 fuel elements (700 gm U-235) in storage racks dr y or flooded -w ith water. The I r-J ~~~

fuel storag e pits shall be sec red with a lock and chain VJW\'6-

• except during fuel transfer OF, rations. A 11.2 Add~tional fuel storage racks may be located in the rea~tor tank . Each of these storage facilities shall be so designed that .for .all conditions of moderation keff sh~ll not exceed a value of 0. 8.

'i 11.J A fuel . handling tool shall be used in transferring fuel ele-

\ ments. *of low radioactivity bet ;..* een the storage .pits and the reactor; a shielded fuel tr~n ri ~r cask shall be used for the .

I transfer of highly radioactiyc fuel elements. The fuel handling )

to.ol shall remain in a locked .:.1binet under the cognizance of  !

the Reaeter s~~ervieer when nc ~ authorized for use. *

.c-J il i -'-t°u.<5<._~oA,..rJti~ s""~u~-s~"'-- ,

. \

i --di' ri Amendment . No. 4

- - - --~ -- - *

. JAN ~*- ;~~ -198i r

11.4 Transfer of irradiated fuel in the reactor tank shall be conducted by a minimum staff of two, a Certified Fuel Handler (CFH) and an additional person trained in radiation safety. The staff shall monitor the operation using the appropriate radiation monitoring instrument. A RSO or designee shall be present for irradiated fuel transfers outside of the reactor tank but within the facility . Under no circumstance is fuel to be transferred to or stored in the core lattice .

11.5 Not more than one fuel element shall be allowed in the facility which is not in storage.er in the sar&daltise:

12.0 Administrative Requirements 12.1 Organization , ~

• _ __,.,,..;,*_

t~ct, f,e,;) F'-'el ~~ ~~r.--.- r"-~ /-(vwdL~ oy--*r*-* -

12. 1.1 The ~Glor ~" ~oF\liser sh~ ha~ responsibility of t reactor facility. In all matters pertai ing t

• and to these Technical Specifications, the Reacto~L1pen1iior shall be responsible to the President, Aerotest Operations, Inc. The President, Aerotest Operations, Inc. shall report to the Board of Directors of Aerotest Operations, Inc.

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 Men~§<j:! , Aerotest Operations.

f't2a-~

12.1.3 The Reactor Safeguards Committee shall be composed of not less than five members, of whom no mor ~

members of the . The committee 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 standards associated with the use of the facility; 12.1 .3.2 Reviewin~ anEl approvi~ ell 19mr,osed exoe1 ii 11e1 its and Revj ewing facilities proce ures ana significant facility modifications.

tt'le* reactor ancflts OSSOOiated GOR'lpOAents ;

Amendment No. 5

I I

f II 12.1.3.3 Determining whether proposed ~

proced~res or modifications involve unreviewed safety questions; as defined in 10 CFR 50, Part 50.59(c), and are in accordance with these Technical Specifications; 12.1.3.4 Conducting periodic audits of procedures,

.~aetsr 0pe.ati0ss aae maintenance, equipment performance, and records; 12,l,3.5 Reviewing all reported abnormal occurrences arid violations of these Technical $pecificationsp evaluating the causes of suc.h events and the corrective action taken and recommending measures to prevent reoccurrence and; 12.1.3.6 Reporting their findings and recommendations c.ha e.-5

• concerning the above to the M4:aaner,

/\ a Aerotest .u..r .I f_.,.,..,o-10 .

Operations.

11

• • ,>tter,~+ * .rw ;I 12 .1. 4 'fhe Reacor-Sttl')~61'."-8'1ta-l-l-aave-a- Ra~e-1-G-:i:;..!...-da=P.

. (_

12.1.4 The CFH Supervisor shall have at least 5 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant N RC regulations and A LARA principles. Classroom education in the nuclear and radiation related fields of tudy may be considered in lieu of the experience requirement. I

~.£:-LWa~~---0,r.-upe:i;.a.t.o,i:-1-1-c-e-n-s.e- f..or- tae

-.f.ae.--i.~1-~

12 .. 1. 5 The Racli.,olog.ic.al S ;i £e t~z Of£~:i.~- s.h~~1J.-have-a--Ba-Gh0 lar' s 12.1.5 The Radiation Safety Office~ sh~II h~ve a;;in*i~um'o{2~~~ ; s~of ~:p:r7:~le in personnel and environme ntal radiation monitoring programs. Classroom ed ucation in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

- - J --- J

~-ae-edue,a,t4-aa-and-~e~i.enc.e-r.equixements given abmze.

12.2 Procedures 12.2.1 Detailed written procedures shail be provided and followed for the following ~aae~Qc operations:

J 12.2.1.l Normal startHp, operation aaa shtitdewn of tae eom13l:eee faeility and 0£ *a11

• s:ys*tems and

- e ~ g - - f t t l t t t : e a r safety 0£ the -

facility.

( " *-*

f ~t<- ~l""D .

12~2.l.2 ~ operations.

12.2.1.3 Actions to be taken to correct specific and foreseen potential malfunctions of systems

• or components, including responses to alarms_,.f~~<.--'1~

suspected primary system leaks aaQ abagl'-!Bal 12.2.1.5 Preventive or corrective maintenance opera-tions which could have an effect on the safety of the Peeeeer, rlfC.ii./

1 12.2.2 Temporary procedures which do not change the intent of previously approved procequres may be utilized

• on approval by a lieeaeea SeRie!' Reseter QpePeter*

aod one other qualified individual. Such procedures shall be subsequently reviewed by the Reactor Safe-guards Committee.

12.3 Records r

/VLt&.1..Ac-.-'/\ . .

In addi~n te these records required under the facility license~~d applicable regulat1ons., the fellewiag rQQ.g:i;dil shall. lua .kap t whee 1-0Jru#e--m.Ei-aEE~~-B-- a --t:,-se-4~ad-;i,a-i:aa gr .a~igsrapa~

U ** 3.1 :the type and quantity of matedal-1-r~adtated.

12.:1.2 ~ate, Lime of"'tfay, aud length of exposute.

12.3 -. .3 toe.at neattorr and gmmua exposaze li!vel.

)

TA!>L! .1

(, Channel Detector Minimum Information Minimum Range Informs tion t o (No .) Sensitivity Logic tJ.emem:

. . (scram)

Sta

,, , rtup BF3 *4:5 ~ounts/sec per Neutron flux, source 1 ev.!?l to Perio.d ~cram; ( a )

\,J.J r '- "'1-'L \.J.VHCI..L ll/ - ~ -sec J;'t:l." .Lvs.. J. WaL(.; 10w coun.t: rate Counter s crem I. ~ 1n-14 I , n-2 .,..,,,ttr. .. ,...,

1--

V U I"- -- .,,, .. ~A

- ' .., - -*-- ... 1 ..... ",

- Period scram (2) ion chamber cm2 -sec period- 120% full power.

I T.inear TTn ....

- ,,~  !. I, * ,.. -1 li.

I -- *- ~- .,_

... ,1 -:in -"Rtt~ t-n Hiih and low Level ion chamber n/cro~~;;c 120% full power level \U/ scrams .. -

Safety ....

V, (3) - .. I Linear Compensated 4.4 X 10-14 amp/ Power

• level 10-l watts to High and low

~

1.,eVeJ. ion cnamoer u/cm -sec4 r:t.u7. -ru11 power level scram Sa f e ty (4) , . *-

(a) Scrams on Channel 1 are bJ passed wheri signal on Cheuoel .2 exceeds a £+/-,reel se tt fug similarl:) t-he hig,R veltage is Femeveel frem the lieteeter and

• t he deteeter :Ls sMrt:ed. ** * 'C"'

~) I,ew le..-el se'fam is hypessed en Channel 9 and 4---whert Ghi!!:nn e l 2 is be-lew* a fttea setting ,

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

.~:: *. .

~

16 - . i j*

,,.--*. i

'I

L I TABLE I

I .r SAFETY SYSTEM FUNCTIONS . . .J\~

, 1../J I 6**:

No. of Switches -.A.tlwmci~ a;~ Annunciator and Sensor or Tri Device or Sensors -ser t Alarm Set Point Short Per.iod.;......Chs- .L..._.,- 1-_ __.._ _ _-+- -

. High Neutron Flux

• r r*

Leuel; 6-ns.

• 3, 4

• High Temperature of

• Coolant Water l L- *13e f Low Pool Water Level l <l ft max decrease Seismic Disturbance l \ii 6Al 1\1',t>tkf, ~.)

• Merca li Sc~le

• max.

MGeP- /Ii . c~W s i I,

( I

. .. : Bricz~ Crane Location l When located off storage position

~

Lmr :fautron Detector V '

I evel

• Ch. 1 . 1 \,.

Los::: of Instrument Power; ~

!i Ch, 2, 1

& 4 *2 .

• . scale

• ----- r' I, t" ti *. 1, Area Radiation Monitor 1 S 10 mr/hr r

Water Radioactivity l 520 mr/hr i

i I.

. Demineralizer Water Flow l 2!4 gpm *1 Building Gas Effluent 1 I Monitor

°W"' <, ter Ke y Swi ,.:.11 l

II

~ 2 mr/hr iI I

!I i;

I i..:..;.....:.. ~:.::t...*\14Ji,-!4*~.;..***.:. .~ ._ . ....... ~ ... -_....,___;: ;b:.t:.. t i'cv\:-~ . -.. . l*.*.'.t;,J;;i

Enclosure 3 AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 June 28, 2019 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

Changes to the operating license R-98:

2B (1) Omit", use and operate".

Justification: no longer allowed in permanent shutdown and limits the authorization on possession to storage during decommissioning activities.

2B.(2) Omit "receive", and "and use"; exchange "operation" for "decommissioning" Justification: This removes authorization to receive and use fuel and limits the authorization on possession to storage during decommissioning activities.

2B.(3) Omit "receive", and "and use".

Justification With operation of the reactor prohibited, ARRR no longer has need to receive or use the startup source.

2C.(1) The Licensee is not authorized to operate the reactor at any power. Add "not" and omit "steady state power levels not in excess of 250 kilowatts (thermal)."

Justification: no longer allowed in permanent cessation of operation 2C.(2) Change Technical Specifications amendment no. from 5 to 6 and change "operate" to "maintain" Justification: current amendment is 5 new amendment would be 6.; operate suggests reactor operation whereas maintain suggests maintaining status quo ofstorage (Fuel possession only)

Changes to the Technical Specifications:

1.0 Definitions 1.1 Replace definition for Shutdown with Permanent Shutdown The reactor is permanently shut down when the reactor is maintained in permanent shut down configuration with the fuel elements stored in storage racks that maintain a criticality of equal to or less than 0.8 keff, 1.2 Replace Reactor Operation with Permanent Shutdown Configuration Core lattice containing no fuel or reflector elements and control rods disabled fully inserted.

1.8 Add the definition for Core Lattice The array of machined positions for fuel or reflector elements in the grid plates.

1

Enclosure 3 1.9 Add the definition for Core Structure The upper and lower grid plates connected by structural members Justification: Require new nomenclature to describe components independent of the presence offuel or reflectors.

2.3 Exchange the existing "operation" for "decommissioning" and change to .... with the storage of the fuel and reflector elements in the tank and the use of machine shop, electrical shop, and chemistry laboratory.

Justification: Reactor operation is prohibited and the hot cell no longer exists.

4.1 Exchange the existing "active core" for "core structure" and minimum temperature from "60 F" to "40 F" Justification: no longer allowed an active core. The 60 Fin the TS was extrapolated from experimental data when estimating isothermal temperature coefficient of the fuel when operating. This benchmark temperature is no longer needed simply for the storage offuel. Seasonal water temperature is approximately around 50 F thus a lower limit was selected to be 40 F. The lower temperature prevents the possibility ofhaving to heat the water because of an obsolete TS requirement. Aerojet-General Nucleonics Industrial Reactor -Hazards Summary report, AN-1193, September 1964. (Current SAR) 4.2 Omit "pH and" and "a pH of 7.5 or" Justification: pH is correlated with water conductivity; limiting conductivity to 5 D mho/cm ensures acceptable range ofpH This understanding is referenced in a May 11 2015 memorandum entitled Safety Evaluation Input by the Office of Nuclear Reactor Regulation Research and Test Reactors Pool Water-Safety Evaluation on Electrolytic Conductivity (TAC ME8511).

Change "at least once a month " to "quarterly" Justification: reasonable measurement frequency given storage strategy.

5.0 Reactor Core 5.1 Fuel Elements Insert "-No Fuel Elements shall be allowed in core lattice" 5.2 Reflector Elements Insert" -No Reflector elements shall be allowed in core Lattice" 5.3 Control Elements insert"- Control Elements shall be disabled and fully inserted in core lattice" Subsections of 5 .1, 5 .2, and 5 .3 are no longer needed given the restrictions. Omit these sections:

5.1.1, Justification: Prohibits the loading of any fuel into the core structure.

5 .1.2 Justification Maximum excess reactivity requirement is redundant with the more limiting prohibition of loading fuel into the core structure..

5 .1.3 Justification: Temperature coefficients are no longer relevant with the core defueled and all fuel storage facilities having maximum keff value of 0. 8, as limited in TS 11. 2.

5.1.4 Justification

Void coefficient is no longer relevant with the core defueled.

5.2.1 Justification

Reflector elements will no longer be allowed in the core. As such, dimensional requirements are no longer relevant.

5.3.1 Justification

This requirement is made obsolete by the prohibition of loading fuel into the core structure.

2

Enclosure 3 5 .3 .2 Justification: Without the possibility of adding reactivity, the minimum time requirement for control rods to drop is obsolete.

5.3.3 Justification

Without the possibility of adding reactivity, the minimum time requirement for control rods to drop is obsolete.

6.0 Reactor Safety System Insert "Reactor operations sequences, Interlock and safety systems need not be operable since no fuel and/or reflector elements shall be allowed in the core lattice."

Omit sections 6.1 through 6.6. These subsections are no longer needed due to the Permanent Shutdown and the Permanent shutdown configuration.

6.1 Justification

With no fuel allowed in the core, no possibility for criticality exists. Hence, the nuclear instruments and scram functions no longer serve any purpose.

6. 2 Justification: Without possibility for criticality, the alarms associated with operation of the nuclear instruments no longer serve a purpose with regards to safety.

6.3 Justification

With no fuel allowed in the core, scram circuitry and associated design requirements are irrelevant.

6. 4Justifcation: The condition for which this specification applies, fuel being in the core, is explicitly forbidden by modification of TS 5.1.

6.5 Justification

Control rod interlocks served to preclude the possibility ofachieving excessively high positive reactivity addition rates. With fuel no longer allowed in the core, control rod interlocks serve no further purpose.

6. 6 Justification: Critical experiments will no longer be possible with the prohibition of adding fuel to the core structure..

7.2 Exchange the existing "reactor operation" for "fuel movement in the reactor pool" and existing "reactor core" for "core structure" ; omit "and glory hole" Justification: Eliminates reference to reactor operation, which is now prohibited, and extends the sampling requirements to include all fuel movements in the pool; previously,fuel transfers that did not qualify as operation were exempt from this requirement. Changes from "reactor" to "reactor pool" and from "reactor core" to core structure" reflect a change in the functional necessity of monitoring these locations from operation to fuel storage and handling. Reference of the glory hole irradiation facility is eliminated, as the facility has been removed.

7 .3 Exchange the existing "on the console" for "in the control room" Justification: As the prohibition of adding fuel to the core structure eliminates the need for reactor controls, this allows for alarms to be consolidated at a single alarm panel within the protected area of the control room.

7.7 Renumber and relocate 6.7 to 7.7. Add the sentence "Table 1 contains alarm set points for sensors."

Justification: Maintains relevant sensors independent of inoperable safety interlock system.

8.0 Experimental Facilities 3

Enclosure 3 8.1 Large Component Irradiation Box Insert"- Not in pool and shall not be authorized for use."

8.2 Pneumatic Transfer Facility Insert"- Not in core lattice and shall not be authorized for use."

8.3 Glory Hole Facility Insert" -Not in pool and shall not be authorized for use."

8.4 Neutron radiography Facility Insert"- shall not be authorized for use."

8.5 Thermal Column Insert "-Shall be authorized for reflector element storage only."

8.6 Vertical Tube Insert"- Shall not be authorized for Use."

8.7 Other Irradiation Facilities Insert "-Shall not be authorized for Use."

Justification: experimental facilities cannot be used.

Most of these Subsections of 8.1, through 8.7 are no longer needed given the restrictions. Omit these specific sections:

8.1.1 Justification

The large-component irradiation box is no longer installed and is neither useful nor neutronically relevant with the core defueled.

8.1.2 Justification

The large-component irradiation box is no longer installed. There is no longer aneed for a requirement to purge with CO2 or maintain a positive pressure.

8.1. 3 Justification: ARRR will no longer have the capability to use the large-component irradiation box for irradiation. There is no reason to install it and no need for it to be purged of air, as there is no sufficient source of neutrons to which it can be exposed.

8.2.1 Justification

The pneumatic transfer facility is not installed and no longer has any practical use.

There is no reason to install it; operation, filtering, and monitoring regulations no longer serve any purpose.

8.2.2 Justification

Pneumatic transfer facility is no longer installed; regulation ofcontrol system is no longer necessary. Void volume is not relevant with fuel removed from the core.

8.3.1 Justification

Glory hole facility has been removed from the core and cannot be used for its intended purpose.

8.3.2 Justification

With fuel removed from the core, glory hole facility cannot be subjected to neutron flux. Requirement to minimize formation of argon-41 is not necessary.

8.5.2 Justification

With no source ofneutrons for experimentation, there is no longer a need to allow experiments to be attached to the thermal column.

8.6.1 Justification

With no source ofneutrons for experimentation, there is no longer a need to allow vertical irradiation tubes to be attached to the thermal column.

8.6.2 Justification

With no vertical tubes attached to the thermal column, and with no source ofneutrons for irradiation, there is no need for a requirement to purge with CO2 to prevent argon-41 buildup.

8. 7.1 Justification: Authority to use central hex for irradiation removed by change to TS 8. 7.

8. 7.2 Justification: Authority to use triangular exposure facilities removed by change to TS 8. 7.

8. 7. 3 Justification: Authority to use irradiation capsule in core structure removed by TS 8. 7.

9.0 Experiment Limitations Insert "-No experiments shall be authorized."

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Enclosure 3 9 .1 through 9 .11 Omit Justification: these subsections are not needed due the restriction ofno experiments will be authorized in

9.1 Justification

Evaluation of experiments will not be necessary; experiments in the pool will not be allowed per change to TS 9. 0.

9.2 Justification

There will be no further approval of any experimentation; review and approval requirement is no longer necessary:Focus of documentation requirement is shifted to record retention with respect to previously performed experiments.

9.3 Justification

This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9.4 Justification

This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9. 5 Justification: This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9. 6 Justification: This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9. 7 (including 9. 7.1-9. 7.3) Justification: This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9.8 Justification

This requirement can be eliminated as it is less restrictive than the prohibition of experiments proposed in TS 9. 0.

9.10 Justification: Experiment reactivity addition rate requirements are no longer relevant with fuel removed from the core and experiments prohibited in the reactor pool.

9.11 Justification: With no capability ofperforming neutron radiography, there is no need to maintain allowances and guidelines for introducing explosive materials to the facility.

9.11.1-9.11.3.1 Justification: This requirement is made obsolete by the prohibition of explosive materials proposed in TS 9.11.

9.11.3.2 Justification: No explosive material will be allowed in the facility. As the function of these records was solely to track explosive material while at the facility, maintenance of these records after prohibition of the explosives is not necessary.

9.11.4 (including9.11.4.1-9.11.4.2) Justification: This requirement is made obsolete by the prohibition of explosive materials proposed in TS 9.11.

9.12 Justification: With the prohibition ofexplosive material proposed in TS 9.11, there will be no personnel handling explosives; no explosives training will be necessary.

9.12.1 Justification: With the prohibition of explosive material proposed in TS 9.11, there will be no need for special equipment for the handling ofexplosives.

9.12. 2 Justification: With the prohibition of explosive material proposed in TS 9.11, there will be no need to restrict the operation ofhigh-frequency generating equipment.

9.12.3 Justification: Exposure limits for explosive devices are no longer relevant due to the prohibition of explosive material proposed in TS 9.11.

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Enclosure 3 9.12.4 Justification: This requirement is made obsolete by the prohibition of explosive materials proposed in TS 9.11.

10.0 General Operating limitations Insert "-No reactor operation shall be authorized."

Omit sections 10.1 10.2 and 10.3 Justification: These are not needed due to the restriction of no operation shall be authorized. It is no longer necessary to facilitate transition from an abnormal operating condition, as operation will no longer be allowed.

11.1 Insert words "when fuel is present" Justification: There is no need to keep the pits locked when not used for fuel storage.

11.3 Exchange existing words "Reactor Supervisor" for "Fuel Handling Supervisor" Justification: Consistent with proposed reorganization ofstaffing responsibilities.

11.4 Replace this section in its entirety with "Transfer of irradiated fuel in the reactor tank shall be conducted by a minimum staff of two, a Certified Fuel Handler (CFH) and an additional person trained in radiation safety. The staff shall monitor the operation using the appropriate radiation monitoring instrument. A RSO or designee shall be present for irradiated fuel transfers outside of the reactor tank but within the facility. Under no circumstance is fuel to be transferred to or stored in the core lattice."

Justification: activities limited to Fuel storage and transfer only.

11.5 Omit "or in the core lattice" Justification: No fuel shall be stored in core lattice.

12.1.1 Change from "Reactor Supervisor" to "Certified Fuel Handler Supervisor" Change from "reactor operations" to "fuel handling operations" Justification: The authority and technical capabilities focus on fuel handling and not reactor operation.

12.1.2 Change from "Manager" to "President" Justification: Clarifying administrative responsibilities. "Manager" was an artifact of an administrative position when Aerojet General owned the facility; the Current administrative officers have been President and General Manager (GM only since 2008). President was recently assigned the title of "Manager" to avoid confusion.

12.1.3 Change wording "operating organization" to Aerotest Operations, Inc.

12.1.3.2 Replace with "Reviewing facilities procedures and significant facility modifications."

12.1.3.3 Remove the word "experiments" 12.1.3.4 Remove the words "reactor operations and" 12.1.3.6 Change from "Manager" to "President" (see 12.1.2.)

Justification: Reactor Safeguard Committee restructured to meet the needs of the decommissioning facility 12.1.4 The CFH Supervisor shall have at least 5 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles. Classroom education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Justification: These are more reasonable technical qualifications for CFH supervisor given the duties.

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Enclosure 3 12.1.5 The Radiation Safety Officer shall have a minimum of 2 years of experience in personnel and environmental radiation monitoring programs. Classroom education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Justification: These are more reasonable technical qualifications for an RSO given the duties.

12.2.1 Omit the word "reactor" Justification: Operation prohibited 12.2.1.1 Omit in its entirety.

Justification: Operation prohibited 12.2.1.2 Change from "Refueling" to "Fuel Handling" Justification: changes reflect that no fuel to be loaded in the core lattice.

12.2.1.3 Omit "and abnormal reactivity changes." add an "resulting in" after alarms Justification: procedures are to protect the safety of the facility.

12.2.1.5 Change "reactor" to "facility" Justification: procedures are to protect the safety of the facility.

12.2.2 Omit "licensed Senior Reactor Operator and one other" Justification: the skill ofSROIROs are not needed.

12.3 Records "In addition to these" replaced with "Maintain" Omit the wording "the following records shall be kept when explosive materials are to be irradiated or radiographed:"

Omit sections 12.3.1 to 12.3.3 Justification: no experiments are to be allowed including those that contain explosives.

Page 15: Omit Table 1 Nuclear Instrumentation Justification: console instrumentation listed in this table are no longer needed since no fuel or reflector elements are to be placed in the core lattice. The controls rod drives are disconnected with the rods fully inserted.

Page 16: Change Table number from 2 to 1. Omit Safety System Functions associated with reactor operation: short period, high neutron flux level, low neutron detector voltage, low source level, loss of instrument power, low neutron flux, master key switch, and manual scram button.

Justification: the safety functions are no longer needed given the absence offuel and reflectors in the core lattice. The neutron counts will be well below detectable levels and no power will be available to the console. The controls rod drives are disconnected with the rods fully inserted.

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