ML21126A150

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License and TS Amendments
ML21126A150
Person / Time
Site: Aerotest
Issue date: 04/28/2021
From: Slaughter D
Aerotest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21126A150 (39)
v • d • e


Text

{{#Wiki_filter:I , AEROTEST OPERATIONS, INC. 3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

  • F;AX (925) 866-1716 April 28, 2021 I

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_NRC staff's communication 3/30/21 ML21o47A468 requesting supplemental information. Request for additional information (RAI) numbered 28 and 29 appear unrelated to the License and Technical Specifications. These are found under the heading Other; our response to those items will be sent under separate cover. 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 with the list of explanations, changes and justifications provided in . A more extensive proposed amendments are shown in a "penciled" markup of the proposed License and TS (Enclosure 2). A clean copy (Enclosure 3) with the changes included. Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 63_1 5919 or dmsraven@gmail.com. I declare under penalty of perjury that the statements above are correct and truthful. PJ/A-jn--__ David M. Slaughter, Ph.D. President, Reactor Administrator, Manager Aerotest Operations, Inc.

Enclosures:

1. List of Explanations, Changes, and Justifications
2. Mark-up of License and TS
3. Clean copy of proposed License and TS

Enclosure 1 RAI Response L.C. and Tech Specs: RAis - License Conditions

1. The regulations in 10 CFR Part 70 provide for the licensing of receipt, possession, and use of SNM. We did not agree with NRC staffs proposed LC2.B.(2) we have changed it to:
            "Pursuant to the Act and 10 CFR Part 70, "Special Nuclear Material," to possess up to 5.0 kilograms of contained uranium 235, and limit actions involving special nuclear material to those related to fuel storage and decommissioning."

We chose this wording based on 10 CFR 70.38 C (1): Each specific license continues in effect, beyond the expiration date if necessary, with respect to possession of special nuclear material until the Commission notifies the licensee in writing that the license is terminated. During this time, the licensee shall-(1) Limit actions involving special nuclear material to those related to decommissioning

2. The regulations in 10 CFR Part 30 provide for the licensing of receipt, possession, and use of byproduct material. We did not agree with NRC staffs proposed LC2.B.(3) we have changed it to:
            "Pursuant to the Act and 10 CFR Part 30, "Licensing of Byproduct Material,"

(1) to possess, and 2 curie americium-beryllium neutron startup source, and (2) to possess, but not to separate, such byproduct material and limit actions involving byproduct material to those related to fuel storage and decommissioning." We chose this wording based on 10 CFR 30.36 C (1): Each specific license continues in effect, beyond the expiration date if necessary, with respect to possession of byproduct material until the Commission noiifies the licensee in writing that the license is terminated. During this time, the licensee shall-(1) Limit actions involving byproduct material to those related to decommissioning; and

3. Revised LC 2.C.(3) to the NRC proposed wording:
              "Physical Security Plan The licensee shall maintain in effect and fully implement all provisions of the NRC-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR Section 50.54(p). The approved

Enclosure 1 security plan consists of the document withheld from public disclosure pursuant to 10 CFR 73.21, entitled, "Aerotest Operations, Inc. Security Plan," dated October 1, 2020"

4. Revised LC 2.C.(4) to the NRC proposed wording:
                 "Certified Fuel Handler Training and Requalification Program Whenever the.licensee processes TRIGA fuel elements pursuant to License Condition 2.B.(2), the licensee shall maintain in effect and full implement all provisions of the NRC-approved Certified Fuel handler training and requalification Program, including changes made to the program without NRC approval as permitted by the program. The approved program consists of the document entitled' "ARRRCFH Training/Requalification Program," dated---- 2021. Certified Fuel Handlers qualified in accordance with the program may approve licensee actions permitted by 10 CPR 50.54 (x)."
5. Revised LC 2.F by removing license expiration date:
            "This amended license is effective as of the date of issuance and shall follow requirements outlined in 10 CFR 50.51 (b)."

RAis -Technical Specifications 5.1 Revised TS 1.1 to the NRC proposed wording: 

            "Permanent Shutdown The reactor is permanently shut down when the reactor is maintained in permanent shut down configuration."
6. Revised TS 2.3 to provide better clarity to read:
            "The principal activity carried on within the exclusion area shall be associated with fuel storage and decommissioning of the ARRR; however, it does not exclude other activities from being performed using unimpacted facility areas i.e.,

machine shop, electrical shop, chemistry laboratory, etc. RAI's 6.3-6.5 are not relevant with the new revision

7. Revised TS 3.1.2 to change "in the roof' back to "on the roof' it now reads:
            "Ventilation shall be achieved by gravity ventilators located on the roof of the building, and"

Enclosure 1

8. Deleted TS 3.2
9. TS 4.2 "The conductivity of the primary coolant shall be measured at least once quarterly. Corrective action shall be taken to avoid exceeding a conductivity of 5 mho/cm.

The NRC guidance suggests if the reactor is not operated for a long period of time the surveillance interval may be less frequent. While a recommendation in provided in section 4.3(6) in Appendix 14.1 ofNUREG-1537 Part 1 The reactor has been inoperable for more than 10 years. The existing measured surveillance data during last ten years shows no significant variation.

10. TS 6.0 Mike Working on Table 5.1 "Reactor Safety Systems Safety System Instruments listed in Table 1 shall be operable as long as fuel is present at the facility. A thirty day out of service period shall be allowed to facilitate repairs, replacements, maintenance, and/or calibration to any of the instruments listed in Table l."
11. Revised TS 8.5 to reflect the NRC proposed corrections:
           "Thermal Column Shall be authorized for reflector element storage only.

8.5.1 The thermal column shall be positioned remotely on steel locating pins immediately adjacent to the reactor structure. 8.5.2 The thermal column shall be composed of a three-foot cube of graphite encased in aluminum containing five rows of 1.5 in. diameter irradiation holes. The rows shall be placed 6 inches apart and contain seven holes per row.

12. Revised TS 11.3 to reflect the NRC proposed corrections:

Enclosure 1 "A fuel handling tool shall be used in transferring fuel elements of low radioactivity between the storage pits and the reactor; a shielded transfer cask shall be used for the transfer of highly radioactive fuel elements. The fuel handling tool shall remain in a locked cabinet under the cogniz.aoce of the Certified Fuel Handling Supervisor when not authorized for use."

13. Revised TS 11.4 to reflect NRC proposed corrections and clarify transfer location it now reads:
                         "The transfer of irradiated fuel in the reactor tank, storage pits and facility 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 a hand held Gama/Beta monitoring instrument The Radiation Safety Officer or designee shall be present for irradiated fuel transfers outside of the reactor tank.
14. Revised TS 11.5 to reflect NRC proposed corrections it now reads:
                         No more than one fuel element shall be allowed in the facility which is not in storage. The only movement of the fuel elements are for fuel element inspections, canister surveillances, rearrangement of fuel elements in storage, or final placement in the transportation cask."
15. Revised TS 12.1 to the following to address organizational structure, individual responsibilities and reporting.

12.1 Organization (Figure 1) 12.1.1 Aerotest Operations President {Level 1) shall have the responsibilities for all activities associated with obligations and processes associated with operating

Aerotest-- OpeFati0ns-whieh-in eludes-eomplying-wi t-h-lirense-and--:reci lniGal--------

specifications, facility physical security and safety programs. The President of Aerotest Operations, Inc. shall report to the Board of Directors of Aerotest Operations, Inc. 12.1.2 The Reactor Administrator (Level 2) shall have the responsibilities of ensuring security and safety of the Aerotest facility. He/she shall enforce, review and amend procedures associated with security and safety programs. The reactor administrator shall be responsible to the President, Aerotest Operations, Inc. The Reactor Adminastrator shall have a minimum of 5 years of experience in reactor operations, 2 years of experience with personnel and environmental/occupational radiation monitoring programs, and 2 years of experience with complying with government regulations. Successfully

Enclosure 1 completed college level work in the nuclear and radiation related fields of stl!dY may be considered In lleu of the experience requirement. 12.1.3 The Certified Fuel Handler Supervisor (Level 3) shall have the responsibility of handling fuel and In all matters pertaining to fuel handling operations and to these Technical Specifications, the Certified Fuel Handler Supervisor shall be responsible to the President, Aerotest Operations, Inc. 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. Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements. 12.1.4 The Radiation Safety Officer (Level 3) shall review and approve all procedures involving radiological safety. He/she shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the President, Aerotest Operations, Inc. The Radiation Safety Officer shall have a minimum of 2 years of experience in personnel and envlronmental/occupational radiation monitoring programs. Successfully completed college level work In the nuclear and radiation related fields of study may be considered in lieu of the Xperlence requirement. 12.1.5 The Certified Fuel Handler (level 4) is a non-licensed operator who has qualified in accordance with the Certified Fuel Handler Training and Requalification Program.Fuel handling obligations include maintenance, periodic fuel inspections and/or putting the spent fuel in transportation caskets for fuel shipment from facility. The CFH only handle fuel when need and only handle 1 fuel element at a time. The CFH does not make decisions on fuel handing, decommissioning or radiation; those are made by the Reactor Administrator or Radiation Safety Officer (RSO). the CFH shall have at least 2 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles. Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements. 12.1.6 The Reactor Safeguards Committee shall be composed of not less than five members, of whom no more than three are members of Aerotest Operations, Inc. 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:

Enclosure 1 12.1.6.1 Reviewing and approving nuclear safety standard's associated with the use of the facility; 12.1.6.2 Reviewing facilities procedures and modifications; 12.1.6.3 Determining whether proposed changes to the facility or procedures are allowed without prior authorization by the NRC, as detailed in 10 CFR 50.59,; 12.1.6.4 Conducting periodic audits of procedures, maintenance, equipment performance, and records; 12.1.6.5 Reviewing all reported violations of these Technical Specifications, evaluating the causes of such events and the corrective action taken and recommending measures to prevent reoccurrence and; 12.1.6.6 Reporting their findings and recommendations concerning the above to the President, Aerotest Operations, Inc.

16. TS 12.1.3.2 revised to TS 12.1.6.2 and now reads:
          "Reviewing facilities procedures and modifications;"

RAI 16.2. All is not needed. The statement does restrict any procedure or modification from review RAI 16.3 removed "significant" from the TS

17. TS 12.1.3.3 revised to TS 12.1.6.3 "Determining whether proposed changes to the facility or procedures are allowed without prior authorization by the NRC, as detailed in 10 CPR 50.59;"
18. TS 12.1.3.5 revised to TS 12.1.6.5 now reads:
          "Reviewing all reported violations of these Technical Specifications, evaluating the causes of such events and the corrective action taken and recommending measures to prevent reoccurrence and;"

Enclosure 1 The term abnormal occurrences was removed due to no relevant definition of the term's use. NRC staff asked in a previous RAI the description of abnormal. Tue licensee could not determine the definition of abnormal occurrences; thus, its removal was obligated.

19. TS 12.1.3.6 revised to TS 12.1.6.6. We added Inc. and took out the quotation marks intentionally.
               "Reporting their findings and recommendations concerning the above to the President, Aerotest Operations, Inc."
20. TS 12.1.4 revised to 12.1.3 wording has been changed to that in the ARRR CFHTRP "The Certified Fuel Handler Supervisor (Level 3) shall have the responsibility of handling fuel and in all matters pertaining to fuel handling operations and to these Technical Specifications, the Certified Fuel Handler Supervisor shall be responsible to the President, Aerotest Operations, Inc. 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. Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements."
21. TS 12.1.5 revised to 12.1.4 "The Radiation Safety Officer (Level 3) shall review and approve all procedures involving radiological safety. He/she shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the President, Aerotest Operations, Inc. The Radiation Safety Officer shall have a minimum of 2 years of experience in personnel and environmental/occupational radiation monitoring programs. Successfully completed college level work in the nuclear and radiation related fields of study

- -- - - --- --may-beconsrdered mheu of the expenence requrrement." -- - -- - - - - - - Removal of "at a nuclear facility. A nuclear facility, by definition, suggests an operating reactor, The POL is concerned with storage not operation. It is appropriate to focus on the broader skill set and experience in occupational/environmental radiation monitoring programs.

22. Revised TS 12.2.1 "Detailed written procedures shall be provided and followed for the following operations:

Enclosure 1 12.2.1.1 Fuel Handling operations; 12.2.1.2 Systems and components involving nuclear safety systems of the facility. 12.2.1.3 Actions to be taken to correct specific and foreseen potential malfunctions of systems or components, including responses to alarms and suspected primary system leaks; 12.2.1.4 Preventative or corrective maintenance operations which could have an effect on the safety of the facility. RAJ 22.1 A relevant portion of the noted deleted TS 12.2.1.1 has been included in TS 12.2.1.2 RAJ 22.2 Provide a justification for the proposed change. TS 12.2.1.2 was corrected and renumbered to TS 12.2.1.3

23. Revised TS 12.2.2 to reflect the NRC proposed corrections:
                         "Temporary procedures which do not change the intent of previously approved procedures may be utilized on approval by the Reactor Administrator. Such procedures shall be subsequently reviewed by the Reactor Safeguards Committee."

23 .2 Reactor Administration is now defined in the Organizational Chart and TS 12.1.2.

24. Revised TS 12.3 "Records Records shall be maintained as required by the facility license and applicable regulations."

---RAls-Otne:r TS Changes:

25. We confirm the punctuation changes. The removed punctuation does not impact the meaning.
26. We confirm the punctuation changes. The removed punctuation does not impact the meaning.
27. We confirm the punctuation changes. The removed punctuation does not impact the meaning.
  • I 't ,.

Enclosure 1 RAJ - Changes made by Areotest Operations of clarity 7 .1 Deleted " Both" and "and a criticality alarm" 7 .2. Now reads: 

                  "During fuel movement in reactor pool, a gas sample shall be continuously withdrawn from above the reactor in the vicinity of the reactor bridge. The gas-effluent shall be monitored by a beta-gamma detector which shall have a continuous readout in the control room. An annunciator shall indicate when the gas exceeds 2 mr/hr."

We deleted the roof vent" from between "continuously withdrawn from" and "above the reactor" We added "in" after "above the reactor." We deleted "over the core structure and pumped through a radioactive gas detection chamber after the reactor bridge." We replace "The gas chamber" with "The gas effluent." 7.6 Replaced "detector packets containing a series of threshold detectors" with "dosimeter" and replace "post accident" with "area".

"J 8.EROTEST RADIOG API IY AND RESE:\RCJ I RJ;.->C[Ol{i,._\l{RRJ AMENDMENT TO CILITY OPERATIN_iUJCENSL Amendment No. 6 License No. R-98

1. The Nuclear Regulatory Cornn ission (NRC 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. ct transfer of license and confom1ing amendments to Amended Facility Ope ting 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; Janu ry IO, 2013: and April 21, June I 6, August 22, and October 10, 2016, complies wi the standards an*d requirements of the Atomic Energy Act of 1954 (the Act), as ame ded, and the rules and regulations of the Commission as stated in Title 10, Chap er I. **Nuclear Regulatory Commission, of the Code cf Federal Regulations ( I CFR Chapter I).

8. Construction of the fac ity has been substantially completed in confom1ity with Construction Permit N . CPRR-86, and the application, as amended, the provisions of the Act and the rules and regulations of the Commission; C. The facility will operat in confom1ity with the application, as amended, the provisionsof the Act, a dllie rules ani:J regulationsofthe* CoH1missio-n~* - - -

D. There is reasonable ass ranee: (i) that the activities authorizL-d by this operating license can be conduct without endangering the health and safety of the public, and (ii) that such activities *ill be conducted in compliance with the rules and regulations of the Commission; E. Aerotest Operations, In*. is technically and financially qualified to possess, use, and operate the facility in a cordance with the rules and regulations of the Commission: 1 Amendment No 6

F  !"he issuance of this ope, ting lii.:ensc \\ill not b1.: inimil:al to the l.:l 111111llll1 Jd~n:-.e and security or to the he Ith and :-iafct) ol' thl! public. unJ Joe:-. not imul\e a signifo;ant hatnrds cons eration: G. The receipt, possession, anti use of byproduct anti special nudear matl!rinl a::, authorized by this licen '\\ ill he in accordam:c \\ ith the Cummbsion*s regulations in 10 CFR P rts 30 arn.J 70. in..:luding Sectiun~ 30.33. 70.23, am! 70.31: I. The transfer of the licen e is otherwise consistent with applicable prm is ions of la\',, regulations, and or crs issued by the Commission pursuant thereto.

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

A. This license applies to e Aerotest Radiography and Research Reactor (ARRR), a pool-type nuclear react owned by Aerotest Operations, Inc. The facility is located at the Aerotest Operatio s site near San Ramon, California, and is described in the application dated Septe ber 14, I 964 (the application), and in supplements thereto, including the applicatio for transfer of license dated April 24, I 974, and the application for indirect t nsferdated Ma) 30, 2012. B. Subject to the condition and requirements incorporated herein, the Commission hereby licenses Aerates Operations, Inc.: (1) Pursuant to Sectio 104c of the Act and 10 CFR Part 50. "Licensing of Production and Uti ization Facilities," to possess the reactor at the designated locatio in San Ramon, California, in accordance \\.ith the 

     ~-- ___procedures and lim          tations set forth in this license:__ ___ _ __ ----~- _

(2) Pursuant to the Act and 10 CFR Part 70, "Spt..>cial Nuclear Material," to possess up to 5 .0 ki ograms of contained uraniufTl 23 5 in eonm:ctiop wit Ii 

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(3) Pursuant to the Act and IO CFR Part 30, **Licensing of Byproduct Makrial," d~t~\':>S\o;.._v (I) to possess, and curie americium-beryllium neutron startup source, and (2) to possess, but ot to separate, such bvproduct material asma5 be-p1oduced by op~ nuf1~r. ' 

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2 Amendment No 6

C Thi.., liccn-;e :-ihull hi: di: mt:J ll) contain and i-, -,uh1ect ll1 thi: cl1ndilil11i-. -,pi:c1lii:d in lite fol km ing Cl)lllmi-,:;ion e!.!.ulatiun:-. 111 IO lTR Ch.~pti:r I* Part 20. Sectillll 30. "i I i)r Part

10. Sections 50.5-1 anc.l 0~59 nr Part 50. and Si.:ction 70.32 llf Part 70: i-, . . ubji:ct tP all
          ;pplicable pro\'isions ol the Act and Ill the rule-,. regulation-;. and _Prdi.:r-, of t~1~

Commi:-ision no,, or hi: *alii:r in dkct: and i:-i . . ubji:ct to thi: add111onal cond1t101i-. 

           -;pi:ci lied or incorpomti: bi:lm,

( 1) The licensee is not, 1thori1ed to opemte the foci lit) at an) pmH!I (2) Technical S cc* fica i ms The Technical Spec fications contained in Appendix A, as revised through Amendment No. 6. re hereb) incorporated in the license. The licensee shall maintain the focilit) in accordance with the Technical Specificatil1ns. (3) The licensee shall n aintain in effect and fully implement all provisions of the NRC-appro\. ed phy ical security plan, including amendments and changes made IC> Cf,£.. pursuant to the auth rity of IO CFR Section 50.54(p). The approved securit} IL"

  • plan consists of the ocument withheld from public disclosure pursuant ta-to- ~
                -CFB 2 7~0{,d), entit ed **Aerotest Operations, Inc. Security Plan-eatec:b\:gg.i.iiit                    7 S 2-\

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                ~~{-J:x_,1/4 D. Reports In addition to rep011s othen isc required under the license and applicable regulations:

(1) The licensee shall port in writing to the Commission within IO days of its observed occurrenc any incident or condition relating to the operation of the facility which preve ted or could have prevented a nuclear system from performing its safet function as described in the Technical Specifications or in the H~ds~umm _R!port. ________________________ _ (2) The licensee shall r port to the Commission in writing within 30 da}s of its observed occurrenc any substantial variance disclosed by operation of the facility from perfor rnnce specifications contained in the I Iazan.ls Summary Report or the Techn cal Specifications. (3) The licensee shall r port to the Commission in writing within 30 days of its occurrence any sig ificant change in transit!nt or accident analysis, as described in the Hazards Sum ary Report. Whenever the licen processes 1RIGA fuel elements pursuant to License Con~i~on 2.B.(2), t e licensee shall maintain in effect and full implement all prov1s10~ of tlu~ C-approved Certified Fuel handler training and requalification Pro~, mcludrng hanges made to the program without NRC approval as permitted by the pro . The approved program consists of the document entitled' "ARRRCFH Trainin equalification Program," dated - - 2021. Certified Fuel 

              ~an~,~rs.1~i!i:_~~          ~~~d~ce with the program may approve licensee actions

In aJJit1on to tlw-.,c othcrwi

  • 1cquircd umkr thi-., lii.:L*11-.,c: n11d appli-:abk n:gulatio1h. the licensL-c shall keep the folio 111g*

(1) Reactor operating ccPrd:-.. ini.:luding plme1 k\cb (2) Records shm\ ing r dioacti\ it~ released or JischargeJ -into the .uir or\\ atcr beyond the effccti1,

  • contrnl of the lict:n-;ec n:i measured at the point of such release or discharg .

(3) Records of emerge 1cy reactor scrams, including reasons for emcrgenc~ shutdowns. F. is amended licen d hal t'.. 5 e&J:L 

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4 Amendment No 6

t\PPENDIX ~ LICENSE NO. R-98 TECHNI AL SPECIFICATIONS tOR THE AEROTEST RADIO RAPHY AND RESEARCH REACTOR ARRR 1.0 Definitions 1.1 Permanent Shutdown The reactor is permanen ly shut down when the reactor is maintained in permanent shut down configuration * *

  • a 1.2 Core lattice containing n fuel or reflector elements and control rods disabled fully inserted.

1.3 Operable A system or component hall be considered operable when it is capable of performing its required function in it normal manner. 1.4 Operating A component or system f operating if ft is performing its required function in its normal manner. 1.5 Experiment Experiment shall mean a y apparatus, device, or material installed in the core or _ - ~ _ e~Q.grlment.aLfac.ilitfes_(e cept.fornnder:water. lfghts,-fuel-stor-age-raGks and-the like)-- - which is not a normal pa of these facilities. 1.6 Experimental Facilities Experimental facilities sh II mean Glory Hole, vertical tubes, pneumatic transfer systems, central thimble, beam tubes, thermal column, and in-pool Irradiation facilities. 1.7 Reactor Safety Circuits Reactor safety circuits sh II mean those circuits, including their associated Input circuits, which are designed to ini iate a reactor scram.

1.8 Core Lattice The array of machined p sitions for fuel or reflector elementc; 111 the grid plates 1.9 Core Structure The upper and lower gri plates connected by structural members. 2.0 Reactor Site 2.1 ~- 2.2 A steel, locked perimete fence shall surround the ARRR facility, forming an exclusion area. The minimum dist ce from the center of the reactor pool to the boundary of the exclusion area fencing s all be 50 feet. The restricted area, as defined in 10 CFR 20, shall consist of the entjre excl sion area. Qc:;\-\\l\~ f ~\ ' 2.3 Th principal aEtiviti9S ca *ed on within the exclusion area shall be"'t'he-5&.associated with ~ ¥'tl_ QAcl, ~ecommissioning of he ARRR'r~a1Ad thi Ulii sf fl'laCFtiRe i;hrJf3, electrical 3hop O....S 

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l 3.1 The reactor shall be hou ed in a steel building capable of meeting the following functional requirements 3.1.1 All circulating fa sand air conditioning systems except the system which supplies air to th control room shall have the capability to be shut off from a single control in he control room, 

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3.1.2 Ventllation shall e achieved by gravity ventilators located~ the roof of the building, and 3.1.3 A positive air pre sure shall be maintained in the control room with respect to the reactor roo 3.2 4.0 Reactor Pool (Primary System) 4.1 The minimum depth of ter above the top of the core structure shall be 16 ft. The maximum bulk water te perature shall be 130°F and the minimum 40°F.

4.2 The conduct1v1ty of the p 1rnary coolant shall be measured at least once quarterly. Corrective action shall b taken to avoid exceeding a conductivity of 5 LLmho/cm 5.0 Reactor Core 5.1 Fuel Elements No fuel elements shall b allowed in the core lattice. 5.2 Reflector Elements No reflector elements sh II be allowed in core lattice. 5.3 Control Elements Control elements shall b disabled and fully inserted in core lattice. 6.0 Reactor Safety System~ S _cs.R' e ~ 5 cj Safety ystem Instruments listed in Tabk 1 s~ajl be ?pe~ble as long as fuel is 

        \ ~ ::S:: C..,\r:)\JL,..J present the facility. A thirty day out of service penod. shal~ be allowed to
        '.v-R. c Ytl'i::.PI'~ facilita repairs, replacements, maintenance, and/or calibration to any of the
                                 ' .......,,,-""nts listed in Table l ."

7.0 7 .1 A fixed gamma monitor mploying Geiger tube detectors shall be located on the wall connecting the control r om and the reactor room. This monitor shall serve as b.Q.th.an area radiation monltortt&-e-efi~i-lH¥-d~Q: l.and will annunciate through an automatic monitoring system to th San Ramon, California, Fire Department and actuate a siren within the reactor buildi g on high radiation level. The monitor shall have a minimum range of Oto 20 mr/hr. e annunciation and the siren actuation shall be tested monthly. 7.2 During fuel movement I reactor pool, a gas sample shall be continuously withdrawn the react&,-M: f1 on, the vicinity of the reactor bridge ooe: ~Ri-. 

            "t:011"M:trattorre;-&A<~um~Ull+O-bl§R-.a.-fii~tlll.e1.g.a~e.tecllil!l..l:ba.m!l~. The gas ed by a beta-gamma detector which shall have a continuous readout in the control ro m. An annunciator shall indicate when the gas exceeds 2 mr/hr.

7.3 A fission product water onitor shall be attached to the process water cleanup system loop adjacent to the de ineralizer and shall provide continuous Indication In the control room. High radiation lev Is within the demineralizer or pool water shall annunciate an audible alarm in the con rol room. The range of the monitor shall be from 0.1 to 100 mr/hr. 

                                                                                                                       *Sc\ c....\o s v r 12.. ?-

7.4 Portable survey instrume ts for measuring beta-gamma dose rates in the range of O O1 mr/hr to 50 r/hr shall be va1lable at the facility 7s Portable instruments for ,easuring fast and thermal neutron dose rates from O 1 mrem/hr to 1.0 rem/hrs all be available at the facility. dO'::>\ro 7.6 Radiation e@~~i:...p.;a.o~;..c.cw.t.+R+Ag..a-!..eJ:Jie.s...o.t..Lll!:es.JJ.Q!QJ!.e.tf'!!:J;t a.,iqo sh a11 be p Iaced at e reactor building for t3e!lt seeieleRt radiation analysis. Q(~O..... 7.7 Process instrumentation ith readout in the control room shall be operating to permit continuous indication of ool water temperature and conductivity. Alarms shall be operable to indicate low ater flow, low pool water and improper location of the crane bridge. Table 1 contains larm setpoints for sensors. 8.0 Experimental Facilities 8.1 Not in pool and shall not e authorized for use. 8.2 Pneuma ic Transfer Facili Not in core lattice and sh II not be authorized for use. 8.3 Glory Hole Facility Not In pool and shall not e authorized for use. 8.4 Neutron Radio ra . __________ 8.4.1 T~eam_tube_s II.consist of..a-two-se<rt~0n tapered-tube-having a rectangular-- pper and lower ~ections of the tube shall be equipped with a 8.4.2 All components c ntacting the pool water shall be fabricated from aluminum or stainless steel. 8.4.3 The beam catche shield shall consist of a movable radiation shield. 8.5 Thermal Column Shall be authorized for re ector element storage only.

8.5.1 n shall be positioned remotely on steel locating pins immediately adJ cent to the reactor~ ~.\--vc_j._)r-JL.. 8.6 Vertical Tube Shall not be authorized f 8.7 Other Irradiation Facilit1 Shall not be authorized f ruse 9.0 Experiment Limitation No experiments shall be authoriz d. 10.0 General Operating Limitations No reactor operation shall be au orized. 11.0 Fuel Transfer and Storage 11.1 The fuel storage pits loca ed in the floor of the reactor room shall accommodate a maximum of 19 fuel ele ents (700 gm U-235} in storage racks dry or flooded with water. The fuel storage p ts shall be secured with a lock and chain when fuel is present except during fuel transf r operations. 11.2 Additional fuel storage r ks may be located In the reactor tank. Each of these storage facilities shall be so deslg ed that for all conditions of moderation kett shall not exceed a value of 0.8. 11.3 A fuel handling tool shall e used in transferring fuel elements of low radioactivity 

~e...... -         betweer\'storage pits an the reactor; a shielded transfer cask shall be used for the

_ __ _ ____ transfer of ~lghly r"?diQa _iY_e f_u_el elements._The_fueLhandling tool shall remain-in-a- - - -- -- - - locked cabinet under the ognlzance of the Fuel Handling_ Supervisor when not authorized for use. A ~ . \ , ~, @-d. . . Pl.. S3/4o-r-ct':)~? \.\- ~r"\d Fo.._c...\ \\ t,4 11.4 Transfer of irradiated fue in the reactor tan~ snall be conducted by a minimum of staff -.- \ 

             ,.,. of two~ a Certified Fuel H ndler (CFH) and art additional person trained in radiation             ~             \-\clJ Ro..d ,o...\.-liC\ ~~:~~;,:~ sAa~:all mo itor the operation using~e1ppr:or;irie1te radiation monito~L,.,. __

S Q.-f'~ O 1/4,~~(""' the reactor tank, or des gnee shall be present for irradiated fuel transfers outside of 

                                                                                                                      ~N\°'1
                                                                                                                         ~.Q....-\-o-._,
                    ~

11.5 'NQJ;_more than one fuel e ement shall be allowed in the facility which is not in storage. The only movement of e fuel elements are tor fuel element mspecuons, canister surveillances, rearrang ent of fuel elements in storage, or final placement in the transportation k." 

        ~

8.5.2 The thermal column shall be posed of a tbree-roo1 cuoe or grapnne encased in aluminum containin five rows of 1.5 in. diameter irradiation 

 ~ s . The rows shall be pla                 6 inches apart and contain seven holes per 12.0  Administrative Requirements 12.1   OrgaAI~

\ \ ~ \ t\t.,e,J 

~-L 12.1.2                       afety Officer shall review and approve al rocedures and ving radiological safety. He shall enforc rules, regulations and
 \~Q_,~\-

procedures relat to radiological safety, conduct rout" e radiation surveys and is responsible to he resident, Aerotest Operations, I c. 

 '?a..sQ_

12.1.3 The Reactor Sa ittee shall be c of not less than five members, of an three are rs of Aerotest Operations, ci ?C\1~ Inc. The comm an and they shall meet at ---===:::::::: least annually. following: e for, but not limited to the 12.1.3.1 ewing and a lear safety standards associated the use oft 12.1.3.2 es and significant modifications; 12.1.3.3 modifications irflO t: FR-50,, Technical. 5 ~R....-f, \o cr-e so, 12.1.3.4 o..r+ so periodic audits of proced t performance, and records; 12.1.3.5 R v* wing all reported abno1111al"1CC.I.IIT.ence.S ii violations of t se Technical Specifications, evaluating the caus s of such ents and the corrective action taken and recomm ding easures to prevent reoccurrence and; R porting their findings and recommendations concern in a ove to the President, Aerotest Operations, Inc. 12.1.4 hall _!,ave a experlen mov onstrated e relevan ALAR clearand fields

12,0 Administrative Requirements 12.1 Organization (Figure 1) 12.1.1 Aerotest Oper ions President (Level 1) shall have the responsibilities for all activities assoc ted with obllgatlons and processes associated with operating Aerotest Ope ions which Includes complying with license and Technical specifications, cility physical security and safety programs. The President of Aerotest Ope tlons, Inc. shall report to the Board of Directors of Aerotest Operations, In . 12.1.2 The Reactor A mlnistrator (Level 2) shall have the responsibilities of ensuring security and sa ety of the Aerotest facility. He/she shall enforce, review and amend proced res associated with security and safety programs. The reactor administrator hall be responsible to the President, Aerotest Operations, Inc. The Reactor A minastrator shall have a minimum of 5 years of experience In reactor operat ons, 2 years of experience with personnel and environmental occupational radiation monitoring programs, and 2 years of experience wit complying with government regulations. Successfully completed coll ge level work in the nuclear and radiation related fields of study may be consld red In lieu of the experience requirement. 12.1.3 The Certified el Handler Supervisor (Level 3) shall have the responsibility of handling fuel d in all matters pertaining to fuel handling operations and to these Technlc I Specifications, the Certified Fuel Handler Supervisor shall be responsible to the President, Aerotest Operations, Inc. 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. Successfully c mpleted college-level work in the nuclear and radiation related fields of study ay be considered in lieu of the experience requirement. Maintain heal h/medlcal requirements required for the CFH Job. The biennial CFH Health Q estlonnalre will be used to assess health/medica l requirements. " 12.1.4 The Radiation afety Officer (Level 3) shall review and approve all procedures involving radl logical safety. He/she shall enforce rules, regulations and procedures re ating to radiological safety, conduct routine radiation surveys and is responsible o the President, Aerotest Operations, Inc. The Radiation Safety Officer shall h ve a minimum of 2 years of experience in personnel and environmenta /occupational radiation monitoring programs. Successfully completed col ege level work In the nuclear and radiation related fields of study may be consi red In lieu of the experience requirement. 

            .u.u:    The Certifi Fuel Handler Oevel 4) is a non-licensed operator who has qualified in cordance with the Certified Fuel Handler Training and
                    ""Re,::e=~I"""i==o~P....,ro==*Fuel handling obligations include maintenance, periodic fuel            ections and/or putting the spent fuel in transportation

caskets for fu 1 shipment from facility. The CFH only handle fuel when need and only handle 1 fuel element at a time. The CFH does not make decisions on el handing, decommissioning or radiation; those are made by the Reacto Administrator or Radiation Safety Officer (RSO). the CFH shall have at 1 2 years of experience in irradiated fuel movements and owledge of the relevant NRC regulations and ALARA sfully completed college-level work in the nuclear and radiation rela fields of study may be considered in lieu of the experience r uirement. Maintain health/medical requirements required for the CFH j b. The biennial CFH Health Questionnaire will be used to assess health/ edical requirements. 12.1.6 The Reactor S eguards Committee shall be composed of not less than frve members, of horn no more than three are members of Aerotest Operations, Inc. The comm - ee shall meet on call of the chairman and they shall meet at least annually. e committee shall be responsible for, but not limited to the following: 12.1.6.1 Reviewing and approving nuclear safety standards associated with the use of the facility; 12.1.6.2 Reviewing facilities procedures and modifications; 12.1.6.3 Determining whether proposed changes to the facility or proce ures are allowed without prior authorization by the NRC, as detail d in 10 CFR 50.59,; 12.1.6.4 Conducting periodic audits of procedures, maintenance, equipment performance, and records; 12.1.6.5 Reviewing all reported violations of these Technical Specifications, evaluating the causes of such events and the corrective action taken and recommending measures to prevent reoccurrence and; 12.1.6.6 Reporting their findings and recommendations concerning the above to the President, Aerotest Operations, Inc.

12.1.5 The ea rrn pers e v1ron n mo edu h ucle n rela in lieu o t e ex 12.2 Procedures 12.2.1 Detailed written rocedures shall be provided and followe d for the following operations: 12.2.1.1 uel Handling operations; 12.2.1 .~ ctions to be taken to correc t specific and foreseen potential alfunctions of systems or compo nents, including responses to 

                                                                      !arms resulting from suspected primar y system leaks; 12.2.1 ~
                                                       '-\            reventative or corrective mainte nance operations which could ave an effect on the safety of the facility.
                  --- --t p 12.2.2 Temporary proc du res which do not change the intent of previously approved procedures may e utilized on approval by a qlfali fiedin d~I.

Such -. 

      /                                   procedures shall be subsequently reviewed by the Reactor Safegu ards I

I Committee. I I I 12.3 Records I ~IL~ d-5 5 ~ \ ~.e._. \'('\~ ~~ ~\.AQ cl QS B~Q.\), ~_Q_J \I -..AllJ.aJ.UJ.s;UJ.U.;i;;J..1.,WJ..:i.Li~J.UJa1p-1,1-A,1;J.eilhe facility license and applicable regulations. 

                                                                            ~'\
 \

12 .. 1.4

TABLE 1 SAFE SYSTEM FUNCTIONS SENSOR OR TRIP DEVICE NO. OF SWITCHES OR SENSORS ANNUNCIATOR AND ALARM SET POINT High Temperature of 1 s 130° F Coolant Water Low Pool Water Level 1 5 1 ft max decrease Seismic Disturbance 1 IV on Modified Mercalli Scale Bridge Crane Location 1 When located off storage position Area Radiation Monitor 1 s 10 mr/hr Water Radioactivity 1 s 20 mr/hr Demineralizer Water Flow 1 ~4gpm 8::"' lj;;g Gas Effluent Monitor 1 s 2 mr/hr

Level 1 President Level2 

                                                                       ..., l~rrl~ r.nmm

[l,-,,.,,,..tnr ~~fArn Reactor Administrator Level3 Level3 Radiation Safety Certified Fuel Handler Supervisor Level4 Certified Fuel Handler Figure 1 -ARRR Organization chart

Enclosure 3 AEROTEST OPERATIONS, INC. DOCKET NO. 50-228 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (ARRR) AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 6 License No. R-98

1. The Nuclear Regulatory Commission (NRC 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 requirements 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; 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 haz.ards consideration; G. The receipt, possession, and use of byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's 1 Amendment No 6

Enclosure 3 regulations in 10 CFRParts 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 lo<?S,ted 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 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 possess up to 5.0 kilograms of contained uranium 235, and limit actions involving special nuclear material to those related to decommissioning. (3) Pursuant to the Act and IO CFR Part 3 0, Licensing of Byproduct Material," (I) to possess, and 2 curie americium-beryllium neutron startup source, and (2) to possess, but not to separate, such byproduct material andlimit actions involving byproduct material to those related to decommissioning C. This license shall be deemed to contain and is subject to the conditions specified in the following Com.mission 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 The licensee is not authorized to operate the facility at any power. 2 Amendment No 6

Enclosure 3 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 6, are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical Specifications (3) Physical Security Plan The licensee shall maintain in effect and fully implement all provisions of the NRC-approved physical security plan, including amendments and changes made pursuantto 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 73.21, entitled, "Aerotest Operations, Inc. Security Plan," dated October 1, 2020 (4) Certified Fuel Handler Training and Requalification Program Whenever the licensee processes TRIGA fuel elements pursuant to License Condition 2.B.(2), the licensee shall maintain in effect and full implement all provisions of the NRC-approved Certified Fuel handler training and requalification Program, including changes made to the program without NRC approval as permitted by the program. The approved program consists of the document entitled' "ARRRCFH Training/Requalification Program," dated 2021. Certified Fuel Handlers qualified in accordance with the program may approve licensee actions permitted by 10 CFR 50.54 (x). 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. E. Records In addition to those otherwise required under this license and applicable regulations, the licensee shall keep the following: 3 Amendment No 6

Enclosure 3 (1) Reactor operating records, including power levels (2) Records showing radioactivity released or discharged -into the .air or water beyond the effective control of the licensee as measured at the point of such release or discharge. (3) Records of emergency reactor scrams, including reasons for emergency shutdowns. F. This amended license is effective as of the date of issuance and shall follow requirements outlined in 10 CFR 50.51 (b). 4 Amendment No 6

Enclosure 3 APPENDIX A LICENSE NO. R-98 TECHNICAL SPECIFICATIONS FOR THE AEROTEST RADIOGRAPHY AND RESEARCH REACTOR (ARRR) 1.0 Definitions 1.1 Permanent Shutdown The reactor is permanently shut down when the reactor is maintained in permanent shut down configuration. 1.2 Permanent Shutdown Configuration Core lattice containing no fuel or reflector elements and control rods disabled fully inserted. 1.3 Operable 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 Experiment Experiment shall mean any apparatus, device, or material installed in the core or experimental facilities (except for underwater lights, fuel storage racks and the like) which is not a normal part of these facilities. 1.6 Experimental Facilities Experimental facilities shall mean Glory Hole, vertical tubes, pneumatic transfer systems, central thimble, beam tubes, thermal column, and in-pool irradiation facilities. 1.7 Reactor Safety Circuits Reactor safety circuits shall mean those circuits, including their associated input circuits, which are designed to initiate a reactor scram.

Enclosure 3 1.8 Core Lattice The array of machined positions for fuel or reflector elements In the grid plates. 1.9 Core Structure The upper and lower grid plates connected by structural members. 2.0 Reactor Site 2.1 The reactor and associated equipment is located within an exclusion area. 2.2 A steel, locked perimeter fence shall surround the ARRR facility, forming an exclusion area. The minimum distance from the center of the reactor pool to the boundary of the exclusion area fencing shall be 50 feet. The restricted area, as defined In 10 CFR 20, shall consist of the entire exclusion area. 2.3 The principal activity carried on within the exclusion area shall be associated with fuel storage and decommissioning of the ARRR; however, It does not exclude other activities from being perfonned using unimpacted facility areas i.e., machine shop, electrical shop, chemistry laboratory, etc. 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 shall have the capability to be shut off from a single control in the control room, 3.1.2 Ventilation shall be achieved by gravity ventilators located on the roof of the building, and 3.1.3 A positive air pressure shall be maintained in the control room with respect to the reactor room. 4.0 Reactor Pool (Primary System) 4.1 The minimum depth of water above the top of the core structure shall be 16 ft. The maximum bulk water temperature shall be 130°F and the minimum 40°F.

Enclosure 3 4.2 The conductivity of the primary coolant shall be measured at least once quarterly. Corrective action shall be taken to avoid exceeding a conductivity of 5 µmho/cm. 5.0 Reactor Core 5.1 Fuel Elements No fuel elements shall be allowed in the core lattice. 5.2 Reflector Elements No reflector elements shall be allowed in core lattice. 5.3 Control Elements Control elements shall be disabled and fully inserted in core lattice. 6.0 Reactor Safety Systems Safety System instruments listed in Table 1 shall be operable as long as fuel is present at the facility. A thirty day out of service period shall be allowed to facilitate repairs, replacements, maintenance, and/or calibration to any of the instruments listed in Table 1. 7.0 Radiation Monitoring 7.1 A fixed gamma monitor employing Geiger tube detectors shall be located on the wall connecting the control room and the reactor room. This monitor shall serve as betfl an area radiation monitor and will annunciate through an automatic monitoring system to the San Ramon, California, Fire Department and actuate a siren within the reactor bullding on high radiation level. The monitor shall have a minimum range of Oto 20 mr/hr. The annunciation and the siren actuation shall be tested monthly. 7.2 During fuel movement in reactor pool, a gas sample shall be continuously withdrawn from above the reactor in the vicinity of the reactor bridge. The gas-effluent shall be monitored by a beta-gamma detector which shall have a continuous readout In the control room. An annunciator shall indicate when the gas exceeds 2 mr/hr. 7.3 A fission product water monitor shall be attached to the process water cleanup system loop adjacent to the deminerallzer and shall provide continuous indication in the control room. High radiation levels within the demineralizer or pool water shall annunciate an audible alarm in the control room. The range of the monitor shall be from 0.1 to 100 mr/hr. 7.4 Portable survey Instruments for measuring beta-gamma dose rates In the range of 0.01 mr/hr to 50 r/hr shall be available at the facility.

Enclosure 3 7.5 Portable Instruments for measuring fast and thermal neutron dose rates from 0.1 mrem/hr to 1.0 rem/hr shall be available at the facility. 7.6 Radiation dosimeters shall be placed at several locations within the reactor building for area radiation analysis. 7.7 Process instrumentation with readout In the control room shall be operating to permit continuous indication of pool water temperature and conductivity. Alarms shall be operable to indicate low water flow, low pool water and improper location of the crane bridge. Table 1 contains alarm setpoints for sensors. 8.0 Experimental Facilities 8.1 Large-Component Irradiation Box Not in pool and shall not be authorized for use. 8.2 Pneumatic Transfer Facility Not in core lattice and shall not be authorized for use. 8.3 Glory Hole Facility Not in pool and shall not be authorized for use. 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. 8.4.3 The beam catcher shield shall consist of a movable radiation shield. 8.5 Thermal Column Shall be authorized for reflector element storage only. 8.5.1 The thennal column shall be positioned remotely on steel locating pins immediately adjacent to the reactor structure.

Enclosure 3 8.5.2 The thermal column shall be composed of a three-foot cube of graphite encased in aluminum containing five rows of 1.5 in. diameter Irradiation holes. The rows shall be placed 6 inches apart and contain seven holes per row. 8.6 Vertical Tube Shall not be authorized for use. 8.7 Other Irradiation Facilities Shall not be authorized for use. 9.0 Experiment Limitation No experiments shall be authorized. 10.0 General Operating Limitations No reactor operation shall be authorized. 11.0 Fuel Transfer and Storage 11.1 The fuel storage pits located In the floor of the reactor room shall accommodate a maximum of 19 fuel elements (700 gm U-235) in storage racks dry or flooded with water. The fuel storage pits shall be secured with a lock and chain when fuel Is present except during fuel transfer operations. 11.2 Additional fuel storage racks may be located in the reactor tank. Each of these storage facllltles shall be so designed that for all conditions of moderation keff shall not exceed a value of 0.8. 11.3 A fuel handling tool shall be used In transferring fuel elements of low radioactivity between the storage pits and the reactor; a shielded transfer cask shall be used for the transfer of highly radioactive fuel elements. The fuel handling tool shall remain in a locked cabinet under the cognizance of the Certified Fuel Handling Supervisor when not authorized for use. 11.4 The transfer of Irradiated fuel in the reactor tank, storage pits and facility 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 a hand held Gamma/Beta radiation monitoring instrument. The Radiation Safety Officer or deslgnee shall be present for irradiated fuel transfers outside of the reactor tank. 11.5 No more than one fuel element shall be allowed in the facility which Is not in storage. The only movement of the fuel elements are for fuel element inspections, canister surveillances, rearrangement of fuel elements in storage, or final placement In the transportation cask.

Enclosure 3 12.0 Administrative Requirements 12.1 Organization (Figure 1) 12.1.1 Aerotest Operations President {Level 1) shall have the responsibilities for all activities associated with obligations and processes associated with operating Aerotest Operations which Includes complying with license and Technical specifications, faclllty physical security and safety programs. The President of Aerotest Operations, Inc. shall report to the Board of Directors of Aerotest Operations, Inc. 12.1.2 The Reactor Administrator (Level 2) shall have the responsibilities of ensuring security and safety of the Aerotest facility. He/she shall enforce, review and amend procedures associated with security and safety programs. The reactor administrator shall be responsible to the President, Aerotest Operations, Inc. The Reactor Adminastrator shall have a minimum of 5 years of experience in reactor operations, 2 years of experience with personnel and environmental/occupational radiation monitoring programs, and 2 years of experience with complying with government regulations. Successfully completed college level work in the nuclear and radiation related fields of study may be considered In lieu of the experience requirement. 12.1.3 The Certified Fuel Handler Supervisor {Level 3) shall have the responsibility of handling fuel and In all matters pertaining to fuel handling operations and to these Technical Specifications, the Certified Fuel Handler Supervisor shall be responsible to the President, Aerotest Operations, Inc. 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. _Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements." 12.1.4 The Radiation Safety Officer {Level 3) shall review and approve all procedures involving radiological safety. He/she shall enforce rules, regulations and procedures relating to radiological safety, conduct routine radiation surveys and is responsible to the President, Aerotest Operations, Inc. The Radiation Safety Officer shall have a minimum of 2 years of experience in personnel and environmental/occupational radiation monitoring programs. Successfully completed college level work in the nuclear and radiation related fields of study may be considered In lleu of the experience requirement. 12.1.5 The Certified Fuel Handler Oevel 4) is a non-licensed operator who has qualified in accordance with the Certified Fuel Handler Training and Requalification Program.Fuel handling obligations include maintenance,

Enclosure 3 periodic fuel inspections and/or putting the spent fuel in transportation caskets for fuel shipment from facility. The CFH only handle fuel when need and only handle 1 fuel element at a time. The CFH does not make decisions on fuel handing, decommissioning or radiation; those are made by the Reactor Administrator or Radiation Safety Officer (RSO). the CFH shall have at least 2 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles. Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements. 12.1.6 The Reactor Safeguards Committee shall be composed of not less than five members, of whom no more than three are members of Aerotest Operations, Inc. 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: 12.1.6.1 Reviewing and approving nuclear safety standards associated with the use of the facility; 12.1.6.2 Reviewing facilities procedures and modifications; 12.1.6.3 Determining whether proposed changes to the facility or procedures are allowed without prior authorization by the NRC, as detailed in 10 CFR 50.59,; 12.1.6.4 Conducting periodic audits of procedures, maintenance, equipment performance, and records; 12.1.6.5 Reviewing all reported violations of these Technical Specifications, evaluating the causes of such events and the corrective action taken and recommending measures to prevent reoccurrence and; 12.1.6.6 Reporting their findings and recommendations concerning the above to the President, Aerotest Operations, Inc. 12.2 Procedures 12.2.1 Detailed written procedures shall be provided and followed for the following operations: 12.2.1.1 Fuel Handling operations; 12.2.1.2 Systems and components involving nuclear safety systems of the facility.

Enclosure 3 12.2.1.3 Actions to be taken to correct specific and foreseen potential malfunctions of systems or components, Including responses to alarms and suspected primary system leaks; 12.2.1.4 Preventative or corrective maintenance operations which could have an effect on the safety of the facility. 12.2.2 Temporary procedures which do not change the intent of previously approved procedures may be utilized on approval by the Reactor Administrator. Such procedures shall be subsequently reviewed by the Reactor Safeguards Committee. 12.3 Records Records shall be maintained as required by the facility license and applicable regulations.

Enclosure 3 TABLE 1 SAFETY SYSTEM FUNCTIONS SENSOR OR TRIP DEVICE NO. OF SWITCHES OR SENSORS ANNUNCIATOR AND ALARM SET POINT High Temperature of 1 ~ 130° F Coolant Water Low Pool Water Level 1 ~ 1 ft max decrease Seismic Disturbance 1 IV on Modified Mercalli Scale Bridge Crane Location 1 When located off storage position Area Radiation Monitor 1 s 10 mr/hr Water Radioactivity 1 s 20 mr/hr Demlnerallzer Water Flow 1 ~4gpm Gas Effluent Monitor 1 s 2 mr/hr

Level 1 President Level2 Reactor Safeguards Comm. Reactor Administrator Level3 Level3 Radiation Safety Certified Fuel Handler Supervisor Level4 Certified Fuel Handler Figure 1 - ARRA Organization chart}}

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