ML21181A123

License and TS Amendments

ML21181A123
Person / Time
Site:	Aerotest
Issue date:	06/22/2021
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21181A123 (40)

Text

AEROTEST OPERATIONS, INC.

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

• FAX (925) 866-1716 June 22, 2021 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 e-mail communication on June 3, 2021 from Geoffrey Wertz requesting additional information.

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) 631 5919 or dmsraven@gmail.com.

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

Sincerely yours, ~

D~~

President, Reactor Administrator, Manager Aerotest Operations, Inc.

Enclosures:

1. List of Explanations, Changes, and Justifications

2. Mark-up of License and TS

/J!JZ !J

3. Clean copy of proposed License and TS

vXrf.

Enclosure 1 RAI Response L.C. and Tech Specs: 6/22/21 RAis - License Conditions

1. Revised LC.2B(2) to:

"Pursuant to the Act and 10 CPR Part 70, 11 Special Nuclear Material, 11 to possess up to 5.0 kilograms of contained uranium 235. Actions involving special nuclear material are limited to those related to fuel storage and decommissioning" We feel that the brevity of the language for the license condition is clear that we are in possession of special nuclear material and are limited in its use to fuel storage and decommissioning. The use of the other suggested language provides no additional value but may add confusion to the intent of the license condition. As for the other SNM materials and sources present at Aerotest, they are included on the inventory of the State of California Radiation License (No. 2010-07). These sources include instrument calibration and check sources, Cs, PuBe, etc. and are not inventoried under the NRC part 50 license.

The wording was chosen from 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. Revised LC2.B.(3) to:

"Pursuant to the Act and 10 CFR Part 30, "Licensing of Byproduct Material,"

(1) to possess 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 removed", and" after to process. We disagree with NRC staff proposed LC2.B. (3) wording. We feel that this is clear that we are in possession of byproduct material and are limited in its use to fuel storage and decommissioning. We do not need to include the other suggested language. The use of the other suggested language provides no additional value but may add confusion to the intent of the license condition.

Enclosure 1 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 notifies 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"

5. Revised LC 2.F by adding the infonnation in 10 CFR 50.5l(b)

"This amended license is effective as of the date of issuance and shall follow requirements outlined in 10 CFR 50.51 (b). Each license for a facility that has permanently ceased operations, continues, until the Commission notifies the licensee in writing that the license is te1minated."

RAis -Technical Specifications

6. Revised TS 2.2 to provide better clarity it reads:

"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 part of the exclusion area. The exclusion area that is part of the non-restricted area is the prior machine shop, the prior electrical shop, the prior chemistry laboratory, the prior tagging room, the prior set-up room, the prior garage and out buildings, the prior magazine vault, the prior office area, the prior control room and the prior break/meeting room."

Revised TS 2.3 to provide better clarity to read:

"Within the restriction area activities are limited to fuel storage, fuel handling and decommissioning activities as approved in the decommissioning plan of the ARRR. The non-restricted area can be used for non-NRC regulated activities."

6.3 Added word "prior" to the descriptions on the areas included in the non-restricted area.

6.4 Removed word "principle" 6.5 The non-restricted area of the exclusion area contains no radioactive contamination and the radiation level is at background levels. These areas of the building maybe used for activities not regulated by the NRC. The site characterization study performed by Energy Solutions (conducted in 2011) is the basis for the establishment of the non-restricted areas.

Enclosure 1

10. TS 6.0 reads "Storage Safety Systems Safety systems instruments that are related to the safe and secure storage of the irradiated fuel shall be operable when relevant if the irradiated fuel is present in the facility. Those safety system instruments are noted by an asterisk(*) in Table

1. A service period not to exceed thirty days shall be allowed to facilitate any required repairs, replacements, maintenance, and/or calibration to any of the instruments listed in Table l ."

10.4. TS 7.1 see RAI 30 10.4.1.1 We have removed the term "criticality alarm" from TS 7 .1. Per TS 7 .1 "This monitor shall serve as an area radiation monitor" and is listed on Table 1 as "area radiation monitor" Per the TS the range on the monitor is "Oto 20 mr/hr". The alarm set point on Table 1 is less than or equal to 10 mr/hr which is within the TS monitor range.

The use of the term "criticality alarm" suggests that the alarm associated with a criticality accident is different than the alarm for reaching a threshold radiation rate in the area. The alarm is set off by reaching a measured threshold radiation rate. (One possible cause for alarm may be from a criticality accident.) The choice of broader title allows for the responder to consider more likely causes given the fuel storage restrictions and circumstances. The instrument and function are the same.

10.4.1.2 See explanation for 10.4.1.1 10.4.2 TS7.2 See RAI 31 10.4.2.1 "Gas effluent Monitor" it is located in Table 1.

10.4.2.2 The "Gas Effluent Monitor" is operational at all times. See changed TS 7 .2 in RAI31 10.4.3 Changed TS 7.3 to show the monitor on Table 1 and it currently reads:

"A water radioactivity monitor shall be attached to the process water cleanup system loop adjacent to the demineralizer 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."

Enclosure 1 I 0.4.4 Made changes to the following TSs to bring the wording consistent with Table 1 entries.

TS 7.4 "Portable survey instruments (gamma, beta) for measuring beta-gamma dose rates in the range of 0.01 mr/hr to 50 r/hr shall be available at the facility."

TS 7.5 "Portable survey instrument (neutron) for measuring fast and thermal neutron dose rates from 0.1 mrem/hr to 1.0 rem/hr shall be available at the facility."

Changed "instruments" to "instrument as we only have one.

TS 7.7 "Instrumentat ion with readout in the control room shall be operating to permit continuous indication of pool water temperature and pool water conductivity.

Alarms shall be operable to indicate low water flow, low pool water and bridge crane location. Table I contains alarm setpoints for sensors."

10.5 Changed TS 6.0 wording from "Safety System Instruments listed in Table I shall be operable as long as fuel is present at the facility" to "Safety systems instruments that are related to the safe and secure storage of the irradiated fuel shall be operable when relevant if the irradiated fuel is present in the facility. Those safety system instruments are noted by an asterisk(*) in Table l."

Once there is no fuel in the pool (storage racks) or ARRR core structure, the water in the pool is no longer needed as a shield to radiation exposure. The pool will be drained in compliance with the decommissioning plan. Once the radiation sources are eliminated from the pool, there are no need to continue to the use of certain safety systems.

I 0.6 Changed TS 6.0 wording from "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 I." To "A service period not to exceed thirty days shall be allowed to facilitate any required repairs, replacements, maintenance, and/or calibration to any of the instruments listed in Table I."

We feel up to 30 days is a reasonable time frame to access mode of failure, order and install replacement parts, and to calibrate any instrument after maintenance. Under the circumstance of fuel storage, the systems monitored are extremely stable and have not shown dynamic changes. The stability of the circumstance merits a 30-day allowance for repair and calibration.

Enclosure 1

11. Revised TS 8.5 to reflect the NRC proposed corrections:

"Thermal Column Shall be authorized for reactor 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.

"Core Structure" is defined in TS 1.9 "Core Structure The upper and lower grid plates connected by structural members."

14. Revised TS 11.5 to reflect NRC proposed corrections it now reads:

"No more than one fuel element that is not in storage shall be allowed in the facility. The only movement of the fuel elements shall be for fuel element inspections, canister surveillances, rearrangement of fuel elements in storage, or final placement in the transportation cask."

Changed first sentence by changing "which is not in storage" to "that is not in storage" and moving that phrase to after "fuel element" in the first sentence. Changed "are" in 2nd sentence to "shall be" per NRC's request to clarify language in TS.

15. TS 12.1.3 and TS 12.1.5 were changed to reflect the changes to ARRR CFH Training/Requalification Program submitted to the NRC on 3/31/21. We have not received any additional RA.Is or heard the ARRR CFH Training/Requalification Program was approved. The duties, experience and qualifications on the Certified Fuel Handler (CFH)

Supervisor and Certified Fuel Handler (CFH) have been reviewed in detail by the NRC in the ARRR CFH Training/Requalification Program. We want to make things consistent between the two documents.

Enclosure 1 15.1 Changed 12.1.3 CFH Supervisor to:

The Certified Fuel Handler Supervisor (Level 3) is a non-licensed operator who has qualified in accordance with the ARRR CFH Training/Requalification Program and 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 Reactor Administrator, 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."

15.1.3 Organizational chart has been revised. The Radiation Safety Officer, the Reactor Administrator and the Reactor Sa,feguards Committee reports to President. . The solid lines on the organization chart show the reporting structure while the dashed lines indicate the communication lines. The organization chart is compliant with the ANSI/ANS 15 .1 standard.

15.2 CFH or CFH Supervisor is not required on a daily basis. They are only required when fuel handling activities are needed. Added TS 11.6 "CFH or CFH Supervisor does not need to be at the facility on a daily basis.

They are only required when there is a transfer/movement of fuel."

15.3 A CFH or CFH supervisor may hold another role or position at Aerotest. However, when they are performing as a CFH or CFH supervisor they are only performing CFH handling duties. If they perform duties outside of those associated with Certified Fuel Handling then they are performing those duties under a different role for the company.

ARRR Emergency Plan dated March 26, 2020 Adams ML20098D412 inadvertently put CFH Supervisor as Emergency Coordinator alternative. We will be revising that emergency plan as organization chart has changed since March 26, 2020 and removing the CFH Supervisor from being an Emergency Coordinator. We have not employed either a CFH or CFH Supervisor yet as we are waiting on the approval of the ARRR CFH Training/Requalification Program submitted to the NRC on 3/31/21. Thus, the CFH Supervisor has not or never will be an Emergency Coordinator, 15.4 A CFH or CFH supervisor is not need after the fuel is removed from the ARRR Facility.

When there is no fuel left at the ARRR Facility, there will be no fuel for them to handle.

15.5 None 15.6 Closed-quotation mark(") removed

Enclosure 1 15.7 None 15.8 TS 12.1.5 CFH Handler. The information in this section is a combination of the Experience/Qualifications and duties from ARRR CFH Training/Requalification Program submitted to the NRC on 3/31/21. We have not received any additional RAis or heard the ARRR CFH Training/Requalification Program was approved. The duties, experience and qualifications on the Certified Fuel Handler (CFH) Supervisor and Certified Fuel Handler (CFH) have been reviewed in detail by the NRC in the ARRR CFH Training/Requalification Program. We want to make things consistent between the two documents.

Yes, the position as described for a fuel handler tasks is very narrow. The training described in the training and requalification program also ensures that they ae familiar with a board range of associated topics. Their responsibilities are matched with their training and job expectations.

Note to perform a CFH task, the CFH follows a written task plan and procedures TS 11.4 requires a radiation safety analyst or Radiation safety officer to be present; they are present to ensure the staff compliance with safety radiation protocols and limits.

Radiation concerns are left to the judgement of the Radiation Safety Officer. If there are any engineering failures i.e., fuel handling tool breaks in process of transferring fuel, the work is stopped by procedure for a required 10 CFR 50.59 evaluation before a solution can be implemented. If the transfer is done outside the pool the RSO is present thus the RSO is responsible for good judgement.

It is anticipated that the Certified Fuel handlers also hold other facility positions of authority that demand a certain expertise to empower their actions. For example, it is anticipated that that the reactor administrator and the certified fuel handler supervisor will be held by the same person.

If an emergency arises the authority of action goes to the highest-ranking emergency personnel on site in descending order: President, Reactor Administrator, and RSO.

(However, the RSO is not to be CFH fuel handler of any rank.)

_J

Enclosure 1 TS 12.1.5 now reads:

"The Certified Fuel Handler (level 4) is a non-licensed operator who has qualified in accordance with ARRR CFH Training/Requalification Program. Fuel handling obligations include maintenance, periodic fuel inspections and/or putting the spent fuel in transportation casks for fuel shipment from facility. The CFH only handles fuel when need and only handles 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."

16. Revised to TS 12.1.6.2 and now reads:

"Reviewing ARRR facility's procedures and modifications;"

18. 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;"

The guidance ANSI/ANS-15.1 specified by the NRC staff is for operating reactors; this is clear by the wording "operating abnormities having safety significance". For the more complex dynamics of an operating reactor, this is reasonable. The abnormal occurrence is usually a prelude to a failing system. However, it is not clear operating abnormalities is relevant given the much simpler fuel storage circumstances. Initially, the verbiage "abnormal occurrences" was included in a previously license /TS changes by the licensee; the NRC staff asked for the definition of "abnormal occurrences"; having none for the storage circumstance, it was admitted. The omission of "abnormal occurrences" remains appropriate.

22. Revised Former TS 12.2.1.1 which is now TS 12.2.1.2 to wording suggested by the NRC.

TS 12.2.1.2 now reads:

"Normal operating of all systems and components involving nuclear safety of the ARRR facility"

Enclosure 1

30. TS 7.1 reads; "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 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 building 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."

TS 7.1 meets the requirements of 10 CFR 70.24. "a monitoring system meeting the requirements of either paragraph (a)(l) or (a)(2), as appropriate, and using gamma- or neutron-sensitive radiation detectors which will energize clearly audible alarm signals if accidental criticality occurs." 10 CRF 70.24 (a)(2) "The monitoring devices in the system shall have a preset alarm point of not less than 5 millirems per hour (in order to avoid false alarms) nor more than 20 millirems per hour".

No changes to the TS required as we meet the requirements outlined below:

10 CFR 70.24 requirement "monitoring system". TS "automatic monitoring system 10 CFR 70.24 requirement "using gamma- or neutron-sensitive radiation detectors" TS "fixed gamma monitor" 10 CFR 70.24 requirement "energize clearly audible alarm signals if accidental criticality occurs" TS "actuate a siren within the reactor building on high radiation level."

10 CRF 70.24(a)(2) "5 millirems per hour (in order to avoid false alarms) nor more than 20 millirems per hour" TS "The monitor shall have a minimum range of 0 to 20 mr/hr"

31. Revised TS 7 .2 reads:

"A gas sample shall be continuously withdrawn from above the reactor and below the pool cover 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" 31.1 Changed TS to better clarify the gas-effluent monitor is continuously monitoring the gas above the reactor. Other changes to the language were required to better describe the circumstances caused by our security improvements. The gas sample is collected under the pool cover above the pool water 31.2 Changed TS to better clarify that the gas-effluent monitor is monitoring the gas above the pool 24/7 and not just when we are doing fuel movement and/or maintenance.

Enclosure 1

32. TS 7.6 reads:

"Radiation dosimeters (gamma, neutron) shall be placed at several locations within the reactor building for area radiation analysis."

The two detector packages were designed for high neutron flux measurements. Those detectors are not be appropriate for an accurate radiation measurement for the accident reconstruction from a radiation accident involving an operating 250 KW TRI GA reactor let alone fuel storage with or without existing shielding. The detector packages were replaced by numinous gamma and neutron monitors (dosimeters). These dosimeters have the appropriate sensitivity to measure radiation incident to assist in the reconstruction of the post-accident radiation exposure.

The changes to the radiation monitor were made with 10 CPR 50.59 and meet the regulations in 10 CRF 20.1501(a) "Each licensee shall make or cause to be made, surveys of areas, including the subsurface, that (1) May be necessary for the licensee to comply with the regulations in this part; and (2) Are reasonable under the circumstances to evaluate (i) The magnitude and extent of radiation levels; and (ii) Concentrations or quantities of residual radioactivity; and (iii) The potential radiological hazards of the radiation levels and residual radioactivity detected."

Enclosures 1 and 2 have been changed to reflect "dosimeters".

33. Typo correct in TS 12.1.6.3 removed","

34. Changes to TS 11.4. We confirm the change was intended.

35. We capitalized "Specifications" in Tech Spec 12.1.1 for consistency.

36. We changed all "college level" to be "college-level" to be consistent with the ARRR CFH Training/Requalification Program

AEROTESJ" Ql~El(;\Tl< >NS~ INC, AtvtENDMENT TO FACII.ITY OPER0TINCi 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 l 0, 2013; and April 21, June 16, August 22, and October l 0, 20 I 6, 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 I 0, Chapter I, --Nuclear Regulatory Commission;* of the Code <d' Ft!deral Regulations ( l OCFR 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; 1 Amendment No 6

F. The issuance of this operating li-:i:nsi: \\ill not be inimil.:al to the et1111nwn dd"cnse and si:curity lH. tu thi: health and salet) ol'the public. and dot.::- not i11\ul,e a signilkant luuard:,; consideration:

G. The receipt, possession, and use of byproduct and special nudear material as authorized b\' this license\\ ill be in accordance \\ith the Commission *s regulations i;1 IO CFR Pa11s 30 and 70. induding Sectiuns 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 pn)\ isions uf law, regulations, and orders issued by the Commission pursuant thereto.

2. Facility Operating License No. R-98, issued to Aerotest Operations. Inc., is hereb) 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 elated 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 IO CFR Pat1 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 IO CFR Pait 70, "Special Nuclear Material," to ~JLc...\u.J. J~tx...,\Q..ttr possess up to 5.0 kilograms of c~mtained urnniL\~ 1 \V\-o.....-\-3/4\. o. J Qr-Q.....

• opcmtio!t-~k@ l'@th!W.t, tt11a. * \ \ 1'..:_ , -\--Q..~%~ a~*oia a)c) \f\j ~ *.) 1',,\

§ 1t) 9 CjJ~J )') >lC I La:, :P O \£ f \O \ --\-Q ~ o ~-L Tc\ L \CA.\ \Le\ .,h '~o,_c:;a..

(3) . OJ"">~

Pursuant to the Act and IO CFR Pait 30, **Licensing of Bv11roduct

~ J Material." c.\,.,..__,~ 0""'""'\ ..,..,,c,r-,"

, . , . . , ... c. '

(I) to possessa 2 curie americium-beryllium neutron staitup source, and (2) to possess, but not to separate, such byproduct material a ~ -

1 r,reducecl by opetatron*ufthe ffactor. 0..{"\ _1 L\""' \ ,... c:... \ ......,..\ ,

' . C,l . . * * \ \ -r \.A I \ V1 ~ \ f\ \,) 0 \ () \ (\ j

~ <~Hoc\vd- rnc1...,-\-u,(J -h:> -fno~ e... ~.e_\c~*\.-ed ~ t:

1) . \-vu

\ ~ C.CN\N\ lS '.-.:i \.Orq ~ . .

2 Amendment No 6

C. Thi:- license shall be dec111ed t\1 contain and is ~uh_ject l\l the ..:pnditi\111: ~11~..:il}ed i~1 th-:

folk1\\ in!.! CL1m111i-;sin11 rcg.ulatiLlll:i in IO lTR Chapter I: Part 20. Sc..:11'.111 ,o._ 1 -I 11 1 I1art

10. Secti:ms 50.5-1 and 50.59 of Part 50. and Sei.:tilln 7lU2 lit' Part 70: 1s :-;ub_1c..:t tP all

~ipplicable pnivisions o!'the Act and to the n_iles. r~g:ulations. ant_! ~1rdi:r~ ut*t~1~

Commission m1\\ or hi:ri:alkr in effect: and is suh_1eet to the add1t1011al co11d1t101b specilied or incorporated belo\\

( 1) 1\-laximum PLmer l.e\el The licensee is not authori1ed to nperate the focilit) at an) ptmer.

(2) Teehnical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 6, are hereby incorporated in the license. The licensl.!e shall maintain the facility in accordance with the Technical Speciticatit1 ns.

(3) Phvsical Securitv Pla11 The licensee shall maintain in effect and fully implement all provisions of the NRC-approved physi~al se~urity plan, in_clu~in~ amendments and changes_made IO C..f, ~ ,

pursuant t_o the authority of 10 C_FR Section :i0.:i4_(p)._ The approved security /

plan consists of the document withheld from public disclosure pursuant tcn * ~

Cl!R :2 W°'d), entitled '"Aerotest Operations, Inc. Security ~lan-4ded*A:ggu~ 7 ~ 2-I rn,==t976,--submitted by f~dmed 0t*tooor4,, .l 9,76, as Fe! vrSed:;t..ntffl~.(,. '

~cd-~c:_,-\-t>bt,, \ \ 2-07-o D. Reports In addition to repo11s otherwise required under the license and applicable regulations:

(1) The licensee shall rep011 in writing to the Commission within l Odays of its observed occurrence any incident or condition relating to the operation or 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 rep011 to the Commission in writing within 30 days of its observed occu1Tence any substantial variance disclosed by operation of the facility from performance specifications contained in the I lazards Summary Repo11 or the Technical Specifo:ations.

(3) The licensee shall repo11 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.

"Certified Fuel Handler Training and Requalification Program Whenever the licensee processes TRIGA fuel elements pursuant to License Con~i~ion 2.B.(2), the licensee shall maintain in effect and full implement all prov1s1on~ of th~ NRC-approved Certified Fuel handler training and requalification Prog~am, mcludmg changes made to the program without NRC approval as pemutted by the program. The approved program consists of the document entitled' "ARRRCFH Training/Requalification Program," dated------ 2021. Certified Fuel Hand_lers qualified in accordance with the program may approve licensee actions penmtted by 10 CFR 50.54 (x)." __

t:,-0 c_\o '::lvf" L "d-E. Recl_)rds In additiun to tlw~c tHhern ise required under thi~ license and applicable n:~ulatilllh. Ilic licensee shall keep the ti.,(hl\\ ing:

( 1) Re,Jctm operating n.:cPrd~. including ()ll\\L'r lc\eb (2) Records shm,ing radiuacti\ it~ released or discharged -intn the .air or \\akr beyond the effective wntrnl ot"the lice1fsee as measured at the point ur such release or discharge.

(3) Records of emergency reactor scrams, including. reasons fi.ir emcrgem:~

shutdowns.

F. This amended license is effective as of the date of issuance and shall ~ lit midniglct ~-

~ 0 \ \ av0 , LG..~ \. ~~ro~-\- S ().J \ \_~ \f\ Q...c_.:\ ~ V'\ _,,,,<tc ~

~ 5 2:oo.L

. I

,o c~ C_hl_

L\ ~-L.. foiL Q -f'Qc..\ \ l~\

- ~ So .S \ ~ ~ e Q d"\

- """-~\- ~~~

~-tr l'<'O-f\(U\-\-\i c_~°'-~"--c\ C)~JL(""'O-"*h Of\S I

~.\\ V\u-o , v 'f\-\-, \ --\-V\ Q_ C:..ornM\~5~" f\ o\-, ~ ;~~

"°'-e_ L { ~ ,*(\ \..U~,-+,~ ~\- ..\-~a_ L,c..Rf\~Q_

~ ~ ~ ~~\ .e_~) l 4 Amendment No 6

[\PPENDIX__~

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 witl:l th@ fY@I elerl'wnts stored ifl stoFage I acks t11at fflaintain a critiealit9 of equal to or less tl1a1: 8.8 lL"r1.

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.

1.8 Core Lattice The array of machined positions for fuel or reflector elements in the grid platec;.

1.9 Core Structure The upper and lower grid plates connected by structural members.

'\~~~~

2.0 Reactor Site '-'21 i i; h Is:

-~...;_---

2.1 The reactorand ~~~ociated equipment is located within an exclusion area.

~ A -J.*r-V 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 fen i~g shall be 50 feet. The restricted area, as defined in 10 CFR 20, shall 0

consist of.t~~itjre exclusion area The exclusion area that is part of the non-restricted area is the prior machine shop, the prior electrical shop, the priorchemis try c ~,

~

--~ laboratory, the prior tagging room, the prior set-up room, the prior garage and out -r'\J 1-1 buildings, the prior magazine vault, the prior office area, the prior control room and the J§<i] &i<L.

_prio!~eak/m eeting roo~.* _.__,,.,;;-,c:o*-a- -\ ~...- -~s ,'\6*;\' ~\vd: :: o1/4 <2,,(

J .. *3 ~ ~Within the restriction area activitiesa,,e limited to fuel storage, fuel handling and

~ "Id'*

B decommissioning activities as approved in the decommissioning plan of the ARRR. The 3.0 Reac t or u, rng * * . . . ,,

non-restricted area can be used for non-NRC regulated act1v1t1es.

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 ON Ventilation shall be achieved by gravity ventilators located~ the roof of the building, and 3.1.3 A positive air pressure shall be maintained in the control room with respect to the reactor room.

3.2 A-1.elarFR syste1+1 ,t:iall be installed to de!ecr il atithgrii;eEI eRtry iAte the Feact~

builelins. The alerff! s1;stoR1 sl=t;ill be r:i:ioni!oced const;intli,i JnEI its aARUAciatior:i s:ball b.f..

tested rnootbl't,..

4.0 Reactor Pool (Primary System) 4.1 The minimum depth of water above the top of the core structure shall be 16 h. The maximum bulk water temperature shall be 130°F and the minimum 40°F.

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 ,LLmho/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 an,d fully inserted in core lattice.

S+or Q'.1.Q_

6.0 ~Safet y Systems Safety systems instruments that are related to the safe and secure storage of the irradiated fuel shall be operable when relevant if the irradiated fuel is present in the facility. Those l..fu.9.1 safety system instruments are noted by an asterisk (*) in Table 1. A service period not to exceed thirty days shall be allowed to facilitate any required repairs, replacements,

~-inte_n_a_nce, and/or calibration to any of the instruments listed i=n_.:.T:. .:a: . : b:.=.le-=----=.l.:. . ._ _ _ __

7.0 t\dUldLIUII IV.IUIIILUI Ill~

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 bQ.t.h.an area radiation monitorclfle l a eritkality alai::A:l and will annunciate through an automatic monitoring system to the San Ramon, California, Fire Departmen t and actuate a siren within the reactor building 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.

A Rwiag fl nl rnoHerneot jn reacJ;or ia!!'m'l, 'El.gas sample shall be continuousl y withdrawn fro1T1-the roeh@lilt-ab ove the react&:~r f10111 the vicinity of the reactor bridg1; 0021 th,Q..

• w1 est, ucture, anci p, ,roped tbcoug . The gas~

chein::ibe.i:: 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. ,

~ctcl OQ c_ 1t,I.) ~~

7.3 Afis&ion prnd*JCt wate?\moni tor shall be* attached to the process water cleanup system loop adjacent to the demineraliz er and shall provide continuous indication in the control room. High radiation levels within the demineraliz er 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.

-£,(\ c....\o 5 v r Q.. ":)._

(.9 o..~~, ~ 0-\ t\.J 7.4 Portable survey instrurnents~r measuring beta-gamma dose rates in the range of 0.01 mr/hr to 50 r/hr shall be available at the facility.

C t-J~v~~J 7.5

• Portable instrument..for measuring fast and thermal neutron dose rates from 0.1 mrem/hr to 1.0 rern/hr shall be available at the facility.

do"=>*, N\e....~ ..S ( S a.tnm~, r\~l)-+t-01\)

7.6 Radiation detector packets cootai91r:ig a series of threshold dete.c.tefS"shall be placed at several locations within the reactor building for t:JSSt accideR-1: radiation analysis.

Q(.Q..0....

7.7 Pibe~strumentation with readout in the control room shall be operating to permit continuous indication of pool water temperature andbtonductivity. Alarms shall be operable to indicate low water flow, low pool w~r and iW~~~~tefl'-et--ffit~:a-Fl"e-4 ielgc. 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 therm al column shall be positioned remotely on steel locating pins imme diatel y adjacent to the reac tor~ , ~1/4c ._.\..

.lr-L, 8.6 Vertical Tube /4 --

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 reacto r room shall accommodate a maximum of 19 fuel elements (700 gm U-235) in storag e racks dry or flooded with water. The fuel storage pits shall be secured with a lock and chain when fuel is present except durin g fuel trans fer operations.

11.2 Additional fuel storage racks may be located in the reactor tank. Each of these storage facilities shall be so designed that for all conditions of moderation kett shall not exceed a value of 0.8.

11.3 A fuel handling tool shall be used in transferring fuel elements of low radioactivity

~ s t o r a g e pits and the reactor; a shield ed transfer cask shall be used for the transfer of highly radioactive fuel elements. The fuel handling tool shall remain in a locked cabinet unde r the cognizance of the Fuel Handl ing Supervisor when not authorized for use. A ~ . \ , ~, Cl~ . .

"- S-\o-r 11.4 Transfer of irradiated fuel in the reactor tan~ shall be-a.r:)Q... '? '-\- O.r'\o\ *F-o..c_, \\j,4 conducted by a minim um of staff ..... \

of two: a Certified Fuel Handler (CFH) and ar! additional safety. The staff shall moni tor the operation using,:i;;i.ip person trained in rad iati on~ -. 1 prnprie-te radiation monit oring ; ~

\-\clJ Instr urne fifA ~ or designee shall be present for irradia the react or tankQbl!lt *eritbiA the fadli~I'- UAeler no eireu1 ted fuel transfers outside of 6-a_~N\o.../

ts<< stsreel il'l tl'le eere lattiee..

11stai.ees b fuel to be transferretl ~ ~--\--o,__

~ -t--1'\t\.,t 11.5 'Not_more than one fuel eleme nt 5hall be allowed in S'ro...\\

the facilitlfui*chicil is not in stora g~ a._\\ci~~~

'o.Q...,

The only movement of the fuel* S '°'~~\_

elements ~ ~ e ?Ll element mspecnons,

"'->, .* ~ . 1.,.

canister surveillances, rearrangement of fuel elements in storag ,,,~

placement in the transportation cask."

e, or final fi=a.u \~~

( .

- 8.5.2 The thermal column shall be composed of a three-rem: cuoe or grapmte 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

~-

-- -- ~ -- - ------ ---

!z.O "1-.ef R'liRistrative Rw311icemegts 12 .1 Q~gaAiz-a-ti0u

. * - 'e-S- . bt+itV-Gf-~--C.e_il Ct O r nd to thes.e

~~~~~~~~~!11...M..[Qle.sl..LlpLei::.::1-UG~-H=H;..+A--~'5.!U~~ rotest

\\.y,~~J

~~

12.1.2 The Radiologic I Safety Officer shall review and approve all rocedures and

\~Q_Y-t- experiments inv ving radiological safety. He shall enforc rules, regulations and procedures relatin to radiological safety, conduct rout' e radiation surveys and

'?Qse... is responsible to the resident, Aerotest Operations, I c.

12.1.3 The Reactor Safeguards ommittee shall be comp sed of not less *than five members, of whom no m e than three are me bers of Aerotest Operations,

d. ?0.1'.tS Inc. The committee shall me ton call of the c irman and they shall meet at

==-----

---

=: least annually. The c6mmittee hall be resp sible for, but not limited to the following:

12.1.3.1 Reviewing and a lear safety standards associated with the use of 12.1.3.2 es and significant modifications; 12.1.3.3 Determinin involve unr  ?-'-a.=.L..::i..:::.:::.::.:;~~ elefi-ned in70 t:FR*50.I

--'TJaTt-5

• these Technical

~

Specific o..r+~R. .:f,50

\." \

a er-~ so, 12.1.3.4 Con periodic audits of procedur equ performance, and reco~ds; 12.1.3.5 Rev* wing all reported abnO'l'l"fti:H..Qcc;.urren.ce.s a violations of t se Technical Specifications, evaluating the caus s of such vents and the corrective action taken and recomm ding measures to prevent reoccurrence and; Reporting their findings and recommendations concernin above to the President, Aerotest Operations, Inc.

12.1.4 The CFH,_Su

• r shall have at I, ast f experien *

• uel movem emonstrated kno e relevan and ALARA es. Classroom ed uclear and d fields o y y be consider xperienc

CFH -- - u c.:_,_ * .. - , l l.s_ . E0c.....\a .Svr-e.. <;}-

re . ordCFH Superv_isor does not need to be at the facility on a daily basis. They are only qmre when there is a transfer/movement of fuel.

12.0 Administrative Requirements 12.1 Organization (Figure 1) S\"'lv\SO~f\.5 (Q._\'.>C)~("\s 0-i'"\c\ C..O\'<'\IY\Uf\l '---Q,\l a(\ L,M. . S

• 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

..)pecifications, facility physical security and safety programs. The President of Aerotest Operations, Inc. shall report to the Board of Directors of Aerotest Operations, Inc.

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 colleg&Jevel work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

LS, 0.. "C>f\-Lt...-<U°'SQ.d '\:)~Jtf'c;t\ c,r.

'->.:>~ '0 o..~ Q.OQ.\ \ ~ 1...\ d , ~

12.1.3 The Certified Fuel Handler Supervisor (Level 3),thall have the responsibility of ~ ~c:s:,rc\ON!.-L handling fuel and in all matters pertaining to fuel handling operations and to

• these Technical Specifications, the Certified Fuel Handler Supervisor shall be \).:) ~~

\\~~ L--\ \)){L. responsible to the f'resideRt, Aerotest Operations, Inc. The CFH Supervisor shall f\. 9--.~

f\ ~ \'f\ 1 " , S-\-fo.__-\or have at least 5 years of experience in irradiated fuel movements and C~ \-\

demonstrated knowledge of the relevant NRC regulations and ALARA principles.

\ ' ( 0--\f'\\Y'\

Successfully completed college-level work in the nuclear and radiation related -..J fields of study may be considered in lieu of the experience requirement. R~vc.\

Maintain health/medical requirements required for the CFH job. The biennial \c_o....~o CFH Health Questionnaire will be used to assess health/medical requirements~ ~n>yo..m Or.J ,

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 lieu of the experience requirement .

.lbl2 The Certified Fuel Handler ~vel 4) is a non-licensed operator who has quahhed m accordance withtlie:(;;lj ,tiS cl fp 1II slier Trainin~

Requalification Program.Fuel handling obligations include maintenance, periodic fuel inspections and/or putting the spent fuel in transportation

caske-ts for fuel shipment from facility. The CFH only handli;Sfuel when need and only handl61 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)-:lii.e 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; A.\ZR~ 't C\.C..,' \ \-\~.!J 12.1.6.2 Reviewing ~aeilitie.s procedures and modifications; I'-

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. 1.s The Safety Of ve a mi pers env iron n ion mo ms.

edu the nuclea n rela cly r in lieu o the experience t.

12.2 Procedures

12. 2.1 Detailed wri tten proced ures shall be pro vid ed and foll ow ed for the foll ow ing ope rati ons :

12. 2.1 .l Fuel Handling ope rati ons ;

12 .2. 1.~ Actions to be taken to cor rec t specific and foreseen pot ent malfunctions of systems or com ial pon ent s, including responses alarms resulting from suspec to ted prim ary system leaks; Preventative or cor rec tive ma inte nan ce ope rati ons whi ch have an effect on the saf ety could of the facility.

12.2.2 Tem por ary procedures which do not change the inte nt of previously approved pro ced ure s may be utilized i on approval by aq 11 a!ifiea$d I

pro ced ure s shall be subsequen i:Y~I. Such ___ -

I tly rev iew ed by the Reactor I Safeguards I Co mm itte e.

! 12. 3 Records i

~L ~- rd -5 5~ ?- \,\ ~-e...

Mamta,n records ceq*ured und '\'< :.C ~.f \~ C:..'-f'\Q er the fac1l1ty A QS B.Q...Q.o,~~c\

\I l

\1)t license and applicable regula tions.

I I

\

12 .. 1.4 t'.hanges co fatlllty vv1t11om License A1 11E 1,f l~

n,e l_iceAse; shall_ mal~e cl9ani;;es to Hie faeilitv uoi the l1ee1,!c7tecl1111eal spceifieatioA tlm at NIK approval when a c l : d ~

is 11ot 1eqaired-:--

El1anges car, !:Jc Made wiH1e1:1 t RSC app1 oval to pFoceaures

, educe tlle existing effectiveness aAEl R1etheGI, wbicb does not of the design fuIIction5-:-

Cha~ges tha t may, in the ir 1m piementat1on, red te tl,e effe unct,on ace coosidei:ild 1:1A~c v1ev ctive11ess of the 61esigoJ

'd ve d du t s 1a II e tJ rev1*evv ed

---lIanges shall be doc um ent a1 id app1 uved b*f RSC ed and retained by the license rrrspectton by the NRC. Record e and 111ade available 11pan s should be held as I eqail ed by appI0µ1 iate reg1:1latia s

TABLE 1 SAFETY SYSTEM FUNCTIONS

- ,ec..,r, ;)~C:..

_,::\:\ SENSOR OR TRIP DEVICE NO. OF SWITCHES OR SENSORS ANNUNCIATOR AND ALARM SET r ()';)\ \j) ().." v-

~em pera ture Gt.

• POINT 1

Coula11t Wate-r .

s 130° F 0..-\

'\) C)C) \ \.()

Low Pool Wate r Level ~

e.£ C..0rsd..:iC..~\ V\~ 'f: j_  !:: 5 AA M h of C l'Y\

1 s 1 ft max decrease Selsffiie 9htui bdt'rt=e IV on Modif ied Merca lli Scale Bridge Crane Locat ion ~

1 When locate d off storage positi on Area Radia tion Moni tor 1

s 10 mr/hr Wate r Radio activi ty "iE- 1 LQw s 20 mr/hr Osn: iifler ~r Wate r Flow ~

1 7, -z_:e: *1 ling Gas Efflue nt Moni tor

• 1

.:: 4 gpm s 2 mr/hr 7 . t..\- "? ac\o .1/2\- -L ~0,0~"i

I:.£\ ~,c-v c*r, e. . !{\. '\- ~

(._ 6 (). fYn (Y\c.__ I &Q_,.\ c-_)

• ~~ . o \ rA Ro.m /hr;_

0.1'"\d So R~.xv1 /'hr .

7.s  ?'v r\ v-...~t<L Su, \J~ 1

~ 5-.\--,vrc.....Jt<'\+ 'D-__1/4 ~ *0 \ ~ rJt..-'(\/ h ,

C N~\ -R-o t-S) Qi'\a \ \. 0 f:~ / r\ r f\ .5 f-J.rz...~d-'!. j

\)o~ ~ C'NLl -U'_j ~

• Safety systems instru ment s that are related to the safe and secure stora ge of the irradiated fuel shall be operable when relevant if the irradiated fuel is present in the facility.

Level 1 President Level2 I,*""" t. * ""

"\I "J 'I

• I\ "

• 1"

'-J \j ',./ V "f,.

~ t,.

\j\l \I\,

Reactor Administrator ,.... - -- Reactor Safeguards Comm.

Level3 Level3 Radiation Safety Certified Fuel Handler Supervisor

~JL\)o 1 ~ \ ~ L\~~_j

• - - - - ~{Y\ mu f\' c.o,J \ ; GV\Q.S .

Level4 f"\

Certified Fuel Handler Figure 1 - ARRR Organization chart

Enclosure 3 AEROTEST OPERATIO NS. 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-9 8 issued on January 2 8, 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 (IO 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 hazards consideration; 1 Amendment No 6

Enclosure 3 G. The receipt, possession, and use of byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30 and 70, including Sections 30.33, 70.23, and 70.31; H. The licensee is qualified to be the holder of the license; and I. The transfer of the license is otherwise consistent with applicable provisions of law, 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 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. Actions involving special nuclear material are limited to those related to fuel storage and decommissioning; (3) Pursuant to the Act and 10 CFR Part 30, "Licensing of Byproduct Material,"

(1) to possess 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.

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 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 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 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 repmts 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 3 0 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 3 0 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). Each license for a facility that has permanently ceased operations, continues, until the Commission notifies the licensee in writing that the license is terminated.

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 part of the exclusion area. The exclusion area that is part of non-restricted area is the prior machine shop, the prior electrical shop, the prior chemistry laboratory, the prior tagging room, the prior set-up room, the prior garage, the prior magazine vault, the prior office area, the prior control room and the prior break/meeting room.

2.3 Within the restriction area activities are limited to fuel storage, fuel handling and decommissioning activities as approved in the decommissioning plan of the ARRR. The non-restricted area can be used for non NRC regulated activities.

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.

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 lllmho/cm.

Enclosure 3 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 Storage Safety Systems Safety systems instruments that are related to the safe and secure storage of the irradiated fuel shall be operable when relevant if the irradiated fuel is present in the facility. Those safety system instruments are noted by an asterisk(*) in Table 1. A service period not to exceed thirty days shall be allowed to facilitate any required 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 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 building 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 A gas sample shall be continuously withdrawn from above the reactor and below the pool cover 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 water radioactivity monitor shall be attached to the process water cleanup system loop adjacent to the demineralizer 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 (gamma, beta) 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 survey instrument (neutron) 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 (gamma, neutron) shall be placed at several locations within the reactor building for area radiation analysis.

7.7 Instrumentation with readout in the control room shall be operating to permit continuous indication of pool water temperature and pool water conductivity. Alarms shall be operable to indicate low water flow, low pool water and bridge crane location.

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 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.

Enclosure 3 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 facilities shall be so designed that for all conditions of moderation kett 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 designee shall be present for irradiated fuel transfers outside of the reactor tank.

11.5 No more than one fuel element that is not in storage shall be allowed in the facility. The only movement of the fuel elements shall be for fuel element inspections, canister surveillances, rearrangement of fuel elements in storage, or final placement in the transportation cask.

11.6 CFH or CFH Supervisor does not need to be at the facility on a daily basis. They are only required when there is a transfer/movement of fuel.

Enclosure 3 12.0 Administrative Requirements 12.1 Organization (Figure 1) showing reporting and communication lines 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, 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 Administrator 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) is a non-licensed operator who has qualified in accordance with the ARRR CFH Training/Requalification Program and 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 Reactor Administrator, 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 lieu of the experience requirement.

Enclosure 3 12.1.5 The Certified Fuel Handler (level 4) is a non-licensed operator who has qualified in accordance with ARRR CFH Training/Requalification Program. Fuel handling obligations include maintenance, periodic fuel inspections and/or putting the spent fuel in transportation casks for fuel shipment from facility. The CFH only handles fuel when need and only handles 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 ofthe 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 ARRR facility's 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.

Enclosure 3 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 Normal operating of all systems and components involving nuclear safety of the ARRR 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.

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.

TABLE 1 SAFETY SYSTEM FUNCTIONS TECH SPEC SENSOR OR TRIP DEVICE NO.OF ANNUNCIATOR AND ALARM SET

1. SWITCHES OR POINT SENSORS 7.7 Pool Water Temperature

• 1 ~ 130° F 7.7 Pool Water Conductivity* 1 ~ 5 µmho/cm 7.7 Low Pool Water

• 1 ~ 1 ft max decrease 7.7 Bridge Crane Location

• 1 When located off storage position 7.1 Area Radiation Monitor 1 ~ 10 mr/hr 7.3 Water Radioactivity* 1 ~ 20 mr/hr 7.7 Low Water Flow

• 1 ~ 4 gpm 7.2 Gas Effluent Monitor* 1 ~ 2 mr/hr 7.4 Portable Survey Instruments 1 Between .01 mrem/hr and (Gamma, Beta) 50 rem/hr 7.5 Portable Survey Instrument 1 Between .Olm rem/hr and (Neutron) l.0rem/hr 7.6 Radiation Dosimeters As needed N/A (Gamma. Neutron)

• Safety systems instruments that are related to the safe and secure storage of the iITadiated fuel shall be operable when relevant if the iITadiated fuel is present in the facility.

Level 1 President Level2 Reactor Administrator Reactor Safeguards Comm.

Level3 Level3 Radiation Safety Certified Fuel Handler Supervisor Reporting lines Level4 Certified Fuel Handler Communication lines Figure 1 -ARRR ANSI/ANS-15.1 Organization