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EPID:L-2017-RNW-0027, Submittal of Response to Request for Holding Information from Public Disclosure (Approved, Closed) EPID:L-2018-LLA-0096, Elimination of Technical Specification 6.6 (Approved, Closed) |
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MONTHYEARML17363A3032017-12-20020 December 2017 Aerotest Operations, Inc. - Submittal of Response to Request to Supplement the License Renewal Application Project stage: Supplement ML18010A5622018-02-0202 February 2018 Aerotest Radiography and Research Reactor - Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML18066A0752018-02-28028 February 2018 Submittal of Response to Request for Holding Information from Public Disclosure Project stage: Request ML18093A3852018-03-29029 March 2018 Clarification of TS 6.6 Project stage: Request ML18088A7532018-03-29029 March 2018 Draft Request for Additional Information for License Renewal of the Aerotest Radiography and Research Reactor Project stage: Request ML18074A1112018-04-0202 April 2018 Aerotest Operations, Inc. - Request for Withholding Information from Public Disclosure Response to Request to Aerotest Operations, Inc. to Supplement the License Renewal Application Project stage: Withholding Request Acceptance ML18088A7012018-04-24024 April 2018 Request for Additional Information Regarding the Renewal of Facility Operating License No. R-98 Project stage: RAI ML18127A0752018-04-30030 April 2018 Elimination of Technical Specification 6.6 Project stage: Request ML18129A0562018-05-16016 May 2018 Acceptance of Requested Licensing Action Regarding Technical Specification 6.6 for the Aerotest Radiography and Research Reactor Project stage: Acceptance Review ML18127B7032018-06-0808 June 2018 Review of the Restart Plan for the Aerotest Radiography and Research Reactor Project stage: Approval ML18201A1972018-07-17017 July 2018 Request for Additional Time Project stage: Request ML18198A4512018-07-23023 July 2018 Response to Request for Extension of Time to Respond to Request for Additional Information Regarding the Renewal of Facility Operating License No. R-98 Project stage: RAI ML18257A0752018-09-11011 September 2018 Request for Additional Time Beyond the Deadline to Answer Questions Project stage: Request ML18260A0452018-09-18018 September 2018 Response to Second Request for Extension of Time to Respond to Request for Additional Information Regarding the Renewal of Facility Operating License No. R-98 Project stage: RAI ML18277A2962018-10-15015 October 2018 Request for Additional Information Regarding the Operator Requalification Program for the Aerotest Radiography and Research Reactor Project stage: RAI ML18303A2912018-10-24024 October 2018 Aerotest Radiography and Research Reactor Response to RAI-ORP-7 Project stage: Request ML19015A3322019-01-25025 January 2019 Requests for Renewal of Facility Operating License No. R-98, Review of the Restart Plan, and Amendment to Technical Specification 6.6 for the Aerotest Radiography and Research Reactor Project stage: Approval ML20309A6762020-11-0404 November 2020 Missouri University of Science and Technology - Written Communication as Specified by 10 CFR 50.4 Requesting Approval of an Exigent Amendment to the Technical Specifications Appended to Facility Operating License R-79 Project stage: Request ML20314A3622020-11-12012 November 2020 Board of the Curators of the University of Missouri - Issuance of Amendment No. 22 to Renewed Facility Operating License No. R-79 to Extend the Period to Perform Visual Inspections of the Shim/Safety Rods Project stage: Approval 2018-04-30
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Category:Letter
MONTHYEARIR 05000228/20230012024-02-0505 February 2024 NRC Inspection Report 050-00228/2023-001, Disputed Cited Violation and Minor Violation Revised, EA-23-118 ML23279A1062023-10-0202 October 2023 Response to Violation 05000228/2023001-001B ML23255A0342023-09-0909 September 2023 Response to Violation 050-00228/2023-001-00lA ML23255A0362023-09-0909 September 2023 Response to Inspection Report 050-00228/2023-001 ML23219A1882023-08-24024 August 2023 NRC Inspection Report 05000228/2023001, and Notice of Violation ML23187A0562023-07-0101 July 2023 Radiation Safety Officer Change Update ML23187A0582023-07-0101 July 2023 July 1, 2022 Thru June 30, 2023 Summary of Changes, Tests, and Experiments ML23157A0662023-05-24024 May 2023 Letter from David Slaughter, Aerotest Operations, Inc. Inadequate Oversight of Non-Power Reactor OIG Case No. 21-012 and Requested Payment for Damages Caused by the Nrc'S Inadequate Oversight ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22340A0062022-11-16016 November 2022 Reference Documents from Decommissioning Plan ML22215A1522022-07-21021 July 2022 Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan ML22187A0852022-07-0101 July 2022 Inc - July 1, 2021 Thru June 30, 2022 Summary of Changes, Tests, and Experiments ML22152A2522022-06-28028 June 2022 Request for Additional Information on Review of Request for Amendment to Approve Decommissioning Plan, Arrr (License No. R-98, Docket No. 50-228) ML22060A2602022-03-21021 March 2022 Change in NRC Staff Project Management Responsibility for the Aerotest Radiography and Research Reactor ML22040A1992022-03-0909 March 2022 Examination Confirmation Letter No. 50-288/OL-22-03, Reed College ML22025A2002022-01-20020 January 2022 Amendment to AO Decommissioning Plan Submittal Letter Dated July 20, 2021, Agencywide Documents Access, and Management System (ADAMS) Accession No. ML21230A304 ML21307A3242022-01-12012 January 2022 Request for Supplemental Information for Decommissioning Plan, Arrr (License R-98, Docket 50-228) ML21344A0332022-01-0303 January 2022 Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346 ML21361A0472021-12-21021 December 2021 Response to December 6, 2021 NRC Pol Issuance; the Licensee and Its Reactor Safeguard Committee Request a Reasonable Opportunity to Review and Address Short Comings of the Draft Licensee and Technical Specifications Along with the Draft Sa ML21242A4632021-12-0606 December 2021 Issuance of License Amendment No. 6 to Facility Operating License No. R-98 for the Aerotest Radiography and Research Reactor with Partial Denial of Amendment Request ML21307A1252021-10-28028 October 2021 Letter Regarding Charges Billed ML21209A5192021-07-20020 July 2021 Aerotest Radiography and Research Reactor, Response to NRC Letter Dated July 12, 2021 (ML21188A391) ML21230A3042021-07-20020 July 2021 Decommissioning Plan Submittal (Redacted) ML21147A3732021-07-19019 July 2021 Correction of Letters Regarding Closure of Confirmatory Action Letter No. NRR-04-003 and Review of Physical Security Plan ML21188A3912021-07-12012 July 2021 Inc. - Revised Completion Date Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License ML21188A2162021-07-0101 July 2021 July 1, 2020 Through June 30, 2021 Summary of Changes, Tests, and Experiments ML21193A0892021-07-0101 July 2021 Emergency Plan (Redacted) ML21181A1232021-06-22022 June 2021 License and TS Amendments ML21147A0602021-05-19019 May 2021 Response to RAI 28 and 29 ML21056A3172021-04-30030 April 2021 CFO Response to Aerotest November 11 2020 Letter ML21126A1502021-04-28028 April 2021 License and TS Amendments ML21098A1572021-03-31031 March 2021 Response to RAI CFH Training and Requalification Program- 3/30/21 ML21118A0252021-03-30030 March 2021 Confirmatory Order ML21047A4682021-03-30030 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 ML21034A6262021-03-12012 March 2021 Request for Additional Information Possession-Only License Amendment Request for the Aerotest Radiography and Research Reactor Facility Operating License No. R-098 ML21048A1392021-03-0505 March 2021 Acknowledgement of Letter Regarding Decommissioning Plan and Exercise of Enforcement Discretion ML21004A0792021-01-0707 January 2021 Review of Physical Security Plan in Support of Possession-Only License Amendment Request License No. R-98 ML20345A0312020-12-28028 December 2020 CFO Response to Aerotest November 2020 Letter Re Lfb 20-1849 IR 05000228/20202022020-12-10010 December 2020 U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000228/2020202 and Notice of Violation - Non-OUO-SRI (Cover Letter) ML20332A0322020-11-18018 November 2020 Unable to Submit Decommissioning Plan by December 5, 2020 Due to COVID-19 ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20325A1762020-11-11011 November 2020 Response to NRC CFO, Letter Dated April 18, 2019 Re Reimbursement Request for Activities Associated with the Fees That Were Not Performed in a Satisfactory Manner ML20325A1342020-11-10010 November 2020 Letter Disputing to Make Payment for Services That Are Not or Poorly Rendered ML20289A4772020-10-23023 October 2020 Aerotest Response Letter from D. Slaughter Dated September 14, 2020 Docket 50-228 ML20304A1532020-10-21021 October 2020 Response to Notice of Violation IR 05000228/20202012020-10-15015 October 2020 U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000228/2020201 and Notice of Violation ML20276A2472020-09-28028 September 2020 Aerotest Radiography and Research Reactor - Updated Arrr Security Plan ML20234A6312020-09-17017 September 2020 Request for Clarification Physical Security Plan Review - Cover Letter - (Public Version) ML20248H4602020-08-28028 August 2020 Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program ML20177A2032020-07-27027 July 2020 Request for Additional Information Possession-Only License Amendment Request to Use Certified Fuel Handlers for the Aerotest Radiography and Research Reactor Facility Operating License No. R-98 2024-02-05
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML22215A1522022-07-21021 July 2022 Aerotest Radiography and Research Reactor - AO RAI Responses for Decommissioning Plan ML21344A0332022-01-0303 January 2022 Aerotest Letter from the Chief Financial Officer Regarding Additional Information for the Fees Assessed Under to Aerotest Operations, Inc. (Aerotest) within Invoice Number Lfb 22-0346 ML21181A1232021-06-22022 June 2021 License and TS Amendments ML21147A0602021-05-19019 May 2021 Response to RAI 28 and 29 ML21126A1502021-04-28028 April 2021 License and TS Amendments ML21098A1572021-03-31031 March 2021 Response to RAI CFH Training and Requalification Program- 3/30/21 ML20325A1762020-11-11011 November 2020 Response to NRC CFO, Letter Dated April 18, 2019 Re Reimbursement Request for Activities Associated with the Fees That Were Not Performed in a Satisfactory Manner ML20248H4602020-08-28028 August 2020 Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program ML20098D4152020-03-26026 March 2020 Aerotest Radiography and Research Reactor, Response to NRC Staff Request for Additional Information (Redacted Version) March 26, 2020 ML19184A1122019-06-28028 June 2019 License and TS Amendments ML18303A2912018-10-24024 October 2018 Aerotest Radiography and Research Reactor Response to RAI-ORP-7 ML18240A1412018-08-22022 August 2018 Response to Request for the Small Entity Fee Adjustment ML18068A1632018-02-28028 February 2018 Response to Request for Holding Information from Public Disclosure, Non-Proprietary Chapter 15, USAR ML17363A3032017-12-20020 December 2017 Aerotest Operations, Inc. - Submittal of Response to Request to Supplement the License Renewal Application ML16319A1322016-11-0101 November 2016 Aerotest Operations, Inc., Response to Generic Letter 2016-01 Regarding Monitoring of Neutron-Absorbing Material in Spent Fuel Pools ML16313A1582016-11-0101 November 2016 Aerotest Operations, Inc., Response to NRC Generic Letter 2016-01 in Regard to Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML16294A2502016-10-10010 October 2016 Aerotest Radiography and Research Reactor Response to Request for Additional Information Regarding Opportunity to Supplement 2012 License Transfer Application ML16245A2302016-08-22022 August 2016 Pillsbury, Winthrop, Shaw, Pittman, Llp, Submittal of Response to Request for Additional Information Regarding Opportunity to Supplement 2012 License Transfer Application ML16203A1542016-07-12012 July 2016 Supplemental Response to Request for Additional Information Regarding Application for Change in Method of Providing Financial Protection ML16190A1732016-06-15015 June 2016 Pillsbury, Winthrop, Shaw, Pittman, Llp, Response to Request for Additional Information Application for a Change in Method of Providing Financial Protection ML16117A2592016-04-21021 April 2016 Response to Request for Additional Information Re; Opportunity to Supplement 2012 License Transfer Application 2022-07-21
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Text
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY
- SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 October 24, 2018 ATTENTION: Document Control Desk (per 10 CFR 50.4)
U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.
RESPONSE TO RAI-ORP-7 Ladies and Gentlemen:
The response concerning the request for additional information, RAI-ORP-7, obtained in NRC letter dated October 15, 2018 is provided in this document. The response is governed by the cited NRC regulations and July 27, 2000 ARRR Requalification program on the subject. (The new ARRR requalification program submitted in 2017 remains under review for approval and therefore is not relevant.)
ARRR SROs have maintained active status according to 10 CFR 55.53(e). Each Senior Reactor Operator has performed SRO activities for more than the minimum 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per calendar quarter and is documented in the SRO's activity log. This regulation.does not specify a composition or percentage of an acceptable SRO workload. While the ARRR SROs have maintained active status, if an operator did not, a remedial program including, at a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of supervised SRO work as detailed in 10 CFR 55.53{f) (and reinforced with similar verbiage found in ANSI/ANS 15.4-2016.) Again, required tasks and composition of SRO activities are not specified in these regulations and standards. Simply, providing specificity for SRO duties is difficult due to varying circumstances surrounding each test or research reactor.
Examining the 10 CFR 55.59 requalification requirements, the ARRR SROs are also in compliance. Section (c)(3)(i) requires that " ....the requalification programs must contain a commitment that each individual shall perform or participate in a combination of reactivity manipulations based on the availability ofplant equipment and systems." (It also states that "senior operators are credited with these activities if they direct control manipulations as they are performed.")
The NRC ordered the ARRR shutdown on July 24 2013, thus eliminating the availability of the plant equipment and systems for the compliance with this obligation. The order was lifted shortly after the license transfer on July 17 2017. The plant equipment and systems needed to satisfy (c)(3)(i) (control manipulations) remain unavailable due to evaluation and preventive/corrective maintenance before the ARRR restart.
Based on the NRC regulations cited, the NRC staff conclusion "none of the Aerotest's licensed personnel currently hold an active status" is in error.
As part of the ARRR restart plan two activities were performed to re-familiarize with the control console instruments/systems and their function.
- 1. The TRIGA reactor response to the insertion of reactivity approach to criticality, low-power, and high power operations (including tthe impact of the fuel's negative temperature coefficient).
The licensed ARRR SRO, Chris Bauman completed SRO training activities on September 20, 2018 at Reed Research Reactor under the auspices of Director Melinda Krahenbuhl, PhD. Below are the activities performed include 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of operation with a minimum of 10 reactivity manipulations of the control rods.
- 1. Briefed on security and safety for entrance.
- 2. Toured the control room, reactor, and related ancillary equipment.
- 3. Reviewed the console layout operation limits (scram settings), the start-up, normal shutdown, and emergency shutdown procedures.
- 4. ARRR SRO brought the reactor to 5 Watt, stabilized and recorded the power level.
(The Reed SRO noted the actions and instrument responses while the ARRR SRO initially withdrew the control rods.) Mr. Bauman was instructed to perform "power steps" at his discretion.
- 5. Starting from 5 Watts power, the ARRR SRO performed a series of reactivity manipulations by altering the position of the control rod to increase/decrease the power level. At each level (step), the power was stabilized and recorded before moving to the next requested power. The Reed SRO monitored the chosen power levels based on his/her understanding of equipment and instrument capabilities.
- 6. The Reed SRO discussed the shutdown process while Mr. Bauman performed that task.
- 7. A debriefing of the training session occurred shortly thereafter to ensure meeting the regulatory obligations.
An objective and performance of the activities are summarized in fulfilment of Section VI of the ARRR Re-Start Plan. The activity was recorded in the SRO activity logbook with activity summaries placed in Chris Bauman SRO's file.
- 2. ARRR 's unique layout of instruments and familiarity of switching sequences and the eye and hand coordination needed to successfully bring the reactor to criticality and sustain power operation.
The licensed ARRR SRO and Reactor Supervisor, A. Meren provided lectures and practicums of the ARRR checkout, Startup and Shutdown procedures to re-familiarize the operators with the reactor console.
Lectures were held on dates 5-30-18 (checkout), 6-5-18 (start-up), and 6-13-18 (shutdown) with individual practicums performed with Mr. Meren shortly after each lecture. An objective of the activities performed are summarized in fulfilment of Section VI of the ARRR Re-Start Plan. The activity is documented in SRO activity logbook and operators file.
I declare under penalty of perjury that the statements above are correct and truthful. Should you have any questions or require additional information regarding this submission, please contact AO President and Reactor Administrator David M. Slaughter, Ph.D. at (801) 631-5919 or dmsraven@gmail.com
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David M. Slaughter, Ph.D.
President and Reactor Administrator Aerotest Operations, Inc.