ML122021201

Response to Request to Aerotest Operations, Inc. and Nuclear Labyrinth, LLC to Supplement the License Transfer Application

ML122021201
Person / Time
Site:	Aerotest
Issue date:	07/19/2012
From:	Silberg J Aerotest, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME8811
Download: ML122021201 (31)

Text

NOTE: Attachments to this document contain confidential information submittedunder 10 CFR 2.390. This information is Business Confidential to Aerotest andNuclear Labyrinth and is identified with brackets as such [] or in the case ofattachments in their entirety.July 19, 2012ATTENTION: Document Control DeskU.S. Nuclear Regulatory CommissionWhite Flint North11555 Rockville PikeRockville, MD 20852-2738AEROTEST RADIOGRAPHY AND RESEARCH REACTORDOCKET NO. 50-228/LICENSE NO. R-98.RESPONSE TO REQUEST TO AEROTEST OPERATIONS. INC. ANDNUCLEAR LABYRINTH LLC TO SUPPLEMENT THE LICENSETRANSFER APPLICATION (TAC NO. ME8811)Ladies and Gentlemen:Enclosed please find the response of Aerotest Operations, Inc. ("Aerotest")and Nuclear Labyrinth LLC ("Nuclear Labyrinth") to the U.S. Nuclear RegulatoryCommission's Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC toSupplement the License Transfer Application dated July 5, 2012 including supportingaffidavits on behalf of both Aerotest and Nuclear Labyrinth. Also enclosed are arequest to withhold confidential information from public disclosure and a copy of theresponse redacting the confidential information.Should you have any questions or require additional information regardingthis submission, please contact Jay Silberg, counsel to Aerotest at 202-663-8063 orjay.silberg@pillsburylaw.com.Sincerely yours,2 SbergCounsel for Aerotest Operations, Inc.Enclosures 14_

July 19, 2012Page 2STATE OF MICHIGANCOUNTY OF OAKLAND: TO WIT:I, Michael S. Anderson, state that I am the Secretary of Aerotest Operations, Inc., and that I amduly authorized to execute and file this supplemental information on behalf of AerotestOperations, Inc. To the best of my knowledge and belief, the statements contained in thisdocument with respect to Aerotest Operations, Inc. are true and correct./4~~9-Subscribed and sworn before me, a Notary Public in and for the State of Michigan and County ofOakland, this / day of July 2012.WITNESS my Hand and Notarial Seal:Notary Pu7icMy Commission Expires:CANDACE MIERZWINSIQNotary Public, Stats of MichiganCounty of OaklandActing in theC, 403572395vl July 19, 2012Page 3STATE OF UTAHTO WIT:COUNTY OF SALT LAKE COUNTYI, Dr. David Michael Slaughter, state that I am the Chief Executive Officer of Nuclear LabyrinthLLC, and that I am duly authorized to execute and file this supplemental information on behalfof Nuclear Labyrinth LLC. To the best of my knowledge and belief, the statements contained inthis document with respect to Nuclear Labyrinth LL re true and correct.Subscribed and sworn before me, a Notary Public in and for the State of Utah and County of SaltLake, this j day of July 2012.WITNESS my Hand and Notarial Seal:My Commission Expires:NotaryfPiu-&icI NOTARY PUBLICDOWEL KING652053COMMISSION EXPIRESFEBRUARY 01, 2016STATE OF UTAH403572400vi plisburqJuly 19, 2012Page 4Enclosures1. Response to Request to Supplement License Transfer Application -proprietary copy2. Response to Request to Supplement License Transfer Application -non-proprietary copy3. Request to Withhold From Public Disclosurecc: U.S. NRC Office of Nuclear Reactor Regulation/NRLPOU.S. NRC Region IV, Regional AdministratorNRC, NRR (Traiforos)NRC, OGC (Uttal)NRC, OGC (Safford)

Aerotest Radiography and Research ReactorDocket No. 50-228Enclosure 2Non-proprietary CopyJuly 19, 20121. Provide all of the general information for any Nuclear Labyrinth-owned entities inthe ownership chain that may not have been included in the application, includingthe names, addresses and citizenship of the principal officers.There are no additional Nuclear Labyrinth-owned entities in the proposed ownershipchain ofAerotest Operations, Inc. ("Aerotest "). As stated in the Application for Approval ofIndirect Transfer of Control of the License Pursuant to 10 C.F.R. § 50.80 dated May 30, 2012("Application "), Nuclear Labyrinth LLC ("Nuclear Labyrinth ") will become the owner of allshares ofAerotest. Nuclear Labyrinth was created to purchase the shares ofAerotest and ismanaged by its Chief Executive Officer ("CEO "') and sole owner, Dr, David M. Slaughter, PhD.Attachment 3 to the Application provides the post-transfer organization chart demonstrating theownership chain ofAerotest. Attachment 4 to the Application provides the names, addresses,and citizenship of directors and principal officers of both Nuclear Labyrinth and Aerotest as ofthe effective date of the transaction. In simplified form the ownership chain willbe as follows:Nuclear Labyrinth LLC[ Aerotest Operations, Inc.2. Since there were no sources of funds identified in the application, provide thesource(s) of funds to cover the projected operating costs identified in theProjected Income Statement included in Attachment 7 of the application, pursuantto 10 CFR 50.33(f)(2). Specifically, state if there are any committed sources offunds (e.g., commercial, government, educational) for operations of the AerotestRadiography and Research Reactor (ARRR) facility, and provide any applicablecommitments, letters of intent, or contracts with these sources of funds.PROPRIETARY -BUSINESS CONFIDENTIAL TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390Withhold from public disclosure under 10 C.F.R. § 2.39403575635vl

3. State if there are any contracts between Autoliv and Nuclear Labyrinth to providetwelve months of operating expenses as well as the initial decommissioning trustfund contribution of $3,285,800.PROPRIETARY -BUSINESS CONFIDENTIAL TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390Withhold from public disclosure under 10 C.F.R. § 2.394. Provide Nuclear Labyrinth's latest annual financial statements.Nuclear Labyrinth was created for the purpose ofpurchasing the shares ofAerotest. Asa newly created entity, it has nofinancial statements to submit.5. Since future funding is expected to be provided from decommissioning feescharged to users of the ARRR for the first five years of operation, state if there areany commitments, letters of intents, or contracts entered into with potential usersof the ARRR and, if applicable, provide these documents for review, pursuant to50.75(d)(2)(iii). In addition, state the method of providing decommissioningfunding assurance after the first five years of the projected license transfer.As discussed in the response to request 2, there are no commitments, letters of intent, orcontracts entered into with potential users of the ARRR. As provided in the Funding Agreement,a decommissioning trust fund will be established at the closing of the transaction and will befunded according to the current estimate of decommissioning costs, $3,285,800. In order toassure the adequacy of the decommissioning trust, it is Nuclear Labyrinth's intention toimplement afee structure that can easily accommodate changes in decommissioning costestimates. In the initialfive years of new ownership, a fee consisting offive percent of theunadjusted cost will be assessed to work that uses the ARRR. After five years, the assigneddecommissioning fees applied to the use of the reactor will be evaluated for adequacy. Thesefees may continue to be assessed at the current level, or be changed (increased or reduced) inaccordance with updated decommissioning cost estimates. A new decommissioning cost estimatewill be prepared as part of the recurring biannual review and update of the study provided inAttachment 8 of the Application.6. Attachment 10, Conforming Amendments, is based on a previous application forlicense transfer that was never approved. Submit Attachment 10 using the currentlicense and technical specifications, marked up to clearly show all insertions,deletions and revisions.Attachment 2 to this response provides conforming markups of the current ARRR licenseand technical specifications. These markuzips also include correction of historical typographicalerrors.2403575635vl

Attachment

s:1. Funding Agreement2. Conforming Amendments403575635vl ATTACHMENT (1)PROPRIETARY -BUSINESS CONFIDENTIAL TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390Withhold from public disclosure under 10 C.F.R. § 2.390FUNDING AGREEMENT403575635vl ATTACHMENT (2)Conforming Amendments403575635vl UNITED STATES( -/ ATOMIC ENERGY COMMISSIONWASHINGTON. D.r0. 20545AEROTEST OPERATIONS, INC.DOCKET NO. 50-228AEROTEST RADIOGRAPHY AIND RESEARCH RPEACTOR (AIMRR)-AXENDIHENT TO FACILITY OPERATING LICENSEAmendment No. -k..L h e l -R, -/'a I-" 0Licen{ se No. R-98.The -m--Eneee Commission (the Commission) has found that:A. The apolication for transfer of license led byQ*ions, Inc. (the licensee) complies with thestandards and rcquirements of the Atomic Energy Act of 1954, asamended (the Act), and the Comamission's rules and -egulationsse t.forth in 10 CFR Chapter !;B. Construction of the facility has been substantially completedin conformity with Construction Permit No. CPER-86, and theapplication, as. amended, the provisions of the Act and the rulesand regulations of the Commission;C. The facility will. operate in conformity with the application, asamended, the provisions of the Act, and the rules and regulationsof the Commission;,D. There is reasonable assurance: (i) that the activities authorizedby this operating license can be conducted without endangering thehealth and safety of the public, and (ii) that such activities willbe conducted in .compliance with the rules and regulations of theCommission;E. Aerotest Operations, Inc. is technically and financially qualifiedto possess, use, and operate the facility in accordance with therules and regulations of the Commission;

-2-F. The issuance of this operating license will not be inimical tothe common defense and security or to the health and safety ofthe public, and does not involve a significant hazards con-sideration;G. The receipt,. possession, and use of byproduct and special nuclearmaterial as authorized by this license will be in accordance withthe Commission's regulations in 10 CFR Parts 30 and 70, includingSections 30.33, 70.23, and 70.31;H. The licensee is qualified to be the holder of the license; andI. The transfer of the license is otherwise consistent with applicableprovisions of law, regulations, and orders issued by the Commissionpursuant thereto.2. Facility Operating License No. R-98, issued to "eT ceCcrporat i, lb tr- ...nrr-eA-ti7verotest Operations, Inc. .a..-he-1,4A u-6 t ~tcec~v~Lct.v'jr 1-711-, LLC.° t~'!Irl~~~)A. This license applies to-the Aerotest-1adlography and Research Reactor(AERR), previously called the Aerojei General Nuclear Industrial Aer e;RReactor (AGNIR), a pool-type nucleam reactor owned Inz t r .The facility is located at the Adr/otest Operations site near San I W V)hdRamon, California, and is described in the application dated awne-dSeptember 14, 1964 (the application), and in supplements thereto, Natearincluding the application for transfer of license dated April 24, B. Subject to the conditions and requirements incorporated herein, theCommission hereby licenses Aerotest Operations, Inc.:(1) Pursuant to Section 104c of the Act and 10 CFR Part 50,"Licensing of Production and Utilization Facilities", topossess, use, and operate the reactor at the designatedlocation in San Ramon, California, in accordance with theprocedures and limitations set forth in this license;(2) Pursuant to the Act and 10 CFR Part 70, "Special NuclearMaterial", to receive, possess, and use up to 5.0 kilogramsof contained uranium 235 in connection with operation of thereactor; and(3) Pursuant to the Act and 10 CFR Part 30, "Licensing ofByproduct Material", (1) to receive, possess, and use a2 curie americium-beryllium neutron startup source, and(2) to possess, but not to separate, such byproduct material-as may be produced by operation of the reactor.I'_ __ ...... ....

KI)3C. This license shall be deemed to contain and is subject to theconditions specified in the following Commission regulations in10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Sections 50.54and 50.59 of Part 50, and Section 70.32 of Part 70; is subject toall applicable provisions of the Act and to the rules, regulations,and orders of the Commission now or hereafter in effect; and issubject to the additional conditions specified or incorporatedbelow:(1) Mlaximum'Power LevelThe licensee is authorized to operate the facility at steadystate power levels not in excess of 250 kilowatts (thermal).(2) Technical .SpecificationsThe Technical Specifications contained in Appendix A, asrevised, are hereby incorporated in the license. Thelicensee shall bperate the facility in accordance withthe Technical Specifications, as revised by issued changesthereto through Change No. 8.D D. ReportsIn addition to reports otherwise required under this license andapplicable tegulations:(1) The licensee shall report in writing to the Commission within10 days of its observed occurrence any incident or conditionrelating to the operation of the facility which prevented orcould have prevented a nuclear system from performing itssafety function as described iq the Technical Specificationsor in the Hazards Summary Report.4(2) The licensee shall report to the Commission in writing within30 days of its observed occurrence any substantial variancedisclosed by operation of the facility from performance speci-fications contained in the Hazards Summary Report or theTechnical Specifications.(3) The licensee shall report to the Commission in writing within30 days of its occurrence any significant change in transientor accident analysis, as described in the Hazards SummaryReport.E. RecordsIn addition to those otherwise required under this license and appli-cable regulations, the licensee shall keep the following:

-4-(1) Reactor operating records, including power levels.(2) Records of in-pile irradiations.(3) Records showing radioactivity released or discharged intothe air or water beyond the effective control of thelicensee' as measured at the-point of such release ordischarge.(4) Records of emergency reactor scrams, including reasonsfor emergency shutdowns.F. This amended license is effective as of the date of issuance andshall expire at midnight April l6, 2005.FOR ATD E COMMISSIONKarl R. Goller, Assistant Directorfor Operating ReactorsDirectorate of Licensing (Ch:anc- No. 8 to th0 TechnicalDate. of Issuance: October .2 .107/L A wP-3 APPENDIX A-'I LICENSE NO. R-98'TECHNICAL SPECIFICATIONS FOR THEAEROTEST RADIOGRAPHY AND RESEARCH REACTOR(AERR)1.0 Definitions1.1 ShutdownThe reactor, with fixed experiments in place, shall be considered tobe shut down (not in operation) whenever all of the following conditionshave been met: (a) the console key is in the"'off" position and the keyis removed from the console and under.-the control of a licensed operator(or stored in a locked storage area); (b) sufficient control rods areinserted so as to assure the reactor is subcritical by a margin greaterthan 0.7% delta k/k cold, clean critical condition; (c) no work is inprogress involving refueling operations or maintenance of its controlrod mechanisms.1.2 Reactor OperationReactor operation shall mean any condition wherein the reactor is not shutI) down.1.3 OperableA system or component shall be considered operable when it is capableof performing its required function in its normal manner.1.4 OperatingA component or system is operating if it is performing its requiredfunction in its normal manner.1.5 ExperimentExperiment shall mean any apparatus, device, or material installed inthe core or experimental facilities (except for underwater lights, fuelstorage racks and the like) which is not a normal part of these facilities.1.6 Experimental

• AcilitiesExperimental facilities shall mean Glory Hole, vertical tubes, pneumatictransfer systems, central thimble, beam tubes, thermal column, and in-pool irradiation facilities.1.7 Reactor Safety CircuitsReactor safety circuits shall mean those circuts, including their associated,

-2-input circuits, which are designed to.initiate a reactor-stram.2.0 Reactor Site2.1 The reactor and associated equipment is located within an exclusibnarea.2.2 A steel,'locked perimeter fence shall surround the ARRR facility,forming an exclusion area; The minimum distance from the centerof the reactor pool to the boundary of the. exclusion area fencingshall be 50 feet. The restricted area, as defined, in 10 CFR 20,shall consist of the entire exclusion area.2.3 The principal activites carried on within the exclusion area shallbe those associated with the operation of the ARMa reactor and theuse of a hot cell and chemistry -laboratory.3.0 Reactor Building3.1 The reactor shall be housed in a steel building capable of meeting..the following functional requirements:3.1. all circulating fans and air conditioning systems except thesystem which supplies air to the control room shall have thec.apability to le shut off from a single control in the' controlroom.3.1.2 ventilation shall be achieved by gravity ventilators 'locatedon the roof of the building, and3.1.3 a positive air pressure shall be maintained in the controlroom with respect to the reactor room.3.2 An alarm system shall be installed to detect unauthorized entryinto the reactor building. The alarm system shall be monitoredconstantly, and its annunciation shall be tested monthly.4.0 Reactor Pool (Primary System)4.1 The minimum depth of water above the top of the active core shallbe 16 ft. The maximum bulk water temperature shall be 130*F and!the minimum 600F.4.2 The pU and conductivity of the primary coolant shall be measuredat least once each month. Corrective action shall be taken toavoid exceeding a pH of 7.5 or a conductivity of 5 umho/cm.

-3-5.0 Reactor Core5.1 Fuel Elements5.1.1 The reactor shall contain no more than 90 TRIGA type fuelelements. The core shall be loaded with not more than3.30 kg of U-235.5.1.2 The maximum excess reactivity above cold, clean critical,with or without experiments in place, shall be 3 dollars.5.1.3 The bath temperature coefficient and the prompt fuel temp-eratutre-cbefficient shall be negative at all operating .temp-eratures and the minimum reactivity decrement at full powershall be 80 cents when measured with respect to source powerlevel.5.1.4 The coolant void coefficient shall be negative across theactive core. Maximum in-core operating void shall be 10%of the coolant core v6lume as defined by a cylinder boundedby the grid plates.5.2 Reflector Elements5.2.1 The overall reflector elements' dimensions shall be the same asthe fuel elements.5.3 Control Elements5.3.1 The reactor shall be subcritical by a minimum margin of 0.50 dollarwhen the maximum worth rod is fully withdrawn from the core.5.3.2 The maximum rate of reactivity addition for the control rods shallbe 11 cents/second. There shall be a minimum of three operablecontrol elements.5.3.3 The total time for insertion of the control rods following receiptof a scram signal by the safety system shall be a maximum of 600milliseconds.6.0 Reactor Safety Systems6.1 'The reactor. safety system shall include sensing 4evices and associatedcircuits which automatically actuate visual and audible alarms and,when certain pre-set limits are exceeded, scram the reactor.. Thesystems shall be fail-safe(de-energizing shall cause a scram) Table 1describes the minimum requirements of the safety system.

-4-6.2 The nuclear, process and radiation monitoring instrumentation shallprovide the functions and have the set point ranges and associatedannunciations listed in Table.2 of these specifications.6.3 The.safety system shall be designed such that no single componentfailure or circuit fault shall ,eOstqy disable both the auto-matie and manual scram circuits. i ~ o .t6.4 Reactor sequence, interlocks and safety circuits shall remain operablewhile fue!L is in the core except that one chpnnel may be removed formaintenance purposes when the reactor it shat d.own.6.5 Interlocks shall prevent safety rod withdrawal unless all of thefollowing conditions exist:6.5.1 The master switch is in the ON position;6.5.2 The safety system has been reset;6.5.3 All four nucle.r instruments channels are in the OPERATEmode;6.5.4 The startup channel count rate is greater than 2 cps.(0.5. E, It shall not be possible to withdraw more than the saf~e'trod untilit has reached the upper limit interlock, at which time either theshim or regulating* rod may be moved, but only one at a time.6.6 During a critical experiment a subcritical multiplication plotsshall be obtained from at least three instrumentation channels.These channels may be used in addition to the normal operating,instrumentation in Table 1.6.7 Process instrumentation with readout in the control room shall beoperating to permit continous indication of pool water temperatureand conductivity. Alarms shall be operable to indicate low waterflow, low, pool water and improper location of the crane bridge.7.0 Radiation Monitoring7.1 A fixed gamma monitor employing Geiger tube detectors shall belocated on the wall connecting the control room and the reactorroom. This monitor shall serve as both an area >radiation monitorand a criticality alarm and will annunciate through an automaticmonitoring system to the San Ramon, California, Fire Departmentand actuate a siren within the reactor building on high radiationlevel. The monitor shall have a minimum range of 0 to 20 mr/hr.The annunciation and the siren actuation shall be tested monthly.

IIj-5-7.2 During reactor operation, a gas sample shall be continuously withdrawnfrom the roof vent above the reactor, or from the :io tJ of the re-actor core, and pumped through a radioactive gas detector chamber. Thegas chamber shall be maonifored by a beta-gamma detect6r which shall havea continuous readdut in the control room. An annunciator shall indicatewhen the gas exceeds 2 mr/hr.7.3 A fistion product water monitor shall be 'attached to jthe process watercleanup system lo6p adjacent to the demineralizer and shall provide con-tinuoiis indication in the control room. High radiation :levels withinthe demineralizer or pool water shall annunciate an audible alarm on thereactor console. The range of the monitor shall be from 0.1 to 100mr/hr.7.4 Portable survey instruments for measuring beta-gamma do'se rates in therange of 0.01 m'r/hr to 50 r/hr shall be available to the facility.7.5 Portable instruments for measuring fast and thermal neutron dose ratesfrom1 0.1 trem/hr to 1.0 rem/hr shall be available at the facility.7-.6 Radiation detector packets containing a series 'of threshold detectorashall be placed at several locations within the reactor building for0 post-accident radiation ..endysis.8.0 Expet.mental Facilities8.1 Large-Component Irradiation Box8.1.1 A large-component irradiation box shall have a maximum volumeof 20 cu...f.eet. The box shall encompass not more than 120*arc of the core 'nd shall be designed so that it can be placedno closer than 5 cm to the outer row of active fuel elements.8.1.2 The platform shall be positioned remotely relative to thereactor core by a positive drive and shall be captive to thestand which is bolted to the floor of the tank. Positivemechanical stops shall provent moving the experiment box intothe active reactor core. CO2 shall be used for purging and tomaintain a slight positive pressure in the box relative to the"pool water pressure.8.1.3. To remove or install the experiment box, the platform shall bemoved two or more feet away. from the reactor core.. The boxshall then be lowered onto the platform and bolted in placewith remote handling equipment. The voided box shall be purgedof air prior to exposure to neutrons.8.2 Pneumatic*Transfer Facility 8.2.1 A pneumatic transfer facility may be located in any reactor coreposition. The facility shall be operated with dry CO2 and. ex-hausted through a filter ventilation system, which is monitoredfor radioactivity.8.2.2 The in-core portion of the transfer facility shall have a max-imum void volume of 34 cu. in. in the active fuel region. Amanual control shall be provided which is capable of overridingthe automatic timer control.8.3 Glory Hole Facility8.3.1 A dry glory hole facility may be located in any reactor core position.The glory hole shall accept capsules to a maximum of 1.35 in. indiameter.8.3.2 The glory hole shall be purged with CO to prevent f'ermatibn. of ex-cessive amounts of argon-41. Gas sampIes shall be taken near thepool when the glory hole facility is'operated without a shield plugto insure adequate monitoring of radioactive gases.8.4 "Neutron'Radiogtaphy Facility8.4.1 The beam tube shall consist of a two-section tapered tube having arectangular cross section. The upper and lower sections of .thetube shall be equipped with a fill and drait line.8.4.2 All components contacting the pool water -shall be fabricatedfrom aluminum or stainless steel.8.4.3 The beam catcher shield shall consist of a movable radiation shield.8.5 Thermal Column8.5.1 The thermal column shall be positioned remotely on stetel locatingpins immediately adjacent to the reactor core.8.5.2 The thermal column shall be composed of a three-foot cube of grap-hite encased in aluminum containg five rows of 1.5 in. diameter'irradiation holes. The rows shall be. placed 6 inches apart andcontain seven holes per row. Slotted beams shall be provided toallow experiments to be attached directly to the thermal column.8.6 Vertical Tube8.6.1 Vertical irradiation tubes, having diameters up to 6 in. ,may heattached to the thermal column.

D .-7-8.6.2 The vertical tube shall be purged with CO2 to prevent the formationof excess amounts of argon-41.8.7 Other Irradiation Facilities8.7.1 The central 7 fuel elements of the reactor may be removed from thecore and a central irradiation facility installed rovided the cross-section area of the-facility does not exceed 16 in'.8.7.2 Two triangular exposure facilities are available which shall allowthe insertion of circular experiemats to a maximum of 2.35 in. dia-meter or triangular experiments to a maximum of 3.0 in. on a side.8.7.3. Irradiation capsules in the shape of dummy fuel elements shall havea maximum inner void volume of 34 cu. in. in the active fuel region.9.0 Experiment Limitations9.1 Experiments shall be evaluated in the most reactive condition.9.2 The documentation of experiments, which shall be reviewed and app-roved prior to insertion in the reactor, shall include at least:9.2.1 The purpose of the experiment;9.2.2 A description of the experiment; and9.2.3 An analysis of the possible hazards associated with the per-formance of the experiment..9.3 The value of the reactivity worth of any single independent experimentshall not exceed 2 dollars. If such -experiments are connected or other-wise related so that their combined reactivity could be added to thecore simultaneously, their combined reactivity shall not exceed 2dollars.9.4 The reactivity worth of any single independent experiment not rigidlyfixed in place shall not exceed 1 dollar. If such experiments areconnected or otherwise related so that their combined reactivity couldbe added to the core simultaneously, their combined reactivity worthshall not exceed 1 dollar.9.5 No experiment shall be installed in the reactor in such a mannerthat it could shadow the nuclear instrumentation system monitors.

-8-9.6 No experiment shall be installed in the reactor in such a mannerthat a failure could interfere with the insertion of a reactorcontrol element.-9.7 No experiment shall be performed involving materials which could:9.7.1 Contaminate the reactor pool causing corrosive action onthe reactor components or experiments;9.7.2 Cause excessive production of airborne radioactivity; or9.7.3 Produce an uncontained violent chemical reaction.9.8 Experiments shall not be performed -- inele- equipment whosefailure could result in fuel element damage.9.9 -The amount of special nuclear material contained in an experi-ment shall be limited to 5 grams in the form of solid samplesor 3 grams in the form of liquid. Liquid. special nuclear materialsshall be doubly encapsulated.9.10 Experiments having moving parts shall be designed.to have reactivity-insertion rates less than 10 cents/see except that moving partsworth less than 5 cents may be oscillated or removed at higherfrequencies.9.11 Solid explosive materials may be brought into the facility for thepurpose of being radiographed in the neutron radiography facilitieslocated above the pool; provided that the following conditions aremet;9.11.1 Individual explosive devices shall be limited to 1000 grainsequivalent TNT encased in metallic sheathing.9.11.2 The maximum quantity of explosive material that may bepossessed at one time shall be'llmited to 50 poundsequivalent TNT.9.11.3 Explosive material shall be stored in designated areaswithin the reactor facility.9.11.3.1 Only the explosive devices, to be radiographedwithin 4 hrs. not to exceed a maximum of tenpounds equivalent TNT, may be removed from thestorage area at one time for radiographing, in-cluding preparation but excluding packagedshipments.

-9-.9.11.3.2 An accountability log shall be maintainedto show the amount of explosive materialin the reactor facility at all times, andshall contain a description of the explosive,and the location within the facility(e.g.,storage,radiographing facility, or shipping dock).9.11.4 The maximum amount of explosive material con-tained in devices that may be placed in theradiography facilities at a time shall belimited to five pounds equivalent TNT.9.11.4.1 Explosive material in the radiationfield at one time shall be limitedto 1 pound equivalent TNT.Explosive material contained inlong device(s) shall be limitedto 0.5 pound equivalent TNT perfoot.9.12 Personnel handling the explosive devices shall be trainedand familiar with the devices being radiographed.9.12.1 Personnel handling the explosive devices shall usespecial equipment, such as nonsparking-tools and shoes,protective clothing, safety shields and grounded benchesas required for the explosives being handled.9.12.2 Unshielded high frequency generating equipment shallnot be operated within 50 feet of any explosive device.9.12.3 The explosive device shall be subjected to a total ex-posure not to exceed 3 x i011 neutrons/cm2 and 3 x 103roentgens of gammas.9.12.4 Explosive devices that, upon ignition, have or providea thrust in a definite direction shall be positioned soas to be aimed away from the reactor and components.10.0 General Operating Limitations10.1 Reactor operation shall be permitted only when two or morepersonnel are in the reactor building, at least one of whomis a licensed Operator.10.2 The reactor shall not be operated wherever there are significantdefects in fuel elements, control rods or control circuitry.10.3 Upon occurrence of abnormal .operation of the reactor, including* its controls, safe tystems and auxiliary systems, actionshall be taken immediately to secure the safety of the facilityand determine the cause of the abnormal behavior.

-10-11.0 Fuel Storage and Transfer11.1 The fuel storage pits located in the floor of the reactor roomshall accommodate a maximum of 19 fuel element.s(.700 gm.U-235)instorage racks dry or flooded with water.. The fuel storage pitsshall be secured with a lock and chain except during fuel transferoperations.11.2 Additional fuel storage racks may be located in the reactor tank.Each of these storage facilities shall be so designed that for allconditions of moderation k eff shall not exceed a value of 0.8.11.3 A fuel handling. tool shall be-used in ýtransferring fuel elements oflow radioactivity between the storage pits and. the reactor; a shieldedfuel transfer cask shall be used.for:the transfer of highly radio-active fuel elements. The fuelchandling tool shall remain in a.lockedcabinet under the cognizance of the Reactor Superyisor when not author-ized formuse.11.4 All fuel transfers.mn the reactor:tank shall be conducted by a minimumstaff: ofthree any and shall include a licensed Senior Operator anda licensed Operator. The staff.members shall monitor the operationusing::appropriate radiation monitoring.instrumentation. Fueltransfers outside 'the. reactor tank but within the facility shall. besupervisedtby alicensed Operator.11.5 Not m6re than one fuel element. shall be allowed' in. the facility whichis not in storage or in the core lattice.12.0 Administrative.Requirements12.1 Organization12.1.1. The Reactor Supervisor shall have responsibility of".the.reactor facility. In all matters pertaining to reactoroperations and 'to these Technical Specifications, the ReactorSupervisor shall be responsible to the President,: Aerotest"The President, Aerotest Operations,. Inc.'shall report to the Board of Directors of Aerotest Operations,.12..1.2 The Radiological Safety Officer shall review and approve: all.procedures and experiments involving radiological safety:. Heshall' enforce rules, regulations and: procedures relating toradiological safety.,. conduct routine radiation surveys andis. responsible to the Manager, Aerotest Operations.12.1.3 The Reactor Safeguards Commit.tee shall be composed of not:less than five members, of whom no more than three aremembers of the operating organization. The committee

-11-shall meet on call of the chairman and they shall meet atleast annually. The committee shall be responsible for,but not limited to the following:12.1.3.1 Reviewing and approving nuclear safety standardsassociated with the use of the facility;12.1.3.2 Reviewing and approving all proposed experimentsand procedures and changes thereto, and modificationsto the reactor and its associated components.12.1.3.3 Determining whether proposed experiments, proceduresor modifications involve unreviewed safety questions,as defined in'10 CFR 50, Part 50.59(c), and are inaccordance with these Technical Specifications;12.1.3.4 Conducting periodic audits of procedures, reactor.operations and maintenance, equipment performance,and records;12.1.3.5 Reviewing all reported abnormal occurrences andviolations of these Technical Specifications,evaluating the cause of such events and thecorrective action taken and recommending measuresID/ to prevent reoccurrence and;12.1.3.6 Reporting their findings andrecommendations con-cerning the above to the Manager, Aerotest Operations.12.1.4 The Reactor Supervisor shall have a Bachelor's degree in Engineeringor Physical Science and shall have a minimum of 4 years experiencein the operation of a nuclear facility during which he shall havedemonstrated competence in supervision and reactor operations. Heshall hold a Senior Reactor Operator License for the facility.12.1.5 The Radiological Safety Officer shall have a Bachelor's degree inBiological or Physical Science and shall have a minimum of 2 yearsexperience in personnel and environmental radiation monitoringprograms at a nuclear facility. Certification as a Health Physicistby the Health Physics Society is acceptable in lieu of the educationand experience requirements given above.12.2 Procedures12.2.1 Detailed written procedures shall be provided and followed for thefollowing reactor operations:12.2.1.1. Normal startup, operation and shutdown of the completefacility and of all systems and components involvingnuclear safety of the facility.12.2.1.2. Refueling operations.

-12-12.2.1.3 Actions to be taken to coriect specific and foreseenpotential malfunctions of systems or components, in-eluding responses to alarms, suspected primary systemleaks and abnormal reactivity changes.12.2.1.4 Paragraph omitted.12.2.1.5 Preventive or corrective maintenance operations whichcould have an effect on the safety of the reactor.12.2.2 Temporary procedures which do not change the intent of previouslyapproved procedures may be utilized on approval by a licensedSenior Reactor Operator and one other qualified individual. Suchprocedures shall be subsequently reviewed by the Reactor Safe-guards Committee.12.3 RecordsIn addition to those records required under the facility license andapplicable regulations, the following records shall be kept when explo-sive materials are to be irradiated or radiographed:12.3.1 The type and quantity of material irradiated. .12.3.2 Date, time of day, and length of exposure.12.3.3 Total neutron and gamma exposure level.

(-..HUCIZA INSTRIUPEWNTOlNUJ,Channel Detecto.r"- Minirm= Minimu.m Range" Inforrastio; to(.!o.) 1a .i t Logic ler-_nt.. ._.._ (Scra:*).Startup " F3 4.5 counrs/see per Neutron flux, source level to Period orram;(a)(1) Proportional n/c,42-sec .period I ,att low count rateCounter scramLog H Compens'ated. 4 X 16-14 anip/fn Power level, 10-2 watts to Feriod scram(2) ion chamber cm2-sec period- 1207 full powerLinear Uncopensated 4.4 1 amp/ Po'wer level 30 watts to High end lowLevel ion chamber n/cw -sec 1207 full power. level.(b) scruosSafety -(3).Linear Compensated 4.4 x 10"14 ampi Power level * ,0-1 "watts to High and lowLevel ion chamber n/cm2-sec 120% full power level scram) Safety(4)'"3(a) Scrazm on Channel 1 are by-passed when signalhigh voltage is removed from the detector" andon Channel .2 exceeds a fixed.setting similarly thethe 'detector is shorted.(b) Low level scram ia.bypassed on Channel 3 and 4 when Channel 2 is below a fixed setting.1~~

TABLE 2SAFETY SYRTDrX FUNCTIONSRen~sor or Trin DeoviceNo. of Switcheoor Sensors-Anrnunciator andScrom.Set Pnint* "Annuncator andAlarm net PointI ~ 9 -VShort Pez~iod; Chs. 1. 2* igh. Neutron Flux' Level; Cbs. 3, 4.High Temperaturo o0: Coolant WaterLow Pool Water Lev~el, I"Selsmic Disturbance,BridSo Cirane Locatio.Lov Necutron Detector%Voltage;. Chs. 2, 3, 4Low Source' Level;, Ch. 1Losa of -Instrument Power;Ch .2. *L.ow.iVutroa Fluxi Ch. 3Area Radidtirn MonilorWater RadioactivityDemifieralizor Water Flow2.211 "31* 21"* I.*1S I.1-3 aac.I 98. of* fullscale abd notS reato.r than;1207.*futllpower130oF1Rdecreava1ft tQA,IV on modifWerMercalli Scalemax.> 500 volta2 cps-.X.57. of full'scale"* Not on OWpositionIButton.Depressed14hen located offatorage poe ition1.~0 mr/hr.'420 mr/kr.>4 gpm *S2 mr/hr.*BuildinZ Gas EffluentMonitor-Haster Key Switc-1.,Xainucal Scridc Du tton

Enclosure

3License No. R-98July 19, 2012Document Control DeskU.S. Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852-2738Aerotest Radiography and Research ReactorDocket No. 50-228Request for Withholding of Proprietary Information related to AerotestRadiography and Research ReactorLadies and Gentlemen:Pursuant to 10 CFR 2.390. Public Exemptions, Request for Withholding, AerotestOperations, Inc. (Aerotest) and Nuclear Labyrinth LLC (Nuclear Labyrinth) herebyrequest that certain information contained in their Response to Request to AerotestOperations, Inc. and Nuclear Labyrinth LLC to Supplement the License TransferApplication (the "Response") be withheld from public disclosure as such informationcontains trade secrets, commercial information, and financial information which isBusiness Proprietary.In support of our request we state the following:1. The information sought to be withheld from public disclosure are sections of theResponse to Request to Aerotest Operations, Inc. and Nuclear Labyrinth LLC toSupplement the License Transfer Application dated July 19, 2012 submitted byAerotest Operations Inc. and Nuclear Labyrinth marked as Business Confidentialincluding Attachment (1).2. The persons making this request are Michael S. Anderson of Aerotest and Dr.David M. Slaughter of Nuclear Labyrinth.3. The basis for proposing that the information be withheld from public disclosure isthat the information marked as Business Confidential contained in the Responseis confidential business and financial information of Aerotest and NuclearLabyrinth, which information has been held in confidence by Aerotest andNuclear Labyrinth, is a type customarily held in confidence, is not available inpublic sources, and if publicly disclosed would be likely to cause substantial harmto the competitive position of Aerotest and Nuclear Labyrinth taking into accountthe value of the information, the amount of effort and money expended by PROPRIETARY -TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390.Withhold from public disclosure under 10 C.F.R. § 2.390Aerotest and Nuclear Labyrinth in developing the information and the difficultlywith which the information could be acquired or duplicated by others;4, If such information were disclosed to the public, Aerotest and Nuclear Labyrinthbelieve that competitive harm would result;5, The Response has been marked to show locations of the information sought tobe withheld.2 PROPRIETARY -TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390.Withhold from public disclosure under 10 C.F.R. § 2.390Michael S. Anderson, being dully sworn, states that he is Secretary of Aerotest, that heis authorized on the part of said Company to sign and file with the U. S. NuclearRegulatory Commission this request for the Aerotest Radiography and ResearchReactor, and that all the matter and facts set forth herein are true and correct to the bestof his knowledge.Vichael S.-AndersonSecretarySubscribed and sworn to before me, a Notary Public, in and for the State of Michiganand County of Oakland, this _L. day of July 2012.Q2V Z'(Notary Public in and for theOtate of MichiganMy Commission Expires: " /CANDACE MIERZWINSIKNotary Public, State of MichiganCounty of OaklandMy Con -ssion Etpires May 26 2013Acting in the County of3 PROPRIETARY -TRADE SECRETConfidential information submitted under 10 C.F.R. § 2.390.Withhold from public disclosure under 10 C.F.R. § 2.390David M. Slaughter, PhD, being dully sworn, states that he is Chief Executive Officer,that he is authorized on the part of said Company to sign and file with the U. S. NuclearRegulatory Commission this request for Nuclear Labyrinth, and that all the matter andfacts set forth herein are true and correct to the best of his knowledge.Da id M. Slaughter, PhDChief Executive OfficerSubscribed and sworn to before me, a Notary Public, in and for the State of Utah andCounty of Salt Lake, this I1-- day of July 2012.Notary Public in and for the State of UtaMy Commission Expires:4