ML20011A787

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Responds to Citizens for Nuclear Reactor Safety Interrogatories.Affidavit,Prof Qualifications & Certificate of Svc Encl
ML20011A787
Person / Time
Site: Armed Forces Radiobiology Research Institute
Issue date: 10/30/1981
From: Bachmann R
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
CITIZENS FOR NUCLEAR REACTOR SAFETY, INC.
References
NUDOCS 8111030188
Download: ML20011A787 (25)


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10/30/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

  • 1.

Docket No. 50-170 T

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p,A ARMED FORCES RADI0 BIOLOGY RESEARCH 6

INSTITUTE (Renewal of Facili i'~e License No. R-84)f y

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  • HRC STAFF RESPONSE TO INTERROGATORIES h

N FROM CITIZENS FOR NUCLEAR REACTOR SAFETY, INC.

h pd The NRC Staff hereby responds to " interrogatories to the NRC Staff from the Citizens for Nuclear Reactor Safety, Inc." dated September 30, 1981. Although 10 C.F.R. 9 2.720(h)(2)(ii) requires that interrogatories to the Staff must be filed with the presiding officer who may require response by the Staff member designated by the Executive Director for Operations, the Staff has waived this provision for one time only by informal agreement with the Intervenor, on the condition that the inter-rogatories do not require significant expenditure of the Staff's time or resources. The Staff reserves the right to invoke the requirements of 10 C.F.R. 9 2.720(h)(2)(ii) when responding either to the second set of interrogatories or to any additional discovery which may be deemed necessary.

Except as noted, the Staff views the Intervenor's interroga-l l

tories as meeting the conditions of the informal agreement and provides its answers below.

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. Interrogatory 1 For each contention and sub-contention thereof, stipulated to by the NRC, AFRRI, and the Intervenor (" Attachment A of the Stipulation signed by said parties on March 31,1981), and for each unstipulated contention

(" Attachment 8" of said Stipultion) approved by the Atomic Safety and Licensing Board in its Memorandum and Order served September 1,1981, state what the staff's present position is (insofar as it has fonel an opinion at this stage) with respect to each such contention and sub-contention and identify all documents and studies relied upon the the staff now or in the past which serve as the basis for each position taken. Any such document shall be identified with reference to its title, author (s), any identifying serial numbers or filing numbers, the particular par',s therof which are relied upon, and the places where it is known to be available for inspection.

In lieu thereof, attach a copy of each document and study to the answer.

Staff Response As indicated in the letter from Staff Counsel to the Licensing Board dated October 14, 1981, the Staff intends to issue its Safety Evaluation Report (SER) and Environmental Impact Appraisal (EIA) the week of December 21, 1981. Until such time as these documents are issued, the Staff will be continuing its technical review of AFRRI's license renewal application.

Therefore, the Staff positions stated in this response to the interroga-tories are subject to modification by the SER and EIA.

Documents relied upon by the Staff have been identified and are generally available in the NRC Public Document Room. Those documents marked with an asterisk (*) are available for inspection and copying by contacting Staff Counsel at 492-7290.

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. Stipulated Contentions Contention 1. - Staff Position The contention is in error in two ways:

1)

The HSR does not discuss a quantitative probability for clad failure versus fuel temperature. The HSR assumes, for purposes of calculations, that the cladding of one fuel element has certainly failed.

2)

The HSR does not derive the fraction of the fission products inventory in the gap from the fuel tempera-ture.

For purposes of conservative calculations, the HSR assumes a specific fraction, which corresponds to an operating temperature (fuel) of at least 600*C.

Documents relied upon:

1.

HSR 9 6.3.2 2.

Foushee, F.C., and R. H. Peters, " Summary of TRIGA Fuel Fission Product Release Experiments," GA Report Gulf FES-A10801, Vol. II, General Atomic Company, and also S. Langer and N. L. Bald. vin,

" Fission Product Release Experiments on Uranium-Zirconium Hydride Fuels," GA Report Fulf GA-A1781, Vol. I, General Atemic Company, 1971.*

3.

Baldwin, N. L., F.C. Foushee, and J. S. Greenwood, " Fission Pro-

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duct Release from TRIGA Reactor Fuels," GA document E117-830, General Atomic Company, January 1980.*

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Foushee, F. C., Release of Rare Gas Fission Products From U-ZrH Fuel Material" GA 8597, liarch 29, 1968.*

5.

C. O. Coffer, J. R. Shoptaugh, Jr., and W. L. Whitter " Stability of U-ZrHl.7 TRIGA Fuel Subjected to Large Reactivity Insertions" GA 6874, January 1966.*

Contention 2. - Staff Position The subject of this contention and its sub-contentions is still under Staff technical review. However, the documents listed belo, are being used to determine the Staff's position.

1.

J. A. Sholtis, Jr. " Nuclear Criticality Safety Analysis of Hypothetical AFRRI TRIGA Fuel Element Storage Rack Accidents" Memorandum For Record, AFRRI Scientific Support Department, 19 January,1981.*

2.

Braser, R I. King, L. L.

P., and Mills, C. B., Application of Low Critical Mass Studies to Reactor Design," Nuclear Applica-tions, Vol. 6, p. 266, April 1969.*

3.

AEC I&E Inspection Report No.'50-170/62-2, 5/5/65 4.

NRC I&E Inspection Report No. 50-170/76-02,4/23/76.

5.

O. L. Cordes, " Comparison of Fission Product Releases From the Destructive Tests of SNAP 10A/2 Reactors," Proceedings of the First International Congress of Radiation Protection, Part 1, pp. 571-587, Peraamon Press, 1966.*

W.E.Kessler,etal.flircopium-HydrideFuelBehaviorinthe 6.

SNAPTRAN Transients Tests" Trans-Am-Nucl-Soc. 9.1, 155 (1966).*

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M. T. Simnal & J. B. Dee, "Equilibrim Dissociation Pressures and Performance of Pulsed U-ZrH Fuels at Elevated Temperatures,"

Thermodynamics of Nuclear Materials,1967; Proceedings of a Symposium, Vieina, 4-8 September, 1967.

IAEA(STI/ Pub /162).*

8.

Ulrich Merten, R. S. Stone, and W. P. Wallace " Uranium-Zirconium Hydride Fuel Elements" Nuclear Fuel Elements H. H. Hausner and J. F. Schumar, eds. Runhold Publishing Corp. New York,1960.*

9.

T. J. Thompson, " Accidents and Destructive Tests" Chapter 11 The Techonology of Nuclear Reactor Safety, Vol.1. T. J. Thompson

& J. G. Beckerly, eds. The MIT Press 1964.*

10.

J. R. Shoptaugh, Jr., " Simulated Loss-of-Coolant Accident for TRIGA Reactors" GA 6596, August 18, 1965.*

Contention 3. - Staff Position The subject of this contention is still under Staff review. The Staff currently recommends the guidance found in Regulatory Guide 2.6 (1979).

Contention 4. - Staff Position The Staff believes that AFRRI maintains its routine emissions within the limits of 10 C.F.R. Part 20. The following documents provide a history of inspections and evaluations which supports the Staff's position.

1.

AFRRI Reports to AEC/NRC a)

Environmental Release Report, Docket No. 50-170, transmitted by letter dated 12/14/71 b)

Environmental Report for the AFRRI-TRIGA Reactor License R-84, June 1981, Docket No. 50-170, transmitted by letter dated 7/13/81

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I&E Reports a)

Report No. 50-170/64-2 10/19/64 b)

Report No. 50-170/65-4 1/8/66 c)

Report No. 50-170/66-1 6/14/66 d)

Report No. 50-170/66-2 11/28/66 e)

Report No. 50-170/67-1 6/7/67 f)

Report No. 50-170/68-1 7/3/68 g)

Report Ho. 50-170/68-2 12/2/68 h)

Report No. 50-170/69-1 5/27/69 i)

Report No. 50-170/70-1 3/10/70 j)

Report No. 50-170/73-01 9/21/73 k)

Report No. 50-170/76-02 4/23/76 1)

Report No. 50-170/77-01 2/15/77 m)

Report No. 50-170/78-01 3/23/78 n)

Report No. 50-170/79-01 2/6/79 i

Contentions 5. and 6. - Staff Position As noted above, the Staff has not yet issued its EIA. Therefore, the Staff does not have a position on these contentions at this time.

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Unstipulated Contentions The Staff's positions for each of the unstipulated contentions have been previously stated in "HRC Staff's Statement of Position on Unstipu-lated Contentions of Petitioner Citizens for Nuclear Reactor Safety, Inc."

dated April 14, 1981. Therefore, for each contention the Staff lists the documents relied upon for its previously stated positions.

Contention 1.

See documents 5 and 9 listed for unstipulated Contention 2, plus 1.

L. I. Moss, et al., "Prelininary Analyses of SNAPTRAN-2 Data."

Trans. Am. Nucl. Soc. 9,1,155(1966).*

2.

International Commission on Radiological Protection.

1960.

" Report of Comittee II on Permissible Dose of Internal Radiation (1959)." Health Physics 3:11.*

3.

International commission on Radiological Protection.

1978.

" Limits for Intakes of Radionuclides by Workers."

ICRP Publication 30, Part I, Annals of the ICRP 2(3/4):88.*

4.

NURET/CR 1962. Vol. 1. K.F. Eckerman, M. R. Ford and S. B. Watton,

" Internal Dosimetry Data and Methods of ICRP-Part 2 Vol.1:

Committed Dose Equivalent and Secondary Limits February,1981.

5.

M. R. Ford, S. R. Bernard, L. T. Dillman, and S. B. Watson, Internal Dosimetry Data and Methods of ICRP-part 1, NUREG/CR 0789, 1979.

ItRP Publication 26, Afdals of the ICRP, Vol.1. No. 3, Pergamon 6.

Press, 1977.*

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L. Thomas Dillman, Absorbed Gamma Dose Rate For Immersion in a Semi-Infinite Radioactive Cloud" Health Physics, Vol. 27, 571-s' 580(1974).*

Contention 2.

Documents relied upon:

1.

Baker, L., Jr., and L. C. Just,1962.

Studies of Metal-Water Reactors at High Temperatures III Experimental and Theoretical

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Studies of the Zirconium-Water Reactor. ANL-6548.*

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2.

Baker, L., Jr., and R. C. Liimatainen.

1978.

" Chemical

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Reactions."

In Reactor Materials and Engineer:ing. Vol.1 q

of The Technoloqy of Nuclear Reactor Safety, pp. 419-523.

(T. J. Thompson & J. G. Beckerley, eds) The M.I.T. ' Press, Cambridge, Massachusetts.*

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3.

Epstein, L. F. 1960.

Reactor Safety Aspects'of Metal-Water Reactions. Metal-Water React!ons:

VII.

GEAP-3335.*

4.

J. R. Lingren and M. T. Simnod, " Low-Enriched TRIGA Fuel Water-Quench Safety Tests." Trans. Am. Nucl. Soc. 33, 276

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(1979).*

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5.

O. L. Cordes, Comparison.of Fission Product Releases From The Destructive Tests of Two SNAP 10A/2 Reactors Proceedings of the First International Congress of Radiation Protections Parti,(pp. 571-587), Pergamon Press, 1966.*

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. Contention 5.

See documents listed for unstipulated Contention 4.

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Contention 7.

Documents relied upon:

1.

Physical Security Plan for AFRRI-TRIGA Reactor Facility.

(withheld from public disclosure pursuant to 10 C.F.R. 2.790(d)).

2.

Regulatory Guide 5.59 (1980).

c Interrogatory 2 For each contention and sub-contention referred to in Question 1, identify all documents and studies, and the particular parts thereof, known to exist but not relied upon, which pertain to the subject matter of the contention or sub-contention.

In lieu thereof, attach a copy of each document and study to the Answers and identify the contention or sub-contention to which it pertains.

Staff Response The Skaff objects to this interrogatory on the basis that it is unduly burdr;nsome and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence.

Interrogatory 3 Explain whether AFRRI, the NRC Staff, or any other individual, agency,

. or organization is engaged in or intends to i+9 age in further research or studies which may affect any answers.

Identify such research or work and, to the extent possible, its projected completion date (including but not Appraisal).Jne Staff's Safety Evavation Report and Environmental Impact limited to

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. Staff Response Los Alamos National Laboratory is currently preparing 2

-hnical Evaluation Report on AFRRI under contract to the NRC Staff. This report will form the basis for the Staff's SER. The projected completion date is the end of November, 1981.

Battelle Pacific Northwest Laboratory is currently preparing a

" Generic Credible Accident Analysis for TRIGA Fueled Reactors" under contract to the NRC Staff.

It is anticipated that information from this analysis will be included in the Staff's SER. The projected completion date is unknown at this time.

As stated previously, the Staff's SER and EIA are projected to be completed the week of December 21, 1981.

Interrogatory 4 For each contention and sub-contention referred to in Question 1, identify the expert (s), if any, whom the Staff intends to have testify on the subject matter of the contention or sub-contention.

State the qualifications of each expert.

P Staff Response Tne Staff intends to provide the following individuals as a panel:

I Albert W. Blackstock Charles A. Linder l

l Dean H. Whitaker James E. Hyder Robert E. Carter l

Oonald M. Carlson Eugene F. Bates

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Copies of the professional qualifications of the witnesses are attached, with the exception of Eugene F. Bates, which will be submitted as soon as available.

Respectfully submitted, TA%tsFM Richard G. Bachmann Counsel for NRC Staff 1

1 Dated at Bethesda, liaryland this 30th day of October,1981 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket No. 50-170 1

ARMED FORCES RADI0 BIOLOGY RESEARCH

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INSTITUTE)

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(Renewal of Facility

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License No. R-84)

(TRIGA-Type Research Reactor)

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AFFIDAVIT OF ROBERT E. CARTER STATE OF MARYLAND

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COUNTY OF MONTGOMERY) SS I, Robert E. Carter, being duly sworn, depose and state:

1.

I am a Project Manager with the Standardization and Special Projects Branch, U.S. Nuclear Regulatory Comission, Washington, DC 20555.

2.

I have prepared the statement of Professional Qualifications attached to "NRC Staff Response to Intervenor's First Set of Interrogatories",

and, if called upon would testify as set forth therein.

3.

I have contributed to the responses to interrogatory numbers 1 through 4, and I hereby certify that the answers given are true and correct to the best of my knowledge.

JU Robert E. Carter Subscribed and swcen to before me this27'Aday of October, 1981

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e ALBERT W. BLACKSTOCK PROFESSIONAL QUALIFICATIONS LOS ALAMOS NATIONAL LABORATORY My name is Albert W. Blackstock.

I am a staff member in the Engineering k 41ysis Group (WX-8), Design Engineering Division, Los Alamos National L moratory.

I am participating in a team providing engineering evaluation assistance to the Nuclear Regulatory Commission related to relicensing nonpower nuclear reactors.

I received a Bachelor of Science Degree in Physics from Texas A. and M.

University in 1948, a Mastbr of Arts in Physics from Rice University in 1950, and a Doctor of Philosophy degree in Engineering Physics from North Carolina State University in 1955.

I performed the research for my Ph. D. thesis at Oak Ridge National Laboratory while I was on an Oak Ridge Institute of Nuclear Studies Graduate Fellowship.

In addition to doing graduate work at North Carolina State University, I was an Instructor in Physics there from 1950 through 1952. My graduate studies included a number of courses in Nuclear Engineering.

From 1955 to 1957, I was employed on the Aircraf t Nuclear Propulsion (ANP)

Project at General Dynamics Corp. in Fort Worth, Texas. On this project, I

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did reactor and shielding analysis and shielding experiments using the Ground Test Reactor.

I also taught a reactor engineering course to AKP project personnel.

My next employment was at the Los Alamos National Laboratory in the I 'id research and development work on Weapons Division Crom 1957 to 1959.

d nuclear. weapon components.

I also participated in the nuclear weapon tests at Eniwetok.

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From.1959 to 1962 I did research on the ORION nuclear-pulseu propulsion project at the General Atomic Corp. in San Diego, California.

I returned to the Los Alamos National Laboratory in 1962, and I was a member of the Advanced Concepts Group of the Nuclear Propulsion Division until 1973. My work included designing and conducting in-core reactor tests of nuclear-fueled thermionic converters and components, and performing heat transfer analyses. The tests were run either in the Los Alamos Omega West Reactor (0WR), where core neutron flux mapping was done, or in the EBR-II reactor in Idaho.

Before joining WX-8, I worked in the Health Physics Group at Los Alamos for 6 yr.

I made photon and neutron measurements related to mixed-field neutron dosimetry over a wide energy range using both continuous-spectra and monoenergetic neutron sources. These sources included the O'<lR, where the thermal neutron flux from the thermal column was measured. This work contributed to the design and development of the cur'ent Los Alamos TLD personnel dosimeter.

I also participated in the review of the Preliminary Safety Analysis Report for the Los Alamos Plutonium Facility, where many neutron measurements were also made.

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CHARLES A. LINDER PROFESSIONAL QUALIFICATIONS LOS ALAh0S NATIONAL LABORATORY My name is Charles A. Linder.

I am a staff member in the Support Encineering Group (WX-4), Design Engineering Division, Los Alamos National Laboratory.

I received a Bachelor of Science in Marine Engineering from the United States Merchant Marine Academy in 1952 and a Masters of Science in Mechanical' Engineering from Virginia Polytechnic Institute (VPI) in 1956. After teaching mechanical engineering cour'ses at VPI, I joined the los Alamos National Labcratory as a staff member in late 1956.

My initial assignment was with the nuclear rocket propulsion program.

From 1956 to 1958 I designed and conducted high temperature heat transfer experiments. From 1958 through 1962 I was in charge of instrumenting and assembling test reactors at the AEC Nevada Test Site. From 1962 through 1971 I was in charge of the reactor component test program.

In 1971 I joined Group WX-4 and from then until the present I have worked as project engineer on such projects as accelerator beam diagnostic sensor design, explosive containment vessel and pressure vessel design and on a program in support of the Nuclear Regulatory Commission that concerned the physical security of US Nuclear Power Plants.

I am a registered professional engineer in the State of New Mexico.

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DEAN H. WHITAKER PROFESSIONAL QUALIFICATIONS My name is Dean H. Whitaker.

I am an engineer in the Engineering Analysis Group (WX-8), Design Engineering Division, Los Alamos Natienal Laboratory.

I am now involved in providing technical assistance to the Nuclear Regulatory Conunission (NRC) in the relicensing of nonpower nuclear reactors.

I received a Bachelor of Science Degree in Physics from the University of Texas at El Paso (UTEP) in 1963 and attended graduate school at UTEP in 1964.

During this period I also worked as a research assistant at the Schellenger Research Laboratory at UTEP, where I was involved in Upper Altitude Atmospheric studies.

From April 1965 until April 1966, I was a Tooling and Production Planning Engineer.for. the Boeing Co., Seattle, Washington. My duties included developing new manuf acturing techniques and methods for aerospace applications.

From May 1%6 until October 1966, I was involved in the Design and Installation of Flight-Test Instrumentation for the F-111 Aircraf t.

My

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employer was VOLT Technical Corp. under contract to General Dynamics, Ft. Worth, Texas.

From October 1%6 until March 1967, I was employed by the UNIDYNAMICS Corp., Phoenix, Arizona. My duties included applied research in primary explosives and the design and fabrication of various explosive devices for aerospace and military applications.

From April 1967 until July 1975, I was employed by several different technical service contractors at the White Sands Test Facility near Las Cruces, New Mexico. My duties ranged from Materials Test Engineer to supervisor of the Systems and Materials Evaluation l

Laboratory. Technical experience gained during this time inc~uded vibration / shock testing (sinusoidal and' random), high pressure gas system design and analysis, high " vacuum, system design, environmental testing, hazardous material handling and safety, cryogenics systems design, class-100 cleanroom design and operation, complex

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WX-8-4324 August 12,1981 instrumentation system design and operation, plastics technology, spacecraf t component testing, flight simulation, and spark-gap studies.

In addition, I gained personnel management and supervision experience.

From July 1975 until June 1977, I was a design and development engineer in the Energy Storage Systems Oroup (CTR-9), Controlled Thermonuclear Research Division, Los Alamos National Laboratory. My

o. 'ies included development of cryogenic energy storage systems including superconducting coils and high-current, high-voltage switching systems.

From July 1977 until the present, I have been involved with assisting the Nuclear Regulatory Commission in various tasks including providing technicaliassistance in the implementation of the physical security upgrading of nuclear power plants (10 CFR 73:55) and the evaluation of nuclear power plant emergency planning, guard training programs, and instrumentation systems.

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PROFESSIONI.L' QUALIFICATIONS JAMES E. HYDER fly name is James E. Hyder.

I am a staff member in the Engineering Analysis Group (WX-8), Design Engineering Division, the Los Alamos National Laboratory.

I am a member of the team conducting the re-licensing review of nonpower resea.-ch and test reactors for-the Nuclear Regulatory Commission (NP.C).

I am a Certified Health Physicist with over 20 yr of radiation-safety experience.

My formal technical education consists of a Bachelor of Arts Degree in Physics from Berea College in 1955 and a Master of Science Degree in Physics from Vanderbilt University in 1957. Additionally, I have had courses in mathematics and chemistry at Florida State University and industrial hygiene,. occupational health, and environmental pollution and control at the University of Pittsburgh.

I was awarded a US Atomic Energy Comission Radiological Physics Fellowship in 1955 by the Oak Ridge Institute of Nuclear Studies. This fellowship included special courses in Radiologica Physics at Vanderbilt University and a 3-month internship with the Applied Health Physics Division at the Oak Ridge National Laboratory.

From April 1957 through September 1957, I was employed as a Radiation Analyst by the Atomic Energy Comission (AEC), Division df Civilian Application. My duties were to evaluate license applicants' qualifications, equipment, facilities, and proposed procedures to insure that the applicant was qualified to use specified quantities of radioisotopes and was unlikely to endanger the health and safety of the employees or general public.

From the fall of 1957 through 1960, I was employed as the Radiological Safety Officer for the Nuclear Science Program at Florida State University.

I established a University-wide Radiation Safety i

Program,pbtained a University *Eroad License for radioisotope research, and developed the radiation safety procedures for the installation and routine operation of the Electron and Tandem Van de Graaff Accelerators. During this period I also served on the Radiological Safety Comittee of the Florida Nuclear Development Comission and on 4.

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6 Professional Qualifications 1 James E. Hyder the Safety Engineering Advisory Comittee of the Florida Industrial Comission.

From early 1961 until late 1963, I was the Chief Health Physicist at the University of Pittsburgh.

I supervised the Radiation Safety Program for the University (including the medical school and its re-lated research programs), the 16 MeV Deuteron Cyclotron, and the plans for the construction and operation of a Tandem Van de Graaff Accelerator.

I also served as a member of the University Radiation Safety Comittee and its Subcomittee on Human Use of Radioisotopes.

I assisted in the Radiation Safety Programs at the Children's Hospital, the University-Presbyterian Hospital, and the Magee Women's Hospital.

I also guided the program for the Carnegie Institute of Technology.

I was employed as a Radiation Specialist by the AEC, Directorate of Regulatory Operations (formerly the Division of Compliance) from 1963 until 1973. My duty stations were Region I, New York (1963--1966) and Region IV, Denver (1966--1973). My assignment was to inspect the radiation safety aspects of all types of comission lice sees, includ-ing nuclear reactors.

I provided on-site reviews and ana ysis of radiatior-related accidents involving personnel overexposures or body uptakes,1arge releases of radioactive material to the environment,.and the consequences of unusual events (such as fires or floods) that would affect the licensees' f acilities. From 1970 through 1972, I was assigned half-time to Region III, Glen Ellyn, Illinois, to perform

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radiation safety inspections of nuclear power reactors and assist in training new inspectors for that office.

I became a staff member in the Health Physics Group (H-1), Health Research Division, at the Los Alamos National Laboratory in January 1975. Although my duties have varied, all have been radiation-safety related. My principal assignments have included the following.

1.

Januar"y 1975--May 1975.

I was assigned to the Los Alamos Meson Physics Facility (LAMPF), a proton accelerator.

I assessed the LAMPF liquid, radioactive waste (primarily tritiated water)

Professional Qualifications James E. Hyder generation and potential disposal alternatives, including esti-mating population dose connitments.

2.

Api ~~ 1975--September 1975.

I was the Los Alamos Radiation Safety Rep esentative for the weapons-related testing program at the Nevada Test Site.

This assignment was erith the Field Health Physics Section of Group H-1.

3.

October 1975--May 1977.

I had dual half-time assignments in the Radiological Engineering Section.

I assisted in the radiation safety review for the design of the Los Alamos High-Energy Gas Laser Facility (Laser Fusion Research) and coordinated the writing of the Preliminary Safety Analysis Report for that program.

At the same time, I participated in the Regulatory Technical Service Program under a contract with the NRC for safety reviews of plutonium oxide conversion and mixed oxide fuel fabrication f acilities. The team reviewed license applications and related documents, visited sites, and held discussions with the applicant's staff to insure that the facility and its proposed activities would conform to NRC regulations and applicable regulatory guides.

The review included preparing Safety Evaluation and Environmental Assessment Reports.

4.

April 1977--May 1981.

During this time, I was the supervisor of the Reactor and Laser Section, Area Health Physics.

I directed the work of 10--12 technicians in routine health physics support for numerous Los Alamos programs (including a research reactor, numer-ous critical assemblies, several accelerator programs, and all laser-related research).

I investigated unusual personnel expo-sures, releases of radioactive material, and other nonroutine events to determine their cayses and establish methods to limit their effects and minimize the pdisibility of their recurrence.

I also reviewed and approved operating procedures for Los Alamos groups that pj)tentially used or produced radiation.

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Professional Qualifications James E. Hyder In June 1981, I transferred to the los Alamos Engineering Analysis Group (WX-8) to assist in the relicensing review of nonpower research and test reactors under a contract with the NRC. This is a team review of license applications, SARs, proposed Technical Specifications, and related documents.

This review includes site visits and discussions with license applicant's staff to determine that the facility and the proposed activities will conform with the NRC's regulations and the applicable Regulatory Guides, as well as with existing industry stan-dards and practices. This involves assisting in the preparation of Safety Evaluation Reports, which are required before licensing deci-sions concerning such facilities are made. The areas of the reviews that are my responsibility include Radiation Protection Programs and their implementation, Radwaste Management and Effluent Monitoring, Accident Analysis, and Environmental Monitoring.

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ROBERT E. CARTER PROFESSIONAL QUALIFICATIONS I am a Project Manager in the Standardization and Special Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation of the U. S.

Nuclear Regulatory Commission.

I have been employed by the Nuclear Regu-latory Commission since May 1980. My principal duties and responsibilities are to review design and operating characteristics of non-power research and testing nuclear reactors that are associated with construction permits and operating licenses, and amendments to these, to assure that assigned reactors are operated safely and do not endanger the public or the environ-ment. Additionally, I am frequently assigned special technical projects which concern generic questions related to non-power reactors.

Reactors assigned to me include examples of nearly all fuel types and power levels licensed by NRC.

I received a Bachelor of Science Degree in Physics from Washington College (Chestertown, Maryland) in 1942.

During 1942-1943 I studied Phy:ic3 in the graduate school of Pur Jniversity.

During 1946-1948 I was a graduate studant at Univer.

/ of Illinois (Urbana), receiving a Masters Degree in Physics in 1947.

I have completed many short courses and special training programs, mostly related to Physics, Mathematics, or computers.

In 1942-1943, at Purdue University, I was employed part-time as both an instructor and a research assistant. The latter position was in a project which was a part of the U. S. Nuclear Weapon's program.

During 1943-1945, I was employed as a staff member at the Los Alamos, New Mexico scientific laboratory. My initial principal duties and accomplishments were to participate in the design, construction, and testing of the first homogeneous, enriched-uranium, nuclear reactor.

During the second year I participated in the design, construction, and operation of a higher power level version of the same type of reactor, and participated in many physics-type experiments using the radiations produced.

From 1948-1963, I was egain employed as a staff member in the research reactor group of the Physics Division of Los Alamos Scientific Laboratory.

Although my principal functions and interests were in radiation physics research, I participated in the design, construction, testing, and operation of a third homogeneous research reactor, and a higher powered heterogeneous research reactor.

In addition to doing radiation physics research, I helped initiate a program in neutron radiation biology.

For several years, I was a qualified sugervisory operator of both research reactors, and was the only person on(the Safety Review Committees of both reactors simultaneously.

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1 From 1956-1963, I was an instructor of Nuclear Physics and of Nuclear Engineering in the joint University of New Mexico /Los Alamos Scientific Laboratory Graduate School Program.

During 1959 through 1963 I was a part-time consultant-on-loan to the Walter Reed Army Institute for Research, in their acquisition and start-up of a homogeneous research reactor.

I was chairman of their Safety Review Committee for several' years, starting in 1964.

From 1963-1975, I was chairman, Physical Sciences Department, Armed Forces Radiobiology Research Institute, Bethesda, Maryland. My duties and functions were, to perform scientific research related to the radiation biology mission of the Defense Nuclecr Agency, and to specify, acquire, calibrate, and operate radiation sources essential to the radiation biology mission.

I managed the operations of a TRIGA research reactor, and put into operation a high performance electron linear accelerator, a cobalt-60 irradiato., and an electro-magnetic pulse irradiator.

I acquired and managed advanced-design computing facilities for the Institute.

From 1976-1980, I was employed by the Institute for Resource Manage-ment, Inc., as tM Head, Reactor Sciences Division. My duties and functions included initiating, developing bids and proposals, and implementing technical projects. Most were related to research reactors, seme were related to nuclear power reactors, and some were related to non-radiation technical questions. Among principal functions were international relations, and technical sies promotion of a line of research reactors based on the use of PULSTAR fuel.

Among other accomplishments, I head 'd up the installation, fuel-loadim, and start-up of a Mark I TRIGA Reactor in 1976-1977.

Over the years, I have maintained membership in several professional societies, and served or. 'crious committees. Among the latter, during 1964-1968, I was a member of a National Academy of Sciences / National Research Council sub-committee on Research Reactors.

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PROFESSIONAL QUALIFICATIONS DOMALD M. CARLSON fly name is Donald M. Carlson.

I am a Plant Protection Analyst in the Physical Security Licensing Branch, Division of Safeguards, Office of Nucler flaterials Safety and Safeguards, U.S. Nuclear Regulatory Com-ni<sion(NRC).

I am responsible for reviewing and assessing the adequacy o' licensee security programs designed to protect-reactor and fuel cycle acilities against theft er diversion of special nuclear material (SNM).

In conjunction with this, I prepare NRC license amendments regarding the protection of various qucntities and types of SNM used and/or stored at these facilities.

I am also responsible for evaluating NRC inspection reports to determine if JRC regulations and license conditions are per-forming their intended safeguards functions.

I am currently participating as a member of the American Nuclear Society 15.14 (Physical Security o.

Research Reactors) working group.

I have represented the NRC at nonpower reactor conferences for the purposes of discussing NRC licensing programs and policies.

Prior to my current position, I was a Reactor Safeguards Analyst with the Reactor Safeguards Development Branch, Division of Operating Raactors, Office of Nuclear Reactor Regulation, NRC.

I was primarily responsible for reviewing and atsessing the adequacy of nonpower reactor licensee security programs.

I was also responsible for identifying and suggesting research and development programs for improving physical protection pro-grams; assisting in the conduct and coordination of in-depth safeguards research and technical assistance programs; recommending and participating in the developnunt of standards and criteria for the physical protection i

of licensed facilities; developing guidance to establish explicit and uni-form acceptance criteria for plant security; and drafting and reviewing guidance developed to implement new reactor safeguards i'qulations and requirements.

l Subsequent to the above position I was a Physical Security Specialist with l

the Security and Investigation Section of the Safeguards Branch, Region III, Office of Inspection and Enforcement; NRC.

I implemented the NRC's security l

inspection program relating to the protection of SNil and facilities.

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was responsible for independently reviewing and assessing licensee _ security programs and procedures to determine their conformance with applicable physical protection regulations and requirerents.

I also conducted special security related investigations.

Sefore empleyment with the NRC (then galled the AEC) I was employed by the United Stajes Property and Fiscal Office of the Illinois Army National Guard as a Battery Commander of a nuclear capable missile firing unit. As l

such, I~ supervised all operational and administrative activities of the l

unit, to include sepervision of site security measures required to insure a safe and secure environment for nuclear weapons.

l Collectively, I have eighteen years of professional experience in nuclear

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related safeguards.

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UNITED STATES OF AMERICA flVCLEAR REGULATORY C0ftMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Dacket No. 50-170 ARMED FORCES RADIOS 10 LOGY RESEARCH

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INSTITUTE

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(Renewal of Facility

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License No. R-34)

(TRIGA-Type ; search Reactor)

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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO INTERR0GATORIES FROM CIT?

NS FOR NUCLEAR REACTOR SAFETY, INC." in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regula-tory Conmission's internal mail system, this 30th day of October, 1981:

Louis J. Carter, Esq., Chairman lis. Elizabeth B. Entwisle Administrative Judge 8118 Hartford Avenue Atomic Safety and Licensing Board Silver Spring,11D 20910 2'l Wiltshire Road Philadelphia, PA 19151 Atomic Safety and Licensing Board Panel

  • Mr. Ernest E. Hill U.S. Nuclear Regulatory Comission Administrative Judge Washington, DC 20555 Lawrence Livermore Laboratory University of California Atonic Safety and Licensing Appeal P.O. Box 808, L-123 Panel (5)*

Livermore, CA 94550 U.S. Nuclear Regulatory Commission Washington, DC 20555 '

Dr. David R. Schink Administrative Judge Docketing and Service Section*

Department of Oceanography Office of the Secretary Texas A&M University U.S. Nuclear Regulatory Comission College Station, TX 77840 Washington, DC 20555 Mr. Robert L. Brittigan, Esq.

General Counsel Defense Nuclear Agency Washington, DC-20305

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M7ronKfman Counsel for NRC Staff

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