ML20035G137

Decontamination Plan for Interior of Plainville,Ma Plant of Engelhard Corp

ML20035G137
Person / Time
Site:	07000139
Issue date:	04/30/1993
From:	Berlin R, Duggan W AFFILIATION NOT ASSIGNED
To:
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ML20035G136	List: ML20035G135 ML20035G137
References
PROC-930430, NUDOCS 9304260204
Download: ML20035G137 (53)

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{{#Wiki_filter:... i l 'O i l f I i I i t l DECONTAMINATION PLAN r FOR INTERIOR OF PIAINVIII F, MASSACHUSETTS I PLANT OF ENGELHARD CORPORATION } .j Prepared for: Engelhard Corporation { Route 152 Plainville, Massachusetts 02762 k i Prepared by l Robert E. Berlin, D.P.H. 1 William Duggan Ph.D. i April,1993 O f39 KO i PDR

i f i l t TABLE OF CONTENTS Sectiog Page Number 1.0 Introduction .........................................1 t r i 2.0 Relevant Plant Operational History......................... 3 3.0 Plant Area to be Evaluated for Decontamination............... 5 3.1 Survey Results..................................... 5 3.2 Potential Plant Locations to be Decontaminated............ 10 i 4.0 Cleanup Criteria.....................................12 5.0 Decontamination Work Scope........................... 14 t 6.0 Organization and Responsibilities.......................... 18 7.0 Sample Analysis...................................... 20 8.0 Health and Safety. -................................... 21 9.0 Quality Assurance Plan................................ 24 10.0. Documentation and Reports............................. 27 11.0 Disposal of Decontaminated Waste........................ 29 l References 30 Appendix A - Resum es................................. 40 i

TABLE OF FIGURES O Figure Pace Number 1 i 2-1 Plainville Facility Site Plan.............................. 31 2-2 Factory Building Floor Area Where Survey Was Conducted...................... 32 3-1 Grid Locations....................................... 33 3-2 Surface Wipe Test Locations ............................34 3-3 Location of Air and Particle Samples...................... 35 3-4 The Designation of Affected and Unaffected Areas............ 36 O TABLE OF TABLES l Table Page Number 2.1 Locations of Surface Wipes Taken On 7/14-7/15/88............ 37 O 1 l

i I I l.0 INTRODUCTION j This decontamination plan (the " Plan") covers the anticipated program for revisiting the radiological decontamination of interior walls and floors at the Engelhard i Corporation's Plant on Route 152 in Plainville, Massachusetts. A separate plan has been j 4 i developed for the radiological characterization of the exterior regions of the site. This i 1 f facility was formerly operated by the D.E. Makepeace Division of Engelhard Industries, Inc. l 1 i for the fabrication of nuclear fuel elements under U. S. Atomic Energy Commission (AEC) licenses SNM-185 and SUB-172 from 1957 until the licenses were terminated. License termination occurred after nuclear operations ceased in 1962, a decontamination program l l was conducted by Engelhard, and the AEC validated that the residual contamination levels i and exposure levels in the building interior were within then-established regulatory limits. [ O The unai radiaesicai -ey (a-1 survey) a me fac e y aner e i decontamination was submitted to the AEC on June 27, 1963 as part of a request to ] terminate the licenses (Weiss-1963). Based on an AEC Division of Compliance close-out mspectmn, validation that residual levels were within the specified limits, a recommendation i l i by AEC Compliance personnel that the licenses be terminated (Lorenz-1963), and concurrence by the Source and Special Nuclear Materials Branch (Lane-1963) of this 7 i recommendation, Engelhard was notified that no future facility license would be required (Director-1963). i 5 A radiation survey of the Plainville facility conducted in July,1988, however, { showed that the gamma radiation levels in certain areas of the plant ~ -ilding were elevated based on current exposure criteria. Alpha radiation measures of surface wipes and, O 4 -,--e,w= 1

2 subsequently, of strippable coatings confirmed that the surfaces and recesses (cracks, t grooves) contained material that could have produced the elevated gamma levels. The results of this measurement program are described in Section 2.0. Engelhard proposes to perform additional decontamination of the facility interior as described in this Plan, to assure that the residual surface contamination levels conform with current regulatory standards (see Section 3.0) and achieve as low as reasonably achievable exposure levels (ALARA). After acceptable residual levels have been validated by a final sumy, the Nuclear Regulatory Commission (NRC) will be requested to confirm i these levels and document the successful final completion of decontamination. t O i F O i

l l i i l l 3 l 2.0 ' ELEVANT PLANT OPERATIONAL IIISTORY Makepeace, piedecessor of the currert Engelhard Corporation, manufactured nuclear fuel elements at its plant on Route 152 in Plainville, Massachusetts from 1957 until cessation of operations in 1962. Manufacturing operations involved the use or c W uranium, enriched uranium, and depleted uranium. Figure 2-1 is a current site plan of the facility, with the portion of the plant used for nuclear fuel fabrication in the 1957-62 period shown in relation to the remainder of the plant and exterior grounds. Fuel element fabrication operations were totally segregated from the non-nuclear manufacturing and l other operations. The interior layout of buildings 1 and 2, which were the only buildings existing at the time of nuclear fuel fabrication, is shown in figure 2-2. The building interior and O esuigment used in the feei febricatioe everations were deeeetemineied and a iinai l radiological survey performed by Engelhard Industries in 1963 (Weiss-1963). Based on the results of this survey and a confirmatoly sursey conducted of the building interior and equipment by the AEC (Lorenz-1963), the facility license was terminated (Director-1963). The decontaminated equipment had been removed from the plant and sold to the Italian government. Subsequently, the area used for nuclear fabrication was converted to other non-nuclear metal fabrication operations. A radiation survey was conducted of the plant building in July,1988 as a part of a multi-phase site assessment initiated by Engelhard Corporation to identify areas of environmental concern. The results of this survey have provided the basis for the development of the proposed interior decontamination program. O

4 Based on a review of historical documentation, the interior areas of the plant in which the nuclear material was handled and processed were delineated, and became the principal locations for the radiation survey. In addition, the contaminants of concern were clearly identified as U238, U235, and U234. 1 I O l l l O

i I a l 5 l O i 3.0 PIANT AREAS TO BE EVALUATED FOR DECONTAMINATION i 31 Survey Results A radiation survey was conducted in July,1988 of the interior of buildings i No.1 and 2 (as shown in the layout drawing of Figure 2-2). The purpose of the I survey was to obtain rapid gross measurements in these potentially contaminated I areas of the plant and pinpoint those locations, if any, where above background gamma and/or alpha levels would be present. This combined scoping and characterization survey involved an initial screening of the building interior and j a follow-up, more detailed assessment oflocations where hot spots were identified. The interior areas initially surveyed were identifie.d by a review of historical information and confirmed by plant personnel as those areas believed to have O been nsed in the fermer euciear fee > grecessins activities. These areas ceneisted of: l i 1. Basement area under north end of building No.1; surveyed on a 10 ft. x 10 t j ft. grid (where unobstructed by equipment), with follow-up measurement in f l t the region of exhaust fan filters. 2. Metal stairs leading from the basement to the upper floor. i i 3. Open factory floor area of building No.1; initially surveyed on a 10 ft. x 10 l ft. grid, and subsequen?y on a 20 ft. x 20 ft grid (where unobstructed by equipment). l 4. Partitioned offices, laboratories and work areas generally around periphery of building surrounding open Door area along east side of buildings Nos.1 O. l

6 10 j and 2. Measurements were taken at selected locations (doorway, corners, walkways) where contamination might preferentially collect. More extensive mapping was made of areas showing instrument readings above background. 5. " Tunnel" ramp area at south end of building. 6. In the south and north parking lots and adjacent wooded areas remote from the plant to establish background levels. The radiological survey included the following components: The plant areas surveyed were examined for access and condition. Plant personnel provided a description of operations conducted at each location. A reference grid was established using markers at the grid block corner. A = 10' x 10' grid wa, initially used over the entire floor in the nuclear fabrication area. In regions where radiation levels were uniformly at background, a 20' by 20' grid was subsequently used (See Figure 3-1). Ambient gamma levels were measured at 5xed points at the intersection of the grid blocks at three feet above the surface in open Door areas and of selected locations in partitioned rooms shown in Figure 2-2. A recently calibrated Victoreen 290 meter was used. Areas within the grid blocks, wall surfaces, and equipment were concurrently scanned by the operator by 1 ,oving the instrument over the surface at a slow speed. Surface alpha activity was measured at the same locatioirs as the gamma measurements on, or close to, the surface. A Victoreen 290 meter with alpha probe 489-60 was used.

7 Locations showing -ither elevated (above background) gamma and/or alpha readings were noted for further evaluation and potential decontamination. Surface wipes (smears) were taken in areas that might have been particularly susceptible to past deposition and collection of particulates and from locations at which the gamma and alpha surveys showed elevated readings 2 (See Table 2.1 and Figure 3-2). An area of approximately 100 cm was wiped using a dry filter paper to obtain each smear. Airborne particulates were collected on a filter using a Hi-Vol air pump operated for approximately 30 minutes at breathing zone height in a number of selected locations in the building (See Figure 3-3). The filters were subsequently read for alpha, beta and gamma activity. O ne wiges and fiiters were individueiiy gectased in siessene m>veieges, labeled, recorded, and sent to the Material Leak Test Center in New York (an NRC licensed laboratory) to be read. The results reported by the laboratory were recorded, and a report was prepared. The material in the report is summarized in this decontamination plan. All measurements (instrument, wipes, air tilters) showed essentially background gross radiation levels in all areas surveyed with the exception of the locations described below. Background gamma levels measured in the external plant locations ranged between 18-22 pr/hr. Interior background surface alpha 2 levels were approximately 20 dpm/100 cm, j O i

The Scrap Melt Room and Adiacent Corridor Area (Building No. 2) The gamma survey results showed elevated radiation levels over a wide range of the Door in this area with readings of up to a maximum value of 110 r/hr and an average of 83 r/hr over the Door area. The alpha survey and the surface 2 wipes confirmed somewhat elevated levels, up to 40 dpm/100 cm, at these locations. The air filters collected at breathing zone heights did not show any alpha or beta / gamma levels above background. It was therefore concluded that minor radiological contamination exists in this area, most likely in the form of particulates that have become embedded in the surface of the floor and that have adhered to the lower region of the walls in certain locations. The floor appears to have a relatively thick layer of dirt and grease which had been built up over an extended period and holds particulates tracked into the area. The Room to the Immediate North of the Scrap Melt Room (Building No. 2) Neither the gamma or alpha survey showed any readings in this area above background levels, either at the bottom level or on the metal platform or stairs. However, one Door wipe and the duplicate at the same location, read at the 2 slightly elevated level, up to 40 dpm/100 cm, It is likely that some of the fugitive dust has been tracked from the adjacent scrap melt room and corridor area to this room and became imbedded in the l surface dirt and grease in individual spots. The floor surface shows the same long-term buildup of dirt. ~

9 The Precious Metal Storare Area (Vault) (Buildine No. 2) The gamma survey results showed elevated radiation levels over a wide range of the floor in the precious metal storage area with the highest readings obtained at the back of the room at and beyond the mesh wire fencing which is normally inaccessible to plant workers. The maximum reading was 114 gr/hr, and the average was 38 gr/hr over the floor area. The alpha survey and surface wipes 2 confirmed slightly elevated levels, up to 40 dpm/100 cm, at these locations. Minor radiological sources (hot spots) exist across the entire floor area with the highest concentration in the collected dirt and residue beyond the fence at the back of the room. The floor has the same appearance as in the scrap melt room, dirt and grease covered, in which particles containing radioactivity have apparently become embedded in the surface dirt. The Tunnel Ramp at the Wall Near the Capped Pipes (Building No. 2) The gamma survey results showed elevated radiation levels adjacent to and above four of the capped pipes on the inner (north) wall of the ramp with a maximum level of 100 gr/hr measured at the second pipe from the top of the ramp. Neither the i ha survey or the analysis of surface wipes at these locations confirmed the existence of a radiological source, since these results were essentially at background levels. l The Region Adiacent to the Filters on the Fans in the Basement (Building No.1)

10 Gamma survey readings taken in the basement at the north end of the building showed elevated levels only adjacent to the filtered side of the bank of fans. These levels ranged up to a maximum reading of 75 pr/hr and averaged 61 gr/hr across the entire face of the filters. However, none of the alpha survey results in the basement, including those at the fan or filter, were elevated. The surface wipes taken on the filter grid and a sample of material collected from the filters also showed r sentially background levels. It was concluded that the gross gamma survey results were not representative and were likely reflecting the presence of electrical equipment. 3J Potential Plant Locations to be Decontaminated Based on the results of the survey described in Section 3.1, it is anticipated that selective decontamination of floor areas, including recesses in the concrete, cracks and regions around pipe penetrations and lag bolts, and of the lower regions of walls will be required in the following interior plant locations: The former scrap melt room and adjacent corridor area in building No. 2. The former precious metal storage area in building No. 2. The room to the immediate north of the scrap melt room in building No. 2. In addition, it is possible that localized accumulations of material will have to be removed from grooves in the tunnel ramp at the wall near the capped pipes in building No. 2. The plant area encompassing these locations has been thus designated as the

11 "affected area" for the building decontamination program. The remainder of the building will therefore be considered to be " unaffected" and is not expected to contain residual radioactivity. The affected and unaffected areas are shown on Figure 3-4. A follow-up detailed Characterization Survey of the affected areas and adjacent locations will be conducted by the selected decontamination contractor to verify the above described results and pinpoint locations to be decontaminated before the program starts. In addition, a Remediation Control Survey will be conducted to assess the ongoing effectiveness of the decontamination effort and a Final Status Survey will be conducted after decontamination is completed to validate that the plant interior meets residual contamination standards (See O Sectiees o eed sm. 1 O

l 12 4.0 CLEANUP CRITERLi Engelhard proposes to decontaminate the plant building surfaces, including recesses and penetrations to achieve acceptable residual surface contamination levels. The surface contamination levels to be used as guidelines will be those specified by the NRC in " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Byproduct, Source or Special Nuclear Material" (NRC-1987) as they apply to UNAT., U235, and U238 and associated decay products. These residual surface activity guidelines are: 2 2 Average (over 1 m ) - 5,000 dpm/100 cm j 2 Maximum - 15,000 dpm/100 cm Removable - 1,000 dpm/100 cm 2 While these guidelines represent the upper limit, the decontamination program will emphasize achieving residual contamination levels that are ALARA considering existing i technical and economic constraints. The decontamination program will also provide a level of protection to the public and future onsite non-nuclear workers consistent with current radiation exposure guidelines and with the objective of achieving ALARA exposure levels. The objective of the decontamination program will be to achieve the NRC specified in-plant exposure rates of less than 5 pr/hr (abc /e background) as measured 1 meter from the floor and lower wall 2 surfaces and averaged over floor areas not to exceed about 10 m as set forth in the draft " Manual for Conducting Radiological Surveys in Support of License Termination." (" Draft Manual") (ORAU-1992). It is anticipated that the demonstrated performance of the plant decontamination O

13 in accordance with this Plan and the incorporated cleanup levels, as concurred in by the NRC, will result in Engelhard's release by the Commission from any further obligation to the NRC now or at anytime in the future to conduct additional cleanups. 1 1 I O i O

14 5.0 DECONTAMINATION WORK SCOPE The objective of the interior decontamination program of the Plainville facility is to achieve levels that meet current NRC residual radioactive contamination guidelines and result in exposure levels that permit unrestricted building occupancy by non-nuclear workers as defined in Section 4.0. To achieve this objective, a qualified decontamination contractor will be selected to perform a phased work scope. The selected contractor will provide, as part of this proposal, a work plan describing the tasks to be performed, schedule, instrumentation and equipment to be used, residual contamination standards to be met, health and safety precautions to be taken to maintain worker exposure at ALARA levels, QA/QC standards and procedures, and steps to be used to minimize the generation of contaminated waste. AV The program to be performed is intended to follow the procedural steps and achieve the objectives defined in the Draft Manual. The following program will be performed:

1) A Scanning Survey of the designated affected area (100% of surface) and unaffected area (10% of surface) will be conducted to pinpoint any locations of elevated activity. At suspected affected area locations, direct measurement oi alpha and beta-gamma surface activity will be performed on a pre-established grid.

i l A minimum of 30 random measurements will also be performed in the designated l unaffected plant survey units. Smean will be collected at each measuremeni location. Swabs or strippable gel coatings will be used to collect samples from small penetrations. The smears, swabs, and coatings will be packaged and sent to O 1

15 a licensed laboratory facility for analysis. Gamma exposure rates will be measured at 1 meter from floor surfaces. The results of these building surveys will be recorded on appropriate forms and the contractor, in consultation with Engelhard, will interpret the results to establish those locaLons requiring decontamination. The affected area designation will be re-evaluated based on the results of the surveys and revised if necessary. Instrument selection for the surveys will be consistent with the recommendations in the Draft Manual. 2) Background radiation levels will be validated in the plant building interior, at locations other than in buildings 1 and 2, where no licensed nuclear operations were performed. Statistically significant background levels will be established. 3) All identified elevated areas will then be decontaminated as follows: O teese dirt wiii be ceiiected by sweegins andrer vaceumies. Locations characterized by surface accumulations ofimbedded dirt and grease will be scraped and/or subjected to other surface treatment techniques in a manner that removes the contamination while minimizing waste generation. More aggressive techniques will be used (as necessary) to remove material collected in recesses and cracks, around floor penetrations and lag bolts, and around buried piping. This will include strippable coatings, scabbling, and core drilling individually or in combination. Strippable coatings will be initially applied to shallow recesses and cracks to remove imbedded dirt. Scabbling and core drilling will be employed if contamination remains inaccessible or if the surface concrete is contaminated. fJ ~ _.

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4) The effectiveness of each phase of the decontamination effort (described in (3) above) in reducing residual radioactivity to within guideline levels will be monitored as the decontamination proceeds by performing an ongoing Radiation i

Control Survey. This Survey, which will guide the extent and phases of decontamination and assure that the remediation workers and the public are protected against excessive exposure, will use direct radiation exposure from the surface as the parameter for making in-operation determinations that guideline values have been attained. 5) Upon determination that residual contamination levels have been reduced to within guideline levels, a Final Sta+us (termination) Survey will be conducted. The Final Status Survey will demonstrate that total surface activity, removable activity, O aed exgesure rete are within the suideitee vaiues (See Section 4.03 The methodology used to conduct the Final Status Survey will be consistent with the 1 approach described in (1) above and with the procedures described in the Draft Manual for building interiors. The Survey methodology and results will be documented, and a report prepared incorporating the results of the Survey (See Section 10.0 for a discussion of the report contents) and relevant data from the prior Scoping, Characterization, and Control Surveys. 6) The fm' al status (termination) survey report will then be submitted to the NRC with a request that the plant building be released for unrestricted use. If the NRC requests that the Oak Ridge Associated Universities (ORAU) (or other contractor) perform a confirmatory survey to validate the adequacy and accuracy j O )

_ = _ _ _ 17 of the Final Status Survey, Engelhard will provide access and assistance to ORAU to perform their survey.' 7) As decontamination proceeds, the waste generated will be collected, and samples analyzed for gross activity and total uranium. TCLP analyses will be performed on representative samples of the decontamination waste. Liquid wastes will be solidified and packaged for offsite disposal. Disposition of waste will be a function of whether it is a radioactive or mixed waste l l lO l O

i i 18 6.0 ORGANIZATION AND RESPONSIBILITIES The plant decontamination program will be conducted by Engelhard with Mr. Donald Chabot functioning as the onsite Program Manager. Mr. Chabot, Plant Engineer at the Plainville facility, is currently responsible for site characterization and remediation activities. As Program Manager, he will supervise the activities of the decontamination contractor, audit their health and safety operations, assure that the proposed work scope is achieved, and that survey results clearly demonstrate that residual contamination guidelines have been achieved. Mr. Chabot will be Engelhard's point of contact with the NRC. Mr. Chabot will be assisted in performing these functions by Drs. Robert Berlin and William Duggan, who are self-employed contractors. Both Drs. Berlin and Duggan i O are toewiedseabie ebeut the rieinviiie egerations, heve extensive experience with comparable facility remediation programs, are familiar with the decontamination programs to be conducte.d, and are experienced in performance of radiation surveys. They will provide onsite technical support, and assist in the selection of subcontractort nerformance i of surveys, interpretation of results, and preparation of the survey report. l Resumes for Mr. Chabot and Drs. Berlin and Duggan are provided in Appendix A. The decontamination contractor will be selected by use of a formal bidding process. An NRC-licensed contractor will be selected that is experiencer in performing comparable decontamination jobs and whose personnel have the appropriate health and safety training and medical certification. The selected contractor will be required, at a O

19 C\\ V minimum to: Commit qualified and experienced key personnel to the project for its duration Provide a detailed work plan and realistic schedule Identify the instrumentation and equipment to be used and their operating characteristics Demonstrate how residual contamination guidelines are to achieved and validated Establish the necessary insurance coverage Provide a qualified health and safety plan adapted to the project conditions j Establish QA/QC procedures and guidehnes O ineiyticai services for stess aigha/ beta ieveis en smears aed TCte aeeirses a, i necessary will be obtained from a licensed contract laboratory. l l 1 O l l l

-f l 20 3 ]s 7.0 SAMPLE ANAIXSIS Analytical services for gross alpha / beta levels on the smears and TCLP analyses, if necessary, will be obtained from a well-established licensed laboratory that has documented procedures for the handling of the smears, performance of analyses, and recording of results. A QA/QC program which assures the validity of the analytical results and is consistent with NRC/ EPA standards will be required. j The filter paper smears will be individually packaged in standard glassene envelopes as they are collected, labeled and numbered, and the locations of each smear recorded. Chain of custody documentation will be used to establish location and custody of the samples as they are shipped from the site to the analytical laboratory. Precautions will be taken to avoid contamination of the smears in transit or at the laboratory. O The metheds sed to aneiyze ihe smears wiii be cogebie ef meeserins ieveis heiew the established rele-ased guidelines, with detection sensitivities between 10 and 25% of the l guidelines. It is currently anticipated that the filter paper smears will be counted for gross alpha and beta in a low background gas proportional counter that has the measurement sensitivi'y to achieve this value. The laboratory will provide the analytical results in their standard reporting format i together with a quality assurance report for each batch of smears. O

i 21 8.0 IIEALTII AND SAFETY The decontamination of the plant will be planned and monitored to assure the health and safety of the decontamination workers, other onsite personnel, and the public. Thus, policies and procedures will be followed to assist personnel in minimizing the risk of 1 injury; to assure that exposure to any hazardous agents and release of contaminants is controlled to AI. ARA levels; and to comply with the applicable Federal and State of Massachusetts regulations. Organizationally, this will be accomplished at both the plant management and at the decontamination sub-contractor levels. Donald Chabot, the Engelhard decontamination program manager, with radiological support (See Section 6.0), will provide management oversight in health and safety. This will involve joint development with the sub-contractor and approval of the O deceetemieetien heaith end sefety vien, estebiishins and mainteinies eccess ceetrei te the work areas, auditing ongoing health and safety to assure that contamination control and radiation control support surveys are conducted, and that the protective work rules established for the project are adhered to in order to meet ALARA levels. As primary criteria for selection of a decontamination contractor, the company will be licensed by the NRC and thus possess a qualified and approved generic health and safety plan which can be readily adapted to conditions at the Plainville site. The personnel assigned to the project will have received the appropriate health and safety training, and be medically qualified. A project radiation safety officer (RSO) will be appointed who will be responsible for assuring adherence to the provisions of the health and safety plan and thus for the protection of the workers and the public. O i

I (] The primary health and safety concerns during the decontamination operations will l be potential exposure through inhalation, ingestion, and direct exposure to radiation and the common potential industrial hazards found in factory buildings. During the final survey, after residual guidelines have been achieved, only the common industrial hazards will be of concern. The health and safety plan will consider both situations. 1 Based on the results of the prior plant radiological surveys, it appears that radiological contamination is confined to discrete locations in the plant building and is at relatively lowlevels. In selecting and applying the techniques to remove the contamination, controls will be exercised to prevent dispersion and thus minimize any potential exposure of decontamination workers. The protective guidelines and measures established in the health and safety plan will be based on the results of the pre-decontamination surveys, and will be revised if actual conditions during decontamination require a different level of protection. At the time decontamination is performed, there will be no processing operations conducted in any of the affected areas of the building or adjacent locations. Thus, aside from the personnel involved in the decontamination operations, there will be no Engelhard personnel in these locations. The components of the health and safety program to be conducted during the decontamination program and surveys are covered by the site-specific health and safety plan 1 and include: Facility background O

23 Organizational responsibilities Project hazard analysis Worker training - inclusive of mandated general health and safety training, OSHA training for hazardous waste sites (as required); site-specific radiological and hazards training; short-duration " tailgate" safety meetings. Access control to affected area - including delineation of decontamination area and clean area. Site safe work practices ALARA program - management commitment and practices to assure ALARA exposure levels. Personnel monitoring and protective equipment - use of protective clothing; O gersoneei m eniterins; erea eirseree garticuiete m neiterins; criterie for use of respiratory protective equipment. Environmental monitoring. Radiation and contamination control - p. rsonnel radiation control measures (as required); procedures for minimizing contamination of field equipment; equipment survey and decontamination procedures. Contingency Plans - responsibilities; first aid and/or professional medical treatment for accidents and injuries; material release; operation shutdown criterit amunication. Record keeping - responsibilities; forms and documentation. O

24 9.0 QUALITY ASSURANCE PLAN A quality assurance (QA) program will be implemented for the decontamination program and surveys consistent with the projected magnitude of the decommissioning effort as described in this Plan. The QA program will operate from the pre-decontamination additional characterization survey through final validation of the data and interpretation of the results. Mr. Diomas Brown, Engelhard Corporate Manager of Environmental Affairs, will be QA Officer for the project. Mr. Brown, who will not be involved in the ongoing survey activities, will represent Engelhard's management QA oversight of the work and will coordinate the results of his QA oversight with the Project Manager, Donald Chabot. Mr. Brown will be the focal point for QA activities and validate that decontamination and O survey ectivities ere conducted in accordance with esieblished geiicies end recederes. ne P will oversee the site activities by conducting periodic audits and reviewing selected field and analytical data to validate adherence to procedures and acceptable data quality. Mr. i l l Brown's resume is provided in appendix A. In implementing the QA program, guidelines for acceptable QA practices and procedures will be obtained from (1) NRC Regulatory Guide 4.15," Quality Assurance for Radiological Monitoring Program - Effluent Streams and the Environment," 1979, and (2) ANSI /ASME NQA-1, " Quality Assurance Program Requirements for Nuclear Facilities," 1989. Decontamination and laboratory subcontractor QA procedures will be evaluated as part of the selection process to assure compliance with Engelhard and regulatory QA standards. O

1 25 All radiological surveys will be performed by Messrs. Berlin and Duggan or other j trained and qualified personnel, and will be conducted in accordance with standard, written procedures. Each step of the plant decontamination and surveys will be documented thus i developing a stand alone record of the decommissioning process that will be suitable for internal audit and regulatory review. Survey procedures developed for this project will be based on the guidance provided in NUREG/CR-5849. The Project Manager, Mr. Chabot, will approve all procedures and any subsequent revisions. All instrumentation used in performing the surveys will be maintained in accordance with vendor specifications. Calibration schedules will be established and adhered to for all instruments and analytical equipment. The instrumentation will be calibrated based on NIST-traceable standards or standards of other acceptable j organizations, and calibration records will be maintained. Daily tests of instrumentation will be performed against performance criteria prior to its use and any instruments failing to meet the criteria will not be used. Engelhard considers instrumentation calibration and demonstrated performance to be a significant aspect of the OA program, and care will be taken to assure that this is properly done and validated by audit of the program. The data management program will conform with established QA procedures and the guidance provided in NUREG/CR-5849. In-progress field procedural and measurement information will be recorded in bound logs or pre-developed forms comparable to those in the ORAU Survey Procedures Manual of 1990 (ORAU 1990). Laboratory analytical data will be recorded on standard forms. All calculations using the recorded field data or laboratory results will be reviewed and formally validated. Mr. Chabot will maintain O

26 control of original records, logs, and other project documentation through final report preparation. Duplicates of important records and data will be kept in Engelhard's corporate office in Iselin, New Jersey. The records will be archived for five years after completion of the final confirmatory survey and release of the site. The selected laboratory (s) will be required to meet NRC/ EPA QA standards for sample handling and preparation, analysis, and record keeping. Field and laboratory duplicate samples at a ratio of 1 for every 10 samples will be obtained. All samples collected in the field (wipes, material samples) will be carefully packaged, labeled, and i i recorded. Sample custody will be maintained by a responsible individual at all times with standard chain-of-custody records used to document custody from the field through laboratory analysis. Surveillance of the effectiveness of the QA program will be validated at the project level by continuous monitoring of the work against defined procedures and standards. Scheduled and unannounced QA audits will be performed by the QA officer and the results recorded on checklists. Any deficiencies will be documented, and project personnel will be required to resolve these deficiencies. 1 O

i l 27 l 10.0 DOCUMENTATION AND REPORTS l Engelhard will assure that the documentation developed during the l decontamination program will be complete and unambiguous, and will be sufficient to I permit an independent re-creation and evaluation of the decontamination process and the final radiological status of the plant. The data collected at each step during the interior decontamination program will be recorded in tabular form and on scale drawings and archived by Engelhard. This will include the results of the Pre-decontaminatien survey, the In-Progress Radiation Control j survey, and the Final Status Survey. This material, together with information prosided in j this Plan (i.e. relevant history and prior survey data) and by the decontamination 1 subcontractor in their proposal and final summary report (i.e. work plan, health and safety O rien aed dem ouoc dxumeemtiee> in grevide the sasis for the deveiegment ef the final status report. The final status report will generally adhere to the following outhne 1.0 Background information 2.0 Site information 2.1 Type and location of facility 2.2 Description of plant / site 2.3 Ownership 2.4 Plant conditions at time of final survey 3.0 Relevant operating history 4.0 Results of previous surveys O 1 ~..

28 5.0 Decommissioning program 5.1 Objectives 5.2 Release guidelines l 5.3 Work plan / procedures l 6.0 Final status sun'ey procedures 6.1 Survey objectives 6.2 Organization and responsibilities 6.3 Instruments and equipment 6.4 Survey procedures / parameters l 6.5 Records 7.0 Survey findings and results O 2.1 Surver resuits crasuieted deta. aneirsis and intergretation) 7.2 Comparison of results with guideline value 8.0 Waste disposal l 9.0 Summary and program oveniew 1 i Appendices: Tabular records of data and results of data interpretations QNOC records Health and safety records l l Chain of custody / manifest records Cd i l

i 29 O 11.0 DISPOSAL OF DECONTAMINATION WASTE j Existing criteria and acceptable practices for the packaging, transport and disposal i of decontamination waste will be adhered to and required of the decontamination contractor. Thus, the radioactive waste generated by the decontamination operations will i be immobilized and package.d for disposal as low level radioactive waste (LLW). The free water content in the waste package will be restricted based on NRC transport regulations. Arrangements will be made for waste disposal prior to initiation of the decontamination program to allow for immediate shipment of waste from the site. The waste will be disposed in a commercial facility licensed to accept LLW. It is currently anticipated, based on the status of LLW disposal nationally and in Massachusetts, that arrangements will be made to ship the waste to the Barnwell South Carolina LLW burial O eite. If any of the waste is determined to be mixed waste, (i.e. radioactive and hazardous waste) this waste material will be segregated and stored on site pending treatment to eliminate the mixed waste status or to await availability of a disposal facility that will accept a mixed waste. Such storage of waste may be subject to permitting or licensing requirements. l O

t 30 REFERENCES Weiss-1963 Letter, N.W. Weiss of Engelhard to D.A. Nussbaumer of USAEC,

Subject:

Cancellation of SNML-185 and SUB-172, June 27,1963. Lorenz-1963 AEC Memo, W.R. Lorenz to R. B. Chitwood,

Subject:

Engelhard Industries, Inc., Makepeace Division, Attleboro, Massachusetts License No. SNM-185 and SUB-172 - Request for Close-Out Inspection, August 13,1963. Lane-1963 AEC Memo, J.J. Lane to Files,

Subject:

Termination of Engelhard Industries Licenses SNM-185 and SUB-172. Dockets 70-139 and 40-768, September 19,1963. Director-1963 Director of Division of Licensing and Regulation to Engelhard Industries, September 27,1963. O NRC-1987

uSNRC, oeideiines for Deceetemina11ee of Faciiities end Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," Policy and Guidance Directive FC 83-23, August 1987.

ORAU-1990 Oak Ridge Associated Universities, "Suney Procedures Manual for the ORAU Environmental Survey and Site Assessment Program", March,1990. ORAU-1992 Oak Ridge Associated Universities (J.D.Berger), " Manual for Conducting Radiological Surveys in Support of License Termination" (draft), NUREG/CR-5849, ORAU-92/C57, June 1992.

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37 Table 2-1 LOCATIONS OF SURFACE WIPES TAKEN ON 7/14/88 AND 7/15/88 (Refer to Figure 3-2 for locations) l Wipe l No. Location l 1 Basement: old rack with electrical control panel: top and rear sections l l 2 Basement: electrical switch boxes on wooden wall board ) 3 Basement: middle selection wipe by electrical clock area 4 Basement: pipe at base of stairs (overhead pipe) l 5 Main floor: by fan and electrical junction box, just before cage on 'I' beam 20 l ft. from window. Wipe 10 ft. from floor. l 6 Main floor: floor by cage area below fire extinguisher 7 Main floor: side of 'I' beam by drums near 4-tank hook-up 8 Main floor: top of electrical control boxes 9 Main floor: floor by gate 10 Main floor: 'I' beam sides at 6 feet 11 Main floor: piping overhead as you enter room l 12 Main floor: gold vault, left side looking into vault (metal post at 6 feet) l 13 Main floor: left side vent by door (looking into room) l n) 14 Main floor: 2 electrical boxes adjacent to 3 push button switch

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15 Main floor: just inside Melt Room 2nd 'I' beam 6 feet from floor 16 Main floor: top off frame in Melt Room, of broken glass window (on wall side) 17 Main floor: side wall adjacent to door leading into oC5ce in Melt Room 18 Main floor: windows in Melt Room 7 to 8 feet from floor 19 Main floor: metal cage and locker room wall areas 20 Main Door: window area in shower room 21 Main floor: Ceiling of air conditioner: sitting-lunch area room 22 Main floor: solder room side wall by 1st. set of windows 23 Main floor: vent over Solder Room doors (outside room) 24 Main floor: top of hood 25 Main floor: top of pipes 26 Main Door: top of electrical furnace 27 Main floor: pipes 12 feet high on wall 28 Main floor: radiator, Die Room 29 Main floor: women's room wmdow frame and radiator 30 Main floor: men's room window frame 31 Main Door: small machine shop radiator, left side (as you look into room) l 32 Main floor: small machine shop wooden bench top and sides 33 Main floor: electrical prael 34 Main floor: sprinkler pipe old Main entrance 35 Main floor: wipe office: radiator interior 36 Main floor: contact test area inside of radiator l

1 38 O Wipe No. Location 37 Main floor: Lab. office, floor 38 Main floor: Lab. balance room wall 39 Main floor: Lab. hood vent over glass sider,1st hood as you enter room 40 Main floor: Lab. electrical junction boxes by fire extinguisher 41 Main floor: Lab. filter wipe 42 Main floor: I2b. wipe over major control panel 43 Main floor: wipe in Lab. area on top of electrical box by double doors 44 Main floor: 'I' beam wipe 6' from floor. Beam is 4th from wall "A" 45 Main floor: floor wipe as noted 46 Main floor: floor wipe as noted 47 Main Door: floor wipe as noted 48 Main floor: Door wipe as noted 49 Main floor: floor wipe as noted 50 Main floor: floor wipe as noted j 51 Duplicate wipe of #50 area wipe 52 Floor as noted 53 Floor as noted 54 Floor as noted p 55 Floor as noted x 56 Basement: grid for vent 57 Basement: grid for vent 58 Basement: grid for vent 59 Basement: grid for vent 60 Basement: grid for vent 61 Basement: grid for vent, repeat for #60 area 62 Basement: grid for vent 63 Basement: grid for vent 64 Basement: grid for vent 65 Basement: grid for vent 66 Pipe in carpenter room 67 Upper level: Door area 68 Upper level: floor area 69 Upper level: floor area 70 Upper level: floor 71 Upper level: repeat area of #70 (duplicate) 72 Upper level: window in hallway 73 Upper level: electrical junction box, top of box 74 Upper level: wipe of pipe 75 Upper level: repeat of area wipe #10 (duplicate) 76 Upper level: repeat of area wipe #20 (duplicate) ( 77 Upper level: repeat of area wipe #30 (duplicate)

a 1 i 1 39 Wipe No. Locatio.i 1 78 Upper evel: repeat of area wipe #40 (duplicate) 79 Upper evel: machine room window wipe 80 Upper evel: machine room electrical junction box, wipe on top of box 81 Upper le 7el: machine room electrical junction box, repeat of wipe area #80 82 Upper levd: floor wipe as noted 83 Upper leve.: floor wipe as noted 84 Upper Dooi.' floor wipe as noted 85 Upper level: floor wipe as noted 86 Upper level: wall wipe as noted 87 Upper level: floor area of room A 88 Upper level: doorway floor as noted 89 Upper level: floor of room 8 90 Upper level: pipe in tunnel 91 Upper level: wire area: desk top 92 Upper level: Metal Coin Room (vault) 1st, section: floor 94 Upper area: wire area by 480 Volt junction box (top of box) 95 Upper level: inner vault mid-section of shelves section: floor 97 Upper level: inner vault floor center of room 98 Upper level: inner vault general floor wipe O 99 ugger ievei: inner va it fieer 100 Upper level: inner vault floor area O

-u-a .a 2 I 40 0 l APPENDIX A ' O PERSONNEL RESUMES l I 4 I 1 i O l m - .----4

Thomas S. Brown O Corporat'"mager, Environmental Affairs

lharti Corporation isl Wood Avenue Iselin, New Jersey 08830 Credentials.

B.S. Chemical Engineering i Drexel University M.S. Environmental Health Engineering University of Texas l Experience: 1978 - Present Engelhard Corporation i Corporate Manager, Envimnmental Affairs: Corporate oversight and leadership of environmental compliance programs. l Operations Manager, Seneca Plant: Budget responsibility and j accountability for managing four operating departments and utilities and maintenance. Covered stan-up of relocated operations. Operations Manager, Delancy Street Plant: Budget responsibility and accountability for managing three operating departments during period of plant shutdown and relocation. Manager, Plant Services, Delancy Street Plant: Budget responsibility and i accountability for managing five service departments, environmental engineering, project engineering, maintenance, construction, and utilities. Manager, Environmental Engineering, former Enge'hard Industries Division: Budget responsibility and accountability for managing divisional group supponing all division plants in areas of environmental compliance. Environmental Engineer, former Engelhard Industries Division: Responsible for prograins supponing plant compliance with waste water, hazardous waste, and toxic substance rules. i 1975 - 1978 Delaware River Basin Commission Acting director ofjoint industry / government funded program investigating need for and availability of disposal capacity for " exotic" wastes. O Section chief of water quality section responsible for ob'aining and publishing water quality data for the mainstream of the Delaware River.

~ _- = Panicipated in review of projects r rused for Commission approval to O determine conform nce with c

== im ruies. 1973 - 1975 Gibbs & Hill, Consulting Engineers Environmental engineer participating in various municipal and industrial waste water treatment design pmjects. 1969 - 1973 Manville Corporation Reseamh engineer participating in various projects investigating applicability of various technologies to water and waste water treatment. i t l

!O l DONALD P. CHABOT WORK EXPERIENCE ENGELHARD CORPORATION - Route 152. Plainville. MA 02762 Senior Environmental Fully responsible for taking all the actions necessary for full compliance with Engineer all federal, state, and local environmental regulations as it relates to (December 1989 to designated sites. Develop and administer various environmental and present) contractor safety programs. Develop written plans and actions to satisfy regulatory agencies. Site remediation responsibility for compliance with RCRA's Corrective Action, DEP's MCP, NRC's Site Decomissioning Management Plan requirements. Environmental Developed plans, designed specifications, produced cost estimates and j Engineer other data needed to pursue the acquisition of new technology or the (December. A w correction of existing technology to comply with current or anticipated laws l December 1989) or environmental matters. Project engineering responsibility for the l application of technical knowledge and expertise in conjunction with engineering, organizational and plannire skills to successfully manage all aspects of environmental projects. Assessed the affects of current and proposed manufacturing technology on the invironment, specifically water and air as well as the generation o' Y tardous waste. Managed operation of plant environmental systems 1 Juding wastewater treatment, fume scrubbers, dust collectors, hazard alarms, cooling towers, and city water. Developed and administrate various environmental programs: hazardous waste, hazardous material inventory cor, trol, waste minimization, source reduction, pretreatment, SARA 313, regulatory permitting, and etc. Plant Engineer Project management responsibility for aspects of facility projects. (November 1985 to Assessed the affects of proposed manufacturing technology on production December 1986) processes. Managed operation of plant systems and utilities. PHILLIP A. HUNT CHEMICAL - One Wellincton Road. Lincoln. RI 02695 Plant Engineer Engineered and 1xecuted planned maintenance, repairs and replacements. (August 1982 to Supervised maintenance force. Engineered and supervised projects. l November 1985 Responsible for generation and distribution of power and other utilities. I l l page 1 l t

s l O 1 REFINEMET INTERNATIONAL - 162 Main Street. Woonsocket. RI 02895 3 Process Engineer / Duties included design and implementation of process Production Manager improvements, laboratory benchwork, quality control, (1978 to 1981) equipment design and specifications. EDUCATION B.S., Chemical Engineering, Georgia institute of Technology,1978 O i 9 O page 2

1p Robert E. Berlin O RR1-13 Sterling Pines I Tuxedo, New York 10987 (914) 351 2880 (Home) (212) 920-0294 (College Office) EXPERTISE-Health Physics and Industrial Safety Radiological Assessment Waste Management ACADEMIC EXPERIENCE Associate Professor, Manhattan College 1983-Present Mechanical En design courses.gineering Department-Teach undergraduate Coordinate and teach graduate programs in nuclear power and waste management / facility restorat!on. Reactor Administrator, Manhattan College Zero Power Reactor. Licensed Senior Reactor Operator. Radiation Safety Officer for reactor facility. Environmental Engineering Department-Teach graduate courses in hazardous waste management. 1985-Present Visiting Lecturer, Columbia University School of Public Health INDUSTRIAL EXPERIENCE 1983-Presen! h Consultant in Radioactive Waste Management, Facility Restoration and Radiological Health. Devel performance, of facility restoration programs,opment and impact assessments, contamination studies radiological programs. Regulatory liaison and preparation of license, monitoring applications, EAs, ERs, Rl/FS. Technology assessments and site ap plans, plications. Development of H&S plan and manuals, OA and operating manuals. Michigan, !!!inois, and Florida; former fuel fab DOE /ORNL waste burial site. facility in Massachuset:s; U.S. R 1980-1983 President, Waste Management Group, Inc : Industrial firms in the management of hazardous radioactive waste forms. Developed industrial safety, health physics and monitoring programs, performed environmental impact assessments, and assisted in regulatory compliance and licensing action. Prepared monitoring manuals for mining and milling facilities; waste management and transportation section of EIS impact assessments for DOE site remedial actio g (FUSRAP).

Robert E. Berlin ,( RR1-13 Sterling Pines Tuxedo, New York 10987 (914) 351-2880 (Home) (212) 920-0294 (College Office) EXPERTISE: Health Physics and industrial Safety Radiological Assessment Waste Management ACADEMIC EXPERIENCE Associate Professor, Manhattan College 1983-Present Mechanical Engineering Department-Teach undergraduate design courses. Coordinate and teach graduate programs in nuclear power and waste management / facility restoration. Reactor Administrator, Manhattan College Zero Power Reactor. Licensed Senior Reactor Operator Radiation Safety Officer for reactor facility. Environmental Engineering Department-Teach graduate courses in hazardous waste management. 1985-Present Visiting Lecturer, Columbia University School of Public Health INDUSTRIAL 1983-Present i EXPERIENCE lO ce" eiie#i i# aeeieective we ie ue#eoeme#i. e ciiiiv i Restoration, and Radiological Health. Development and j performance of facility restoration programs, radiological l Impact assessments, contamination studies, monitoring programs. Regulatory liaison and preparation of license applications, EAs, ERs, Rl/FS. Technology assessments and site applications. Development of H&S plan and manuals, OA plans, and operating manuals. Facilities include CERCLA designated Denver Radium Site; thorium-contaminated sites in Michigan, Illinois, and Florida; former fuel fabrication facility in Massachusetts; U.S. Radium site in New Jersey and DOE /ORNL waste burial site. 1980-1983 President, Waste Management Group, Inc.: Provided consultation services to government agencies and industrial firms in the management of hazardous chemical and radioactive waste forms. Developed industrial safety, health physics and monitoring programs, performed environmental impact assessments, and assisted in regulatory compliance and lic$nsing action. Prepared monitoring manuals for mining and milling facilities; waste management and transportation section of EIS for TMI-2 accident cleanup; and developed methodology for O-impact assessments for DOE site remedia: action program. (FUSRAP).

I l ROBERT E. BERUN O 1973-1980 Associate, Dames & Moore Performance of a range of programs at LLW sites, uranium facilities, and contaminated sites involving the modeling of sources, pathway dispersion, and receptor impacts through air and water pathways; validation of performance of performance objectives; determination of stabilization covers based on diffusion analysis; and assessment of impacts of projected accident conditions. Development of industrial safety and health physics programs for a variety of nuclear facilities with primary emphasis on contaminated facilities and waste disposal sites. Work included definition of procedures, preparation of operating manuals, development of-job descriptions and organizational responsibilities in accordance with Federal and St::te Regulatory Standards. Project Manager of Dames & Moore's technical support to NRC 1 in generating the 10 CFR Part 61 regulation for LLW disposal. Development of criteria and guidelines for LLW management practices at DOE laboratories consistent with 10 CFR 61, performance of LLW management facility ' assessments at ORNL, and preparation of guidelinec for review and approval of O LLW disposal sites. Preparation of EAs and ERs, and conduct of regulatory compliance programs for some 20 uranium projects as part of licensing and compliance activities. Development and performance of site remedial action programs (Maxey Flats and West Valley burial sites, and radium and thorium processing industrial facilities); design and application of air and water monitoring programs (U.S. DOE sites); and generic and site-specific migration studies. Represent clients in public information sessions and regulatory hearings, on the health-related and environmental effects of nuclear and waste management facilities. 1970 Assistant to Chairman, NYS Atomic and Space Development Authority, Managed demonstration programs on power plant siting, environmental assessment and waste disposal. 1966-1970 Manager of Direct Energy Conversion Projects RCA. .O. Responsible for development of Thermoelectric Technology for space and commercial applications.

i l ROBERT E. BERUN i 1960-1966 Division Director, US Atomic Energy Commission. Technical and contractual management of SNAP nuclear technology and ? portable reactor construction projects. 1956-1960 Senior Engineer, Pratt & Whitney Aircraft performed structural analysis of advanced reactor systems for space applications. ACADEMIC BACKGROUND Dr.P.H., Public Health / Environmental Sc;ience Concentration, Columbia University, School of Public Health,1985 M.S., Industrial Engineering, Now York University,1970 ) M.S., Engineering Science, Rensselaer Polytechnic Institute, i 1959 l B.S., Mechanical Engineering, City College of New York,1956 REGISTRATION: Professional Engineer, New York PUBUCATIONS: R. Berlin, C. Stanton, " Radioactive Waste Management," J. Wiley & Sons,1988. j Numerous papers and reports on radioactive waste management, thermoelectric technology, and radiological health. O . t ~.

1 i i WILLIAM P. DUGGAN, Ph.D. I 30 Von Beaste Lane (914) 268 - 2568 (Home) Congers, New York 10920 (718) 920 - 0112 (College Office) Oxeeniesce: j Manhattan Colleg. l Assistant Pwfessor, Mechanical Engineering 1990 - Present Supervisor of the College's Critical Reactor and nuclear engineering laboratory. Research in radiological environmental contamination and waste management. Instruction of undergraduate and graduate students in nuclear engineering and radiological topics, as well as basic engineering courses such as thermodynamics. J Prirate Consultant 1990 - Present ) Performance of projected pathway analyses and calculation of dose commitments for a former uranium 1 fuel fabrication facility. j Facility investigation and upgrade of thorium-contaminated industrial site. Impact assessment of j remediation alternatives included evaluation of pathways and calculation of potential dose i commitments to workers and off-site public. Project required establishment and execution of field health physics program. 3 Project Manager of technical and management assistance contract for the New York State Energy I f Research and Development Authority (NYSERDA), the agency responsible for construction and operation of New York's LLRW disposal facility. Tasks included planning for interim storage needs, preparing NYSERDA's program plan, and assisting in facility design and bcensmg. j Facility Investigation for geothermal power plant complex seeking to develop disposal facility for filtercake material with high radium concentrations. Duties involved assessment, through analysis and sampling, of exposures to workers and the public from radon emanations and particulate dispersion, I and client support in the permitting process and public hearings. Dames & Moore Consultant 1990 - 1992 Senior Engineer 1989 - 1990 Project Engineer 1987 1989 a Project Manager for Firm's Basic Ordering Agreement with Brookhaven National 12boratory. Management and technical responsibility for environmental services task order projects, including 4 j NEPA documentation; permitting under RCRA, NESHAPs, and other environmental regulations; and appraisal of the environmental monitoring program. Project Manager for Dames & Moore Licensing and assessment support ofIllinois LLRW Disposal Facility License application by Chem-Nuclear Systems, Inc. Coordinated multi-discipline efforts in preparation of license applications and evaluation of safety and environmental impacts for two sites. Performance assessment of West Valley Demonstration Project Class B and C LLRW Drum Cell. Evaluated compliance with 10 CFR Part 61 objectives, particularly with respect to intruder scenarios. ] Prepared position paper for WVDP use. Technical support in development of the Environmental Assessment and Safety Analysis Report for the West Valley Demonstration Project. Principal duties included accident analyses and system hazard classification as part of the Safety and Environmental Assessment Group. Technical support in preparation of a generic Safety Analysis Report for a low Ixvel Radioactive Waste disposal facility based on below-grade vault technology. Responsibilities included development of the environmental monitoring plan and auxiliary system requirements. Technical support for radon investigations as part of site assessments. Responsibilities included planning sampling program, interpreting results, and idemifying possible mitigating actions. Project Engineer in support of an application for onsite disposal of radioactive waste under 10 CFR Part 20.302. The submittal was the first under the guidance of NUREG 110L

l WILLIAM P. DUGGAN, Ph.D. Page 2 1 . EXPERIENCE: Rensselaer Polytechnic Institute l.'esearch Assistant 1984 - 1987 Instructor 1983 - 1984 i Research involved design and analysis of blanket and divertor systems ' r fusion reactors using the novel Integrated-Blanket Coil concept. As a member of the design tu.n for the TITAN project, i l collaborated with UCLA, Los Alamos Laboratory, the Fusion Engineering Design Center at Oak Ridge and GA Technologies. ) Preparcd and taught two laboratory courses at the senior and graduate levels invoMng use of the sub-critical reactor facility and various data acquisition systems, including CAMAC. j l Stone & Webster Engineering Corporation l Career Development Engineer 1982 - 1983 Responsibilities involved analysis and evaluation of engineered safeguard systems, including l containment pressure and temperature effects; determination of non-accident power plant radiation t source terms; and evaluation of shielding requirements. l EDUCATION: Rensselaer Pol,; technic Institute, Troy, New York i Ph.D. Nuclear Engineering and Science,1987 i Thesis: Application of the Integrated-Blanket Coil Concept to the Compact Reversed-Field Pinch Fusion l Reactor. l M.S. Nuclear Engineering,1982 Thesis: Heat Transfer in a Shipping Cask Containing Bundled Spent Fuel Pins O 8.s.xeciern#8 eeri8.298o l i 1 PUBLICATIONS: Duggan, W.P. " Pathway Analysis to Establish Clean-up Criteria" Mixed Waste Regulation Conference, Atlanta, GA, June 17-18, 1991. Berlin, R.E., Stanton, C., and Duggan, W.P. " Developing a Graduate Program in Nuclear Waste l l Management / Facility Restoration" Waste Manacement. '91, Tuscon, AZ, Feb. 24-28,1991. l Duggan, W.P. and D. Steiner " Integrated-Blanket Coil Applications to the TITAN Reversed-Field Pinch Reactor" Proceedincs of the Twelfth Symposium on Fusion Encineerine, Monterey, CA, Oct.12-16,1987, p.1279. Duggan, W.P. and D. Steiner " Applications on the Integrated-Blanket Coil Concept to the Compact Reversed-Field Pinch Reactor" presented at the Seventh Topical Meetinc on the Technoloev of Fusion Enercy Reno, NV, June 1986. I PROFESSIONAL AND CIVIC Adjunct Assistant Professor, Rensselaer Polytechnic Institute i Engineer-In-Training, Commonwealth of Massachusetts Member, American Nuclear Society Member, Health Physics Society Treasurer, Greater New York Chapter Health I aysics Society Member Sigma Xi Associate Member, American Society of Mechanical Engineers O Directer. Renssei er ^iumniisseciatien Ciub ef weetche ter National Chairman, Rensselaer Fund Phonathon l i ... - _ _ - _ - ~.. _ _. _ _... _ _ _ -, - _ _. ~. ~ ~}}