ML20052C691
| ML20052C691 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/04/1982 |
| From: | Hinson C, Wing J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20052C678 | List: |
| References | |
| NUDOCS 8205050398 | |
| Download: ML20052C691 (20) | |
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A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMf11SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322
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(OL)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
NRC STAFF TESTIMONY OF CilARLES S. HINSON AND JAMES WING ON ALARA RADIATION EXPOSURES 4
(SC Contention 26)
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OUTLINE OF TESTIMONY Suffolk County contends that Applicant has not demonstrated that Shoreham meets the requirements of 10 C.F.R. 20.1(c) in a number of specified areas. The testimony addresses each of the areas specified and shows that Applicant has adequately provided that occupational exposures will. be kept as low as is reasonably achievable (ALARA).
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.y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322
)
(0L)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
NRC STAFF TESTIMONY OF CHARLES S.
HINSON AND JAMES WING ON SC CONTENTION 26 Q.
Please state your nane and position with the NRC.
A.
(CSH) My name is Charles S. Hinson.
I have been a health physicist with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation of the NRC since 1976. A copy of my professional qualifications is attached.
(JW)
My name is James Wing.
I have been with the NRC since 1975. Since 1980, I have been a Senior Chemical engineer in the Chemical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulations. A copy of my professional qualifications is attached.
Q.
Please describe the purpose of this testimony?
A.
(CSH,JW) The purpose of this testimony is to address Suffolk County Contention 26, which states:
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Suffolk County contends that LILC0 has not ade-quately demonstrated that Shoreham meets the requirements of 10 C.F.R. 20.1(c), with regard to provisions for maintaining occupational radiation exposure as low as is reasonably achievable (ALARA).
Demonstration of compliance is inadequate as follows:
(a) Plant and equipment design has not been shown to be optimally developed for minimization of radiation exposure during maintenance of the plant by:
(i) Selection of low cobalt materials; (ii) Separation or isolation of various components and piping systems; (iii) Provisions for flushing or decontamination; (iv) Equipment layout and arrangement for ease and automation of maintenance and refueling; and (v) Condenser design utilizing the minimum number of shell connections.
(b) Procedures have not been developed and emplaced to provide:
(i) Limitation of iron-cobalt buildup in the primary system through water chemistry control; (ii) Monitoring and control of individual and plant total annual occupational radiation doses, with individual exceedance of three rem per quarter and five rem per year occurring only on an emergency basis and requiring special management approval; and (iii) Action to reduce radiation levels and/or exposure if the in-plant totals signifi-cantly exceed U.S. plant averages.
Q.
Could you describe generally the provisions of-10 C.F.R.
20.1(c)?
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A.
10 C.F.R. 20.1(c) states that persons engaged in activities under NRC issued licenses should make every reasonable effort to maintain radiation exposures, and releases of radioactive materials in effluents to unrestricted areas, as low as is reasonably achievable (ALARA). As defined in 10 C.F.R. 20.1(c), the term ALARA means "as low as is reasonably achievable taking into account the state of technology, and the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to the utilization of atomic energy in the public interest." Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As low As Is Reasonably Achievable," provides information on how to maintain radiation exposures to station personnel as low as is reasonably achievable during routine station operations. This Regulatory Guide was first issued in July of 1973, three years after the Staff's compilation of the PSAR Safety Evaluation Report for Shoreham, in February of 1970.
Q.
Part (a) of SC Contention 26 addresses plant and equipment design at Shoreham. Subpart (1) deals with the selection of low cobalt materials. Has the Applicant made use of low cobalt materials in its design of the plant?
A.
(CSH) The regulations contain no specific requirements for limiting the cobalt content in components within the reactor coolant pressure boundary (RCPB). During the plant initial design and during NRC Staff review of the PSAR for Shoreham (in the late 1960's), and during early station construction, there were no NRC guidelines (in the form of Regulatory Guides) for use of low cobalt materials in the plant
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It was not until the issuance of Revision 3 of Regulatory Guide 8.8, in June 1978, that the use of low cobalt materials in the plant systems was recommended by the NRC. The materials used in the fabrication of the components within the RCP8 at Shoreham are in con-formance with the rules of 10 C.F.R. Part 50, Section 50.55a. These rules are based on the applicable American Society of Mechanical Engineers codes and standards.
Although there are no NRC requirements limiting the cobalt content in RCPB components, LILC0 has taken several steps to minimize the buildup of iron-cobalt corrosion products at Shoreham. These inlude design features to minimize crud traps and reduce the amount of circulating corrosion products and water chemistry controls to minimize crud buildup.
Q.
Addressing Subpart (ii), how has LILC0 made use of the separation or isolation of various components and piping systems to minimize maintenance exposures?
A.
(CSH) The separation of various components and piping systems at Shoreham is consistent with the guidelines of Regulatory Guide 8.8 "Information Relative to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As low As Is Reasonably Achievable,"
Revision 3.
According to Applicant's FSAR, radioactive tanks and piping requiring shielding will be isolated or located in separate cubicles to minimize radiation exposures to workers working on adjacent systems. For example, all tanks requiring radiation shielding are placed in shielded cubicles and tanks of different systems are kept separate from each other.
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The evaporators at Shoreham are individually shielded by concrete cubicles. Where necessary, the liquid filters are also located in separately shielded cubicles. Cubicles containing radioactive equipment are designed so that the dose rate contribution from the principal source in the adjacent cubicles does not exceed 5 mrem /hr.
This minimizes the dose received by personnel servicing the equipment.
Cubicles containing equipment requiring servicing are designed with access openings for equipment removal.
Pumps, valves, and associated equipment are isolated from sources of high radiation such as tanks and filters.
Valves on radioactive lines are serviced remotely using reach rods. This is done so that personnel servicing or operating this equipment can do so without being exposed to high radiation doses from the associated tank and/or filters.
s Radioactive piping is shielded and segregated from nonradioactive piping, personnel passageways, and operating areas. Ventilation ducts are separated from all sources by shield walls whenever practicable to keep maintenance exposures as low as possible.
To summarize, radioactive components and piping are separated and shielded from each other whenever practical at Shoreham. This design feature reduces dose rate contributions from adjacent equipment, and thereby reduces the occupational radiation exposures of personnel servicing this equipment.
Q.
To address Subpart (iii), how has LILC0 incorporated provisions for equipment flushing or decontamination as a means of minimizing radiation exposures at Shoreham?
A.
(CSH) All systems at Shoreham which may contain or transport significant amounts of radioactive fluids are provided with permanent
ts, pipe flushing connections to facilitate decontamination for maintenance purposes. Liquid filters will be rinsed or backwashed prior to per-formance of any maintenance work. The evaporators will be completely drained and flushed hrior to any maintenance work on them, or any of the associated equipment, to reduce dose rates.
Shoreham has several decontamination areas located throughout the plant for decontamination of tools, small parts, and equipment. Applicant stated in its FSAR that contaminated equipment will either be decontaminated or placed in plastic bags prior to moving. Any area which is found to be contaminated to an undesirable level will be roped off, posted, and de-contaminated as soon as possible. Demineralized water hose stations are located on the reactor building operating floor for use in cubicle de-contamination.
All persons will be checked for contamination upnn exit from con-trolled areas. A decontamination area, located at the access control point in the turbine building, contains a shower, sink, and decontamination supplies for use in personnel decontamination.
Q.
To address Subpart (iv), how does the Shoreham plant equipment layout facilitate ease and automation of maintenance and refueling and thereby serve to maintain occunational radiation exposures as low as is reasonably achievable?
A.
(CSH) The Shoreham plant is designed to minimize radiation exposure to personnel during maintenance, operations, and refuelings.
This has been done by locating radioactive comlonents in separate, individually shielded cubicles. The evaporators at Shoreham are individually shielded by concrete cubicles and the liquid filters are I
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located in separately shielded cubicles where necessary. This arrangement reduces dose rate contributions from adjacent radioactive 4
equipment and thereby allows personnel servicing equipment to work in lower radiation zones. Equipment associated with radioactive components, such as pumps, valves, filters, and readouts, are located outside of the component cubicle in lower radiation zones. At Shoreham, valve stations for radioactive equipment are shielded from the equipment, filters are separated from their supportina equipment, and pumps are isolated from sources of high radiation. This design allows personnel servicing this auxiliary equipment to do so in a lower radiation zone than if the radioactive component were located in the same cubicle as the equipment requiring servicing. All nonradioactive equipment will be located outside of cubicles in radiation zones of less than 5 mrem /hr.
Instrument racks requiring periodic in situ calibration and/or maintenance are placed in instrument racks located in easily accessible locations.
LILC0 has taken the following steps in order to minimize doses to personnel servicing radioactive equipment located in cubicles. Equipment layout in the cubicles is such that the electrical portion is nearest the access point (for servicing) and platforms are provided for easy access to out-of-reach areas requiring service.
Radioactive equipment requiring servicing is located in cubicles designed with access openings sized for equipment removal. Valves requiring maintenance are provided with shielding based on anticipated maintenance time. The design of the ventilation systems p
'ided shielded access to the charcoal and high efficiency particulate air (HEPA) filter trains. These filter trains
e-9 8-have adequate space to add, test, and remove charcoal and HEPA filters.-
Where practicable, the associated ventilation ducts are shielded from all radiation sources to keep maintenance exposures as low as is reasonably achievable.
In areas of the plant where permanent shielding is not practicable, steel supports and large access ways have been provided for the use of portable shielding. Portable shielding has been provided for refueling and inspection operations to minimize the dose accumulated during these periods. These plant and equipment layout provisions are consistent with the guidance of Regulatory Guide 8.8, Rev. 3.
Q.
To address Subpart (vi, have the condensers at Shoreham been optimally designed to minimize radiation exposure during maintenance by-utilizing the minimum number of shell connections?
A.
(CSH) This subpart is concerned with reducing maintenance exposure by minimizing the number of steam inlet connections (referred to as shell connections in the contention) to the main condenser at-Shorehan. Use of a condenser inlet pipe configuration having fewer pipe connections than the Shoreham design could theoretically result in a small reduction in the amount of radioactive material (commonly referred to as " crud") on the condenser tube surfaces.
The main condensers at Shoreham are of a standard design and have l
been designed in accordance with guidance contained in the document StandardforSteamSurfaceCondensers.E These condensers are located in the turbine building below the main turbine and moisture separator reheators. Their function is to condenser primary steam coming from the I
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Standards for Steam Surface Condensers, Seventh Edition, Heat
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low pressure turbines. This is done by directing the steam around the outsides of thousands of tubes carrying cooling water. Tr,e cooling water enters a large chamber (called the inlet waterbox) at one end of the
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condenser, passes through the tube bundle, and exits through the outlet waterbox at the other end of the condenser. As the plant ages, these tubes sometimes develop leaks.
If leaks are detected in the condenser tubes, the tubes must be plugged to maintain integrity against cooling water ingress into the primary system. To perronn this plugging operation, personnel must enter the condenser waterboxes. During full power operation, the dose rates in the waterboxes can be as high as i
several hundred mrems/hr. Nearby radiation sources, such as the moisture separator reheaters and the heat exchangers, account for a major portion of this dose rate. At full power operation, the dose rate contribution to the waterboxes from the radioactive " crud" on the condenser tubes is negligible.
In order to minimize personnel exposure, most tube plugging work is done at reduced power levels (typically between 20 and 50 percent of full power).
Even at these power levels, the dose contribution at the waterboxes from condenser " crud" is very small when compared with the dose rate contribution from other sources.
During plant shutdown, radiation levels in the condenser waterboxes and in the tube area typically average less than five mrems/hr. Since there are no major radiation sources near the condensers during shutdown, these condenser radiation levels are primarily due to " crud" buildup on the condenser tubes.
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A major portion of the personnel exposure associated with condenser maintenance is received from tube testing and plugging, which is usually performed while the plant is operating. Since the dose rate contribution from condenser tube " crud" is small during plant operation, a small reduction in " crud" levels would have little effect on personnel ex.
posures associated with condenser maintenance. On the average, personnel doses associated with condenser maintenance account for one percent or less of the total annual personnel exposure at BWRs. Therefore, designing condensers with a minimum number of shell connections wouso not provide any significant reduction in personnel exposure during maintenance.
Q.
Part (b) of SC Contention 26 deals with procedures at Shoreham.
Subpart (1) of Part (b) deals with iron-cobalt buildup. Have procedures been developed and emplaced to orovide limitation of iron-cobalt buildup in the primary system through water chemistry control?
A.
(JW) Limitation of iron-cobalt buildup in the primary system is accomplished at Shoreham by the procedures for the Reactor Water Cleanup System and the Condensate Demineralizer System, and by an oxygen control program.
The Reactor Water Cleanup System consists of demineralizers which continuously remove suspended solids and dissolved impurities such as iron and cobalt species frcm the reactor water, thus limiting iron-cobalt buildup in the primary system. The influent to and the effluent from each demineralizer are sampled to determine its effectiv@ ness in removing solids and impurities. When the effectiveness of the demineralizers is
reduced to below sixty percent of the original capacity, the active filtering elements in the demineralizers will be replaced.
The quality and impurity level of reactor water are indicated by its electrical conductivity and acidity. The limits of the conductivity and acidity in the reactor water have been established in accordance with the recommendations in Table 1 of Regulatory Guide 1.56, " Maintenance of Water Purity in Boiling Water Reactors," Revision 1 (July 1978). The conductivity and acidity will be monitored continuously to ensure that their limits will not be exceeded. Appropriate corrective actions will be taken when the limits of conductivity or acidity in the reactor water are exceeded, consistent with the recommendations in Table 1 of Regulatory Guide 1.56, Revision 1.
Specific procedures for implementing the corrective actions are given in the proposed Technical Specifications Section 3.4.4.4.
Currently, the Staff is finalizing its review of the plant Technical Specifications.
The Condensate Demineralizer System consists of demineralizers which continously remove corrosion products, suspended solids, dissolved impurities, fission products, suspended solids, dissolved impurities,
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fission products, and activation products, including iron and cobalt species, in the condensate before it returns to the reactor vessel as feedwater, thus limiting iron-cobalt buildup in the primary system. The influent to and the effluent from each demineralizer are sampled to l
determine its effectiveness in removing impurities. When the effective-ness of the demineralizers is reduced to below sixty percent of the original capacity, the active filtering elements in the demineralizer will be replaced. The quality and impurity level of the feedwater are m
indicated by its electrical conductivity. The limits for the con-ductivity in the condensate system water have been established in accordance with the recomendations in Table 2 of Regulatory Guide 1.56, Revision 1.
The conductivity of th? feedwater is continuously monitored to ensure that its limits are not exceeded. Appropriate corrective actions will be taken when the limit of conductivity in the feedwater is exceeded, consistent with the recommendations in Table 2 of Regulatory Guide 1.56, Revision 1.
An' oxygen control program to reduce material corrosion rates in the primary coolant systems was recommended by the General Electric Company to all boiling water reactor operators, in the report, "BWR Coolant Oxygen Control", NED0-23631 (June 1977). We are of the opinion that an oxygen control program will reduce materials corrosion rates and radiation buildup, including iron-cobalt buildup, in the primary system.
The Shoreham Nuclear Power Station has committed to an oxygen control program to minimize iron-cobalt buildup in the primary system.
In conclusion, the Shoreham Nuclear Power Station has developed procedures to limit iron-cobalt buildup in the primary system through the Reactor Water Cleanup System, the Condensate Demineralizer System, and an oxygen control program.
Shoreham has committed to implementing these procedures when the plant is in operation.
Implementation of these water chemistry control procedures will provide assurance that occupational radiation exposure will be kept as low as is reasonably achievable.
Q.
Addressing Subpart (ii) of Part (b), what are LILC0's procedures for monitoring and controlling individual snd plant total annual occuaptional radiation doses? Are invidivual doses permitted to
exceed three rems per quarter and five rems per year only on an emergency basis (which requires special management approval)?
A.
(CSH) The Applicant intends to maintain occupational radiation exposures at Shoreham as low as is reasonably achievable. This policy applies to total man-rems accumulated by all personnel, as well as to individual exposures. Each individual receives sufficient training so that they are capable of carrying out their responsibility for main-taining their own exposure as low as is reasonably achievable.
In addition, it is the responsibility of the Health Physics (HP) Staff to take positive steps to reduce personnel exposures such that maximum individual radiation dose is always below the limits of 10 C.F.R. Part 20
" Standards for Protection Against Radiation" and the total in-plant dose is maintained ALARA. The maximum allowable individual dose limit specified by 10 C.F.R. Part 20 is 1.25 rems per quarter and five rems per year (an individual may receive up to three rems per quarter as long as he does not exceed the 5(N-18) rems limit).
All personnel who enter a Controlled Access Area at Shoreham are required to wear personnel monitoring devices at all times.
Pocket dosimeters are read and the dose recorded at least once during the working day. Personnel TLD badges or film badges are processed monthly, 4
or more frequently if significant exposures are expected.
Pemanent lifetime, annual, and quarterly dose records are kept for all personnel. Current exposure data is recorded on Form AEC-5, " Current Occupational External Radiation Exposure" or the equivalent. The employees' prior radiation exposure history is recorded on Form AEC-4,
" Occupational External Radiation Exposure History." These records are maintained under the supervision of the HP Engineer at the plant.
All plant personnel performing work in Radiation Areas, High Radiation Areas, contaminated areas or areas where airborne radioactivity or neutron radiation is present, must first obtain a Radiation Work Permit (RWP). A RWP informs the individual as to the dose rate present in the work area and, by assigning stay times, ensures that the worker does not exceed his dose limits. Plant supervisors will review RWP dose rates so that work assignments may be planned in a manner consistent with the ALARA policy.
The HP section is responsible for reviewing plant occupational radiation exposures to assure that they are as far below the specified limits as practicable. Whenever recommended radiation exposure values are exceeded, the HP Engineer will, in accordance with applicable pro-cedures, direct an investigation to determine the causes of such ex-posure and then take steps to reduce the likelihood of similar future occurrences.
For each such occurrence, the HP Engineer must demonstrate that an investigation was performed, conclusions were reached as a result of this investigation, and that corrective actions were taken as appropriate.
In these ways, LILC0 can remain cognizant of individual as well as overall I
personnel exposures at Shoreham and implement controls to maintain.
occupational exposure ALARA.
Q.
Addressing Subpart (iii) of Part (b), what actions will LILC0 take to reduce radiation levels and/or exposure if the in-plant totals I
signficantly exceed U.S. plant averages?
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A.
(CSH) LILCO has not developed any specific actions to take if the in-plant totals at Shoreham significantly exceed U.S. averages.
However, it is the responsibility of the HP Section to conduct sur-veillance programs and investigations to assure that occupational radiation exposures are as far below the specified limits as practicable.
Whenever recommended values for weekly, quarterly, or annual exposure guides are exceeded without authorization, or whenever special guides authorized by the HP Section are exceeded by more than a factor of 1.25, the HP Engineer must, in accordance with applicable procedures, direct and particupate in an investigation to determine the causes of such exposures. Corrective actions (such as implementation of revisoins to procedures and plant modifications, as appropriate) will then be taken to avoid a recurrence of such a situation.
Since increasing radiation fields can result in increased occupa-tional exposures, status sheets showing contamination leuls, radiation levels, and significant radiation sources will be posted outside the Health Physics Office at Shoreham. Any area or piece of equipment which is found to be contaminated to an undesirable level will be roped off, posted with appropriate signs and decontaminated as soon as practical.
Guards will be posted where the contamination levels are such that a major portion of the body could receive in any one hour a dose in excess of 100 mrems. These areas will remain under surveillance until they are either decontaminated or provided with locked barriers. All systems at Shoreham which may contain or transport significant amounts of radioactive fluids are provided with permanent pipe flushing connections to facilitate decontamination for maintenance purposes.
By maintaining i
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plant-radiation levels as low as is reasonably achievable, LILC0 plans to minimize the overall in-plant total exposures.
Q.
Could you please give a brief conclusion to your testimony?
A.
(CSH, JW) In our testimony, we have described the measures taken by Applicant in the specific areas addressed in the Contention to assure that occupational exposure to radiation is kept as low as is reasonably achievable as required by 10 C.F.R. 5 20.1(i). The Staff has concluded that Applicant has met the requirements of 10 C.F.R. $ 20.1(1).
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CHARLES S. HINSON Professional Qualifications My name is Charles S. Hinson,.
I am a Health Physicist with the Radiological Assessment Branch in the Office of Nuclear, Reactor Regulation of the U.S. Nuclear Regulatory Commission (NRC).
1 am responsible for technical review and evaluation of the radiation protection pr'ogram for proposed nuclear facilities.
I have been with the Radiological Assessment Branch for about 61/2 years.
I received a B.S. in Nuclear Engineering from the University of Virginia in 1974, and a M.E. in Health Physics / Nuclear Engineering from the University of Virginia
- in 1976.
I worked in the Radiation Protection Section (RPS) of the Radiological Assessment Branch (RAB) from 1974 to 1975 and have been with the RAB since I received my M.E. degree in mid-1976. My principle function is the review of power reactor applications, both at the construction permit and operating license stage. The objective of this review is to assure that the plant is designed and operated in a manner that will maintain occupational radiation exposures as low as is reasonably achievable.
My secondary duties include reviewing and development of HRC regulations and safety guides, participation in task forces to resolve generic issues, and compilation of annual radiation exposure data for LWRs.
I co-authored the report entitled " Occupational Radiation Exposure at LWRs 1969-1974" (NUREG-75/032) and presented a paper entitled " Occupational Exposure and ALARA" at a ANS conference on Decontamination and Decommissioning of Nuclear racilities.
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o JAMES WING Professional Dualifications My name is James Wing.
I am a'; Senior Chemical Engineer in the Chemical Engineering Branch, Division of Engineering, Of fice of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
I received a Bachelor of Science degree in Chemistry from the University of Tennessee in 1949, a Master of Science degree in Chemistry from Purdue University in 1953, and a Ph.D. degree in Chemistry from Purdue University in 1956.
Before joining the Commission, I was employed by Argonne National Laboratory from 1955 to 1959 as first, Assistant Chemist and then, Associate Chemist.
In this capacity, I performed basic research in nuclear chemistry.
From 1969 to 1975, I was employed by National Bureau of Standards as a research chemist and computer programmer.
In these two positions, I did research work on radio-chemistry and air pollution, and wrote computer program's for laboratory automa tion.
I have written 28 technical papers and 10 laboratory reports on various topics, including nuclear chemisty, radiochemistry, air pollution, applied mathematics, and food technology.
In the academic year of 1964-1965, I was a Fulbright Lecturer.
I am a member of the American Chemical Society.
I have been a staff member of the Nuclear Regulatory Conmission since January 1975.
From 1975 to 1978 I was a Nuclear Chemist in the Accident Analysis Branch..
From 1978 to 1980, I was a Senior Nuclear Engineer in the Ef fluent Treatment Systems Branch.
Since 1980, I have been a Senior Chemical Engineer in the Chemical Engineering Branch. My duties in this position include reviews and evaluation of reactor water cleanup systems, post-accident emergency cooling water chemistry, spent fuel pool cleanup systems, protective coating systems and organic materials inside containment, process sampling systems, chemical and volume control systems, and post-accident sampling systems in nuclear power plants.
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