ML20081K432

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Provides Addl Responses to NRC Request for Addl Info Pertaining to CAVALIER Decommissioning Plan
ML20081K432
Person / Time
Site: University of Virginia
Issue date: 06/17/1991
From: Mulder R
VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To: Alexander Adams
Office of Nuclear Reactor Regulation
References
NUDOCS 9106270189
Download: ML20081K432 (57)


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& APPL. LED SCIENCE 14 r wl m \ 1 ( U \i t Il.G 1 \t.I\lI RI\G A i %lil i Alm l'll) \!( s Mr. Alexander Adams, Jr. .y Non-Power Reactors, Decommissioning i

and Environmental Project Directorate Division of Advanced Reactors y

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and Special Projects Office of Nuclear Reactor Regulation

Subject:

U.Va's Response to NRC Request for Additional Information Pertaining to the CAVALIER Decommissioning Plan.

Dear Mr. Adams:

Please find enclosed the information requested by the NRC, which we hope will help bring to a close the review of U.VA.'s application to decommission the CAVALIER and terminate its license.

Despite the late hour by way of this cover letter and in our response to questions 1 and 14, the NRC is asked to reconsider whether all decommissioning release criteria actually need be met in the CAVALIER decommissioning. This request is based on the special circumstance whereby the CAVALIER site would be absorbed into the UVAR reactor site immediately following CAVALIER license termination. If the decommissioning rula does not allow variances, even for good cause, this licensee is prepared to go ahead as originally committed in the Decommissioning Pla1 and the response to the NRC questionnaire. However, if variances are allowed the licensee requests that the Plan be amended to the extent that the final radiation survey of the CAVALIER site be deferred until such time that the UVAR reactor is decommissioned.

.nity/Cnunty of _'d b "u" Commonwealth of Vncinia I hereby certify that the attached document c a tp> ano Sincerely, ]

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. i Page 1-2 1 1.a. Driefly provide additional information on your current plans to reuse the CAVALIER facility for future activities. Does this include possible transfer of the area to another NRC license.

No plans exist at present for the reuse of electronic console components of the CAVALIER facility, or the area occupied by the reactor itself, i.e. the reactor pit and tank. We anticipate that the pit and tank can be decontaminated (there is little contamination to start with). The tank will be left in place, to accommodate an eventual experimental need. Due to the low reactor power level and its infrequent use, the concrete pit has not been activated to an appreciable extent, and therefore we believe that physical removal of concrete is not required.

It is noted that the " site" presently occupied by the CAVALIER (see also the answer to question 4) will revert to the UVAR license R-66 immediately following the termination of the CAVALIER license.

Reactor fuel, control rods and grid plate will be held under the UVAR R-66 License (see also response to question 6), and the remaining materials will be discarded of as waste, either radwaste or normal waste, as appropriate.

1.b. Discuss the "one-time basis" (2nd paragraph) for meeting the requirement to permit unrestricted use of the CAVALIER facility.

The unusual aspect associated with the CAVALIER decommissioning is that this reactor shares a building with the UVAR reactor. Presently, the entire building (known as the

Reactor Facility") is a restricted area, with a single access point-for both reactors. Access .to the Reactor Facility, and thus the CAVALIER " site", will continue to be restricted during the entire decommissioning phase. After CAVALIER decommissioning and license termination, the CAVALIER " site" will revert to the UVAR R-66 license and remain restricted with respect to access. The-(former) " CAVALIER site" might be used in the future in connection with experiments involving radioactive materials. Since the area would be under license R-66, unrestricted access contamination and exposure levels would not need to be maintained.

Our understanding is that, at least momentarily, the CAVALIER

" site" has to conform to the criteria permitting unrestricted access, in order for the NRC to terminate the CAVALIER license, even though unrestricted access will never exist because the area will be " absorbed" under UVAR license R-66 immediately upon-CAVALIER license termination. If we misunderstand the regulations, and the " site" is amenable to incorporation under the UVAR R-66 licensee "as is", please advice us immediately. In this case, we are hereby requesting a waiver of the final radiation level survey 4 usually performed following dismantling operations.

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1.c. What release criteria (residual contamination levels and exposure rates) will be used for this purpose?

Release criteria for acceptable surface contamination are given in Table 1, page 2-3, of the plan. These critoria are based on NRC Regulation Guide 1.86. The criteria are also discussed on pages 4-1 and 4-2 of the plan. The criteria will be applied by the licensee on a "one-time basis" for licence termination (see answer to question 1.b.).

With regard to ambient exposure levels, the NRC permits the licensee the option of demonstrating that the maximum exposure to an individual due to residual contamination from the CAVALIER will be 10 mrom per calendar year. This can be assured through a thorough "one-time" decontamination of the " site", smear surveys, positive access control to the Reactor Facility, limited occupancy of the area, and personnel dosimetry. When this option is exercised, radiation levels less than 5 uR/hr above natural background need not be demonstrated. This option should be taken by the licensee because the local background exposure rate is influenced by reactor fuel kept in the Fuel Storage Room and a natural uranium sub-critical facility, both located nearoy.

(Note: In response to NRC question 4, some wording on page 2-3 of the plan has been edited. A replacement page is in attachment.)

2. Page 1-2 You describe methods for making changes to your decommissioning plan after NRC approval. Because NRC authorization to decommission the facility in accordance with the plan is in the form of an order, regulations such as 10CFR50.59 do not apply. If you desire to have the flexibility to make changes to the plan after the order is in place, provide additional detail in the plan for the methodology to make such changes. If approved, the methodology will then be part of the plan that is authorized by the order.

We understand that regulations such as 10CFR50.59 will not apply to the CAVALIER license after the NRC issues an order for decommissioning which supersedes the license. However, since the UVAR license will be in effect for the remainder of the building, it is reasonable that the provisions contained in 10CFR50.59 be followed, to the extent possible. A copy of the QA/QC checklist used to comply with 10CFR50.59 is in attachment. In direct response to this NRC question, the last paragraph of page 1-2 of the plan will be substituted with the following:

The methodology which will be used for making changes to the decommissioning plan, should 1

3 the need should arise, is as follows. The staff will prepare a formal written submittal for review and approval by the Reactor Safety Committee. This packet will contain the proposed changes and justifications. Only after obtaining Reactor Safety Committee approval will the plan be considered modified.

The NRC will review any modification during its regular facility inspection visits.

A revised page 1-2 of the Decommissioning Plan is in attachment.

3. Page 2-2 The list of HRC regulations or guidance does not include Regulatory Guides 8.13, Revision 2, " Instruction Concerning Prenatal Radiation Exposure," or 8.29, " Instruction Concerning Risk from Occupational Radiation Exposure." These two Regulatory Guides should be used when preparing the content for the radiation health and safety training for personnel required to be instructed by 10CFR19.12.

While the listing (in the plan) of NRC regulations / guidance which apply to decommissioning did not explicitly include Regulatory Guides 8.13, Revision 2, " Instruction Concerning Prenatal Radiation Exposure," or 8.29, " Instruction Concerning Risk from Occucational Radiation Exposure, these guides are indeed used in the radiation health and safety training and retraining given to all Reactor Facility personnel, as required by 10CFR19.12. Thus, this NRC concern is addressed.

4. Pages 2-3 You describe the " site" for the purpose of decommissioning as the' CAVALIER cago. Figure 4.1 of NUREG-lll9, " Safety Evaluation Report Related to Renewal of the Operating License for the CAVALIER Training Reactor at the University of Virginia" shows the facility to be the laboratory that the CAVALIER is located in. Please justify not surveying this room and decontaminating, if necessary.

The room in which the CAVALIER pit and tank are located is ordinarily not subject to contamination. (This room is labelled

" Control Room" in the plan's Figure 2.) This room will be surveyed for centamination (i.e. smear samples will be taken) . However, the exposure levels in the room are affected by fuel kept in the Fuel Storage room and uranium in a sub-critical facility, both of which are nearby. The best approach that this licensee can take is I

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4 discussed in response 1.c., involving a demonstration that the 10 mrem per calendar year exposure criterion based on contamination arising from the (former) CAVALIER will be met. The criterion can be met easily because of the short duration between decommissioning "end" and absorption of the area under license R-66.

The staff has no objection to the NRC point-of-view that the CAVALIER " site", for the purpose of decommissioning, be taken to be the laboratory that the CAVALIER is located in. This site definition would be in conformance with Figure 4.1 of NUREG-1119,

" Safety Evaluation Report Related to Renewal of the Operating License for the CAVALIER Training Reactor at the University of Virginia." The site (obviously) can't include the Fuel Storage Room, and the tank in which the sub-critical assembly is located.

5. Figure 2, Page 2-6 Provide information on the areal extent and source of th 0.03 mR/hr exposure rate measured outside of the CAVALIER Room. Also commit to provide measurements of removable contamination on surfaces inside the CAVALIER Room where material might settle or accumulate such as cracks, beams, piping, ledges, and ducts. This survey should also include the inside surfaces of any drains and exhaust air ducts to assure conformance with Regulatory Guide 1.86 surface contamination criteria.

On May 20, 1991, the Reactor Director and Administrator performed a special (unofficial) radiation survey of the areas depicted in Figure 2, to evaluate potential changes which could have occurred since the time of the plan submittal. The results obtained are furnished in an attachment. It is noted that the sub-critical facility has been moved forward a few feet, from the point previously noted in the plan, in the direction of the CAVALIER pit.

The readings were taken with a calibrated BICRON micro-analyst (uR meter), U.Va. asset number 37347, instrument number a040G. The readings registered within the facility were generally taken at waist level. The readings taken outside were at several height levels. It is noted that the external ground-level backcround readings are about 0.02 mr/hr. In comparison, the maximum outside reading was found against a window pane directly adjacent to the sub-critical facility. This reading was 0.04 mr/hr, and clearly due to the subcritical facility located just inside which contains natural uranium slugs. The extent over which higher than background readings are obtained is a few square feet.

5 As /equested by the NRC, the licensee will commit to provide measurements of removable contamination on surfaces inside the CAVALIER room where material might settle or accumulate. Examples of these are cracks, beams, piping, ledges and ducts. The survey will also include the inside surfaces of any drains and exhauct ducts to assure conformance with Regulatory Guide 1.86 surface contamination criterion.

6. Page 2-10 You discuss the transfer of material identified as radioactive waste to the UVAR R-66 reactor license. Please justify transfer to the R-66 license instead of your by-product license. This statement appears in conflict with the information on the bottom of page 2-15.

We still hold to our statements made on page 2-15 regarding radwaste, and don't perceive a conflict to exist with page 2-10, were non-radwaste is covered. Indeed, radwaste will be transferred to the by-product license, while salvageable components (console, for example) may be stored and later used in connection with the UVAR. A CAVALIER component which is lowly-activated, such as a detector or gridplate, may be kept under the R-66 license until the decision is reached that it has no potential future use, hence is radwaste, and should at that point in time be disposed of under the by-product license.

7. Page 2-11 You state that spray painting may be considered as a means of fixing contamination in place. This is an unacceptable method of treating contamination for license termination. Please revise your plan.

The plan was revised and the statement regarding spray painting withdrawn. Please see a revised page 2-11 for the Decommissioning Plan in attachnent.

8. Page 2-15, first paragraph; page 4-1, paragraph 2 The staff position on decontamination to permit release of material to unrestricted use is contained in Regulatory Guide 1.86.

The nominal limit of 5 micro-Roentgen / hour above background at 1 meter from the surface will be applied to the exposure rate measurements. , As a further alternative, the licensee can i demonstrate that the residual radiation from the decommissioned

. facility provides a maximum exposure to an individual of less than the staf f's annual exposure criterion of 10 mrem /yr from potential f

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limited occupancy in the vicinity of the radiation, and/or other radiation exposure pathways. Indicate the manner in which you will apply these alternatives to your decommissioning plan to be consistent with the above-mentioned criteria.

The nominal limit of SuR/hr above background at 1 meter from a surface is a very low value, admittedly, and dif ficult to measure accurately when the background level, in the best of circumstances, is about 20uR/hr. As pointed out in the response to previous questions, the exposure levels in the " laboratory" containing the CAVALIER are as high as 400uR/hr, due to the presence nearby of the Fuel Storage Room and sub-critical facility. Therefore, the staff should elect to use the NRC permitted alternative of meeting the 10 mrem per calendar year exposure criterion. This dose would be associated with radiation originating from CAVALIER originated contamination not removed during decommissioning. This alternative will be achieved during the decommissioning period by positive access control of the Reactor Facility and verification through the issuance of personnel dosimetry.

9. Page 2-16 Please commit to sending a copy of your final survey to the NRC af ter completion of decommissioning activities. Please include in this final survey, the location and current license of any material from the CAVALIER that was transferred to another University of Virginia NRC license. This survey will be evaluated to determine if there is sufficient justification to conduct a NRC confirmation survey to support license termination.

The licensee will send a copy of the final survey of the CAVALIER " site" to the NRC after decommissioning activities are completed. In this survey a description of those materials (as well as their location) which were transferred to another U.Va.

license will be included.

10. Section 2.3 The decommissioning organization and responsibilities are outlined in Section 2.3 of the decommissioning plan, however, the specific names of key personnel and their personnel qualifications relevant to the decommissioning and decontamination are not included. Submit the names and personnel qualifications for the following positions regarding this decommissioning: Reactor Facility Director, Reactor Supervisors, reactor staf f (responsible for specific dismantling tasks), reactor health physicists and the new Radiation Safety Officer as stated in NRC Inspection Report No.

50-62/90-03 and 50-396/90-01.

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7 The Curriculum Vitae of key reactor and health physics staff who will be directly involved in the decommissioning activities are provided in attachment. If staff changes were to occur, any replacement personnel would have comparable background enabling them to assist in carrying out the plan, and would be employed by the licensee.

11. Page 3-6, last paragraph Please provide a collective dose estimate for the CAVALIER decommissioning. Provide a table of the occupational radiation exposures, detailing the assumptions made, calculations used, including the numbers and types of workers involved, doso rates, and projected collectivo doses.

Page 2-3 of the Decommissioning plan states that it is anticipated that the decommissioning will require 2 man-years of effort. This includes the time expended in formulating the plans (first the dismantling plan, then the decommissioning plan) , the preparation of responses to the NRC, in-house reviews, etc... The

" paperwork" accounts for most of the estimate. The workforce who will execute the physical aspects of the decommissicning will be comprised of professional and technical staff of the Reactor Facility with additional health physics support supplied by the Radiation Safety Office. It is not expected that any outside contracted assistance will be used. A review of the floor plan and radiation doses in and around the pit show exposure rates of about 0.02 mr/hr in the pit, and 0.05 mr/hr in the Control Room.

Conservatively assuming thac 20 man-hours of work will take place in the CAVALIER Control Room, and another 20 nan-hours in the pit, the collective dose is estimated at 1.4 E(-03) man-rem.

12. Section 3.2, Radiation ProtectioD Provide the following information:
a. The criteria for selecting portable and laboratory technical equipment and instrumentation for performing radiation and contamination surveys.

The principle sources of radiation and contamination most likely present are beta-gamma emitters such as Co-60, Eu-152, Cs-137 (as mentioned on page 4-2 of the plan) Ni-59, Zn-65, and Nb-94 (as mentioned on page 2-12 of the plan). Since the CAVALIER reactor components contain aluminum and not steel, Na-24 and Al-28 would also have been produced. These nuclides are short-lived, however. A variety of survey instruments routinely in use at the UVAR Facility are adequate for performing the required surveys.

Sensitive detection instruments such as an Eberline E-120 with a

8 pancake GM, Eberline Rm-14 with pancake GM, or Eberline ESP-1 with HP-270 GM can be used to identify areas of contamination and measure relative exposure rates. They can also be used for frisking personnel and objects for contamination. All of these instruments have audio capability for ease of survey, and their use is familiar to the staff since they are used routinely for other required survey at the Facility.

Instruments such as the Victoreen 450 ionization chamber, ESP-1 and HP-270 GM with energy compensation and beta shield, and Eberline E-520 with HP-260 probe can be used to measum exposure rates. In addition, a Bicron microanalyst with an internal gamma scintillation crystal may be used for terminal surveys where higher sensitivity may be needed to measure near background exposure rates.

Measurement of removable surface contamination requires sensitive detection equipment capable of producing count ratec from alpha, low- and high-energy beta and gamma contaminetion. A GM and sample holder and a Tennelec alpha / beta proportional counter can be used to provide these counting capabilities.

b. The description of the method, frequencies, and procedures for conducting radiation surveys.

An initial complete radiation survey of the site will be performed using one of the sensitive detection instruments mentioned in paragraph a. above. Relative exposure rates and l centamination levels will be established initially. At positions of higher exposure rates, individual determinations of dose or exposure rate will be made . with exposure rate measuring instruments.

Areas of contamination and maximum exposure rates will be clearly marked until decontamination is completed.

Surveys will be performed as needed as work progresses. All items from the site will be surveyed and decontaminated if necessary prior to removal from the site. Daily radiation- and l- contamination surveys of areas adjacent to the site will be

! performed at the end of each work day to prevent contamination of areas outside of the site in uncontrolled areas. All personnel will be surveyed before exiting the site. The terminal HP survey will consist of radiation and contamination surveys to insure that t

the release criteria stated in paragraph 1.c. of this response are met. This survey will be conducted as stated on page 2-15 of the decommissioning plan.

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c. If the radiation surveys identified " hot spots" that may require chipping of concrete for removal, describe the additional radiation protection precautions which would be used to preclude the spread of contamination and assure maintaining of ALARA radiation exposures (airborne radioactivity pathway) to workers.

As stated on pages 2-3 and 3-9 of the plan, it is not expected that any chipping of concrete will be necessary. However, should we find this is necessary, these areas would most likely be small areas and a temporary tent or glove box type arrangement could be constructed over the area requiring chipping. This should prevent exposure of personnel and prevent spread of any contaminated chips and dust in or outside of the site. In addition, the area being chipped could be dampened to minimize dust generation. '

d. Describe the method you will use (e.g. , GeLi spectrometer) to identify radionuclides found in swipes, samples, etc. that will be taken during dismantling.

A GeLi or HPGE gamma spectrometer will be used to identify radionuclides on suipes, or in samples taken during the dismantling.

e. Is it possible that contaminated water mist could form during washing of the reactor tank? If so, what additional precautions are to be taken to control the spread of contamination?

No, we do not believe it is possible that water mist will form during the washing of the tank. As stated on page 2-11 of the plan, decontamination activities will consist of simple washing and -

wiping. No high pressure spray, etc., will be used in the decontamination process.

13. Page 3-8, laat 2 paragraphs, Radioactive Waste Manacement
a. Please provide an estimate of the maximum concentration of solid radwaste that is anticipated to be generated during the decommissioning. Also provide an estimate of the dose rate at contact with such waste, Due to the minimum number of items which will be disposed of and the low operation power and frequency at which the CAVALIER was operated, it is difficult to estimate the maximum concentration of solid radwaste that might be generated. A very conservative estimate of the maximum concentration of radioactive material in the solid radwaste would be 10 uCi/kg with the likelihood that this overestimates the concentration by 1 or more orders of magnitude.

The dose rate at contact with such waste would consequently be very low.

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b. Provide concentrations of principel radionuclides in the 11,000 liters of water that were contained in the CAVALIER'S tank. Also describe the steps you took to minimize environmental impact during the disposal of this water.

The CAVALIER tank was drained directly to the onsite pond through a drain in the pit which the tank sits in. The recorded volume of water released was 2450 gallons (9300 liters). The concentration of radioactivity in this water, as measured by gross beta analysis, was 2.1 E-8 uCi/ml. As this was below the MPC for effluents for which the specific radionuclides are not known, no isotopic analysis was performed on this water. As this water was released directly to the onsite pond, there was no direct exposure to the offaite environment. This water mixed with the pond water which is routinely released offsite per SOP. Consequently the impact to the environment was no greater than the impact from a routine release of pond water.

14. Page 4-2 To terminate the CAVALIER facility license the requirements of Regulatory Guide 1.86 and the limits on radiation fields must be met. After termination, the former restricted arca of License No.

R-123 can become a restricted area for another license after proper documentation. Another option is that the radioactive material formerly on License no. R-123 can become a restricted area for another license after proper documentation. Another option is that the radioactive material formerly on License No. R-123 is transferred to another license. However, the area cannot be retained as a restricted area under Licence No. R-123 with the license terminated. Please restate the bottom of this page to be consistent with this guidance.

The licensee agrees that the CAVALIER " site" can't remain a restricted area under License R-123 after this license is terminated. This is not the intent. Therefore, the wording at the bottom of page 4-2 has been revised to indicate clearly that the area will be turned over to License R-66 the moment that the CAVALIER license is terminated. A revised page 4-2 is attached.

It is noted that the CAVALIER room should be renamed following license termination to avoid confusion.

15. Page 6-1 The dacommission order supersedes the existing 3icense for the purpose of decommissioning. Any current Technical specifications that you deem are necessary for safe decommissioning of the CAVALIER reactor should be referenced or restated as part of the decommissioning plan.

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11 The C1.VALIER has boon defuelled as per SOP's and in a shutdown mode for K several years. Since its Technical Specifications apply to sperational requirements, none were found to be needed for the safe decommissioning of the reactor. Hence, no TS will apply af ter the decommissioning order is issued by the NRC.

16. Page 6-1 Unless a specific exemption is granted, reference to the CAVALIER reactor in the facility emergency plan should be retained until the license is terminated by the NRC, not after the completion of decommissioning activities.

The licensee loosely equated the term " completion of decommissioning activities" with " license termination." As requested by the NRC. the CAVALIER reactor will be referenced in the Emergency Plan until its license is terminated by the NRC.

17. NRC Inspection Report No. 50-62/88-03(1)

In this NRC inspection, the following weaknesses were identified: " housekeeping" practicos within the UVAR reactor room, documentation of self-reading dosimeter (SRD) and environmental exposure measurement records, and also the need to improve the timeliness of portable air sampling equipment calibrations.

Because these weaknesses may in a generic manner impact the CAVALIER decommissioning, briefly discuss the resolution of these concerns.

During the time since the NRC identifled these weaknesses in support of the reactor operation (1988-1991), there has been an aggressive commitment to correct these valid concerns. Management and health physics attention at the reactor has been keen to constantly review these items, in particular, to ensure that they do not recur. The response to the Inspection Report acknowledged the same and the commitment to the implementation of corrective action has been, and still is, very strong.

ORIGINAL SUIntITTAL l

i i Following the CnVALIER decommissioning and termination of its I operating license, the University of Virginia understands that authorization for possession of special nuclear material (10 CFR Part 70, "Special Nuclear Material"), byproduct material (10 CFR Part 30, " Rules for General Applicability to Licensing of Byproduct Material"), and source material ( 10 CFR Part 40, " Licensing of Source Material") under the CAVALIER license will not be retained.

However, such authorization will be retained under the UVAR license.

It is emphasized that the CAVALIER facility " site" (defined as the CAVALIER's reactor pit, tank and cage area only, please see Figure 1) will not be converted to an unrestricted area following CAVALIER license termination, from both the physical security and radiological points-of-view. This is neither necessary nor desirable, given that the UVAR and CAVALIER are both located within the same building (named the Reactor Facility). Since the removal of radioactive materials to reduce radiation and contamination levels to permit unrestricted use of the CAVALIER site is mandatory for a full license termination, the licensee will take the necessary steps to meet this requirement, in the CAVALIER reactor pit, tank and cage, on a one timu basis. Therefore, upon successful completion of the CAVALIER dismantling operations, a terminal contamination and radiation survey will be performed to document the release levels of the CAVALIER " site" for the purpose of CAVALIER license termination only.

It is anticipated that the present CAVALIER pit and cage could be used af ter decommissioning for experiments involving radioactive materials, and that the low levels to be verified in the terminal survey will not necessarily be maintained indefinitely.

The licensee does not expect to change this plan once it has been approved by the NRC, because it is general and not extremely detailed. It has been formulated to accommodate some change through implementing procedures and methods which do not require NRC approval. However, even the most perfect plan may need alteration in light of new facts. Changes to this plan which constitute unreviewed safety questions au defined in 10 CFR-50.59 will be made only with the specific approval of the NRC Division of Reactor Licensing. Changes which do not constitute unreviewed safety questions as defined in 10 CFR 50.59 nay be made if the proposed changes are reviewed and approved by the Reactor Safety Committee. Minor changes which do not change the original intent of this plan may be made with the approval of the Reactor Director, who will describe these minor changes in a follow-up information memoranda to the Reactor Safety Committee.

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REVISED 6-3-91 Following the CAVALIER decommissioning and termination of its operating license, the University of Virginia understands that authorization for possession of special nuclear material (10 CFR Part 70, "Special Nuclear Material"), byproduct material (10 CFR Part 30, " Rules for General Applicability to Licensing of Byproduct Material"), and source material ( 10 CFR Part 40, " Licensing of Source Material") under the CAVALIER license will not be retained.

However, such authorization will be retained under the UVAR license.

It is emphasized that the CAVALIER facility " site" (defined as the CAVALIER's reactor pit, tank and cage area only, please see Figure 1) will not be converted to an unrestricted area following CAVALIER license termination, from both the physical security and radiological points-of-view. This is neither necessary nor desirable, given that the UVAR and CAVALIER are both located within the same building (named the Reactor Facility). Since the removal of radioactive materials to reduce radiation and contamination levels to permit unrestricted use of the CAVALIER site is mandatory for a full license termination, the licensee will take the necessary steps to meet this requirement, in the CAVALIER reactor pit, tank and cage, on a one time basis. Therefore, upon successful wmpletion of the CAVALIER dismantling operations, a terminal contamination and radiation survey will be performed to document the release levels of the CAVALIER " site" for the purpose of CAVALIER license termination only.

It is anticipated that the present CAVALIER pit and cage could be used af ter decommissioning for experiments involving radioactive materials, and that the low levels to be verified in the terminal survey will not necessarily be maintained indefinitely.

The licensee does not expect to change this plan once it has been approved by the NRC, because it is general and not extremely detailed. The methodology which will be used for making changes to the decommissioning plan, should the need arise, is as follows.

The staff will prepare a formal written submittal for review and approval by the Reactor Safety Committee. This packet will contain the proposed changes and justifications. Only after obtaining Reactor Safety Committee approval will the plan be considered modified. The NRC will review any modification during its regular facility inspection visits.

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The following regulations (Code of Federal Regulations, CFR) or guidance, in total or in part, have been identified as possibly pertaining to the dismantling of a non-power reactor such as the CAVALIER:

Title 10 of CFR Subpart and Section Part 2 Subpart A 2.100 (a) (1) ; Subpart B 2.204; Subpart G 2.701, 2.708);

Part 20 20.101, 20.103, 20.105, 20.301-311, Part 40 40.44; Part 50 50.82, 50. 4 (b) (1) , 50.33, 50.34, 50.36, 50.04, 50.56, 50.59, 50.64, 50.90, 50.91(a), 50.92; Part 51 51. 2 0 (b) ( S) , 51.23; Part 70 70.24, 70.34, 70.42, 70.54, Part 72 72.18, 72.38, 72.39, 72.51, 72.52, 72.54; Part 73 73.60; Part 170

  • 49 CFR, Parts 173 through 178.

Also NRC Generic Letter No. 84-18 from Darrell Eisenhut, dated July 6, 1984.

Additionally, " Guidance and Discussion of Requirements for Application to Terminate a Non-Power Reactor Facility Operating License", Rev.1, Sept. 15, 1984 by Div. of Licensing,,NRC.

The ANSI /ANS-15.10-1981 guide on the decommissioning of research reactors, and ANSI N13.12, have also been consulted for the formulation of this decommissioning plan.

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ORIGINAL SUBMITTAL 2 . 2. Decommissioning Activities, Tasks, and Schedule The area 1ccated within the confines of the CAVALIER cage will constitute the CAVALIER " site" for purposes of decommissioning.

The wire screen cage surrour. ding the tank is not contaminated and will likely remain in place. There are physical security alarms installed at or within the cage which could be deactivated once the operating license has been terminated. As there is a strong possibility that the CAVALIER tank will be left in place in the present CAVALIER pit area for possible use in other radiation experiments, 1ergetic efforts will be made to decontaminate the tank, by chemical and/or other means.

The fuel storage room should remain as it is at present. The barriers to entry into this room and into the CAVALIER room should remain in place after the CAVALIER dismantling. These barriers, with their penetration alarms, are described in the physical security plan for the Reactor Facility. This plan was updated by the reactor staff and the changes reviewed and approved by the Reactor Safety Committee, to take into account the planned effect of a CAVALIER decommissioning.

Also left in place, in a corner of the CAVALIER room not part of the CAVALIER site, is the natural uranium subcritical assembly.

Dismantling activities will be performed during normal single 8-hour shifts, 5 days per week. A total staff effort of about 2 man-years is estimated for the completion of the decommissioning plan. The activities do not involve major construction or demolition aspects. The disposal of systems normally associated with larger research reactors, such as activated / contaminated beam tubes, rabbit systems, thermal column, primary system piping, resin demineralizer system, heat exchanger system, radwaste storage room

&/or tank, cooling tower, graphite reflector elements, emergency discharge basin, hot cells and laboratory hoods, will not be necessary in the CAVALIER decommissioning, because they do not exist. Explosive techniques, or remote cutting apparatus will not be needed.

The required essential support systems and services for the CAVALIER dismantling such as power, heat, water, communications, safety, security, etc... Will be maintained by virtue of the continuation of operations of the UVAR reactor in the Reactor Facility.

2-3

REVISED 6-3-91 1

2.2 Decommissioning Activities, Tasks, and Schedule The area located within the confines of the CAVALIER cage and Control Room will constitute the CAVALIER " site" for purposes of decommissioning. The wire screen cage surrounding the tank is not contaminated and will likely remain in place. There are physical security alarms installed at or within the cage which could be deactivated once the operating license has been terminated. As there is a strong possibility that the CAVALIER tank will be left in place in the present CAVALIER pit area for possible use in other radiation experiments, energetic efforts will be made to decontaminate the tank, by chemical and/or other means.

The fuel storage room should remain as it is at present. The barriers to entry into this room and into the CAVALIER room should remain in place after the CAVALIER dismantling. These barriers, with their penetration alarms, are described in the physical security plan for the Reactor Facility. This plan was updated by the reactor staff and the changes reviewed and approved by the Reactor Safety Committee, to take into account the planned effect of a CAVALIER decommissioning.

Also left in place, in a corner of the CAVALIER room not part of the CAVALIER site, is the natural uranium subcritical assembly.

Dismantling activities will be performed during normal single 8-hour shifts, 5 days per week. A total staff effort of about 2 man-years is estimated for the completion of the decommissioning plan. The activities do not involve major construction or demolition aspects. The disposal of systems normally associated with larger research reactors, such as activated / contaminated beam tubes, rabbit systems, thermal column, primary system piping, resin demineralizer system, heat exchanger system, radwaste storage room

&/or tank, cooling tower, graphite reflector elements, emergency discharge basin, hot cells and laboratory hoods, will not be necessary in the CAVALIER decommissioning, because they do not exist. Explosive techniques, or remote cutting apparatus will not be needed.

The required essential support systems and services for the CAVALIER dismantling such as power, heat, water, communications, safety, security, etc... will be maintained by virtue of the continuation of operations of the UVAR reactor in the Reactor Facility.

2-3

Figure 2  : CAVAL.lER Room Typical Radiation Survey Results _  !

. ;. t

- . , ORIGINAL SUBMITTAL.1 t

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, ,2 Control Room 4 *l -

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,.9 Fue1 - 4 8

  • ' ' S t o rage  !

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j CAVALIER Tank & Pit '

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.o2 mr/hr % r - -

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pd. " Facility

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l' c l * , l ' * ' ' ' * * * * {,,-

Outside nullding .03 mr/hr i -y g

Instrument:_ BICRON (Micro-Analyst) Date surveyed: _ June 19. 1989 i

A survey of the CAVALIER reactor tan) was taken on June 13, 1989 to determine both dose _ rates and contamination Icvels. The results of this survey are as follows:

l liighest dose - rate found:

0.05 mR/hr on top of grid plate Swipes (approximately 100 cm^2 each, net after background subtraction)

Each swipe was counted for 15 minutes and the two o errors range from-l 20 to 40 percent, o Location DPH / 100 cm^2 1 grid plate 17 2 grid plate 30 3 detector 12 4 wire mesh t 0 5 tank wall 3 6 tank wall 4 7 tank floor 5 8 source tube 11 9 outside BF 3 tubes 32 10 *ank drain 3

! 2-6

Sample Hmm Counting Lab .

OD o  :

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1

- 1 CE o O -

, ,- s 1, -

-u Oy

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4.:.':' OsVaT, in . - .7

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. Machine Shop l

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  • _ g,g Sub. Critical

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  • s' O.Ulb Readings in Mr/hr Instrument Used - BICRON Date Surveyed: 5-20-91 Ground near pond - 0.02 Mr/hr Top of Waste Tanks - 0.023 Mr/hr i

i SURVEY OF CAVALIER AREA i

i  !

l

ORIGINAL SUlmlTTAL According to the decommissioning rule, decommissioning activities do not include the removal and disposal of nonradioactive structures and materials beyond that necessary to terminate the NRC 1iconse. However, the consolo components will be checked for contamination and the majority of these may go into storage or be used elsewhere at the Reactor Facility. If not needed, these components may also be properly disposed of as waste.

Radioactive components may be kept under the UVAR R-66 license until disposed of as radioactive waste.

The former criticality monitoring _ system for the Reactor l Facility's Fuel Storage Room was powered from the CAVALIER reactor console. To permit the de-energizing and dismantling of the console, a new independent criticality monitoring system was installed in parallel- to the present system. Following an operational testing period and Reactor Safety Committee approval, the new system replaced the former system. This action clears the way for a completo disassembly and removal of the CAVALIER console.

The CAVALIER's aluminum grid plate was last surveyed on 6 I 89 and the (Figure 2). dose rate on contact was found to be less than 1 mR/hr  ;

The dimensions of the base plate are 36 in, by 36 in. 1 by 1 in., and of the two center plates (with twenty-eight 3 in, holes) are 25 in, by 25 in, by 0.5 in., with a combined weight of about 150 lbs. Underwater cutting of core support structures is not anticipated. Bolted rather than welded construction techniques were used in assembling those structures. The CAVALIER grid plate and core support structures will be kept either in the UVAR pool, the source sto age room or the hot cell, at the discretion of the licensee. Eventually they will be used or disposed of in an appropriate manner.

steel The four CAVALIER control rods are made from boron-stainless with an aluminum jacket and are the most radioactive components of the reactor.

as follows:

The dose rates measured on 5-4-84 were ROD CONTACT READING

_ (mR/Hr) 1 200 2 350 3 400 4 1 It should be noted that the high values obtained for three of these rods is due to their use at one time in the UVAR, before their transfer to the CAVALIER.

2-10

ORIGINAL SUBMITTAL The control rods were transferred to the Reactor Facility's source storage room following the final defuelling of that reactor.

However, storage location and future use will be at the discretion of the licensee. Good HP practices will be observed in this undertaking. Use of one or more of these rods in the OVAR core at some future date is not precluded.

The aluminum tank in which the CAVALIER core sat measures 67 in, by 67 in, and is 11 feet deep, with a minimum thickness of 0.25 inches. Its total weight is about 1950 lbs. The tank volume is 2970 gallons, and it has been normally filled with 2900 gallons of reactor grade water. The tank was emptied following the removal of the CAVALIER fuel and rods as per SOP's. Decontamination of the tank walls will be accomplished by washing and wiping. If necessary, spray painting may be considered as a means of fixing contamination in place. The decontamination method to be ultimately used will be at the discretion of the licensee.

The CAVALIER tank will most likely remain in place following decommissioning, and may prove useful for other experimental uses involving radiation sources. However, the licensee reserves the option of later removing, disassembling and disposing of the tank under the UVAR license requirements.

The automatic reactivity insertion system (ARIS) tank held a solution of boric acid. This corrosive solution was discarded after CAVALIER defuelling. The ARIS tank is neither contaminated or activated and will be lef t in place or removed at the discretion of licensee.

The Reactor Facility's liquid waste tanks will remain in service for the UVAR. Liquid wastes from CAVALIER decommissioning can be pl.mced in these waste tanks and disposed of as per UVAR SOP's.

The nature of operation of the CAVALIER was such that the likelihood of significant contamination or activation is extremely low. The CAVALIER was operated at powers below 100 W on an infrequent basis. A distance of about 2 feet separated the core and the tank wall. This distance will have served to prevent major activation of the tank and concrete biological shield. The reactor fuel has existed in a sealed form, and no fuel leaks were ever detected. The fuel did not receive sufficient exposure to accumulate a significant fission product inventory.

2-11

REVISED 6-3-91 The control rods were transferred to the Reactor Facility's source storage room following the final defuelling of that reactor.

Ilowever, storage location and future use will be at the discretion of the licensee. Good llP practices will be observed in this undertaking. Use of one or more of these rods in the UVAR core at some future date is not precluded.

The aluminum tank in which the CAVALIER core sat measures 67 in, by 67 in, and is 11 feet deep, with a minimum thickness of 0.25 inches. Its total weight is about 1950 lbs. The tank volume is 2970 gallons, and it has been normally filled with 2900 gallons of reactor grade water. The tank was emptied following the removal of the CAVALIER fuel and rods as per SOP's. Decontamination of the tank walls will be accomplished by washing and wiping. The decontamination method to be ultimately used will be at the discretion of the licensee.

The CAVALIER tank will most likely remain in place following decommissioning, and may prove useful for other experimental uses involving radiation sources. Ilovever, the licensee reserves the option of later removing, disassembling and disposing of the tank under the UVAR license requirements.

The automatic reactivity insertion system (ARIS) tank held a solution of boric acid. This corrosive solution wan discarded after CAVALIER defuelling. The ARIS tank is neither contaminated or activated and will be lef t in place or removed at the discretion of licensee.

The Reactor Facility's liquid waste tanks will remain in service for the UVAR. Liquid wastes from CAVALIER decommissioning can be placed in these waste tanks and disposed of as per UVAR SOP's.

The nature of operation of the CAVALIER was such that the likelihood of significant contamination or activation is extremely low. The CAVALIER was operated at powers below 100 W on an infrequent basis. A distance of about 2 feet separated the core and the tank wall. This distance will have served to prevent major activation of the tank and concrete biological shield. The reactor fuel has existed in a sealed form, and no fuel leaks were ever detected. The fuel did not receive sufficient exposure to accumulate a t ignificant fission product inventory.

2-11

l l

ORIGINAL SUBMITTAL The terminal HP survey gamma radiation level survey, to be reported to the NRC in appropriate units, will be performed within the CAVALIER cage with a calibrated low-level reading instrument held at appropriate location at one meter above floor level.

Within the CAVALIER tank and pit and in the immediate vicinity where the CAVALIER core was located, the instrument will be held at 1 centimeter from surfaces. The ceiling within the CAVALIER cage will also be surveyed. In general, the survey instrumentation to be used will have sufficient range, accuracy and sensitivity to determine that compliance with the criteria referenced in this plan and the Facility's SOP's are met. A release criterion of 10 uR/hr above natural background when measured at one meter from a surface will apply. Natural background levels will be established at on-site locations that have not been exposed to a neutron flux or contamination.

Contamination surveys will be performed on CAVALIER equipment removed from the CAVALIER room during the dismantling phase. The terminal contamination survey will cover the object left in place, for example, the interior of remaining CAVALIER tank piping, the tank and pit walls, and selected locations on other surfaces within the CAVALIER cage. The survey will consist of measurements of removable 2

contamination. Small area smears (of approximately 100 cm ) will be taken with dry filter paper disks, in accordance with standard industry practico, and counting the smear samples in a laboratory (gas proportional) low-background counter, fer beta / alpha activity.

Guide The release contamination criteria specified in Regulatory 1.86's, June 1974, Table I will be used. Count rates obtained with the low-background counter will be converted into surf ace contamination levels for comparison with the limits, using internal HP procedures which call for counter calibration with NBS traceable beta and alpha sources. Smears taken will be identified and analyzed in accordance with HP procedures. Should contamination be found that is fixed and difficult to remove, attempts will be made to identify the nuclides involved by gamma spectroscopy, in our NAA lab supported with several germanium counters.

Radwaste generated during the dismantling will be tracked on the Reactor Facility's By-product Materials License, if justified.

Preparation, packaging, storage and disposal of radwaste shall be in compliance with the license. Waste intended for disposal shall be sent to a licensed vaste burial f acility, in accordance with the applicable provisions of 10 CPR Parts 61 and 71, at a date convenient to the licensee.

2-15

- - - . - - - - . - - --. .. - . . . ~ - , - - - . - - -

o .

ORIGINAL S1111MITTAL l

The following CAVALIER records and logs shall be prepared and retained at the Reactor Facility until tho termination of the t'9C Licenso R-123 a) CAVALIER operational logbooks and documents (SAR, old and now Technical Specifications, old and now SOP's).

b) CAVALIER Decommissioning Plan and eventual QA/QC records associated with execution of the plan.

c) IIP radiation surveys of the CAVALIER reactor room. ,

d) Radiation exposures records for personnel associated with tho i physical dismantling operations of the CAVALIER.

c) CAVALIER fuel inventory and transfer records.

f) Content and disposition of solid wasto containors.

g) CAVALIER facility as-built drawings.

h) Records of inspection of physical barriera (same as Roa: tor Facility Security Plan inspection records).

i) Abnormal occurrences, such as spills, 1

j) Reactor Safety Committoo mooting minutes A summary of the CAVALIER decommissioning efforts and results will be documented in the appropriato Annual Report for the Reactor Faci.'Lty that is sont to the NRC overy year. Following this

' summary, it is not likely that mention of tia CAVALIER will nood to be made in future annual reports.

A NRC-314 form cortifying the disposition of accumulated decommissioning wastos will be completed and submitted to the NRC.

l i

The units for reporting radiation and radioactivity to the NRC shall be as follows:

Beta and/or Gamma radiation: uRad/hr at 1 cm and 1 motor from surfaces Radioactivity (alpha, etc.)  : dpm or uC1/100 sq.cm, removable and fixed,  ;

on surfaces; '

uCi/ml for liquids; pC1/g for solids.

i 2-16 o t

, . - . ----,,--r-----

. . j i

ORIGINAL SUIWITTAL 3.2 Radiation Protection Tho decomminait' 7 plan is an aid in minimizing worker exposuro. Occupational dosos will bo kept ALARA by (1) performing radiation surveys to identify radiation areas, (2) minimizing the exposure of personnol to radiation exposure by limiting the timo spent in high radiation areas, by using remeto devices, and by using shielding, (3) promptly decontaminating any areas accidentc11y contaminated during the course of operations, (4) careful accounting of the radiation donos as they are being incurred, to taka correctivo action as necessary, (5) the wearing of throwaway garments whero called for, and (6) body frisking upon leaving the work area, as necessary. It is noted that the Reactor Facility has a record of very low occupational exposures of its personnel.

Exposure to radiation and contamination will be controlled by the Roactor liealth Physicist and !!P Technicians. Radiation exposuro pathways normally considered for airborno roloases are (1) direct external exposures, (2) inhalation, and (3) ingestion of food products. The ;3rimary hypethetical sources of radioactivo offluent from routino dasmantling are radioactivo liquid norosolo produced during localized chemical decontamination, vaporized radioactivo metal released during equipment or piping removal, and radioactive concreto dust resulting from concreto removal.

It is noted again that the decommissioning of the CAVALIER will ngt involve the disposal of svstoms normally associated with larger research reactors, such a r. activatod/ contaminated beam tubos, rabbit systems, thermal co' amn, primary system piping, resin domineralizer system, heat exch- ,er system, radwasto storage room

&/or tank, wasta evaporator,- cooling tower, reactor bridge, emergency rotontion basin, hot cells, laboratory hoods and exhaust stack. Demolition of concreto structures, or soil removal, are not planned, and the contamination lovels are minuto at any rato.

Therefore, it appears highly unlikely that the dismantling crew will be subject to thoso sources and pathways, specially when l- common sense health physics practicos are followed.

I It is very difficult to estimate the occupational doso resulting from the dismantling of a small training reactor. The occupational estimato of 18 man-rom for the decontamination of a i

research reactor is made in NUREG/CR-1756 pg. 12-1. It is not unreasonable to estimate that for a training roactor auch as the CAVALIER, subject to the considerations previously stated, the doso may well be lower by a factor of 1000 or more, considering also that the CAVALIER dismantling involves mostly defuelling (already completed without incident) and very little decontamination work.

3-6

OltlGINAL SUIMITTAL 3.3 Radioactive Wasto Management The CAVALIER's !!EU fuel olomonts are of exactly the same type as thoso presently used in the UVAR. Due to the infrequent and short periods of CAVALIER reactor operation and the low powers

, achiuved, the olomonts are not very radioactive (maximum doso rato

-of about 2 mR/hr at 1 foot). Thoroforo, an easy, (uick physical in-house transfor of CAVALIER fuel to the Fuel Storago Room or the

' UVAR pool, and inventory transfer to the UVAR licenso was possiblo.

The UVAR 11conso's fuel limit is such that all CAVALIER fuel could be transferrod to it.

It should be noted that the Roactor Facility no longer stores fresh !!EU fuo'l within the accure fuel storage room on its promises.

Ilowever, "used" IIEU reactor fuel olomonta of low activity may be stored thoro safely and legally. It is intended that the CAVALIER fuel elements be used in the UVAR until it's conversion to LEU, and that thov be eventually shipped off-site as spent fuel. The spent fuel shipments costs will be covered by the DOE oponsored LEU conversion program for the UVAR.

The residual radioactivo items associated with the CAVALIER may be kept temporarily in the UVAR pool, or in waste drums stored in the unused hot cell, or in other areas and conditions at the discretion of the licensoo, until a suf ficient number of drums havo

' gathored solid radwasto.

to warrant shipment for burial as low specific activity Airborno radioactivo roloaco due to CAVALIER dismantling can be predicted to rango from non-existent to negligible amounts. The dismantling of the CAVALIER will bo dono in a closed room, which does i.ot havo a stack to the exterior environment. No credible mechanisms for airborno release outside of the Reactor Facility are forosoon as a result of the benign techniques to be employud.

The amounts of solid low-specific-activity (LSA) radwasto that are anticipated to be generated are small, cortainly no more than soveral barrels. This waste avontually will be sont off-site for legal disposal in a licensed burial ground, probably at Barnwell, South Carolina. The principal environmental impact of solid wasto disposal is the land area that must be committed to this activity.

Shipping of those wastos may also involve a very low dose to the drivers and possibly to persons along the transportation route.

Clea rly, the environmental impact of this aspect of-the CAVALIER decommissioning will be minusculo.

about 11,000 litors. It The water contained in t.ho CAVALI ER tank has a volumo of originally was obtained from the UVAR, and has very low activity. Following CAVALIER coro dofuelling it was disposed of in conformity with the Reactor Facility's procedures with negligible environmental impact.

3-8

_ _ _ . - _ . - _ _ - - - - - _ - . - _ _ - -- - - . _ . ~ . _ _ _ _

ORIGINAL SUMITTAL b) Other than surface contamination Isotopes such as co-60, Eu-152, and Cs-137 may oxist in concreto, components, structuros, etc... The radiation level from those isotopos at a distance of one motor from the surface should be loss than 5 uR/hr abovo natural background (as measured at a comparable uncontaminated structure or exterior soil surfaco), or 10 mrom/yr above background, considering reasonable proximity and l occupancy (from NRC Div. of Lic.'s " Guidance and i Discussion of Requirements for an Application to Terminato a Non-Power Roactor Facility Operating License").

From NUREG/CR-1756, pg. 6-7, the following is quotod: "a residual radioactivity level for permitting rolease of a nuclear facility for unrestricted uso should be consistent with ALARA. Guidance in establishing such a lovel is b3st i expressed in terms of a value which bounds the dose for the majority of nuclear facilities.

This value is datormined to be 10 mrom/yr whole-body done equivalent..." l NUREG/CR-1756 contains tables on page 2-12 and page 9-10 '

depicting-acceptable residual radioactivo contamination lovels insido a reference research reactor. '

Those tables '

are reproduced in our Table 1.

It.is the intention of the University of Virginia Reactor Facility staff to make reasonable efforts to decontaminate the CAVALIER reactor pit, following reactor dismantling, to moot the '

levels for-the terminal HP survey required for license termination.

However, the area presently occupied by the CAVALIER will not be released for unrestricted access. Therefore, the radiation doso standards to be applied within the Reactor Facility, and specifically the CAVALIER room following CAVALIER operating license termination, will be for individuals in restricted areas (10 CFR 20.101).

The purpose of the terminal post-dismantling - radiation and contamination surveys is to provide assurance that the CAVALIER-site moots the prescribed radioactivity levels that permit its safe and legal use following- decommissioning. In the case of the CAVALIER site, the area is ultimately destined for further rostricted use _within' the Reactor Facility building that also houses the UVAR. Hence, the requirement that this sito meet'the release critoria necessary for operating liconne termination should be restricted to a one-time affair.

4-2

,_ -..,.,.-,r ---.o_, r,., , ., se, ,..m,c... .%, ,e., ..._-.%e..- .-m_. . , , , - - . ,,,,m-n-.. ,-E.._-,_,,Umm ..m , %., ..,,,p.v

REVISED 6-3-91 b) Other than surface contamination Isotopos such as Co-60, Eu-152,_and Cs-137 may exist in concrete, compononts, structures, etc... The radiation lovel from those isotopos at a distance of one motor from the surface should be less than 5 uR/hr abovo., natural background (as measured at a comparablo uncontaminated structure or exterior soil surface), or 10 mrom/yr above background, considering reasonable proximity and occupancy (from NRC Div. of Lic.'s " Guidance and Discussion of. Requirements for an Application to Terminate a Non-Power Reactor Facility Operating License").

From NUREG/CR-1756, pg. 6-7, the folicwing.is quoted: "a residual radioactivity lovel for permitting releano of a nuclear facility _for unrestricted uso should bo consistent with ALARA._Guidanco in establishing such a level is best expressed-in terms of a value which bounds the dose for the majority of nuclear facilities. This value is datormined to bo 10 mrom/yr wholo-body doso equivalent..."

NUREG/CR-175G contains tables on pago 2-12 and page 9-10 )

depicting acceptable residual radioactivo contamination  !

IcVels inside a reference research reactor. Those tables are reproduced in our Tablo 1.

It ~is the intention of the University of Virginia Reactor Facility staff to make reasonable efforts to decontaminate the CAVALIER reactor pit, following reactor dismantling, to meet the levels 1for the terminal HP survey required for licenso termination.

However, the area presently occupied by the CAVALIER will not be released for unrestricted accoJa. Therefore, the radiation doso standards to be applied within tho- Reactor Facility, and specifically the former CAVALIER room following CAVALIER operating license termination, will be for individuals in restricted areas (10 CFR 20.101), because of turn-over of tho area to licenso R-66 (UVAR).

The purpose of tho. terminal post-dismantling radiation and contamination surveys is to provide assuranco that the CAVALIER site meets the prescribed radioactivity levels that permit its safe and legal use following decommissioning. In - the case of the CAVALIER site, the area is ultimately destined for= further restricted use within the Reactor Facility ovilding that also houces-'tho UVAR. Hence, the requirement that this site meet.the release criteria necessary for operating license termination should be restricted to a one-tino affair.

4-2

, , . . . . - y .- ,, _my.-_.~....r,, _, . , . _ , ~ , ., . . , _ , _ , , _ ~ _r,,-,.c , . . ~ . . . , , - . . , . . . , n

OltlGINAt StilellTTAI'

6. TECliti1 CAL SPECIPICATIO!1S Ill PIACE DURI!1G DECOMMISS10111110 The federal regulation that outlinen the information and proceduren nocennary for the termination of an operacing licence appearn la 10 CFR 50.82. The application for termination of license in nubmitted at the time of initiation of decommiculoning.

Decomminnioning in carried out under an amended licenne in accordance with the terms of a decomminnioning order, The licenne in terminated only af ter the 11RC is naticfied that decommincioning has been properly completed. 14ormal]y, an amended Part 50 licenne authorizing "ponnension-only" will bo lunued prior to the decommincioning order, to confirm the nonoperating ntatun of the reactor and to reduce nome curve 111ance requirements which are important only for operation.

The 11RC in expected to follow itu cuntomary procedures, not out in 10 CFR Part 2 of the 11RC Rulen of Practice, in amending Part 50 licennes to implement the decomminnioning proceno. The licencee's authority to pouceos radioactive materials under Parts 30, 40, and/or 70, as appropriate, continues to be incorporated in the modified licenso, as it was during operation. Subsequent amendmento are issued as appropriate.

Following the adoption of the new rule on decomminnioning, the term " decommissioning order" la used by the 11RC in 1 leu of the term

" dismantling order" because the overall approach to decomminoloning must now be approved nhortly after operation ceanen, rather than an amended "ponceoulon-only" Part 50 licence being issued without planc for ultimate disposition.

The liRC acknowledgen that a licennee may proceed with some activities such decontamination, minor component dioancembly, and shipment and storage of spent fuel if these activition are permitted by the operating licence and/or 10 CFR 50.59.

Following the decommissioning of the CAVALIER, the CAVALIER T SAR will no longer be applicable. Decommisnioning of the CAVALIER will be deemed to have been completed once the terminal Hp survey resulta have been found to be acceptable by the 11RC.

The Technical Specifications are part of the operating 11conne and are meant to accure the safe operation of the reactor. They will be in ef f ect during the decommisoloning phase, and amended by the 11RC as nececcary. Af ter the CAVALIER has been decommiccioned, the Technical Specifications for License R-123 will no i onger be applicable.

The Emergency Plan for the Reactor Facility has been " bounded" by the requirements imposed by the higher power UVAR, and van formulated for the Reactor Facility an a whole. Therefore, no changen to the plan are foreceen other than dropping all sections or referencen to the CAVALIER at the ne>:t opportune review date for the Emergtacy Plan following CAVALIER decommissioning.

fi-l

i t . l l

t i

FACILITY-DislGN, CONSTRUCTION OR MODiflCAT10N EVALUATION FORM (ThisQ/Aformt'asedon10CFRS0.59requirementswasapprovedbyRSCon 12 / 0S/85 .) f

1. Requested by: Date:  !
2.

Description:

I f

3. Safety Analysis:

lI) is the facility to be designed, constructed or modified described in the SAR?

Yes, in section No N/A b) Is a change required in S0P as referenced in the SAR?-

Yes, updated 50P to be reviewed by RSC on / / .

No , i N/A c) Does the proposed change, test, experiment or facility involve a change in Technical Specifications?-

Yes, to Tech. Spec.

(therefore a license amendment pursuant to 10CFR 50.90 is required)

.No i d) is the probability of an accident with or ,

malfunction of the equipment such that it may bear on safety items considered in SAR7 Yes.. bearing exists on SAR items ,_ .

No -

.e) Are the consequences of a malfunction of this equipment

-important to safety evaluations previously made in the SAR?

' Yes, affects evaluation in SAR section .

No 4 f) Is an a*cident or malfunction of a different type than previously evaluated in the SAR possible?

Yes, the scenario not previously considered is ..

No g) is the margin of safety as defined in the basis for any Technical Spec.ification reduced?

i ..

Yes, margin of safety for T.S.- (is are) reduced.

No ,

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h) When the answers to questions 3 (d.e.f. and g) are all "No", the Facility Director may conclude that the request does not constitute an unreviewed safety question. Does the proposition constitute an unreviewed safety ouestion?

Yes, because ~ .

No

4. He,cerdteeping Requirements Required Completed

.:, Yes tio Yes No Comments 4.1- Jafety Analysis 10 CFR 50.59 (a) 4.2 Design Review 4.3 Drawing Revision 4.4 New Drawings 4.5 Manual Change ___

4.6 l'rocedure Change. '

4.7- RSC Approval Tech. Spec. 6.2  !

4.8 Tech. Spec. Change 10 CFR 50.59 (c) 4.9 License Change 4.10 NRC Approval 10 CFR 50.59 (c)-

4.11 Procurement Review 4.12 Material Control Review 4.13 Inspection and Tests 4.14 Non-Conforming Materials ,

4.15 Failure Records

5. Official Approval: Facility Director or Reactor Safety Committee  :

Approval for proposal vas granted on / / t-l Director's' signature

6. Work Completed by:

Title:

Date: __

7. Form Completed by:

Title:

Datef s - - - - ,.wv..e,,,,,-%,,.m - , - ,,, .,.,-w',.. . , .,v.,mm._,. ,y e 'EM.,%,

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Pobert U. Mulder Born:

Caleiras, Cao Paulo, Brasil, 1952 Educationt B. S. (physics) Universidade de Brasilia Brasilia, Brasil, 1973 l M. E. (nuclear ~ engineering) University of Virginia ,

Charlottesville, U.S. A. ,1976 Ph.D. (nuclear engineering) University of Virginia Charlottesville, U.S.A., 1981 l Academic Positions:

School of Engineering and Applied Science, University of Virginia, Charlottesville, Virginia

. Department of Nu: lear Engineering and Engineering Physics Assistant Professor, N.E. , Generel Faculty, July 1987 - Present Research Assistant Professor, N. E. , July 1984 - July 1987 Director of the Nuclear Reactor Facility, July 1984 - Present-Visiting Assistant Professor, N. E. , January 1984 - June 1984 Non-Academic Positidns: ,

L Comissao Nacional do Energia Nuclear - CNEN 1 . Ric _ de Janeiro, R. J. , Brasil Instituto de Radioprotecao o Dosimetria - IRD

j. Department for Environmental Radio Protection
Group Mana6er,-March 1981' August 1983 l

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Robert U. Mulder .

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Non-Academic Positions: (continued)

Brasil-FRG Nuclear Expert Exchange Program

[ Advanced Radioactive Effluents Measurement and Control]

Institut fuer Strahlenschutz Bundesgesundheitsamt BCA Munich, West Germany, 1982 Biblis Nuclear Power Plant Biblis, West Cermany, 1982 ,

i Karlsruhe Nuclear Research Center KfK Karlsruhe, West Cermany, 1982 Publications and Presentations:

Mulder, R. U. , and Kelly, J. L. , "An Experimental Investigation of Iodine Partition Coefficient with Pure Water," ANS 1981 Heeting in Miami, Florida.

Mulder, R. U., Winter, M., et al., "Preoperational Environmental

! . Monitoring of the Angra Reactor Site," ISSN 0101-6148, CNEN 1001, KfK L

3448, March 1983.

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Lowenstein, A., Dinger, E., Mulder, R., and Ritenour, R., "The Development of Consolidation Circuits Using Capacitive Energy Storage-Elements,"

23rd Symposium on Engineering Aspects of Magnetohydrodynamica (Ml!D),

June 25-28, 1985.

Keliy, J., Muider, R., and Babad, C., " Experimental Investigation of the .

Iodine Partition Coefficient," Nuclear Technology,'Vol. 71, November

-1985.

Lowenstein, A. , Ritenour, R. L , Mulder, R. U, , and Felber, J . , " Capacitive

-Consolation for MHD Cenorators," Final Report, EPRI AP-5139, May_1987.

R.A. Rydin,' D.W. Freeman,.B. Hosticka, R.U. Mulder, " Safety Analysis for the University-.of Virginia Reactor LEU Conversion" XII. International- '

Heeting on Reduced Enrichment for Research and Test Reactors, 10 13 y September-1989-Berlin Fed. Rep. of Cermany.

L i Ritenour, R.L., Rydin, R., and Mulder, R.U.. " Scattering Model l Approximations for Neutron Thermalization Problems", Nuclear Science-l and Engineering, .Vol.106, No. 4, December,1990, pp. 457-470.

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3 Robert U. Mulder Publications and Presentations (con't)

Combs , M. J . , Mulder, R. U. , et al . , " Evaluation of a Portable CdTe Gamma Detection System for Gastric Emptying Measurements," Society of Nuclear Medicine 37th Annual Meeting, Washington, DC, June 19 22, 1990.

Combs, M. J . , Mulder, R. U. , c t al. , " Optimization of Auger Camera Window Settings Using Er-171 and SM 153 in Gastrointestinal Imar,ing," to be presented at the Society of Nuclear Medicine 38th Annual Meeting, Cincinnati, OH.

Combs, M. J., Mulder, R. U., et al., " Activity Selection and Dosimetry for Gastrointestinal Transit of Er 171 and Sm 153 Labelled llydrogel Beads,"

to be presented at the Society of Nuclear Medicine 38th Annual Hecting, Cincinnati, OH.

Professional Societies:

Member, American Nuclear Society Member, Americar. Society for Engineering Education Research Interests:

Isotope applications, mixed radiation field dosimetry, envitonmental radioprotection.

Committees:

U.Va. Reactor Safety Committee U.Va. Radiation Safety Committee SEAS Open House Committee Research Projects, Grants and Sponsors:

Capacitive Consolidation for KHD Generators EPRI AP-5139 Conversion of UVA Reactor to Low Enriched Uranium DOE LEU Conversion of U.Va. CAVALIER Reactor DOE Nuclear Reactor Operator Training DOE DOE Reactor Sharing Program

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Robert U. Mulder Class subjecte Taught: '

NE 681, 381 and 382 Rad. Labs

  • NE 605 Nuclear Reactor Safety NE 472 Nuclear Engineering Design Languages:

Portuguese, Spanish, German r

CV7 Updated: 3/25/91

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, h-May, 1991 hm.es Preston Farrar Born:

Lynchburg, Virginia, 1932 1

Education:

B.S. (Physics) Lynchburg College Graduate Courses University of Virginia Experience:

The Babcock & Wilcox Company 1956 - 1966 - Experimental Physicist - Critical Experiment Lab.

Assisted in the planning and execution of critical experiments connected with the Consolidated Edison Reactor, the Liquid Hetal Reactor, and the N.S.

Savannah Reactor, performing reactor operations, data analysis, and report writing. As a member of the physics start-up teams, assisted in the loading and testing of the N.S. Savannah Reactor on board ship at Camden, N.J. and the Consolidated Edison Reactor at Indian Point, N.Y.

Operations Supervisor of the Babcock & Wilcox Test Reactor. Responsible for the operation of the BAVTR, a 6 MV test reactor. Held Senior Operator Licenses for all critical experiments, the 1 MW pool reactor, and the 6 MW test reactor.

The University of Virginia 1966 - present - Reactor Administrator - responsible for 2 MW research reactor (UVAR) and low power training reactor (CAVALIER)

Secretary of Reactor Safety Committee. Prepares and updates operating procedures. Asertains that all operations meet license requirements. Responsible for inventory and preparation of Haterial Status Reports on Special Nuclear Material. Preparas annual report to NRC Division of Regulation and such other reports as required by the license. Administers Reactor Operator Requalification Program. Conducts training classes for new operators, lloids Senior Operator License for UVAR and CAVALIER 1

reactors.

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  • ,+ *o Technical Society: Member since 1962 of American Nuclear Society (Reacto Operations Divistori)(Education Division)

Hember - ANS-15 Standards Committee, responsible for developing standards for Research Reactors I Hember ANS 15.1 - Techrical Specifications for Research Reactors.

Member ANS 15.14 - Security Standard for Research Reactors 1 1

Clearance: NRC clearance for classified information Technical papars - presented at annual ANS meetings Co-author " Reactivity and Flux Heasurements in Highly Reflected U 235, Bismuth, Craphite Critical Experiments",

(Catlinburg, Tenn.,1959)

Co-author " Operating Coefficients and Reactivity Behavior at Indian Point". (hew York, 1963)

Co-author " Utilization of the University of Virginia Research Reactor" (Toronto, Canada, 1568) 1 l

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hul E Benrttrie.

Born:

Washington, D.C., 1953 Education:

B.S. (nuclear engineering) University of Virginia, 1975 M.S. (nuclear engineering) University of Virginia, 1982 Experience:

School of Engineering and Applied Science, Research Laboratories for the Engineering Sciences, University of Virginia, Charlottesville, Virginia Department of Nuclear Engineering and Engineering Physics Nuclear Reactor Operator, 1977-1978 Nuclear Reactor Senior Operator, 1978-1979 Research Engineer, 1979-1985 Nuclear Reactor Operations Supervisor, 1985-1987 Nuclear Reactor Services Supervisor, 1987-Professional and llonorary Societies:

American Nuclear Society American Society for Testing and Materials llealth Physics Society Institute of Electrical and Electronics Engineers Tau Beta Pi Virginia Academy of Scler.cc Publications and Presentations Chiang, A.T., Benneche, P.E., and Rydin, R.A, " Optimal Control of Xenon Spacial Oscillations in Reactors," presented at the 1976 American Nuclear Society International Cor.ference on World Energy, Washington, DC; and published in 6]nericen Nuclenr Society Trnnsnetions, Vol 24 (1976), p. 427.

Benneche, P.E. and Shriver, B.L., "The Use of Research Reactors for Educational Programs in Scierice," presented at the Virginia Academy of Science 59th Annual Meeting, May 1981, horfolk, VA; and published in Virginia Journal of Science, Vol 33, No. 1 (1982), p. 20.

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2 Benneche, P.E., " Dose Rate Measurement of University of Virginia Reactrer Fuel Elements," preacnted at the Institute of Nuc1 car Materials Management 23rd Annual Meeting, July 1982 Washington, DC; and published in Journal of the Institute of Nuclear Mnterials Mannrement, Vol 11 (1982), pp. 236 243.

Benneche, P.E., and Vil11anson, T.C., " Dose Rate Measurement of Research Reactor Fuel," presented at the American Nuclear Society Meeting, Nov.

1982, Washington, DC; and published in American Nucienr Society Transactions, Vol 43, 1982, pp. 121 122.

Williamson, T.G., llosticka, B., and Benneche, P.E., " Facility for Epithermal Neutron Activation Analysis," presented at Topical Conference on Reactor Operating Experience, Williamsburg, Virginia, 1985.

Villiamson, T.O., Benneche,- P.E., liosticka, B. , and Brenizer, J .S. ,

" Char.seterization of an Epithermal Irradiation Facility," presented at 7th International Conference on Modern Trends in Activation Analysis, Copenhagen, 1986.

t I

Benneche/cv

Updated
10/17/89 l

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1 S9uyerd.JJqvtickA Borni i

Denver, Colorado, 1952 Education:

B. S. (nuclear engineering) University of Virninia, 1986 Experience:

United States Navy Eltetronic Maintenance, 1970-1972 Reactor Operations-(enlisted), 1972-1979 Department of Nuclear Engineering and Enoineering Physics, School of Engineering and Applied Science, University of_ Virginia, Charlottesville, Virginia Senior Reactor Operator, 1979-1986 Research Scientist, Reac'or Facility, 1986--

Publications:

Hosticka, B., "A Heated Fast Neutron Irradiation Facility for Metallurpical Samples," in~Hardling, O. K., Clark, L., and Von Der Hardt, P., eds.,

Ptereed)DQM..RI thP_.lgtt>tnatipppL_Symposboten.1h t spJtgLDeyglppe.nept.

U of_L5 Land Medium Flux _Reseatgt L Reagtorg, Supplement to Vol. 44, Atomlernener-)ie Kerntechniek (Cambridge, Massachusetts: 1984),

~

pp. 928-934.- Presented at the Massachusetts Institute of Technology, Cambridge, Massachusetts, October 16-19, 1983.

Williamson, T. G. , Host icka, D. ,- and Benneche, P. E., " Facility for Epithermal Neutron Activation Analysis," Prggeepinyy_pf;tfita Twelfth BiWRnJAlggnigtence on Reacipr_OpezaunqJaper_tenge, Supplement No. 2

- to _Vol. 49.-- Transactions of the Arnerican Nuclear Society .. (1985), pp. '

39-40. Presented _at Willia:nsburg, Virginia, August 4-7, 1983.

~

McRae, D. D., Brenizer, J. S. , Tobin, K. W., Hosticke, B., and Sulcoski, ,

l' M. F., " Quantitative Density Measurement from a Real-Time Neutron Radiography Sybtem, " invited paper, - Trat!y,_A Joenican Nuclear _Sqciety, L Vol. 33-(1986), pp._178-180.

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Publications (continued):  !

Breniger, J. S,, Hosticka, D., Jenkins, R. W., and McRae, D. D. , "An 4d-vanced Video System for Real-Tiene Neutron Radiography," Neutron,Radior .

11C#pftYLJ.'rgceetjinq9_of_the_See,pnt) Worli Corderence _on Neut ron,Ratjto- ~

  • ntaphy, Paris, France (June 16-20, 1986), J. Barton. G. Farny, J. Per-son, H. Rottger, D. Deidel, eds. (Pub. Co., Dordrecht, holland 1987), ,

pp.- 571-578.

Williamson, T. G. , Dennet.he, P. E., Hosticka, D., Breni mr, J. S.,-and Nguyon, T. L., " Characterization of an Epithermal leradiation Fact- __ '

l i t y, " h_ Rad lSa ttalt_NypJ,_Qhein, , Vol. 114, No. 2 (1987), pp. 387-392.-

Rydin, R. A., Fehr, M., Wasserraan. S., Freeman, D., and Hosticka, B., ,

" Status of the University of Virginia Reactor Conversion to LEU  ;

Fuel," [960_ int.ernatiqnal,_Mv.tJnq_qrLReducedJnri.phment for Re-MeargtL!stLTgw1_ Rear (qty, San Diego, CA, Gepteinber 19-22, 1908.  ;

Rydin, R. A. 'Fre9 man, b. W., Hosticka, D., and Mulder, R. U., " Safety Analysis for the Univerrity of Viruinia Reactc.e LEU Conversion,"

P_rctCeed1DQu. oijhe MLJaitetnat_ionaLMewt.th(LML epuced.,Epr1.chment, R ,

- fge_Researgh,grgLTestJeaptgrs, e Berlin, Federal Republic of Germany (Sept. 1989). l Williamson, T. G. and Hosticka, B., "Use of Internel Conversion X-Rays for INAA,".Trang, Ameripart Nuc)parJoc i_ety,, San Francisco. C? November 26-30, 1989.

Brentrer, J. S., Hosticka, B., and McRae, D. D. , " Neutron Radioscopic Applications at the University of-Virginia." Trang,J merican_Nucleat See fLgly, -- Vol . - 61 (1990), p p. 105-107.-

Hosticka, B.,--and Breniver, J. S. , " Evaluation of Knife-edge Geometry on the Lambda Sharpness Pararneter, " Presented at the First int. Topical-Meeting on Neutron Radiography System Design and Characterization, Pembroke,-Ontario, Canada, August, 1990.

L

( .' Research Interestsi Neutron Fluoroscopy, Neutron Shielding, Neutron Activation Analysis, and Neutron Induced. Lattice Defects Updated: 09/19/90 l.

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RICllARD G. PICCOLO KEY WORDS Certified llealth Physicist Operational llealth Physics Nuclear Liability Environmental Monitoring i Records Management Effluent Monitoring l Program Management EXEERIENCE UNIVERSITY OF VIRGINIA September 1990 to Present RADIATION SAFETY OFFICER Provides health physics and administrative oversight for use of radioactive materials and experimentation in approximately 420 laboratories with 1500 users in the University and Medical Sciences I system. Performance of audits ensuring safe operations and compliance to both regulations and good practico. Authority and responsibility l for the quality of programs throughout the University which affect the l use of radioactive material. These programs include l training, surveillance, records management, procurement, incident investigation and remedial action, ALARA, and other operational and administrative programs. Development of programs to reduce the nuclear liability of  ;

the University. Member of the Radiation Safety Committee, Reactor Safety Committee, and Medical Isotopes Subcommittee.

i Lectures within the University system on the hazards of radiation and the proper methods to control exposure; use of protective clothing; respiratory protection; decontamination techniques; use of radiation ,

detection instruments and laboratory instruments.

AMERICAN NUCLEAR INSURERS i January 1980 to September 1990

!!EALTH PilYSICS MANAGER Management of the health physics activities for the Nuclear Liability ,

Pools. Activities included the management and performance of inspections reviewing the programs of insureds'in tho' areas of:

health physics operations, facility management, ALARA , contamination control,_ environmental and effluent monitoring, incident investigation, surveillance and records management. Worked with-clients to-identify elements of their prograns that are_important to nuclear liability _and how suggested improvements might best bu

implemented.

Developed and formalized ANI/MAELU Bulletins in the specific areas of:

  • Nuclear Liability Records Retantion
  • Nuclear Liability Records Audits 1

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  • llot Particle controls
  • Environmental Monitoring
  • Recommendations for Use of Optical Disk Developed and issued these Bulletins by working closely with the legal staff at ANI and through a cooperative review process with ANI clients during pilot implementation.

Worked with clients and attorneys during all phases of litigation in the evaluation of claims made against the nuclear liability its .rance policy. Reviewei information found in the discovery process and provided technical opinion to underwriting, claims, and legal departments.

VIRGINIA POWER - SURRY POWER STATION June 1976 to September 1976 (Co-op)

June 1977 to December 1979 HEALTil PilYSICS TECl!NICIAN Routine llealth Physics Technician responsibilities including:

radiation surveys, jub coverage, RWP preparation, radwaste work and dosimetry issuance and processing. Qualified count room technician for all categories of releases; calibration of count room equipment including: MCAs, gas proportional counters, liquid scintillation counters and GOLi detectors. Operation and calibration of whole body counter. -Conducted new worker radiation safety training during the Steam Generator Replacement Project (SGRP) .

AFFILIATIONS American Academy of Ilealth Physics Health Physics Society American Nuclear Society Nuclear Information and Records Management Association

  • Nuclear-Liability Subcommittee o Regulations Committee INSI N13.6 - Practice for Occupational Radiation Exposure Records Systems, member AIF/NESP - Record Keeping Practices for the Nuclear Industry, member AIF/NESP - Ad' hoc committee on radiation tort litigation ASTM E10.04 - Documentation of Radiation Surveys, member EDUCATLQH Virginia Polytechnic Institute and State University - BS Ilealth Physics / Biology, 1977 2

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SP' mED PUBLIfATIONS AND PRESENTATIONS

1. " Cost Impact from the Decontamination of Three Mile Island -

Unit-2, Santiago Working Committee, International Conference, April 1044 l

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2. " Probability of Causation and its Application to Nuclear Power,"

Edison Electric Institute, September 1984

3. " Respiratory Protection Programs - the Nuclear Insurers' Perspective," Radiation Safety Associates, October 1984
e. " Nuclear Power Plant - Insurance Inspection Philosophy for Health Physics," Edison Electric Institute, April 1985
5. " Nuclear Liability Insurance Records Retention," EEI, September 1985 4 i
6. " Data Handling and Retention," Harvard School of Public Health, Control of Occupational Exposures at Nuclear Power Plants, May 1987
7. " Nuclear Liability Interest in Population Exposures from the Nuclear Fuel Cycle," Oak Ridge National Laboratories, September 1987
8. " Recommendations for Exposures from Hot Particles," Edison Flectric Institute, April 1988 and September 1988 L 9. " Technical Advances in Recordkeeping," Nuclear Information and Records Management Association, August 1987
10. " Health Physics, Insurance and Radiation Litigation," Harvard School of Public Health, May 1989 '
11. " Radiation Dosimetry and Litigation Concerns," Panasonic International Users Conference, June 1990 l
12. " Software Control and.its Use in Dosimetry," International Science Associates, August 1990 Additional training and presentations have been given at numerous in-house. training courses presented by American Nuclear Insurers from years 1980 through 1990.

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RICHARD G. PICCOLO Mr. Piccolo is the Radiation Safety Officer at the University of Virginia. At UVA he has health physics and administrative oversight at the University's rosearch reactor, and at the 420 laboratories with 1500 users in the University and Health Sciences Center system. Prior to his employment with UVA in September 1990, Mr. Piccolo was the Health Physics Manager at -

American Nuclear Insurers in Farmington, Connecticut. He began at ANI in 1980 after three years at Virginia Power's Surry Power .

Station. At ANI he directed the health physics. inspections and follow-up for all nuclear power facilities and support and research facilities that are insured by ANI. The areas under direct management included: operational health physics, records management, environmental and effluent monitoring, hot particle issues, and the identification of performance indicators. His duties also included advisement of the company's legal and claim departments on the health physics issues associated with nuclear

, liability claims. Mr. Piccolo developed and finalized company i

position papers in the areas of: records retention, records audits, environmental monitoring programs, hot particle practices and optical disk _ storage of records. These position papers were issued to the nuclear industry as ANI/MAELU Engineering Bulletins. Mr. Piccolo was a member of the AIF/NESF Task Force on Radiological._Recordkeeping, and-is the Chairman of the Nuclear Liability Subcommittee of the Nuclear Information and Records Management Association. He is c member of Planning Committeo 56 of ASTM E10.04 which is completing a standard on the performance of radiation surveys. .He is also a member of ANSI N13.6 which is ,

re-writing the standard on the practice for occupational radiation exposure systems. He has spoken extensively on these j subjects at meetings of EEI, ANS, the Harvard-School of Public Health and other seminars. Mr. Piccolo attended Virginia Polytechnic Institute and State University; graduated in 1977 with a Bachelor of Science in the Health Physics option of -

Biology. He_was certified by the American Board of Health Physics in 1906 and was recertified in 1990.

e .

RESUh111 JAMi!S RAYh10ND GILCilRIST University of Virginia Office of Environmental llealth & Safety Charlottesville, VA 22903 (804) 924 7334 EDUCATION 11.S. degree in Nuclear Engineering, University of Virginia,1975 Major course work included Reactor Theory, Reactor Engineering, Reactor Design, Nuclear Power Plant Instrumentation, llcalth Physics (Environucleonics), Reactor Safety, and Radiation Measurements.

Successfully completed 29 semester hours of graduate course work in Nuclear and 13iomedical Engineering at the University of Virginia (May,1979).

Major course work included Physh! cay, Radiochemistry, Shielding, Radiobiology.

Reactor Engineering, Radiological Pi. ics, and Radiation Dosimetry, Attended two week course entitled " Health Physics in Radiation Accidents" offered by ERDA through the Oak Ridge Associated Universities at the Radiation Emergency Assistance Center / Training Site, Oak Ridge, Tennessee (June,1976).

PROFESSIONAL EXPERIENCE June,1989 . present: Assistant Director & University Radiation Safety Officer, University of Virginia, Office of Environmental IIcalth and Safety, in additic,c to the duties of Assistant Director described below, the responsibility for directing the University's radiation safety program and serving as the individual named as Radiation Safety Officer on the University's various Nuclear Regulatory Commission licenses was assumed. The program covers the hospital (with nuclear medicine, teletherapy, brachytherapy and a " gamma knife" stereotactic surgery unit),

medical school, 2 MW research reactor, and various academic departments.

Supervision of three health physicists and five technicians.

4 August,1986 June,1989: Assistant Director for Operations, University of Virginia, Office of Environmental licalth and Safety.

Served as an administrative faculty member responsible for assitting the half time director in the administration of a University wide health and safety program.

Coordinating the activities of the 22 member staff responsible for the areas of radiation safety, chemical safety, industrial safety, fire safety, asbestos anatement monitoring, infectious waste handling and disposal and workers compensation.

Departmental budgeting and fiscal management.

August,1975 August,1986: llealth Physicist, University of Virginia Radiation Safety Office Supervision of health physicist, three radiation safety technicians, and secnetary in performance of routine surveillance of radioactive material and radiation producing equipment use at medical center, research reactor facility, and academic departments; radioactive waste management, including coordination of on-site waste pickups, packaging, transfer to disposal company, and recordkeeping; review and implementation of state and federal regulations; management of radiobioassay program including analysis of various biological samples as well as external thyroid measurement; environmental sample analysis; emergency response to radiation accidents at the University and throughout Virginia (appointed by Virginia IIcalth Commissioner as Emergency Radiation Specialist).

October,1974 August,1975: Student assistant with University of Virginia Radiation Safety Office.

Performance of laboratory surveys; collection and packaging of radioactive waste; assisted bioassay program and dosimetry program.

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R8SUhis Name: Deborah Powell Steva Office Address: Office of Environmental Health and Safety P.O. Box 3425 Charlottesville, VA 22901

[804] 924 7334 Date of Birth: April 10,1956 EDUCADONAL BAl% GROUND College: Virginia _ Polytechnic Institute & State University (VPI)

Blacksburg, VA B.S., Biology / Health Physics option,1979 Additional: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of graduate credit toward hi.S. in Environmental Biology, Ohic State University Cooperative Education Program - Four quarters of working experience in the Radiation Safety Branch of NIH, Bethesda, h1D during last two years of school Health Physics and Radiation Protection (5 week course), Oak Ridge Puoll3SIONA!. hitMillRSlitP Health Physics Society Chartet hiember, Backeye Chapter of HPS Confereace of Radiation Control Program Directors Board hiember of Ohio Radioactive Afaterials Users Group (ORhiUG)

- Virginia Chapter, H.P. Society

, . , , . ,-m , - y am-. - -r- -+,,--v, - - +3 m ,-r---..,w<+ , -~-

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. , 1 R$ SUM 8 Exmuunx from 10/89 to present:

Employer: Office of Environmental llealth and Safety, University of Virginia Position: Radiation Safety Specialist Description of Duties: Responsible for the licalth Physics program at the University of Virginia Reactor Facility; provide guidance and training on the safe use and handling of radioactive materials to users throughout the UVa campus; develop policies and procedures pertaining to use and handling of radioactive materials at UVa; supervise routine bioassay 1 program; calibrate and operationally check sun'ey instruments; conduct radiation and contamination surveys, from 3/83 to 10/89:

Employer: Ohio Department of licalth Position: Health Physicist 11 Description of Duties: Design, coordinate and supervise state environmental radiation surveillance programs conducted in the vicinity of nuclear power stations and DOE facilities located in Ohio.

Coordinate with ODH laboratory 'nd interpret laboratory analyses of environmental samples collected. Design and utilize computer programs used to process data.

Responsible for preparation of annual report of environmental surveillance activities. Participate in exercises of the state emergency response plan for nuclear facilities as a member of the state Dose Assessment team. Coordinate with and provide technical assistance to local health departments on radiological health issues. Assisted Ohio Commissioner to the Midwest Compact with a number of public education activities related to LLRW disposal, and accompanied Commissioner to Compact meetings when requested. Serwd second term on Ohio Radioactive Mateihls Users Group (ORMUG) Board of Directors. As Ohio's state radon contact person, coordinate and implement state radon program activities and perform public speaking activities on radon.

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R$SUhiE from 11/79 to 3/83 Employer: Ohio State University, Radiation Safety Office, Columbus, Ohio Position: Radiation Safety Officer Description of Duties: As a staff radiation safety officer, provided guidance and training on the safe use and handling of radioactive materials to users throughout the OSU campus and ho.<pital.

Performed review of applications for use of radioacti,e materials, laboratory surveys, meter calibrations md microwave surveys. Coordinated and implemented precautionary procedures associated with iodine and brachytherapies. Responsible for bioassay program for radioactive materials users and nuclear medicine personnel.

Conducted radiation surveys at OSU Reactor Laboratory and served on reactor operations audit committee.

Conducted inservice training for auxiliary campus and hospital personnel. Assisted in packaging and preparation of LLRW for shipment for disposal.

from 6/77 to 3/79 Employer: National Institutes of Health, Radiation Safety Branch, Bethesda, hiD Position: Student Trainee Description of Duties: Received training in and performed general health physics duties such as laboratory surveys and preparation and analysis of air, incinerator ash, and bioassay samples.

Performed computer processing of air sample data, assisted with TLD monitoring program and meter calibrations.

Assisted in performance of various diagnostic and therapeutic nuclear medicine procedures. Observed various surgical procedures in which use of radioactive material was involved.

Training Courses Attended:

Health Physics and Radiation Protection, Oak Ridge,1987 (5 weeks)

USEPA Radon Diagnosis and hiitigation Training Course,1987

  • NRC Inspection Procedures Course,1985 NRC Nuclear Transportation for State Regulatory Personnel,1984 FENIA Nuclear Power Plant Off Site Accident Assessment Course, Emmitsburg, h1D,1984 FEhiA Radiological Ernergency Response Course, Nevada,1984 Assessment of Environmental Releases of Radioactivity, Third Annual Health Physics Society Summer School, Washington,1980 Radiological Health for Radionuclide Users, NIH,1978

i RESUME Name: Vance G. Hampton Date of Birth: July 28, 1931, Winston Salem, NC 6

Educetion:

Completed VirB i nia, High School in 1950, William Flaming High School in Roanoke, Completed Electronica Fundamentals,-1951, USAF. i Completed three courses in Auto Hechanics throu6h Armed Forces.

Institute while overseas.

Completed Al CH . APG 30 Radar School in 1952 USAF.

Con.pleted Senior Fire Control Systems Technician School,1953, USAF.

Completed of Virginia, the followingDivision:

Extension Engineering School Courses from the University '

1. College Algebra 3. Trig & Analytic Geometry
2. Engineering Drawing 4 Electronics Courses Completed Microwave course sponsored by Sperry Piedmont.

Completed a 17 week company sponsored Value Engineering Course at 1 Sperry Marine Systems Division, Fall 1968. {

Completed course in Industrial Time and Motion Study for Cost Control at the University of Virginia. Winter 1968-69.

Hachine shop apprenticeship with'U.Va. engineering school 1969 1970.

Monitored course in reactor operations 1973 1974. j Military Record:

Entered U.S. Air Force February 1951.

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- Overseas duty on Okinawa and Japan.

l Awarded the U.N. Medal, the Korean Service Medal and Good Conduct Medal.

. Awarded Clearance up to and including Secret.

Attained rank of Staff Sgt.

1 Awarded an Honorable Discharge in February 1955,

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l g_ . Employment Record:

Forty Years of Electronics exeerience as of April 1, 1991 Emnlover Descriotion University of Virginia Dept. Electronics Shep Supervisor of Nuclear Fngineering and doing rapairs, some design Oct. 1972 to Present Engineering Physics and assembly of all related electronics equipment; maintaining parts irventory, some supervision in use of equipment.

University of Virginia Electronics repair and Research Labs for the assembly and some Oct. 1969 - Oct. 1972 Engineering Sciences machining Electronics Repair Shop Sperry Marine Systems, Div. Process Engineer: Mfg.

Charlottesville, Va. Engr., responsibility Oct. 1964 to May 1969 for a number-of regular electronics products, and covering Spares in general for Hfg. Engr.

both Commercial and Military.

Electronic Concepts, Inc. Manufacturing Supt.

Gaarlottesville, Va. Complete Charge of Oct. 1963 to Sept. 196 4 manufacturing and I

quality control of

- electronics equip-ment both Commercial and Military.

,Sperry Piedmont Co. Process Engineer:

Charlottesville, Va. Aug. 1959 to Oct. 1963 Methodizing Engineer-ing Information for manufacturing. Setting up aasembly lines and Design of Assembly Fix-tures and Aids.

Sperri Piedmont Co.

Chsrlottesville, Va.

Electronics Engineering Oct. 1956 to Aug. 1959 1.ab Technician. Design Layout, and Testing of New Products, i Melpar, Inc.

L -Falls Church, Va. Electronics Engineering Feb. 1955 to Oct. 1956 Lab Technician; Design Layout and testing of New Products.

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  • . -U.S. Air-Force Sr. Electronics Fire 1 %!- 1951 to Feb. 1955 Control and Navigation ,

Systems Technician.

Johnson McReynolds, Inc. Apprentice Auto and Roanoke, Virginia- Aug. 1950 to Jan. 1951 Truck Hechanic.

Awarded Secret security Clearance in each position except Johnson McReynolds. Inc, llobbies: Fishing, Colf and Do It Yourself Projects.

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DONALD R. KRAUSE Work (804) 924-7136 WORK EXPERIENCE UNIVERSITY of VIRGINIA, Charlottesville, Vir81 nia 1990 PRECE14T Senior Reactor Operator Formulate / document maintenance procedares.

Design / upgrade auxiliary systems and experiments.

. Involved in L.E.U. Safety Analysis J. R. TUCKER HIGH SCHOOL, Richmond, Virginia 1989 - 1990 Teucher. Mathematics Develop lesson plans and implement instruction to class.

. Supervise and motivate students.

. Set ob stives and assess performance.

Use Apple personal computer for class administration and lesson plans.

Coach basketball and track teams.

VIRCINIA POLYTECHNIC INSTITUTE 6 STATE UNIVERSITY, Blacksburg, Virginia 1982 1987 Full-time Student 1983 - 1987 Licensed Senior Reactor Operator 1982 - 1986 Reactar Supervisot, 1984 - 1985 Administered training and instruction of personnel in reactor operations, maintenance, and safety.

Oversaw operation of all reactor labocatory facJlities.

Directed maintenance and testing of reactor and auxiliary systems.

Programmed campus computer to aid in facility administration and analysis.

Formulated and implemented facility operations procedures.

Supervised complete rewrite of Final Safety Analysis Report.

Worked with ANS, ANSI, NUREG, and CFR requirements.

Staff Senior Reactor Operator, 1982 - 1984 Instructed personnel regarding reactor operations and maintenance procedures.

Supe,.tsed reactor personnel during daily operations.

Assisted researchers in formulation of experiments, design and fabrication of equipment, and assessment of problem areas.

Heavily' involved with design procurement, and installation of equipment and materials for power upgrade project.

VIRCINIA POWER COMPANY, Surry Nuclear Power Station 1981 - 1982 Technical Assistant. Operations and Desien Encineerint Units Qualified control room operator (non-licensed).

Actively participated in Surry Unit Two refueling; updating Final Safety Analysis Report; and completing Fuel Building C.C.T.V. design change project.

DONALD R. KRAUSE Resume page 2 WORK EXPERIENCE (cont.)

VIRGINIA POLYTECHNIC INSTITUTE & STATE UNIVERSI7T, Blacksburg, Virginia 1980 - 1981 Beactor Facility Laboratorv Assistant Assisted researchers with neutron activation analysis.

-UNITED STATES NAVY, Norfolk Naval Base. Nuclear Aircraf t Carrier E.ropulsion Plant Watch Sunervisor/ Divisional Traininc Supervisor 1974 - 1980 Managed operators. divisional administration, training and qualification of electrical nuclear Directed the activities of operations / maintenance personnel.

Administered and supervised electrical components electrical maintenance and repair of generators and other of reactor, i

Participated in initial start up and physics testing of reactor plants, EDUCATION / TRAINING VIRGINIA POLYTECllNIC INSTITUTE & STATE UNIVERSITY, Blacksburg, Virginia 1987 lB.S. Secondary Education, Physf.cs concentration.

Nuclear Engineering, 14 credits, Virginia Tech.

Electrical / General Engineering, 27 credits, Virginia Tech.

Education / Curriculum Development, 42 credits, Virginia Tech.

Technical Writing, 3 credits, Virginia Tech.

Nuclear Power Training Schools, U.S. Navy Flectricians Mate "A" School, U.S. Navy

- Familiar with Fortran, Pascal, Lotus, AppleWorks, and VordStar PAPERS Presented and Co authored:

" Thermal Hydraulic Studies for the Upgrade of the Virginia Polytechnic Institute and State University Argonaut Reactor from 100 kwt. to 500 kwt.", R,J. Florian, Krause et al. Presented at D. R.

Experience, Phoenix, Arizona,the Eleventh August Biennir.1 1-3, 1983.

ANS Conference of Reactor Operating Co-authored:

" Power Uperade of the Virginia Tech Argonaut Reactor", T. F. Parkinson, D. R. Krause et al.

Presented at the International Symposium on Use and Development of Low and Medium Flux Research Reactors, M.I.T., October 17-19, 1983, AFFILIATIONS American Nuclear Society - member since 1981

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GILBERT D. GLENNIE Work Address Environmental Hea'th & Safety Special Materials & Handling Facility Edgemont Road, University of Virginia Charlottesville, VA 22901 (804) 924-7334 OBJECTIVE Obtain professional position in research or engineering with more challenges and rewards.

EXPERIENCE University of Virginia, Charlottesville, VA.

Radiation Safety Technician: In charge of liquid waste program - collection, processing, analysis, and disposa Perform nuclear reactor survey and other taskt ensure safety and compliance with regulationt le facilitating research. Radioactive survey inst uments maintenance and calibration.

Accurate 2y update critical inventories and database files. Responsible for initiating action on any omissions or insufficiencies in university-wide radiation safety program. 1984 present.

Archeologist. Supervised and participated in archeological excavation and survey in Colorado, Arizona, Utah, New Mexico, and Virginia. Careful planning and documentation of excavations and surveys. Identify and catalogue artifacts. Filing, computer inventory. Summers 1980-1983, springs 1982 and 1983.

Crown Zellerbach Corp., Camas, WA.

Extraboard paper mill worker. Boilerman - maintain steam boilers and furnaces critical to cperation of entire plant, supervise grate-cleaning crew. 5.tJ1 Hand on

  1. 9 paper machine - perform hard physical labor to maintain pace of paper production. Several other short term positions requiring rapid familiarization to processes and-keeping up with production line.

Summers of 1977-1979.

Hooker Chemical Corp.,. Port of Tacoma, s'. . Paint crew - thoroughly inspect chemical production equipment in unpleasant conditions, chip of f corroded rust spots, and apply primer paint. Summer 1976.

Bruce Parker, Ransomville, NY. Grape vineyard worker

- patiently prune and train young vines to trellis, collect and stack heavy hay bales. Summers of 1972 and 1973.

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Gilbert D. Glennie, Page 2 EDUCATION University of Virginia, Charlottesville, VA.

Currently enrolled as part time graduate student in

{ Biomedical Engineering with about 4 classes remaining to complete ME degree. Also successfully completed 2 undergraduate Nuclear Engineering classes.

Washington State University, Pullman, WA. MA in Anthropology, spring 1983. Cumulative GPA = 3.54.

Washington State University, Pullman, WA. BA in Anthropology, spring 1980.

Dashington State University, Pullman, WA. BS in Physics, spring 1979. Minor in Math. Participated in Honors Program.

ACHIEVEMENTS Authore.d 2 science fiction / fantasy novels. Currently submitted for publication.

Researched, planned, and built an aboriginal style pithouse for masters thesis, using replicated prehistoric tools and techniques. Used stone ax to chop down and process pithouse timbers, pit excavated with digging stick and basket.

Winner of $1,000 National Merit Scholarship.

PERSONAL Enjoy designing and making latch-hook rugs, softball, making rusic, woodworking.

SUMMARY

OF QUALI-Intelligent meticulous individual with over 7 years FICATIONS of experience in applied radiation safety. Learns quickly and performs dependably with superior results.

perfection.

Strives for greater understanding and

', a RESUME JAMES RAYMOND GILCllRIST University of Virginia Office of Environmental IIcalth & Safety Charlottesville, VA 22903 (804) 924-7334 EDUCATION B.S. degree in Nuclear Engineering, University of Virginia,1975 Major course work included Reactor Theory, Reactor Engineering, Reactor Design, Nuclear Power Plant Instrumentation, llcalth Physics (Environucleonics), Reacto:

Safety, and Radiation Measurements.

Successfully completed 29 sem,: ster hours of graduate course work in Nuclear and Biomedical Engineering at the University of Virginia (May,1979).

Major course work included Physiology, Radiochemistry, Shielding, Radiobiology, Reactor Engineering, Radiologica! Physics, and Radiation Dosimetry, Attended two-week course entitled "licalth Physics in Radiation Accidents" offered by ERDA _

through the Oak Ridge Associated Universities at the Radiation Emergency Assistance Center / Training Site, Oak Ridge, Tennessee (June,1976).

PROFESSIONAL. EXPERIEND June,1989 - present: Assistant Director & University Radiation Safety Officer, University of Virginia, Office of Environmental Ilealth and Safety.

In addition to the duties of A;sistan! Director described below, the responsibility for directing the University's radiation safety program and serving as the individual named as Radiation Safety Officer on the Unisersity's various Nuclear Regulatory Commission licenses was assumed. The program covers the hospital (with nuclear medicine, teletherapy, brachytherapy and a " gamma knife" stereotactic surgery unit),

medical school, 2 MW research reactor, and various academic departments.

Supervision of three health physicists and five technicians.

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? !'. 5 August,1986 June,1989: Assistant Director for Operations, University of Virginia, Office of Enviromnental licalth and Safety.

Served as an administrative faculty member responsible for assisting the half time

! director in the administration of a University wide health and safety program.

Coordinating the activities of the 22 member staff responsible for the areas of radiation safety, chemical safety, industrial safety, fire safety, asbestos abatement monitoring, infectious waste handling and disposal and workers compensation.

Departmental budgeting and heal management.

August,1975 - August,1986: Ilealth Physicist, University of Virginia Radiation Safety OfGce

, Supervision of health physicist, three radiation safety technicians, and secretary in l performance of routine surveillance of radioactive material and radiation producing equipment use at medical center, research reactor facility, and academic departments; radioactive waste management, including coordination of on-site waste pickups, packaging, transfer to disposal company, and recordkeeping: review and implementation of state and federal regulations; management of radiobioassay program including analysis of various biological samples as well as external thyroid measurement; environmental sample analysis; emergency response to radiation accidents at the University and throughout Virginia (appointed by Virginia Health Commissioner as Emergency Radiation Specialist).

October,1974 August,1975: Student assistant with University of Virginia Radiation Salety

( Office.

Performatice of laboratory surveys; collection and packaging o radioactive waste; l assisted bioassay program and dosimetry program.

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