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RECEIVED JUL -2 2013 2July2013 Dear Dr. Roldan: DNMS Listed below (in order of your previous request: 1 thru 6) is the expanded information requested by the NRC to address your questions regarding the potenti al appointment of an authorized individual (Dr. Janet Benson) to complete the duties of the RSO for LRRI. Due to the NRC e-mail box fi le size constraints, the bulk of our response is included below. Additional supporting documentation/attachments will be forthcoming today from Jennifer Roberts, in individual separate e-mails. Please let me know if there is any supplementary information required or questions regarding Dr. Benson's credentials for this appointment. We look forward to receiving your assessment and feedback on this expedited amendment request. Bret Hendzel Sr. Director of Operations Lovelace Respiratory Research Institute PUBLIC IJ jlmnadla!e Release I!I" Normal Release NON-PUBLIC IJ A.3 Sensltive-Securily Related IJ A.7 Sensitive Internal IJ Other:._;;-___ _ RevIewer: Date: n/03#3 1. Dr. Benson's formal didactic and hands on training relevant to the role of R d' f S f t Offi . d' T bl 1 b I a Jalon a elY Jcer IS summarize Jn a e , eow. Name of Training Location of Date of Clock Hours/ Course Training/Hands Training Laboratory Comments on TraininQ TraininQ Course RP- Highlighted in 01382, Radiation LRRI/ E.L. attached Training Worker (Beta- Headrick 15Nov1983 1 report (pre-dates Gamma) Training Manager system) Course PD- Highlighted in 01334, Principles attached Training of Liquid LRRI 21May1984 1 report (pre-dates Scintillation Training Manager Spectrometry system) Course, Hazard Highlighted in Communication LRRI/ J.J. attached sign-in Standard Thompson 17Jan1986 1 sheet (pre-dates Training Manager system) Course, LRRI/ E.L. Highlighted in Hazardous Headrick 12Aug1987 attached sign-in Waste Training sheet (pre-dates Training Manager

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Page 1: Lovelace Respiratory Research Ins.; Response to Request for … · 2019. 12. 29. · Lovelace Respiratory Research Institute PUBLIC IJ jlmnadla!e Release I!I" Normal Release NON-PUBLIC

RECEIVED

JUL - 2 2013 2July2013

Dear Dr. Roldan: DNMS

Listed below (in order of your previous request: 1 thru 6) is the expanded information requested by the NRC to address your questions regarding the potential appointment of an authorized individual (Dr. Janet Benson) to complete the duties of the RSO for LRRI. Due to the NRC e-mail box file size constraints, the bulk of our response is included below. Additional supporting documentation/attachments will be forthcoming today from Jennifer Roberts, in individual separate e-mails. Please let me know if there is any supplementary information required or questions regarding Dr. Benson's credentials for this appointment. We look forward to receiving your assessment and feedback on this expedited amendment request.

Bret Hendzel Sr. Director of Operations Lovelace Respiratory Research Institute

PUBLIC IJ jlmnadla!e Release I!I" Normal Release

NON-PUBLIC IJ A.3 Sensltive-Securily Related IJ A.7 Sensitive Internal IJ Other:._;;-___ _

RevIewer: ~ Date: n/03#3 1. Dr. Benson's formal didactic and hands on training relevant to the role of

R d' f S f t Offi . d' T bl 1 b I a Jalon a elY Jcer IS summarize Jn a e , eow. Name of Training Location of Date of Clock Hours/

Course Training/Hands Training Laboratory Comments on TraininQ TraininQ

Course RP- Highlighted in 01382, Radiation LRRI/ E.L. attached Training

Worker (Beta- Headrick 15Nov1983 1 report (pre-dates

Gamma) Training Manager system)

Course PD- Highlighted in 01334, Principles attached Training

of Liquid LRRI 21May1984 1 report (pre-dates Scintillation Training Manager

Spectrometry system)

Course, Hazard Highlighted in Communication LRRI/ J.J. attached sign-in

Standard Thompson 17Jan1986 1 sheet (pre-dates

Training Manager system)

Course, LRRI/ E.L. Highlighted in Hazardous

Headrick 12Aug1987 attached sign-in

Waste Training sheet (pre-dates Training Manager

5~OII{P

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system)

Course RP- Highlighted in 00066, attached Training

Radioactive LRRII William C. 10Dec1990 1 report (pre-dates Waste Schleyer III CHP Training Manager

Packaging and Handline

system)

Course RP- Highlighted in 00801, LRRII William C. attached Training

Radiological Schleyer III CHP

17Jan1991 8 report (pre-dates Worker Training Training Manager

system)

Course RP- Highlighted in 00799, Fume LRRII Brian attached Training

Hood and Glove Ritchey and Rick 21Jan1991 7 report (pre-dates Box Operationl Brodbeck Training Manager

Radiation system) Worker Traininq

Course Highlighted in Emergency attached sign-in Evacuation LRRII William C. 09Jul1992 0.75 sheet (pre-dates

Training Schleyer III CHP Training Manager system)

Course EH-082, Hi9hlighted in Cross- LRRII John attached sign-in

Contamination Lopez

09Jun1993 1.5 sheet (pre-dates Control Training Manager

system)

Course RP- Highlighted in 00048, Low- LRRII William C. attached Training Level Waste

Schleyer III CHP 07Sep1993 1.5 report (pre-dates

Management Training Manager system)

Course Highlighted in Principles of attached sign-in

Liquid LRRII M.B. 21May1984 1 sheet (pre-dates Scintillation Snipes, PhD Training Manager

Spectrometry system)

Course RP- LRRI/Wiliiam C. 24May1994 1.5

Highlighted in 00005, General Schleyer III CHP attached Training

Employee report (pre-dates

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Radiological Training Manager Training system)

CourseWM- Highlighted in 00363, RCRA Mary S Halll attached Training

Hazardous Cynthia Hess, 21Jul1994 3 report (pre-dates Waste Seminar PRC Training Manager

system)

Course EQ- Highlighted in 00285, Liquid LRRII Brad attached Training Scintillation

Tibbetts 12Dec1995 2 report (pre-dates

Counting 1 Training Manager system)

Course RP- Highlighted in 00003, LRRII William C. 19- attached Training

Radiological Schleyer III CHP 20Dec1995

12 report (pre-dates Worker II Training Manager

system)

Course OS- Highlighted in 00090, Lab LRRII Steve attached Training

Safety Inspection Rohrer

28Mar1996 1.5 report (pre-dates Procedure Training Manager

system)

Informs workers of the radiation hazards in areas controlled for

ESH-Course-99 radiological purposes.

(Various formats) Provides information about

Radiation radiation, risks Worker Training: LRRII Don Baker 27May1999 1 associated with General exposure, Employee radiation dose

Radiological limits, ALARA

Training concepts and practices, the different radiological areas and postings, and radiological orotection

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responsibilities.

Highlighted in attached Training Manager report

ESH-Course-24, Highlighted in RCRA for Small LRRII Don Baker 26Apr2000 1 attached Training Quantity Manager report Generators

Qualified on 02Feb2001

Highlighted original in

ESH-Course-4 Employee LRRII Don Baker 02Feb2001 4 Training Record

Radiation preceding Training Worker Manager

and Highlighted in attached Training Manager report

Highlighted original in Employee

ESH-Course-62, Training Record

Tc-99m LRRII Don Baker 03Dec2001 0.5 preceding Training

Refresher Manager

Training and Highlighted in attached Training Manager report

ESH-Course-29, Highlighted in Waste Handling, LRRII Don Baker 12Dec2002 1 attached Training Documentation, and DisDosal

Manager report

ESH-Course-12, Hazard

Highlighted in Communication: The Globally LRRII Don Baker 01 Nov2004 1 attached Training

Harmonized Manager report

System (with Quiz)

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ESH-Course-4 Highlighted in LRRII Don Baker 02Nov2004 4 attached Training

Radiation Manager report Worker

Demonstrates familiarity with LRRI-specific

ESH-Course-1, LRRI/ Don Baker 28Dec2004

safety concerns

Employee Safety 0.5 and procedures.

Orientation Highlighted in attached Training Manager report

ESH-Course-99 (Various formats)

Radiation LRRI/ Elaine Highlighted in

Worker Training: Marshall 23Jan2008 1 attached Training

Radiation Manager report

Worker Practical Factors

Required for workers who handle radioactive materials or sealed sources, who operate radiation-

ESH-Course-99 generating

(Various formats) devices, or who generate

LRRI/ Elaine Radiation 23Jan2008 radioactive waste.

Marshall 4 Includes

Worker Training: Radiation

employees working in, or who

Worker routinely enter the Beta/Gamma labs and researchers using radioactive material in individual labs. Provides information on worksite radiation

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hazards, basic radiation concepts, the risks associated with exposure to ionizing radiation, and general radiation control requirements that will allow the employee to make informed decisions on personal safety and to take actions that can reduce radiation exposure. Also includes procedu re for generating and documenting radioactive waste. Includes hands-on training. Also includes course for Practical Factors.

Highlighted in attached Training Manager report

ESH-Course-93, Highlighted in Hazardous LRRII Scott

31Jan2008 1 attached Training Waste RCRA Weiner Manager report Awareness TraininQ

ESH-Course-99 Highlighted in (Various formats) LRRII Elaine

05Jan2009 4 attached Training Marshall Manager report Radiation

Worker Training

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ESH-Course-93, Highlighted in Hazardous LRRII Scott

10Mar2009 1 attached Training Waste RCRA Weiner Manager report Awareness Trainina

ESH-Course-99 Highlighted in (Various formats) LRRII Elaine

16Mar2010 4 attached Training Marshall

Manager report Radiation Worker Training

ESH-Course-99 Highlighted in (Various formats)

LRRII Elaine 30Mar2011 4 attached Training

Radiation Marshall Manager report

Worker Training

ESH-Course-93, Highlighted in Hazardous LRRII Scott

04Jul2011 1 attached Training Waste RCRA Weiner Manager report Awareness

Trainirlg

Highlighted in Course ESH-LRRII Scott

10Jul2012 4 attached Training 003, NRC Weiner

Manager report Radiation Safety Reaulations Course

Highlighted in ESH-RP-11 LRRII Scott

18Jul2012 1 attached Training Radiological Weiner

Manager report Surveys

Required for ESH-Course-99 workers who (Various formats) handle radioactive

materials or Radiation sealed sources,

LRRII Scott who operate Worker Training: 18Jul2012 4 radiation-Rad worker Weiner

training and generating radiation worker devices, or who practical factors generate

radioactive waste. Includes employees

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working in, or who routinely enter the Beta/Gamma labs and researchers using radioactive material in individual labs. Provides information on worksite rad iation hazards, basic radiation concepts, the risks associated with exposure to ionizing radiation, and general radiation control requirements that will allow the employee to make informed decisions on personal safety and to take actions that can reduce radiation exposure. Also includes procedure for generating and documenting radioactive waste. Includes hands-on training. Also includes course for Practical Factors.

Highlighted in attached Training Manager report

Course RSC- LRRII Jennifer Highlighted in 001, NRC

Roberts 13Dec2012 1.0 attached Training

Inspection Manager report Debrief; Rad

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Safety Program Expectations Henceforth Course LRRI RSC Basic Training: Broad LRRII Jennifer Highlighted in Scope License,

Roberts 29Jan2013 1.5 attached Training

CFR Manager report Regulations, and Internal SOPs-Part 1 of 2 Course LRRI RSC Basic Training: Broad LRRII Jennifer High lighted in Scope License,

Roberts 30Jan2013 1.5 attached Training

CFR Manager report Regulations, and Internal SOPs-Part 2 of2 Course LRRI

Scored 100% on RSC Basic quiz Training: Broad

LRRII Jennifer Scope License,

Roberts 31Jan2013 0.5

Highlighted in CFR Regulations, and attached Training

Internal SOPs- Manager report.

Quiz Course ESR-

LRRII Amanda Highlighted in AU01, AU 28Mar2013 1.5 attached Training Functional Role Rector

Manager report. TraininQ SOP ESR-1407,

LRRlf self Highlighted in Radiological

training 27Feb2004 0.5 attached Training

Postings and Manager report. Labels

SOP ESS-1314, LRRII self Highlighted in

Job Safety training 27Feb2004 0.5 attached Training

Analysis Manager report.

SOP ESS-1315, LRRIf self Highlighted in

Workplace training

27Feb2004 0.5 attached Training Injuries and Manager report. Illnesses SOP ESR-1401, LRRIf self

27Feb2004 0.5 Highlighted in Radiation training attached Training Exposure Limits

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Manager report

SOP ESS-1366, lRRl1 self Highlighted in

Occupational 27Feb2004 0.5 attached Training Health training

Manager report. Assessments SOP ESS-1367,

lRRl1 self Highlighted in Medical

training 27Feb2004 0.5 attached Training

Surveillance for Manager report. lRRI Employees SOP ESS-1315, lRRII self Highlighted in Workplace

training 05Dec2004 0.5 attached Training

Injuries and Manager report Illnesses SOP ESS-1366, LRRII self Highlighted in Occupational 23Apr2005 0.5 attached Training Health training Manager report Assessments SOP ESR-1407,

LRRII self Highlighted in Radiological 22Dec2006 0.5 attached Training Postings and training

Manager report Labels SOP ESR-1407,

LRRII self Highlighted in Radiological

training 18Jul2008 0.5 attached Training

Postings and Manager report labels SOP ESS-1315,

Highlighted in Reporting LRRII self 09Aug2009 0.5 attached Training Workplace training

Manager report Injuries and Illnesses SOP ESS-1315,

Highlighted in Reporting LRRII self 03Sep2012 0.5 attached Training Workplace training

Manager report Injuries and Illnesses SOP ESR-1370,

lRRII self Highlighted in Radiation

training 27Dec2012 0.5 attached Training

Instrument Manager report Function Check SOP ESW-1413,

LRRII self Highlighted in Radioactive

training 27Dec2012 0.5 attached Training

Waste Manager report Mana!lement

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SOP ESW-1805, Highlighted in Packaging and LRRII self

28Dec2012 0.5 attached Training Shipment of training Manager report Radioactive Waste SOP ESR-1845,

LRRII self Highlighted in Accounting for 28Dec2012 0.5 attached Training Special Nuclear training Manager report Materials SOP ESR-1364, Radiation LRRII self Highlighted in Protection

training 29Dec2012 0.5 attached Training

Instrumentation Manager report Test and Calibration SOP ESR-1786, LRRI/seif Highlighted in Accountable

training 30Dec2012 0.5 attached Training

Sealed Source Manager report Control SOP ESR-1405, LRRII self Highlighted in Radiation

training 31Dec2012 0.5 attached Training

Dosimetry Manager report Program

SOP ESR-1407, LRRII self Highlighted in

Radiological training 31 Dec2012 0.5 attached Training

Postings Manager report

SOP ESR-1782, LRRII self Highlighted in

Radioactive training

01Jan2013 0.5 attached Training Contamination Manager report Controls SOP ESR-1404, Glovebox, Hood,

LRRII self Highlighted in and Benchtop

training 01Jan2013 0.5 attached Train ing

Control of Manager report Radioactive Materials SOP ESR-1774,

LRRII self Highlighted in Performing

training 27Jan2013 0.5 attached Training

Radiological Manager report Surveys SOP ESR-1774,

LRRII self Highlighted in Performing

training 07Apr2013 0.5 attached Training

Radiological Manager report Surveys

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SOP ESR-1399, Shipment and Receipt of LRRI/self Highlighted in Radioactive

training 07Apr2013 0.5 attached Training

Materials and Manager report Radiation-Generating Devices

SOP ESR-1787, LRRI/ self Highlighted in

Radioactive training 07Apr2013 0.5 attached Training

Material Controls Manager report

SOP ESR-1409, Radiation

LRRII self Highlighted in Worker

training 07Apr2013 0.5 attached Training

Requirements Manager report and Safety Training

Total hours of training 105.75

2. Dr. Benson's practical experience working with radioactive materials is summarized in Table 2, below. All the experience was obtained at LRRI (formerly the Inhalation Toxicology Research Institute). The total hours of hands on involvement with the listed studies/activities and the years in which they occurred are best estimates. Laboratory notebooks that may have provided details on yeast, dates and hours are no longer available at LRRI because Institute notebooks were required to be returned to the Department Of Energy. This was completed by 2010.

Study Component Isotope Maximum Clock (chemical Quantity Date of Hoursl

and/or physical Handled per Training Laboratory form) Experiment Training

Benson, J. M., "'NiO synthesis ""NiCI2 (starting 750 mCi NiCI2 et al. Fate of and material) 1992-

Inhaled Nickel characterization 14 grams 1993 Oxide and s'NiO (high 40

Nickel temperature, 1.6 Cilmmole

Subsulfide in green oxide) Ni

F344IN Rats.

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/nha/. Toxico/. 6'Ni,S, 6(2): 167-183, synthesis and 1994. characterization ·'NiCI, (starting

material) 800 mCi NiCl, 40

·'Ni,S, 17 grams 2.96 mCilmmole Ni

Inhalation s'NiO 9.9 mg/m' 60 Exposures C setup and

·'Ni,S, 5.7 mg/m' 60 conduct,

Animal ·'NiO

0.47 euthanasia, nCi/animal tissue harvest, metabolism 0.91 cage ·'Ni,S,

nCi/animal collections

Benson. J. M .. 800 mCi NiCl, et al. Particle 63NiSO. 6H,O >80 g

Clearance and synthesis and "'NiSO. 6H,O synthesized, 1992

Histopathology characterization 2.7

in Lungs of mCi/mmole Ni

F344/N Rats and B6C3F, "'NiSO. 6H,O

Mice Inhaling inhalation

Nickel Oxide exposure

or Nickel system setup 32

Sulfate. and animal

Fundam. App/. inhalation

Toxicol. 28: exposures 1993 -

232-244, 1994

"Sr 1995. polystyrene

·'Sr polystyrene latex particle 2.2 C 5.9 inhalation

latex particle (3.6 Bq/m'

30

exposures (7 C 4.7 fJm)

total)

Final Report: Uptake and ·'NiSO. 6H,O,

·'Ni,S" 0.001 Submitted to dissolution of fJCi; B'NiO, 0.1 1991 the Nickel nickel .aNiO, ·'Ni,S, fJCi; ·'NiSO. Producers compounds 6H,O.0.07

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Environmental studies in ~Ci per cell Research alveolar culture Association, macrophages experiment Inc. 1993. in vitro

Exposure system setup,

63Ni3S" 25 testing, and

63NiSO, 6H,O, mg/m3; 63NiO,

animal 10 mg/m3

; 1992 240 exposures (all 63NiO,63NbS,

63NiSO, 6H,O, compounds 34

15 mg/m3

monkey exposures)

Benson, J et Rat, mouse 0.48 ~Ci I ai, Uptake, and hamster ~mole Tissue nose only generator Distribution, exposures, solution

2000 24 and Fate of 14C-CCI, specific

Inhaled activity. 20 Carbon

Tetrachloride: ppm vapor Comparison of exposure, . Rat, Mouse,

Animal sample and Hamster. highest /nha/. Toxico/. collections and deposition per

48 13(3): 207- tissue harvest animal 1.75 217,2001 . j.lCi

Benson, J. M., Rat, nose only Uniformly labeled 2 mCi/mmole,

The Uptake, exposures (five 14C-methyl 4, 40, and 400 1996 -

40 Distribution, sets of 4 hour tertiary butyl ppm exposure 1998 Metabolism, exposures to ether concentrations and Excretion

14C-MTBE, of Methyl Tertiary-Butyl

sample Ether Inhaled Alone and in collection and

Combination tissue harvest with Gasoline Vapor. J. 40 Toxico/. Environ. Health A 66: 1029-1052, 2003.

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Benson, J. M., Intratracheal et al: Uptake, instillation Tissue Distribution, and Excretion of Brevetoxin 3 Administered

'H-brevetoxin 20 IJCi total

to Rats by dosing 1999 40 Intratracheal (labeled at C42).

solution. Instillation. J. Toxico/. Environ. Hea/th 57: 345-355, 1999.

Benson, J. M., Cutaneous 0.19 et al. Uptake, exposure in mCi/mmol (1.2 Tissue hairless guinea IJCi/mg), 18 IJL Distribution, pigs aliquots per

2009 -16

and Excretion 2012 of HC-Sulfur animal. Or

Mustard Vapor 21.6

Following IJCi/animal Inhalation in F344 Rats and Nose-only

(CICH2'·CH),S Cutaneous inhalation Exposure in exposure in Hairless rats 256 mgl Guinea Pigs. compoundlm'

2009-J. Toxicol. 15 IJCi 24 Environ. deposited per 2010

Health 74: rat. 875-885, 2011.

Carbon Nose-only Tetrach loride inhalation Data not

in exposure in reported . 1992 -

Combination rats and Syrian 238pU(NO,).. Notebooks

1994 40

with Plutonium golden submitted to

239-nitrate or hamsters DOE.

85Sr-labeled

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Fused Alumino­silicate Particles. Inhalation Toxicology Research Institute Annual Report 1993, pp 146-148. ITRI Annual Report 1995, pp 145 C 147.

3. Dr. Benson's experience in assessing liquid and gaseous effluents when operating under an established effluent monitoring program is largely limited to recent activities at LRRI and will be supplemented by available internal and external consultants on this matter. Dr. Benson had reviewed and commented on the SOP's related to the Bladeworks instruments used to monitor the gaseous effluents. She served as the technical reviewer of the Bladeworks Instrument Validation Report. The engineering rationale for the gaseous effluent stack setup was described to her in detail by Dr. Hammad Ishrad and together, they examined the system located on the LRRI roof. Dr. Benson has also examined the waste water effluent monitoring site and system and reviewed the Standard Operating Procedure covering its use. Dr. Benson is also supported internally by Dr. Dunstana Melo, Dr. Raymond GUilmette, Ralph Becker, Cheryl Schloesslin, and Larry Roybal as well as extemally by consultants Dade Moeller and MH Chew, as necessary.

Dr. Melo has vast experience in the health effects of radiation and bioassay measurements including assessment of dose calculations to members of the public. Dr. Melo has been directly involved in responding to inadvertent release of radioactive isotopes and is very active in the field of radiological safety. Dr. Melo has already assisted Dr. Benson and LRRl's Radiation Safety Committee by providing dose calculations and interpretation of COMPL YCode results for incorporation into LRRl's effluent monitoring standard operating procedure.

Dr. Guilmette has over 40 years of experience with radiation safety and dose monitoring and has served as an Assistant Health Physicist (please see attached CV).

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Mr. Becker is serving the role of Assistant Radiation Safety Officer and is dedicated to assisting the RSO in all ways necessary for program improvement. Mr. Becker was the Health Physicists for the University of New Mexico from 1994-2013 and, as such, was responsible for assuring an adequate effluent mon ito ring program (please see attached CV).

Ms. Cheryl Schloesslin has experience in developing and auditing quality systems in radiological testing environments as well as analyzing isotopes (please see attached CV). Currently, Cheryl works closely with Dr. Benson in her RSO delegate role . Mr. Roybal has experience in working with transuranics and waste as well as working within environments that have an established effluent monitoring program. Drs. Irshad and Melo, Mr. Becker, Mr. Roybal, and Ms. Schloesslin are full time LRRI employees and available to consult with Dr. Benson on a regular basis.

Dade Moeller and MH Chew are external consultants that have been qualified and used by LRRI historically. They are available for additional consultation should the need arise, and should Dr. Benson have questions that internal personnel are not able to answer. Dr. Benson is also actively familiarizing herself with NRC regulations and ANSI standards and has been involved in discussions around fully implementing LRRI's gaseous and liquid effluent monitoring programs. Dr. Benson has also been in direct contact with the staff of Ecology Services regarding questions of hazardous waste shipments planned for summer 2013.

4. Dr. Benson has been actively involved in and has lead studies which utilize radioactive materials since the 1980s. Dosimetry and bioassays have been a part of these studies; thus, she is familiar with how personnel monitoring programs work and how they are implemented. Dr. Benson has not had direct experience with determining the need for and evaluating bioassays, monitoring personnel exposures records, determining the optimal sampling frequency and developing corrective actions. However, Dr. Benson is supported at LRRI by Dr. Melo (see description above and attached CV) who has vast experience with dosimetry and bioassay determinations and assessments.

5. Dr. Benson has committed at least 90% of her time to her role currently as RSO delegate. This will continue to be the amount apportioned to the RSO role, should the NRC approve this appointment. As is stated in the memorandum summarizing Dr. Benson's qualifications, she is currently a member of the RSC, LRRI Select Agent, Biological Toxins Security Committee, and IACUC. She was a member of the RSC prior to becoming delegate RSO. Current involvement relates directly to the RSO and RSO delegate positions, thus will be considered time dedicated to the radiation safety program. Dr. Benson has research experience in with select agents and therefore is a member of the BSAT committee. Involvement with the

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safety team takes a minimal number of hours per month. Continued participation allows a broader view of safety and emergency response procedures implemented throughout the Institute and therefore is of use to the radiation program. Dr. Benson is now a second altemate chair to the IACUC and as such has minimal time dedicated to that committee. She serves as needed in the absence of the chair and first alternate and reviews protocols, including the radiation safety component (as applicable) for the committee. Dr. Benson's involvement with the committees are seen as supplemental to her potential role as RSO and will not interfere with nor become too large of a time burden that they may detract from time necessary to actively participate as the RSO on a daily basis at LRRI.

6. Dr. Benson's training and experience in the specific areas queried are as follows: • Ordering, receipt, surveys, and delivery of byproduct material:

o Since her appointment as RSO delegate, 99mTc has been the primary RAM purchased. Dr. Benson has participated in ordering, this material and has observed receipt and surveys. She has worked with QA staff and Mr. Becker to update the receipt procedure. She has also reviewed survey results, and interviewed personnel currently involved with these procedures at LRRI.

• Packaging, labeling, surveys, etc., of shipments of byproduct material leaving the institution. Specifically, provide documentation showing Dr. Benson has received Department of Transportation (DOT)/HAZMAT training.

o Dr. Benson is currently taking the DOT Hazardous Materials Transportation Initial Training - Online (Complete Certification) offered on line by Compliance Solutions. She expects to achieve certification by July 5, 2013. A copy of the course authorization is attached and a copy of the completion certificate will be provided upon successful completion of the course.

• Waste disposal

o Dr. Benson has personally and hands-on been involved with packaging 239pU and 241Am waste for offsite shipment this summer. LRRI and worked in tandem with current on-site experts in this area. She has been directly in contact with the staff of Ecology Services which will provide transport of the waste off site. She is aware of the need submit an application to the Rocky Mountain Low-Level Radioactive Waste Board to export waste from the Rocky Mountain Region. She has been advised of the components of the request and will work with Mr. Roybal to properly prepare and submit an application to export waste this summer.

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• Inventory and Leak Tests of Sealed Sources

o During an inventory of sealed sources at LRRI, the presence of a USDOT special form capsule containing approximately 18Ci of 238pU was noted. Possession of this amount of 239pU classifies LRRI as a Category 2 facility. Dr. Benson is working with Off-site Source Recovery Program (OSRP) to return the material to Los Alamos National Laboratories. Dr. Benson has also worked to inventory and secure sealed check sources at LRRI.

• Decontamination

o Other than decontaminating areas within her specific laboratory space, Dr. Benson has no experience with large scale decontamination of facility areas but is supported internally by experiences staff as noted above.

• Investigating any incidents and responding to emergencies

o Dr. Benson is an active member of the Albuquerque Community Emergency Response Team. OngOing training includes working with Incidence Commanders and first responders in dealing with emergency situations, search and rescue, triage, and reporting. She is prepared to be a subject matter expert in directly dealing with emergency responders at LRRI should the need arise.