ML20028G350
| ML20028G350 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/01/1983 |
| From: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Vaughan C GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20028G351 | List: |
| References | |
| NUDOCS 8302080471 | |
| Download: ML20028G350 (18) | |
Text
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RECunningham BBrooks General Electric Company ATTN: Mr. C. M. Vaughan, Manager GBennington Licensing and Nuclear Materials i
DWeiss Management M/CJ26 JBlaylock P.O. Box 780 Region II CCoryell, R:II Wilmington, NC 28402 i
t Gentlemen:
We have completed our review of your application for renewal of SIM-1097.
i Enclosures 1 and 2 provide our comments and identify supplemental information needed for the renewal. This information should be provided within 6 months of the date of this letter.
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Also enclosed is a copy of Materials License SIM-1097 as revised. This revistoi includes a change in the expiration date of the license, the addition of environmental monitoring license conditions and incorporates all previous license amendments into S W 1097. This action was discussed, and agreed to, by your Mr. Vaughan and Mr. Bidinger of g staff.
Enclosed with the license is a Safety Evaluation Report which describes l
the disposition of the 27 amendments to SIM-1097, modification of two license conditions (12 and 14), and the addition of environmental monitoring conditions (21-23).
i In accordance with 10 CFR 51.5 the Commission will prepare an environmental inpact assessment related to the issuance of a full term renewal of your i
special nuclear material license. As required by NEPA, this assessment will i
l evaluate the impact of both radiological and non-radiological contaminants in the effluents fmm the GE facility. As discussed by your Mr. Vaughan and g staff, we have reservations regarding your method of determining total fluoride releases in the gaseous effluents from your fuel facility. Also, there may be other sources of fluorides from your facility. GE should conduct a program to provide valid data on the floride release rate and a i
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determination of the environmental impact associated with these releases.
We believe an adequate program to evaluate the inpact of fluoride releases at your site should include am6ient air and vege1:ation sampling and analysis, as well as, stack monitoring to develop source terms. This inforation will be valuable to GE in demonstrating that the cuaulative impact of the total fluoride released from the site would not result in significant impact to the environment. This issue is discussed further in the enclosed Safety Evaluation Report.
Sincerely, a
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.n G. Psgo R. G. Page, Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, INSS
Enclosures:
1.
Request for Supplemental Safety Information 2.
Request for Environmental Infora tion 3.
Materials License No. SNM-1097, as amended 4.
Safety Evaluation Report 1
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FEB 1 1303 Request for Supplemental Information License Renewal Application 5/27/81 Chapter 1.0 1.2 Figure 1.1, referenced in 1.2, should be revised to show all use areas (lagoons, storage pads, etc.).
1.4 This section requests uranium in "any form." Metal, pyrophoric materials, etc., should be excluded.
1.4.3 Identify the isotope that was enriched in the requested special nuclear material.
1.5.3 Since there was no licensed activity here, this subsection should be moved to the safety demonstration part of the application.
1.5.4 Figures 1.3 and 1.4, which are referenced in 1.5.4, should be updated.
1.6.4 The reflector thickness should be expressed as greater than 3 inches, but not less than 12 inches, of water.
1.8.2 This section should be revised to include the attached Annex as an enclosure to Chapter 1.
1.8.3.2 The recipient of the nitrate bearing liquid and the environmental monitoring program should be specified.
1.8.4.1 Identify who has the safety responsibility for the material being used at off-site location.
1.8.4.2 and 1.8.4.3 Provisions to comply with Part 73 requirements should be briefly addressed.
1.8.5 This section should be deleted because of revised Part 20 requirements.
1.8.6 The section needs editorial work to delete erroneous numbers.
Provisions to comply with Part 73 requirements should be addressed.
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2 1.8.7 This section should be revised to indicate how the control factor will be utilized. Will a factor of 100 always be used?
1.8.8 Two of the proposed units have erroneous references to Chapters "1.6.10" and "1.8.5(3)."
These references are unclear; hence, further review and comment is not possible.
1.8.9 Editorial correction to "10 CFR 10.305" is needed.
Chapter 2.0 2.2.1 One person should have overall responsibility for safety and compl iance.
This individual should be identified, e.g., the WMD General Manager.
- 2. 2.1. 2
" Measurement of the program effectiveness" should be defined to ensure safety and to permit demonstration of compliance.
2.2.1.4 We believe that for the Radiation Protection Function Unit to conduct its work independently, the Supervisor of the Radiation Protection Function should have the authority to shut down an operation which he believes threatens the health and safety of employees or the public.
- 2. 2.1. 5 The responsibilities of the environmental protection function should be stated explicitly.
2.3 The qualifications of committee members should be established in this section.
The committee should have responsibility for providing a formal annual report which reviews employee radiation exposure (internal and external) and effluents release data to determine:
a.
if there are any upward trends developing in personnel exposure for identifiable categories of workers, types of operations, or effluent releases, b.
if exposures and releases might be lowered in accordance with the ALARA concept, and c.
if equipment for effluent and exposure control is being properly used, maintained and inspected.
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3 This report should include review of other required audits and inspections performed during the past 12 months, and review of the data from the following areas: employee internal and external exposures; in-plant airborne radioactivity and surface contamination levels; and environment monitoring.
This report should also include a recommendation for any required action necessary to assure adherence to the ALARA concept in all areas of the radiation safety program.
An individual in top management (General Manager of WMD) should be identified and be responsible for assuring that the recommendations introduced by the SRC are implemented.
2.5.2 It appears that the criticality safety function's minimum experience and qualifications requirements needs upgrading because of the general technical complexity of codes and interpretation of critical mass data.
The junior member should have a bachelor's degree in a related science or engineering. The senior member should have a bachelor's degree in a related science or engineering with a minimum of two years' experience in out-of-reactor nuclear criticality safety work and demonstrated competence.
2.6.1 This section should indicate that an individual whose work involves handling licensed material must finish a formal training program in radiation protection prior to working in the controlled area.
2.6.2 The maximum time interval for " periodic" safety meetings should be defined.
2.6.8 Retraining of individuals with access to the uranium areas should be scheduled annually. Conditional words such as " continually" should be deleted.
2.6.10 The frecuency of training program audits and the function that performs the audits should be specified.
2.7.1 The minimum frequency for review of instructions by the radiation safety function should be specified.
" Generally annually" is not acceptable.
2.7.4 TP.e minimum frequency and the organizational review function that will document the review should be snecified.
"As required" is not appropriate.
FEB 1 ii33 4
2.8 This entire section (2.8.1 though 2.8.3) needs to be revised to provide the maximum interval between inspections and audits (including specific exceptions, if any), identification of the inspection or audit function, treatment of inspection or audit findings (to include, as a minimum, written documentation of audits and of necessary corrective actions), and distribution of such documen-l tation (including General Manager and members of the Safety Committee).
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2.8.2.2 This section should require that the quarterly audit be conducted in accordance with a preconceived written audit plan approved in a manner established by GE management.
2.9 In Table 2.1 (page 2):
the classification of incidents is ba'.ed on " permit criteria." The classification should be based on regulatory limits as well.
In 2.9.22, the " operations manager" has certain responsibilities.
This individual and his responsibilities should be included in Section 2.2.1 and in Chapter 11.
2.10 The following records should be maintained for at least 2 years:
1.
Records of the safety review connittee meetings.
2.
Releases of radioactive contaminated equipment to unrestricted area.
3.
Instrument calibration.
4.
Safety audits.
5.
Training and retraining.
6.
Radiation work permits.
7.
Surface contamination surveys.
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Airborneradioactive material in the facility concentrations.
9.
Radiological safety analyses.
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Chapter 3J 3.1.1 This section should confirm that unless the operation for maintenance work is covered by an effective operating procedure, a Radiation Work Permit (RWP) shall be prepared for all work where a potential for release of contamination exists or the potential for radiation exposure exists.
The RWP should specify the necessary radiation safety controls including but not limited to respiratory protection, special air sampling, and special local ventilation.
The RWP shall have an expiration date, and the RWP shall be reviewed by Radiation Protection Function weekly.
3.2.2 The following specifications relevant to ventilation requirements should be added in this section, or deviations should be justified:
1.
Air flew through open faced hoods or other open faced containment devices shall meet a minimum requirement of 100 LPM.
2.
Each glove box used to handle licensed material shall be equipped with a device to measure the relative pressure in the enclosure.
3.
Specify at what pressure aifferential level the HEPA filter in the exhaust system shall be replaced. The pressure differential across the HEPA filter should be checked on a monthly basis.
4.
Direction of air flow in the work area shall be checked on a monthly batis.
3.2.3.3 This section should require that radiation survey instruments be calibrated every 6 months.
3.2.4.2 The air sampling program should be revised to contain the following:
(a) Permanent air sampling equipment used to determine airborne concentrations of radioactivity shall be evaluated for its representativeness of personnel exposures at least once every 12 months and whenever any licensed process or equipment changes are made.
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6 (b) During the normal operation period, airborne ccacentra-tions of radioactivity in the work area where the dispersible form of radioactive material is handled shall be analyzed every shift, and if a single air sampling station indicates the airborne concentration of radioactivity for that area exceeds the MPC air specified in Table I, Column 1 of 10 CFR 20, Appendix B, an investigation as to the cause shall be conducted and any necessary corrective action shall be taken and documented.
3.2.4.3.1 Unless a statement is made that the bioassay program shall be conducted in accordance with Regulatory Guide 8.11. " Application of Bioassay for Uranium," June 1974, this section on the bioassay program should be revised to contain the following elements (any deviation from the specification in Regulatory Guide 8.11 should be justified):
1.
Criteria for determining who is required to participate in the specified bioassay program.
2.
Frequencies for bicassay, action levels and action to be taken at each action level for each measurement technique (bioassay frequency should vary according to the elevation of airborne concentration of radioactivity in the work area and dust classification).
3.
Criteria for determining that a diagnostic bioassay measurement shall be initiated.
3.2.4.5 Notwithstanding the respiratory protection program described in Section 3.2.4.5, GE must comply with 10 CFR 20.103.
This section should be revised accordingly.
3.2.4.6 This section should be revised to contain the following additional specifications:
1.
Survey frequency fo? the area where food is allowed shall be each day.
l 2.
Action levels (in units of dpm/100 cm for removable and total 2
counts) for cleanup of each area should be stated.
If GE's action level for cleanup is different from that which Regula-tory Guide 8.24, Table I, has suggested, a justification should be provided for the staff's evaluation.
If the remedial action (decontamination) is to be delayed, it should be noted that in no case shall the delay exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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3.2.4.7 This section should be revised to require that an individual whose skin or personal clothing is found contaminated above background radiation level may not exit a controlled area without prior approval of the radiation protection function.
3.2.4.9 The section should be revised to provide:
(a) the frequency for reading personnel dosimeters.
(b) the action levels of personnel exposure above which an appropriate action will be taken to prevent the total exposure from exceeding the maximum permissible exposure specified in 10 CFR 20.101.
Include the action to be taken.
Chapter 4.0 4.1.1 We note that "the preferred method for assuring nuclear criticality safety is by the use of geometry control."
In 1.4.3, a possession limit of 500 kg of uranium enriched up to 15% in the U-235 isotope is requested.
In Tables 4.1, 4.2 and 4.3, geometrical limits are provided only for enrichments up to 7% U-235.
In line with the expression of philosophy, the three tables should provide geo-metrical limits for the higher enrichments.
4.1.2 If the area manager is the individual who is to determine whether or not a criticality review and approval is necessary, a vigorous training program should be developed and adhered to in Section 2.6.
On the other hand, if it is the area manager's responsibility to seek a review by the nuclear safety function, such a vigorous training program may not be necessary.
The requirements for the safety committee to review major analyses should be expressed in Section 2.3.
4.1. 6 Audits and advice on training should be included in the role of the safety function.
4.2.1.3 In this subsection, a limit of 0.97 for K-effective is proposed.
Limited validation effort in Chapter 15 demonstrates that this lin it is unacceptably high and needs downward revision.
4.2.1.4 Thi tubsection should also include a consideration of the maximum enrichment.
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4.2.1.5 Use of all analytical methods referenced in this section must be demonstrated in Part II of the application.
4.2.2.1 This section should also include a requirement for consideration of maximum and minimum dimensions, as appropriate.
4.2.2.5 The criteria for use of fixed neutron absorbers is deficient in that it does not require verification of the initial presence of the absorber, nor does it provide for lockout of the system if the absorber is removed.
This section should include conditions in the existing license.
4.2.4.2 The criteria for undermoderation controls should be expanded to satisfy the philosophy of 4.1.4, viz, two unlikely, independent, and concurrent changes will be required before criticality is possible. As presented, double barriers and/or other controls are not required in 4.2.4.2.
Chapter 5.0 5.1 The lower limits of detection (LLD) for analysis of airborne concentration of radioactivity in the facility. and liquid and airborne effluents release to unrestricted area from the facility shall be not more than 10% of the concentration limits listed in Table I and Table II, respectively, of Appendix B to 10 CFR Part 20.
LLD is defined in Regulatory Guide 4.16, March 1978.
5.1.1.1 Please identify the exhaust stacks that will be sampled for-radio-activity and provide the frequency of analysis.
l 5.1.4 Justification is required for treating low activity level liquid waste as contamination-free liquid.
l Chapter 7.0 7.0 This section needs to be updated to incorporate the decommissioning plan approved by Amendment No. 22 to SNM-1097.
Chapter 8.0 This section needs to be updated to incorporate the contingency I
plan approved by Amendment No. 24 to SNM-1097.
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.:. w,y Chapter 10.0 10.1 In Figure 10.2, the two waste treatment facilities and the storage pads should be given unique identifications, e.g., Pad No.1.
10.3.10 If the exhausted air from hood or chemistry lab is not being monitored for radioactivity, please provide a justification.
Chapter 11.0 11.4 & 11.5 The name and title of the key person in the Nuclear Energy Business Group in San Jose, California, should be identified.
11.'4 Key functions for safe operations extend beyond the safety function.
These functions in production and support services should be described herein.
11.6 A section describing the training program needs to be developed.
Chapter 12.0 12.8 Table 12.2 should be revised as follows:
(a) about skin contamination limit: see comment for Section 3.2.4.7.
(b) action guide for urinalyses appears to be in error.
Chapter 13.0 Paragraph 20.203(d)(1)(ii) of 10 CFR Part 20 requires that action shall be taken if the airborne concentrations exceed 25% of the MPC specified in Appendix B, Table I, Column I, of 10 CFR Part 20.
The records of average air concentration of radioactivity in various work areas submitted reveal that the air level at some work areas constantly exceeds 50% of MPC.
See, for example, the
" inner room" of the decontamination facility, where an average of 1 MPC air level can be observed.
We request that GE provide an appendix to the chapter, describing measures planned or taken to reduce the airborne concentration of radioactivity in work areas where elevated airborne level was observed.
The appendix should include a proposed schedule for completion of corrective actions.
13.1.3.2 Air concentration in the chemical area appears to be in error.
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- 163 10 13.6.2 In table 13.9, the p missible level for alpha contamination should be 220 dpm/cm Chapter 14.0
'14.1.2.1 The unit used for Q on Page 11.14.5. appears to be in error.
Chapter 15.0 15.1.1 Area manager assignments are listed in Table 15.1.
These assignments should be identified with personnel in 11.5.
15.2.1 It should be an explicit requirement that the safety manager will sign off on an FCR request.
Revisions should be included in the license condition section.
15.2.2 and 15.2.4 These sections should be revised so that the nuclear criticality safety function review and approval documents should (a) explicitly identify the design limits upon which subtriticality depends that require physical verification at the completion of construction, and (b), explicitly identity the operating limits upon which subcriticality depends that require implementation in operating procedures. Revisions should be reflected in the license condition section.
15.3.1.8 The administrative controls are listed in the order of preference.
The first preference (15.3.1.8.1) is mass control. The fourth preference (15.3.1.8.4) is a combination of controls, e.g., mass and moderation.
It would seem logical as well as highly desirable and perhaps necessary to satisfy the philosophy of 4.1.1, that dual j
controls be the first preference when use of favorable geometry is not practicable.
Revisions or justification should be provided.
l 15.3.1.8.2 A safety factor of 2 for moderation control may not provide a sufficient margin of safety for low moderation material, Because the amount of moderator may be extremely small, the safety factor should be recor.sidered.
15.3.1.8.3 This section, which is limited to a reference to Chapter 4.0, does not demonstrate how density control will be used in design l
considerations. Density corrections may be made only when the H/X 1
ratio remaics constant.
This section should be revised accordingly.
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11 FEB 3 :y3 15.4.4.2 The basis for neglecting quantities on volumes less than 10% of Table 4 quantities should be provided.
Is the negligible quantity limited to an individual unit or is it part of a unit? This should be clarified in presenting the basis.
15.4.4.3 The basis for ignoring fissile units when k-infinity for r:aterial in the unit is less than unity should be provided. J. T. Thomas shows that this is not universally acceptable (reference NUREG/CR/2223).
15.4.4.5 This reference in this section is incorrect and should be revised.
15.4.4.6 The basis for this spacing / interaction criterion should be provided.
15.5 Numerous diffusion, transport c$nd Monte Carlo codes are described in this section.
There is no indication, however, that some of the codes are validated in the application. Without the validation and demonstrated use of the codes, a basis for cooe approval does not exist. Accordingly, the validation and use should be provided, cr reference to the code should be deleted.
15.6 We note that validation efforts for GEKEN0 show that k-effective
+ 3 sigma in Table 15.2 violates the proposed k-effective =0.97 criterion of Chapter 4.0.
In Table 15.6, the k-infinity values of MERIT and GEMER are sub-stantially different.
Since the two codes use the same cross-sections, this should be explained.
We note that the validation efforts in Table 15.? are not for U0 An allowance for different materials must be l
ma$-watermixtures.e in any validation effort and an appropriate allowance I
l provided for in the maximum k-effective / limit. The maximum k-effective in Chapter 4.0 should provide for this margin of uncertainty.
l Chapter 16.0 General Comments The process descriptions should be expanded to cover all process steps, including inprocess storage.
Each process description should be detailed enough to permit independent review of the safety analysis.
The safety analysis should demonstrate safety of the individual unit and of the associated array of units.
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. Rod 12 The demonstrated basis for nuclear criticality safety should be the criteria in Chapter 4.0 or should be subject to specific license conditions expressed in Chapter 6.0.
16.1 In line with the general comments above, are OR-30 cylinders to be stored only on the raised cement platform? Use of cylinder valve covers during storage and transit should be established as a condition in Chapter 6.0.
Will UF, enriched to more 7% U-235, be limited to the mass limits inTabib4.4? The proposed 80% of a critical mass as a limit for U(75)F violates Table 4.4 and the definition of a safe mass in g
1.6.
Revisions should be made to this section to provide consistent application of safety criteria.
16.E.1.3 The safety analysis should demonstrate, by means of a solid angle calculation, that the equipment size and spacing satisfies the solid angle criteria.
16.2.3.3 The reactivity analysis for the centrifuge should be included in the section.
Ak of 0.97 is unacceptably high. - The centrifuge should be describ$d7along with assumptions used in the calculation.
Unless controls are established as conditions of license, optimum moderation and full reflection must be considered normal.
16.2.4.2 The comment in 16.2.3.3 above also applies to the analysis for the defluorinator. Storage or shipment of the product must be described and analyzed in the application.
16.3.2.2 The comment in 16.2.3.3 above also applies to the GEC0 reactor and filter.
16.4.2 The comment in 16.2.3.3 above also applies to the hammermill and granulators.
The moisture enalysis and moisture limit should be established in Chapter 6.0.
16.8.2 The GEBLA code is used here for the safety analysis.
It should be identified and described in Chapter 15.0.
16.12.2 The safety analyses for the fuel bundle storage area should be described.
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16.14 The array analyses for the process equipment and the storage areas must be provided. License conditions for transfer of liquids from quarantine tanks to the 20,000-gallon tanks should be provided in Chapter 6.0.
Prevention of sludge should be described.
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- g;g 13 16.15.1.1 The safety analysis using GEMER should be provided.
16.15.2 Controls on transfers from favorable geometry to unsafe geometry should be described in Chapter 6.0.
The reference to a description of 6-inch slab tanks in 16.2.3 is inadequate since 16.2.3.1 references this section for a description.
3 16.15.5 The ncclear criticality safety analysis for solid waste should address individual container safety and array safety.
Fire safety of combustible solids in storage must also be addressed.
16:18.7.4 This section should address disposal of all liquid wastes.
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FEB 1-1833 Request for Environmental Information In connection with your license renewal application, environmental information is required to allow NRC to conduct an environmental impact assessment in accordance with 10 CFR 51. Please provide an updated and consolidated environmental report addressing the various topics as shown in the index shown on the next two pages.
If some of the infermation is available in your past documents, please make an effort to update that inf<ormation and enclose them as an appendix.
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FE::i 1 wa Information To Be Submitted on the Following Topics 1.
Introduction 1.1 Description of the Proposed Action 2.
Description of Site Environment 2.1 Site Location 2.2 Demography 2.3 Land Use 2.4 Geology 2.5 Hydrology 2.5.1 Surface water 2.5.2 Groundwater 2.5.3 Water Use 2.6 Meteorology and Climatology 2.6.1 Winds, tornadoes and hurricanes 2.6.2 Atmospheric dispersion 2.7 Background Characteristics 2.7.1 Radiological Characteristics 2.7.2 Nonradiological Characteristics
- 2. 7. 2.1 Atmospheric Effluents 2.7.2.2 Background nonradiological characteristics of water 2.8 Ecology l
2.8.1 Terrestrial biota 2.8.2 Aquatic biota 3.
The Facility 3.1 External Appearance 3.2 Operation Processes 3.3 Waste Confinement and Effluent Control l
3.3.1 Gaseous effluents 3.3.2 Liquid effluents 3.3.3 Solid wastes
2 fEB 1 1983 4.
Environmental Impacts of Facility Operations 4.1 Radiological Impacts 4.1.1 Terrestrial 4.1.1.1 Individual dose 4.1.1. 2 Population dose 4.2 Nonradiological Impacts 4.2.1 Terrestrial Impacts 4.2.2 Aquatic Impacts 4.2.3 Impacts of liquid effluent on groundwater 4.2.4 Impacts of solid waste 5.
Environmental Monitoring Program 5.1 Radiological 5.1.1 Air monitoring 5.1.2 Water monitoring (surface and groundwater) 5.1.3 Area monitoring (fallout, vegetation, soil and fish) 5.2 Nonradiological 5.2.1 Atmospheric monitoring 5.2.2 Monitoring of surface waters 5.2.3 Groundwater monitoring 5.3 Summary of Effluent and Environmental Monitoring Data from the Past Five Years and Interpretation 6.
Impact of Accidents 6.1 Radiological Accident Evaluation 6.2 Nonradiological Accident Evaluation 6.3 Accidents which occurred in the past five-year operation and their environmental impact.
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