ML20076M698
| ML20076M698 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/05/1982 |
| From: | Hildebranch J, Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 1000-PLN-4010.0, NUDOCS 8307210049 | |
| Download: ML20076M698 (16) | |
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GPU duclear Corporation Radiation Protection Olan 0
Applicability /f., cope Responsiole Office nil GPU iluclear Personnel 9000 P.'. D.
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Title l Revision No
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GPU Nuclear Corporation Radiation Protection Plan l0 Taole of Contents Article Page No.
Article 1 Foundation for tne GPU Nuclear Radiological
- 3. 0 Controls Program Article 2 Responsibilities of Workers 5.0 Articl e 3 Audits, Reviews and Reports on the GPUN 7.0 Radiological Controls Program Article 4 Radio 1ogical Control s Training
- 9. 0 j-Article 5 Control of External Exposure 10.0 Articl e 6 Control of Internal Exposure 12.0 l
Article 7 Control of Radioactive Contamination 13.0 Article 8 Control of Radioactive Materials 14.0
'- T Article 9 Organization for Radiological Controls 15.0 i
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GPU Nuclear Corporation Radiation Protection Plan j 0 Article 1 - Foundation for GPU Nuclear Raciolcaical Controls Program The GPU Nuclear (GP'UN) Radiation Protection Plan sets fortn the philosophies, basic policies and objectives of tne Raciological Controls Programs at TMI-1, TMI-2 and Oyster Creek Nuclear Generating Stations.
Tne objective of the raciological controls program is to control radiation hazards tc avoid accidental radiation exposures, to maintain exposures within tne regulatory requirements, ano to maintain exposures to workers and the general population as low as is reasonaoly achievaole.
Tnese pnilosophies, policies, and objectives are based on and implement the regula-tions of tne Nuclear Regulatory Commission (NRC) as contained in Title 10 of the Coce of Federal Regulations, Parts 19, 20, 50, and 71, ano appropriate Regulatcry Guides, specifically 8.8 Rev 3 (1978), 8.10 Rev 1-R (1975), 8.13 Rev 1 (1975), and 8.15 (1976). Tne GPUN Raciation Protection Plan is cased on tnese references; therefore, they are not repeated throughout the remainder of this document.
Specific details as to how the GPUN Radiation Protection Plan is implemented shall oe promulgated in the plant specific Radiological Controls Procedures Manual (RCPM) and snall include those applicable procedures addressed in Reg. Guide 1.33 Rev. 2 (1978), App. A, paragrapn 7, and paragrapn 8 (aa), (bb); further references to the RCPM are not repeated throughout this document. The RCPM will consist of revi-sions to existing procedures, applicable Administrative procedures, and additional proceduresdeemednecessaryhoverningreleaseofraoioactiveliquidsandgase This GPUN Radiation Protection Plar, is tne first part of-tne RCPM. Requirements environment and the disposal of solid radioactive waste are not addressed in this GPUN Radiation Protection Plan, but are addressed in the Technical Specifications.
Verbatim compliance.with the GPUN RCPM is mancatory.
In the event a procedure cannot be followed exactly, work under tnat procedure shall be stopped and shall not commence again until the procedure has been corrected.
This GPUN Radiation Protection Plan and the RCPM are written to increase the effectiveness of the Radiological Controls Programs. _ Procedures shall provide adequate guidance and specify appropriate methods or techniques to insure that the performance of each activity is in accordance with sound radiological controls principles, and is in compliance with applicable regulatory provisions.
The RCPM snall De preparea, reviewed, approved, and controlled as described in the GPUN Administrative procedures.
The GPUN Radiological. Controls Program is to be fully integrated into each and every_pnase of operations'at TMI-1, TMI-2 and Oyster Creek. The Radiological Con-trols Program when carried out.as specified will assure tnat the operation of the GPU Nuclear Generating Stations will be performed witn personnel who work at the site
' incurring radiation exposure as' low as can reasonably be achieved.
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In order to meet this objective, the program must be_ carried out by eacn person involved in radiological _ controls activities.. Tnere is no group or person' involved sj in nuclear' operations who does not nave some degree of responsibility for the Radiol-
. g ogical Controls Program. Failure of any person to recognize this responsibility or
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A radiologically safe ioperation will be achieved if eacn individual carries out his or her responsibility.
i The performance of eacn manager and supervisor must demonstrate support for the commitment by top corporate management to a strong, effective radiological controls program.
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Article 2 - Responsibilities of Workers Although personnel specially trained in radiological controls nomally oversee Radiological work, each individual involved in this work must constantly remain aware of the potential radiological oroblems. Each individual is responsible for maintain-f ing his or her exposure as low as reasonably achievable.
Each individual's actions directly affect his exposure, contamination, and overall radiological problems associated with the work. The following rules shall be followed by individuals to i
minimize radiological problems:
I 1.
Obey promptly "stop-work" and " evacuate" orders of radiological controls personnel.
l 2.
Obey posted, oral, and written radiological controls instructions and procedures, including instructions on Radiation Work Pemits.
3.
Wear TLD and self reading dosimeter where required by signs or by radiolo-gical controls personnel.
Immediately report loss or unexpected exposure and offscale dosimeter to Radiological Controls Department.
4.
Keep track of personal radiation exposure status and avoid exceeding exposure limits.
5.
Remain in as low a radiation area as practicable to accomplish work.
6.
Do not loiter in radiation areas.
7.
Do not smoke, eat, drink, or chew in a Radiologically Controlled Area unless specifically authorized by the Radiological Controls Manager.
8.
Wear anti-contamination clothing and respiratory protection properly and wherever required by signs or by Radiological Controls personnel.
9.
Remove anti-contamination clothing and respiratory protection properly te minimize spread of contamination.
10.
Frisk or be frisked for contamination when leaving a contaminated area or a radiological control point. Notify Radiological Controls personnel if contamination is found.
11.
For a known or possible radioactive spill, minimize its spread and notify j
radiological controls personnel promptly.
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Do not unnecessarily touch a contaminated surface or allow clothing,
,j tools, or other equipment to do so.
_i 13.
Place contaminated tools, equipment and solid waste on disposable surfaces
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(for example, sheet plastic) when not in use and inside plastic bags when 5
work is finished.
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14.
Limit the amount of material that nas to be decontaminated or disposed of ds radioactive waste.
15.
Notify Radiological Controls personnel of faulty or alarming radiation protection equipment.
16.
Report tne presence of open wounds to radiological controls and medical personnel prior to work in areas where radioactive contamination exists and exit inuediately if a wound occurs while in such an area.
17.
Notify Radiological Controls personnel upon returning to the site after medical administration of radiopharmaceuticals.
18.
Assure a mentally alert and physically sound condition for performing assigned work.
19.
Ensure that your activities do not create radiological problems for others and be alert for the possibilities that the activities of others may change the radiological conditions to which you are exposed.
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- 0 i Article 3 - Audits, Reviews and Reports on tne GPUN Racioloaical Controis Procram 4
j As indicated in Article 2, each individual is responsible for maintaining his or her radiation exposure as low as reasonably acnievaole wnile completing the scope of work tney are required to perform. Each will be required to comply witn the applica-ble procecures of the plant specific RCPM and tne specific radiological controls prescrioea for work in wnicn tney are engaged.
In orcer to ensure that these requirements are being met and to assist all site-personnel in understanding and complying with tnese requirements, a system of audit and review proceoures shall be established including criteria for timely and appro-priate corrective action. The following audit and review procedures shall be used:
1.
Radiological Controls tecnnicians shall monitor and aid the performance of each individual insofar as radiological work practices are concerned.
2.
Tne Radiological Engineering section shall review on a regular basis the performance of tne radiological controls technicians. This review in-cluces shift coverage on those jobs whicn are considered likely to have a nign notential for radiological difficulties.
3.
Radiological assessments shall be concucted tnroughout the Radiological Controls Program on a continuous basis. Tnis assessment function shall report directly to tne Vice President - Radiological and Environmental
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Controls. A written report of the findings of this assessment shall be prepareo and issued at least monthly.
4.
Radiological Controls is subject to tne provisions of the Corporate Quality Assurance Plan.
5.
Tne GPUN Radiation Protection Plan and any changes thereto shall be reviewed in accordance witn applicaole Technical Specifications. All RCPM's snall also be reviewed in accordance with the applicable Technical Specifications.
Periodically, the services of an outside consultant will De utilized to o.
provi.de evaluation and guidance on ways to improve the Radiological Controls Program.
7 In adaition to tnese reviews 'and aucits, a system snall be employed to identify raoiological controls deficiencies. A radioloaical controls ceficiency is defined as eitner a violation of an established procedure or a practice wnich could and should be improved.
Such deficiencies are recordedLin a Radiological Deficiency Report.
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specified in the RCPM embodying the following concepts. A Radiological a
Deficiency Report may be initiated oy any individual who observes a i
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-deviation from 9000 raciological practices. Tnese reports shall ce evaluated by Radiological Engineering fcr cesiracle or necessary correc-l tive action. Tne purpose of this system is to identify all deficiencies, i
regaraless of how small or inconsequential, the correction of wnich will result in an improved' Radiological Controls Program. The Radiological Engineering group snall prepare a montnly report summarizing the Radiolo-gical Deficiency Report findings and corrective action taken.
8.
Tne Nuclear Regulatory Commission (NRC) also inspects and reviews the.
Radiological Controls Program. The Raaiation Protection Plan and any enanges thereto shall be submitted to the NRC for information.
(The Raaiation Protection Plan and any changes tnereto shall be submitted to tne NRC for approval for TMI Unit 2 only.)
9.
In tne event all the preceding measures fail to prevent a radiological incident, an investigation shall be conductec to determine the causes of tne incident and to determine the corrective actions and improvements needeo.
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Il Article 4-RadiologicalControlsTrainino i
1.
Periooic raciological controls traininc snail De given to ensure eacn I
person understands the radiological concitions to whicn ne is exposed, understands nis responsioility to minimize his own exposure to radiation, and understanos his own responsibilities for complying with radiological controls procedures. Personnel occupationally exposed to radiation snall receive instruction on the effects of raciation and the risks associated with radiation exposure.
2.
General radiological indoctrination shall be given to those not directly involved with radiation so that they understand not to enter areas requir-ing TLDs ano not to cross radiation barriers.
Tne indoctrination shall include explanation of the radiological environment in which they wo*k.
3.
Radiological controls training shall be given to personnel requiring access to radiologically controlled areas. These personnel shall be required to pass a written examination, and they.shall requalify by written examination at least annually.
4 In addition to the training and written examinations of paragraph 3, those wno require access to areas controlled by Radiation Work Permits shall receive more extensive training and snall be required to pass a radiolo-
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gical examination on their practical abilities, including use of dosi-metry, frisking, anti-contamination clotning, respirators, and response to unusual situations. Retraining and both written and practical examina-tions shall be conducted at leas,t annually.
In addition, spot checks snall De maoe to ensure that personnel retain the required knowledge during the period between examinations.
Special oriefings and extra training including use of mockups wnere applicable, shall be conducted for work involving higner than usual exposures to radiation and radioactivity.
5.
Radiological controls technicians and tneir Supervisor / Foreman shall receive theoretical and practical training and training for unusual situations.
Training shall also be given for changes to procedures, equipment and programs. They shall pass both written and oral examinations, in which the passing grade for Supervisor / Foreman shall be nigher tnan the passing grace for tecnnicians. Periodic practical drills and oral drills shall be required'for GaCD technician and Supervisor / Foreman. Biennial requalification shall be required including both written and oral examinations. Raciological controls technician assistants shall perform specific functions under the directio.1 of a qualified technician or Supervisor / Foreman after being qualified for the j
specific' function.
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< Article 5 - Control of Externai Excosure l
Control of radiation exposure is based on the assumption that any exposure, no
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matter how small, involves some risk; however, exposure within tne accepted limits represents'a risk that is small compared with normal nazards of life. Therefore, the
, policy of GPU Nuclear is to maintain exposures to individuals and total man-rems as low as is reasonaoly acnievable (ALARA). Line management from all departments as well as eacn individual worker shall take an active role in radiation exposure reduction.
To aid in exposure reduction, administrative radiation exposure control levels snall be estaolisned. Radiation man-rem exposure goals shall be established for each major job'and for.2ach year. Work involving radiation exposure shall be preplanned.
Major exposure jobs shall require that radiological controls be incorporated in the design, that written procedures be prepared, and tnat pre-job briefing and rehearsals be conducted prior to commencing work. A Radiation Work Permit will be required for any-worx.or entry to restricted areas that would involve or create any of the follow-ing:
(a) hign radiation area, (b) airborne radioactivity area, and (c) contaminated area, or (c) those radiation areas specified in applicable procedures.
Restricteo areas used to control personnel access to radiation and radioactive materials snall be defined, access controlled, and posted in accordance witn 10 CFR m
20.203 with tne following modifications:
e 1.
Each High Radiation Area shall be barricaded and conspicuously posted as a Hign Radiation Area, and personnel desiring entrance shall ootain a Raciation Work Permit (RWP). Any individual entering a High Radiation Area shall (a) use a continuously indicating dose rate monitoring device, or (b) use a radiation dose rate integrating device which alarms at a preset dose level, or (c) assure that a radiological controls technician provides periodic radiation surveillance with a cose rate monitoring instrument.
2.
Any area accessible to personnel where a major portion of the body coulo receive in any one hour a dose in excess of one thousand mrem, shall be locked to prevent unauthorized entry.
Tne keys to these locked barricades shall be maintained under the administrative control of the Radiological Controls Supervisor / Foreman on Duty in accordance with the RCPM.
Radiological Controls personnel shall be exempt from the RWP issuance require-ment during the performance of their assigned radiation protection duti_es providing tney are following radiological controls procedures for entry into High Radiation Areas.
2 3
To evaluate radiological conditions, radiation surveys shall be conducted for j
air activity, removaole surface contamination and external' radiation at regular 3 -intervals. Surveys are performed in order to (a) monitor the suitability of control n
g measures, (b) evaluate the needs for' additional controls, (c) evaluate trendsLfor-Hf j
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- ALMn purposes, and (d) evaluate radiological conditions in areas routinely entered
' wi tnout raoiation work permit coverage. Surveys in unrestricted areas are provided to insure the effective control of radioactive material.
Unusual conditions detectec in tne perfonnance of eitner a routine or special survey shall immediately be brought to tne attention of Radiological Controls Management.
Portable radiation survey instruments will be calibrated semi-annually except for dose rate measuring instru-ments, whicn will De calibrated quarterly, to assure a consistent, reliable and predictable response to radiation level s.
Records of surveys shall be maintained on file. An Administrative prograin will be used to verify the calibration of personnel and field monitoring instruments.
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fArticle6-ControlofInternalExoosure i
ine GPUN policy is not to nave any significant internal exposure to personnel from raaioactivity associated with GPUti Operations or activities. For personnei exposed to radioactivity during their work, this means that no one snoula receive from internal radioactivity more than one tentn of tne radiation exposure that 10 CFR 20 would allow one to accumulate in a year.
Controls in other parts of this Radiation Protection Plan to minimize internal raaioactivity, such as control of surface contamination and control of wounds, are not repeated in this article. The following controls are utilized to minimize internal exposure from airoorne radioactivity:
1.
Engineering controls and controls on personnel access shall be applied to tne maximum extent practicable so that radioactive work does not increase the amounts of airborne radioactivity inhaled. Wnen no other controls are practicable, respirators shall De usea. Those who may need to use respi-rators shall be medically qualified and trained at least annually. Also, such persons shall De successfully fit tested to tne appropriate respira-tor (s) prior to being authorized to wear the respirator (s) and at least annually thereafter.
(For TMI the annual Fit Test Requirement shall ce implemented oy Marcn 31. 1983).
c 2.
Airoorne radioactivity shall be measured regularly in areas where person-nel may be exposed. Continuous sampling representative of air tne person is breathing shall be performed to supplement periodic measurements during work which has the potential for the generation of significant airborne radioactivity.
Internal radioactivity shall De measured prior to assignment and at least annually in each person wno works in an area requiring a radiation work permit; this incluaes eacn person who wears respiratory p'rotection.
Internal radioactivity shall be measured promptly in eacn person wno receives significant radioactive contamina-tion on nis skin, and in_each. person who is suspected of innaling sufficient racio-activity to cause measuraole internal radioactivity.
Each measurement of internal radioactivity shall be reviewed in accordance with investigative levels specified in tne RCPM to_ determine the cause and to assist in minimizing internal exposures.
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I Article 7 - Control of Radicactive Contaminatien I
Radioactive surface contamination shall be centrcllec in orcer to minimize
! pcssible inhalation or ingestion of radioactivity anc te minimize builcup of racio-I activity in the envircnment. Measures to contain racicactivity and to minimize the numcer ano extent of areas centaminated shall be taken in orcer to minimize personnel radiation exposure, to simplify subsequent personnel ano area or facility cecentami-nation, and to minimize the need to rely on anti-contamination clothing.
The limit used to verify the absence of contamination shall be 100 cpm as measured with a pancake GM detector.
The surface contamination limits for unrestricteo release of materials and equipment are as follows:
Beta-Gamma Smearable(l)
Total (Fixed and Smearable)
TMI-1, Oyster Creek 1000 dpm/100cm2 0.1 mR/hr TMI-2 500 cpm /100 cm2 0.1 mR/hr Aloha
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All Sites 100 cpm /100cm2 1CO cpm (2)
Emphasis in planning, training and worklng shall be placed on minimizing the numbers of occurrences and amounts of radioactivity involved in occurrences of radioactive surface contamination of a person's skin or on areas not contrclled for radioactive surface contamination. Each such occurrence shall be reviewed-in cetail to determine how to correct deficiencies and improve control of radioactivity.
4 (1) Direct frisking may be used in place of smears for release of materials and/or (2) equipment.
As measured with an alpha survey meter i
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' Article 8 - Control of Radioactive Materials In addition to the definition of 10 CFR 20, any material having a dose rate measured with a beta gamma survey meter at 1 inch exceeding 0.1 mR/hr or with surface contmaination in excess of tne liraits specified in Article 7 snall be handled as radioactive.
A radioactive material control system shall be established to ensure radioactive uaterial is not lost or iaisplaced in a location where personnel could unknowingly be exposed to radiation and to prevent the uncontrolled spread of radio-activity to areas where the public mignt be affected.
This system shall include the following requirements:
1.
Tne number of areas in which radioactive materials are stored shall be iainimi zeo.
2.
Any new radioactive material storage area shall be approved before use by tne Kanager-Padiological Controls.
3.
The numoers of radioactive items and the amount of radioactivity in storage shall be minimized to the extent practicable.
4.
All items shall be surveyed before removing them from a restricted area.
5.
Radioactive materials removed from the Protected Security Area or removed from a restricted area outside the Protected Security Area shall be controlled in accordance with an accountability procedure which ensures tne materials are not lost or improperly handled during transfer or subject to unauthorized removal.
This accountability procedure shall require inventory of radioactive materials which remain outside such areas.
6.
Each incoming or outgoing shipment of radioactive material shall be handled in strict compliance with detailed written procedures.
Each case in whicn radioactive material is lost or unaccounted for shall be reviewed in detail to detenaine the potential radiation exposure personnel might unknowingly receive, to correct deficiencies, and to improve control of radioactive materi al s.
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Article 9 - Radiological Controls Organization A radiological controls program cannot be strong and effective if left solely to the Radiological Controls Department.
Eacn worker and supervisor has responsibility for radiological controls; consequently, the organization for each of the GPUtl sites h
represents t e organization for radiological controis.
However, each Manager-Radiological Controls is responsible for ensuring that a nigh quality radiological controls program is established and maintained.
It is the responsibility of the Radiological Controls Department to evaluate radiological conditions and recommend precautionary measures.
At times when demands upon the Radiological Controls Department are sufficiently
.neavy to require a temporary increase in staff, qualified contractor personnel will be used. These personnel will be fully integrated into the department under the
. direction of the !!anager-Radiological Controls.
Support services (instrument cali-bration, respiratory protection, bioassay, TLD/ dosimetry, and training) may be provided by other GPUll organizations. These support services will be administered by procedures which define the organizational interface required to insure the quality of services provided meet the commitments of the Radiation Protection Plan.
Qualifications for the key radiological managers in IJRC Regulatory Guide 1.8, Rev.1-R,'(1975) will be met as far as practicable. Where the combination of strong panager and experience in radiological controls cannot practicably be obtained in the same person, either the manager. or a deputy manager will meet the requirements of Regulatory Guide 1.8.
One portion of the GPUll radiological controls program which warrants particular note is the ALARA program which requires personnel radiation exposures to be as low ps reasonably achievable. To accomplish this each engineer involved with the pperation of TNI-1, TMI-2 or.0yster Creek has to have radiological engineering as p' art of his assignment. Thus, most radiological engineering functions are performed n engineering groups rather than in the Radiological Controls Department.
The verall c0 ordination of the ALARA program, however, is assigned to Radiological ngineerine in the Radiological Controls Department.
The respective TMI-1, TMI-2, and Oyster Creek Radiological Controls organiza-tions are depicted in the GPU tJuclear Organizational Plan.
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GPU Nuclear Corporation g
gf Post Office Box 480 g
Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
July 8, 1983 5211-83-183 Dr. Thomas A. Murley Region I, Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 GPUNC Radiation Protection Plan Enclosed is a copy of the CPU Nuclear Corporation Radiation Protection Plan, Revision No. O, for your information (Procedure 1000-PLN-4010.01).
The Plan does not contain substantive changes from the existing Radiation Protection Plan, and sets the radiation protection policies and philosophies of the CPU Nuclear Corporation radiological controls program.
Details of Plan implementation are contained in the plant specific Radiological Controls Procedure Manual (RCPM).
Based on the above, this plan revision is being implemented under the provisions of 10 CFR 50.59.
Sincerely, W
H. D. H kill Director, TMI-l llDil:JGB:vj f 2 copies cc: Director, Office of Inspection and Enforcement gf-GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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