ML20153C252
| ML20153C252 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/17/1988 |
| From: | Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20153C249 | List: |
| References | |
| 50-382-88-20, IEB-79-19, NUDOCS 8809010058 | |
| Download: ML20153C252 (10) | |
See also: IR 05000382/1988020
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APJENDIX
U.S. NUCLEAR RiGVLATORY COMMISSION
REGION IV
NRC Inspection Report:
50-382/8ta-20
Operating License:
Docket:
50-382
Licensee:
Louisiana Power & Light Company (LP&L)
317 Baronre Street
New Orler.is,. Louisiana 70160
Facility Name: Waterford Steam Electric Station, Unit 3 (WAT-3)
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Inspection At: WAT-3 site, Taft, St. Charles Parish, Louisiana
Inspection Conducted:
July 10-15, 1988
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Inspector:
b'-
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8 IY[
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H. D. CharWM Radiation Spec
list, Facilities
Date
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Radiological Protection S tion
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Approved:
- d.
cSM7 M
R./E.
Laer, Chief, facilities Radiological
Date
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Protection Section
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Inspection Summary
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Inspection Conducted July 10-15,-1988 (Report 50-382/88-20)
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Areas Inspected:
Routine, unannounced inspection of transportation of
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radioactive materials and low-level radioactive waste (LLRW) management.
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Results: Within the areas inspected, no violations or deviations were
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identified.
One unresolved item concerning the transportation of radioactive
materials was identified (see paragraph 8).
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8809010058 880824
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DETAILS
1.
Persons Contacted
LP&L
- N, Carns, Plant Manager
- S. Alleman, Quality Assurance Manager
F. Davis, Nuciear Operations Support and Assessment Enrineer
G. Espenan, Nuclear Operations Support and Assessment Engineer
R. Kenning, Nuclear Operations Support and Assossment Engineer
- W. LaBonte, Radiation Protection Superintendent
J. Ladet, Security Supervisor, Operations
- H. Langan, Technical Support Training Supervisor
D. Landeche, Health Physics (HP) Supervisor
M. Marler, HP Trainer
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R. McLendon, Dosimetry Supervisor
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- P. Prasankumar, Assistant Plant Manager, Plant Technical Services.
S, Ramzy, Assistant Radiation Protection Superintendent
- J. Ridgel, Assistant Radiation Protection Superintendent
- D. Stevens, Radwaste Supervisor
Others
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- T. Staker, NRC Resideni. Inspector
- Denotes attendance at the exit interview.
The NRC inspector also contacted other licensee personnel including
administrative, security, and quality assurance (QA) personnel.
2.
NRC Inspector Observations
The following are observations that the NRC inspector discussed with the
licensee during the exit interview on July 15,-1988 and (observation b.
which was discussed with R. Kenning) by phone on July 19, 1988.
These
observations are not violations, deviations, unresolved items, or open
items. These observations were identified for licensee consideration for
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program improvement, but the observations have no specific regulatory
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requirement.
The lice..see stated that the observations would be reviewed
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(no commitment was made in regard to observation b.).
a.
Clean Waste Release - The procedure currently in use for the testing
of gamma scintillation counting of bulk paper and plastic wastes to
be released for unrestricted use is not signed or dated.
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b.
Radwaste Program Assessments - Neither the Corporate Nuclear Support
Services Section nor the onsite Operations' Support and Assessment
Group routinely performs assessments on low-level solid radwaste and
transportation activities.
3.
Open Item Identified During This Inspectio_n
An open item is a matter that requires further review and evaluation by
the NRC inspector.
Open items are used to document, track, and ensure
adequate follow-up on matters of concun to the NRC inspector.
The
following open item was identified:
Open Item
Title
See Paragrapn
382/8820-01
Retraining of Radwaste Staff
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4.
Unresolved Item Identified During This Inspection
An unresolved item is a matter aboiit which more information is required to
ascertain whether it is an acceptable item, a deviation, or a violation.
The following unresolved item was identified:
Open Item
Title
See Paragraph
382/8820-02
State of Nevada Identified
8
Transportations Regulation
Violations
5.
Organization and Management Controls - Transportation /Radwaste
(83522/83722)
The NRC inspector inspected the licensee's staff assignments including:
organization, assignment of responsibilities, authorities, staffing,
identification and correction of problems, audits and surveillances,
communication to employees, documentation and implementation relating to
radioactive effluents and solid wastes, and the transportation of
radioactive materials to determine adherence to commitments contained in
Sections 11 and 13 of the Updated Final Safety Analysis Report (UFSAR),
and NRC Inspection and Enforcement Bulletin (IEB) 79-19
and compliance with Technical Specification (TS) 6.2, 6.8, and 6.13.
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The NRC inspector reviewed the organization of the licensee's radwaste
department which is responsible for management of solid radioactive waste
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processing and transport ,t :on of radioactive materials (RAM).
The NRC
inspector also reviewed the LD'
Carporate support (Nuclear Support
Services Section) provided the WAT-3 radwaste program.
The NRC inspector reviewed the licensee's senior management pclicies
(Nuclear Operations Management Manual), which included the assignment of
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responsibility for RAM shipments, implementing procedures for control of
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LLRW processing and transportation of RAM, the NRC approved Process
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Control Program (PCP)-(Procedure RW-01-210), field quality control
activities, and the NRC approved QA program (Docket:
71-0604) for
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transportation activities.
The licensee utilizes an ancillary special
scope QA program-in conjunction with their 10 CFR Part 50, Appendix B, QA
program for ensuring quality in RAM transportation activities.
P:ocedures.
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and other documents reviewed during the inspection are listed in the
Attachment to this report.
The NRC inspector reviewed the licensee's audit program; including current
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and planned audits-for LLRW and RAM transportation activities.
Tne
following audits and surveillances were' reviewed:
Surveillance QS-88-055, Purchase Orders'and Receipt Inspection of
Shipping Packages
Audit SA-87-024.1, Radwaste Processing
Audit SA-87-003E.1, Radwaste Training and Qualification
Audit A39.356-87.1, Container Products Corporation (Vendor Audit)
The licensee's audits were found to be comprehensive and included an
adequate amount of performance based objectives.
The NRC inspector noted
that while the Nuclear Operatiens Support and Assessment (NOSA) Group
performed operational assessments on most other activities at WAT-3, NOSA
does not perform assessments in the area of radwaste operations.
No violations or deviations were identified.
6.
Training and Qualification - Transportation /Radwaste (83523/83723)
The NRC inspector reviewed the licensee's training program including
adequacy of training, employee knowledge, qualification requirements,
position descriptions, technician, contract technician screening and
training, audits, and training not covered by INP0 accreditation to
determine agreement with commitments in Section 13.2.2.8 of the UFSAR,
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and NRC IEB 79-19, and compliance with the requirements of Technical
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Specification (TS) 6,3 and 6.4.
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The NRC inspector observed work practices and interviewed radwaste group
personnel.
The licensee's biennial requalification program for personnel
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involved in radwaste processing and transportation activities was reviewed
for adequacy. Training records for the plant staff (approximately
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21 radwaste and HP individuals) involved in the processing and
transportation of RAM were reviewed for completeness.
The NRC inspector
also reviewed the licensee's implementing procedures and lesson plans for
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the training of radwaste personnel.
The NRC inspector noted (this was
also identified during a QA audit) that at least four radwaste personnel
have not received any formal radwaste training since hiring on at WAT-3.
None of these persons appeared to have performed radwaste processing
activities other than collection of waste.
The last training for many
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radwaste personnel was the completion of on-the-job training checklists in.
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1986.- The NRC inspector noted that the licensee had provided many
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individuals with required reading of procederal changes'and vendor
provided training on radwaste and transportation activities in 1986 and
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1981 which satisfies the biennial requalification requirements. .The NRC
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inspector also noted that the lesson plans for the radwaste^ training
program were not current (1984 vintage) in the areas of regulatory
requirements and licensee facilities.
The licensee training program for'
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radwaste workers was an item of concern in NRC Inspection.
Report 50-382/85-26 and resulted in the. issuance of a Notice _of;
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Violation (NOV) for the failure to ensure.that a contract worker received
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proper training.
This area was strengthened as a result of the NOV.- The -
Nuclear Training Departmen'c:(NTO) staff positions responsible for radwaste-
group training activities have had a high turnover rate in the past which
has resulted in the program not being maintained in a current status.
The
licensee's NTO had filled the vacant position of_ instructor for the
radwaste group around July 1,1988.
The licensee's radwaste training
program will be considered an open item pending licensee implementation of
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an upgraded training and requalification program for radweste workers-
(382/8820-01).
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No violations or deviations were identified.
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7.
Solid Radioactive Waste (84522/84722)
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The NRC inspector reviewed the' licensee's program for the control,
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classification, characterization, and shipment of low-level radioactive
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waste to determine agreement with the commitments contained in Section 11
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of the UFSAR and compliance with the requirements coctained in TS 3.11.3,
4.11.3; 10 CFR Parts 20.301,-20.311, 61.55, and 61.56, and the
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recommendations of NRC Branch Technical Position (BTP) papers on LLRW
classification and waste form.
The NRC inspector reviewed the licensee's computerized program for
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management of waste processing and packaging activities (RADMAN).
The
licensee's biannual evaluation of waste streams and development of isotope
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correlation factors were reviewed.
The licensee's LLRW characterization
and classification program is well documented. The NRC inspector reviewed
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the licensee's vendor provided processes for dewatering of filters and
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resins.
The licensee's PCP and the licensee's vendor's PCP for the
processing of various waste streams were reviewed for management control
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over changes and revisions.
The NRC inspector reviewed selected records
of waste processing activities (resin solidification, filter dewatering,
dry active waste compaction, and oil solidification) for 1987.
The NRC inspector reviewed the licensee's records for LLRW shipped since
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1985.
The following tabulation shows the total volume of LLRW shipped for
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the 1985 through 1987.
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volume Shipped (Cubic feet)
Year
Goal
Actual
Curie Content
1985
5,000
9,997
33.5
1986
6,227
6,138
37.5
1987
8,000
-13,530*
178.2
- Included approximately 5,000 cubic feet of boric acid concentrator bottoms
held over from 1985 due to licensee efforts _in evaluating onsite burial.
No violations or deviations were identified.
8.
Transportation (86721/86740)
The NRC inspector reviewed the licensee's prograu for transportation of
RAM, program audits, procurement and evaluation of packaging,
determination of package activity, preparation of packages for shipment,
maintenance of packages, delivery of packages to carrier, and the receipt
of RAM for compliance with the requirements of 10 CFR Parts 20.205 and
20.311: d CFR Part 71; and Department of Transportation (DOT) regulations
(49 C;;j .ncorporated by 10 CFR Part 71.
The NRC inspector reviewed 30 shipping records from the 1986 and 1987
period for completeness and accuracy.
The licensee's authorization to
utilize specific shipping packages was verified.
The NRC inspector
reviewed the docwaentation including advanced notification, package
opening and closing checklists, hazardous waste manifests, sole use
instructions, and survey records. . The NRC inspector noted that the
licensee routinely used extensive checklists for accomplishing shipments
of RAM.
The NRC inspector was informed, on July 11, 1988, by the licensee, that
LP&L had been notified by the state of Nevada that several violations of
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00T and burial site requirements had be identified during inspection of
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two of the licensee's waste shipments to the Beatty, Nevada, burial site
(May 1988, Radioactive Shipment Record (RSR) 88-1008 and June 1988,
RSR 88-1010).
The violations identified by the state of Nevada included
radiation dose rates on waste containers significantly greater than
shipping records indicated, a waste container [ strong tight package for
low-specific-activity shipment (s)) was found to have a k-inch hole in it
(manufacturing defect), improper location of 00T required placard,
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illegible manifest copies, and the bracing used in a sole-use enclosed
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trailer-van came loose and allowed the load to shift.
The licensee had
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not fully investigated each of the apparent violations at the time of this
inspection.
The licensee had instituted an immediate inspection of waste
containers used for the shipment of dry active waste (DAW).
The licensee
determined that several of the onsite ready for use Container Product
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Corporation's B-25 containers (steel boxes of approximately 95 cubic feet
capacity) contained manutacturing defects. These containers are not
required to be 00T approved or NRC certified.
The hole in the B-25
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container, found by the state of Nevada, wts the result of a weld
burn-through that was painted over at the manufacturing facility and was
not readily identifiable during the '.icensee's proceduralized preuse
inspection of the container.
At the time of this NRC inspection, the
licensee had already instituted corrective actions concerning potential
defects in waste containers used for DAW packaging and had revised their
receipt inspection program for strong, tight containers.of all makes.
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licensee informed the NRC inspector by telephone on July 18, 1988, that
preliminary investigation of the ap.narent high dose rates on waste
containers may be the. result of a state of Nevada mix up involving another
shipper's material and not LP&L's. NRC enforcement will be deferred until
all of the state of Nevada's violations have been resolved.
The
licensee's apparent' violation of NRC and DGT regulations will be
considered an. unresolved item pending further review by the NRC during a
future inspection (382/8820-02).
The NRC inspector noted that the licensee's QA' department had just
completed a surveillance of-waste packa0 ng procurement and receipt
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inspection.
The draft results of the sur*/eillance indicated that several
deficiencies were identified in the licensee's program for these
materials.
The licensee had not experienced any transportation incidents which
caused a reduction in the effectiveness of an NRC or DOT' certified
packaging since the previous inspection.
No violations or deviation: were identified.
9.
Review of Periodic and Special Feports (90713)
The NRC inspector reviewed the licensee's semiannual effluent reports for
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1986 through 1987 for conpliance with the requirements of TS 6.9.1.8,
6.13, and 6.15 and the rkc enendations of RG 1.21.
The licensee's semiannual reports for the years 1985, 1986, and 1987 were
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reviewed and compared to the '.icensee's documentation concerning
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radioactive material shipments (solid LLRW disposal), PCP changes, and
modifications to the solid LLRW processing systems.
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No violations or deviations were identified.
10.
Exit Interview
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The NRC inspector met with the NRC resident inspector and licensee
representatives denoted in paragraph 1 on July 15, 1988, and summarized
the scope and findings of the inspection as presented in this report.
The
licensee ageeed to provide the NRC with all correspondence involving the
state of Nevada's 1988 inspection and enforcement actions concerning LP&L.
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ATTACHMENT
TO NRC INSFECTION REPORT
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50-382/88-20
11TLE
REVIS100
DeT.E
Nuc l ear _ Opera t t ons _ tier)agement _tianual.
Section VI. Special Scope Quality Policies
Chapter
5.
Radioactive Waste Management
3
12-21-87
P10 !t _Degtat) prjs_tigoup1_
Volume 20. Radioactive Wasto Manaoement Pr ocedur es
FW-01-tOO. Radioactive Waste Reduction
2
02-18-87
FW-01-2OO. Record Preparation. Filing,
and Storage
1
06-26-87
RW-01-210
Process Control Procram
2
07-10-87
RW-02-100. Waste Material Collection and
Hand 1ing
4
03-25-88
RW-02-110. Waste Sample Collection and
Isotope Evaluation
3
05-18-87
RW-02-120. Handling Used Protective Clothina
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07-14-86
RW-02-2OO. Packaging Radioactive Solid Waste
(DAW) for Disposal
5
08-20-86
RW-02-210
Radioactive Waste Solidification
6
10-26-87
RW-02-220. Radwaste Filter Di sposal
2
01-07-86
RW-02-230. Waste Material Segregation
3
06-20-88
RW-02-231. Granulating Material for Disposal
2
03-29-88
RW-02-240, Blowdown Domineralizer Rosin
Transfer
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04-07-86
RW-02-3OO. Receipt. Storage and Loading of
Shipping Containers
2
05-23-86
RW-02-310. Storace of Loaded Shippino
Containers
3
09-15-86
RW-02-320. PacLaced Radioactive Waste
Control and Inventory
5
06-26-87
RW-02-330
Radicactive Waste Tracking
1
02-18-86
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RW-02-401. Use of Radman Operating Program
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08-27-87
RW-02-411. Use of Radman Data Manager
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09-10-87
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RW-02-420. Operation of the Filtrk Computer
Program
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05-04-87
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RW-02-430, Operation of the RAMSHP Computer
Program
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06-01-88
RW-02-500. Radioactive Material Shipment
3
09-15-87
RW-02-501. Radioactive Waste Shipment
1
04-08-88
RW-02-521. Type and Duantity Determination
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05-05-87
RW-02-530. Decav Heat Calculations for
USNRC Certified Containers
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05-05-87
RW-02-541. Hydrocen Gas Calculation
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05-04-87
RW-02-800. Dose to Curie Conversion
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02-18-86
RW-02-810, Waste Cl assi f i cat i on
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02-18-86
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TITLE
REVISI.QN
DA1E
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ypndpt [roce(1 prog
F1-013, LN Technologieu Proccus Control
Prooram for Dewaterino Liners
G
Untnown
S5-001. LN Technolooies Process Control
Program for Radwaste Solidification
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05-05-87
SS-005. Operating Procedure for LN
Technologien Radwaste Solidification
G
Unknown
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Svetem N8908
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NRC Approved Topical Roport PS-53-0378.
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NUS Radwaste Solidification System
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05-30-85
(N FlflaC_ It a iOi0g_Denettment_Ergceduces
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NTC-237
Radwaste Services Trainino Program
2
04-29-88
!
ld!SPOO Ela05
TO20-OOO-01. Radwaste Helper Final Exam
1
01-23-66
T001-000-01. Radweste Helper - Radwaste
Program Overview
1
09-28-84
T001-001-00. Radwaste Helper - Nuclear
Power Orientation
O
09-28-84
T001-002-00
Radwaste Helper - WAT-3 Radwante
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Systems
O
09-28-84
TOO2-OOO-01. Radwaste Hel per - Solid Radwaste
Compaction
1
09-28-84
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T003-006-01. Radwanto Helper - Radwaste
t
Solidification
1
09-28-84
W3TOO4-OOO-OO. Radwaste Helper - Radi oactive
Material Classification and
Qualification
1
04-18-83
,
W3TOO4-OO1-OO. Radwaste Helper - Radioactive
Material Packaging
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04-18-83
W3TOO4-OO2-OO. Radwaste Helper
Marking.
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Labelino. Placardino
Requir ement f or Shipmonts
04-18-83
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W3TOO5-OOO-OO. Radwaste Helper
Radioactive
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Material Shipping Papers
04-18-83
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7017-000-00
Radwaste Helper - Radioactive
Shipments
O
09-28-84
T018-000-00
Radwaste Helper - Dry Waste
Seuregation
O
03-11-85
T901-OOO-OO. Radman Software
O
08-30-84
00:Ibe: Job _Icelnico_Cbechlists
,
T501-OOO-OO. Basic Radwaste
05-02-86
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T506-OOO-01. Radwaste Equipment Operation
09-08-86
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T502-OOO-OO. Handling and Control of DAW
05-02-86
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T503-OOO-OO, Packaging of DAW
05-02-86'
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1510-000-00, Radioactive Material /Radwaste
,
Shipping
05-02-86
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T511-OOO-OO, Contract Decon Technician Duals
07-30-86
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2
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' 'un d or 6_ f1g nu.ii l s.. a nd NRC _ Qs r t i f I c.a t es ,of ..Compl. 2 a nc e
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Chem-Nuclear Cank 14-195H. Co+C 9094
Ch azin--Nu c 1 v ar Cash 8-120B. CofC 9168
LN Technolooten Cank USA /9151/A. Cof C 91'51
Nt15 Ca@ 7-100. CofC 9080
L 1_ c en s oo _ Gor r o m p on tpf n ep
Inter-Offtre Correspondence.
S.
Devel l e (LP&L) to file. Subject: "IE
Pack.uging of Low-Level Radioactive Waste for Transport and
burial". dated July 19,
1983. Serial No. W3P83-2488
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