IR 05000151/1997201

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Insp Rept 50-151/97-201 on 970623-26.Violations Noted.Major Areas Inspected:Organization,Periodic & Special Repts, Operations,Maint & Procedures,Requalification Training, Surveillance,Experiments,Radiation Controls & EP
ML20149J301
Person / Time
Site: University of Illinois
Issue date: 07/24/1997
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20149J286 List:
References
50-151-97-201, NUDOCS 9707280156
Download: ML20149J301 (15)


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.. U.S. NUCLEAR REGULATORY COMMISSION

' Docket No: 50-151_

.L1 cense No: R-07 :

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Report No: 50-151/97201 (DRPM)

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Licensee:' University of Illinois

. Facility Name: Advanced Triga Research Reactor-Location: Champaign-Urbana. Illinois

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. Dates: June 23-26. 1997 sk

-Inspectori T. M. Burdick

. Approved by: Marvin Mendonca. Acting Director Non-power Reactor and Decomissioning Project Directorate ,

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x Executive Summary-Advanced Triga Research. Reactor Report No. 50-151/97201(DRPM) 1 lThis routine, announced inspection included aspects of organization, periodic and special reports, operations, maintenance and procedures: requalification-training: surveillance: _ experiments: radiation controls; environmental >

3rotection:' design change, audit, and review: emergency preparedness: fuel

landling activities
(69001); event follow-up (97200); and review of licensee reports (90713). ,

Oraanization and Staffina (69001)

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l "o The Advanced Triga Research Reactor staffing has been declining over the '

j past two years. Only three licensed staff members remain, all holding a

. senior reactor operator's (SRO) license. They hired one undergraduate as a full time employee this month.

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One' violation was identified in that the Reactor Administrator (RA).

whose license had expired on November 30. 1996, had been fulfilling i positions requiring an NRC license after that date. (Section 1.0)

i Ooerations and Maintenance. Procedures. Recualification Proaram. Exoeriment l L Audits and Reviews. and Fuel Handlina (69001). Periodic and Soecial- i

[ Reoorts(90713)

l e No concerns were identifie (Sections 2.0, 3.0, 4.0. 6.0. 9.0. 11.0, and 12.0)  !

Surveillance and limitina Conditions for Ooeration (69001)

, m One Non-Cited Violation was identified when the licensee discovered that the transient rod pulse interlock was not operable while troubleshooting 1

, another problem. (Section 5.0) l

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Radiation Control (69001)

e The exposures to employees, students, researchers, and members of the aublic did not exceed regulatory limits. The campus radiation arogram c lad established ALARA thresholds to initiate review before furtier

. exposur (Section 7.0)

Environmental Protection (69001)

e :.The licensee has managed to reduce the liquid waste produced by l eliminating leakage. One Non-Cited Violation was identified when the l

licensee determined they had discharged a small quantity of insoluble radioactive material. (Section 8.0)

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_2 Emeraency Preoaredness (69001)

e The licensee carried out program requirements. They just completed a review of their program for changes. (Section 10.0)

follow-uo(92701)

m The inspector followed up and closed two items of concern from the last inspection. (Section 13.0)

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1.0L0raanization

Insoection Scooe (69001. 92700)-

-The inspector reviewed Technical Specifications (TS) and the Safety .

Analysis Report (SAR) related:to organization and staffing and-compared the requirements with current conditions. The inspector Lalso reviewed licensee reporting.' evaluation, and corrective measures

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, Observations and Findinas-The inspector determined that the organizational structure and assignment of responsibilities were as specified in TS 6.0.

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Graduation and departure of student employees had left the staff at

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three SR0s and one recently hired studen Membership of the Reactor Committee (RC) was in accordance with TS and the SAR. Meetings were conducted as require The inspector identified that reactor staffing usually met requirements. However..the RA inadvertently had allowed his license

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to expire on November 30. 1996. Yet, he continued to conduct reactor operations both as a reactor operator (RO) and a senior reactor operator (SRO) from November 30, 1996 to March 21, 199 Upon notification-from the NRC, he refrained from further licensed

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activities until he applied for and was issued a new license i- effective March 21, 199 :

TSs 3.1.2.a.1 and c.1 required that the reactor be operated by a licensed R0 and that a licensed SR0 be present at the reactor during t initial reactor startups and approach to power. This is a violation (50-151/97201-001).

The inspector concluded that the cause was a licensee

misunderstanding of the license renewal requirements and that the licensee had implemented acceptable corrective measures to reduce the chances of recurrence and that no other license renewal was at or near expiratio , Conclusions e

. A violation of the TS requirements was cited by the inspector. At *

. the time of the inspection the licensee had already corrected the :

violation and implemented measures to reduce the chance of recurrence.

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2.0 - Operations and Maintenance Activities a. 'Insoection Scoce (69001)

The inspector reviewed the reactor 03erations and maintenance logs to determine compliance with Operating .icense Condition 3.A. The-inspector observed startup and operation of the reactor and sample handlin b. : Observations and-Findinas The licensee operated the reactor intermittently at various thermal

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-power-levels in accordance with Operating License-Condition Selected reactor operator and maintenance logs from July 1995 through _

June 1997 were reviewed. The licensee's logs and records documented  :

reactor operations and maintenance activities,- fanclusions o

The licensee operated and maintained the reactor in accordance with the reactor's license conditions, safety limits and limiting ,

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conditions for operation. The logs were acceptable.

! 3.0 Procedures i - Insoection Scooe (69001)

The. inspector reviewed the licensee's written procedures for

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operating and maintaining the reactor, performing surveillance activities. and conducting experiments to determine compliance with the requirements in TS 6.4.

, Observations and Findinas The inspector verified that procedures were reviewed by the licensee l

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-as required. Significant changes were reviewed by the R The inspector noted that the licensee had not yet revised the daily startup checklist to incorporate the change to the 1 kW pulse interlock surveillance. This change was part of the corrective action because of the licensee's discovery earlier this year that the

. interlock was not operable under certain conditions. See Section 5.u'

for details. They issued a Standing Order to incorporate.the change

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until they ' aid revise the procedur ,

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- 5- Conclusionl The licensee had approved procedures to sufficiently conduct reactor operations, maintenance, experiments, surveillance testing, and instrument calibrations according to TS requirement .0 Requalification Training

- Jnsocction Scooe (69001)

The inspector reviewed the reactor operators' requalification

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training program to determine compliance with the requirements in-10-CFR 19.12 and 10 CFR 55.59.

. Observations and Findinas

.The licensee's last biennial written exam was acceptable. Each

. licensed operator had a current license and physical examinatio Operators were aware of the required physical examinations every two year '~

As part of the violation followup from Section 1.0 the inspector reviewed the RA's requalification records in detail. For the most .

part, he did participate in the requalification program. The RA i

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discovered and documented that he was two weeks late in performing an annual o erating examination in Februar 1996. He had not performed 1 an annua operating examination since t en which was due March 1 j n 199 l The RA stated that he had understood that the examination l

requirements were based on the effective date of the license meaning his annual examination was not due until one year from his new license effective date of March 21, 1997. The inspector advised the

RA that the requirement for annual administration of an operating l

examination was' independent of the renewal or issuance anniversary ,

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date of a license and must be administered at the required annual l interval Based on the licensee's definition of annual that is I every 14 months. The licensee acknowledged the concern.

No other licensed operators were overdue for examination No one ,

Two o I was overdue for physical examinations.totaketheirbiennialwrittenexaminationst

.e week following the I inspectio l

'c. Conclusions

An acceptable training program was being conducted and training records were being maintained. The licensee was incorrect in assuming -

. that the. annual operating examination could be administered based on )

i: the effective renewal or issuance anniversary date of the licens '

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'Because the RA's license had expired'before the operating examination ,

due date and a new license was issued. no annual exam was required-and therefore,-no violation occurre '

5.0. Surveillance and Limiting Conditions for Operation-a- Insoection Scooe (69001)

The inspector reviewed selected' surveillance test documentation to-determine compliance with the requirements in TS Observations and Findinas-Surveys and prestartup surveillances reviewed were routin Setpoints-for Limiting Safety System Settings were maintainea within the allowable value The licensee notified the NRC cn February 10, 1997, that they had identified on' February 7.1997, that the 1 kW pulse interlock which-was required to be operable in all modes of operation was not functioning under certain conditions. This was a violation of TS 3.5. Safety System Operabilit The licensee determined-that-the software-based interlock was operable in all modes of operation except the conditions that existed at the time of discovery - all rods inserted and the reactor control l

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system in manua The interlock was' designed to prevent exceeding 1 fuel temperatures when pulsing the transient rods at high power. The l TS limit is 250 kW but the setting had been set at 1 k j i

The. inspector reviewed the original acceptance testing procedures

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approved by the NRC when the licensee installed the Gulf Atomic

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digital console in 1992. The procedure verified that the interlock'

was operable by injecting a test signal to simulate high power and confirming that the computer displayed a message that the interlock was. active. The licensee had written the dail manne They did not challenge the interloc checklist to by attempting in fire the same the transient rods like they challenged all other interlocks and trips during the daily checklist.

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The , licensee prepared a modification to the interlock circuit that m incorporated a relay into the transient rod iiring circuit and

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-conducted'a'10 CFR 50.59 review. This provided a hardwired

' interruption of the firing system when power exceeded the 1 kW setting under all conditions. They obtained NRC 10 CFR 50.59 review and approval on February 12. 1997.

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The licensee also wrote a Standing Order to challenge the' interlock by. attempting to fire the transient rods with the interlock- activ The inspector observed that the rods would not fire during an attemp The inspector noted that they issued.a Standing Order but that the procedure for-daily checks had not yet been revised to incorporate the change to the test., Although one operator interviewed was unaware of the Standing Order he did know of the surveillance chang This: licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.l. of the NRC Enforcement Polic Conclusions Reactor surveillance tests reviewed by the inspector had been -

completed and documented at the required frequencies. One surveillance test had not ensured that a TS requirement was met. The licensee identified the violation and made acceptable corrective actio .0 Experiments Insoection Scooe (69001)

.The inspector reviewed the licensee's program to control and conduct experiments performed in the reactor and observed sampling operations

'to determine compliance with the requirements in TSs 3.1, 3.8, and Observations and Findinas The inspector reviewed a sampling of experiments and observed one evolution. No items of concern were note Conclusions Those reactor. experiments reviewed and observed by the inspector were conducted in accordance with properly reviewed and approved procedures and acceptably documented in the reactor operations 109 7.0 Radiation Contro Insoection:Scoce (69001)

.The inspector reviewed the radiation protection program-and records and interviewed personnel to determine compliance with the

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requirements in'10.CFR Part 20 and TSs 3.6, 3.7. and __ .. . _ _ _ _ -

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i Observations and Findinas

The inspector atte ied an RC meeting during the inspection at'which the Chair raised a question regarding the ALARA review practices for radiation exposure records. The reactor HP realied that the doses noted on the-record in question were not very ligh' and had not drawn his attention. The Chair recommended that the reactor radiation protection program should include a review of the highest dose for-the resorting period as a matter of practice. The inspector noted that t1e ALARA program at the reactor did not include dose thresholds for review of exposur The Un1wesity campus radiation protection program does require that any daily exposures planned for greater than 100 mrem must be revievied and approved by the RSO. There were no recorded daily doses of that level at the reactor during the period mspecte The RSO

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stated that they would rarely approve such-a maaest The licensee acceptably posted and iliuminated the control roun, ,

reactor top, deminerali n area, and beam port area. The reactor top and control room areas were relatively free of extraneous equipment while the basement floor area had a considerable amount of equipmen ;

Potentially contaminated tools and equipment were acceptably. stored i and marke i l

A special hooded glove box installed ":o conduct experiments involving i Uranium 235 foils was not in use and appeared to be secured in an 1 acceptable condition, i

c Conclusions  !

All badged reactor personnel exposures were below 10 CFR 20.1201 l limits and generally less than detectabl The licensee had no threshold for ALARA review. The campus threshold of 100 mrem per day would cause a review before exposur .0 Environmental Protection Insoecticn Scooe (47050. 92700)

The inspe: tor reviewed the licensee's program for the discharge or removal of radioactive liquid, gases - and solids from the reactor laboratorf. -The inspector also reviewed licensee reporting, ,

evaluation. and corrective measures for event )

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-9-in ' Observations and Findinas The licensee had managed to reduce their liquid effluent by investigating ark! correcting leakage from the bulk shield facility

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. that is currently empty but formerly. housed the subcritical assembly (LOPRA) which they had recently decommissione On' April 19, 1996 the licensee reported to the NRC that a release ~of 0.084 microcuries of' insoluble radioactivity to the' sewer occurred on

' April 11, 1996. Discharge of any amount of insoluble radioactivity  :

to the sewer is a violation of-10 CFR 20.2003(a)(1).

The licensee had previously installed a 0.45 micron discharge filter to meet the requirements for discharging insoluble radioactivity and obtained NRC review of its procedures to sample and discharge liquids

< 'to the sewer'in 1995.

j- The licensee identified the problem through routine sampling that

. required processing over a period of one to two days after the discharge. They made the initial discovery on April 12. Because of questionable sample handling. they recounted it on April 17. A verification sample was' drawn. prepared and counted on April 17 and  !

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18. At that point the' licensee recognized the violatio l U)on identifying the violation the licensee took steps to investigate t1e cause, which they believe was a damaged 0.45 micron filter, and i

implemented corrective actions. Following RC review and approval, a J holding tank was added in which all radioactive liquids were temporarily held. Sampling and recirculation through filters ensured the removal of all insoluble radioactivity before discharg The inspector verified that the licensee met the reporting requirements
the system modification was acceptable; and that procedures were modified and implemented to ensure the operation of 1
the system and sampling techniques acceptably prevented recurrenc l

This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC '

Enforcemmt Polic Airborne effluent monitoring records- for 1995-1996 showed that the

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releases were within the regulatory limits, a The inspector. determined that solid radioactive waste was acceptably stored and transferred to the university broadscope license.

L Conclusions-

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' Airborne. releases and solid waste disposal were within the regulatory limi ts .- The licensee had reduced liquid waste. The licensee identified 1-the violation and provided acceptable corrective actio ' '

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.- i 9.0. Audit and Reviews Insoection Scoce (69001)

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The inspector reviewed the RC meetings, audits, and reviews and u

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attended one. meeting conducted by the RC to determine compliance with the requirements in TS : Observations and Findings i i

RC meetings were held quarterly and the'RA presented relevant matters to the committee for review as require The licensee prepared and presented several 10 CFR 50.59 reviews to .

' the RSC for approval. They appeared to be acceptabl : The required TS operations safety audits were_ conducted by an evaluator with applicable experienc .

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Annual HP audits were conducted by the RSO as require i

' Audit findings _were evaluated and tracked for implementation as ,

appropriate, Conclusions o RC meetings were conducted as recuired;by T The licensee made

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objective evaluations of the fincings and implemented acceptably change Emergency Preparedness Inspection Scoce (82745)

! The inspector reviewed the emergency plan and the last drill and exercise-for the reactor laboratory: interviewed licensee' employees; and inventoried storage lockers to determine compliance with the

requirements in 10 CFR 50-54(q) and (r).

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, Observations and Findinas '

Recent program-changes were implemented. Self-evaluations were

objective and recommendations were made for improvement- .

4 'c . Conclusions The licensee maintained their emergency program in a state of-operational readiness.

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o-11.0 Fuel Handling ,

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-a. >Insoection Scoce (60745)  ;

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-.The11nspector, reviewed the fuel' handling procedures and records at the reactor laboratory, and interviewed employees to determine compliance with TS bservations and Findinas

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The licensee received new TRIGA fuel and defueled the LOPRA without inciden j c-. Conclusions The licensee's. procedures and' documentation for fuel movement were acceptabl .0 Review of Periodic and Special Reports Insoection'Scoce (90713) .

The inspector reviewed the ' licensee's submittal of reports and notifications.to the NRC to determine compliance with the requirements.in (S 6.8 b .- Observationt and Findinas ,

The inspector found that the last"two annual reports reflected actual

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conditions and . status of the reactor laborator .

! Conclusions The licensee had submitted required reports to the NRC in accordance

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with TS requirement .0 Follow up Items Inspection Scope (92701)  :

The inspector followed up on two-inspector-identified concerns.

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Follow-up review included consideration of licensee evaluation:

- . corrective actions, and actions to prevent recurrenc . ,

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- 12 - Observations and Findinas 1. (Closed) Follow-Vo Item 50-151/95003-01: . sampling of auxiliary cooling water effluent. This item was opened because of the water effluent path directly to a nearby creek without sampling ;

for radioactivity. The licensee had not made any determination that samaling was required. The inspector confirmed that the heat exc1 anger was not ordinarily used and was isolated from the primary cooling wate . (Closed) Follow-Uo Item 50-151/95003-02: charcoal performance in the ventilation system. This item was opened because the licensee's SAR described testing the charcoal performance without a specified frequency for testing or replacement of the charcoa The i_nspector verified that the SAR accident analysis had not taken credit for the charcoal to mitigate releases to the atmosphere. The inspector noted that the licensee had obtained new replacement charcoal in August 1995 and incorporated the charcoal replacement into a three-year surveillance schedul .0 Persons Contacted

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University of Illinois

  • B. Jones Head, Department of Nuclear Engineering i
  • R. Holm Reactor Administrator 0. Scherer Radiation Safety Officer
  • M. Kaczor Senior Reactor Operator and Reactor HP H. Romans Senior Reactor 0)erator ,

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A. Smith Nuclear Reactor _ab employee The inspector also contacted other technical and administrative staff '

personnel during the inspectio * Denotes those attending the exit meeting on June 26. 199 .0 Exit Interview (30703)

The inspector presented the inspection results to members of the licensee management at an exit meeting on June 26. 1997. The licensee acknowledged the findings presented. The inspector asked the licensee ,

whether any material examined during the inspection should be considered 1

. proprietary. They identified no proprietary informatio l The inspector advised'the licensee that the NRC may schedule future !

inspections at more frequent intervals for shorter periods. This would i

. provide more continuity for the inspector and less impact on the

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L Inspection Procedures Used  !

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tIP 69001 Class'II'Non-power Reactors" . l IP 90713 Review of Periodic and Special Reports  :

IP 92700 Licensee Event; Follow-up 1 IP 92701~ Fo110w-up on Inspector Identified Problems

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Items 00ened-and Closed i

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,50-151/97'201-01 VIOL Performance of licensed duties by unauthorized

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50-151/95003-01 IFI Auxiliary heat exchanger sampling [

50-151/95003-02 IFI- zVentilation charcoal performance ,

List of Documents Reviewed l

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Sa'fety-Analysis Reaort . l Safety Evaluation Report '

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Reactor Operating License-Technical Specifications

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Administrative Procedures -

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.0perating Procedures '

, Maintenance Procedures'

-Surveillance Procedures

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Shipping records and procedures  !

Maintenance and Surveillance Records  :

L Emergency procedures  !

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Training Progra ;

. Emergency Plan ,

[ Dosimetry Records x Training Records Various Reports i

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List of Acronyms Used 1

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ALARA As Low as Reasonably Achievable--

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-CFR- Code:of-Federal. Regulations _

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-DRPMf Division of Reactor Project Management .

Health Physicist

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.NRC> : Nuclear Regulatory Commission- l PDR -Public Document Room- 1 i: RAL Reactor ~ Administrator' i

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PL . Reactor Comittee RSO Radiation Safety Officer SAR.. ~ Safety Analysis Report T Technical Specifications

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