IR 05000267/1989014

Insp Rept 50-267/89-14 on 890710-14.Violation Noted.Major Areas Inspected:Radiation Protection Program

ML20246E608
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/15/1989
From:	Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246E598	List: IR 05000267/1989014 ML20246E594 ML20246E601
References
50-267-89-14, NUDOCS 8908290228
Download: ML20246E608 (13)

Text

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, p ;.n . APPENDIX BL U.S. NUCLEAR REGULATORY COMMISSION h E -

REGION IV

 .NRC Inspection Report: 50-267/89-14    Operating License:' DPR-34
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 : Docket: 50-267
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 ! Licensee: Public Service Company of Colorado _(PSC).

P-0.. Box 840 Denver, Colorado 80201 > Facility Name: Fort St. Vrain Nuclear Generating Station -(FSV)- Inspection At: .FSV Site, Weld. County, Platteville, Colorado

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Inspection' Conducted: July 10-14, 1989 Inspector: -- I ! H. D. Cha wy, Senior Rad tion Specialist Date Facilities-Radiological rotec' tion Section

 ' Approved:  w )%

W . E. her, Chief, Facipities Radiological Datd

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j Protection Section Inspection Summary-Inspection Conducted July 10-14, 1989 (Report 50-267/89-14)

 : Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection (RP) progra Results: Within the areas inspected,_one violation (several examples of
 - failure to comply with byproduct transfer requirements of.10 CFR Part 30, see
 ' paragraph 4.1) was identified. Two licensee identified Technical l Specification (TS) violations including administrative reports were identified that'will be considered non-cited violations, see paragraph The licensees RP program has received significant management attention :,ince the last SALP' period report. The licensee has expediently applied the appropriate technical resources to resolving nearly all of the outstanding NRC
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concerns and issues. The licensee has also embarked on a major self-improvement

 - program for the RP program and has entered into a contract with a health physics consulting firm for providing technical assistance in improving the technical
 .and performance aspects of the FSV RP program. The licensee's quality 8908290228 890821 PDR ADOCK 05000267 g  PDC

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n i assurance (QA) program is still maintained at a high. level of excellenc Technical expertise of audit teams.has been significantly improved by use of . contracted health physics technical specialists for the performance based auditing of all RF program areas. Audit reports are still comprehensive and-the performance type findings have significantly improved. Senior licensee managers are actively involved in monitoring and assessing plant performance and program activitie ! I f l l l

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   -DETAILS Persons Contacted PSC

W. L. Alderman, Radiochemist

* E. Deniston, Operations Superintendent V. H. Frahm, Senior Radiochemist
*J. M. Gramling, Supervisor of Nuclear Licensing
*J. P. Hak, Maintenance Supervisor
*M. H. Holmes, Nuclear Licer. sing Manager L. Hutchins, Staff Health Physicist
* D. Miller,. Radiochemistry Supervisor M. P. Mcdonald, Nuclear Training Instructor P. F. Moore,'QA Supervisor
*F. J. Novachek, Nuclear Support Manager E. J. O'Donoghue, Senior Health Physics Technician M. Raymond, Technical Training Supervisor, Acting T. E. Schleiger, Chemistry and RP Superintendent
*L. D. Scott, QA Services Manager D. G. Seymour, QA Engineer
*S. S. Sherrow,. Staff Health Physicist C. Stolley, Nuclear Staff Training Supervisor L. R. Sutton', QA Auditing Supervisor
*P. F. Tomlinson, QA Manager W. Woodard, Acting RP Supervisor N. Zerr, QA Engineer Others
*R. E. Farrell, NRC Senior Resident Inspector
* Denotes those individuals present during the exit interview on July 14, 198 The inspector also interviewed seseral other licensee employees including reactor operators, RP personnel, and clerk . Followup on Previous Inspection Findings (Closed) Open Item (267/8221-04): High Range Noble Gas Effluent Monitors, NUREG-0737,~ Item I.F.1.1 - This item concerned the upgrading of gaseous effluent release pathway (stack) monitors and was previously discussed in NRC Inspection Reports 50-267/87-24 and 50-267/88-1 In a letter (P-89026) dated January 20, 1989, the licensee requested relief from commitments made to the NRC to modify the reactor plant exhaust stack radiation monitoring system to resolve this item. The NRC Project Manager (K. L. Heitner) in a letter (PSC No. G-89137) dated April 19, 1989,
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_4 approved the licensee's request for relief from the above discussed commitmen (Closed) Violation (267/8420-02): Liquid Effluent Monitoring Instrumentation - This item concerned the licensee's commitment to install a continuous reactor building sump liquid release pathway monitor that would provide monitoring for radionuclides that predominantly decay by beta radiation. The licensee committed to providing quarterly progress reports on the development of the monitoring system. The licensee's most recent progress report (Final, October 22,1987) indicates that the development of beta monitor-(beta scintillation cell) had encountered severe difficulties due to the foreign material contamination within the sump and its deleterious effect on the monitor's scintillation crysttis (calcium fluoride). The licensee has abandoned further effort in developing a sump monitoring system and has petitioned the NRC (Project Manager, K. Heitner) for relief from their commitment to develop such a system. The licensee has requested permission to continue to utilize the batch release manual sampling of sump liquified effluents as has been used since the violation had occurred in 1984. The NRC Project Manager (K. L. Heitter) in a letter dated August 11, 1988, approved the licensee's request to abandon development of an in-line beta monitoring system for the sump and continue to utilize the batch sampling and analysis method for sump contents prior to release and every 24 hours during the releas (Closed) Violation (267/8817-02): Failure to Implement a Proper Respiratory Protection program - This item was previously discussed in NRC Inspection Report 50-267/88-17, and involved the licensee's failure to implement appropriate training and procedures to allow personnel to use respiratory protection equipment in accordance with the provision of 10 CFR Part 20.103. The inspector reviewed the licensee's implementation of the corrective actions committed to in PSC letter (P-88370) to the NRC dated November 4, 1988. The inspector verified the implementation of the corrective actions (retaining of instructors, training lesson plan and implementing procedures upgrading, and coordination / integration of PSC corporate and site respiratory protection programs). The licensee's corrective actions appear to be satisfactory to prevent a future recurrence of this violation. The licensee's resp'ratory protection program now satisfies the requirements of 10 CFR Part 20.103 and credit for protection factors associated with respiratory protection equipment use can be utilize (Closed) Violation (267/8817-03): Posting of Radiation Areas - This item was previously discussed in NRC Inspection Report 50-267/88-17, and involved the licensee's failure to properly post radiation areas with regard to personnel working more than 40 hours during a week. The inspector reviewed the licensee's implementation of the corrective actions committed to in PSC letter (P-88370) to the NRC dated November 4, 198 The inspector verified the implementation of the corrective actions (PSC evaluation Memorandum PPS-88-2564, dated August 10, 1988, revisions of Radiation Area Posting Procedure HPP-125, Issue 1). Confirmatory dose rate measurements at several posted radiation areas were made. The ___

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I , es . 4 1-5-licensee's corrective actions appear to be satisfactory to prevent a future recurrence of.this violatio (Closed) Violation (267/8817-04): Failure to Fit Test Respirators - This item was previously discussed in NRC Inspection Report 50-267/88-17, and involved the licensee's failure to ensure that personnel followed procedures and performed a sealing fit test of respiratory protection equipment prior to entering airborne radioactivity areas. The inspector reviewed the licensee's implementation of the corrective actions committed to in PSC letter (P-88370) to the NRC dated November 4, 1988. The inspector verified the implementation of the corrective actions (retaining and added emphasis on performance of acceptable fit tests by users). The licensee's corrective actions appear to be satisfactory to prevent a future recurrence of this violatio (Closed) Open Item (267/8817-05): Hot Particle Exposure Assessment Methodology - This item was previously discussed in NRC Inspection Report 50-267/88-17 and involved the licensee's methods for assessing personnel skin exposure due to hot particles of radioactivity The licensee was provided with the NRC approved VARSKIN computer code during

 ' the referenced inspection. The licensee is evaluating and developing a hot particle control and exposure assessment program to support plant defueling and decommissioning due to start following the June 1990 plant shutdown. This item will be closed and the issue of skin exposure assessment methodology will be tracked via Open Item 267/8817-07 which is scheduled for completion in December 198 (Closed) Open Item (267/8817-06): Industrial Respiratory Protection
 . Program - This item was previously discussed in NRC Inspection Report 50-267/88-17 and involved the inadequate reference of industrial respiratory protection (PSC corporate program) in FSV site training and implementing procedures (Administrative Procedure P-10). Training lesson plans and student handouts have been revised to adequately address industrial respiratory protection aspects, and responsibilities of corporate and site persons responsible for implementation of the industrial respiratory protection progra (Closed) Open Item (267/8817-08): Defining Units Used for Fixed Radioactive Contamination - This item was previously discussed in NRC Inspection Report 50-267/88-17 and involved the licensee's referencing in RP Procedures HPP-21 and 26 that contamination results could be identified in units of counts per-minute (cpm). The licensee revised Procedures HPP-21 and 26 to clarify the use of cpm and conversion to standard units of radioactivity, as referenced in 10 CFR Part 20.5, (Closed) Open Item (267/8817-09): Release of Potentially Radioactive Materials for Unrestricted Use - This item was previously discussed in NRC Inspection Report 50-267/88-17 and involved the licensee's radiological survey and release program for material removed from radiologically controlled areas and the guidance contained in NRC Inspection and Enforcement Information Notice No. 85-92. The licensee's release limits

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 -were considered unacceptably high. .The licensee revised Procedure:HPP-26
 .and provided release limits that were in agreement with NRC. guidance.-

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 ~(Closed) Open Iteni (267/8817-10): Location of Contaminated Material-Receptacles - This item was previously discussed.in.NRC Inspection Report 50-267/88-17 and involved discrepancies.between the proper locatio of_ disposal receptacles for contaminated clothing and waste at the exits from controlled surface contamination areas (CSCAs), and what is_ taught in radiation worker training classes and instructions found in RP-Procedure HPP-125. .The licensee revised Procedure HPP-125 to agree with the. instructions given in radiation worker traini_ng (GET-3) (i.e.,

receptacles shall be on the inside of _CSCAs.) The inspector viewed receptacles during inspections of work areas and determined that training,

 -procedures, and actual implementation were in agreement on receptacle locatio . 0 pen Items Identified During This Inspection An open item is a matter that requires further review and evaluation by
 .the inspector. Open Items are used to document, track, and ensure

' adequate followup on matters of concern to the inspector. The following open item was identified: Open Item Title See Paragrapl) 267/8817-05 Airborne Radioactivity Analysis 49 Form Errors Occupational Exposure, Shipping, and Transportation -(83750) Audits and Appraisals (83750, 83522, and 83722) The inspector examined selected audit and surveillance of the licensee's health physics group activities and RP program

 . implementation procedures. The following 1989 audits and surveillance were examined:

Audits TRQL 89-01, " Training and Qualification," February 1989 HPHY-89-01, " Radiation Protection Program,' March 1989 ENPR 89-01, " Environmental Protection Program," June 1989 Surveillance QAMP-RAP-05-88-1, " Irregularity Reports," December 1988 QAMP-RAP-15-88-2, " Unplanned Gaseous and L.iquid Releases," August 1988 QAMP-RAP-15-88-3, "RP ALARA Practices," September 1988

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  ..QAMP-RAP-15-88-4, " Gaseous 'and Liquid Effluent Release , Followup,"

December 1988 QAMP-RAP-05-89-1, " Radioactive, Material Shipping," February 1989 QAMP-RAP-10-89-1, " Respiratory Protection," , February 1989 L , QAMP-RAP-14-89-1, "RP Instrument 1 Calibration and Documentation," January 1989-QAMP-RAP-15-89-2,. "ALARA Reviews of Procedure Deviation Report," January 1989 ' QAMP-RAP-15-89-3, " Health Physics Document Reviews (HPP-77)," April 1989-The licensee's audits and surveillance are of exceptional detail an comprehensiveness. -Only infrequent and minor procedural violations (including administrative TS items'that involved two separate

  . findings of missing information-required to be in the semi-annual effluent reports,.TS 7.5.1.e) were. identified in the audits and surveillance-reviewed. Since the apparent violations were

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  .self-identified, a Notice of Violation is not being issued because the licensee satisfied the criteria of 10 CFR 2, Appendix C, Section V.G.I. Effective corrective action to audit and surveillanc findings were being expediently provided by the health physics grou :The, health physics group has embarked on a self assessment and
  ' improvement program, and has hired. technical specialists to perform reviews, evaluations, and propose solutions to problems identifie Audit plans, checklists, and schedules appear to be adequate for'the RP progra No violations or deviations were identifie Changes (83750, 83522,'83722, and 83527)

The licensee's organization and staffing of the RP group was inspected to determine agreement with commitments in the Updated Final Safety Analysis Report (UFSAR) Sections Il and 12; and compliance with the requirements of TS 7.1, 7.3, 7.4, and 7.5; and the recommendations of NUREGs-0731 and 076 The inspector examined licensee facilities, interviewed personnel, and reviewed revised procedures (nearly all RP program procedures had been review, revised,. and reissued during the first part of 1989).

The. inspector examined the qualifications and experience level of a new staff health. physicist (previously assigned to the Training Department and a former health physics technician) and the acting technical training supervisor (responsible for health physics technician, radiochemistry, technical advisor, and water chemistry

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   -8-training). The inspector determined that procedure and personnel changes were acceptabl The licensen's turnover rate for health physics group personnel was reviewed. This was an NRC concern addressed in the last SALP cycle report (50-267/87-35). Ttc licensee is currently fill'ng health physics technician positions with contractor personnel to maintain proper staffing. The inspector and licensee representatives discussed the last two health physics technician losses (one left to improve his job security, and one was terminated for cause). The licensee is keeping employees informed, as well as possible, as to developments in future plant closure and staffing needs. The licensee has put in place a program to help improve employee (all)

retention that provides economic and future job placement assistance incentives to. stay with PSC until their services are no longer neede The licensee had improved (aesthetically and environmentally) office type work space for all health physics technician No violations or deviations were identifie c. Planning and preparation (83750 and 83728) The inspector reviewed the licensee's proposed decommissioning plan, specifically the operations to be undertaken following plant shutdown on or about June 30, 1990, involving off loading of the reactor core and subsequent shipment to the Department of Energy storage facility in Idaho. The licensee has started refurbishment of the fuel handling machine to ensure that it will provide suitable reliability during the lengthy fuel removal projec The health physics group is procuring new laboratory type beta and alpha radiation counting equipment and an improved portable radiation monitoring instrument calibration device (cesium-137 type).

No violations or deviations were identifie d. Training and Qualification (8375[ ,d 83723) The licensee's radiological training and the radiation protection personnel qualification programs were inspected to determine agreement with commitments in Section 12 of the UFSAR; and compliance with the requirements of TS 7.1, and 30 CFR Part 19.12; and the recommendations of NRC Regulatory Guides (RGs) 8.13, 8.27, and 8.29; Industry Standard ANSI 18.1-1971; and NUREGs-0041 and 076 The inspector reviewed the licensee's radiological training programs for permanent plant employees, visitors, and contractors. Lesson plans had been supplemented and or revised to provide added emphasis on NRC and Occupational Health and Safety Administration (OSHA) I __________-_ -

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   -9-requirements for the qualification and use of respiratory protection equipment. The last two personnel hired as health physics technicians were contractors and had previously completed FSV health physics technician qualifications and were being provided updated trainin The inspector reviewed the qualifications and experiences of the health physics staff and supervisors and found them to meet the requirements of TS 7.1 and 7.3, and ANSI 18.1-1971 due to a combination of experience a-d specialized trainin No violations or deviations were identifie e. External Exposure Control and Personal Dosimetry (83750)

The licensee's external radiation exposure control program was reviewed for agreement with the commitments in Section 11 of the UFSAR and compliance with the requirements contained in TS 7.4.d, 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203., 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409; and the recommendations of NRC Inspection and Enforcement Information Notices (IEINs) 86-23 and 87-39, and also the recommendations contained in NRC RGs 8.8, 8.13, 8.14, and 8.28, and those of Industry Standard ANSI N13.11-198 The inspector reviewed personnel exposure records, records storage facilities, exposure control procedures, dosimetry processing procedures, dosimetry quality control methods, and data processing, and verified that the licensee's supplier of personnel dosimetry services was currently accredited in accordance with the requirements of 10 CFR Part 20.202(c).

No violations or deviations were identifie f. Internal Exposure Control and Assessment (83750, 83525, and 83725) The licensee's internal radiation exposure control program was reviewed for agreement with the commitmer.ts in Section 11 of the UFSAR; and compliance with the requirements contained in TS 7.4.d; 10 CFR Parts 19.13, 20.103, 20.108, 20.203, 20.206, 20.401, and 20.405; and the recommendations of NRC RGs 8.8, 8.13, 8.15, 8.20, 8.26, and 8.28; NUREG-0041; and Industry Standards ANSI 13.1-1969, and N343-197 The inspector reviewed the licensee's implementing procedures, management policies governing use of RP equipment, programs and activities involving routine and emergency aspects of the internal dosimetry, air sampling and analysis, and posting of airborne radioactivity ', ea _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -

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inspector:and'found to be much improved over that found during'the previous inspection-of this area.

, The licensee's whole body counting procedures and practices involving- ' .

  .a select number of previous employees were reviewed for compliance with 10 CFR 19;and 20 requirement No violations or deviations were identifie Control of Radioactive Materials (RAM) and Contamination, Surveys,

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  -and Monitoring (83750, 83526, and 83726)

The,11censee's-programs for.the control of RAM and contamination, radiological surveys, and monitoring were reviewed for. agreement with the commitments in Section 11 of the UFSAR; and compliance with the requirements of TS 7.4; 10 CFR Parts 19.12, 20.4, 20.5, 20.201, 20.203, 20.205,'20.207, 20.301,.20.401, and 20.402; and the recommendations of IEINs 85-92 and 86-4 The inspector toured FSV facilities; conducted independent gamma radiation dose rate measurements; reviewed ongoing work operations within the reactor building and turbjne building; reviewed Radiation Work Permits; reviewed' radiation, airborne, and surface contamination surveys (routine and work related); reviewed response checking of instruments; and reviewed the updating of plant radioicgical information maps. The licensee's analysis equipment provides for beta and alpha . radioactivity analysis and the evaluation of air samples for iodine and other fission product During the review n 1989 surveys (30), it was noted that the computerized printoet of airborne radioactivity sample analysis does not provide sufficient information to allow ~the reviewer (health physics supervisor) to verify the results. This is due to the lack ofLinformation on the form concerning counting instrument efficiency, background counts, and background counting time. The health physics supervisor acknowledged the shortcomings of the analysis printout and committed to revising the form to include the necessary information so the form could stand alone as an official docement. This is considered an open item pending licensee correction of the air sample analysis form. (267/8917-02) The inspector also brought to the attention of the RP supervisor errors on surveys that had been through the review proces The inspector examined the licensee's RAM storage facilities (fully enclosed van type trailers) for posting, material labeling, a security. All drums observed were properly labele No violations or deviations were identifie . - _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ - _ -

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, b. Maintaining Occupational Exposure ALARA (83750 and 83728) The licensee's ALARA program was reviewed to determine agreement with the commitments in Section 11.2 of the UFSAR: the' requirements of 10 CFR Part 20.1(c); and the recommendations of RGs 8.8, 0.10, and 8.2 The inspector reviewed the licensee's ALARA plan (HPP-925). The licensee's ALARA plan has all the attributes of a good exposure reduction program. The plant health physicist is designated as the station ALARA coordinato FSV's exposure expenditures for 1987 and 1988 were 1.24 and 0.720 person-rem, respectively. FSV was not operating for approximately 10 months of 1987 and nearly all of 1988. The licensee's' 1989 ALARA goals for various radiological performance aspects are as'follows: Collective Radiatior Exposure Goal: 2.0 person-rem Current: 1.45 perron-rem

  ' Low Level Solid Radwaste Generated Goal: 42.6 cubic meters Current: 5.0 cubic meters Skin and Clothing Contaminations Goal: 24 or fewer Current: 8 skin contaminations Positive Whole Body Counts Goal: 0 (zero)

Current: 0 (due to FSV operations) No violations or deviations were identifie . Shipping of Low-Level Waste for Disposal and Transportation (83750) The inspector examined licensee records and interviewed personnel to cetermine compliance with DOT and NRC requirements contained in 10 CFR Parts 20.205, 20.311, 61.55, 61.56, and 71; and 49 CFR Part 173, Subpart 1, as they relate tc the transportation of RAMS and wast The inspector examined the licensee's progress on investigating the unauthorized modification of one or more NRC certified spent fuel shipping casks (Package Identifications USA /6346/B( )F OR _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ -

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USA /6347/AF). .The licensee had established a multiple discipline task.forc (see FSV' Corrective' Action Request:89-007 and Memorandum NFS-89-0322, dated June.22, 1989) to evaluate the problem and formulate appropriate corrective actions to return the casks to e certification status. This item'was previously discussed in NRC Inspection Report 50-267/89-1 * During the review of eight shipments' during the first part of 1989, it was noted that the licensee did not have, on file, a copy of.the transferee's NRC or Agreement State License.for four of-the seven radioactive material-shipment Section 1.I of-the FSV Facility Operating License states, in part, that'"The receipt, possession, and use'of byproduct . . . materials

as authorized by this license will be in'accordance with the Commission's regulations in 10' CFR Parts 30, 40 . . . ."

paragraph (c) of .10 CFR Partt30.41, " Transfer of' Byproduct Material," states,. in part, that "Before transferring special nuclear material to a . . . licensee cf-an Agreement State . . . the licensee transferring the. material ~ shall verify- that the transferee's license-authorizes receipt of the type,. form, and quantity of special nuclear material to be transferred." Paragraph (d) identifies five dif ferent physical methods of verifying that the transferee's license < authorizes such possession. Only in emergency shipments / transfers is the transfe er authorized to use oral verification by the transferee as to license condition The licensee was noted to.have. .on file, current copies of burial site licenses and a transferee's license that had expired in 1987 but was under timely review by the NRC Region I of fices. The failure to have, on hand, copies of transferees' licenses is an apparent violation of 10 CFR Part 30.41. (267/8914-01) The. licensee admitted that the failure to have licenses in files was an oversight by the responsible party and that verbal verifications were generally made. The licensee immediately revised the procedure checklist to indicate that only copies of the licenses of transferees-would be suitable verification of allowable materials. Current material licenses for the four shipments missing were obtained prior to the inspector's exit meetin Due to the expeditious, comprehensive, and effective manner in which the licensee corrected this administrative violation, it will not be necessary for the licensee to respond .in writing, to this violatio This violation is identified for documenting purpose _ _ _ _ _ _ _ - - - _ -

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< 5. Exit Interview

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The inspector met with the resident inspector and licensee representatives denoted in paragraph 1 on July 14, 1989, and summarized the scooe and findings of the inspection as presented in this report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during the inspectio . - . _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ _ _ _ - }}