IR 05000416/1993020
| ML20059L023 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/10/1993 |
| From: | Forbes D, Rankin W, Shortbridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059L021 | List: |
| References | |
| 50-416-93-20, NUDOCS 9311160273 | |
| Download: ML20059L023 (14) | |
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UNITED SVATES f#p asa\\,
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Report No.:
50-416/93-20 Licensee:
Entergy Operations, Inc.
Jackson, MS 39205 Docket No.:
50-416 License No.: NPF-29 Facility Name:
Grand Gulf Inspection Conducted: October 25-29, 1993 Inspectors:
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U/8/93 II.'B. Forbes Date Signed
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R. B. Shortridge
Date Sfigned
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Accompanying Personnel:
W. T. Loo Approved by:
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////#/93 W. H. Rankin, Chief Date Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards i
SUMMARY Scope:
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This routine, announced inspection was conducted'during Refueling Outage-6
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(RF0-6) in the area of occupational radiation safety and involved an assessment of onsite activities in the area of radiation control (RC).
Elements of the program examined were audits and appraisals, planning and
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preparation, training and qualifications, external exposure control, internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposures ALARA.
Results:
The RC activities reviewed were conducted in accordance with regulatory requirements and licensee conditions. The RC contract technician and general employee training (GET) programs were conducted in accordance with approved procedures and the RC technician staff appeared knowledgeable and well
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trained. The licensee continued to implement effective internal and external
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exposure programs with all exposures less than 10 CFR Part 20 limits.
i Contamination control-and overall housekeeping practices as well as ALARA-t
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9311160273 931110 PDR ADOCK 05000416 O
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initiatives were considered adequate.
In the areas inspected, no violations or deviations were identified. One Inspector Followup Item was opened to review resolution of corrective actions to a Radiological Deficiency Report addressing an inadequate procedure (Paragraph 3.b).
Based on interviews with licensee management, supervision, personnel from station departments, and records review, the inspector found the radiation protection program to be adequate in protecting the health and safety of plant employees.
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l REPORT DETAILS
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1.
Persons Contacted-i Licensee Employees l
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R. Benson, Shift Supervisor, Health Physics, Radiation Control
- D. Coulter, Supervisor, Radiation Control
- L. Daughtery, Superintendent, Plant Licensing i
- M. Dietrich, Manager, Nuclear Training
- C. Dugger, Manager, Operations j
'N.~Edney, Supervisor, Health Physics, Radiation Control
- W. Garner, Supervisor, Quality Performance F. Guynn, Supervisor, Health Physics, Radiation Control
- C. Hayes, Director, Quality Performance
- C. Hicks, Superintendent, Operations
M. Larson, Audit Team Leader, Quality Performance i
S. Marrs, ALARA Specialist, Radiation Control
S. Murano, Shift Supervisor Health Physics, Radiation Control j
- D. Pace, General _ Manager
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B. Roberson, Dosimetry Technician, Radiation Control i
F. Rosser, Supervisor, Dosimetry, Radiation Control l
- R. Ruffin, Specialist, Licensing
S. Speyerer, Quality Spacialist
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. Tankersley, Superintendent, Radiatinn Control
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T. Trichell, ALARA Technician, Radiation Control
I Other licensee employees contacted during this inspection-included
~j craftsmen, engineers, mechanics, technicians, and administrative i
personnel.
j Nuclear Regulatory Commission
- R. Berni.ard, Senior Resident Inspector C. Hughey, Resident Inspector
- Attended October 29, 1993, Exit Meeting l
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2.
Organization and Staffing (83729)
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The inspector reviewed and discussed with licensee representatives changes made to the radiation control (RC) organization since the last
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inspection of this area conducted May 24-28, 1993, and documented in _
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Inspection Report (IR) 50-416/93-08.
Cognizant. licensee representatives stated that no significant changes had been made to the organizational structure or lines of authority as they related to the RC function; however, the licensee is planning to make changes to the health physics supervisory structure. The licensee informed the inspector that-the changes will include eliminating a technical assistant position in the RC_ staff. The individual now serving as technical assistant will become the operations RC supervisor. The current operations RC. supervisor will replace the current technical-RC superviscr, who is being transferred to-
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a special projects position in the corporate office. The licensee continued to maintain a stable core RC-technician staff of approximately
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36 RC technicians to support operations, ALARA, radwaste, respiratory j
protection, and dosimetry in the RC Organization.
j for RF0-6 approximately 96 contract technicians were utilized to-supplement the routine staff. This number included senior. technicians, RC administrative technicians, and decontamination personnel. The percentage rate of _ health physics (HP) contract technicians returning to -
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Grand Gulf was 46 percent, with a percentage returnee rate to the Entergy System of 69 percent. The qualifications of the outage RC staff i
are discussed in detail in Paragraph 4.b.
Based on discussions with licensee representatives and observation of
I activities in progress, the RC staffing levels appeared to be adequate to support on-going and planned outage activities.
No violations or deviations were identified.
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3.
Self Assessment Programs (83729)
a.
Quality Assurance Audits Technical Specification (TS) 6.5.2.8 requires audits of facility activities to be performed under the cognizance of the Quality
Assurance (QA) Program encompassing conformance of facility
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operation to all provisions contained in the TSs and applicable License Conditions at least once per 12 months, and the process control program (PCP) and implementing procedures at least once per 24 months.
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The inspector reviewed licensee efforts to self identify potential radiological issues or problems while performing audits of the RC program. Observations by the inspector and discussions'with
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cognizant licensee personnel indicated that these efforts were
accomplished by reviewing procedures, observing work, reviewing i
industry documentation and performing plant walk downs to include surveillance of work areas by supervisors and technicians during normal work coverage. Documentation of problems by licensee representatives was included in Radiological Deficiency Reports (RDRs), and/or Quality Programs Audit Reports (QPARs). The QPARs reviewed since the last inspection included:
QSA-93/0017, June 03, 1993, Health Physics Dosimetry Program
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QSA-93/04003, September 24, 1993, Low Level Radioactive a
Waste and NRC Approved Packaging and Shipping Program and
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Radio:.ctive Laundry
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In general, the audits were determined to be well planned and conducted, and contained items of substance relating to the radiation protection program.
Based on these observations by the
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inspector, the Audit and Appraisal Process continued to be
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considered as a program strength.
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b.
Radiological Deficiency Reports
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The inspector reviewed 31 RDRs that were written in 1993.
RDRs were tracked and trended and specified recommended corrective action.
Licensee procedure 01-S-08-26, Radiological Deficiency Reports, Revision (Rev.) 0, dated May 6,.1992, provided the
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guidance for implementation of the RDR program.
The inspector reviewed an RDR relating to a deficiency in which a
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worker entered a precoat filter and pump room to perform a transfer evolution involving resin. This evolution resulted in unusually high radiation levels in the room because the resin
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became unshielded as the water level was decreased in the tank.
When the inspector looked at the digital alarming dosimeter (DAD)
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it displayed 1,600 millirem per hour (mR/hr); however, the
histogram later showed a maximum dose rate of 1,941 mR/hr. The
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i licensee attributed the higher than usual radiation levels to a l
recent reactor scram which suspended high levels of corrosion products in the reactor water. The licensee's RC staff identified the root cause of the deficiency as an inadequate procedure and i
recommended corrective actions to include an RC staff review of specific procedures in the event a scram occurs. The inspector's review of this event determined differing opinions among licensee
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representatives as to the root cause of the deficiency and corrective action required. The inspector informed licensee management at the exit interview that satisfactory resolution to
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this RDR would be an Inspector Followup Item (IFI), to review
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licensee corrective actions, and would be tracked by the NRC and
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inspected during subsequent inspections (IFI 50-416/93-20-01).
No violations or deviations were identified.
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Training and Qualifications (83729)
10 CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in the applicable provisions of the Commission
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regulations; in the individuals's responsibilities; and in the availability of radiation exposure data.
a.
General Employee Training (GET)
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GET Level I training was provided to employees needing unescorted access to only the protected area.
For workers needing unescorted
access to the radiologically controlled area (RCA), Level II
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training was required, in addition to Level 1.
The specific lesson plans and procedures related to the GET program reviewed by the inspector and discussed with licensee representatives included the following:
Administrative Procedure, 01-S-04-9, Health Physics Training
Program, Rev. 11, dated October 08, 1992 Administrative Procedure, 01-S-04-29, Site Continuing
Training, Rev. 1, dated October 03, 1988 GE-RWl-HN-001-02, Radiation Worker l' Training, Rev. 2, dated
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August 06, 1993 GE-GET2-HN-001-06, Radiation Worker 2 Training, Rev. 6,
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dated July 28, 1993 In addition, a selected number of individual training qualification records were reviewed by the inspector. For the records reviewed, no discrepancies in personnel qualifications were noted.
Based on the evaluation of selected training procedures, examinations, student handouts, and course outlines, the inspector determined that the licensee's GET program met the provisions of
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b.
Contractor Technician Training The inspector reviewed the process for qualifying and training contractor HP personnel. Licensee procedures require temporary contractor HP personnel to meet the qualifications of ANSI /ANS-18.1-1981 which stipulates a minimum of three years of related working experience. Contract personnel must also satisfactorily l-complete Radiation Control Training and/or the Radiation Control Training Examination in addition to Temporary Employee Training to include site specifics.
The inspector reviewed selected resumes for the contractor technicians employed onsite for the current Unit 1 outage and i
verified compliance with ANSI 18.1-1981 requirements.
Review of l
training documentation and interviews with several contractor HP technicians and licensee staff members determined successful completion of procedural reviews and qualification tasks.
The inspector determined the licensee's program for contractor HP technician training was adequate and conducted in accordance with approved procedures.
No violations or deviations were identified.
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5.
External Exposure Controls (83729)
10 CFR 20.101 requires that no licensee possess, use, or transfer i
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licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a total
occupational dose in excess of 1.25 rem to the whole_ body, head and truck, active blood forming organs, lens of the eyes, or gonads;
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18.75 rem to the hands, forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
a.
Personnel Dosimetry l
10 CFR 20.202(a) requires each licensee to supply appropriate
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monitoring equipment to specific individuals and requires. the use of such equipment.
10 CFR 20.202(c) requires that dosimeters used tc comply with 10 CFR 20.202(a) shall be processed and evaluated by a processor accredited by the National Voluntary Laboratory Accreditation
Program (NVLAP) for the types of radiation for which the individual is monitored.
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During tours of the plant, the inspector observed personnel-wearing appropriate monitoring devices on the location of the body
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as specified by the radiation work permits (RWPs). The inspector
reviewed and discussed the licensee's dosimetry program with site
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personnel and determined licensee dosimetry was being processed
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under NVLAP certification by plant personnel on a monthly bases.
The licensee is implementing the processing of dosimetry'on a
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quarterly bases in lieu of monthly processing.
b.
Whole Body Exposure The inspector discussed the cumulative whole body exposures for-i plant and contractor employees.
Licensee representatives stated
and the inspector confirmed that all whole body exposures assigned
since the previous NRC inspection of this area were within 10 CFR
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Part 20 limits. A discussion with licensee representatives and a review of pertinent records determined the licensee had established an exposure goal of 345 person-rem for 1993 based on
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an estimated 270 person-rem for the tentative work schedule of
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RF0-6 and 75 person-rem estimated for operational exposure for the t
year. The licensee's exposure for 1993 as of October 27, was
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approximately 209.4 person-rem based on estimated TLD readings,
which included RFO-6 outage exposure and 44.1 person-rem
operational exposure year to date.
- No violations or deviations were identified.
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6.
Internal Exposure Controls (83729)
10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual
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in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
a.
Respiratory Protection and Breathing Air Quality The inspector reviewed records for selected employees who had been issued and had used respiratory protection equipment during the current outage. The inspector verified that for the records reviewed, each worker had successfully completed respiratory protection training, was medically qualified, and was fit-tested for the specific respirator type used in accordance with licensee procedural requirements. The inspector reviewed licensee training procedure GE-GET3-HN-001-04, Initial Respiratory Protection Training, Rev. 4, dated July 28, 1993.
The inspector examined respiratory equipment for physical integrity.
In addition, the inspector further noted that the supplied air hoods, fittings, and hoses available for use were compatible per manufacturer's instructions. Selected training records, medical qualifications, and fit test records for individuals qualified to wear respiratory equipment were also reviewed by the inspector. An individual's qualification for wearing respiratory equipment is provided on a computer screen at the respiratory issue station.
30 CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air set forth in the compressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
The inspector reviewed and discussed with the licensee's Respiratory Protection Supervisor the program for testing and qualifying air as Grade D, particularly as it related to the preparation for RF0-6 activities. The inspector observed the in-use breathing air system which included a plant in'line system using 2 permanently installed compressors. The inspectors examined breathing air. manifolds for physical integrity, current calibration of gauges, and the presence of carbon monoxide monitoring equipment.
For the tests reviewed, breathing air met Grade D requirement '
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Whole Body Counting
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10 CFR 20.103 (a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely
detection and assessment of individual intakes of radioactivity by
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exposed individuals.
10 CFR 20.103(b) requires that when an individual exceeds 40 Maximum Permissible Concentration-hours (MPC-hours) in any consecutive seven day period, the licensee shall make such evaluations and take such action necessary to assure against recurrence.
The inspector observed performing whole boc.y counting of selected
personnel and reviewed Licensee Procedure 08-S-02-32, Evaluation of In-Vivo Bioassay Results, Rev. 4, dated September 13, 1988, which provided the methodology for evaluating measured organ burdens and estimating the amount of radioactivity taken into the
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body. A review of licensee records and discussions with licensee representatives identified that approximately 2 low level internal contaminations had occurred in 1993, of which, all were less than ten percent Maximum Permissible Organ Burden (MP0B).
Based on the above, the inspector concluded that the licensee was effectively controlling internal contaminations with no exposure greater than the 40 Maximum Permissible Concentration - hour (MPC-hr) control limit as identified in Licensee Procedure 08-S0-2-41, MPC Hour Tracking, Rev. 7, dated Jat.uary 5, 1993, which is consistent with regulatory requirements.
No violations or deviations were identified.
7.
Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750)
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10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contains any radioactive material in an amount-
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exceeding ten (10) times the quantity of such material specified in l
Appendix C of this part to be posted with the sign or signs bearing the.
- radiation caution symbol and the words: " Caution, Radioactive
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Material (s). "
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Posting and Labeling 10 CFR 20.203(f) requires, in part, each container of. licensed material containing greater than Appendix C quantities to bear a durable, clearly visible label identifying the radioactive
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contents and providing sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
During tours of the Unit 1 Containment, Auxiliary Building.
Radwaste Building and selected outside radioactive material storage areas, the inspector noted that radioactive material areas
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were appropriately posted and containers were labeled consistent with regulatory requirements and in accordance with licensee procedure 08-S-02-20, Establishing and Posting Controlled Areas,
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Rev. 10, dated December 16, 1992, and 01-S-08-6, Radioactive t
Material Control, Rev.13, dated January 8,1993.
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Personnel and Area Contamination
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The licensee maintained approximately 507,500 square feet (ft ) of floor space as radiologically controlled. As of October 25, 1993, the licensee.was tracking approximately 13 percent of.the total RCA recoverable contaminated space as a primarily resulting from RF0-6 outage activities. The licensee was tracking approximately
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2.7 percent of recoverable space as contaminated during the last non outage inspection of May 24-28, 1993.
As of October 26, 1993, approximately 115 Personnel Contamination Events (PCEs) had occurred in 1993. Discussions with licensee representatives and review of PCE data revealed that approximately a
43 were skin contaminations and 72 were clothing contaminations.
Of the PCEs that occurred in 1993, 58 PCEs had occurred during RFO-6 which included approximately 32 skin contaminations and 34 clothing contaminations.
During plant tours, the inspector generally observed good housekeeping and contamination control practices.
c.
High Radiation Areas TS 6.12.1 required, in part, that each High Radiation Area (HRA)
with radiation levels greater than or equal to 100 mrem /hr but less than or equal to 1000 mrem /hr be barricaded and conspicuously posted as a HRA.
In addition, any individual or group of individuals permitted to enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously
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indicates the radiation dose rate in 'he area or a radiation
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t monitoring device which continuously integrates the dose rate in the area, or an individual qualified in radiation protection-i procedures with a radiation dose rate monitoring device.
Licensee Procedure 01-S-08-2, Exposure and Contamination Control, Rev. 28, dated January 27, 1993, described the licensee's. specific requirements for establishing, posting, and controlling HRAs.
During tours of the Auxiliary Building, Radwaste Building, and the-
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Unit 1 Containment, the inspector noted that all HRAs and locked
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HRAs were locked and/or posted, as required. The inspector performed independent radiation surveys at the boundaries of
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selected HRAs and locked HRAs verifying licensee survey results'.
l The licensee's posting of the affected areas was conservative and
appropriate.
d.
Radiation Detection snd Survey Instrumentation
t During facility tours, the inspector observed health physics
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personnel operating survey instruments following the requirements of Licensee Procedure 08-S-01-70, Health Physics Instrumentation, Rev. 13, dated November 25, 1992. The inspector noted that survey
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instrumentation and continuous air monitors in use within the RCA were operable and displayed current calibration stickers. The
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inspector further noted an adequate number of survey instruments were available for use during RFO-6 and background radiation levels at personnel survey locations were observed to De within the licensee's procedural limit of 300 counts per minute.
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Surveys
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The inspector reviewed the plant procedure which established the licensee's radiological survey and monitoring program and verified that the procedures were consistent with regulations, TSs, and good HP practices.
-f The inspector reviewed selected records of radiation and contamination surveys performed during RF0-6, and discussed the survey results with licensee representatives.
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During tours of the plant, the inspector observed HP technicians.
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Surveillance, Rev. 16, dated February 2, 1993.
During facility l
tours, the inspector also independently verified radiation and/or contamination levels in selected areas of the Unit 1 Containment, o
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Radwaste Building,-the Auxiliary Building, Radiative Material and Storage Areas. The inspector noted that all containers, materials, and areas were properly. labeled, posted, and/or
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safeguarded in accordance with the radiation hazard present.
l No violations or deviations were-identified.
8.
Operational and Administrative Controls (83729)
a.
Radiation Work Permits The inspector reviewed Plant Procedure 08-S-01-24, Radiation Work Permit (RWP), Rev. 24, dated March 31, 1993, which provided detailed instructions on the preparation and processing of RWPs.
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The inspector reviewed selected routine and special RWPs for adequacy of the radiation protection requirements based'on work scope, location, and conditions.
For the RWPs reviewed, the
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inspector noted that appropriate protective clothing, respiratory protection, and dosimetry were required. During tours of the plant, the inspector observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with plant
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workers at the job site.
The inspector reviewed Radiological Status Boards used to enhance RWP survey information. These Status Boards are posted at the
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access to the RCA and also posted at specific boundaries
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throughout the plant. The status boards contained current survey i
information and were color coded to emphasize particular radiological areas such as HRAs and locked HRAs.
The inspector found the' licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
b.
Notices to Workers i
10 CFR 19.11(a) and (b) require, in part, that the licensee post
current copies of 10 CFR Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a notice describing these documents and where they be examined.
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posted to permit licensee workers to observe them on the way to or i
from licensee activity locations.
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During tne inspection, the inspector verified that NRC Form-3 was posted properly at. various plant _ locations permitting. adequate worker access.
In addition, notices were posted referencing the location where the license, procedures, and supporting documents
could be reviewed.
No violations or deviations were identified.
9.
Information Notices (92717)
The inspector determined that the following Information Notices (ins)
had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate,
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was taken or scheduled:
Enforcement of Safety Requirements for Radiographers
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False Alarms of Alarm Ratemeters Because of
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Radiofrequency Interference
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10 CFR Part El and 50.55(e) Final Rules
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Potential Weakness in Licensee Procedures for Loss of
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Refueling Cavity Water r
Falsification of Plant Records
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New Exposure Limits for Airborne Uranium and Thorium l
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Implementation of the Deliberate Conduct Rule
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Recent Revisions to 10 CFR 20 and Change of
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Implementation Date to January 1,1994 IN 93-05:
Locking of Radiography Exposure Devices
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No violations or deviations were identified.
10.
Program for Maintaining Exposures As Low As Reasonable Achievable (83729)
10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable (ALARA).
Regulatory Guides 8.8 and 8.10 provide information relevant.to attaining goals and objectives for planning and operating light water reactors and provide general philosophy acceptable to the NRC 'as a necessary basis
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for a program of maintaining occupational exposures ALARA.
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The inspector reviewed and discussed with cognizant licensee representatives ALARA program implementation and initiatives for RFO-6 and RFO-7. The licensee is currently planning major chemical system decontamination efforts for RF0-7 to include the Reactor Recirculation System, the Reactor Water Cleanup System and the Residual Heat Removal System.
The licensee was also in the planning phase to include:
hydrolancing internals of selected piping sections, reduce feedwater iron, and begin zinc injection. The licensee's efforts for non-stellite replacement parts was still in the planning stages.
One ALARA initiative by the licensee for RFC-6 was to reduce respirator usage while continuing to minimize internal uptakes of radioactivity.
By increased use of engineering controls such as worksite ventilation, decontamination of areas, and increased worker awareness of contamination controls, the licensee had effectively capitalized upon this initiative. The inspector reviewed the number and types of respirators issued during the current outage. Respiratory devices such as respirators, bubble hoods, and self contained breathing apparatus (SCBA) had been reduced approximately 74 percent for day 28 of the
outage.
The licensee had used approximately 1,200 respiratory devices during RF0-6 and 1,700 respiratory devices year to date as of September 27, 1993. The licensee used approximately 9,352 respiratory j
devices which included 7,014 used during RF0-5.
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The inspector attended an ALARA Committee Meeting held by the licensee to discuss agenda items to include a review of exposure estimates verses
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exposure goals for Main Steam Relief Valve work, to review site exposure performance during the outage for the months of September and October, and possible adjustment of November goals.
In general, based on the above, the inspector found ALARA initiatives to be adequate to support ongoing operations.
No violations or deviations were identified.
11.
Exit Interview (83729, 92702)
At the conclusion of the inspection on October 29, 1993, an exit meeting was held with those licensee representatives indicated in Paragraph 1 of this report.
The inspector summarized the scope and findings of the inspection and indicated that no apparent violations or deviations were identified.
The licensee did not indicate any of the information provided to the inspectors during the inspection as proprietary.in nature and no dissenting comments were received from the licensee.
Item Number Description and Reference i
50-516/93-20-01 IFI - Review resolution of corrective actions to a RDR addressing an inadequate procedure (Paragraph 3.b.).
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