ML18152A652
| ML18152A652 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/21/1988 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A650 | List: |
| References | |
| 50-280-87-35, 50-281-87-35, IEIN-87-007, IEIN-87-031, IEIN-87-31, IEIN-87-7, NUDOCS 8802030151 | |
| Download: ML18152A652 (12) | |
See also: IR 05000280/1987035
Text
Report No.:
Licensee:
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
f .1'. i ... 1
....
~i
- *i '. .
50-280/87-35 and 50-281/87-35
Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
Inspection Conducted:
December 7-11, 1987
___ ...,.-?
---
Inspector:
---....._/~~--:
/
F. N. Wright
Approved
SUMMARY
Date Signed
// **;In.
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IC,'-.)
Date Signed
Safeguards
Scope:
This was a routine unannounced inspection in the areas of previous
enforcement matters, internal exposure control, control of radioactive
material, solid wastes, transportation, NRC Information Notices, allegations,
and occupational exposure during extended outages.
Results:
One violation was identified: failure to adhere to radiation control
procedures.
8802030151 880122
ADOCK 05000280
G
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
H. L. Anglin, Assistant Supervisor, Health Physics
- D. L. Benson, Station Manager
M. R. Beckham, Assistant Supervisor, Health Physics
E. E. Bick, Senior Instrument Technician
H. D. Collar, Supervisor, Quality Assurance
W. N. Cook, Operations Supervisor, Health Physics
D. W. Densmore, Assistant Supervisor, Health Physics
R. C. Early, ALARA Technician, Health Physics
C. E. Foltz, Jr., Assistant ALARA Supervisor, Health Physics
- B. Garber, Health Physics Supervisor
- E. S. Grechelk, Assistant Station Manager, Nuclear Safety and Licensing
- G. D. Miller, Licensing Coordinator, Safety Engineering Staff
- A. Price, Qualtiy Assurance Manager
- S. P. Sarver, Superintendent, Health Physics
- E. A. Schnel, Superintendent, Health Physics (Corporate)
Other licensee employees contacted included technicians and mechanical
maintenance personnel.
- Attended exit interview
2.
Exit Interview (30703)
The inspection scope and findings were summarized on December 11, 1987,
with those persons indicated in Paragraph 1.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below.
Dissenting comments were not received from the licensee.
The
licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
Item Number
50-280, 281/87-35-01
50-280, 281/87-35-02
Status
Open
Open
Description/Reference Paragraph
Violation - Failure to control
radioactive material in accordance
with
licensee
procedures
(Paragraph 4).
Unresolved Item* - Failure to
identify potential violations of
10 CFR 20 requirements in licensee
- Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or deviations.
..
2
50-280, 281/87-35-03
Open
50-280, 281/87-35-04
Open
50-280, 281/87-35-05
Open
50-280, 281/87-24-02
Closed
Quality Assurance Audits and
Surveillance as findings requiring
corrective action (Paragraph 4).
Inspector Followup Item (IFI) -
Review criteria for initiating
investigations
of
dose
abnormalities (Paragraph 4).
IFI - Review controls for
misplaced, dropped or offscale
self reading pocket dosimeters
(Paragraph 4).
IFI - Review licensee controls
for health physics procedures
(Paragraph 4).
Violation - failure to perform
quality control checks on the
whole body counter (Paragraph 3).
3.
Licensee Action on Previous Enforcement Matters (92702)
(Closed) Violation (50-28)/87-24-02 and 50-281/87-24-02).
Failure to
perform quality control checks on the whole body counter.
The inspector
reviewed the licensee's response dated September 25, 1187, and verified
that the corrective action specified in the response had been taken.
4.
Occupation Exposure During Extended Outages (83729)
a.
Unit 2 Snubber Outage
The licensee took the unit two reactor offline on December 8, 1987,
after a utility record of 248 straight days on line.
The unit was
taken offline for a 12 day outage to include work on snubbers and
miscellaneous valves, repair a cracked letdown line, repair a
residual heat removal RHR pump and motor, and replace a containment
ventilation fan.
The* outage,. originally scheduled to begin in
October, had been delayed due to unplanned outages at other utility
facilities.
The licensee brought in approximately 40 contract health
physics technicians to support the outage work.
Containment vacuum
was broken on December 9 and preparations for containment work,
surveys, shi el ding, and the positioning of equipment began that
afternoon.
The stations ALARA man-rem goal was set for 719 man-rem.
The
licensee had about 600 man-rem total before the outage work began and
had set an outage goal of about 60 man-rem.
The licensee expected
..
L --~--
3
the RHR pump and motor replacement to be the highest dose task for
the outage which was projected to account for about 6 man-rem.
No violations or deviations were identified.
b.
Unit Two Containment
The inspector accompanied.two mechanical maintenance personnel and a
contract health physics technician into the licensee's unit two
containment building to observe. a gasket replacement on a chemical
volume control system (CVCS) valve.
Radiation Work Permit '(RWP)
87-RWP-2161 had been prepared for the gasket replacement task.
The
gasket replacement involved three crafts:
the insulators who had
already removed the insulation, the electricians who had also
disconnected valve controller cable and the mechanical maintenance
personne 1 who wou 1 d open the va 1 ve and rep 1 ace the gasket.
The
inspector reviewed the radiation work permit requirements for
appropriateness based on the work scope, location, and conditions and
verified that the RWP had been properly approved.
10 CFR 20.lc 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).
The
recommended elements of an ALARA program are contained in Regulatory
Guide 8.8, Information Relevant to Ensuring that Occupational
radiation Exposure at Nuclear Power Stations will be ALARA, and
Regulatory Guide 8.10~ Operating Philosophy for Maintaining
Occupational Radiation Exposures ALARA .
. An ALARA job briefing had been conducted with the licensee employees
working on the eves valve the previous day.
The inspector reviewed
the ALARA prejob briefing documentation and ALARA job requirements
for the valve work.
The inspector determined through interviews with
the mechanical maintenance workers, assigned to the task, that the
mechanical maintenance section had also discussed job requirements
again that morning to ensure all of the needed tools and equipment
were in hand prior to entry into containment.
10 CFR 20.103(a) established the limits for exposure of individuals
to concentrations of radioactive materials in air in restricted
areas.
This section also requires that suitable measurements of
concentrations of radioactive materials in air be performed to detect
and evaluate the airborne radioactivity in restricted areas and that
appropriate biossays be performed to detect and assess individual
intakes of radioactivity.
10 CFR 20.103(c)(2) requires that the licensee maintain and implement
a respiratory protection program that includes, as a minimum, written
procedures regarding supervision and training of personnel, issuance
records, and evaluation by a physician prior to initial use of
4
respirators, and at 1 east every 12 month thereafter, that the
individual user is physically able to use the respiratory protective
equipment.
10 CFR 20.20l(b) requires each licensee to make or cause to be made
such surveys as maybe necessary for the licensee to comply with the
regulations and are reasonable under the circumstances to evaluate
the extent of radiation hazards that my be present.
requires a 1 i censee to maintain records s 1 owing the results of
surveys required by 20.20l(b).
The inspector was not respirator qualified by the licensee and was
not allowed to wear a respirator or enter containment on 87-RWP-2161.
The inspector was able to observe all work from a distance on another
radiation work permit written for inspections inside containment.
The valve work area was approximately twenty foot away from the
inspector who was located directly under a containment ventilation
exhaust duct.
Radiation surveys and surveys of radioactivity in air
were made in the inspector's observation area.
The inspector
observed the 1 i censee maintenance employees wearing respirators
unbolt and lift the valve bonnet from the value seat, remove the
gasket, take seal measurements, and lower the valve bonnet rinto its
seat.
The task was efficiently completed in minutes.
The valve was
not put back together since the gasket was not to be replaced until
the 1 i censee had reviewed the sea 1 measurements made by the
maintenance workers later that day.
While the mechanical maintenance
personnel were working on the valve the health physics technician
monitored the workers activities.
The inspector observed the health
physics technician performing direct gamma and beta radiation surveys
of the valve internals and surrounding area, smearable contamination
surveys of the valve internals, and airborne radioactive material
surveys.
The inspector reviewed the results of surveys made by the
health physics technician covering the job and verified that the
survey records were properly completed.
The air sample results
showed the air activity to be well below the concentrations required
to calculate maximum permissible concentration hours (MPC-Hours).
The inspector reviewed licensee* procedure RPM-7,
Full Face
Respirators Issuance Wearing and Removal, dated June 1, 1978.
The
training records, respirator fit test data, and medical
qualifications for workers who had worked on 87-RWP-2161 were
reviewed by the inspector and verified that all required training and
medical evaluations had been completed and documented.
The inspector
toured all elevations of containment and made independent radiation
surveys of radiation and high radiation areas.
The inspector
observed the use of lead shielding in various locations and the use
of portable continuous air samplers.
During the tour the inspector
observed employees checking valve alignments and making preparations
to drain systems.
No violations or deviations were identified.
- ,:
5
c.
Control of Radioactive Material
Technical Specification 6.4.D requires that radiation control
procedures be followed.
Licensee Procedure HP 2.3, Contaminated Equipment and Component
Control, revision dated February 2, 1987 specifies the requirements
for moving and storing radioactive material and contaminated
equipment.
During tours of the fuel building, yard buildings, and auxiliary
building, the inspector observed stored radioactive material in
accordance with the requirements of HP 2.3.
While touring the
basement of the auxiliary building the inspector discovered a gang
box which was unlocked.
The inspector opened the box and found
several open yellow poly bags with a radiation symbol and the words
"Caution Radioactive Material" printed on the sides.
The area was
not posted as a radioactive materials area and the gang box was not
labeled.
The
inspector determined that Health Physics
representatives were unaware that contaminated material was being
stored in the gang box.
The inspector asked licensee representatives
to survey the gang box contents.
The bags contained leak rate test
equipment typically utilized by the operations section.
Survey
results showed several i terns in the gang box and the bags to be
contaminated with Cobalt-60, Cesium-137 and Cesium-134.
The highest
contaminated item was a small tool box inside the gang box ha~ing
7000 disintegrations per minute per 100 square centimeters
( dpm/lOOcm2).
The inspector determined that the contaminated
equipment in the gang box lacked sufficient quantity of radioactive
material to meet the posting requirements of 10 CFR 20.203(e).
However, Section D of licensee procedure HP 2.3 specifies the storage
requirements for contaminated material and requires the following:
0
0
0
Before storing any equipment or components which were present in
the Restricted Controlled Area, smears must be taken to
establish current levels.
Equipment exceeds 1 mR/hr at one inch or 2200 dpm/100cm2 must
- posted and/or wrapped and tagged
Health Physics must be notified of any storage to be made under
this part.
The inspector stated that failure to establish the contamination levels of
the equipment, to wrap and tag as required, and to notify the hea 1th
physics section of the equipment storage as required by Licensee
Procedure HP 2.3
was
an
apparent
violation
of
Technical
Specification 6.4.D (50-28ID/87-35-01 and 50-281/87-35-01) .
6
d.
Audits
The inspector discussed the audit and surveillance program related to
radiation
protection,
radioactive
waste
management,
and
transportation of radioactive material with licensee representatives.
The inspector reviewed the following audits and surveillances:
Audit-S 87-17, Process Control Program/Offsite Dose Calculation
Manual, May 27 - July 23, 1987
Audit-S 87-1~, Health Physics and Environmental Monitoring,
April 21 - July 13, 1987
Surveillance -
SAC 20A, Dose Control Record Respiratory
Protection, April, 1987
Surveillance - SAL 20B, Health Physics Contamination Monitoring
Station Required Posting of Radiation Areas and Housekeeping,
October, 1987
Surveillance - SAC 20C, Radiation Work Permits, June, 1987
10 CFR 20.103(b) requires that when it is impracticable to apply
process or engineering controls to limit concentrations of
radioactive material in air below 25 percent of the
concentrations specified in 10 CFR 20, Appendix B, Table 1,
Co 1 umn 1, other precautionary measures should be used to
maintain the intake of radioactive material by an individual
within seven consecutive days as far below 40 Maximum
- Permissible Concentration (MPC)-hours
as
is reasonably
achievable.
10 CFR 20.103(c)(2) provides that the licensee may make
allowance for the use of respiratory protective equipment in
estimating exposures of individuals to radioactive material in
air provided the licensee maintains and implements a respiratory
protection program that includes, as a minimum:
written
procedures regarding supervision and training of personnel and
issuance records; written procedures regarding selection,
fitting and maintenance of respirators; and determination by a
physician prior to initial use of respirators, and at least
every 12 months thereafter, that . the i ndivi dua 1 user is
physically able to use the respiratory protective equipment.
Audit S 87-19 reported that the auditor had selected 20 individuals from a
respirator issuance log to verify the qualifications for issuance were
being met.
Licensee procedures require respirator users to have a medical
evaluation, respirator fit test, respirator training, and a whole body
count within the previous 12 months.
The audit report stated that the
auditor was unable to find the records for several names selected from the
respirator issuance 1 og.
The item was presented in the report as a
7
concern and the names of the persons with missing records were listed.
The report recommended the licensee reevaluate the method used to verify
personnel status prior to issuing a respirator.
The inspector discussed
the audit concern with the Radiation Protection Manager.
The inspector
determined that the respirator qualification records had not been found as
of December 10, 1987, but that a thorough search had not been made for the
records.
The inspector stated that fa i 1 ure to have respirator
qualifications for persons issued respirators was an apparent violation of
10 CFR 20.1Q3(c)(2) and requested the records be located if possible. The
licensee was able to produce records for the individuals identified in the
audit report before the exit meeting and the inspector reported to
licensee management that the audit finding did not appear to be a
violation of 10 CFR 20.103(c)(2) requirements.
The inspector stated that
the licensee's failure to identify a potential violation of 10 CFR 20
requirements as an item deserving immediate attention and documented
corrective action could be a violation of the licensee's quality
assurance program.
However, the inspector did not have sufficient
inspection time to evaluate the licensee's corrective action program for
quality assurance findings. Therefore, this item is considered unresolved
pending review of the area by the inspector during a future inspection
{50-280/87-35-02 and 50-281/87-35-02).
No violations or deviations were identified.
e.
Control of High Radiation Areas
Technical Specification (TS) 6.4.B.l requires the entrance to each
high radiation area in which the intensity of radiation is greater
than 100 millirem per hour but less than 1000 millirem per hour be
barricaded and conspicuously posted and that the entrance to each
high radiation area in which the intensity of radiation is equal to
or greater than 1000 millirem per hour shall be provided with locked
barricades to prevent unauthorized entry into these areas.
During tours of containment, yard, and the auxiliary building, the
inspector performed independent radiation surveys with NRC and
licensee survey instruments, reviewed records of licensee radiation
surveys, observed area postings, surveyed the exposure rate at
various radiation boundaries, and checked the security of selected
The inspector determined that the areas
were being properly controlled.
No violations or deviations were identified.
f.
Portable Survey Instruments
While touring the licensee facilities the inspector examined portable
radiation survey instruments and air sampling equipment in use to
verify that each had a calibration sticker.
Each instrument examined
had a calibration sticker and no instruments were found in use with
expired calibration due dates.
The inspector recorded the serial
numbers of several instruments and later reviewed the calibration
8
data packages and ca 1 i bra ti on procedures for the instruments.
The
inspector reviewed the licensee's records tracing radiation sources
to National Bureau of Standards (NBS) and also verified mechanical
and test equipment (laminar flow elements, pressure gauges, etc.)
utilized to verify flow rates on air sampling equipment were
calibrated and tracable to NBS.
No violations or deviations were identified.
g.
Dosimetry
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and require the use of
such equipment.
During tours of the licensee's facility the
inspector observed workers wearing appropriate personnel monitoring
devices.
The inspector reviewed an individual's occupational exposure report
issued by the 1 i censee for the second quarter of 1987.
The
occupational exposure report had assigned an exposure of 0.007 rem to
the whole body, 0.125 rem to the skin, and 0.125 rem to the
extremity.
The dosimetry supervisor was aware of the unusual
exposure ratio.
The inspector determined that the licensee had not
been able to explain the unusual ratio of shallow to deep dose for
the individual and conservatively assigned the exposure reported from
the TLD readout.
The licensee response checked the specific TLD upon
the inspector's request and no abnormalities were found.
The
individual assigned the TLD had not worked in the radiation control
area during the period that the TLD response was reported.
The
inspector determined that the 1 i censee did not have criteria or
guidelines in procedures to require an investigation of unusual
- personnel monitoring results, for example, unusual beta to gamma
measurement .ratios.
Licensee representatives agreed to es tab 1 i sh
criteria and guidelines that would cause an abnormal exposure report
to be investigated and documented.
The inspector stated that a
review of the development of the criteria and guidelines utilized to
investigate and document abnormal occupational exposure reports would
be identified as an inspection followup item (50-280/87-35-03 and
50-281/87-35-03).
The licensee issued self reading dosimeters (SRD
1s) to persons
entering the radiation control area (RCA).
The SRD
1s were drift and
responsed tested prior to initial issue and at six months intervals
thereafter when in service in accordance with HP-3.1.4.2 Personnel
Dosimetry -
SRO Testing and Preparation dated October 9, 1986.
Through interviews with 1 i censee representatives the inspector
determined that the licensee conducts an undocumented leak test on
SRD's that have been dropped, found, or turned in off-scale.
Licensee representatives agreed to revise SRU procedures to segrate
dropped, found, or off-scale SRD's and process those SRD's through
the documented 1 eak rate and response test as described in *
- ,,
9
HP-3.1.4.2.
The inspector stated that the procedures to test
off-scale, dropped, and found SRD's would be reviewed in a future
inspection as an inspector fo 11 owup item ( 50-280/87-35-04 and
50-281/87-35-04).
No violations or deviations were identified.
h.
Procedures
As part of the corrective action for violation 87-35-01 the licensee
committed to revise procedure HP-5-2B-50 Whole Body Counter OperatiQn
- Chair/ND680, revision dated March 4, 1986, to address verification
of quality control checks for the whole body counter (WBC).
The
'inspector determined that the procedure manua 1 utilized by the
operators of the WBC equipment still contained , revision dated March
4, 1986.
Licensee representatives had the newly revised HP-5-2B-50
procedure, revision dated October 14, 1987 in a reading file for
emp 1 oyee review.
The inspector verified that a majority of those
persons assigned to the dosimetry section had reviewed the new
procedure.
The inspector determined that the procedures in the whole
body count/dosimetry laboratory were not controlled procedures issued
by the document control section and that the health physics section
had two controlled manuals of health physics procedures.
The
licensee health physicist was copying the controlled procedures and
forwarding them to the various hea 1th physics groups.
Licensee
representatives agreed that the working copies of health physics
procedures should be current and agreed to have the health physics
procedures controlled by a formal receipt/acknowledgement program to
ensure copies of procedures were current.
The inspector stated that
the licensee's controls of health physics procedures would be
reviewed in a future inspection as an inspector followup item
(50-280/87-35-05 and 50-281/87-35-05).
No violations or deviations were identified.
5.
Solid Waste (84722)
10 CFR 20.203 (e) requires that each area or room in which licensed
materi a 1 is used or stored in excess of 10 times the quantity of the
material listed in Appendix C be posted as a radioactive materials area.
During tours of the low level radwaste storage facility, the waste
compactor area, and various waste storage areas, the inspector verified
that radioactive materials storage areas were properly posted.
10 CFR 20.311 requires a licensee who transfers radioactive waste to a
land disposal facility to prepare all waste so that the waste is
classified in accordance with 10 CFR 61.55 and meets the waste
characteristic requiremerits of 10 CFR 61.56 .
The inspector determined that the licensee had made 38 radioactive waste
shipments in 1977.
Nineteen shipments had been made to Barnwell, South
....
10
Carolina and 19 to a vendor for super compaction.
The inspector reviewed
radioactive waste classification documentation for selected radioactive
waste shipments made in 1987 and determined that the waste had been
properly classified and met the waste characteristics requirements of 10 -
CFR 61.
.
.
No violations or deviations were identified.
6.
Transportation (86721)
10 CFR 71. 5 requires that licensees who transport licensed material
outside the confines of its plant or other place of use; or who deliver
licensed material to a carrier for transport, shall comply with the
applicable requirements of the regulations appropriate to the mode of
transport of the Department of Transportation in 49 CFR 170 through 189.
The inspector reviewed selected records of radioactive waste and
radioactive material shipments performed during 1987.
The shipping
manifests examined were prepared consistent with 49 CFR requirements.
The
radiation and contamination survey results were within the limits
specified for the mode of transport and shipment classification.
The
inspector selectively performed independent calculations using licensee's
records of material radioactive nuclide composition and verified that the
shipments reviewed had been properly classified.
No violations or deviations were identified.
7.
Allegation Followup (99014)
Allegation (RII-87-A-0102)
A contract employee working at Surry may not have received the correct
external occupational exposure record.
The employee stated that during
the exit whole body count, the health physics technician operating the
equipment became alarmed with the levels of internal contamination being
measured.
The employee stated the health physics technician asked him
where he had been working to have received such a large dose of internal
contamination.
Discussion
The inspector reviewed the licensee's written response to this allegation
to Region II, dated November 23, 1987.
The licensee did not substantiate
any of the concerns.
The inspector reviewed the licensee's investigation
package which included TLD monitoring results, *whole body counts, quality
control checks of whole body counting equipment, surveys, respirator
issuance log, and radiation work permits.
The inspector determined that
the alleger
1s whole body count results showed a measured intake of 1.41%
Maximum Permissible Organ Burden (MPOB) of cobalt-60.
The licensee's
action level is 5% MPOB.
Licensee records showed the calculated exposure
to be 11.5 MPC-Hours.
10 CFR 20.103(a)(l) states that no licensee shall
L
11
possess, use, or transfer licensed material in such a manner as to permit
any i ndi vi dua 1 in a restricted area to i nha 1 e a quantity of radioactive
material in a period of one calendar greater than the quantity which would
result from i nha 1 ati on 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 a uni form
concentration of radioactive material in air specified in Appendix B,
Tab 1 e I, Co 1 umn I ( 520 MPC-Hours).
The inspector determined that the
licensee had only measured one intake of radioactive material above the 5%
MPOB administrative limit in 1987 and that positive measurements of
intakes of radioactive material were not routinely observed by whole body
count operators.
The positive measurements of the alleger
1 s whole body
count may have prompted the whole body counters comments.
The inspector
determined that the licensee
1s measurements were adequate and the results
well below regulatory limits.
The licensee employee who had made the
alleged comments concerning the allegers whole body count results was no
1 anger emp 1 oyed by the 1 i censee and cou 1 d not be interviewed.
The
alleger
1s external exposure report showed 177 mrem exposure to deep tissue
and 18 mrem to the skin.
The inspector determined that the licensee had
adequately accounted for the alleger*s internal and external exposures.
The inspector determined that the licensee
1s investigation of the concerns
had been adequate and that the findings reported to Region II were
accurate.
Finding
The allegation was not substantiated.
No violations or deviations were identified.
8.
NRC Information Notices (IN) (92717).
The inspector determined that the licensee had received IN 87-31
11 81 ocki ng, Bracing, and Securing Of Radioactive Materials Packages In
Transportation,
11 and had distributed the notice to appropriate personnel
for review.
The inspector determined that the licensee had received IN 87-07
11Quality
Control Of Onsite Dewatering/Solidification Operations By Outside
Contractors
11
The licensee had distributed the notice to the Health
Physics and Operations Section for review of applicability. The inspector
determined that the licensee
1 s quality assurance/quality control group had
also received a copy of the document but had not been requested to provide
comments to the licensee's section responsible for coordinating station
evaluations of IE Information Notices.
Licensee representatives agreed to
have the quality assurance organizations comment on the notice
applicability and provide guidance for any actions to be taken to preclude
any similar problems identified in the notice.