ML20236R846

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Insp Repts 50-348/87-28 & 50-364/87-28 on 871019-23. Violations Noted.Major Areas Inspected:Radiation Protection Activities,Including External & Internal Exposure Control, Surveys,Solid Radwaste & Followup on IE Info Notices
ML20236R846
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 11/16/1987
From: Collins T, Hosey C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236R829 List:
References
50-348-87-28, 50-364-87-28, IEIN-87-031, IEIN-87-037, IEIN-87-31, IEIN-87-37, NUDOCS 8711240060
Download: ML20236R846 (9)


See also: IR 05000348/1987028

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                                 . Report Nos.: 50-348/87-28 and 50-364/87-28
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                                     Licensee: Alabama' Power Company                                                                                                                                                                    *
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                                                                        600 North 18th Street
                                                                        Birmingham, AL '35291-0400                                                                                                                                       i
                                     Docket Nos.: 50-348 and 50-364                                                                                      License.Nos.:         NPF-2 and NPF-8'                                       ,3
                                      Facility Name: Farley
                                    ' Inspection Conducted: October 19-23, 1987.
                                      Inspector:p
                                                                       i T. R.LCollins.
                                                                                                                             k 6                                                  Date Signedc
                                                                       ,
                                     Accompanying Personnel:                                                                R. B. Shortridge:                                                                                          j
                                     Approved by: hC.- M. 4iosey, Secti@n Chief
                                                                                           fer                          9-   M                                                             87
                                                                                                                                                                                  Date Signed                                             ;
                                                                                             Division of Radiation Safety and Safeguards
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                                                                                                                                       i SUMMARY
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                                      Scope:                         This routine, unannounced insp$ction invbl_ved onsite: inspection' of                                                                                                 l
                                      radiation protection activities 'in- the areas ofi external exposure 1 control,'. .                                                                                                                  ,
                                      internal exposure control, sur_veys, ' monitoring and control; off radioactive                                                                                                                       i
                                     material, solid radioactive waste, transportation:of radioactive. materials,'and                                                                                                                      ;
                                      followup on IE Information Notices.                                                                                   ,             .
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                                                                                                                                                                      f          i,a.                                                 .l
                                      Results: One violation - failure of 'a licensee em
                                      clothing required by a radiation work' permit (RWP)ployeelto wear'.the protective                                         ..
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                                                      8711240060 071117
                                                      PDR                ADOCK 05000348                                                                                                                                                    ,
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                                                                                  REPORT DETAILS ~
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          1.       Persons Contrcted                                                                                                                                j
                   Licensee Employees                                                                                                        '
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              *J. D. Woodard, General Manager                                             .                                                                         d
              *C. A. Nesbitt, Technical Superintendent
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             *M. W.'Mitchell, Health Physics and Radwaste Supervisor                                                                                                 'j
              *D. N. Morey, Assistant General Manager Operations
              *B. P. Patton, Plant Health Physicist
                   P. E. Farnsworth, Radwaste Supervisor                                                                                                                 j
                   K. Gibson, Health Physics. Foreman                                                                                                               .. J
                   D. Griffin, Health Physics Foreman.
                   G. Neher, Health Physics Foreman-                                                                                                                ~D
             *J. M. Walden, Quality Assurance Specialist
                                                                                                .
              *J. K. Osterholtz, Supervisor, Safety Audit and Engineering Review                                                                                          i
              *L. W. Enfinger, Manager, Plant Administration
                   D. Grubbs, Health Physics Technician
                   Other licensee employees contacted included technicians.o mechanics,                                                                                   j
                   security force members, and office personnel.
                   Nuclear Regulatory Commission

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             *W.                   H. Bradford, Senior Resident Inspector
             * Attended exit interview
          2.       Exit Interview
                  The inspection scope and findings were. summarize'd on .0ctober '23,1987,                                                                           j
                  with those persons indicated in Paragraph 1 above.- .The inspector
                  discussed with licensee management the areas that were inspected during.
                   this inspection and in detail. an apparent violation 'for failure- of an:
                   individual to wear the protective clothing required by an RWP                                                                        '
                                                                                                                                                                     .I
                   (Paragraph 4). Licensee managemt.nt' acknowledged the' inspection findings                                                                               !
                   and took no exceptions. The licensee:did not identify as' proprietary any
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                   of the materials provided to' or reviewed by the inspector during this                                                                            H
                   inspection.
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          3.      Licensee Action on Previuus Enforcement Matters
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                  This subject was not addressed in the inspection.-
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          4.      External'ExposureControl-(83724)
                  a.                          During tours of the containment and auxiliary buildings the inspector.
                                              reviewed the licensee's posting and control of ~ radiation. areas, high.
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                                                     radiation areas, airborne radioactivity areas,1 contaminated areas,
                                                     radioactive. material areas and the labeling of. radioactive materials.   -
                                                     On Unit 2' lower level containment the inspector observed. the
                                                     licensee's method of exposure control for steam generator jumpers'.
                                                     To control exposure during shot peening of the steam generator. tubes
                                                     in the tube sheet area, health physics maintains a computerized-            .
                                                     exclusion area ~ access authorization (EAAA) for each jumper. .The.
                                                     information contained on the EAAA includes all pertinent a steam-
                                                     generator duse rates, the individual's exposure to date a'nd available
                                                     quarterly exposure. From this information stay time is' calculated
                                                     and positive controls such as time.in and.out.of the' exclusion' area
                                                     are maintained to prevent unnecessary radiation exposure tto ' each -
                                                     individual worker. This method of exposure control is implemented -
                                                     for each person required to enter an exclusion area.
                                                     During a tour of the auxiliary building,. elevation 155', a~ security.
                                                     guard was observed not wearing all of the: protective- clothing
                                                     required by the . radiation work permit for. the area. - The guard
                                                     entered the controlled area of the spent fuel pool'on RWP 0-87-0001A
                                                     which required as a minimum that the individual wear.as protective
                                                     clothing; a surgeons cap, labcoat .or coveralls, cotton gloves and
                                                     shoe covers. During questioning-by a health l physics supervisor. the

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                                                     guard who was dressed in a paper . suit without: cotton. gloves or
                                                     surgeons cap, stated that he received a. call byiradio to go to the
                                                     spent fuel pool entrance. He also. stated that he thought he'was
                                                     responding to a security door alarm and did notL don the requ' ired
                                                     protective anti-contamination clothing as specified by the? RWP.
                                                     Later investigation by the inspector revealed that the guard, after .

l arriving at the spent fuel pool entrance, determined that he.was not~ l not actually responding to a security door alarm- but was' required to:

be present while the security door was open to allow ~ work crews to

I remove tools and components from the work area. During this period

                                                     of time the guard stated that he handled a potentially contaminated
                                                     telephone and door with unprotected hands.

l Technical Specification 6.8.1 requires that written procedures be

                                                     established, implemented, and -maintained covering : applicable

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                                                     procedures recommended in Appendix A of Regulatory Guide 1.33,
                                                     Revision 2, 1978. Regulatory Guide, Append h A states that licensees
                                                     should have procedures for control of radioactivity ' including a
                                                     Radiation Work Permit Procedure.     Farley's Health Physics Manual,
                                                     Parcgraph 4.1.1.7 requires an individual to know and follow the
                                                     requirements of the Radiation Work Permit under which the work is
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i being performed.

                                                     Failure of an individual to wear the protective clothing required by          ]
                                                     a RWP was identified as 'an apparent violation of Technical
                                                     Specification 6.8.1 (50-348/364/87-28-01).

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             b.  On October 21, 1987, the licensee initiated Radiation Work Permit
                 No. 2-87-0363 to perform associated work in the Unit 2 reactor vessel
                  (RV) to retrieve a thermal sleeve which became loose inside of the RV
                 during reactor operation. The inspector discussed this planned event
                 with licensee representatives to ensure that adequate prejob
                 planning, ALARA considerations, and controls were in place to perform
                 this task safely and keep radiation exposures ALARA. The inspector
                 was informed that a prejob briefing was held with all personnel

i involved, in which a review of the basic job and expected dose rates

                 were discussed. The licensee only used a minimum work crew to
                 perform this task.
                 The inspector reviewed the RWP, prejob briefing, and controls
                 established for this task and concluded that adequate precautions
                 were taken.
                 No violations or deviations were identified.

{ c. The inspector reviewed the licensee's methods for the detection and

                 control of high specific activity radioactive particles (hot
                 particles). Based on this review, the inspector concluded that,the
                 licensee's successful hot particle control program is due to
                 addressing the cause of hot particles and not the symptoms.
                 Contamination containments and monitoring are the primary means of
                 hot particle control.     Health physics technicians receive specific
                 training in the detection of hot particles on both equipment and

l personnel. Techniques for contamination containment and detection

                  include the use of different types of containment, ventilation, the
                 use of sticky pads, and instruction in the types of instruments best

i suited for detection. Also instruction is given in identification l and retention of the particle-when detected. l The inspector reviewed the licensee's administrative control

                 procedures FNP-0-RCP-0, General Instructions to Health Physics
                 Personnel, and FNP-0-RCP-190, Skin Dose Assessment Due to
                 Contamination on Personnel Skin or Clothing, that addresses hot
                 particle detection and control and method of calculation of skin dose
                 in event of a hot particle exposure. These procedures appeared to be   ,
                 adequate in the instructions and controls provided and the
                 methodology used to calculate skin exposures due.to hot particles.

l No violations or deviations were identified. l 5. Surveys, Monitoring, and Lontrol cf Radioactive Material . (83726)

             3.  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 radiation hazards that may be present.
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                                               4
                During a tour of Unit 2 containment the inspectors observed that
                eleven breathing air manifold pressure gauges were beyond the
                calibration date listed on the calibration tag.          Further
                investigation revealed that calibration of the breathing air manifold
                pressure gauges were incorporated into the plants preventative
                maintenance (PM) program.    The PM program requires calibration every
                18 months or during subsequent refueling outages with a plus or minus
                25% grace period. The eleven gauges were within 18 month calibration
                and PM program time requirements.

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                Based on a review of radiation surveys of Unit 2 steam generators the

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                inspector noted that radiation levels at the tube sheet area were

l low. The licensee has recently implemented different pH controls for -

                reactor coolant.     This adjustment in pH has been primarily
                responsible for a 50 percent reduction of source term in the steam
                generators (S/G). For example, prior to pH adjustment general area
                dose rates in S/G-A averaged-13 R/hr, S/G-B 12.5 R/hr, and 10 R/hr.
                After pH adjustment, the correspondingly dose rates at the tube sheet
                were 6 R/hr, 6.8 R/hr, and 5.4 R/hr respectively. In addition, the
                shot peening of steam generator tubes in the area of the tube sheet
                is expected to further reduce the crud buildup, but this data is not
               yet available,
          b.    The inspector observed that contaminated areas of the plant were        ,
                being adequately controlled. Of 116,000 square feet (ft2) of area       '
                trended for contamination controls,13,500 fte or 11.66 percent of
                the area is controlled due to. surface contamination. Through
 i              September 1987, the station has had 26 skin and clothing

l contaminations greater than 1,000 dpm.

                Personnel are monitored by performing frisk at the nearest frisker
                after work in contaminated areas. They are also required to perform

i a hand and foot frisk using the monitors at the exit of the l

                Radiologically Controlled Area (RCA) in the auxiliary building. In
                addition, full body monitoring is required by utilizing 4, PCM-1-A
                friskers. To detect entry of radioactive material into the RCA a
                PM-6 portal monitor is used for personnel monitoring.
                No violations or deviations were identified.
       6. Internal Exposure Control and Assessment (83725)
          10 CFR 20.103(a) establishes the limits for expcsures 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 bioassays
          be performed to detect and assess individual intakes of radioactivity.-
          Whole body count records were reviewed for the outage that started on
          October 3, 1987.     To date 4 people have organ burdens ranging from 3 to 6
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         percent. Three of the workers are sill being tracked by whole body counts
         on this date.
        'On October 21, 1987, a worker was found to-have 10,000 dpm per probe ' area
         facial contamination and 1,000 dpm on a nasal smear. . The contamination
         event occurred when the individual was' taking an air sample from 2C steam
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         generator shot peening tent. . The licensee stopped all _ work in the area- of
         the airborne contamination until the radiological 1' conditions could be.
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l assessed and the cause of the airborne contamination . identified. The

         radiological evaluation of the event revealed that a: puff of: airborne              !
         radioactive material was released during the gathering of the air. sample-           j
         at a remote. location outside of 'the shot peening tent. Engineered                  ;
         controls, such as, ventilation was -in use,=. however, the 400 SCFM was not-           '
         sufficient to prevent the escape of radioactive materials.         Work' resumed
         after the work area was decontaminated and all shot-peening personnel were-
         instructed in corrective actions to be taken to' prevent recurrence.
         No violations or deviations were identified.
     7.  Transportation (86721)
         The licensee was required by 10 CFR 71.5 to . prepare shipments of
         radioactive materials in accordance with Department of Transportation              '3
         regulations. The inspector reviewed recent changes to shipping. procedures
         and records of shipments of radwaste for the months of September and                 'I
         October 1987. The inspector verified that the licensee' was a registered             l
         user of user packages used'during 1987.
         The inspector also reviewed a radioactive. material            sh'ipment,            .
         RMS No. 87-26, of contaminated equipment which 'was - being shipped to            .l
         Westinghouse Electric Corporation, Spartanburg, SC,: dated October 22,
         1987.    This equipment was shipped to the licensee as non-radioactive            ]2
         material by Westinghouse Electric Corporation on October 15,-1987.- Upon          -!
         arrival of the shipment, the equipment'was . stored .in the Turbine Building           ;
         to be used on a non-radioactive system. Westinghouse personnel assigned                l
         the responsibility to perform work with this equipment completed; their                 i
         assigned task without the use of this equipment. Af ter completion                t
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         Westinghouse personnel decided to return this equipment.to their warehouse        .I
         in Jonesboro, GA. Upon request by Westinghouse to release this equipment,            j
         the licensee performed radiological survey's of this. equipment. and, found'
         that the' tools inside the shipping container were : contaminated to a               j
         maximum of 2,000 dpm/100 cm2 removable and 10,000 cpm /100 cm2 fixed. - The .          <
         licensee took control of ' this . equipment, labeled it as radioactive               i
         material and moved.the equipment inside the. Radiological Controlled > Area            !

l (RCA). Additional. surveys' performed by the . licensee; of the area where . l these tools W re stored detected no further contamination. The inspectors  ;

         verified that the facility. in Spartanburg,'SC was licensed to receive
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         radioactive. byproduct material (South Carolina License No.' 317)'.: -This'

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         material was shipped as Radioactive Material, Limited Quantity, N.0.S.,              j
         UN 2910.     The inspector independently verified -'that _this radioactive .         ;
         material shipment met the conditions and limitations specified 'in.49 CFR              '
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                 173.421 for Excepted Radioactive Material, Limited Quantity, ILO.S., UN
                 2910.
                 NRC Region II notified the State of Georgia Department of Health and Human
                 Services (DHHS) of the potential radioactive contaminated equipment stored
                 in the Jonesboro, GA warehouse.                   Upon notification DHHS personnel                           l
                 performed radiation and contamination surveys of the Jonesboro, GA
                 warehouse and no radioactivity above natural background levels .was
                 detected.
                 The inspector reviewed the results of contamination surveys, conducted on
                 similar vendor equipment. During these surveys a group of tools were

l discovered to be contaminated that was located in the antivibration bar

                 (AVB) trailer.                The tools had fixed' contamination levels from 3,000 to
                 35,000 dpm/100 cm2                   The tools were confiscated and placed in a
                 radioactive materials area inside the RCA and a- Radiological Incident -
                 Report was issued as required by procedure. Further surveys by the
                 inspectors and a licensee health physics technician revealed that. packing
                 material reading 5,000 dpm/100 cm2 was stored in a trailer adjacent to the
                 AVB trailer.                The health physics technician confiscated the packing
                 material and placed the material in a radioactive material storage area                                      f
                 inside the RCA.
                 No violations or deviations were identified.
             8.  Solid Waste (84722)
                 10 CFR 20.311 requires a licensee who transfers radioactive waste to a                                       !

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                 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 requirements of 10 CFR 61.56.                       It further establishes                    4
                 specific requirements for conducting a quality control program and for
                 maintaining a manifest tracking system for all shipments.
                 The inspector reviewed the following plant procedures for the packaging,

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                 classifying, and tracking of radioactive waste shipped to low-level waste
                 burial facilities                                                                                             ,
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                                  RCP-801, Disposal Demineralized Systems Operation (Hittman)                                  !
                                  RCP-805, Utilization of High Integrity Containers for Storage of
                                   Filter Media
                                  RCP-809, Isotopic Characterization of Radioactive Materials for
                                 Offsite Shipments and/or Burial
                                  RCP-810, Shipment of Radioactive Waste to Barnwell Burial Site
                                  RCP-811, Shipment of Radioactive Material
                                  RCP-812, Radwaste Management
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                 RCP-318, Prior Notification and Scheduling of. Radioactive
                Material / Waste. Shipments
                 RCP-819, Waste Classification for Near-surface' Disposal.                        I
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                 RCP-820, Scaling Factor _ Utilization for Waste Classific'ation-
           The inspector reviewed the methods used - by. th'e' licensee to ' assure' that -   q
           waste was properly classified,- met . the waste form' and characteristic
           requirements.
           The inspector- reviewed selected _ manifests prepared! for waste shipments
           made during the period of September and October 1987 to'. verify that a
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           tracking system was being used to. insure. that shipments arrived at the                 .
           intended destinatio'n.without undue. delay.                                        :]
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           The inspector discussed with a licensee representative the- total . solid-
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           radwaste shipped for burial during the year 1986' and 1987. Total' volume-
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           shipped for 1986 was 8,644 ft3 containing 1,798 curies. of- activity as-           :{
           compared to 13,646 fta containing 330 curies of activity ~ shipped-in 1987.            l
           The reason for the increase of radwaste volume shipped :for burialfduring              '
           1987 was that the licensee shipped additional onsite inventory of solid
           waste in storage, primarily dry active waste (DAW). The licensee'.s= goal
           for 1987 for waste shipped-for burial has been set at 17,000 ft8
           No violations or deviations were identified.
        9. Maintaining Occupational Exposures'ALARA (83728)_
           10 CFR 20.1(c) specified that licensees should implement programs to keep-
           workers' -doses as low as reasonably achievable:(ALARA). The recommended
           elements of an ALARA program were contained in Regulatory Guide 8.8,

L Information Relevant to Ensuring that Occupational Exposure at' Nuclear 1 l Power Stations will be ALARA, and Regulatory Guide 8.10, l Operating

           Philosophy for Maintaining Occupational Exposures ALARA.
           The inspector discussed the goals- and objectives for 1987: and reviewed
           man-rem expended during the present refueling outage. The collective
           personnel exposure for 1987 is projected to be 533 person-remt 'At present
           the plant it involved in' Environmental; Qu.tlification Verification ~in .
           Unit 1, which is operating, shot peening of steam generator tubes, pulse
           cleaning, Snservice inspection, eddy current testing, sleeving / plugging SG .           ,
           tubes and sludge lancing of the Unit ~2.SGs.     The station has expended'146      ')
           of the 312 projected person-rem or 46 percent of their outage goal.. With           ~~

l approximately. 50 percent of their outage goal expended 'in .20. percent of

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l the scheduled time, the ALARA. group is assessing additional meansJof dose y

           reduction. The major contributors ~ to' the accumulated collective. exposure-;     y

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           to date has been the environmental. qualification workiin Unit I and the
           unplanned retrieval of a detached thermal sleeve in Unit 2, that resulted          J
           in removal of the core's lower internals. The ' accumulated collectives                 !
           exposure to date for the year is:at 312.5 ' person-rem. As . previously <
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            stated in Paragraph 5, the dose rates in the steam generators have been
            reduced by approximately 50 percent over the past year as a result of.
            adjusting reactor coolant pH rnage from 6.2-6.5 to 6.6-6.9.
            No violations or deviations were identified.
        10. IE Information Notice (IEN) (92717)
            The inspector determined that the following information notices had been

i received by the licensee, reviewed for applicability, distributed to i appropriate personnel and that action, as appropriate, was taken or l scheduled.

                  IEN 87-31, Blocking, Bracing, and Securing of Radioactive Materials ,
                  Packages in Transportation
                  IEN 87-37, Control of Hot Particle Contamination at Nuclear Power

i Plants l l 1 I { l

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