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{{Adams
{{Adams
| number = ML20137W163
| number = ML20202F684
| issue date = 02/04/1986
| issue date = 04/10/1986
| title = Insp Rept 50-293/86-04 on 860102 by State of Sc of Shipment of Radwaste from Facility.Violation Noted:Failure to Meet Packaging Requirements for Low Activity Radioactive Matls. State of Sc Radioactive Shipment Insp Rept Encl
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/86-04.Subj Actions Examined During 860324-27 Insp & Acceptable.Addl Info Will Be Contained in Insp Rept 50-293/86-10
| author name = Miller M, Pasciak W
| author name = Martin T
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Harrington W
| addressee affiliation =  
| addressee affiliation = BOSTON EDISON CO.
| docket = 05000293
| docket = 05000293
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-293-86-04, 50-293-86-4, NUDOCS 8602200073
| document report number = NUDOCS 8604140207
| package number = ML20137W143
| title reference date = 03-11-1986
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 3
| page count = 2
}}
}}


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=Text=
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APR 101986
,
Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199 L Gentlemen:
Subject: Inspection No. 50-293/86-04 This refers to your letter dated March 11, 1986, in response to our letter dated February 12, 1986.
 
Thank you for informing us of the corrective and preventive actions documented-in your letter. These ' actions were examined during an inspection conducted March 24-27, 1986 and are considered . acceptable to prevent a reoccurence.
 
Further documentation will be contained in NRC Inspection Report 50-293/86-10.
 
.Your cooperation with us is appreciated.
 
l
 
Sincerely, OFilihiSIEmoB7I
'
hom s , t.
 
vision of Radiation SafMy
      [
and Safeguards-cc:
A. V. Morisi, Manager, Nuclear Management Services Department C. J.'Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director Senator Edward P. Kirby Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
, CommonwealthofMassachusetts(2)
l OFFICIAL RECORD COPY t8604140207 860410 'T    i
!
PDR ADOCK OS000293:-'      ,,
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Boston EdisonL Company M/C Nuclear 2 bcc:
' Region I-Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section' Chief, DRP
  '
W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR
  ,
  !
b ; RSS RI Miller /mm a's iak Bellamy 4/7/86 4/rl/86 4/lO/86 i
0FFICIAL RECORD COPY RL PILGRIM 86-04 - 0002.0.0 04/04/86 t
 
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BOSTON EpisON COMPANY 800 BOYLSTON STREET BOSTON. MASSACHUSETTS 02199 l
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wituAu o. wAnniwa' "
U.S. NUCLEAR REGULATORY COMMISSION
co........ ....... ,    March 11,1986 n . 6.. .
BECo Ltr. #86-030 l
Dr. Thomas I Regional Administrator - Region 1 .
U. S. Nuclear Regulatory Commission 631 Park Avenue      l King of Prussia, PA 19406    i Subject: Response to Notice of Violation as Contained in NRC Letter to Boston Edison dated 2/12/86 (Inspection Report No. 86-04)
References: (A) Letter dated 1/07/86 from South Carolina Department of Health and Environmental Control, Containing Civil Penalty and (2) Items of l Non-Compliance    ;
  (B) Letter dated 1/28/86 f rom Boston Edison Company to South Carolina ;
Department of Health and Environmental Control, Responding to i Items of Non-Compliance and Civil Penalty
 
==Dear Dr. Murley:==
This letter is in response to the Notice of Violation as contained in Reference (A). As mentioned in our response to the South Carolina Department of Health and Environmental Control [ Reference (B)], we would like to assure you that Boston Edison Company has taken adequate corrective measures to ensure future compliance with the applicable provisions of federal and state laws as they apply to low-level radioactive waste shipments.
 
I trust that the attached response will adequately exhibit our serious commitment to continuing compliance in this area.
 
Please be advised that, upon review of this matter, Boston Edison has decided that further programmatic review and improvements are both necessary and desirable. The improvements are intended to impose enhanced quality requirements on radioactive waste processing, handling and shipping operations. Our approach will consist of a detailed review of 10 CFR 71 Subpart H and a more thorough integration of appropriate requirements into our existing Quality Assurance Program per 10 CFR 50 Appendix B. We expect to have a more detailed plan and schedule in approximately thirty days at which time a copy will be forwarded to the Senior Resident Inspector at Pilgrim Station.
 
Should you have further questions concerning these matters, please do not hesitate to contact me.


==REGION I==
Respectfully submitted, William D. Harring on Attachment
Report N /86-04 Docket N License N DPR-35  Priority --
  .d U ML,
Category  C
  -
!  Licensee: Boston Edison Company 800 Boylston Streets Boston, Massachusetts 02199 Facility Name:  Pilgrim Nuclear Power Station Inspection At: Barnwell, South Carolina
  :35 ]9q.
;  Inspection Conducted: January 2, 1986
'
r a ed by:  [ .&lhf/L%
M. M1Tler M adiation Specialist Y'lffG
          ' date Approved by:  )D- McAe      d4 W. Pasciak, Chief, Effluents    ' date Radiation Protection Section
. Inspection Summary:
!  Inspection on January 2, 1986 by a Representative of the State of South Carolina Department of Health and Environmental Control Areas Inspected:  Boston Edison Company was the originator of a waste shipment
; which was inspected at the Chem-Nuclear Systems, Inc., burial site in Barnwell,
'
South Carolin .
Results: One violation was identified (failuro to meet packaging requirements for low specific activity radioactive materials).


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8602200073 860212 PDR ADOCK 05000293 G    PDR l
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ATTACHMENT
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Violation As the result of the inspection conducted on January 2, 1986, by a representative of the South Carolina Department of Health and Environmental Control of a shipment of radioactive waste sent from your facility in Plymouth, Massachusetts on December 30, 1985, and in accordance with the NRC Enforcement Policy (10 CFR 2 Appendix C), the following violation was identified:
10 CFR 71.5, " Transportation of licensed material," states "each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers 1 censed material to a carrier for transport, shall comply with the at:licable requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 189."
1. 49 CFR 173.425(b) (1) " Transport requirements for low specific activity (LSA) radioactive materials" states that materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation."
Contrary to the above, on December 30, 1985, a waste shipment ,
of solid metallic oxides on noncompacted trash, containing 0.195 Curies in a Seatrain container was delivered to a carrier for transport to a burial site in South Carolina, and upon inspection of the container at the burial site on January 2, 1986, by a representative of the State of South Carolina Department of Health and Environment Control, it was determined that there were "three (3) small holes on the lef t rear side which allowed some of the contents to be visible."
2. 49 CFR 173.475(b) " Quality Control requirements prior to each shipment of radioactive materials" state, "the shipper shall ensure by examination or appropriate tests that the packaging is in unimpaired physical damage condition, except for superficial marks."
Contrary to the above, on December 30, 1985, a waste shipment of solid metallic oxides on noncompacted trash, containing 0.195 Curies in a Seatrain container was delivered to a carrier for transport to a burial site in South Carolina, without ensuring prior to shipment that the packaging was in unimpaired physical condition. The container was inspected at the burial site on January 2, 1986, and at that time a representative of the State of South Carolina Department of Health and Environmental Control determined that the Seatrain container was corroded and damaged.
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ResDonse
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DETAILS On December 30, 1985, the Boston Edison Company dispatched a shipment of LSA radioactive waste (solid metallic oxides on noncompacted trash) to the Chem-Nuclear Systems, Inc. burial site at Barnwell, South Carolina. The shipment was made in a Seatrain container, containing 0.195 Curies of licensed materia On January 2, 1986, a representative of the South Carolina Department of Health and Environmental control inspected the shipment at the burial sit The inspection consisted of a review of shipping papers, placarding,
Boston Edison agrees with both items. Although the subject container was duly inspected and signed off prior to shipment by experienced personnel in accordance with existing Pilgria Station Procedure 6.9.194 (" Loading Transport Vehicle for Radioactive Material and Waste Shipment"), it nevertheless appeared the metal of the cargo container was delaminating due to corrosion, and during transit, the lamination broke loose, leaving the small holes exposed.
, marking and labeling, iadiation measurements, selective contamination surveys and examination of the packages and the tractor-traile A copy of the report prepared by the representative is attached., The report states that upon inspection of the Seatrain container, the con-tainer had three small holes on the lef t rear side which allowed some of the contents to be visible, and the container was very corrode CFR 71.5, " Transportation of licensed material," states that "each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a car-rier for transport, shall comply with the applicable requirements of the regulations appropriate to 49 CFR 173.425(b)(1), " Transport requirements for low specific activity (LSA) radioattive materials." 49 CFR 173.425 (b)(1) states " materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation."


49 CFR 173.475(b) " Quality control requirements prior to each shipment of radioactive materials" states "the shipper shall ensure by examination or appropriate tests that the packaging is in unimpaired physical condition, except for superficial marks." The failure to assure that the Seatrain container was a strong tight package and that the container was in an unimpaired physical condition, except for superficial marks, prior to shipment to the burial site represents a violation of 10 CFR 7 (50-293/86-04-01).
Corrective action taken to correct the condition and to preclude recurrence is that Procedure 6.9.194 (" Loading Transport Vehicle for Radioactive Material and Waste Shipments") has been revised and strengthened to include a checklist requiring receipt inspections be performed on Seatrain cargo containers. The procedure has also been improved to include further checklists assuring that the subject shipping container will be inspected for evidence of corrosion and/or damage prior to shipment. Any indication of corrosion and/or damage will be rectified prior to shipment.


The Pilgrim Nuclear Power Station Assistant Chief Radiological Engineer-Radwaste was informed of this apparent item of noncompliance with NRC requirements in a telephone conversation with P. Clemons of the Region I office on January 14, 198 . . - - - - -
As further corrective action to preclude recurrence, the Training Department will re-emphasize (to individuals involved in the shipping process) the importance of compliance with pertinent regulations and requirements. The subject violation will be used as a specific example in training, as will the procedural improvements which have been made.
  . - - - - - ._ .. - . . . - _ _ _ p m ;;p i        ~
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c5 : ' SOUTM CAE0 TIE & MFARTMEur OF MEALTR AND INVIRO10(ENTAL CONTn0L  ' .',, Q'i Burea3 of Radiclogical 5:alth
.. c  Division of Radioactive Material Licensing and Compliance
          ,_
          ,;
  ,  andiaastive shipment inspection Report  *
a
' General Zafeenstism    Report Es. 85-1247
          '
s
'd Shipper Boston Ediaan Campany-Filgrant Station  Address Plymouth. Massachesat b Carrier. rurai _  Tractor F 37 Trailer # on Type _v.. u  i <
. .
Type Packagaf**** Saatrafn  Cask Containing Wid n er.#. m.,rs.,  - '.o
          .
,      .
" shipping h ation:      '
          ~
, A$f 42137  Volume Allocation i 12st.2&s-A
.i shipping Rama & Class: Radioactiva Materia 1. taA. n Permitf_nantsa_abr Total turial Vol.: 2560    1D( Id.# msels t
        (L72.202(a ft 3(172.202(c) Total Curies o_tes  (172.203 Radionuclides: Co-38660. ca-1374 B-3. Mn-54. Cm-13&. Pu 241. c-14 Describe chem./ phy. media n solid ameni tie nwid . on onnea-... .,e ev..h  (172.203(d- Cholating Agente(%) Nana shippers Cartification: S tataw
        ~
        (172.903(d DOAs (171.204)
Exclusive Use N Instructions N (173.425(b)) Total mA Check fort Radiation Survey N (173.441)    (177.842(a) Compara Contamination Levels y  (1 73.443)
Radionuclides v/ resin analysis NA Rad / Contamination Levels v/CNSI/BRH N
__ shipsest inspection Check List 3 Shipment Braced / Blocked (173.425(b)(6)
v 1 Lids (Drum, ox cask) accure (173.425)(b w isible Leakage (173.425(B)(1)  _g_, Visible DamagT(173.423)
g Package Labelinas_W-I,__Y-II. III(172.403)  E Cask Defects / Missing Parts (b) & (c) otQadio_ active LSp (.173.425) y Radiation Survey Cab /sieepe s Waste Class. MarkedLAJB-t; sta ol  trailer / truck (173.441)
s Gross Weight Marked (172.310)
  (LSA Exclusive Use Exempt)  N Contamination Levels (173.443)
NA Type A/ Type 5 Package Marked (172.310)  g Vehicle Placards (173.425(c) (172.507)
g Tiedowns Secure /Adequata
%~ Trailer / Tractor Defects  t Offloading Discrepancies h" Packages banded / reinforced. palletired Radiation / Contamination Surveys (transport vehicle or package)
  (mR/hr)  Surfsce .0  2 meters:
    ~
Surface:  Cab / sleeper Surfaces
__
R
.. 2 meters:  -
2 meters
!
I  Surface: 30,0 Highest contamination detected: Arrival 0- nich, 2 meters: ___ dpm/100 cad Release  ope /10cem2 l    18 beta nam.-. dpm/100cm2  dpm/100cm2 I
' Results of Inspection: Su::: mary of violations and diserapancies Upon Department inspectio it was found .that the seatrain cargo carrier was vary corroded and had three (3) small holes
_
on the _lef t roar side which allowed some of the contacts to be visible. Since the mestrain
  .
cargo carrier is the disposal package, this_ is contrary to the requiremante of Coidition 6 S.C._ Radioactive Material _ License 097. Amendment 41._and 49 CFR 173.425(b)(1).


_
Full compliance was achieved on January 23, 1986, the date upon which Procedure 6.9.194 was revised to include the aforementioned improvements.
Each of these items of noncompliance constitute separate violatione_of Section 1.2. Department Regulation 61-5 __


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L Date: January 2. 1986  Inspector's Signature s/ Richard S. Sappington Jz  FSOM SES 9- 7L "7 O!'09'95 ! D 07 " d 707 L "
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Latest revision as of 17:15, 7 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/86-04.Subj Actions Examined During 860324-27 Insp & Acceptable.Addl Info Will Be Contained in Insp Rept 50-293/86-10
ML20202F684
Person / Time
Site: Pilgrim
Issue date: 04/10/1986
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Harrington W
BOSTON EDISON CO.
References
NUDOCS 8604140207
Download: ML20202F684 (2)


Text

f

'

APR 101986

,

Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199 L Gentlemen:

Subject: Inspection No. 50-293/86-04 This refers to your letter dated March 11, 1986, in response to our letter dated February 12, 1986.

Thank you for informing us of the corrective and preventive actions documented-in your letter. These ' actions were examined during an inspection conducted March 24-27, 1986 and are considered . acceptable to prevent a reoccurence.

Further documentation will be contained in NRC Inspection Report 50-293/86-10.

.Your cooperation with us is appreciated.

l

Sincerely, OFilihiSIEmoB7I

'

hom s , t.

vision of Radiation SafMy

[

and Safeguards-cc:

A. V. Morisi, Manager, Nuclear Management Services Department C. J.'Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director Senator Edward P. Kirby Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

, CommonwealthofMassachusetts(2)

l OFFICIAL RECORD COPY t8604140207 860410 'T i

!

PDR ADOCK OS000293:-' ,,

!

,

G PDR l l

_ _ _ _ _ _ _ _ - _ -

(['

-.

$

w' ^ '

Boston EdisonL Company M/C Nuclear 2 bcc:

' Region I-Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section' Chief, DRP

'

W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR

,

!

b ; RSS RI Miller /mm a's iak Bellamy 4/7/86 4/rl/86 4/lO/86 i

0FFICIAL RECORD COPY RL PILGRIM 86-04 - 0002.0.0 04/04/86 t

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BOSTON EpisON COMPANY 800 BOYLSTON STREET BOSTON. MASSACHUSETTS 02199 l

wituAu o. wAnniwa' "

co........ ....... , March 11,1986 n . 6.. .

BECo Ltr. #86-030 l

Dr. Thomas I Regional Administrator - Region 1 .

U. S. Nuclear Regulatory Commission 631 Park Avenue l King of Prussia, PA 19406 i Subject: Response to Notice of Violation as Contained in NRC Letter to Boston Edison dated 2/12/86 (Inspection Report No. 86-04)

References: (A) Letter dated 1/07/86 from South Carolina Department of Health and Environmental Control, Containing Civil Penalty and (2) Items of l Non-Compliance  ;

(B) Letter dated 1/28/86 f rom Boston Edison Company to South Carolina ;

Department of Health and Environmental Control, Responding to i Items of Non-Compliance and Civil Penalty

Dear Dr. Murley:

This letter is in response to the Notice of Violation as contained in Reference (A). As mentioned in our response to the South Carolina Department of Health and Environmental Control [ Reference (B)], we would like to assure you that Boston Edison Company has taken adequate corrective measures to ensure future compliance with the applicable provisions of federal and state laws as they apply to low-level radioactive waste shipments.

I trust that the attached response will adequately exhibit our serious commitment to continuing compliance in this area.

Please be advised that, upon review of this matter, Boston Edison has decided that further programmatic review and improvements are both necessary and desirable. The improvements are intended to impose enhanced quality requirements on radioactive waste processing, handling and shipping operations. Our approach will consist of a detailed review of 10 CFR 71 Subpart H and a more thorough integration of appropriate requirements into our existing Quality Assurance Program per 10 CFR 50 Appendix B. We expect to have a more detailed plan and schedule in approximately thirty days at which time a copy will be forwarded to the Senior Resident Inspector at Pilgrim Station.

Should you have further questions concerning these matters, please do not hesitate to contact me.

Respectfully submitted, William D. Harring on Attachment

.d U ML,

-

35 ]9q.

-7

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-

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ATTACHMENT

..

Violation As the result of the inspection conducted on January 2, 1986, by a representative of the South Carolina Department of Health and Environmental Control of a shipment of radioactive waste sent from your facility in Plymouth, Massachusetts on December 30, 1985, and in accordance with the NRC Enforcement Policy (10 CFR 2 Appendix C), the following violation was identified:

10 CFR 71.5, " Transportation of licensed material," states "each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers 1 censed material to a carrier for transport, shall comply with the at:licable requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 189."

1. 49 CFR 173.425(b) (1) " Transport requirements for low specific activity (LSA) radioactive materials" states that materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation."

Contrary to the above, on December 30, 1985, a waste shipment ,

of solid metallic oxides on noncompacted trash, containing 0.195 Curies in a Seatrain container was delivered to a carrier for transport to a burial site in South Carolina, and upon inspection of the container at the burial site on January 2, 1986, by a representative of the State of South Carolina Department of Health and Environment Control, it was determined that there were "three (3) small holes on the lef t rear side which allowed some of the contents to be visible."

2. 49 CFR 173.475(b) " Quality Control requirements prior to each shipment of radioactive materials" state, "the shipper shall ensure by examination or appropriate tests that the packaging is in unimpaired physical damage condition, except for superficial marks."

Contrary to the above, on December 30, 1985, a waste shipment of solid metallic oxides on noncompacted trash, containing 0.195 Curies in a Seatrain container was delivered to a carrier for transport to a burial site in South Carolina, without ensuring prior to shipment that the packaging was in unimpaired physical condition. The container was inspected at the burial site on January 2, 1986, and at that time a representative of the State of South Carolina Department of Health and Environmental Control determined that the Seatrain container was corroded and damaged.

f.- *

,

,

.. .

-

..

ResDonse

.

Boston Edison agrees with both items. Although the subject container was duly inspected and signed off prior to shipment by experienced personnel in accordance with existing Pilgria Station Procedure 6.9.194 (" Loading Transport Vehicle for Radioactive Material and Waste Shipment"), it nevertheless appeared the metal of the cargo container was delaminating due to corrosion, and during transit, the lamination broke loose, leaving the small holes exposed.

Corrective action taken to correct the condition and to preclude recurrence is that Procedure 6.9.194 (" Loading Transport Vehicle for Radioactive Material and Waste Shipments") has been revised and strengthened to include a checklist requiring receipt inspections be performed on Seatrain cargo containers. The procedure has also been improved to include further checklists assuring that the subject shipping container will be inspected for evidence of corrosion and/or damage prior to shipment. Any indication of corrosion and/or damage will be rectified prior to shipment.

As further corrective action to preclude recurrence, the Training Department will re-emphasize (to individuals involved in the shipping process) the importance of compliance with pertinent regulations and requirements. The subject violation will be used as a specific example in training, as will the procedural improvements which have been made.

Full compliance was achieved on January 23, 1986, the date upon which Procedure 6.9.194 was revised to include the aforementioned improvements.

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