Information Notice 1992-75, Unplanned Intakes of Airborne Radioactive Material by Individuals at Nuclear Power Plants
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555November 12, 1992NRC INFORMATION NOTICE 92-75: UNPLANNED INTAKES OF AIRBORNE RADIOACTIVEMATERIAL BY INDIVIDUALS AT NUCLEAR POWER PLANTS
Addressees
All holders of operating licenses or construction permits for nuclear powerreactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this informationnotice to alert licensees to unplanned personnel intakes of radioactivematerials because of inadequate radiological, engineering, and proceduralcontrols regarding radiologically contaminated materials. It is expected thatrecipients will review the 'information for applicability to their facilitiesand consider actions, as appropriate, to avoid similar problems. However,suggestions contained in this information notice are not 'NRC requirements;therefore, no specific action or written response is required.
Description of Circumstances
During two events in 1991 at nuclear reactor facilities, licensee employeesreceived unplanned intakes of-radioactive material while performing work inradiologically controlled areas. The following discussions of these eventssuggest inadequate licensee control in certain areas.FitzpatrickOn May 23, 1991, four workers signed a radiation work permit (RWP) to enterthe torus room to remove insulation from a section of pipe. One was a healthphysics technician (HPT) who was to provide continuous job coverage. All weredressed in accordance with the RWP requirements, which included doubleprotective clothing (PC) and a negative pressure'(particulate) respirator.The HPT took an air sample just before removing the outer metal casing aroundthe insulation. When the casing was removed, parts of the insulation crumbledinto powder and formed a "cloud" of radioactive material in the air. The HPTthen surveyed the insulation and obtained a survey meter reading that was muchhigher than expected, greater than 10 mSv/h (in the R/h range). The HPTpromptly ordered the workers to stop work and leave the area. All four of theworkers were contaminated, some in the chest area and some on the face. Theyall had inhaled small amounts of radioactive material. The licensee estimatedthat the intakes ranged between two and four maximum permissible9211050202eV J\' -T- /1 U K kJ IN 92-75November 12, 1992 hours0.0231 days <br />0.553 hours <br />0.00329 weeks <br />7.57956e-4 months <br /> (MPC-hrs). An air sample taken in the worker's breathing zone in thetorus room while the insulation was being removed showed airborne radioactiveconcentrations of approximately 97 times MPC.About 10,minuteseafter the four workers entered the torus:room, two other-workers'signed the same.RWP tp erect"scaffoldinj in a room adjoining the torusroom.-These workers did n6t wear respirator's since the RWP did not requirerespirators for use in the adjoining room. Consequently, after exiting thearea upon completing their work, both workers were found to be contaminated.One was contaminated on the face and the other on the chest. The workers werethen decontaminated and sent to obtain a whole body count (WBC). The WBCresult's for these two workers indicated much higher intakes than any of themembers of the first group (approximately 27 MPC-hrs). The airborneradioactive material from the torus room was the source of their intakes; thismaterial entered the room through a gap in a sleeve around a pipe passingbetween the two rooms. Natural convection. between these two areas caused the.contaminated airto flow rapidly into fh'e room where the two, workers wereerecting scaffolding. ' " ' ' ' .Du'ring 'the aS low as' is reasonably achievable (ALARA) pre-job,review.meetingthat'was conducted td, 'di'scuss.the torus-room scope-of work, the li~censee'sALARA grouporecommended'using' a hi-gh efficiency particulate air (HEPA) ,filtration system while removing: insulation.' However, the licensee did notuse a HEPA filter sy-st'em. 'Use of the HEPA system would have required removinga heavy concrete floor plug to gain access to the torus room., To remove theplug, the licensee needed to use a crane; maintenance personnel were requestedto remove the plug, but could not support.the job in a timely manner.Therefore', faced with' a delay of several:'hours, the chief.HPT and the,radiological 's'upervisor' (RS). decided to disregard the;recommendation from theALARA'group 'and deleted the HEPA system.requirement-fromthe1RWP. However, -the chief HPT and the RS had riot attended the pre-j6b ALARA briefing, whereworkers stated that more insulation would need to be removed than originally-,indicated and that health physics (HP) personnel had not surveyed thisadditional larger area of insulation. As a result of.missing the ALARAbriefing;,th6 chief HPT and'RS-'used incompTeteinformation and inadequate pre-job'surveys in-their decision to dMelte theHEPA systema recommendation.,The decision to remove lhe~insulatiodn without using the HEPA system did notprompt the licensee to reevaluate theiadequacy of the respiratory protectionrequired by the RWP. For example, a-negative pressure respirator has amaximum protection factor of 50,, while apositive~pressure (continuous flow)respirator hasa maximum protecti6n fad't'or o'f, 2000. Therefore, a positive.- ,-pressure' respfrator Would havebetter protected the workers.Th6'lidnsee' evaluated thi's evYent and" fou'nd I inadequate communication betweenthe insulation remoVe'rs,"th6'ILARA 'group,.and.HP personnel, and reached thefolldwing conclusions. The 'scq'ejof work was' not communicated, adequately- to -radiation protection personhel. Also, the ALARA group did not adequatelyconsider the information presented by insulation removers regarding thecondition of the insulation and the amount of insulation to be removed. , ,,
IN 92-75November 12, 1992 Further, the change in job scope did not prompt the licensee to reevaluate theadequacy of the initial planning and job requirements.LimerickOn March 25, 1991, a group of maintenance workers entered the reactor cavityto perform general inspections and housekeeping activities in preparation forflooding of the cavity. Access to the transfer canal was roped off and postedwith a sign stating "Caution: Do Not Enter." [The transfer canal is a narrowpassageway that connects the reactor cavity to the spent fuel pool (SFP) andis used to transfer fuel between the two areas.] The RWP specified "EntryInto The Transfer Canal Prohibited Under This RWP." The reactor cavity hadbeen decontaminated, but the transfer canal had not; personnel conducting thelast transfer canal survey had found loose contamination levels of 0.24 mGy/h(24 mrad/h), smearable.The licensee job leader (JL) and his crew entered the cavity after signing theRWP. They inspected the reactor vessel flange and started generalhousekeeping activities, including vacuum cleaning of the cavity area. Duringthese activities, the crew found indications of a surface defect in the vesselflange. As a result, the JL summoned assistance from Reactor Services Section(RSS) personnel. The RSS superintendent and another RSS engineer entered thecavity to inspect the flange. After the engineers inspected the flange, thecrew removed the service platform and completed its housekeeping. The JL thenremoved the rope and the "Caution: Do Not Enter" sign at the entrance to thetransfer canal. The work crew then removed a "stop log gate," (a large gateinstalled between the transfer canal and the SFP), at the end of the transfercanal near the SFP. While the gate was being lifted, the JL noted that somesealant material had broken off and fallen on the floor of the transfer canal.Since the vacuum cleaner had been removed from the cavity, the JL asked 7that abrush and dustpan be sent down.The JL then entered the transfer canal. Even though he had just removed therope barrier and sign, the RWP prohibiting such entry was still in effect.Therefore, he was in violation of the RWP. While cleaning the transfer canal,he noticed some damage to the stop log gate guides, and exited the canal tosummon the RSS engineers to inspect the guides. The JL then escorted the twoengineers into the transfer canal to perform the inspection, again inviolation of the RWP.On leaving the cavity, the JL removed his protective clothi'ng and went to thewhole body contamination monitor on the refueling floor to check forcontamination. The monitor alarmed, and a later survey indicatedcontamination around his neck and upper torso. HP personnel escorted the JLto a decontamination facility where extensive decontamination efforts wereperformed. However, no change in count rate was noted, indicating a possibleintake of radioactive material. The licensee final estimate of the intake wasless than 50 MPC-h IIIIN 92-75November 12, 1992 The region held an enforcement conference with the licensee to discuss NRCstaff concerns with programmatic weaknesses, including procedure violations,inadequate HP controls, poor communication between the JL and HP, and aninadequate understanding of the hazards that can result from using a dustpanand brush in a highly contaminated area.DiscussionSection 20.103(b) of Title 10 of the Code of Federal Regulations(10 CFR 20.103), "Exposure of individuals to concentrations of radioactivematerials in air in restricted areas," requires the use of process or otherengineering controls, to the extent practicable, to limit concentrations ofairborne radioactive material.' In the Fitzpatrick case, the HEPA filtrationsystem was an available engineering control. When the use of these controlsis not practicable, the licensee is required to use other precautionaryprocedures, such as increased surveillance, limitation of working times, orprovision of respiratory protective equipment to limit personnel intakes ofradioactive material to~as low as is reasonably achievable.Worker intakes of radioactive-material at nuclear power plants are generallyfar below the limits of 10 CFR Part 20.. During normal/plant operation,airborne radioactive, material is of little concern. However, the eventsdiscussed herein demonstrate-the need for vigilance in conducting maintenanceactivities that could significantly increase airborne radioactive material.These examples indicate that some licensees have not adequately implementedcertain radiological control requirements. In both of these events, processor other engineering controls,. (e.g., HEPA filtration systems, roped-off areasand pre-work ALARA briefings) were available to help control the intake ofairborne radioactive material, but were not effectively used.This information notice requires no specific action or written response. Ifyou have any questions about this matter, please call the technical contactlisted below or the appropriate Nuclear Reactor Regulation (NRR) projectmanager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contacts: Jack M. Bell, NRR(301) 504-1083,Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI(215) 337-5267
Attachment:
List of Recently Issued NRC Information Notices K-attachmentIN 92-75November 12, 1992 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to92-7492-61,Supp. 192-7392-59,Rev. 192-7291-64,Supp. 192-7192-70Power Oscillations atWashington NuclearPower Unit 2Loss of High HeadSafety InjectionRemoval of A FuelElement from A Re-search Reactor CoreWhile CriticalHorizontally-InstalledMotor-Operated GateValvesEmployee Training andShipper RegistrationRequirements for Trans-porting RadioactiveMaterialsSite Area EmergencyResulting from A Lossof Non-Class IEUninterruptible PowerSuppliesPartial Plugging ofSuppression PoolStrainers At AForeign BWRWestinghouse Motor-OperatedValve Performance DataSupplied to Nuclear PowerPlant LicenseesWater Leakage from YardArea Through ConduitsInto Buildings11/10/9211/06/9211-04/9211/04/9210/28/9210/07/9209/30/9209/25/9209/22/92All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All U.S. Nuclear RegulatoryCommission Licensees.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.92-69OL = Operating LicenseCP = Construction Permit IN 92-75K<J November 12, 1992 The region held an enforcement conference with the licensee to discuss NRCstaff concerns with programmatic weaknesses, including procedure violations,inadequate HP controls, poor communication between the JL and HP, and aninadequate understanding of the hazards that can result from using a dustpanand brush in a highly contaminated area.DiscussionSection 20.103(b) of Title 10 of the Code of Federal Regulations(10 CFR 20.103), "Exposure of individuals to concentrations of radioactivematerials in air in restricted areas," requires the use of process or otherengineering controls, to the extent practicable, to limit concentrations ofairborne radioactive material. In the Fitzpatrick case, the HEPA filtrationsystem was an available engineering control. When the use of these controlsis not practicable, the licensee is required to use other precautionaryprocedures, such as increased surveillance, limitation of working times, orprovision of respiratory protective equipment to limit personnel intakes ofradioactive material to as low as is reasonably achievable.Worker intakes of radioactive material at nuclear power plants are generallyfar below the limits of 10 CFR Part 20. During normal plant operation,airborne radioactive material is of little concern. However, the eventsdiscussed herein demonstrate the need for vigilance in conducting maintenanceactivities that could significantly increase airborne radioactive material.These examples indicate that some licensees have not adequately implementedcertain radiological control requirements. In both of these events, processor other engineering controls, (e.g., HEPA filtration systems, roped-off areasand pre-work ALARA briefings) were available to help control the intake ofairborne radioactive material, but were not effectively used.This information notice requires no specific action or written response. Ifyou have any questions about this matter, please call the technical contactlisted below or the appropriate Nuclear Reactor Regulation (NRR) projectmanager. Original signed bYBrian K. GrimesBrian K. Grimes, Director-Division of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contacts: Jack M. Bell, NRR(301) 504-1083Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI -(215) 337-5267
Attachment:
List of Recently Issued NRC Information Notices vDOCUMENT NAME: 92-75.IN*SEE PREVIOUS CONCURRENCE.OFC PRPB:DREP SC:PREP:DREP TECHED BC:PRPB:DREP D:DREP/NRRNAME DCarter JWigginton JK, in LCunningham FCongelDATE 8/25/92* 8/25/92* 30/92* 8/25/92* 8/27/92*OFC BC:OGCB:DORS OGCB:DORSNAME GHMarcus JPetrosino10/16/92* 1//2// 10/14/92*
IN 92-XXOctober XX, 1992 DiscussionSection 20.103(b) of Title 10 of the Code of Federal Regulations (10 CFR20.103), "Exposure of individuals to concentrations of radioactive materialsin air in restricted areas," requires the use of process or other engineeringcontrols, to the extent practicable, to limit concentrations of airborneradioactive material. In the Fitzpatrick case, the HEPA filtration system wasan available engineering control. When the use of these controls is notpracticable, the licensee is required to use other precautionary procedures,such as increased surveillance, limitation of working times, or provision ofrespiratory protective equipment to limit personnel intakes of radioactivematerial to as low as is reasonably achievable.Worker intakes of radioactive material at nuclear power plants are generallyfar below the limits of 10 CFR Part 20. During normal plant operation,airborne radioactive material is of little concern. However, the eventsdiscussed herein demonstrate the need for vigilance in conducting maintenanceactivities that could significantly increase airborne radioactive material.These examples indicate that some licensees have not adequately implementedradiological control requirements. In both of these events, process or otherengineering controls, (e.g., HEPA filtration systems, roped-off areas and pre-work ALARA briefings) were available to help control the intake of airborneradioactive material, but were not effectively used.This information notice requires no specific action or written response. Ifyou have any questions about this matter, please call the technical contactlisted below or the appropriate Nuclear Reactor Regulation (NRR) projectmanager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contacts: Jack M. Bell, NRR(301) 504-1083Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI(215) 337-5267
Attachment:
List of Recently Issued NRC Information NoticesDOCUMENT NAME: AIRRADIO.IN*SEE PREVIOUS CONCURRENCE.OFC PRPB:DREP SC:PREP:DREP TECHED BC:PRPB:DREP D:DREP/NRRNAME DCarter JWigginton JMain LCunningham FCongelDATE 8/25/92* 8/25/92* 9/30/92* 8/25/92* 8/27/92*OFC BC:OGCB:DORS DIR:DORS OGCB:DORSNAME GHMarcus BKGrime JPetrosinoDATE 10/16/92 XQ10/ /92 10/14/92*
- < IN 92-XXOctober XX, 1992Page 4 ofDiscussionSection 20.103(b)(1) of Title 10 of the Code of Federal Requla ons (10 CFR20.103), "Exposure of individuals to concentrations of radio tive materialsin air in restricted areas," requires, the use of process other engineeringcontrols to the extent practicable,to limit airborne radi ctivity. When theuse of these controls is not practicable, the licensee i required to useother precautionary procedures, such as increased surv lance, limitation ofworking times, or provision of respiratory protectiv equipment to limitpersonnel intakes of radioactive material to as low/as is reasonablyachievable.Worker intakes of radioactive material at nucl r power plants are generallybelow the limits of 10 CFR Part 20 by several orders of magnitude. Duringnormal plant operation, occupational airborn hazards are normally of littleconcern. However, the events discussed ab ve demonstrate the need forincreased vigilance in conducting mainte nce activities that couldsignificantly increase the amount of ai borne radioactive material. Theseexamples suggest that some licensees e not adequately implementing their ownradiological control requirements. n both of these events, process or otherengineering controls, (e.g., HEPA ltration systems, roped-off areas and pre-work ALARA briefings) were avail le or in place to help control the intake ofairborne radioactive material, t were not adequately utilized.This information notice requ es no specific action or written response. Ifyou have any questions abou this matter, please call the technical contactlisted below or the appro iate Nuclear Reactor Regulation (NRR) projectmanager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical co tacts: Jack M. Bell, NRR(301) 504-1083Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI(215) 337-5267OCUMENT NAME: AIRRADIO.IN f*SEE PREVIOUS CONCURRENCE.OFC PRPB:DREP SC:PREP:DREP TECHED BC:PRPB:DREP D:DREP/NRRNAME DCarter JWigginton JMain LCunningham FCongelDATE 8/25/92* 8/25/92* 9/30/92* 8/25/92* 8/27/92*OFC BC:OGCB: DIR:DORS OGCB:DORSNAME GHMarcups6 BKGrimefik JPetrosinoDATE 10/1L(/92 10/ /92 10/14/92*
- S ' V IN 92-XXOctober XX, 1992 DiscussionSection 20.103(b)(1) of Title 10 of the Code of Federal Re ulati ns (10 CFR20.103), "Exposure of individuals to concentrations of radioac ive materialsin air in restricted areas," requires, the use of process or ther engineeringcontrols to the extent practicable,to limit airborne radio tivity. When theuse of these controls is not practicable, the licensee is equired to useother precautionary procedures, such as increased surveij ance, limitation ofworking times, or provision of respiratory protective quipment to limitpersonnel intakes of radioactive material to as low a is reasonablyachievable.Worker intakes of radioactive material at nuclear power plants are generallybelow the limits of 10 CFR Part 20 by several o ders of magnitude. Duringnormal plant operation, occupational airborne azards are normally of littleconcern. However, the events discussed abov demonstrate the need forincreased vigilance in conducting maintenan e activities that couldsignificantly increase the amount of airb ne radioactive material. Theseexamples suggest that some licensees are ot adequately implementing their ownradiological control requirements. In oth of these events, process or otherengineering controls, (e.g., HEPA fil ation systems, roped-off areas and pre-work ALARA briefings) were available/or in place to help control the intake ofairborne radioactive material, but ere not adequately utilized.This information notice requires o specific action or written response. Ifyou have any questions about th~s matter, please call the technical contactlisted below or the appropria Nuclear Reactor Regulation (NRR) projectmanager.nran K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contact Jack M. Bell, NRR(301) 504-1083Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI(215) 337-5267DOCU NT NAME: AIRRADIO.IN* E PREVIOUS CONCURRENCE.OFC PRPB:DREP SC:PREP:DREP TECHED BC:PRPB:DREP D:DREP/NRRNAME DCarter JWigginton JMain LCunningham FCongelDATE 8/25/92* 8/25/92* 9/30/92* 8/25/92* 8/27/92*OFC BC:OGCB:DORS DIR:DORS OGCB:Di SNAME GHMarcus BKGrimes JPetronDATE 10/ /92 10/ /92 10/07/92*\"0'
IN 92-XXOctober XX, 199 DiscussionSection 20.103(b)(1) of Title 10 of the Code of Federal Re ulativ (10 CFR20.103), "Exposure of individuals to concentrations of radioacti e materialsin air in restricted areas," requires, the use of process or herengineering controls to the extent practicable,to limit airbo neradioactivity. When the use of these controls is not practiable, thelicensee is required to use other precautionary procedures such as increasedsurveillance, limitation of working times, or provision respiratoryprotective equipment to limit personnel intakes of rad active material to aslow as is reasonably achievable.Worker intakes of radioactive material at nuclear ower plants are generallybelow the limits of 10 CFR Part 20 by several or rs of magnitude. Duringnormal plant operation, occupational airborne h ards are normally of littleconcern. However, the events discussed above emonstrate the need forincreased vigilance in conducting maintenanc activities that couldsignificantly increase the amount of airbor e radioactive material. Theseexamples suggest that some licensees are ot adequately implementing their ownradiological control requirements. In bth of these events, process or otherengineering controls, ( e.g., HEPA fil ation systems, roped-off areas andpre-work ALARA briefings) were avail e or in place to help control theintake of airborne radioactive mate al, but were not adequately utilized.This information notice requires o specific action or written response. Ifyou have any questions about ths matter, please call the technical contactlisted below or the appropria Nuclear Reactor Regulation (NRR) projectmanager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical conta s: Jack M. Bell, NRR(301) 504-1083Daniel R. Carter, NRR(301) 504-1848Ronald L. Nimitz, RI(215) 337-5267DCUMENT NAME: AIRRADIO.IN*SEE PREVOUS CON R CE.OFC R .REP E:DREPNAME Do r ntonDATEOFC C: GCB DORS DIR:DORSNAME GHMarcus BKGrimesDATE 10/ /92 10/ /92TECHED B1JMain Li9/30/92*1 8,O G. RSJPe tidsino10/7 /92::PRPB:DREPCunningham125/92*D:DREP/NRRFCongel8/27/92*
-> j *IN 92-XXSeptember XX, 1992Page 5 of XThis information notice requires no specific action or written response. Ifyou have any questions about this matter, please contact the technical contactlisted below, one of the Board representatives listed on the attachments orthe appropriate Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, DirectorDivision of Operational Events A sessmentOffice of Nuclear Reactor Regu ationTechnical contact: Daniel R. Carter, NRR(301) 504-1848Jack M. Bell, NRR(301) 504-1083Ronald L. Nimitz, RI(215) 337-5267
Attachment:
List of Recen ly Issued NRC Information NoticesDOCUMENT NAME: 92-68.IN*SEE PREVIOUS CONCURRENCE.OFC PRPB:DREP SC:PREP:DREP TECHED BC:PRPB:DREP D:DREP/NRRNAME DCar r JWigginton Jmain 9A LCunningham FCongelDATE 8/ /92* 8/ /92* 813D/92* 8/25/92* 8/27/92*OFC BC:OGCB:DOEA DIR:DOEA OGCBNAME GHMarcus CERossi JPetrosinoDATE 9/ /92 9/ /92 9/ /92 K>Atm 2 7 1992MEMORANDUM FOR:Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationFROM:Frank J. Congel, DirectorDivision of Radiation Protectionand Emergency PreparednessOffice of Nuclear Reactor RegulationSUBJECT: REQUEST FOR ISSUANCE OF INFORMATION NOTICE 92-XX, "UNPLANNEDINTAKES OF AIRBORNE RADIOACTIVE MATER AL AT NUCLEAR POWERPLANTS/Enclosed is the subject draft information notice N), describing personnelintakes of radioactive materials as a result of i adequate radiologicalcontrols associated with working with contaminated materials. This draft INhas benefitted from the review, comment; and Spport of all Regions.Please issue this IN to emphasize the impor ance of using proper radiological,engineering, and procedural controls. To0 btain additional information,please contact Dan Carter at 504-1848.figinal signed by Frank J. CongelFrank J. Congel, DirectorDivision of Radiation Protectionand Emergency PreparednessOffice of Nuclear Reactor Regulation
Enclosure:
Draft Information NoticeDisk containing/draft INDISTRIRUTION- ' .' .GMarcus, 8D22 FCongel JCunninghamJWigginton DCav'ter JBellRNimitz, RI P78B R/F Central FileTEssig / rOFC PRPB:NRR/ PRPB:NRR:SC ADM DREP:NRR: /NAME *DCART/ER *JWIGGINTON *JMAIN FCONGEL k 9 08/ /92 08/ /92 08 92 082Z7/92'*See Previ p'us Concurrence so::OFFICIAL/RECORD COPY 'Docume Name:INAIRB/