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SSINS No. : 6835
f ? IN 85-46
B1 995 UNITED STATES
JUN 1 NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
�j coLo• WASHINGTON, D. C. 20555
GREELEY.
June 10, 1985
IE INFORMATION NOTICE NO. 85-46: CLARIFICATION OF SEVERAL ASPECTS OF REMOVABLE
RADIOACTIVE SURFACE CONTAMINATION LIMITS FOR
TRANSPORT PACKAGES
Addressees:
All nuclear power reactor facilities holding an operating license"(OL).
Purpose:
This information notice is provided to clarify the application of the U. S.
Department of Transportation (DOT) requirements pertaining to the control and
monitoring of removable radioactive surface contamination on packages and
transport vehicles. It is expected that recipients will review this information
for applicability to their transportation activities, and consider actions, if
appropriate, to preclude any problems from arising due to inappropriate
applications of the DOT requirements. However, suggestions contained in this
notice do not constitute NRC requirements; therefore, no specific action or
written response is required. Specific clarification and guidance is provided
in the Attachments on:
1. Averaging of Wipe Samples
2. Use of Higher Efficiency Wipe Sampling Methods
3. "Wrapping" of Packages
4. Exclusive-use Vehicle Surveys for Surface Contamination
Background:
The recent resumption of transportation of commercial power reactor spent fuel
in the U. S. has focused renewed attention on the chronic problem of cask
"weeping. " This is a phenomena whereby certain casks, after their removal from
underwater storage basins (pools) and decontamination, subsequently exhibit an
increase in the level of removable radioactive surface contamination during and
after transport. This increase is believed to be the result of a "weeping" or
"sweating" of previously entrapped activity within surface pores, fissures, etc.
Its occurrence and magnitude appear to be dependent on such variables as cleanup
methods, surface porosity, types of detergents used, surface treatment history,
duration of and temperature during transport, and the period of time between
completion of transportation and performance of a contamination survey. Although
the levels of contamination which have been observed in cask "weeping" episodes
do not present a significant health and safety problem, the levels have been
851163
8506060707
I ,
IN 85-46
June 10, 1985
Page 2 of 3
technically above the regulatory limits, particularly when no further consideration
is given to determining the wiping efficiency more precisely than the ten percent
efficiency that is assumed within the regulatory limit. Recent changes to DOT
regulations as promulgated in Docket HM-169 (48 FR 10218, March 10, 1983, and.
48 FR 31214, July 7, 1983) have also raised a question because of an apparent
unintended revision in the regulatory language relating to averaging of wipe
samples. Notwithstanding the guidance in this notice, shippers of radioactive
packages, particularly spent fuel casks, are reminded of the continuing need for
improving cask decontamination methods and spent fuel pool techniques, so as to
maintain removable radioactive surface contamination levels as low as practicable.
Current Regulatory Requirements:
The DOT regulations in 49 CFR 173.443 prescribe limits for control of removable
(nonfixed) radioactive contamination. The level of such contamination on the
external surfaces of each transport package offered for shipment must be kept
as low as practicable. Determination of the nonfixed contamination may be made
by wiping (e.g. , "smears") an area of 300 cm2 of the surface concerned with an
absorbent material , using moderate pressure, and measuring the activity on the
wiping material . Sufficient wipe samples should be taken in the most appropriate
locations so as to yield a representative assessment of the nonfixed contamina-
tion levels. The limits of §173.443, Table 10, are restated below:
TABLE 10 - REMOVABLE EXTERNAL
RADIOACTIVE CONTAMINATION - WIPE LIMITS
Maximum
Contaminant Permissible limits
uCi/cm2 dpm/cm2
Beta-gamma emitting radionuclides;
all radionuclides with half-lives
less than ten days ; natural uranium;
natural thorium, uranium-235; ura-
nium-238; thorium-232; thorium-228
and thorium-230 when contained in
ores or physical concentrates 10-5 22
All other alpha emitting radionuclides. . 10-6 2. 2
The above limits apply to packages transported as nonexclusive use, e. g. , mixed
freight. For packages shipped as exclusive-use by rail or public highway, the
provisions of §173. 443(b) provide that the removable (nonfixed) radioactive
surface contamination at any time during transport may not exceed 10 times the
limits stated above. At the beginning of transport, however, the levels may
not exceed those stated above. Further, pursuant to §113.443(c) , any transport
IN 85-46
June 10, 1985
Page 3 of 3
vehicle in which packages are transported within the "factor of 10" higher values,
e.g. , above the Table 10 limits, must be surveyed with appropriate radiation
detection instruments after each use and shall not be returned to service until
the radiation dose rate is below 0. 5 mrem/hr and the removable contamination is
below the limits stated in the above table. (An exception to this vehicle survey
requirement is provided by §113.443(d) for closed transport vehicles (highway)
which are dedicated solely to the transport of radioactive materials packages
and are appropriately marked on the exterior of the vehicle. Also, in such cases
the removable surface contamination on packages within such vehicles may be at
the "factor of 10" limits at the start of transport).
No specific action or written response to this information notice is required.
If you have any questions on this matter, please contact the appropriate NRC
Regional office or the technical contact listed below.
AlJCIcan, birector
Divis. of Emergency Preparedness
an ngineering Response
Office of Inspection and Enforcement
Contact: A. W. Grella, IE
(301 ) 492-7746
Attachments:
1. Averaging of Wipe Samples
2. Use of Higher Efficiency Wipe Samples
3. "Wrapping" of Packages (Casks)
4. Exclusive-use Vehicle Surveys for Surface Contamination
5. List of Recently Issued IE Information Notices
Attachment 1
IN 85-46
June 10, 1985
AVERAGING OF WIPE SAMPLES
The DOT regulations currently state in §173.443(a) that ". . . the amount of
radioactivity measured on any single wiping material when averaged over the
surface wiped . . . " shall not exceed the Table 10 values. Prior to the
regulatory amendments by DOT in 1983 (see Docket HM-169, 48 FR 10238, March 10,
1983) , formerly applicable §173. 397(a) provided that wipe samples could be
". . . averaged over any area of 300 square centimeters of any part of the pack-
age surface. " A February 21, 1984 query was made by NRC to DOT to clarify this
matter. It read as follows:
The language of §173.443(a) has been modified somewhat from that
contained in the previous §173. 397(a). The new language no longer
specifically addresses averaging of multiple wipe samples within
any given 300 cm2 area of a package surface. We understand that
it was not DOT' s intention to disallow such averaging and further
that DOT will consider processing a future rule change to restore
such a provision to §173.443. A suggested text for such a modifi-
cation is enclosed. In the interim, until the text has been formally
modified, we will continue to consider that averaging of multiple
wipe samples over any 300 cm2 area of a package surface is an
acceptable practice.
In their March 19, 1984, reply to NRC the DOT stated:
It was not our intent to disallow averaging of wipe samplings over
a 300 cm2 area. Consequently, we believe this is an acceptable
practice and will take the necessary action to clarify this in
§173.443(a). . . .
Attachment 2
IN 85-46
June 10, 1985
Page 1 of 2
USE OF HIGHER EFFICIENCY WIPE SAMPLES
As is stated in §173.443(a): "Other methods of assessment of equal or greater
efficiency may be used. When other methods are used, the detection efficiency
of the method used shall be taken into account and in no case shall the nonfixed
contamination on the external surfaces of the package exceed ten times the
limits listed in Table 10. " NRC also queried DOT on this matter, as follows:
We understand that DOT considers that the reference in §173.443(a)
stating that 'other methods of assessment of equal or greater effi-
ciency may be used, ' may include other wipe sampling methods wherein
the efficiency has actually been demonstrated to be greater than 10
percent. Therefore, in effect, the wipe sample limits stated in
§173.443(a) and (b) and Table 10 therein, are limits "by default,"
which do not take advantage of utilizing an efficiency which has been
demonstrated to be greater than 10 percent. In our evaluations of
licensees' package surveys, we therefore plan to accept assessments
based on efficiencies which have been appropriately demonstrated
to have a higher than 10 percent efficiency.
The reply by DOT on the usage of higher efficiency wipe samples was as follows:
It is our interpretation of this section that wiping methods with
a demonstrated efficiency greater than 10 percent may take this
greater efficiency into account. As you point out, the higher
efficiency must be documented and in no case may the removable
levels exceed 10 times the values in Table 10.
It should be understood that where the term "detection efficiency" is used, it
refers to the efficiency of alternate methods for quantifying the amount of
removable contamination on a package surface. It does not refer to the labor-
atory term relating to instrument effectiveness for counting analyses.
An additional clarification also was received from DOT relative to use of
contamination assessment techniques with greater than 10% efficiencies in
exclusive-use vs nonexclusive-use shipments. It stated that "the provision
for using higher efficiency techniques, described in 49 CFR 173.443(a) may also
be used when operations are being performed in accordance with §173.443(b). "
An acceptable method of demonstrating wipe (smear) efficiency is repetitive
wiping of a portion of the package surface. The demonstrated wipe efficiency
is the ratio of the initial smear activity to the summation of activity on all
the wipes of the designated portion of the package surface. For the purpose
of this calculation, one can assume all activity is removed when two consecu-
tive wipes show less than 10% of the activity of the initial wipe. Because of
variations in package surfaces and contamination characteristics, care should be
Attachment 2
IN 85-46
June 10, 1985
Page 2 of 2
taken to ensure that the demonstrated wipe efficiency is representative of the
wipes to which it is applied. This will normally require delaying package decon-
tamination until after conduct of wipe efficiency determinations if an efficiency
greater than 10% is used. In no case, however, may the removable contamination
levels exceed ten times the Table 10 limits for packages in exclusive-use ship-
ments when no consideration is given to a demonstrated higher wiping efficiency.
Upon such an appropriate demonstration, however, removable contamination limits
may not exceed 100 times the Table 10 limits, as would be the case for a wiping
method demonstrated to have been 100% efficient.
In general , licensees may only utilize demonstrations of high smear collection
efficiencies which have been determined by smear results taken on the same cask
for which the initial smears (using the assumed 10% efficiency) indicated the
regulatory limit was exceeded. Licensees will not be allowed to use the
generic collection efficiencies obtained on one specific cask for other future
cask shipments.
Attachment 3
IN 85-46
June 10, 1985
"WRAPPING" OF PACKAGES (CASKS)
The question of "wrapping" the exterior of transport packages has been raised
on several occasions, particularly in instances where "weeping" of contamination
has occurred on casks that have been immersed in spent fuel storage pools prior
to transport. DOT also was queried on this matter by NRC as follows:
The issue of whether exterior "wrapping" of casks can be used to
achieve compliance with removable contamination limits has been
raised on a number of occasions. Our position on this, with which
I understand you also concur, is as follows:
° The addition of "wrapping" to an NRC-certified package
would not be permissible without obtaining prior
authorization of the modification in the applicable NRC
certificate. In proposing such a provision, an applicant' s
safety analysis obviously would have to address heat
retention since the contents are a heat source.
° The "wrapping" of a non-NRC certified package would not
relieve the shipper from compliance with the removable
contamination limits applicable to the exterior surface of
the unwrapped package unless the wrapping constituted an
integral part of a DOT Specification 7A, Type A, package
design. In such cases, the shipper' s documented package
safety evaluation would need to address whether the wrap-
ping would maintain its closure integrity during the normal
conditions of transport.
The reply to NRC by DOT on this matter read as follows:
For both NRC-certified and non-NRC-certified packages, any wrap-
ping must be addressed in the package design evaluation. For NRC-
certified packages this would include specific mention in the
certificate of compliance. For DOT Specification 7A, Type A, pack-
ages, the shipper' s package safety evaluation would have to document
the ability of the wrapping to successfully pass the Type A tests.
Attachment 4
IN 85-46
June 10, 1985
EXCLUSIVE-USE VEHICLE SURVEYS FOR SURFACE CONTAMINATION
The exact requirements of §173.443 are sometimes misunderstood as they relate
to quantitative limits on the vehicle surface during the survey required by
§173.443(c). For this purpose, the vehicle surface is meant to be those sur-
faces wherein or on which packages are stowed during transport. That paragraph
does not actually set forth any quantitative limit on the surface of the vehicle
itself during the survey which is performed to return the vehicle to service.
The important subtlety therein is that the quantified limit of §173.443(b)
applies to the packages in the vehicle. The "bottom line" of §173.443(b) and
(c), considered collectively, is as follows:
o The acka es within an exclusive-use vehicle may have up to
22,000 d m 100 cm2 during and at the completion of transport
but must be limited to 2,200 d/m/100 cm2 at the start of trans-
port, unless the vehicle is dedicated to radioactive materials
service only, and so marked, pursuant to §173.443(d), in which
case the 22,000 d/m/100 cm2 limit applies at the start of trans-
port.
o §173.443(c) requires a survey of an exclusive-use vehicle (and
also, presumably the dedicated vehicles) after transport of pack-
ages that indicate removable contamination above the Table 10
limits, but within the "factor of ten" higher limit of 22,000
d/m/100 cm2.
o §173.443(c) does not address quantitative limits on the surface
of the vehicle during the survey, however, the vehicle may not be
released for other service until the 2,200 d/m/100 cm2 and 0.5
mrem/hr limits are met.
o Noncompliance with §173.443(c) would therefore exist if the
survey to return a vehicle to service was not performed, and/or
the contamination or radiation dose rate on the vehicle exceeded
the stated limits upon its release for other service.
Attachment 5
IN 85-46
June 10, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-45 Potential Seismic Interaction 6/6/85 All power reactor
Involving The Movable In-Core facilities holding
Flux Mapping System Used In an OL or CP
Westinghouse Designed Plants
85-44 Emergency Communication 5/30/85 All power reactor
System Monthly Test facilities holding
an OL
85-43 Radiography Events At Power 5/30/85 All power reactor
Reactors facilities holding
an OL or CP
85-42 Loose Phosphor In Panasonic 5/29/85 All power reactor
800 Series Badge Thermo- facilities holding
luminescent Dosimeter (TLD) an OL or CP
Elements
85-41 Scheduling Of Pre-Licensing 5/24/85 All power reactor
Emergency Preparedness facilities holding
Exercises a CP
85-40 Deficiencies In Equipment 5/22/85 All power reactor
Qualification Testing And facilities holding
Certification Process an OL or CP
85-39 Auditability of Electrical 5/22/85 All power reactor
Equipment Qualification facilities holding
Records At Licensees' an OL or CP
Facilities
85-38 Loose Parts Obstruct Control 5/21/85 All PWR facilities
Rod Drive Mechanism designed by B&W
holding an OL or CP
85-37 Chemical Cleaning Of Steam 5/14/85 All pressure water
Generator At Milestone 2 reactor facilities
holding an OL or CP
OL = Operating License
CP = Construction Permit
SSINS No. : 6835
IN 85-45
WHO COUNTY C^ INRERS
UNITED STATES r1
(i 7r1`1, C7r? rs
NUCLEAR REGULATORY COMMISSION " G� '' ;.;
OFFICE OF INSPECTION AND ENFORCEMENT : JUN 1 8
WASHINGTON, D. C. 20555
1985 I
June 6, 1985
IE INFORMATION NOTICE NO. 85-45: POTENTIAL SEISMIC INTERACTION INVOLVING THE
MOVABLE IN-CORE FLUX MAPPING SYSTEM USED IN
WESTINGHOUSE DESIGNED PLANTS
Addressees:
All power reactor facilities holding an operating license (OL) or a construction
permit (CP).
Purpose:
This information notice is provided as notification of a potentially generic
problem involving seismic interactions within the movable flux mapping system
at Westinghouse designed plants. It is expected that recipients will review
the information for applicability to their facilities and consider actions, if
appropriate, to preclude a similar problem from occurring at their facilities.
However, suggestions contained in this information notice do not constitute
requirements and, therefore, no specific action or written response is required.
Description of Circumstances:
On June 22, 1984, Carolina Power and Light (CP&L) Company informed the Nuclear
Regulatory Commission (NRC) of a potentially reportable item per the provisions
of 10 CFR 50. 55(e) and 10 CFR 21 at their Shearon Harris Nuclear Power Plant
(SHNPP) Unit 1. The NRC was informed that interactions between the nonsafety
related portions of the flux mapping system and the tubing/seal table during a
seismic event had not been adequately considered by Westinghouse. At that time
CP&L was waiting for Westinghouse to perform a structural integrity analysis
for the portion of the in-core flux mapping system that is located above the
in-core instrumentation tubing/seal table. In a letter dated February 12, 1985,
CP&L informed the NRC that the potential seismic interactions were indeed
reportable.
The potential interactions exist because portions of the flux mapping system
that have not been seismically analyzed are located directly above the in-core
instrumentation tubing/seal table. Failure during a seismic event could possi-
bly cause multiple failures in the flux mapping tubing or fittings that would
produce a small break loss of coolant accident. Recent discussions with
Westinghouse have revealed that the potential seismic interactions could exist
at other Westinghouse plants including operating plants. Furthermore, multiple
failures of flux mapping tubing and/or fittings constitute an unanalyzed small
break loss of coolant accident because the break flow would effectively be from
8506060677
IN 85-45
June 6, 1985
Page 2 of 2
the bottom of the reactor vessel . Thus , the consequences could be beyond the
licensing design basis for loss of coolant accidents. It should be noted that
any loss of reactor coolant system pressure boundary integrity caused by seismi-
cally induced failures in the flux mapping system would be outside the design
basis of a plant and, therefore, unacceptable, regardless of whether the conse-
quences were within those for loss of coolant accidents analyzed in safety
analysis reports.
The NRC staff has discussed this issue with the Westinghouse Regulatory Response
Group. Based on discussions with the Regulatory Response Group and Westinghouse,
it is our understanding that Westinghouse will notify their customers of this
problem by letter in the near future.
No specific action or written response is required by this information notice;
however, contingent upon the results of further staff evaluations, a bulletin
or a generic letter requesting specific licensee actions may be issued. If you
have any questions regarding this matter, please contact the Regional Admini-
strator of the appropriate NRC regional office or this office.
as
afar Jordan, Director
Divisio of Emergency Preparedness
and E ineering Response
Office of Inspection and Enforcement
Technical Contact: David Powell
(301) 492-7155
Attachment: List of Recently Issued IE Information Notices
Attachment 1
IN 85-45
June 6, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-44 Emergency Communication 5/30/85 All power reactor
System Monthly Test facilities holding
an OL
85-43 Radiography Events At Power 5/30/85 All power reactor
Reactors facilities holding
an OL or CP
85-42 Loose Phosphor In Panasonic 5/29/85 All power reactor
800 Series Badge Thermo- facilities holding
luminescent Dosimeter (TLD) an OL or CP
Elements
85-41 Scheduling Of Pre-Licensing 5/24/85 All power reactor
Emergency Preparedness facilities holding
Exercises a CP
85-40 Deficiencies In Equipment 5/22/85 All power reactor
Qualification Testing And facilities holding
Certification Process an OL or CP
85-39 Auditability of Electrical 5/22/85 All power reactor
Equipment Qualification facilities holding
Records At Licensees' an OL or CP
Facilities
85-38 Loose Parts Obstruct Control 5/21/85 All PWR facilities
Rod Drive Mechanism designed by B&W
holding an OL or CP
85-37 Chemical Cleaning Of Steam 5/14/85 All pressure water
Generator At Milestone 2 reactor facilities
holding an OL or CP
84-55 Seal Table Leaks At PWRs 5/14/85 All power reactor
Sup. 1 facilities holding
an OL or CP
85-20 Motor-Operated Valve Failures 5/14/85 All power reactor
Sup. 1 Due To Hammering Effect facilities holding
an OL or CP
OL = Operating License
CP = Construction Permit
SSINS No. : 6835
IN-85'-44, n ;EPS
UNITED STATES ' ' 77`
NUCLEAR REGULATORY COMMISSION , (OFFICE OF INSPECTION AND ENFORCEMENT 1 ' J(JN 1rgjg85r
WASHINGTON, D. C. 20555
May 30, 1985 •.
IE INFORMATION NOTICE NO. 85-44: EMERGENCY COMMUNICATION SYSTEM MONTHLY TEST
Addressees:
All nuclear power reactor facilities holding an operating license and NFS
Erwin, General Atomics, UNC Montville, B&W LCR Lynchburg, and B&W Lynchburg.
Purpose:
This information notice is being issued to bring malfunctions of the communi-
cation system to the attention of licensees and remind them of their responsi-
bility to test required communication systems in accordance with 10 CFR 50. It
is expected that recipients will review the information for applicability to
their facilities and consider actions , if appropriate, to preclude a similar
problem occurring at their facilities. However, suggestions contained in this
information notice do not constitute NRC requirements; therefore, no specific
action or written response is required.
Discussion:
Section 50. 54(q) of Part 50 requires licensees to follow emergency plans which
meet the requirements of Appendix E to Part 50. Section IV. E. 9. d of Appendix E
requires monthly tests of provisions for communicating with NRC from the control
room, the Technical Support Center, and the Emergency Operations Facility.
Licensee emergency plans might contain additional testing requirements.
Emergency preparedness exercises and specific tests by NRC Headquarters Opera-
tions Officers have identified serious communication malfunctions, which were
previously undetected because of inadequate monthly testing. In most of those
cases, neither the Emergency Notification System (ENS) nor Health Physics
Network (HPN) telephones were found to have been tested routinely.
This Information Notice reminds licensees of their responsibility for satisfy-
ing the requirement for monthly testing of the ENS and HPN telephones. The NRC
is responsible for testing ENS and HPN telephones located in the NRC Resident
Inspector' s office and for testing the link between the NRC Operations Center
and the Regional Office Operations Center since communications with the licensee
via HPN and ENS are completed through the Headquarters Operations Center.
This Information Notice also clarifies that violations in this area may be
categorized at Severity Level III , and civil penalties may be considered.
8505280195
IN 85-44
May 30, 1985
Page 2 of 2
Compliance with the regulation cited above may be achieved through implementa-
tion of the testing scheme shown in Attachment 1.
The primary system for emergency communications with the NRC is a combination
of the ENS and the HPN. Licensees should note that the backup means of
communications for a given link is not required to be tested unless the primary
system is not available.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the Regional
Administrator of the appropriate Regional Office or the technical contact
listed below.
Edk. Jorda�or
Divi n of Emergency Preparedness
an Engineering Response
Office of Inspection and Enforcement
Technical Contact: H. M. Hawkins, IE
301-492-4145
Attachments:
1. Testing of Emergency Communications Links
Between Licensees and NRC
2. List of Recently Issued IE Information Notices
Attachment 1
IN 85-44
May 30, 1985
TESTING OF EMERGENCY COMMUNICATIONS LINKS BETWEEN LICENSEES AND NRC
The matrix below indicates the primary modes of operation for the NRC communi-
cations links which are to be tested monthly by the licensee.
FROM 10
Headquarters*
Control Room ENS only
Technical Support Center ENS and HPN
Emergency Operations Facility ENS and HPN
ENS = Emergency Notification System
HPN = Health Physics Network
* Communication between the Licensee and appropriate Regional NRC Office
will always be completed through the Headquarters Operations Center.
The communications link between the Headquarters Operations Center and
the Regional Office is tested by NRC.
Attachment 2
IN 85-44
May 30, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-43 Radiography Events At Power 5/30/85 All power reactor
Reactors facilities holding
an OL or CP
85-42 Loose Phosphor In Panasonic 5/29/85 All power reactor
800 Series Badge Thermo- facilities holding
luminescent Dosimeter (TLD) an OL or CP
Elements
85-41 Scheduling Of Pre-Licensing 5/24/85 All power reactor
Emergency Preparedness facilities holding
Exercises a CP
85-40 Deficiencies In Equipment 5/22/85 All power reactor
Qualification Testing And facilities holding
Certification Process an OL or CP
85-39 Auditability of Electrical 5/22/85 All power reactor
Equipment Qualification facilities holding
Records At Licensees' an OL or CP
Facilities
85-38 Loose Parts Obstruct Control 5/21/85 All PWR facilities
Rod Drive Mechanism designed by B&W
holding an OL or CP
85-37 Chemical Cleaning Of Steam 5/14/85 All pressure water
Generator At Milestone 2 reactor facilities
holding an OL or CP
84-55 Seal Table Leaks At PWRs 5/14/85 All power reactor
Sup. 1 facilities holding
an OL or CP
85-20 Motor-Operated Valve Failures 5/14/85 All power reactor
Sup. 1 Due To Hammering Effect facilities holding
an OL or CP
OL = Operating License
CP = Construction Permit
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