ML20216E560

Forwards Response to Violations Noted in Insp Rept 70-7001/97-04.Corrective Actions:Naf Oven Disconnected from Naf Trap Jet & Restricted from Use on 970807

ML20216E560
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	09/04/1997
From:	Polston S UNITED STATES ENRICHMENT CORP. (USEC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
70-7001-97-004, 70-7001-97-4, GDP-97-1029, NUDOCS 9709100236
Download: ML20216E560 (17)

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I ntkhment corpwatuin Padmih Site Office P O ika 1410 radmah KY 42001 hl $02 441.%03 Iat: 502 441.%01 September 4,1997 United States Nuclear Regulatory Commission SERIAL: GDP 97-1029 Attention: Document Control Desk Washington, D.C. 20555 Paducah Gaseous Diffusion Plant (PGDP)

Docket No. 70 7001 Response to Inspection Report (IR) 70-7001/97004 Notices of Violation (NOVs)

Nuclear Regulatory Commission (NRC) letter dated August 5,1997, transmitted the subject IR which contained six NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 1-6. Enclosure 7 lists the commitments made in this report.

Unless specifically noted, th.: corrective actions specified in each enclosure apply solely to

PGDP, If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.

Sincerely,

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Enclosures (7)

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a ENCIOSURE1 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY 10 NOTICE OF VIOLAT10N (NOV) 70 7001/97004 01 Techr.ical Safety Requirement 3.4 requires, in part, that individuals relied upon to operate the 1

plant in a safe manner are properly trained.

Flant procedure CP3 CO C01003," Organization and Administration," required that only quallfled operators or trainees operate equipment or systems in Building C 310.

Yblation Cited Contrary to the above, as of Jtr ; 9,1997, Dullding C 310 operators, individuals relied upon to operate the plant in a safe rnanner, had not been trained on the design and nomial and off nonnal operation of the recently im thd sodium fluorUc production oven. Specifically, management i

operated a sndium fluone goduction oven in Building C-310 from March 3 through June 9, 1997 without training building operators on those aspects of oven operations which required 1

control to ensure that the plant was operated in a safe tunner.

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1.

Reason for the Violation 4

The reason for the violation was the Facility owner for C 310 failed to follow UE 2-TO.

E01031(Modi // cation Design Control) for training and procedural requirements. This individual authorited operability of the sodium fluoride production oven by signing the Modification Master Checklist (Fonn UE 74, UE2 TO E01031), but failed to recognize that by approving operability the oven now fell within the requirements of section 5.7.3 of CP*rCO-C01003, Organfration and Adtninistration for " Qualified Operators". As noted in the cited violation, this procedure requires that only qualified operators or trainees operate equipment or systema in Building C 310. The reason this procedure requirement was not recognized was that,in the past, management had allowed non operators (e.g. engineers) to test and operate equipment aller it had been accepted by Operations.

11.

Corrective Actions Taken and Results Achieved The NaF oven wm disconnected from the NaF trapjet and restricted from use on August 7, 1997. Training M operators on the NaF oven will need to be verified prior to restart. Operations has determined that no similar issues exist where engineers are operating equipment in violation of CP3-CO C01003.

111.

Corrective Actions to be Taken

1. By September 10,1997, Operations will issue a memorandum to all facility owners clarifying the responsibilities associated with authorizing operability for any El 1 i

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modifications as defined in UE2-TO E01031,

2. Operations and Systems and Design Engineering will conduct crew briefings by October 17,1997, to communicate the expectations for the operation of equipment by "Quallfled" operators as defined in CP3 CO C01003.

IV.

Date of Full Compliance USEC achieved full compliance with the requirements of this violation when the NaF oven was removed from service on June 10 following the incident. Actions to prevent recurrence will be completed by October 17,1997.

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s, ENCLOSURE 2 UNITED STATES ENRICllhiENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATlON (NOV) 70 7001/97004-06 10 CFR 76.93," Quality Assurance," requires,in pan, that the cenlilcatee shall establish and execute a Quality Assurance Program.

Section 2.11 of the Quality Assurance Prognan," Test Control." requires in pan, that the test control system provide measures to ensure that test procedures include provisions establishing prerequisites, such as appropriate equipment test conditions.

Violation cited Contrary to the above, on hiarch 13,1997, the cenificatee failed to establish appropriate test conditions, in that preventive maintenance adjustments were made to the autoclave head to shell alignment prior to the perfonnance of the Technical Safety Requirement periodic surveillance test.

1.

Backcround Information The Pinch (Fit) Test was developed and implemented to gather data on the degradation of the autoclave 0 ring and to reduce the number of steam leaks at the head to shell interface of the autoclaves. The test measures the scaling capability (autoclave containment) at the head to shell interface on the autoclaves in C-333 A, C-337A, and C 360. The head to stall interface is the most used component of the autoclave containment boundary due to the fact it is cycled every time a cylinder is loaded / unloaded. The procedure which contains the Pinch Test (CP4 GP.

h1M4159," Alignment Check of UF Autoclave llead to Shell, and 0 ring Replacement")

6 provides guidance on perfomiance of the test and also provides direction for correcting the results of any degradation. The conrctions include the adjustment oflimit switches and/or the changing of the 0 ring. which can result in an improvement to the autoclave containment.

The pinch test is perfonned quarterly and is considered a preventive maintenance task. The test is scheduled with other preventive maintenance tasks and other quarterly surveillances. Because the adjustments that can be made affect containment, NRC concluded that this was preconditioning the autoclaves for the pressure decay quanerly surveillance when the pinch test is conducted before the surveillance. In this case, limit switches were adjusted prior to performing the quarterly pressure decay surveillance.

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Jkasan for the Violation The reason for this violation was that requirements regarding preconditioning were not adequatclu described in implementing procedures for maintenance and operations. The problem ofpreconditioning of TSR surveillances with preventive maintenance task had been previously identi.1ed in an NRC Observation Repon (95004). While the corrective actions associated with the observation repon did review existing surveillance / test procedures and practices, there were no procedural guidelines provided for future reviews of preventive maintenance (Pht) task. The procedure establishing the pinch test ( CP4 OP Mh14159) was developed aller the NRC observation report was issued and corrective actions had been completed.

l 111.

Corrective _ Actions Taken and Results Achieved 1

1. USBC has changed the procedure which governs pinch test (CP4 OP hih!4159,

" Alignment Check of UF Autoclave llead to Shell, and 0 ring Replacement") to include the addition of a prerequisite step and of notes throughout the body of the procedure to alert personnel perfonning the pinch test of the need for an as found pressure decay test iflimit switches are to be adjusted.

2. Functional Directive 97 025 was issued by Work Control on August 26,1997, to require all preventative maintenance task / work packages which are associated with TSR surveillances be routed through engineering for interim screening to prevent preconditioning of TSR surveillances. This action will remain in elrect until PM tasks / work requests have been reviewed and incorporated into ChihiS.

.IV.

Corrective Action to be Taken Ily September 30,1997, CP2 EG EOl030," Preventive hiaintenance Program," will be revised to include steps necessary for initial identification of TSR Surveillances required prior to

- Preventive Maintenance.

V.

Date of Full Comnllance USEC is currently in full compliance with this violation. The corrective actions to prevent recurrence will be completed by September 30,1997.

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s ENCLOSURE 3 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97004 09 Technical Safety Requirement 3.9 requires, in part, that written procedures shall be developed, approved, implemented, and maintained for activities described in the Safety Analysis Repon, Section 6.11, Appendix A.

l He Safety Analysis Report, Section 6.11. Appendix A describes changes to facilities and equipment and modification design control as activities requiring written procedures.

Violation Clini Contrary to the above, between March 3 and June 19,1997, activities were conducted to change or modify equipment using installation instructions and test plans which were not developed, approved implemented, or maintained (changed) in accordance with Technical Safety Requirement 3.9. Specifically,1) the modification test plans were not reviewed and approved by the Plant Operations Review Committee (PORC); and 2) changes to the modification installation instructions and test plans, including acceptance criteria, were not reviewed to detemiine if the changes required PORC approval.

r 1.

Reasons for the Violation Test plans for Engineering Service Order (ESO) Z90830 were revised twice without being resubmitted to the PORC for approval. These actions failed to comply with procedure CP3 EG-E01074," Design Document Change Process," which requires that such changes receive a written engineering evaluation to reconcile any deviations from the approved design intent and to detennine if the changes require a revision to the Plant Change Review (PCR) and subsequent PORC approval.

Responsible individuals failed to implement the procedure requirements because they were not aware that the Test Plans must be handled as design output documents. The root cause for this condition is a failure of training to address this element of the modification process.

It should be noted that the cited violation states that the modification test plans were not reviewed and approved by PORC. Ilowever, each of the test plans for ESO Z90830 were included and addressed when the associated modification was originally presented to and approved by the PORC on November 5,1996.

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Corrective Actions Taken and llesults ArXts.yni

1. Engineering evaluations were completed by August 14,1997, for the revised test plans, vacuum testing acceptance criteria, and maintenance instructions for ESO Z90830 in accordance with plant procedures. 'lhe revised test plans and associated review documentation have been reviewed and approved by the PollC.

2. Engineering management implemented a stop work order and recall on August 8, y

1997, of modification work packages that had been issued to construction and maintenance crafts and had not been declared operable. This action was taken to ensure that similar problems did not exist with other modifications. The review of recalled work packages will be in accordance with the Modification Installation Package itecovery Plan, dated August 8,1997. '

3. Training on this issue was provided to all design engineering personnel in the fonn of a required reading / crew briefing doenmentation package describing the methods used for implementation of modification test plans and the change process to be used for changes to test plans. This was completed on August 21,1997.

111.

Corrective Actions to be Taken None IV.

Date of Full Compliants USEC achieved full compliance on August 14,1997, following completion of engineering evaluations associated with ESO Z90830,"C-333A/337A Instrument Upgrade,"its associated Work Packages and PollC approval of associated test plans. The actions to prevent recurrence were completed on August 21,1997, with the required reading / crew briefing.

' USEC recognizes the need to complete this action to assure that similar concerns do not exist in other modi 0 cations certined for construction, llowever, we are not committing to a specific date to complete the review of the recalled packages.

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ENCLOSURE 4 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97004 10 10 CFR 76.68(a) provides, in pan, that the certificatec may make changes to the plant's operations, as described in the Safety Analysis Repon, without prior Commission approval provided that the changes to the Safety Analysis Report do not decrease the effectiveness of the plant's safety, safeguards, or security programs or involve an unreviewed safety question.

- 10 CFR 76.4 defines, in part, an unreviewed safety question as a change which increases the probability of occurrence of a malfunction of equipment imponant to safety previously evaluated in the Safety Analysis Report.

Violation Cited Contrary to the above, on April 2 and June 20,1997, the certificatee made changes to the plant's operations, as described in the Safety Analysis Report, without prior Commission approval and "ithout evaluating whether the changes decreased the effectiveness of the plant's safeguards program or involved an unreviewed safety question. Specifically, on April 2,1997, the certificatec approved an increase in the nossession limits of uranium which allowed possession of a Category 11 quantity of special nuclear material and did not evaluate the impact change on the effectiveness of the Category 111 safeguards program. On June 20,1997, the certificatee approved a change to delete the five year surveillance frequency for the cell trip function and did not evaluate whether the change increased the pmbability of occurrence of a malfunction of equipment important to safety, an unreviewed safety question.

1.

Reason for the Violation The reason for the violation was that the icvel of detail and technical rigor contained within the Plant Change Review (PCR) documentation for the proposed changes were inadequate to fully convey the logie used to reach the conclusions presented. Procedures UE2.RA RR1036, "10CFR76.68 Plant Change Reviews," and UE2 EO.NS1030,"Unreviewed Safety Question Detennination," require that the evaluator ensure that the analysis is appropriate, technically correct, provides a basis for the conclusion, and should contain sufficient information such that independent reviewer will reach the same conclusion and understand the logic. Specifically,in the case of the possession limit change (RAC 97C015), the SE for this RAC states that the number "9.95"in Table 1-3 of the SAR was changed to "10" with thejustification that Note that nofissile materialpossession limit specyled in this table is being increased, Therefore, the preparers and evaluators of this SE viewed this change as administrative in nature to allow the possession limits to be extended up to the maximum permissible amount (i.e.,9.99 percent),

llowever, the actual revised words (i.e., up to 10 percent) could possibly have allowed the possession of enriched uranium beyond the allowed limits in the certificate basis with no evaluation supporting this change.

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In the case of the revision to the cell trip surveillance frequency, as noted in the iR, the SE for RAC 97C014 Revision 2, did not address the long term reliability concerns or safety impacts aswclated with removing the SAR requirementjbr testing the trip circuit every/lveyears. This was due to a lack of attention to detail by the SE preparer and reviewers. As funher noted in the IR, the PCR for the SE erroneously stated that the change was editorial 'this is reflective of a lack of adequate training and monitoring of expectations to ensure the PCR and SE fully and adequately support the approved changes to the SAR.'

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Corrective Actions Taken and Results Achieved

1. NOV 9700410 was discussed in the PORC meeting on August 19,1997, re-emphasizing the management standards and expectations for technical rigor and level ofdetail. Attendees of this meeting included the managers of Nuclear Safety and Nuclear Safety Analysis.

2. PODP Nuclear Regulatory Affairs issued a memorandum to appropriate plant management directing that the possession limits in efTect before RAC 97C015 was approved, continue to be enforced until a new RAC (i.e.,97C0189) can be approved which will clarify the possession limits (i.e, up to but not including 10 percent enrichment).

3. Paducah issued a memorandum to preparers, reviewers and approvers of PCR documentation re emphasizing the management standards and expectations for the technical rigor and level of detail required to adequately assess proposed plant changes.

IV.

Corrective Actions to be Taken

1. Provide refresher training on Lessons Leamed from Instances ofinadequate PCRs (and related Safety Evaluations) and the memo re emphasizing management standards and expectations for the technical ngor and level of detail required to adequately assess proposed plant changes to PCR evaluators, reviewers, and approvers by November 1,1997.

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2. Nuclear Regulatory AfTalrs will ensure that a review ofcompleted PCRs will be incorporated into their Internal Sun'elliance Program in accordance with CP2 QA-QS1031," Conduct ofInternal Surveillances," to verify that the technical content and logic are adequate. One surveillance will be completed by October 31,1997, and at least one will be included in future surveillance schedules.' (Currently SE's are reviewed as part of Engineering's intemal surveillances.)

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3. USEC will review RAC 97C014, R2 and the associated SE (97-018. RI) and decide by September 26,1997, to either delete SAR changes associated with RAC 97C014, R2 or revise the SE to address NRC concerns.

V.

Date of Full Comollance USEC is currently in full compliance with the requirements as stated in this violation since neither the revisions to the possession limits nor the changes for the cell trip surveillance have been implemented. Actions to prevent recurrence will be completed by November 1,1997.

_ 'It thould be noted that the change to the cell trip surveillance ftequency has not yet been implemented since it is part of a Certificate Amendment Request that is still pending NRC review and approval.

2 JSEC recognizes the need to complete this action as an enhancement to the process but does not t

consider this a regulatory commitment.

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ENCLOSURE 5 i

UNITED STATES ENRICllMENT CORPORATION (USEC)

RESPONSB TO NOTICE OF VIO!ATION (NOV) 70 7001/97004 11 Technical Safety Requirement 3.11.5 requires, in part, that the double contingency principle, as stated in the Safety Analysis Report, be used as the basis for the design and operation of processes using fissionable materials.

Section 5.2.2.3 of the Safety Analysis Report," Process Evaluation and Approval " defines the double contingency principle as follows: " Process designs should,in general, incorporate sulTicient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible. The Paducah Gaseous Diffusion Plant (PGDP) nuclear criticality safety (NCS) program applies this principle by implementing controls either on two different parameters or by implementing two controls on ene parameter."

ylolation Cited Contrary to the above, from March 3 through June 19,1997, the double contingency principle was not used as the basis for the operation of storing selected legacy process equipment containing fissionable materials (fissile or potentially fissile materials). Specifically, the certificatee failed to implement controls on two different parameters, mass or enrichment (assay) and interaction (spacing), for some 220 to 260 items oflegacy proecss equipment with unknown mass or assay identified during a plant walkdown subsequent to June 19.

1.

11ackpround infonnation During 1996, Nuclear Criticality Safety Approval (NCSA) OEN 27. "llandling and Storage of Legacy Process Equipment," was prepared to provide requirements for bringing previously uncontrolled legacy process gas equipment w hich had only been exposed to UF. at PGDP into compliance with the double contingency principle. Also, NCSA GEN-20," Receipt, Transportation, Storage, and Disposition of UF. Process Equipment from Off Site," was written to provide requirements for bringing uncontrolled legacy process gas equipment which originated from, or had been exposed to, UF, at the K-25 or Portsmouth GDP into compliance with the double contingency principle.

During early 1997, an action plan was implemented at PGDP pursuant to NCSA GEN 27 to space legacy process gas equipment items at least two feet edge to edge from each other and from other fissile or potentially fissi!c material, after perfonning gross non-destructive analysis (NDA) scans. A list of this equipment was developed to facilitate full characterization at a later date, And iflegacy equipment was identified that could not be confirmed to be from PGDP, such was handled in accordance with NCSA GEN 20.

Subsequently,in June 1997,it was detennined that not all of the legacy equipment had been ES t

scanned for gross activity. Rather, items had only been spaced at least two feet edge to-edge and placed on the NCSA GEN 27 list.

11.

Reason for the Violation The reason for the subject violation was inadequate communication during the implementation at PODP of the action plan in early 1997 to identify, scan and space legacy equipment in accordance with NCSAs OEN 27 and GEN 20, The work was a unique initiative undertr. ken on an expedited basis with less than adequate orientation / training of the involved personnel. As a i

result, the individuals involved in the identification effort did not understand the need for perfonning NDA scans on legacy equipment; and the PODP NCS organization did not recognize that all legacy process gas equipment had not received the required qualitative NDA scans. This resulted in the cited failure to satisfy the double contingency principle for the affected equipment

items, i

111.

Corrective Actions Taken and Results Aehleved

1. After detennination by PODP personnel on June 19,1997, that not all legacy process gas equipment had received an NDA scan for gross activity,immediate action was taken to place the plant in a safe condition by ceasing the movement of all potentially fissile material that fell within the coverage of NCSA GEN 27 or GEN 20. Also, NRC was infomied of the incident on June 19 (Event Notification Worksheet Number 32516), with a follow up written notification on June 20,1997 (USEC Letter ODP 97-1018),

2. On June 20,1997, a site wide walkdown was initiated to identily all applicable equipment and to place such items in a safe configuration pending disposition pursuant to NCSA GEN 27 or GEN 20. This effort was completed on June 23,1997,

3. Beginning June 24,1997, approximately 185 individuals were trained relative to the NCSA GEN 27 and OEN 20 requirements for the storage oflegacy process gas equipment at PGDP.

4. Following assay characterization, proper spacing and tagging or posting, as required, double contingency protection was confinned/ established by August 4, for all applicable items, as reported to the NRC by our letter of August 6,1997 (USEC Letter GDP 971025).

5, NCSA GEN 27 was revised effective August 5,1997, to stipulate that,in the event legacy items are discovered that cannot be adequately characterized for uranium loading prior to movement, a complete inspection, purcuant to applicable provisions of the NCSA, shall be performed as soon as possible for each piece of such equipment.

6. It was detennined that no other PODP NCSAs had vulnerabilities such as contained in NCSAs GEN 27 and GEN 20.

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IV.

l'orrective Actions to be Taken i

None.

- V.

Date of Full Compliance Full compliance with applicable requirements was achieved on August 4,1997. The actions listed above provide assurance that identified legacy process gas equipment at PCDP is stored in accordance with applicable nuclear criticality safety criteria and that the cited conditions / situations should not recur.

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ENCLOSURE 6 UNITED STATES ENRICilh1ENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97004 13 Technical Safety Requirement 3.2.2.b requires, in part, that administrative procedures shall be developed and implemented to limit the working hours of facility staff w ho perform safety functions.

Technical Safety Table 3.2.2.1,"h11nimum Stalling Requirements," specifies that four security guards shall be onsite at all times.

Violation cited Contrary to the cbove, as of July 14,1997, management had neither developed nor implemented administrative procedures to limit the hours of work of security guards, individuals who perfonn safety functions.

1 l.

Reason for the Violation The reason for this violation was due to a misunderstanding as to the application of TSR hours of work limitations to site security personnel. As documented in USEC letters to NRC dated June 26,1997 and July 31,1997 (reference USEC letters GDP 97-0109 and GDP 97 0127, l

respectively), since hiarch 3,1997, USEC has been operating on the basis that the limitations I

were not a requirement for security personnel. Our position was based on the action plan established to implement the Plan of Action and Schedule for the Compliance Plan Issues on Administrative Controls on Overtime and with NRC guidance for nuclear power reactors contained in Generic Letters 82-12 and 83 14. As a result of discussions with NRC on this issue, by letter dated July 18,1997, NRC notified USEC that they disagreed with our position and stated that NRC considers all staff specifically mentioned in the minimum stalling table to be covered by the hours of work TSR.

11.

Corrective Actions Taken and Results Achieved

1. On July 21,1997, USEC applied the site procedure for TSR administrative control of hours of work to security guards, as it applies to security issues. All Police Operations' front line managers (FLhis) were instructed to complete deviation requests for any personnel that were detemiined to exceed the limitations. (The deviation requests are completed pIlm to the individual being allowed to work.)

2. On August 13,1997, Police Operations began utilization of the Overtime Canvassing System (OCS) system. (The OCS will provide supervisors with accurate tracking of security guard overtime.)

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3. On August 13,1997, a decision was made to reduce the number of SPos utilized for Criticality Accident Alarm System (CAAS) outages on the weekends and night shifts.

Only one SPO, with the assistance of shift personnel, will be utilized on an overtime basis to crect the CAAS boundary and to provide a presence at a CAAS boundary portal. (This change reduced the number of security guards required to work overtime on weekends and nights.)

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Corrective Actions to be Taken i

1. The reduction in the number of SPos utilized for CAAS outages on days (Monday through Friday) will be phased in as the installation of CAAS flaming (permanent) is l

cornpleted. The flagging installation 1:: scheduled for completion by October 31, 1997. [When this occurs, only one (1) SPO, instead of five (:i), will be required to support CAAS outages. Once this project is complete, the number of necessary TSR hours of work variance requests should be significantly reduced, in the interim, as the flagging around individual buildings is completed, the SPO support (perimeter control support) will be reduced.)

l IV.

Date of Full Compliance Full compliance will be achieved by October 31,1997, when the CAAS flagging installation is completed. This action will stop the routine use of" hours of work" variance requests.

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ENCLOSURE 7 LIST OF C0hiMITMENTS l

1. Ily September 10,1997, Operations will issue a memorandum to all facility owners l

clarifying the responsibilities associated with authorizing operability for any moditications as l

delined in UE2 TO E01031.

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2. Operations and Systems and Design Engineering will conduct crew briefings by October 17, 1997, to communicate the expectations for the operation of equipment by " Qualified" oper, ;as defined in CP3 CO C01003.

1. By September 30,1997, CP2 EO E01030," Preventive Maintenance Program," will be revised to include steps necessary for initial identification of TSR Surveillances required prior to Preventive Maintenance.

None Enclosure _4

1. Provide refresher training on Lessons Leamed from Instances ofinadequate PCRs (and related Safety Evaluations) and the memo re emphasizing management standards and expectations for the technical rigor and level of detail required to adequately assess proposed plant changes to PCR evaluators, reviewers, and approvers by November 1,1997.

2. USEC will review RAC 97C014. R2 and the associated SE (97 018 R1) and decide by September 26,1997, to either delete SAR changes associated with RAC 97C014, R2 or revise Qe SE to address NRC concems, None

1. The reduction in the number of SPos utilized for CAAS outages on days (Monday through Friday) will be phased in as the installation of CAAS flagging (permanent) is completed.

The flagging installation is scheduled for completion by October 31,1997. [When this E71 l

4 occurs, only one (1) SPO, instead oflive (5), will be required to support CAAS outages.

Onde this project is complete, TSit hours of work variance requests will not be routine. In the interim, as the flagging around individual buildings is completed, the SPO suppen (perimeter control support) will be reduced.]

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