IR 05000277/1993027

Insp Repts 50-277/93-27 & 50-278/93-27 on 931004-10.No Violations Noted.Major Areas Inspected:Alara,Planning for Radiological Work,Radiation Worker Practices,Training & Qualifications & Shipping of LLW for Disposal

ML20058D343
Person / Time
Site:	Peach Bottom
Issue date:	11/23/1993
From:	Bores R, Eckert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058D270	List: IR 05000277/1993027 ML20058D264
References
50-277-93-27, 50-278-93-27, NUDOCS 9312030133
Download: ML20058D343 (15)

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i U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Repon Nos.

50-277/93-27, 50-278/93-27 Docket Nos.

50-277, 50-278 l

License Nos.

DPR-44, DPR-56

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Licensee:

Philadelphia Electric Company (PECo)

Nuclear Group Headquaners Cormspondence Control Desk

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i P. O. Box 195

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Wayne, Pennsylvania 19087-0195 Facility Name:

Peach Bottom Atomic Power Station (PBAPS)

Inspection Period:

October 4-8, and November 8-10,1993 Inspectors:

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3 L. Ecken$ Radiation Specialist ate Facilities Radiation Protection Section R. Fernandes, Reactor Engineer, Reactor Projects Section 2B

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Approved By:

// /2.3 /PS R. Bores, C4ief Date Facilities Radiation Protection Section l

Areas Inspected: The first portion of the inspection included ALARA, planning for

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radiological work, radiation worker practices, traiaing and qualifications, and shipping of l

l low-level wastes for disposal. Additional inspection was conducted to evaluate PECo's

actions associated with entries into high radiation areas and a respintory protection required

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area without satisfying radiological safety reqmrements.

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Results: Good performance was noted by the radiological engineering and radiological controls technician (RCT) staff. No radiation worker practice discrepancies were noted J

during the first ponion of the inspection. A weakness was noted concerning the ability to j

provide emergency response information in accordance with 49 CFR 172. No violations of

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regulatory requirements were identified in the first ponion of the inspection. Based on the results of the second portion of the inspection, the two improper high radiation entries and the improper respiratory protection required area entry are apparent violations.

9312030133 931124 PDR ADOCK 05000277 G

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DETAILS

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1.0 Personnel Contacted i

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f 1.1 Station Personnel

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' H. Abendmth, Atlantic Electric Site Representative

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S. Baker, Radwaste Manager

j L. Beddy, Senior Radiological Controls Technician (RCT)

j M. Blasciak, Senior RCT, Bartlett i

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O. Brown, Materials Manager l

J. Carey, Public Service Electric & Gas Representative

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J. Curran, Maintenance Supervisor

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j M. Dedrich, Health Physics (HP) Supervisor i

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- D. Dicello, Radiological Engineering Managei

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D. Droddy, Radiological Engineer j

' B. Downey, HP Supervisor

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8 W. Eckman, Acting Manager Nuclear Quality Assurance

j G. Edwards, Plant Manager j

R. Farrell, Support Health Physics Manager

'2 D. Ferguson, Senior RCT, Banlett

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'# G. Gellrich, Senior Manager Operations

D. Goodell, System Manager d

G. Haney, Plant Equipment Operator

f C. Hardee, HP Instructor

W. Harris, Radiological Engineer, Limerick Generating Station j

M. Horvatinovic, Radiological Engineer

B. Jefferson, Shift Supervisor t

l S. Kohlbus, HP Supervisor

q S. Lee, Nuclear Quality Assurance (NQA) Engineer l

L. MacEntee, Shift Supervisor

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' G. McCarty, Services Training Manager l

B. Miller, Radiological Engineer

' D. Miller, Vice President PBAPS

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i J. Mitman, Component Engineering Manager l

'# M. Moore, Radiation Pmtection Manager (RPM)

j T. Niessen, Engineering Director l

D. O'Connell, Radiological Engineer j

M. Parcell, Senior RCT, Banlett

' Denotes attendance at the second exit meeting held on November 10, 1993.

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2Denotes attendance at the first exit meeting held on October 8,1993.

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J. Purcell, Senior RCT

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R. Simpson, Engineer 2 G. Smith, HP Supervisor 32 R. Smith, Regulatory Engineer

D. Stein, Senior RCT, Banlett

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2 A. Stuan, Balance of Plant Engineering Manager D. Sware, Radiological Engineer 2 H. Trimble, HP Supervisor

B. Wallace, Senior RCT, Banlett 2 B. Wargo, Nuclear Quality Assurance (NQA) Assessor T. Wasong, Experience Assessment Manager

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M. Weaver, Shift Manager C. Whitaker, Senior RCT, Banlett

i Other licensee personnel were contacted during the inspection.

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1.2 NRC Personnel i

P. Bonnet, Resident Inspector i

R. Bores, Chief, Facilities Radiation Protection Section

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' R. Fernandes, Reactor Engineer I

i R. Lorson, Resident Inspector i W. Schmidt, Senior Resident Inspector 2.0 Purpose and Scope The October 4-8,1993, ponion of this inspection was to review the overall safety effectiveness of the licensee's implementation of its ALARA program, planning for l

radiological work, radiation worker practices, training and qualifications of radiation j

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protection personnel, and shipping of low-level radioactive wastes for disposal.

The purpose of the November 8-10,1993, ponion of this inspection was to review two entries into posted high radiation areas and an entry into a respimtory protection equipment

required area without satisfying the radiological safety requirements. The NRC reviewed these three events and PECo's response primarily to assure that radiological protection of plant perennel was being maintained.

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The NRC review during both ponions of the inspection included interviews with cognizant personnel, including supervisors and managers; review of applicable technical specifications, i

procedures, and instructions; documentation; and observation of activities in progress. In

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addition, the second ponion of the inspection included analysis of the physical barriers in place at the time of each event.

3.0 ALARA/ Work Planning Good planning and control of radiological work was noted in the reactor water cleanup (RWCU) in-senice inspection (ISI) and control rod drive (CRD) exchange jobs. The ability to develop radiation work pemlits (RWPs) in an efficient manner for emergent work was evident.

The inspector also observed a " rad hold" placed by the drywell HP Supervisor on a drywell 151', O degree RWCU insulation removal job. Additional shielding was to be emplaced the following day and delaying the job was determined to have no effect on the seturn to critical path. This action was assessed by the inspector as appmpriate and was indicative of good ALARA awareness on the working level.

The inspector attended a Schedule Discipline Meeting and noted that it was a goad work planning initiative which will help avoid wasted dose, i.e., dose accrued as a result of preparing for a job more than once prior to its actual initiation.

At the time of the first ponion of the inspection, the accmed dose on the drywell ISIjob was observed to be exceeding the radiological engineering staff's expectation and would likely fall well outside the dose goal for the job. The inspector did note appmpriate radiological engineering staff response in that a Work In Pmgress (WIP) review was initiated and a Station ALARA Committee (SAC) meeting was held as the revised dose estimate to complete the job exceeded 25 person-rem. In a future inspection, the inspector will review the lessons learned from this outage and the licensee's plans for implementing these lessons learned to minimize future accmed dose as a result of drywell ISI work.

A more detailed evaluation of the licensee's ALARA performance will be undenaken in a subsequent inspection.

4.0 Radiation Worker Practices At the time of the first portion of this inspection, the inspector noted that there had been few refueling outage related Personnel Contamination Repons (PCRs) and Performance Enhancement Program (PEP) repons generated to that point in the outage. As previously noted in NRC Inspection Repon 50-277/93-19, the PEP discrepancy resolution system has replaced the Radiological Occurrence Reponing (ROR) and Reportability Evaluation / Event

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Investigation Fonn (RE/EIF) systems. Most of the more radiologically challenging work l

was completed by the end of the first ponion of this inspection. No poor radiation worker j

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practice wonhy of note was found by the inspector during this ponion of the inspection.

The inspector also noted that the RCTs were aggressive in helping to ensum good radiation worker practices. Seveml senior RCTs were interviewed to detennine the quality of working

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level relationships with other station groups. The RCTs expressed general satisfaction in the

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mlationship with those work gmups and, also, with station management.

l 5.0 Training & Qualifications Twenty individuals passed the National Registry of Radiation Protection Technicians

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(NRRPT) exam, including one health physics trainer, one physicist, and 18 RCTs. The

inspector noted that this was a good initiative.

i The inspector reviewed 18 contractor resumes to detennine whether the individuals wem appropriately qualified to carry out their outage-assigned responsibilities. The inspector j

noted that the licensee was conservative concerning accmditing time status for senior radiological controls technicians in accordance with ANSI /ANS 3.1 - 1981. No discrepancies were noted.

6.0 Shipping of Low-Level Wastes / Materials for Disposal, and Transportation The inspector conducted an off-hours test of the licensee's ability to provide information in accordance with 49 CFR 172. Funher positions / guidance in this mgard were promulgated in NRC Infonnation Notice 92-62. The test was intended to be open-book, and focused on the i

adequacy of emergency response procedures and how the shift staff were trained on these.

Also, the shift-staff were not denied the ability to contact outside expenise (in this case members of the station's radioactive waste branch). The licensee's Radiological Engineering Manager observed this activity.

In summary, the test posed was as follows.

The inspector informed the shift staff that a test was being conducted and.that they-

should not activate their emergency response facilities in response to the test.

The shift staff were informed that one of the licensee's radioactive waste shipments

(the shipment number was provided) had turned over in Nonh Carolina and the trailer bed was on fire.

The driver was incapacitated by the accident.

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The shift staff were informed that the inspector was acting as the lead fire chief who

had responded to the accident.

The shift staff were asked to provide the appmpriate emergency response information.

• Time Action 1017 The inspector made the first call to the control room. The line was busy.

1024 The inspector reached the Shin Administrative Assistant (SAA). The inspector described the incident to the S AA.

1025 The SAA concluded that she was unable to handle the question and had the Shin Technical Advisor (STA) ansuer the phone. De inspector described the incident to the STA.

1026 The STA concluded that he u as unable to handle the question and had the Shift Manager (SM) answer the phone. The inspector described the incident to the SM. The SM asked numerous questions concerning the shipment (the inspector was later informed that the shipment manifest was raw readily available in the control room).

1034 The SM informed the inspector that he needed to hang up and would call back. The inspector stated that he should hurry and call back as the mformation was needed before fighting the simulated fire.

1043 SM called back to provide the appropriate emergency response information.

While the call demonstrated adequate licensee capability in this area, the call did, however, provide the following indicators that merit licensee consideration from the viewpoint of determining whether training (and/or associated tests) should be strengthened or re-oriented to better assure maintenance of the ability to respond to this type of event, as noted in the Infonnation Notice cited above.

The licensee needs to ensure that appropriate emergency response information is

provided within 15 minutes.

Licensee staff should not hang-up on the caller.

• Shipment manifests need to be more readily available to whomever has the

responsibility of providing off-hours emergency response information for radioactive waste / materials shipments.

This area will be re-examined during a subsequent inspection.

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l 7.0 Event Descriptions

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7J October 27.1993 Hich Radiation Area (HRA) Entry On October 27,1993 two senior contractor RCTs discovered a plant equipment operator (hereafter called opemtor) exiting a high radiation area on the Unit-3165'-elevation by the

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fuel pool (FP) coolers. The RCTs challenged the opemtor on whether all requirements had been met prior to entry. The RCTs interpretation of the operator's response was that the operator had been given permission to enter the area by the operations RCT. Alsa, it i

appeared to both RCTs that this individual possessed a digital alarming dosimeter (DAD).

One of the contractor RCTs chose to ensure that all pmcedural requirements had been met and initiated a call to the operations RCT. At that time, the operations RCT conveyed that l

the operations RCT had not provided the required briefing for entry into the FP cooler HRA.

The RCTs then discussed this situation with the on-shift HP Supenrisor who initiated a PEP at that time. By chance, the same RCTs were in the HP instmment cage when the opemtor turned in a DAD. Funher investigation on the pan of the contractor RCTs showed that the DAD had been set to alarm at a cumulative exposure of 256 mmm rather than at the typical

setting (typically set at 128 mrem when provided to an operator) provided by operations RCTs. Also, they found that the alarming dosimeter had not been signed out that evening.

This information was also conveyed to the HP Supervisor.

The inspectors interviewed the HP Supen'isor who explained how he initiated the PEP. In summary, as the operator was found by contmetor RCTs who were not familiar with this particular indis ' tal, the HP Supenisor discovemd the identity of the operator by security

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The inspectors interviewed the operator who conveyed that he recognized that he was entering a HRA, he had been previously briefed on what the dose rates were in the area (but not this shift), and planned to complete his task within a couple of minutes. The operator also conveyed that he did not contact the operations RCT nor any other RCT to receive a briefing prior to the HRA entry. The operator also stated that he was not in possession of a DAD as the RCTs had believed. When questioned by the inspectors, the operator conveyed that his radiation worker training had been adequate and that there was no dictate from

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l management to complete the job within a specified time period.

October 28.1993 HRA Entry On October 28,1993, operations personnel were attempting to restore the Unit-3 service water system to service. Personnel were sent to several service water vent valves to close them in suppon of the restoration process. At about 1725 hours0.02 days <br />0.479 hours <br />0.00285 weeks <br />6.563625e-4 months <br />, Opemtor 1 pmceeded to the Unit-3 reactor building near the fuel pool heat exchangers in order to verify that tygon tubing (direct discharge into floor drain) which had been attached to a FP heat exchanger

l vent was still in place. Upon arrival, Operator I noted that the tygon tubing had blown off and a senice water leak of 20 to 30 gpm was in pmgress. Operator I contacted the contml mom and reponed the leak to Shift Supervisor (SS) 1.

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SS 1 then contacted SS 2 and the Service Water System hianager to have them mspond to the leak. Meanwhile, RCT 1 arrived in the area while conducting a routine tour. Operator 1 -

and RCT 1 then left the area to make preparations for the HRA entry to shut the vent valve.

At 1729 hours0.02 days <br />0.48 hours <br />0.00286 weeks <br />6.578845e-4 months <br />, SS 2 arrived at the FP heat exchanger area and mdioed the operations RCT (RCT 2) requesting that the RCT respond to the area with a DAD. The System hianager also arrived at the area at about this time. Without pausing to fully contemplate his actions, the System Manager proceeded to climb the ponion of a rigging scaffold that was outside the l

HRA and proceeded across the vertical plane of the HRA boundary to shut the vent valve.

At this time, Operator 2 arrived in the area after hearing a repon of the problem. Shonly themafter, the System hianager secured the leak. Operator 1 and RCT 1 returned to the r

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area. After a discussion, it was determined that additional actions were needed. At 1733 hours0.0201 days <br />0.481 hours <br />0.00287 weeks <br />6.594065e-4 months <br />, the RCT 2 arrived and questioned Opemtor 2 on whether he had entered the HRA.

l Operator 2 informed RCT 2 that he had not entered. RCT 2 did not pursue the matter

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further.

Once licensee evaluation of the events described in Sections 7.1 and 7.3 of this repon l

became common knowledge throughout the station, the individuals involved in the above i

event re-evaluated their own actions and whether their msponse had been appropriate. After discussing the situation with Operator 1, SS 2 mitiated a PEP.

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The inspectors interviewed the System hianager (and other individuals involved in this event). When questioned the System hianager conveyed that he did understand the preparatory requirements associated with HRA entries and that his radiation worker training

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was sufficient for him to carry out his assigned duties. The System hianager also conveyed that he did not fully contemplate the situation prior to carrying out his actions.

i The inspectors concluded that the System hianager understood the ramifications of his actions

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i and the imponance of following good radiation worker practices.

l Figure 1 provides a licensee dmwing created after the rigging scaffold had been removed.

l All individuals interviewed by the inspectors agreed that this drawing was representative of the scaffolding and HRA boundary locations.

2J October 29.1993 Respiratory Protection Requimd Area Entry On October 29,1993, an engineer prepared to evaluate insulation within the Unit-3 drywell and take pictures of a residual heat removal (RHR) testable check equalizer valve and three other similar valves. These pictures were needed to assist in trouble-shooting deficiencies found as a result of pmssure testing these valves.

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Prior to drywell entry, the engineer was briefed by RCT I (a contractor). The engmeer was

i told to stay below elevation 157' due to in-progress fuel movement and above 135' due to l

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contamination concerns below that elevation. RCT 1 also pmvided information on the

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j radiological conditions near the RHR testable check equalizer valve noted above. The area

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j around this valve was roped-off and posted "mspiratory pmtection equipment required",

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since the insulation had been recently removed in the area. RCT 1 told the engineer that he j

should not enter this roped-off area. The engineer was also told that air samples had been

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taken (approximately 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />) and the results would be available later. At that time, the l

engineer felt that taking the pictums fmm outside the roped-off ama would meet his needs.

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Prior to entering the drywell, RCT 2 who was monitoring radiation worker undressing,

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j reaffirmed to the engineer that he should not enter the roped-off area and also offemd to take l

l the pictures for tia engineer. The engineer declined this offer. Upon entering the drywell, l

RCT 3 (the drywell RCT mver) also conveyed to the engineer that he should not enter the

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roped-off area. The engineer attempted to take pictures from outside the roped-off area, but could not get acceptable pictures because insulation blocked part of the valve from view and j

the distance was too great.

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During the inspectors' interview with the engineer, he conveyed that he decided to find out if l

the airborne sample results had been obtained and whether the respiratory protection i

equipment mquirement could be removed. He exited the drywell and proceeded to the first j

step-off pad and attempted to get the attention of a drywell control point RCT. The engineer j

conveyed that the RCT was very busy at that time and the engineer decided not to interrupt.

l At this time, RCT 3 was conducting a survey on drywell elevation 116' and RCT 1 was j

counting the air samples taken after insulation removal.

j The engineer then re-entered the drywell. The engineer proceeded into the roped-off area to i

take the pictures. During the inspectors * interview with the engineer, the engineer conveyed

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that he had reasoned that since the insulation had been mmoved about a half-hour before and the drywell ventilation system was operating, there was little likelihood of any suspended

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radioactive material remaining in the mped-off ama. Subsequently, the engineer was found j

in the roped-off area by RCT 3, who told him to leave the area. The engineer asked if it j

would be acceptable for him to remain in the drywell to take other pictures. RCT 3 allowed j

this to take place and did not exercise stop work authority.

RCT 3 then informed RCT 2 of what had taken place. Subsequently, RCT 2 informed RCT -

1, who had by this time returned from the air sample counting facility. RCT 1 then took j

action to remove the engineer from the drywell and informed the drywell HP Supervisor of ~

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the event. This information was then conveyed to the Radiation Pmtection Manager and a-j PEP was initiated at this time.

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When questioned by the inspectors, the engineer conveyed that his radiation worker training had been adequate, but he had made very few drywell entries since PECo's reorganization.

The engineer also conveyed that although there was pressure to complete the outage, <mtion management had neither dictated nor condoned avoiding safety requirements in order to complete tasks more quickly. The engineer confirmed that he had been instructed by RCTs 1, 2, and 3 not to enter the respiratory protection required area and that RCT 2 had offered to take the pictures for him. The engineer confirmed that he entered the respiratory protection required area without a respirator.

The inspectors concluded that the radiological safety significance of the event was low since the insulation removal team lapel air samples ranged from 1.3 to 3.3 MPC-hours at a nearby valve. The low-volume air sample result was 0.6 MPC-hours and the general area air sample result was < 7.5x10' microCi/cm gross activity. These samples were taken at

least forty minutes prior to the engineer's entry into the respiratory protection required area.

The engineer successfully frisked out of the radiologically contmiled area and was not whole body counted.

Figure 2 provides a licensee drawing of the 135'-elevation respiratory protection required area. The engineer agreed that this drawing was representative of the boundary as it existed.

One radiological controls weakness was noted in the response to this event. The drywell roving RCT allowed the engineer to stay in the drywell to take pictures of other drywell areas, instead of using stop work authority when appropriate.

8.0 NRC Conclusions

Aoplicable Requirements Licensee Procedure A-C-107, " Radiation Work Permit and Radiological Controlled Area Access Requirements", requires that individuals be responsible for the following.

Complying with established posting in the RCA.

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Complying with the requirements of the appropriate RWP.

Notifying HP of any radiological problems encountered during RCA entries.

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Notifying Health Physics of any change in radiological conditions during RCA entries.

Complying with written and oral radiological instructions given by HP.,

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Technical Specification (TS) 6.1I states that " procedures for personnel radiation protection

shall be prepared consistent with requirements of 10 CFR Pad 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."

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TS 6.13.1 states, in pan, "In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20, entrance into an HRA shall be controlled by issuance

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of a Radiation Work Pennit. Any individual or group of individuals pennitted to enter such

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areas shall be provided with or accompanied by one or more of the following.

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A mdiation momtoring device which continuously

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indicates the radiation dose mie in the area.

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A radiation monitoring device which continuously integrates the radiation dose

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rate in the area and alanus when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

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An individual qualified in radiation protection procedures who is equipped with

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a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over activities within the area and shall perfonn

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periodic radiation surveillance at the frequency specified by the plant health

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physicist or his designee on the Radiation Work Permit."

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October 27.1993 HRA Entry

i The entry into the FP heat exchanger HRA by the plant equipment operator without pmper HRA controls, proper briefing, and proper adherence to the HRA posting constitutes an apparent violation (50-277/93-27-01).

The incident was promptly and properly reported to NRC.

• The violations were self-identified by the licensee.

• j The results were of low radiological safety consequence.

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Licensee event investigation was very good. Nothing additional of great relevance

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was learned in the interviews conducted by the inspectors.

Significant disciplinary actions have been taken.

• M October 28.1993 HRA Entry

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The entry into the FP heat exchanger HRA by the system manager without pmper HRA controls, proper briefing, and proper adherence to the HRA posting constitutes an apparent violation (50-277/93-27-02).

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The incident was promptly and properly reported to NRC.

• The violations were self-identified by the licensee.

• The results were of low radiological safety consequence.

• Licensee event investigation was very good. Nothing additional of great relevance

was leamed in the interviews conducted by the inspectors.

At the time of the second ponion of the inspection, the licensee was still investigating

this issue and had not detennined whether disciplinary actions wem appropriate in this case.

8.4 October 29.1993 Resoiratory Protection Recuimd Area Entry The entry into the drywell 135'-elevation RHR valve 46B respiratory protection mquired area by the engineer without the proper respiratory protection area controls, proper briefing, and proper adherence to the posting constitutes an apparent violation (50-277/93-27-03).

The incident was promptly and properly reported to NRC.

• The violations were self-identified by the licensee.

• The results were of low radiological safety consequence.

• Licensee event investigation was very good. Nothing additional of great relevance

was leamed in the interviews conducted by the inspectors.

Significant disciplinary actions have been taken.

!L5 Rverall The inspectors concluded that the radiological safety consequences of the three events were minimal. However it appears that, some radiation workers wem not properly sensitized to radiation health and safety. The inspectors found that this was a causal factor to some degree in all three events. Also, some radiation workers were not properly sensitized to the importance of compliance with instructions provided by radiological contmls staff.

NRC considers these events as significant because of the following reasons.

Two of the events appear to be willful in nature.

• Although the events were of low safety consequences, any failure to comply with

established radiological safety controls is important.

The three events happened in a short period of time.

• Previous examples of complacency towards radiation health and safety have been

identified.

PECo and NRC have identified worker complacency toward radiation health and safety as a causal factor in several events over the past several years. It is recognized by the NRC that licensee management had attempted to address this problem in preparation for the Unit-3

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refueling outage by using broad methods, applicable to all station personnel. Such attempts included formal communication fmm upper management and enhanced supen'ision. Based on the concems identified above, the inspectors concluded that PECo has not been fully effective in maintaining proper worker sensitivity toward radiation health and safety.

It is also important to note that in all three cases those involved had rationalized the radiological safety consequences of their actions to some degree prior to carrying out the actions described in Section 7.0, rather than deferring such decisions to those personnel trained and experienced in dealing with the hazard.

With the exception of the failure to exercise stop work authority noted in Section 7.3, the

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licensee radiological controls staff's response to these three events was appmpriate.

9.0 Exit Meeting The inspectors met with licensee representatives at the end of the first part of the inspection, on October 8,1993. The inspectors reviewed the purpose and scope of the inspection and discussed the findings. The licensee acknowledged the findings and stated their intention to address the issue contained in Section 6.0.

Additional inspection of the licensee's radiological controls progam was conducted on November 8-10,1993. The findings for this portion of the inspection were pmvided on November 10,1993. The licensee acknowledged the findings and stated their intention to address the issues contained in Section,__

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C A L.DUE INSTRUWENT TYPE I.N.

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