ML082270208

Response to Request for Additional Information Regarding NRC Bulletin 2007-01, Security Officer Attentiveness

ML082270208
Person / Time
Site:	Fermi
Issue date:	08/07/2008
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-07-001, NRC-08-0050
Download: ML082270208 (3)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, Ml 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy-10 CFR 50.54(f)

August 7, 2008 NRC-08-0050 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

1) Fermi2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison Letter to NRC, "60-Day Response to NRC Bulletin 2007-01, Security Officer Attentiveness," NRC-08-0009, dated February 11, 2008

3) NRC letter "Fermi 2 - Request for Additional Information RE:

Security Bulletin 2007-01 (TAC No. MD7600)," dated July 11, 2008 Subject; Response to Request for Additional Information Regarding NRC Bulletin 2007-01, "Security Officer Attentiveness" Reference 3 requested additional information to complete the NRC staff assessment of the Fermi 2 response to NRC Bulletin 2007-01, "Security Officer Attentiveness." provides Detroit Edison's response to the request for additional information. No proprietary, safeguards, or classified information is contained in this response.

No new commitments-are made in this letter.

USNRC NRC-08-0050 Page 2 Should you have any questions or require additional information, please contact Mr.

Ronald W. Gaston of my staff at (734) 586-5197.

Sincerely,

Enclosure:

Response to Request for Additional Information, NRC Bulletin 2007-01, "Security Officer Attentiveness" cc:

NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region m Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-08-0050 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Joseeh H. tplona Site Vice President - Nuclear Generation On this 7

day of Q R

,2008 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public OTl REMUgrA*

AE ov m WOMOUMN Jn 4,01

USNRC NRC-08-0050 Page 4 bcc:

M. S. Caragher W. A. Colonnello J. M. Davis R. W. Gaston K. J. Hlavaty J. H. Plona K. C. Scott S. Stasek C. M. Walker Electronic Licensing Library (ELL) (200 TAC)

Information Management (140 NOC)

Michigan Department of Environmental Quality Radiological Protection and Medical Waste Section NSRG Administrator (200 TAC)

NRR Chron File J. P. Flint R. J. Salmon E. L. Sandy T. P. Stack

Enclosure to NRC-08-0050 Response to Request for Additional Information, NRC Bulletin 2007-01, "Security Officer Attentiveness"

Enclosure to NRC-08-0050 Page 1 NRC Bulletin 2007-01 requested Detroit Edison to provide information regarding administrative programs and managerial programs and controls established to prevent, identify and correct security personnel inattentiveness, especially complicity, and failures to implement the Behavioral Observation Program (BOP) by individuals among Fermi 2 security personnel including security contractors and subcontractors.

Reference 2 provided Detroit Edison's response to NRC Bulletin 2007-01, "Security Officer Attentiveness," for Fermi 2. Reference 3 requested additional information to complete the NRC staff assessment of the Fermi 2 response. This enclosure provides Detroit Edison's response.

Detroit Edison's response is provided herein following each question presented in Reference 3.

QUESTION 1 Describe the process for security post rotations including the rotation process for isolated positions.

Include the following information in your response:

A description of the security post rotation process including, but not limited to: (1) a discussion of the types of posts a typical security officer would rotate through during a normal shift; (2) a discussion on whether the type of activity (i.e. roving or foot patrol or stationary in a Bullet Resisting Enclosure [BRE]) performed at each individual post is taken into consideration when a security officer moves from post to post throughout the shift; and, (3) the length of time at each post. When responding, particular emphasis should be placed on whether the licensee takes into consideration the activities associated with each post assignment when formulating their post rotation schedules for each shift (i.e., rotating from foot patrol to BRE to Vital Area patrol or rotating from BRE to ready room to BRE etc.).

RESPONSE

• Fermi 2 Nuclear Security utilizes a standard Daily Post Assignment roster which shows post rotation sequence for security personnel during a specific shift.

All five security shifts utilize the same post assignment schedule; however the frequency of post rotations between the Alarm Stations is different between day and night shifts and on weekends and holidays due to differences in activity level. Low activity levels result in increased post rotation frequency.

" The Daily Post Assignment roster shows how each security post rotates throughout the shift and is indicated on the roster.

Enclosure to NRC-08-0050 Page 2

" The Daily Post Assignment rosters are developed in advance for specific work cycles. Post rotations are modified by Security Supervisors periodically if there is a need to change a rotation (e.g. a compensatory measure is established), or to support emergent work.

" Security officers are not typically assigned to the same post for consecutive days in a row during a work cycle. Exceptions do occur, particularly if a security officer is on a restriction that limits the type of post he or she is allowed to work. (e.g. officer is medically restricted from lifting a particular amount of weight, or can only stand for a specified period of time.)

" Daily Post Assignment rosters are completed in advance of the work cycle typically by a security officer and provided to a security supervisor for review.

" Typically, officers start their shift at a given post and rotate among up to four different posts during a given shift depending on their daily post assignment for that shift.

" Posts are rotated in the following manner:

Internal (Inside the Power Block) post rotations occur at an increased frequency. This is in support of two temporary compensatory measures. These temporary compensatory measure posts are somewhat remotely located and one of the compensatory measure posts is located in a high heat area. As a result, increased rotations of these two compensatory measure posts have been implemented.

When compensatory measures are not in effect, Internal and External (Outside the Power Block) post rotations occur at designated periods. Breaks are provided upon the security officer's request.

The following are specific responses to three items in question 1:

(1)

Officers rotate through three types of posts;

1. Fixed posts

2. Patrols

3. Utility posts.

The type of post an officer rotates through is predetermined and standardized across shifts. For example, an Alarm Station Operator might start out in the Central Alarm Station (CAS) on the day shift for a designated period, rotate to a Utility post for a designated period, and then rotate to the Secondary Alarm Station (SAS) for a designated period. On the Daily Post Assignment roster, this would appear as: CAS/V-l/SAS.

Another example is D-12/D-8/D-9. In this instance the rotation is a mobile patrol for a

Enclosure to NRC-08-0050 Page 3 designated period to a fixed post for a designated period then to another fixed post for a designated period.

Compensatory measure posts rotate at an increased frequency, based on environmental conditions and other factors as described in Security Department Instruction (SDI) 48, "Conducting Security Post Evaluations and Post Inspections," Section 8.

(2)

The type of activity and level of activity on each post was taken into consideration when post rotations were reviewed by Security leadership in accordance with the Nuclear Energy Institute (NEI) Post Evaluation Guidance. Some posts rotate between static positions; these posts are provided with ample time between post rotations to allow the officer to take an adequate break. In addition, officers are encouraged to request additional breaks whenever they feel they need one. Attentiveness aids for each post were assigned with careful consideration being given to the activity level on each particular post in accordance with the NEI Post Evaluation Guidance.

(3)

The length of time spent on each post was evaluated by Security Management in response to NRC Bulletin 2007-01. Consideration was given to the activity level associated with each post with emphasis on changing activity levels during different times of the day.

Post rotations that could be changed to allow an officer to go from a fixed post to a mobile patrol or utility post were changed. Where the rotation sequence was not changed, the frequency of the rotation was increased per the NEI Post Evaluation Guidance. The guidance provided an assessment tool, used by Fermi 2, to evaluate post rotation sequence and frequency. Included in the consideration of post rotation frequency was the officer's ability to use approved attentiveness aids. If additional attentiveness aids were not approved because the location was evaluated as a Level 1 Post (high level of focus without distraction), the rotation frequency was increased. For example, CAS is a level 1 post and as a-result, is allowed very limited attentiveness aids. As a result, CAS rotates at an increased frequency on backshifts, weekends and holidays (both day and night shifts) when there is low activity level vs. a standard rotation on a regular weekday during dayshift. Guidance for Supervisors in evaluating and determining appropriate rotation frequency is outlined in SDI-48, Conducting Security Post Evaluations and Post Inspections.

Enclosure to NRC-08-0050 Page 4 QUESTION 2 Describe any licensee processes or programs that are in place to identify problems in climate controlled security areas. What methods are used to track, inspect, and ensure timely repairs are completed?

Include the following information in your response:

A description of how the security areas are maintained including, but not limited to: (1) a discussion of the maintenance and/or preventive maintenance process and programs in place for these security areas including an overview and brief discussion on routine inspection schedules by maintenance personnel; (2) a discussion on the process a security officer can follow to report concerns with the up keep and maintenance of his or her post; and, (3) a discussion on the timeliness of repairs and any follow up actions taken by the licensee to ensure the repairs are' completed and resolved adequately.

RESPONSE

The following is a list of programs and/or processes in place at Fermi 2 for inspecting and identifying deficiencies in climate controlled security areas.

1. Security Management Tour Rating Sheet

2. Security Supervisor Post Inspections

3. Security Officer self-reports The following is a list of programs and/or processes in place at Fermi 2 for tracking deficiencies.

1. Security on-line Maintenance book

2. Station Work Control Process

3. Corrective action program reports, known as Condition Assessment Resolution Documents (CARDs) at Fermi 2, are initiated to track reports of climate problems resulting from tours, inspections and officer self-reports.

There is a dedicated Security Maintenance Coordinator who tracks identified climate related problems and interfaces with appropriate Maintenance personnel (e.g. Electrical Maintenance and Instrument & Controls Maintenance) to ensure equipment is repaired.

Security Supervisors attend daily Station Work Screening Committee meetings and CARD Ownership meetings to ensure that security equipment and climate control units receive the correct level of attention.

Enclosure to NRC-08-0050 Page 5 House keeping tours by supervisors and officers detect climatic problems and CARDS are generated to initiate repair.

The following are specific responses for the items in question 2.

(1)

Station work control processes implement preventive maintenance for maintaining the climate control units for the Primary Access Portal (PAP), Alternate Access Portal (AAP), as well as CAS and SAS.

Currently there are no Preventative maintenance (PM) programs in place for the climate control units at Fermi Drive Gate (Main Gate house), the BulletResistant Enclosures (BREs), or booths.

(2)

The Security officer can report concerns:

" Directly to their supervisor or management.

" By initiating a CARD and tracking the progress through the work control process.

" By submitting a suggestion or concern to the Security "Q7 Account" which is an internally (within Nuclear Security) established process for reporting issues and receiving feedback. Security personnel are able to electronically view the progress and results of the suggestions or concerns submitted at any time. Additionally, updated hard copies of the "Q7" tracking sheet are posted in the Security break room weekly. If appropriate, certain suggestions or concerns from the "Q7" account are entered into the station corrective action process.

(3)

Repairs to climate control equipment in designated security areas are completed in accordance with the Fermi 2 Work Control processes. CARDs are initiated for inoperable equipment and the CARDs are processed in accordance with site procedure MWC06, "Work Screening and Processing." This means that CARDs submitted for repairs are screened through the Work Control process and assigned a work priority based on the Online Work Prioritization. Normally, repairs to climate control units in Security areas are timely and compensatory actions are implemented where personnel are affected by the heat or cold or where' equipment has the potential to be damaged by high or low temperature.

When modifications are required, the station follows the plant modification process.

Compensatory actions are implemented to reduce the effect on personnel and equipment as appropriate until installation of the modification is completed. An example of a compensatory action is the installation of a portable air conditioning unit at a compensatory measure post in the auxiliary building.

Enclosure to NRC-08-0050 Page 6 The Security maintenance coordinator and Security Supervisors attend daily work screening meetings which provide them with the opportunity to communicate priorities and to voice concerns when it appears that the incorrect prioritization has been placed on the equipment.

Security Supervisor and Manager follow up actions include interfacing with Maintenance Supervision and Management, working with the Security System Engineer, and initiating additional CARDs if unreasonable delays to equipment repair occur. Additionally, the Manager, Nuclear Security also elevates attention when repairs are unreasonably delayed during the daily Operational Focus meeting and Station Management Meetings such as the Quarterly Station Self-Evaluation meeting. These avenues have improved repair timeliness and generally result in an adequate response from the station.

QUESTION 3 What is the level of involvement from management who do not have direct responsibility for the security program (including executive and corporate management) in conducting behavior observations of security personnel?

Include the following information in your response:

A description of any processes in place for licensee and/or contract management, who work day to day at the site or visit the site on a routine basis from a corporate office or other applicable offsite location, for conducting behavior observations of security personnel while on duty at their assigned posts. Examples should include, but are not limited to, a discussion of random or scheduled observations conducted by licensee and/or contract management such as the Plant Operations Shift Managers (SM) or other Plant Operations Shift Supervisors, Plant Maintenance Supervisors (licensee and contractor), or Quality Assurance Supervisors etc. The discussion should include whether these random or scheduled observations are proceduralized and the required or recommended level of licensee and/or contract management involvement.

RESPONSE

Observations of Security personnel by senior site management including the Plant Manager, Site Vice President, and Chief Nuclear Officer, are conducted during management plant walkdowns, however, these observations are not proceduralized. Additionally, manager level personnel conduct daily plant tours under the Fermi 2 Field Manager of the Day Program. The Fermi 2 Field Manager of the Day Program (Rev. 2) provides station leaders with direction to visit Security Posts and to focus on officer attentiveness, environmental conditions, human performance and housekeeping. Lastly, the Nuclear Safety Review Group (NSRG) conducts tours of security areas. All site personnel with unescorted access to the Protected Area are required to complete Behavioral Observation training which includes instruction on the required actions to be taken if aberrant behavior is observed.

Enclosure to NRC-08-0050 Page 7 OUESTION 4 Are security personnel provided opportunities to participate in any personnel surveys regarding the work environment? If so, what is the frequency of the surveys, the average participation rate of security personnel as compared to the general site average, and the process for providing feedback and addressing the results from the survey?

RESPONSE

A Gallup Employee Attitude Survey was issued to Detroit Edison Security personnel (and all other Company employees) and allows security personnel an opportunity to voice any concerns about their work environment.

• The Survey is typically administered on an annual basis

• Average participation rate in the Security organization was approximately 63 percent

" By comparison, the general site average participation rate is 73 percent

" Results are reviewed by Supervisors with Security personnel. This feedback process allows security personnel to have direct input and participation in resolving issues. The Manager, Nuclear Security also reviews Gallup Employee Attitude Survey results at Security Update meetings when appropriate.

A Safety Conscience Work Environment assessment was conducted with Nuclear Security by an independent third party during the first quarter of 2008. The assessment process included interviewing a number of Security personnel including staff, officers, supervisors and the manager.

" This was a one time event

" Thirty-nine (39) interviews were conducted with Security organization personnel. The participation rate is not applicable.

" Participation rate compared to the general site population: Not applicable

" Feedback from the assessment was provided to the Security organization by the Manager, Nuclear Security during the second quarter Security Update meetings.

Additionally, a Utility Service Alliance (USA) Safety, Culture Pre-Assessment Survey was sent to all station employees including security personnel in preparation for the 2008 USA Safety Culture assessment. Participation rates are not available.

Enclosure to NRC-08-0050 Page 8 QUESTION 5 How is the licensee's policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?

RESPONSE

The Fermi 2 policy regarding employee attentiveness is communicated in the following ways:

" Detroit Edison Policy, EM I, "Standards of Conduct," applies to all Detroit Edison employees. Violation of safety rules and safe work practices, as well as sleeping on the job, are examples of unacceptable conduct

" Fermi 2 annual General Employee Training includes Fitness for Duty requirements Fermi 2 annual Behavioral Observation Training includes attentiveness as an attribute of work performance behaviors An annual Nuclear Generation Memorandum is issued by the Manager, Nuclear Security entitled "Fitness for Duty Reminder: Know What You are Taking," and is sent to employees via company email. This memorandum reminds employees that mental or physical impairments may adversely impact the ability to safely and competently perform their duties.

Conduct Manual MGA10, "Fitness for Duty," section 2.3.4, states that employees shall notify their supervisor when using prescription or non-prescription medication or experiencing extreme fatigue that may affect their ability to safely and effectively perform assigned job duties. Conduct Manual MGA 16, "Behavior Observation," section 2.3.2 states that employees have a responsibility to notify their supervisor when using prescription or non-prescription medication or experiencing extreme fatigue that may affect their ability to safely and effectively perform assigned job duties. Supervisors are required to restrict the employee's work involvement as appropriate.

Enclosure to NRC-08-0050 Page 9 QUESTION 6 Describe the process for employees to file reports through the site corrective action program (CAP). Can employees file CAP reports without prior supervisory/management review or approval?

Include the following information in your response:

Describe the process for employees to file reports through the CAP. Discuss the supervisor/management review and/or approval process including, but not limited to: (1) does a supervisor/manager have the authority to reject a report before entering it into the corrective action program without additional management review and approval; and, (2) does a supervisor/manager have the authority to modify the report before such report has been entered into the CAP.

RESPONSE

The CAP at Fermi 2 is implemented through the CARD process. Employees can file reports electronically, in hard copy format, or anonymously.

Supervisor review is required for all CARDs except those submitted anonymously. Any supervisor, including the Shift Manager, or above can review CARDs submitted electronically.

Anonymous CARDs are submitted on a hard copy form through the Fermi 2 Ombudsman or the Shift Manager which maintains the anonymity of the submitter.

Supervisors and Managers do not have the authority to reject a report before entering it into the CARD program. Supervisors and Managers can return the CARD to the CARD initiator to request additional information prior to the CARD moving to the next phase in the process, however, once information is entered into the CARD process electronically or in hard copy format, information can not be deleted.

Supervisors and Managers do not have the authority to modify reports before submitting them into the CARD program. Supervisors and Managers do have the ability to add documentation to the CARD in the form of notes or attachments.

Enclosure to NRC-08-0050 Page 10 QUESTION 7 Can the employees view the status and disposition of reports directly, or must this information be requested? If yes, please describe the process.

RESPONSE

Employees can view the status and disposition of reports at any time after they have been entered into the CARD process electronically. The employee can indicate whether they would like to receive feedback and whether they would like to be part of the solution team. If an employee indicates that they would like feedback then the employee is notified electronically when the CARD issue is resolved.

QUESTION 8 Are formal assessments of the security program conducted by organizations/individuals that do not have direct responsibility for the security program? If so, provide information on the process, including, but not limited to, the organizations and levels of management involved, the frequency of such activities, and any tracking of how findings are resolved.

RESPONSE

The NSRG Safety Oversight Subcommittee meets quarterly and conducts reviews of the Security Program as a part of its overall oversight activity.

Assessments of the Security program are conducted by the stations Quality Assurance (QA) organization on an annual basis. Assessment Findings identified by QA are tracked in the CARD program as audit findings. CARD action plans and CARD closures do not occur without QA review and concurrence.

Periodically, industry experts conduct assessments of portions of the Security program. For example, a Security Training assessment was performed in 2007 and a Safety Conscience Work Environment (SCWE) assessment was conducted by an external consultant in 2008.

Internal and external assessment reports are provided to station management including site senior management. These assessments are tracked in the CARD process.

Enclosure to NRC-08-0050 Page 11 QUESTION 9 How are self-assessment findings and relevant operating experience information communicated to the security force? Describe those processes including, but not limited to, information such as the criteria by which such information is identified, the frequency of such communications, the responsible department(s) or position(s) for such communications, and the recipients of such communications.

Include the following information in your response:

Describe the process including, but not limited to: (1)formal or informal communication methods; (2) procedures that ensure availability of the policy to staff; and, (3) training opportunities for staff to read and understand the policy.

RESPONSE

Internal/external self-assessment results are communicated in accordance with Conduct Manual MQA 16, "Self Assessment." Assessment results are documented in numbered correspondence memorandum and communicated to Organization Unit Heads and Managers, who are the primary customers of the self assessment. The results are also communicated to other managers being assessed, other groups being assessed, the Site Self-Assessment Coordinator and other site organizations that may benefit from the lessons learned captured during the self-assessment.

Findings that directly impact Security are communicated by Security Supervisors and Managers during shift briefings, meetings and in training sessions depending on the applicability of the information.

Relevant Operating Experience (OE) is generally identified by the Security human performance department coordinator via the Homeland Security Information Network (HSIN). CARDs are typically generated on relevant OE. Although not part of a formal process, once identified, relevant OE reports are sent to Security supervisors and the information is shared with the security force during training, shift briefing or other group meetings. When applicable, OE is incorporated into Security work instructions.

Enclosure to NRC-08-0050 Page 12 QUESTION 10 How do you assess the effectiveness of your oversight of contractors and subcontractors?

Include the following information in your response:

Describe the licensees' program for oversight of contractors and subcontractors including, but not limited to: (1) a brief overview and description of licensee 's procedures that describe the oversight process; (2) include a detailed list (bulleted is preferred) of assigned duties for the licensee supervisor(s) or manager(s) responsible for overseeing contractors and subcontractors at the site; (3) include a detailed list (bulleted is preferred) of the assigned duties for the contractor and subcontractor supervisor(s) or manager(s) responsible for overseeing the contractor and subcontractor staff at the site; and, (4) a brief discussion of the corporate (management) involvement with the oversight of contractors and subcontractors at the site.

RESPONSE

The Fermi 2 contractor and subcontractor oversight process is described in Fermi Business Practice (FBP-03), "Supplemental Personnel Control Practice." This business practice provides guidance to personnel assigned responsibility for the control of work by non-station utility and supplemental personnel to ensure contractor compliance with Fermi 2 policies, procedures and safe work practices.

The following responsibilities are described in FBP-03:

Organizational Unit Head:

• Assigns contractor control duties to Requisitioners, Contract Administrators, and Task Managers to ensure contractor control is maintained.

Requisitioner:

Responsible for the development of all specifications, schedules, budgets, and other matters necessary to describe the scope of a contract. This includes items such as contractor qualification, training requirements, and other issues particular to Fermi 2.

Contract Administrator:

" Ensures that the obligations of the Contractor and Detroit Edison are carried out as defined in the contract.

" Coordinates the activities required to address or resolve disputes involving procurement, legal, finance, engineering, and other areas as appropriate.

Enclosure to NRC-08-0050 Page 13

• Responsible for ensuring all administrative procedures are followed.

Task Manager:

Some contracts may be large and involve work in several areas. In these cases, it may be appropriate to name a Task Manager(s) in addition to a Contract Administrator to assist in administering the contract. The Task Manager must be aware of the Contractor Control expectations.

FBP-03, "Supplemental Personnel Control Practice" is utilized by contract employees as well as Detroit Edison employees. Non-station utility personnel and supplemental personnel conducting engineering, maintenance or modifications at Fermi 2 are controlled by and held accountable to the same policies and procedures as station personnel. They must be trained and qualified for the work they are to perform and shall receive the same general orientation training and retraining provided to new employees in accordance with Conduct Manual MNT08, "Certification of Qualification." Prior to performing work, non-station utility and supplemental personnel are required to meet the applicable requirements of Conduct Manual MNT02, "Training and Qualifications."

FBP-03, "Supplemental Personnel Control Practice," requires ongoing oversight of work and monitoring performance of supplemental personnel, typically performed at the supervisory level, including:

" Maintaining a supervisory role and avoiding becoming task facilitators

• Requiring methods be identified during development to monitor the progress and quality of work

" Establishing methods for integrating supplemental personnel with plant staff, communicating roles, responsibilities, and standards

" Consideration of how errors or potential problems are captured

" Consideration of quality of work performed

" Supervisory performance to identify problems and actively champion change FBP-03, "Supplemental Personnel Control Practice," requires assessment of supplemental personnel performance. This is typically performed at the supervisory level. This assessment is shared with the service provider and identifies opportunities for station staff improvement in interactions with supplemental personnel. Performance problems are captured in the CARD process.

Enclosure to NRC-08-0050 Page 14 The Fermi 2 Pursuit of Excellence Program consists of a compilation of individual area Excellence Plans. Each plan has an accountable Fermi 2 Director. One individual Excellence Plan is the Supplemental Staff Field Performance Excellence Plan. The Director Nuclear Production is assigned to this plan. Station leadership periodically reviews Excellence Plan status. The Human Performance Steering Committee provides oversight of the Supplemental Staff Field Performance Excellence Plan.

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