ML20058N574
| ML20058N574 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 08/10/1990 |
| From: | MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE |
| To: | |
| Shared Package | |
| ML20058N573 | List: |
| References | |
| NUDOCS 9008140206 | |
| Download: ML20058N574 (15) | |
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- 1 Table of Contena I
i QUALITY ASSURANCE PROGRAM IOR MITR II SPENT FUEL SHIPMENT P. age I
- 1. Purpose...........................................................................................I l l
- 2. Organization......................................................................................I !
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- 3. Program Req uirement s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
- 4. _ Shipping Container QA Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 r
- 5. Design Control and Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
- 6. - Procurement Document Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 7. Instructions, Proced ures, and Drawings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 -
- 8. Document Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
- 9. Control of Purchased Material, Equipment, and Services................................. 6
- 10. Identification and Control of Materials, Parts, and Components ......................... 6 1 1. Con trol of S pc cial Proc e s s e s.. . .. . . .. ... . .. .... ... . .. ... . . .. ... .... . .. ... . .. ... . .... ..... . . .. . 6
, 12. Inspection and Test Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 I i
- 13. Calibration of Measurement and Test Equipmcnt........................................... 9 4
l 14. Handling, S torage, S hipping, and Pre servation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
- 15. Inspection, Test, and Operating S tatus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 I
- 16. Nonconforming Material, Parts, or Components......................................... 10
- 17. Correc tive Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 18. Q u all t y A : s u ra n ce R ec o rd s. . . .. . . . .. . . .. .. . ... . .. . . . .... . . . . . ... . . . . . . ... . . . . . . . .. . . . . ..... . 10 L 19. Audits...........................................................................................I1 '
l, 2 0. R e fe r e n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1 Figure One: MITR Quality Assurance Organization Chart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Table One: Quality Assura nce Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
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..s s , Pg l of 14 4-OUALITY ASSURANCE PROCiRAM FOR MITR-II' SPENT FUEL SHIPMENT q l
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- 1. Bupom '
i This document, " Quality Assurance Program for MITR II Spent Fuel Shipment,"
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establishes a special Quality Assurance (QA) Program whose policies, goals, and objectives are as set forth in Chapter 11 (Quality Assurance) of the MIT Research Reactor (MITR II) Safety Analysis Report (SAR) and comply with the requirements of 10 CFR 50, 1 10 CFR 71.37, and 10 CFR 71 Subpart H. Chapter 11 is subject to review and approval by the MIT Reactor Safeguartis Committee. -
- 2. Organization q i
- Iha Director of Reactor Operations for the MIT Research Reactor is responsible for developing ud implementing this QA Program. Responsibility for execution of various parts of this QA Program may be delegated to individuals either within or outside of the Reactor Division, the organization chart for which is shown in Figure One.
The MIT Radiation Protection Committee is responsible for the possession and use c of byproduct material at MIT that is not covered by Facility Operating Licer 'e No. R 37. j For activities covered by or related to License No. R 37, the Director of Reactor Operations is responsible for implementing, administering, and auditing this QA Program. ;
He is assisted in this regard by the Superintendent of Reactor Operations and Maintenance.
'I For non routine activities, such as changes to systems or procedures, Safety Review and QA forms are used to document proposed changes and proper performance of the changes, respectively. In both cases they assure adequate review by more than one l
L responsible individual. For both routine and non routine activities, the procedures and l: proposals are reviewed by the Director of Reactor Operations and, where appropriate, by the MIT Reactor Safeguards Committee and Nuclear Regulatory Comndssion.
L The QA responsibility and authority to stop unsatisfactory work is derived from the '
- MIT Reactor Administrative Procedures and Standard Operating Plan. In cases where the quality of a system, component, or procedure comes into question or is disputed, differences of opinion are resolved in the course of review and approval by at least two 1
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individuals of the documentation associated with tests, calibrations, routine procedures, Safety Reviews and QA forms. Unresolved disputes are submitted to higher authority, i including the Chairman of the MIT Reactor Safeguards Committee if necessary. j 1
The Reactor Radiation Pmtection Officer may iscommend that any experiment or 1 work be stopped, if in his opinion funher operation might result in radiation exposure in l excess of permissible limits for the general public or MIT personnel.
t in the event of disagreement between the recommendations of the MITR Radiation ,
Protection Officer and the Director of Reactor Operations or their alternates, on matters pertaining to radiation protection, the course determined by the Director of Reactor >
Operations or his designated alternate to be more conservative will be followed. Records ,
of the disagreement will be sent for review and possible reconsideration to the MIT r Radiation Protection Officer, the Director of the Nuclear Reactor Laboratory, and the ,
Chairman of the MIT Reactor Safeges.is Committee. ,
Because of the size of the organization,it is not feasible to establish a separate Quality Assurance group. For the same reason, the more complex administrative controls necessary in a large, dispersed organization are not required in a much smaller one, where each individual knows all of his colleagues within the Reactor Division. Nevenheless, the
. principle of inspection, review, or other verification by a second individual for safety-related structures, systems, and components of the reactor and for shipping packages subject to 10 CFR 71 and 10 CFR 73 is maintained. Consequently, QA functions are ,
performed with an effectiveness equivalent to that found in a large organization where an ,
independent QA group may be necessary.
'Ihe qualifications for the Director of Reactor Operations are as follows:
The Director of Reactor Operations shall have a college degree or equivalent in specialized training and applicable experience, and at least three years of experience in a responsible position in a reactor !
operations or related field including at least one year of experience in reactor facility management or supervision.
l Qualifications for the St'gs.tendent of Reactor Operations and Maintenance and for other licensed personnel shall be as given in the Technical Specifications. The SR#-0-90-16 AUG 101990
( Pg 3 of 14 h Superintendent and Shift Supervisors shall he',d USNRC Senior Operator Licenses, and the Operators shall hold USNRC Operator Licenses. Licensed personnel are required to participate continuously in the NRC approved Requalification Program for the MITR.
- 3. Program Reauirements This quality assurance program includes those design, construction, maintenance, and operation activities which affect the structures, systems, and components for which specifications are established in the Technical Specifications and which affect the quality of packaging for shipping MITR-II spent fuel.
Any activity which could affect the ability of such a structure, system, or component to comply with the Technical Specifications or fuel shipping requirements of 10 CFR 71,10 CFR 73, and 49 CFR 173 falls within the scope of this quality assurance program.
Except as noted above, QA activities include designing, purchasing, fabricating, handling, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, modifying, and shipping. Where appropriate, these activities are carried out in accordance with written procedures, instructions, and drawings.
- 4. Shippine Container OA Plan The QA plsn for the shipping container provided by the vendor must be reviewed, to verify that the activities planned are permitted by the shipping cask Certificate of Compliance.
- 5. Desien Control and Review For modifications of or additions to those structures, systems, and components within the scope of this quality assurance program the Director of Reactor Operations provides for a design review by the appropriate supervisors of the Reactor Division groups listed in Figure One or by other individuals whom he may designate. The reviews are performed by individuals or groups other than those who performed the original design.
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. l In all instances the review assures that the design is correctly described in the i approval or license application and that the contents of safety analysis are accurate. Design reviews cover items such as reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of materials and design interfaces; and delineation of acceptance criteria for inspection and tests. The review further assures that applicable regulatory j requirements and also, the design basis as specified in the license or other approval application are incorporated in the design and that these are then translated correctly into l specifications, drawings, procedures, and instructions.
Documentation for the design verification reviews is provided in the form of approval applications containing the signatures of at least two individuals who are familiar with the safety related functions of the affected stmetures, systems, and components. The approval application may be in the form of an internal document, a request to the MIT 1
Reactor Safeguards Committee, or an application to the NRC for an amendment to the Technical Specifications.
i Assurance that the approved design is correctly translated into specifications, and installation, testing and operating drawings, procedures and instrxtions is accomplished by requiring that all such documents which fall within the scope of this quality assurance program, shall be checked by a knowledgeable individual other than the one who prepared ,
the document and that they shall be signed or initialed by both individuals.
In order to facilitate the preparation and revision of documents, to assure the appropriate reviews and approvals, and to document operation of the quality assurance program, a " Quality Assurance Approval Requirements Checklist" is used for specifying !
and recording the required actions and QA approvals.
- 6. Pmcurenrnt Document Contml l In documents for procurement of materials, equipment, and services, assurance that applicable regulatory requirements, design bases and other requirements which are l necessary to assure adequate quality are suitably included or referenced in such documents .
[ shall 'oe accomplished by requiring that the appropriate group supervisor or his designee l and the Director of Reactor Operations, or his designee, must both review and approve ;
prior to their release the specifications, drawings, procedures, instructions, or other documents which are parts of purchase orders and contracts subject to this quality SR#-0 90-16 AUG 101990
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assurance program. The Director of Reactor Operations shall specify for which materials, equipment, and services the procurement documents shall be reviewed.
- 7. Instructinne Pmcedures. and Drawinn Activities affecting quality shall be prescribed where appropriate, by documented instructions, procedures, or drawings.
These documetas shall specify the equipment to be used and the necessary i environmental conditions, where appropriate, and shall state the required prerequisites, if any, for QA activities, inspections, and tests. For modifications or additions to structures, systems, or components within the scope of this program, such documents shall be prepared, approved as provided in Subsection Design Control, and retained on file.
- 8. Document Contml All documents related to the fuel shipping cask will be contmlled through the use of the MIT Research Reactor QA Program. All document changes will be performed according to established procedures.
Special forms and procedures shall be developed for spent fuel shipment to insure that all the required steps are performed and documented.
Documents relating to a particular type of activity are,in general, prepared under the direction of the supervisor having responsibility for that activity. That supervisor is delegated the responsibility for maintaining 3 file of such documents, revising them to reflect approved design changes and as built conditions, and clearly identifying all drafts, the document as originally approved, and all revisions. He assures that necessary documents are available at the location where the activity will be performed prior to-
- commencing the work. Other distribution of documents is subject to the approval of the ;
Director of Reactor Operations or other designated individual.
Changes to documents shall be reviewed and approved, prior to implementation of the change, by the same Reactor Division group or the same organization that performed
. the original review and approval, unless the Director of Reactor Operations specifically designates another responsible group or organization. Changes to written procedures for SR# 0-90-16 AUG 101990
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l inspections, tests, and other critical operations are made in accordance with established !
procedures for temporary changes which require the written approval of two members of the reactor staff, at least one of whom must hold a Senior Reactor Operator License. -
p l- 9. Cnntrol of Purchaced Material. Eauinment. and Services j l
In general, all materials, equipment, and services are subject to inspection and
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approval of both the quality and quantity prior to acceptance Responsibility for these functions rests with the group supervisor initiating the procurement, or his designec, unless responsibility is otherwise assigned by the Director of Reactor Operations. Inspection generally is perfortned after receipt of the material, equipment, or service at the reactor site.
When considered necessary to assure quality, and particularly for non standard items, only vendors deemed qualified and acceptable to MIT are invited to bid. Contractors 4
and suppliers are selected on the basis of references, past performance at MIT, reputation ,
and other investigation. Appropriate credentials, and licenses when required by law, code, or regulation, will be furnished and retained on file.
No deviations from procurement documents are allowed without written request by the vendor and written approval by MIT.
if vendor and MIT do not agree on the quality of material or fabrication as defined in the specifications, the vendor may consult an independent expert acceptable to MIT. ,
'Ihis expert opinion will then be used to determine the issue.
- 10. Identincation and Control of Materials. Parts. and Comnonents -
Identification and control is required for fuel elements, control blades, electronic assemblies, and other materials, parts, or ,;omponents where it is necessary to identify items through stages of fabricat6n, delivery, installation, utilization, repair and modification.
I 1. Centrol of Special Processes The group supervisors of the Reactor Division, or such other individuals or organizations as the Director of Reactor Operations may designate, are assigned the SR#-0 90-16 AUG 101990
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responsibility for incorporating into instructions, procedures, and drawings, used dther for procurement or for control of internal activities within the scope of this quality assurance l program, the applicable portions of codes and standards in order to assure that special processes, including welding, heat treating, and non-destructive testing, are accomplished a by qualified personnel using qualified procedures.
Vendors will be required to guarantec compliance before a contract or purchase i order is issued. They will be required to furnish documented evidence of qualification when applicable, including individual as well as company licenses or other proof of j competence.
1 he appropriate group supervisor is responsible for surveillance of both vendor and l
- in house special processes and for certifying to the Director of Reactor Operations in written form that the work has been accomplished as specified. ,
The Director of Reactor Operations may at times involve expen counsel in special ,
problems. The written recommendation of the consultant shall be obtained and shall be part !
of the quality assurance file, but responsibility for acceptance of the work shall emain with the former individuals. !
For the preparation and shipment of spent fuel elements:
(1) Special handling, preservation, storage, cleaning, packaging, and shipping .
requirements are established and accomplished by qualified individuals in :
i . accordance with predetermined work and inspection instructions.
(2) ne departure, nrival time, and destination of a package will be established L and maintained to a degree consistent with the safe transportation of the ,
package.
(3) All necessary shipping papers will be prepared, as required.
(4) All conditions of the NRC package approval and the U.S. Department of Transportation shipping requirements are satisfied prior to shipment.
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- 12. Intamian and Test c'nnimi t The inspection program includes examinations, measurunents, and tests to assure i
that purchased materials, equipment, and services and also work performed by Reactor Division personnel conform to the requitrments of appilcable instructions, procedures, and [
drawings. l Quality in structures, systems, and components affected by the above acdvities is l assured through inspection and/or testing on completion of a job or prior to operation.
Work performed by Reactor Division personnel, including installations, .
. modifications, maintenance, repairs, and refueling, shall also be subjected to inspections :
and tests. Before a job is considered complete, the supervisor, where necessary, initiates a !
" Quality Assurance Approval Requirements Checklist,"if this has not already been done.
The Shift Supervisor assures that the above form has the necessary approvals before he l authorizes startup, startup after normal weekly checklist, startup after special test as specified, continued operation, etc.
Some activities cannot be proven acceptable by test methods and must be subject to inspection by a second individual to assure satisfactory completion of the work. Such l activities include the evaluation of experiments and irradiation series and the correct i placement of fuel elements in the core on refueling. In these cases, the person performing the evaluation or fuel placement signs the evaluation form or instruction sheet as does the ]
person approving the evaluation or witnessing the fuel transfct, I l
Upon approval of a procedure the supervisor is responsible for execution of the i test, indoctrination of participating personnel and supervision of their performance. Data sheets, forms, and checklists on which test infonnation is recorded will be signed by the individual observing the results. The supervisor is further responsible for evaluation of the results and for preparation of a written report for the quality assurance records. The report will incorporate the proposed procedures, any modification of the procedures during execution, the results obtained, and his evaluation of the results. The report is then reviewed and approved by the Director of Reactor Operations, or by his designee. I Appropriate review of the results and documentation is to be made before further dependent tests, studies, and experiments may be undertaken.
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- 13. ('*libratina of M*=enaamant and Test Fouinment i
Measurement equipment is subject to calibration under the surveillance program described in the MITR Technical Specificatiota All instruments used to indicate testing data will have an accuracy of reading which is small in comparison with the tolerances on the parameter being measured, so that the error in the test instrument is unimportant relative t
to the permissible error in the parameter, i
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- 14. Handline. Stormee. Rhinnine and Preservation l
l Established safety restrictions concerning the handling, storage, and shipping of l
- packages for certain special form radioactive material will be followed. Shipments will not be made unless all tests, certifications, acceptances, and final inspections have been ;
completed. All shipping regulations (federal, state, and municipal) must be met. Operating procedures for handling, storage, and shipping operations are prepared in accordance with
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the MIT Research Reactor Quality Assurance Program. k It is the responsibility of the vendor to observe normal precautions in the handling, '
storage, preservation, and shipping of materials and equipment. Inspection upon delivery l
should be adequate to detect any deleterious effects of inadequate precautions and will '
result in rejection of substandard materials and equipment.
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Unusual handling problems are normally not encountered in the operation of the MIT Reactor, and none are expected in connection with future operations. The handling of shleiding and other heavy objects is restricted through key control to those experienced in ,
the operation and use of the overhead crane. I i 15. Insnection. Test ~. and Oneratina Status l I
Inspection, test, and operating status of the fuel shipping cask for solid irradiated ,
fuel elements will be indicated and controlled as described in the MIT Research Reactor Quality Assurance Program.
The status of systems and components is known from entries in the operating, mechanical. and chtronic logs and from the System Test and Calibration Book. These records indicate when periodic surveillance tests required by the Technical Specifications SR#-0 90-16 AUG 101990 i
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, ',, ' Pg 10 of 14 have been performed. They also indicate the status of installation and testing of MITR F systems and components. When appropriate for industrial safety, the marking or tagging i of equipment, valves, and switches will be used.
, 16. Nonconformine Mnwrial. Parts. or Onmnonenta i f
Items found to be nonconforming in operation or in surveillance tests are recorded by identification number, if any, in the appropriate mechanical or electronics log and a removed from service until repaired. The repair, transfer to other use, disposal, or other l ultimate disposition shall be recorded. t i
- 17. Omeetive Action i i
Because of the relatively small size and the simplicity of the plant, most conditions !
adverse to safe operation are easily and quickly communicated. Depending upon the j importance of the deficiency, the information and corrective action may simply be f
documented in the maintenance or electronics logs, or it may be transmitted to the group supervisors or to the Director of Reactor Operations for a decision on appropriate corrective [
action.' l i
Failures adverse to safety which occurred or could have occurred during operation j
are reported in " Unusual Occurrence Reports" which describe the failure and recommend corrective action. These are reviewed by the Director of Reactor Operations and are also
, submitted annually to the MIT Reactor Safeguards Committee. Incidents which are
" Abnormal Occurrences" as defined in the Technical Specifications are submitted to the ,
Safeguards Committee for review at the time of submittal to the NRC. '
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Decisions as to corrective action are made on a case by case basis, depending upon the nature, severity, and frequency of the deficiency.
- 18. Onslity Assurance Records Procedures that implement this QA program and the MIT Research Reactor QA Program are incorporated in the MIT Reactor Procedure Manual, for which there is a '
controlled circulation, including revisions, to appropriate personnel. Activities within the scope of this quality assurance program are documented in the records as listed in Table-SR#-0-90-16 AUG 101990 1 . . _-_-_ _ _ _ _ _ -... --_- _ .-- --~ - -- --. - -- ---- -
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Pg 11 of 14 One. The table also shows the normal location of the records, the person assigned responsibility for their maintenance, and the required period of retention.
- 19. Audils An audit of this quality assurance program shall be performed at least annually in accordance with the requirements of the MIT Research Reactor Administrative Procedures.
The audit will be performed by the Director of Reactor Operations, or a designated, qualified individual. Deficient areas are reaudited on a- timely basis to verify implementation of corrective actions which minimize recurrence of deficiencies.
Documentation of the audit will include, as a minimum, a report of any changes in the program made since the previous audit, a report of random or complete reviews of all the relevant records, and an evaluation of the effectiveness of the program. The audit, .
along w4h necessary actions initiated by the Director of Reactor Operations and/or the Sup r', o dent of Reactor Operations and Maintenance to correct deficiencies itvealed by tht ' 9, are revicwed by all supe: visors and operators.
19, References i
! (i) Safety Analysis Report for the MIT Research Reactor (MITR II)- MITNE-
- 115, Oct.1970 - Chapter 11 (Quality Assurance).
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(ii) Technical Specifications for the Massachusetts Institute of Technology
- Research Reactor- July 23,1975 (as amended).
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( (iii) MITR II Procedure Manual.
(iv) MITR II Reactor Systems Manual.
(v) Shipment and Receipt of Special Nuclear Material (SNM) by Research
, Reactor Facilities- ANSI /ANS 15.19.
(vi) NRC, DOT, & OSHA Regulations.
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l MIT Reactor MIT Radiation Director, Medical Department Safeguards Protection Conun.
Committee Head, Environmental Medical Senice j l
Director, Nuclear Reactor Laboratory Radiation Protection Officer, MIT g
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Radiation Protection Officer, MITR Reactor Division !
m , .
I Director of I RPO Technicians Reactor Operations ]
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Superintendent Quality '
, of Operations Assurance and Maintenance Supervisor Assistant Supt.
e i . y ',
Accountability ,
Senior Shift Officer j Supervisor l
v* # ;
, . ,, 1" Shift Supervisors / :
,. "1 -
Senior Reactor Operator
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,,a Figure One: MITR Quality Assurance Organization Chart r SR#-0 9016 AUG 101990 ,
en Table One -
x o OUALITY ASSURANCE RECORDS b.'
m Recxed NormalI u-arian Responsibility Rre-eing Code *
- 1. Reactor Operanons Log Contml Room ReacsorSupervisors
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'A i
- 2. MechanicalMaineenanzlog Maineenance Maineenance Foreman B i
Offia
- 3. Instrumen'Aquipment Historylog Control Room ReactorSupervisors A
- 4. Instrument / Equipment Malfunction Worklist Control Room Reactor Supervisors A
- 5. SystemTest and Calibration Book Cont ol Room Operations Superineendent B i
- 6. Purchase Orders - Stock Items Business Cffre Business Manager C i
- 7. Purchase Orders- Fuel QA File Duectorof Reactor B
. (with in= action records and (previously Operusions certifications) Business Office)
- 8. Purchase Orders- Other QA File DuectorofReactor B (previously Operations Business Office) :
- 9. Company or personnel qualifications .With applicable Dinectorof Reactor B
> P.O. Operations t
c 3
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- 10. Irradiation and experiment requests, Operations Office Operations Superintendent A "
reviews, approvals, and shipping forms #
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Table One .i g ,
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QUALITY ASSURANCE RECORDS (Continued)
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m Reeord NormalI sw asirvi Responsibility Resension i Code
- 11. MIT Reactor Safeguards Comminee records Headquarters MrIRSCS-y A i (minutes, apprtwals, annual report, unusual Office occurrence reports)
- 12. Engineering drawings, specifwations, QA File Room Operanons Superineendent B and procedures
- 13. Electrical and Electronics drawings, QA File Room Electronics Supervisor B specifrations and procedures
- 14. Design reviews
- MrIR-II QA File Room DirectorofReactor A
- 15. Design reviews: Other QA Fde Roorn DirecaordReactor B 1 Operations
- 16. MrIR-IIinitial sest reports Ik2 N_1w. DirectorofReactor A Office Operations '
- 17. Quality Anur rc Appstwal QA File Room DirecaorofReactor B i Requirements Checklist Operations
> I 8. Audits Operations Office DirectorofReacsor A O
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- Retention Code: A - Termination of reactor's nuclearliability insurance, plus 10 years; B - until item disposed of, plus 5 years; o
. C - 2 years.
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