ML20126H799
| ML20126H799 | |
| Person / Time | |
|---|---|
| Site: | Seabrook |
| Issue date: | 12/31/1992 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-92173, NUDOCS 9301050324 | |
| Download: ML20126H799 (15) | |
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Odli Sea ~u%x%o3874 Telephone (003)474 9521
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j[hf fh Facsimile (003)474 2087 Enor0y Sorvico Corporation Ted C. Felgenbaum Sonic,t Vice President and Chief Nuclear Officer NYN 92173 December 31, 1992 United States Nuclear llegulatory Comtniss,lon Washington, D.C.
20555 Attention:
Document Control Desk Itefe rences:
(a)
Pacility Operating License No. NPP-86, Docket No. 50 443
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(b)
NilY Letter NYN-92045 dated April 10, 1992, Auxiliary Operator Performance Concerns,* T. C. Feigenbaum to T. T. Martin (c)
North Atlantic Letter NYN 92116 dated August 18,1992, " Auxiliary Operator Performance Concerns Action Plan," T. C. Feigenbaum to T. T. Martin
Subject:
Auxiliary Operator Performance Concerns Action Plan Gentlemen:
In a letter dated April 10, 1992 [ Reference (b)), North Atlantic Energy Service Corporation (North Atlantic) committed to provide you with a report regarding the action plans and implementation schedules for each of the recommendations provided in the assessment of the Auxiliary Operator Performance Concerns. Accordingly, the Enclosure contains a description of the individual action plans and implementation schedules as of December 15, 1992. This is a followup status report to the one submitted in a letter dated August 18,1992 [ Reference (c)), for the period ending July 31, 1992. It should be noted that the duc dates for some actions have been extended since the last status report to more accurately reflect implementation schedules and progress.
Should you have any questions regarding the Auxiliary Operator Performance Concerns Action Plan, please con act Mr.. lames M. Peschel, Itegulatory Compliance Manager, at (603) 474 9521, extension 3772.
Vny truly yours,
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Ted L Feigenbaum TCF:JES/jes Enclosure
, e ist d b,OU" I
a member of the Northeast Utilities system l
9301050324 921231 g
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Unitet! States Nuclear Regulatory Commission December 31, 1992 i
Attention:
Document Control Desk Page two t
ec:
Mr. Thomas T. Martin Itegional Administrator j
b gulatory Comsnission l
U.S.
Itegir 475 A ausle Road King 'of Prussia, PA 19406 i
Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555
-t Mr. lien llayes, Director Office of Investigation U.S Nuclear Regulatory Commission Washington, DC 20555 M.
Ilatry Letts,- Field Office Director Office of Investigation 3
- U.S. Nuclear Regulatory Commission i
-l Region l_
475 Allendale Road King of Prussia, PA 19406 t
Mr. Noel Dudley NRC Senior Resident inspector P.O. Ilox 1149 Scabrook, Nil 03874 l
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AUXil,l ARY OPI:H ATOH PEHl'ORM ANCI', CONCI:HNS ACTION Pl AN STATt1S AS OF DI:CI'M HER 15. 1992 Entroduction The Auxiliary Operator (AO) Performance Concerns Action Plan is contained in the Nuclear Production Regarding AO
'Su m mary Report by the Executive Director Performance Concerns
- which is Enclosure 1 to NIIY letter NYN.92045 dated April 10, 1992,
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' Auxiliary Operator Performance Concerns,* T. C. Felgenbaum to T. T. Martin [ Reference (b)]. The Action Plan consists of four recommendations made by the Executive Director -
Nuclear Production and 21 recommendations made by the Independent Review Team (IRT) and endorsed by the Executive Director Nuclear Production; Each of the recommendations required individual action plans to be developed and schedules estab!!shed for the completion of reviews and/or actions. This has been accomplished and the status of each recommendation is provided below.
The recommendations, as described in NYN 92045 and numbered EDNP.1 through EDNP 4 and IRT.1 through IRT 21, are repeated along with the current status.
Action Plan Status 1.
RECOMMENDATION NO. EDNP 1 New llampshire Yankee should acquire the services of an expert consultant to work with Management in order to enhance communications and team building.
The consultant should be selected by May 15, 1992.
Status As pated in the last status report [ Reference (c)],. North Atlantic had engaged the services of Senn Delaney Leadership Consulting Group (Senn Delancy) to provide Executive Management with. analysis and training relative to leadership, communications and teambuilding within the company. North Atlantic, working with Senn Delaney, has developed a project called
- North Atlantic TIDE: Teamwork in Developing Excellence '
North Atlantic TIDE was implemented in a three phase program consistina of 1) a Needs Assessment Audit, 2) Analyses Feedback Report, and 3) Communication and Team Building' Process. All of three steps of this program.
have been. completed. Executive Management has directed that the results of the program be incorporated into the ongoing North Atlantic training program.
Scheduled Completion Completed.
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2.
11ECOMMENDATION NO. I?DNp 2 Management should review its hiring and orientation practices in order to assure that l
they consider all appropriate attributes for hiring and developing employees. This i
4 review will be initiated by the Executive Director Nuclear Production, the Station I
Manager, and the Employee Relations Manager.
Statur The Employee Relations Department has reviewed the North Atlantic hiring and orientation practices.
An action plan was developed and is currently being implemented to provide information regarding the North Atlantic Values for Excellence, work ethic expectations and management expectations to applicants.
Specifically, these actions include: a letter from executive management to perspective employees stating North Atlantic's expectations and the consequences of falling to adhere to these expectations; a revised employee orientation video tape to also convey expectations; and meetings between the Senior Vice President and new employees for the same.
Eshduled Completion The enhancements to the employee orientation process are currently scheduled to be implemented by February 28, 1993.
3.
RECOMMENDATION NO. EDNp-3 Management should redouble its efforts in its support and communication with the on shift crews.
The Station Manager, Operations Manager, and the Shift Superintendents will develop a plan to foster better communications.
Statui The Station Manager and the Operations Manager have implemented a team building and communication plan utilizing department meetings, Operations management presentations during shift crew and Fire Fighters training weeks, and selective shift crew meetings in a non plant environment. The Station Manager has discussed the issue of fostering better communications with the Operations Group Manager and shift
- crews, in addition, the Station Manager has scheduled to meet with each Shift Superintendent semi annually to discuss his evaluation and progress, and to emphasize actions that the Shift Superintendent should take to ensure that the station is operated in accordance with North Atlantic policies in a strong, conservative manner during all shifts.
This recommendation ' is. also being implemented in conjunction with i
recommendation IRT-17. In addition, North Atlantic is utilizing the services of an industrial psychologist to assist in the team building and communication effort utilizing experience gained from the many industries involved in shift and rotating shift work.
At the completion of the initial review, the appropriate aspects of the plan will be:
incorporated in North Atlantle policies, programs and procedures.
l Scheduled Completion This recommendation is currently scheduled to be completed by February 28, 1993, 2
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4.
Ri?COMMl!NDATION NO. l'DNP 4 Management should review industry experience with regard to these types of concerns and implement the lessons learned.
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Status North Atlantic has discussed the AO performas.cc concerns with several utilitics and
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INPO, No significant lessont, it.arned have resulted fiom these discussions as of this time. In light of this, this issue will be kept open for additional review in the Spring i
of 1993. If lessons learned are forthcoming at that time, then a summary report of all related problems and corrective actions will be prepared, North Atlantic will then j
determine the appropriate elements from the industry review to be incorporated into company programs, procedures and guidance.
Scheduled Completion 1
The summary report is currently scheduled to be completed by March 31, 1993.
Management analyt.is of any recornmendations is scheduled to be completed by May 31, 1993.
5.
Iti!COMMI!NDATIDN NO. IRT 1 Executive Management should review and evaluate the procedure compliance policy scope with regard to the applicability of verbatim compliance.
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A task team has been established to conduct a review of the procedure comp!!ance policy scope and applicability and to provide recommendations addressing potential policy revisions. As of this time, the task team hu pretiented management with a draft procedure compliance policy for review and comment. Upon approval of the revised policy, individual manuals, programs, and procedures will be reviewed and recommendations for revisions will be provided to Executive Management for consideration. When Executive Management has determined the appropriate revisions, the normal procedure revision process will be utilized for implementation.
This recommendation is being pursued in conjunction with IRT-3 and IRT 20 to allow nn integrated approach to policy, program, manual and procedure changes.
Scheduled Comotetion Policy resisions are scheduled to be completed by May 31,-1993,-
6.
RECOMMENDATION NO. IRT 2 Conduct-refresher training on a periodic basis in the following:
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Procedure Compliance Policy, 3
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r Need for integrity / accuracy / completeness when documenting work activities.
l!mphasiring that all documentation may be needed to reconstruct work activities.
NRC regulation on willful misconduct by licensed and/or unlicensed employees.
Etabli As described in the last status report l Reference (c)], the General !!mployee Training (UllT) Prograrn, including initial and requalification training, was reviewed and revised to incorporate the appropriate updates and additions. The OET training is providing up to date information during both initial and requalification training to address the i
elements of the recommendation.
The completed actions were reviewed by the independent Review Team and determined to have satisfactorily addressed the recommendation.
Scheduled Comotetion i
- Complete, L
l 7.
RECOhthil2ND ATION NO. IRT 3 Streamline Company operations by consolidating and climinating (as possible) programs, policies manuals and procedures.
Emphasis should be placed on eliminating redundancy and excessive administrative requirements and documentntion (e.g.,
canceling Nuclear Producilon hianual, quarterly surveillance for Shift 1
Superintendents to review Work Request priorities, procedure for bulletin boards),
Consider using outside expertise.
Status The Assiritant Station hianuger has reviewed the AO Action Plan and previous self assessments related to Attention.to Detail and Configuration Control. The. review consolidated similar recommendations and produced additional recommendations that involve changes to North Atlantic policies, programs, manuals and procedures. The combined action plan has been approved and this recommendation will be finallred and implemented in conjunction with IRT-1 and IRT 20.
-As part of implementing this recommendation, the Nuclear Production hianagement hianual has been cancelled and non redundant requirements have been included in the Station hinnagement hianual. Additionally, the North Atlantic-htanagement hianual has been revised to simplify _ and - recognize two distinct program and procedure review / approval processes, i.e., those program and procedure revisions that require review and approval by the Station Operation-Review Committee (SORC), and those that do not.
Furthermore, the Station hianagement hianual has-undergone several revisions to i
-improve human factors aspects. This included improving readability and reformatting policies, programs, SORC, and administrative chapters.
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Scheduled Completion 3
All actions to address this recommendation use-scheduled to be completed by May
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31, 1993.
8.
RI!COMMI!NDATION NO. litT 4 i
Determine where operations administrative burdens for compliance with Technical Specifications and NRC commitments can be reduced by design enhancernents.
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!!FW back leakage temperature monitoring a
Spent Puel Pool cooling pumps area temperature Stiit us The Operations Department is reviewing the various-requirements for the AOs and identifying potential design changes. The Shift Superintendents have been requested to participate in this process. The Station Manager will review the recommendations and determine which design enhancements should be included in the North Atlantic Long Range Plan, Scheduled Conaldim).
The review of potential design changes is currently scheduled to be completed by February 28, 1993, 9.
Rl!COMMl!NDATION NO, IRT 5 i
Review and revise the AO logs to eliminate checks determined to be excessive _(c.g.,
Cooling Tower and CST every four hours).
Status As described in the last status report [ Reference (c)), the AO logs were reviewed and revised to include add!tional criteria for the areas on the rounds and to eliminate exec $sive checks. The revised logs were reviewed by the Independent Review Team; and determined to have satisfactorily addressed the recommendation.
. scheduled Completion Complete.
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10.
El!COMMf NDATION NO. IRT 6
' Consider providing Auxiliary Operators with updated tools for recording rounds data to provide consistent documentation and enhanced capability for equipment rnonitoring.
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Consider systems such as us.ed by Virginia Power (Nuclear Plant Journal, Jan.Feb, 1992).
hii!Lui Thw Operations Department is reviewing the AO rounds data recording requirements and evaluating the potential for utilizing updated tools. The Information Itesources Group has also been involved in this process and has met with various vendors. Any recommendations made by Operations and the information itesources Group will be reviewed by the Station Manager to determine if they will be pursued.
Scheduled Completion The Station Manager's review is currently scheduled to be completed by February 28, 1993.
11.
III!COMMl!ND ATION NO. litT-7 Revise the AO initial Training Program so that at the start and the end of the program, the Executive Director Nuclear Production, Station Manager, Operations Manager, and Training Manager add:ess the Company's expectations and standards that the AO must meet, and convey the consequences of failing to meet these expectations and standards.
This should be emphasired annually during AO Continuing Training.
Status The AO initial Training Program includes presentations at the beginning of the program. The 1992 AO Class began training on July 13, 1992 and the Executive Director Nuclear Production, Station Manager, Operations Manager, Assistant Operations Manager and Training Manager addressed the class during the first three days of training to discuss management's expectations and North Atlantic's Values for Excellence, in addition, a session will be held on the last day of training to discuss management issues and reinforce previous presentations.
The Ao initial Training Program description currently incorporates the elements of this recommendation. Additionally, the AO Continuing Training Program description will be revised to incorporate these elements after the" are adequately tested with the 1992 Class.
Scheduled Completion The AO Continuing Training program description is currently scheduled to be revised by February 28, 1993.
12.
RI! COMMEND ATION NO. IRT-8 Revise the AO Initial Training Program so that upon AO's arrival at training, the Shift Superintendent (SS) delivers Operations Department expectations to the new AO 6
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- (orientation). In addition, an AO currently on the shift meeting these expectations will be assigned as a mentor to train this new AO on job requirements during the OJT process. This will include signing of all qual guide related material. The Shift Superintendent will be responsible for monitoring the progress of assigned AOs
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throughout the training program to make sure the department's expectations are being ruc t, j
St atus.
The AO Initial Training Program Description currently contains the elements of this recommendation. The 1992 AO Class was able to spend approximately two weeks on shift prior to beginning the classroom training. During this period they met the Shift Superintendent and shift personnel and spent time in the Control Room and on the various AO watchstations.
A sponsor was assigned to each AO trainee when he arrived on shift for the first week of on the job training (OJT). The sponsor will fulfill the functions of the mentor as described in the recommendation.
The sponsor will sign appr_opriate qualification guide related material.
The AO-Initial Training Program Description and Qualification Ouide have been revised to include the elements of this recommendaticn. These documents will be tereviewed after they are utilized and tested with the 1992 AO class. The classroom phase will be completed at the end of January 1993.
i Scheduled Completion The reteview of the 'AO Initial Training Program is currently scheduled to be completed by April 30, 1993.
13.
ItECOMMENDATION NO. IRT-9 Revise the AO OJT Program to incorporate the Operations Oood Piactice on AO logs and round taking.
-i Status The AO OJT Lesson Plans have been revised to incorporate the good practices on AO logs and round taking that are described in procedure OP10.8," Auxiliary Operator Watchstanding Practice.'
Scheduled Completion Complete.
14, RECOMMENDATION NO. IRT 10 Add signature blocks on the OJT qual guide to include:
AO mentor, stating.that the AO trainee is ready for qualification approval.
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d AO trainee, stating he accepts all responsibility of information found in qual guide.
Shift Superintendent, stating his expectations have been met.
Operations Manger, stating that the department expectations have been met.
Status The AO OJT qualification guide has been revised to include the signature blocks stated in this recommendation.
Scheduled Completion Complete.
15.
RECOMMENDATION NO. IRT-11 Review applicable OJT lesson pinns and Job Performance Measures (i.e. rounds, logs keeping, CST integrity checks) to ensure that AO administrative requirements have been included in these lesson plans.
Status The applicable OJT lesson plans and Job Performance Measures have been reviewed.
and the AO administrative requirements have been incorporated as appropriate.
Scheduled Completion Complete.
16.
RECOMMENDATION NO.1RT 12 Operations and Training should re evaluate the priority placed on the AOiContinuing Training Program. Training should ensure adequate instructor resources are available.
to conduct the program. Training should consider placing an instructor on shift in the plant to conduct training.
Status The' Operations Curriculum Advisory Council has reviewed the AO Continuing Training Program and determined that the appropriate -priority ls placed on the program.
Training-has increased the instructor staffing by one = position to provide additional--
support to the AO Continuing Training Program and to' supplement 'the on shift on-the. job' trainlag-administration.
Scheduled Completion Complete.
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HJ1COMMFJDATION NO. IRT 13 Re evaluate Ibe AO training commitments to see if any requirements f an be reduced i
or eliminated.'
Recommend that some of the requirements deemed necessary be fulfilled on shift.
Status i
As described in the last status report [ Reference (c)), the AO Initial and Continuing i
Training Programs were reviewed by the Operations Curriculum Advisory Committee (CAC) to determine if any elements could be reduced, eliminated or combined. In addition, the CAC enlisted a review, by 28 Training and Station Staff personnel, of the current AO training program and several lessons were identified that could be
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climinated. The recommendations of the review group were accepted by the CAC and the AO Initial and Continuing Training Programs were revised. The completed actions were reviewed by the Independent Review Team and determined to have satisfactorily _
nddressed the intent of the recommendation.
Scheduled Comoletion i
Complete.
18.
RECOMMENDATION NO. IRT-14 l
c Provide consistent adminlitration of exams, written or walkthrough, to document students have comprehension of the material.
Status The Operations Curriculum Advisory Committee.(CAC) has mandated that weekly examinations be given during the AO Continuing Train'ng Program.
_ These examinations are administered as described _in Section 8.0 of the AO Continuing Program Description. The CAC will annually evaluate the effectiveness of these exams as described in Section 13 of the AO Continuing Program Description.-
Scheduled Comoletion The CAC review of the AO Continuing Program Description is scheduled to be completed by December 31, 1992.
19.
RECOMMENDATION NO.1RT 15 Examine the-training feedback disposition process to_ ensure that actions are properly addressed and implemented.
Status The Operations - Deparr,t
- discussed this recommendation at an. Operations Curriculum Advisory Comm, ace (CAC) meeting and determined that training feedback 9
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e items discussed at a CAC meeting will be added_ to the Operations Department worklist. This action has been completed. Additionally, Training Group Procedure NT.8000 has been determined to provide actions and controls for an effective training feedback process.
Scheduled Comoletion Complete.
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EjlCOMMl!NDATION NO. IRT 16 Develop a standard orientation program for new employees to convey clear and concise Management expectations and develop a means to reinforce these expectations on a requalification basis. (See Recommendation #7 and #8 for example).
Status The Employee Relations Department and the Training Department have developed an enhanced orientation program that incorporates the elements of this recommendation, j
Specifically, this included the revision of the lesson plans for Site Orientation, General Etnployee Training (GET), and the Computer liased GET,- to address procedure compliance and deliberate misconduct.
Scheduled Comoletion l
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21.
RI?COMMl!NDATION NO. IRT 17 Develop team building opportunities with all on shift Operations personnel. Consider periodic gatherings, other than shift turnover, which would encourage team interplay.
~l Status The Operations Department currently conducts monthly meetings with all on shift personnel to provide team building opportunities and to encourage team interplay.
North Atlantic will continue these monthly _ meetings as appropriate.
This recommendation encompasses similar issues described in EDNP 3.
See EDNP-3 for -
additional details.
Scheduled Comoletion Complete.
22.
R11 COMMEND ATION NO. 'IRT Develop Operations-Department good practices to incorporate Operations standards, management expectations and good practices pertaining to AO logs and watchstanding.
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Status As described in the last status report llteference (c)), the Operations Departrnent
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developed a single procedure OP10.8," Auxiliary Operator Watchstanding Practice' that covers AO logs and watchstanding. The Independent Review Team reviewed OP10.8 and determined that the procedure adequately addresses the intent of the i
recommendations.
6 Scheduled Completion
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23.
EJ! COMMENDATION NO. litT 19 Develop Operations Department Qualification Program and include this program in the NYOM.
r filatus The Operations Department is developing the Qualification Program for inclusion in the NYOM.
Scheduled Completion The Operations Department Qualification Program is currently scheduled to - be -
completed by May 15, 1993.
f 24.
RECOMMENDATION NO. litT 20 Review and evaluate the processes utilized to manage technical and administrative tasks to streamline and consolidate the Management function. Encourage the decision making _ process to be made at the appropriate levels in the organization. Allow managers more time to manage people and to develop strategies in order to facilitate improved interpersonal communications. Consider using consultants to complete this-i review and provide specific recommendations.
Status The processes utilized to manage technical and administrative tasks are being reviewed
'in conjunction with IRT 1 and IRT 3.
The processes determined to require revision-will be revised in an integrated manner with other related policy, program, manual:
- and procedure changes.
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Currently, the-following summary actions have been implemented to address 'this' recommendation: revising procedures to allow approval authority to take place.at the.
appropriate organizational level;. consolidation a'ud standardization of procedures to improve efficiency; and conducting meetings with personnel to solicit' input on other.
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actions that may be taken to encourage the decision making process to be made at the appropriate levels in the organization.
Echeduled Comoletion This recommendation is scheduled to be completed by May 31, 1993.
25.
RECOMMiiNDATION NO IRT-21 Operations ManaBement should ensure that the intent of O AI.14 # 8,
' Plant Performance Monitoring la met.
Stntos The Operations Manager has reviewed different options to expand or enhance the instructions for implementing OAI.14 #8; As a result of this review, OAI,14 #8 was revised to ensure that the Shift Superintendent performs or directs an independent -
unannounced monitoring task each calendar quarter. Additionally, OAl.14 #15 was revised to _ ensure that the Operations Technical Project Supervisor performs a bl.
weekly verification of the AO rounds using sceurity door access records, AO round sheets, and/or other means as appropriate. This surveillance will be conducted on j
r a random basis.
Scheduled Comotetiort Complete.
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