ML20199C813
| ML20199C813 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/07/1997 |
| From: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Devault R ENERGY, DEPT. OF |
| References | |
| NUDOCS 9711200148 | |
| Download: ML20199C813 (2) | |
Text
__
, a November 7, 1997 Mr. Randall M. DeVault Regulatory Oversight Manager Office of Assistant Manager
, for Enrichment Facilities U.S. Department of Energy, EF20 ,
P.O. Box 2001 Oak Ridge, TN 37831
Dear Mr. DeVault:
In accordance with the recent Memorandum of Understanding and per discussions between our staifs, we are forwarding the attached certificate amendment request (CAR) regarding issue 24
+ cf the Portsmouth Compliance Plan (DOE /ORO-2027/R3," Plan for Achieving Compliance with
' ~
NRC Regulations at the Portsmouth Gaseous Diffusion Plant") dated October 21,1997, The CAR is reques+ing a date change for completion of a Plan of Action and Schedule item from issue 24. Please review and advise us whether or not DOE approves the requested date change.
You may inform us of your decision on this matter by contacting Yawar Faraz at L
(301) 415-8113.
Sincerely, Original S1900d OY Robert C. Pierson, Chief .
Special Projects Branch ,ig Division of Fuel Cycle Safety and Safeguards, NMSS g\
,g t Docket 70-7002 Certificate GDP-2 kh { n Encloaure: CAR dated 10/21/97.
Distribution: (TAC No: L32051, Control No: 200S)
L Docket 70-7002 cNRC FILE CEf4TER- PUBLIC PHila..d, Rill Dgand. Rill WSchwink,FCOS KWinsberg.OGC SPB r/f FCSS r/f OFC SPB SPB SPB SPB, O SPS ,[
NAME NCox:ij bHoadley bin hN DATE 'l /97 / /97 / /97 //h07 [l/h97 / /97 C = COVER E = COVER & ENCLOSURE N = NO COPY G:klevault.cox OFFICIAL RECORD COPY k {GL l 1LuMS {Dktovrt%W -
llllllh f 9711200148 971107 ll ll lll PDR ADOCK 07007002 . i'o e i-l C FM l
. Randall M. DeVault Row latory Oversight Manager Office Assistant Manager for Enric ent Facilities U.S. Depart t of Energy, EF20 P.O. Box 2001 Oak Ridge, TN 3783
Dear Mr. DeVault:
In accordance with the pending Me randum of Understanding and per discussions between
- our staff, we are forwaiding the attach certificate amendment request (CAR) regarding issue
. 24 of the Portsmouth (PORTS) Complianc. lan (DOE /ORO-2027/R3, " Plan for Achieving Complianc,e with NRC Regulations at the Ports uth Gaseous Diffusion Plant") dated October 21,1997. The CAR is requesting a date nge for completion of a Plan of Action and Schedule item from Issue 24.- Please review and indi . te whether or not DOE would support
- the requested date char.ge.
Please inform us of your decision on this matter by contacting ar Faraz at (301) 415-8113.
Sincerely, N.
Robert C. Pierson, Chief Special Projects Branch
, Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-7002 Certificate GDP-2
Enclosure:
CAR dated 10/21/97 \
Distribution: (TAC No: L32051, Control No: 200S)
Docket 70-7002 NRC FILE CENTER PUBUC PHiland, Rill T W L-DHartland, Rill WSchwink,FCOB KWinsberg,0GC SPB r/f FCSS r/f OFC SPB SPB SPB C/ SPB SPB r ,
NAME CCox:ij i Hoadley DMartin RPierson DATE - /////97 / /97 \l/I/97 / /97 / /97 / /97 ~
C = COVER. E = COVER & ENCLOSUR8i N = NO COPY "G:Wevault cox -
. OFFICIAL RECORD COPY
unaeu States
.- Ennenment Corporat.on 2 oemocracy Centet 6903 Rockledge Dnve
, Betnesda. MD 2081i Tel (301: 564 3200 Fax: (301) S64-3201 JAMES H. MauER Dr. (301) SG4 3309 VicE PRESIDcNT, PRoOUcTioN -- Fax. (301) 5718279 October 21,1997
- Dr; Carl J. Paperiello SERIAL: GDP-97 0180 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U S. Nuclear Regulatory Commis: ion Washington, D C. - 20555 0001 Portsmouth Gaseous Diffusion Plants (PORTS)
Docket No. 70-7002 Certificate Amendment Request - Calibration Program for Measuring and Test Equipment
Dear Dr. Paperiello:
In accordance with 10 CFR 76 45, the United States Enrichment Corporation (USEC or Co.poration) hereby submits a request for amendment to the certificate of compliance for the Portsmouth, Ohio Gaseous Diffusion Plant (PORTS). This certificate amendment request revises the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan), Issue 24, to delete the imp.ication that mea uring and test equipment (M&TE) are categorized by Q, AQ, and AQ-NCS. Those M&TE which are used on Q, AQ, and AQ-NCS equipment are qualified for use on equipment of the highest quality level (i,e , Q) and may be used on any of the 'hree categories it also corrects an inconsistency within Compliance Plan issue 24 regarding th. w ;let.an date for revising the calibration program procedures and training to meet more fomial requirements for AQ SSCs by revising the subject completion date to June 30, 1998. 'Ihe revised date matches dates given elsewhere in issue 24 for upgrading the work control process and preventive maintenance program for other AQ items, and also matches the Paducah.
Kentucky Gaseous Diffusion Plant (PGDP) commitment dates for similar actions.
Enclosure I to this letter provides a detailed description and justificatien for the proposed changes to Compliance Plan issue 24. Enclosure 2 is a copy of the resised Compliance Plan pages and removal / insertion instmetions associated with this request. Enclosure 3 contains the basis for USEC's determination that the proposed change associated with this certificate amcodment request is not significant.
( gMi,-
i n 9 91 Ai ,I L/, G-l' '3- o(f N
')
.. .o;
~
s (Dr; Carl ), Paperiellos October 21,.1997
' GDP 97-0180 Page 2 ,
S:nce this; certificate amendment request is not required to support continued plant operation,--
but is associated with a Compliance Plan action that is currently scheduled to be c~nplete byf December 31,1997, USEC requests NRC review and approval of thb certificate amendment request ;
by December 31,1997.. : The ' amendment should become effective immediatel upon approval by
' NRC:
- - Any quest i ons related _to this subject should be directed to Mr. Mark Lombard at (301) 564 3245. '
New/ revised commitmcats contained in this submittal are provided in Enclosure 4,-
4
-Sincerely,-
~. . /
James il Miller Vice President, Production
Enclosures:
As stated -
.CC:
NRC Region til Oflice NRC Resident inspector - PGDP NRC Resident inspector PORTS DOE Regulatory Oversight Manager t
,4-- r- wwb y ,,sr---- .,e6 -- *- i--r --rr-- r - - -
OATH AND AFFIRh1ATION I, James H Niiller, swear and allirm that I am Vice President, Production, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
O ,
James 11 Niiller On this 21st day of October.1997, the oflicer signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
In witness hereofI hereunto set my hand and otlicial seal il i a i b it is ' I . v, M
- f.aurie N1 Knisicy, Notary Public ~' l~
State of N1aryland, N1ontgomery Count [
N1y commission expires N1 arch 17,1998 c.
^
a Enclosure 1 GDP 97 0180 Page1of1 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request y,w Calibration Program for Measuring and Test Equipment 3 Detailed Description of Change $" U N "'#
The proposed changes involve the PORTS Compliance Plan issue 24, Plan of Action and Schedule. Specifically, on page 4, the fillh bullet paragraph is proposed to be revised as follows:
Revise the measuring and (est equipment and process equipment calibration programs to meet the more formal requirements. The scheduled completion dates for these actions are December 31,1996, for Q SSCs measurigendaestetuipment; February 28,1997, for AQ-NCS SSCs meamng and tes: atuipment; and June 30,1998. December 31,1997, for uther AQ SSCs measuring and te:;: equipmen;- i The proposed change will delete the implication that measuring and test equipment (M&TE) are categorized by Q, AQ, and AQ-NCSc Those M&TE which are used on Q, AQ, and AQ-NCS
- equipment are qualified for use on equipment of the highest quality level (i.e., Q) and may be used on any of the three categories of safety related equipment (Q, AQ, and AQ NCS). It also corrects an inconsistency within issue 24 regarding the date for revising the calibration program to meet more formal requirements for AQ SSCs by revising the subject completion date to June 30,1998 The revised date matches dates given elsewhere in issue 24 for upgrading the work comrol process und preventive maintenance program for other AQ items, and also matches the Paducah Gaseous Diffusion Plant commitment dates for similar work On page five of Compliance Plan issue 24, the following change is proposed in the first bullet:
- Develop and implementi ndividual calibration procedures for Q, AQ-NCS, and other AQ SSCs and for M&TE. I This change is being proposed to indicate that detailed calibration procedures , ire developed to control M&TE as well as the Q, AQ NCS, aad other AQ SSCs-i i
L
x=.i.
- ^
Enclosure 2_ ,
GDP 97 0180 Page1of5 _
- I Proposed Certificate Amendment Request Portsmouth Gascous Diffusion Plant.
Letter GDP 97-0180 Removal / Insertion Instructions Remove Pages Insert Pages Plan for Achieving Compliance with NRC Regulatiors at the Portsmouth Gsseous Diffusion Plant Issue 24 issue 24 Pages 3/4. 5/6 Pages 3/4,5/6 i-
+
F e
f
- Maimenance Program Issae 24. l' age 3 '
In addition, the mamtenance orgamrations has e imtiated special provisions and mterim commitments for the safety systems. These provisions, which are now m place and are incorporated mte existmg procedures, and will be incorporated into new procedures as they are developed, include the followng avions.
{
- l. A work package is prepared prior to commencement of any corrective maintenance work on safety systcms The minimum requirements of a work package for safety system maintenance include: a {
j maintenance service request; a plannmg checklist; written work instructionx; and a safety system data sheet, which provides verification of post maintenance testing. Depending on the scope of the wcrk, the package may also include equipment specific procedures or checkhsts and quality control inspection, nuclear criticality safety analysis, radiation protection, OSHA, or operational requirements. The l composition of a work package is dependent on the maiatenance to be performed and is defined in the work control procedure 2 Systems engmeets have been assigned speci:.c responsibihty for the technical aspects of designated safety systems The systems engmects proude techmcal support for maintenance activities of these systems, includmg assistance m work package preparation, determination of post mamtenance test requirements.obsen ation of suncillance testmg. resicw of procedures, and input to the plant preventive maintenance program Sy stems engineers are required to hase an engincenng education or an appropriate technical background and a basic knowledge of plant systems, pnnciples of gaseous diffusion, administratne procedures and pohcies. plant layout and location of components of assigned systems, techmcal specifications, and in-scruce inspection requirements Intenm Regulatory Commitments The followmg commitments derned from the ROA requirements will remam .n effect until replaced by Apphcation commitment implementation I A correctise mamtenance program shall be implemented to ensure that prompt and effectne mamtenance is performed on malfunctionmg nuclear safety systems. safeguards, and seutnty equipment.
2 A preventne maintenance program shall be implemented to ensure the operability of nuclear safety systems, safeguards, and securn. ;quipment.
- 3. A documented mstrument cahbration program, employing standards traceable to the national standards system or to nationally accepted standaids. shall be implemented for the calibration of equipment and morutonng deuces necessarv for the proper mamtenance and operation of nuclear safety systems and safeguards equipment
- 4. Controls shall be established to ensure safety systems are not disabled or diminished by planned actiuties i Work on safety systems shall be controlled and performed with the use of approved procedures and/or l work instructions. The procedures and work mstructions shall be based upon established and well- i recognized codes and standards in applicable areas such as welding, {
l'OR TS Ret 3,7 9 *,
I
- RAC 97X0502 PROPOSED M m e m xiwyrsn lisue 24 Page 4 electrical, piping, and instrumentaten As applicable, codes and standards shall be iden ified in the procedures as source references.
Pl,AN OF ACI~ ION AND SCllEDULE The actions required to complete the mamtenance program are the followmg-
. Desclop and implement a maintenance history program The scheduled completion date for this action is September 30,1997.
Develop a master equipment list for safety totical equipment.
- Implement a new computer based maintenance management system with the capability to collect and trend the data
. Deselop guidance for cleanhness control and measures to prevent entrv of extraneous material mto a closed system The scheduled completion date for this action is July 31,1996
. Upgrade the current work contro: process to provide the committed level of planmng and work package development for Q, AQ NCS, and other AQ items The scheduled completion dates for these actions are Februarv 28,1997, for AQ.NCS items. Apnl 30,1997, for Q items; and June 30,1998, for other AQ items
- Centralve all plannmg and work control functions m the Work Control organization. (Complete)
- Resisc the work control procedure
- Desclop and proude traming on the upgraded work control process.
. Upgrade the presentne maintenance program to meet the commitments for greater formahsm. The scheduled completion dates for these actions are February 28,1997, for AQ-NCS items; March 31,1997, for Q items, and June 30,1998, for other AQ ttems.
- Des clop an os erall performance mdicator to measure presentn e maintenance effectiveness.
- Identify current preventn e maintenance performed on Q, AQ-NCS, and other AQ items.
- Revise the presentne mamtenance program procedure to estabhsh a formal mechanism tojustify and document changes to Q, AQ NCS, and other AQ item requacments.
- Develop the technical /histoncal basis for use m evaluating preventise mamtenance task adequacy.
} . Revise the measunng and test equipment and process equipment calibration programs to meet the more formal requirements Ttte scheduled completion dates for these actions are December 31,1996, for Q l SSCs; February 28,1997, for AQ-NCS SSCs; and June 30,1998, for other AQ SSCs.
- Implement procedures that dcGee and control the overall measuring and test equipment program (Complete) 1 l
October 21,1997
RAC 97X0502 PROPOSED issue 24, Page 5 Monienance Pmpan,
- Develop and implement indindual cahbration procedures for Q, AQ-NCS, and other AQ SSCs and 1 for Ni&TE. !
- Provide training on cahbration requirements to affected coordinators, managers, technicians, and users
. Identify the procedural deficiencies for performing corrective maintenance, preventive maintenance, calibration, and surveillance testmg of Q. AQ-NCS, and other AQ SSCs, and develop a composite listing of the procedures requiring revision, development, or conversion The scheduled completion dates for these actions are October 31,1996, for Q SSCs, January 31,1997, for AQ-NCS SSCs; and October 31, 1997, for other AQ SSCs
. Des clop procedures and provide the associated trainmg of appropriate personnel for the performance of surveillance tests which are required to support Technical Safety Requirements. This action will be completed prior to the NP.C assumme regulatory authority.
. Reuse, develop. or comert correctise mamtenance, pres entise maintenance. calibration, and surveillance test procedures for Q AQ NCS, and other AQ SSCs The scheduled completion dates for these actions are February 28.1997, for AQ NCS items Ntarch 31,1997, for Q iteus; and June 30,1998, for other AQ items-
- Develop traming materials for the work control, surveillance testing, instrument calibration, ad correctnc and presemise maintem,nce procedures and proude the associated training of appropriate personnel The scheduled completion dates for these actions are February 28,1997, for AQ-NCS items; Ntarch 31,1997. for Q items. and June 30,1998, for other AQ items.
. Identify and control the s endors' manuals used for mamtenance of Q equipment, including entering them into the document control and records management system The scheduled completion date for this action is Ntarch 31.1997
- Identify vendor manuals used for maintenance actiutics of Q equipment.
- Verify approprtate s endors' manuals for accuracy and completeness.
- Enter vendor manual data into the records management and document control system-The proc: dure upgrades and associated traming to address this area of the noncompliance will be completed in coordination with the plans and schedules set forth in the Comphance Plan issues " Procedures Program and "S,sstems Approach to Traimng "
October 21.1997
e e
? #
.{'
,- [
, Mamterance Program p g
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES Issue: Mamtenance Program ,,
Code of Federal Regulations Part -
Title 10 76.87(c)(7) .
l Application Commitment Section 3.5.1,5.3.5,5.65,5.6.5.1,5.6.5.2,5.6.5.3,5.7.3, Safety Analysis Report 5.7.3.2,5.7.3.4,5.7.3.5,6.1.1,6.1.1.9,611.I1, .
l 6.1.1.I4,6.1.1.20,6.1.1.25,6 3.5.2.3.6,
- l. 6.3.5.2.42,6.3.5.4.2,635.6,63.5.7,64,65.7, l 6.61,6.63,663.1,66.5,6.6.13,6.8.2.2,6.8.2.3, 6.8.2.4, 6.10 1.13, 6. I 1.1, 6.1 1. 5, 6. I l-A ppendix l
A
-l Technical Safety Requirements 3 2.2.b,3.9.1,315,334 _
l 2.2.7,2.6,4 1,4.1.1,5.1.2,5.2,5.2.1,5.2.3,13.1
-l Fundamental Nuclear Materials Control Plan 4.1.5, 7.6, 8. 2 l- Emergency Plan - ,
Quality Assurance Program I-218. Appendix A
-l l Section
- Application Noncompliance Statement 64.131,64.132,64.13.3,6.4.13.4,6.4.13.5 l Safety Analysis Report PORTS Rev. 3. 7 996 L
l l
. , , - ~
l
- e. 'O '
Enclosure 3 GDP 97 0180 Page 1 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Muest:
Calibration Program for Measuring and 'Iw Pquipment Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
- 1. No Overall Decrease in the Effectiveness of the Plant's Safety. Safeguards. or Security Prourams-The proposed changes will delete the implication that measuring and test equipment (M&TE) are categonzed by Q, AQ, and AQ-NCS Those M&TE which are used on Q, AQ, and AQ NCS equipment are qualified for use on equipment of the highest quality level (i e., Q) and may be used on any of the three categories of safety related equipment (Q, AQ, and AQ-NCS). It also corrects an inconsistency within issue 24 regarding the date for revising the calibration program to meet more formal requirements for AQ SSCs by revising the subject completion date to June 30,1998, and to indicate that detailed calibration procedures are developed to control M&TE as well as the Q, AQ NCS, and other AQ SSCs The revised completion date matenes dates given elsewhere in Issue 24 for upgrading the work control process and preventive maintenance program for other AQ items, and also matches the Paducah Gaseous Diffusion Plant commitment dates foi similar work, None of the proposed changes affect the associated Justification for Continued Operation, which will be in effect until the actions are complete.
Therefore, the proposed changes do not represent an overall decrease in the efTectiveness of the plant's safety, safeguards, or security programs.
2 No Significant Change to Ane Conditions to the Certificate of Compliance.
No aspect of the Certificate of Compliance (COC) is affected by these changes Therefore, no significant change to any conditions to the COC will result.
- 3. No Sienificant Change to Any Condition of the Anoroved Compliance Plan, The proposed changes do involve changes to the approved Compliance Plan, but as discussed in item 1 above they are required for consistency in completion dates, to clarify that M&TE are not classified as Q, AQ-NCS, or AQ, and to indicate that detailed calibration procedures will be developed to control M&TE as well as the SSCs None of the proposed changes affect the associated Justification for Continued Operation, which will be in effect until the actions are complete. Therefore, the proposed changes are not significant with respect to safety or to meeting the Compliance Plan schedules previously established, and do not represent a significant change to any condition of the approved Compliance Plan.
.e* O-a
- < a Enclosure 3 GDP 97-0180.
Page 2 of 3
. 4; No Significant Irierease in the Probability 'of Occurrence of Conscauences of Previousiv-Evaluated Accidents-The proposed changes are required for consistency in completion dates; to clarify that M&TE ,
are not classified as Q, AQ-NCS, or AQ, and to indicate that detailed calibration procedures will be developed to control M&TE as well as the SSCs. None of the proposed changes affect the associated Justification for Continued Operation, nor do they have any affect on the probability of occurrence of accidents previously evaluated. Therefore, the proposed changes do not represent any increase in the probability of occurrence of consequences of previously evaluated accidents. .
5; No New of DitTerent Kind of Accident.
These changes do not introduce any new or different equipment or processes, nor do they '
involve a mod _ification to existing equipment or operations. Therefore, they will not result in the possibility of a new or different kind of accident.
- 6. No Sinnificant Reduction in Maruins of Safety.
As described in item 4 above, the probability and consequences of an accident are not affected.
The factors which comprise the safety margin, the administrative controls and engineered safeguards, are not afTected by these changes None of the proposed changes' affect the associated Justification for Continued Operation, which will be in etTect until the actions are complete. Therefore, the proposed changes do not represent a reduction in any margin of safety.
- 7. No Siunilipant Decrease in the Effectiveness of Any Program or Plan Contained in the Certification Anolication The p60 posed changes have no affect on the programs or plans contained in the Certification Application Therefore, no decrease in the efTectiveness of any of the programs or plans contained in the Cenification Application will result.
- 8. The Proposed ChaDges do not Result in Unjue Risk To 1) Public Health and Safety. 2) Common
. Defense and Security. and 3) the Environment
'All M&TE used on SSCs will be qualified- for use on equipment of the highest quality level (i.e.,
l; L Q).- The proposed changes do not increase the consequence or probability of an accident and, therefore, do not present an undue risk to the public. The proposed changes do not affect any i
- common defense or security operations, therefore, no undue risk to common defense and -l i
security is presented. No undue risk to the environment is presented by the proposed changes because they do not affect accident scenarios or operations that could affect the environment.
No additional environmental risk is presented because the changes have no impact on plant i
ellluents or postulated accidents which might atTect the environment. Therefore, the proposed L
~ - , . - . -- - - - , - _ . . - - . , - _ - - -- - -.
- Enclosure 3 GDP 97-0180 Page 3 of 3 changes do not result in undue risk to the public health and safety, common defense and security, or the emironment.
- 9. No Change in the Tvoes or Significant increase in the Amounts of Anv Efiluents That May Be Ericand_01 hilt Since M&TE which are used on safety related equipment are always maintained for use on equipment of the highest quality level (i c., Q), no afTect on postulated plant accidents would result from the proposed changes The proposed changes do not involve any process which would change or increase ellluents that may be released by the plant. Therefore, there is no change in the types or any increase in the amounts of any ellluents that may be released offsite.
10 No Significant Increase in Individual or Cumulative Occupational Radiation Exoosuit The proposed changes do not modify any process or equipment which would affect radiation exposure to any individual onsite. Therefore, no increase in individual or cumulative occupational radiation exposure would occur Il No Significmit Construction Imnact These changes do not involve construction of any plant structure or system, nor will they afTect any planned or existing construction project Therefore, there is no construction impact.
12 No Significant increase in the Potential for. or Radiolouical or Chemical Consecuences from.
Previousiv Analyred Accidents The proposed changes do not involve any new or modified operation which would increase the potential for an accident or any associated consequences Therefore, these changes will not increase the potential for, or radiological or chemical consequences from, previously analyzed accidents
-_ - . . . .. - . .- . .. - --.. _ .- --.~. .- --
. s
- .;i
- .-1' l Enclosure 4 GDP9.7 0180_ ;
Page1-of1
- NEW/ REVISED COMMITMENTS CONTAINED IN Tills SUDMITTAL
- 1. The measuring and test equipment andprocess equipment calibration programs to meet the more formal requirernents as described in Compliance Plan issue 24.
31,_1996, for Q SSCs menudag =d test completion dates for these actions are December equ:pacat; February 28,1997, for AQ.NCS SSCs menmi % and4est equ:pmca 1998,Dc " '" for other AQ SSCs measu;ing a;,d tc;t equ:pment
'2. -
Individual calibration procedures will be developed for Q, AQ NCS, and other AQ S for Af&lE.
Note. Additions are shown in italics and deletions are shown as strikeout text.
T i
fr 4- -y m-P= +puTv-is gw--ir-g-t-t-- + - e g,. -~ ' . - - g c +. e es.