ML20213A674
| ML20213A674 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2475, NUDOCS 8702030402 | |
| Download: ML20213A674 (22) | |
Text
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12/10/86 isholgs ACRS REGIONAL AND I&E PROGRAMS SilBCOMMITTEE MEETING MINUTES DECEMBER 2, 1986 GLEN ELLYN, IL PURPOSE: The purpose of the meeting is to review activities which are under the control of the NRC Regional Offices. This meeting focused on the activities under the purview of the Region III Office.
ATTENDEES:
Principal meeting attendees included:
ACRS_
NRC - REGION III 0FFICE F. Remick, Chainnan J. Keppler C. Michelson, Member B. Davis D. Ward, Member J. Hind P. Boehnert, Staff C. Paperiello C. Norelius N. Chrissatimos E. Greenman MEETING HIGHLIGHTS, AGREEMENTS AND REQUESTS 1.
Dr. Remick, in opening remarks, expressed appreciation to Mr. J.
Keppler of Region III for hosting the meeting. The Chairman indicated that the ACRS is interested in learning about Region-al/ Licensee operations / interactions. He said the Subcommittee was in a " fact finding" mode and no " hidden agenda" exists for this meeting.
Mr. Keppler welcomed the Subcommittee and indicated that they wish to provide the informaticn desired by the ACRS. He noted that some topics may require follow-on discussion beyond this meeting due, in part, to their potentially controversial nature.
C. Michelson requested that any changes pending from the upcoming reorganization be made known at this meeting. Mr. Keppler said for the short term he doesn't see any major changes in Regional 8702030402 861210 PDR Certified By N'S ANS-
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Reginal and I&E Program Minutes December 2, 1986 i
operations. Over the long term however, he does see change coming.
He expects the reorganization should simplify the way the Regions' do business.
2.
J. Keppler overviewed the Region III workload (Figure I).
Iowa just became an Agreement State (the first for Region III) and Illinois is expected to shortly follow (early 1987).
In response to Dr. Remick, Region III said the Agreement State provisions excludes responsibility for material designated Special Nuclear Material. The responsibility for inspection of low level waste sites can be given to an Agreement State depending upon their preference.
An overview of the Region III organization was described (Figure 2).
In response to D. Ward, J. Keppler confinned that Region III
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has v 250 employees.
In response to Mr. Michelson, Mr. Keppler said the Regions have the responsibility to implement the in-spection program developed by Headquarters. Mr. Keppler also noted that there is one NDE van to share among the five Regional offices.
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3.
B. Davis discussed the Region III onforcement programs. He noted q
that the Region initiates so-called " escalated enforcement actions" (Severity Level III-I). An enforcement Board is convened in the Regional Office to determine what action (if any) should be taken.
An enforcement conference is then held with the Licensee. These conferences are held in closed session.
After a decision is made, formal notice is given to the Licensee.
In response to a question from Mr. Michelson, Region III said the I
Licensee is formally made aware of potential escalated enforcement action at the enforcement conference. Mr. Keppler said the conference gives the Licensee their " day in court" before any action is taken. Mr. Davis said the Region approaches these conferences with an open mind.
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Reginal and I&E Program Minutes December 2, 1986 9
s The recent issue of the use of radios in plant control rooms was discussed. Mr. Keppler noted that Region III issued a Show Cause
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Order removing radios from the Monticello control room.
He said
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the Prairie Island operators (25 of them) have, as a group, f,o r.mally requested a NRC hearing on this issue and the outcome awditsthh.resultsofthehearing. Mr. Keppler said the Coninis-sion itself supports the ban on radios in plant control rooms.
Dr. Remick ir.dicated that this issue is controversial and he appreciates toth sides of the argument. Mr. Keppler indicated NRC 1-was concerned with the fact that Northern States, without notice to NRC, reinstalled the radio at Monticello in spite of the fact the EDO had indicated NRC's displeasure with their use.
(Note:
the 1,.
radio wai reinstalled after a licensee / union arbitration ruling on t'he mattse.') The Agency viewed this as a set back to the move toward Industry self regulation.
Dr. Remick took exception here indirating that if a licensee was not violating the Law, regulations'or?a. direct written order, they have a right to differ N
with the NRC.
4' J. Hind overviewed the Regional activity in the areas of NMSS, emergency planning and preparedness and safeguards. Since 1983, the Region has been given responsibility for safeguards type reviews and/or modifications.
In response to Mr. Michelson, Mr.
Hind said any significant change to a plant's security effective-
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' ness would iscobably be reviewed at the Headquarters level. This decision on review is usually made on an informal level between Headquaturs and the Region. NRR and NMSS closely monitor the Region's~ actions in their respective areas of interest in security and safeguards. Since 1984, the Materials Licensees have been under the responsibility of the Regions. Over 2000 license actions Were accomplished by Region III related to these Licensees so far this year.
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Reginal and I&E Program Minutes December 2, 1986 In response to Mr. Michelson, Mr. Hind said no enriched material (other than source material) can go under agreement State purview.
Further discussion brought out the fact that a Licensee can be under both Federal and State control depending on the Material and/or processes involved.
In response to Mr. Michelson, Mr. Hind said NRC has a Master Emergency Plan which specifically defines Headquarters / Regional responsibilities given a major plant accident. The Plan encompass-es other Federal / State Agencies depending on the need. The Region is a key player in this Plan. Mr. Davis said a full-scale (Feder-al/ State / Licensee) exercise is planned at Zion in a few weeks. Mr.
Keppler said the Chernobyl lessons learned activities may impact the Agency's emergency planning activities, depending on what is concluded here. Mr. Paperiello said the Agency is prepared to deal with beyond-DBA events.
Mr. Michelson asked about concerns with the potential impact of State PUC's on nuclear plant safety. Mr. Keppler indicated this is an evolving issue of which the Agency and Region are taking in-l creasing note. He said this is potentially a two-edged sword l
vis-a-vis safety. This issue is part of the broader Federal / State cooperation concern.
5.
C. Paperiello overviewed the reactor / operator licensing Program.
Figure 3 details this Program. Mr. Paperiello emphasized that the purpose of this Program is to verify the quality of the Licensees' operator requalification program, not to verify the individual operators' licenses. The Region's requalification Program is audited by NRR twice a year.
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Reginal and I&E Program Minutes December 2, 1986 In response to Mr. Remick, Mr. Paperiello said the Agency is moving towards performance-based operator exams, partially in response to criticism from Licensees. The Region holds a meeting with each Licensee prior to giving the exams in order to assure everyone understands the scope and intent of the exams. Mr. Keppler noted most Licensees don't like the requalification Program, but the situation seems to be improving as the exams are being modified.
Fur +.her discussion noted that operators are concerned that their jobs are jeopardized by these exams.
The Region cited a case with a particular License's plant where the exam failure rate was very high ( N 42%).
It was discovered that the Licensee had failed to correct known deficiencies in their training Program. This has since been turned around by pressure from the Region.
Further discussion noted that there is a (not unexpected) knowledge retention problem with operators being asked to test on emergency and off normal procedures that they never deal with in day-to-day plant operations. Mr. Remick said the situation should improve, given the revisions planned to the regulations governing these examinations (10 CFR 55 Appendix A).
In response to Mr. Ward, Mr. Paperiello said he doesn't have a j
problem with licensing people who don't normally stand watches (i.e., managers, supervisors,etc.). Mr. Ward felt it is counter-productive to have these people in the requalification loop. The l
Region indicated that it appears to be useful in keeping those people "close" to plant operations. Dr. Remick felt that it is worthwhile for these people to be tested. Region III said that new l
regulations will require these people to stand watch for a certain l
number of hours per quarter.
I Reginal and I&E Program Minutes December 2, 1986 Details of Region III's licensing actions are given in Figure 4.
The plant licensing amendment work is due to be picked up by NRR in the future. Mr. Keppler indicated that the Regionalization effort in this area has not been efficient and has been so recognized by Headquarters. The Region's safeguards and NMSS licensing actions activities have worked well, due to the day-to-day Region / licensee contact.
6.
J. Hind discussed the Region III activities vis-a-vis the SALP (Systematic Assessment of Licensee Performance) Program. He de-scribed the details of the initial round of SALP reviews held in the 1980-81 time frame. The initially poor SALP ratings for certain plants in Region III (Zimmer, Marble Hill and Midland) have since been confirmed by events.
Changes have been made to the initial program, among these is that the SALP Board meetings are now open to the public. Training and Qualification Effectiveness has now been elevated to a separate Function Group. Figures 5-8 provide details on the Program. The ratings are assigned by the SALP Review Board - the Staff does not make recommendations regarding the ratings to be assigned. Licen-see response is required for declining (ex: "2" to "3") or a "3-level" Function Group rating.
1 In response to Dr. Remick, Mr. Keppler said that at the SALP Board meetings the licensee is usually represented at the top management level (CEO, VP, etc.).
In response to Mr. Ward, Mr. Keppler said that for a "close call" between a "2" or "3" rating, he will reflect on the overall performance of the licensee before giving his opinion.
(Note: Mr. Keppler is rot a voting member of the Board.)
Reginal and I&E Program Minutes December 2, 1986 Additional discussion noted the following points:
Mr. Keppler said SALP has become one of the most important programs of the NRC.
It has the rapt attention of the licens-ees' top management and the financial community (i.e., Wall Street tracks the results of each plant's SALP review).
Mr. Ward asked how SALP will improve the NRC regulatory Program. Mr. Hind said SALP gives discipline to NRRs monitor-ing of plant operations and points to areas where improvements are needed.
It also helps focus the NRC inspectors' efforts as well as the attention of the licensee's management. Mr.
Keppler said some plants have had inspections cancelled due to a record of continuous outstanding performance. This is seen as a positive incentive to enhancing licensee performance.
Manpower allocations for plant inspections now closely track the SALP ratings.
Dr. Remick asked about variations in Regional policy. Mr.
Keppler acknowledged the problem and said the ED0 is address-4 ing this, partly through periodic meetings with Headquarters /
Regional management.
Mr. Keppler offered a personal opinion that the NRC tends to
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grade "too high" on SALP ratings.
Mr. Michelson asked how the Region protects against the potential problem of a good plant " backsliding" and escaping detection because of reduced inspection efforts. Mr. Keppler said each plant's performance is reviewed each month and trends are monitored via LER's, etc. The Master Inspection plan for each plant is " fine tuned" based on this result. The RI's (Resident Inspectors) also are consulted. Daily k
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Reginal and I&E Program Minutes December 2, 1986 Significant Event reports are also " trended" for the plants.
-In any respect, all plants are inspected from time-to-time via a team Inspection from the Region. Dr. Remick noted that INP0 plant reports are also available (only to the RI at the site).
The Region said that by-and-large INP0 and NRC converge on the same problem areas, although there have been a few exceptions (i.e., INP0 has hit a plant harder in a particular area than NRC had).
In response to Mr. Ward, Mr. Keppler indicated that there is a broad spectrum of performance among the plants in the U.S.
(very good to poor). He also said that the Commission is targeting resources to the problem plants and that the Agency has to be proactive vis-a-vis spotting problem plants. Region III indicated that the big differences they see between good and bad performers are usually related to non-tangibles (ex:
management accountability, etc.). Such non-tangibles are outside the scope of regulation.
7.
The Performance Indicator (PI) program was reviewed by J.
Paperiello. PI's are seen as an indication of a change (good or bad) in plant performance. PI's should help address the problem of non-uniformity in Regional operations.
Plants will be compared on a national basis of performance. Mr. Paperiello cited the PI data for Duane Arnold which indicated a problem with the performance of the HPCI system (Figure 8A). As a result of this, the Region plans a team inspection in January to focus on this issue.
Mr. Ward asked a number of questions on the details of the specific indicators used in the PI program (Figure 9). He asked if the Region believes the PI's can be manipulated (or rigged). Mr.
Paperiello said the indicators were chosen partially with this concern in mind; however no system is perfect. Mr. Keppler said
Reginal and I&E Program Minutes December 2, 1986 however that he doesn't intend to let licensees " play games" here.
Mr. Keppler also said the PI's to date generally support the Agency's feeling of which plants are the better and which are the poorer performers.
In response to Dr. Remick, Mr. Paperiello said that the Regions have for a long time, had a set of unofficial PI's; he indicated that the Agency needs a system to track plant performance. Mr.
Keppler said however that the Chairman has made it clear that there will be only one set of PIs used by the Agency from now on.
In response to a question from Dr. Remick, Mr. Keppler indicated that recent events at certain plants (Davis Besse, TVA, Rancho Seco) have convinced him that the NRC Staff is being held account-able for these problems.
The Commission has indicated that these types of problems must be headed off "up front". He, therefore, feels a responsibility (based on what he sees as Comission direc-tion) to take direct action vis-a-vis assuring safe plant opera-tion.
Dr. Remick asked if the Region believes a maintenance indicator is needed. Mr. Keppler said he feels one is needed and that other PI's will be needed as the program matures.
In response to Mr.
Michelson, Mr. Paperiello said the Staff intends to "try out" new indicators to test their ultimate usefulness.
8.
J. Keppler discussed the impacts of Regional operations on licens-ees.
Positive impacts noted included:
(1) improvements in licens-ee performance, (2) enhanced public perception, (3) timelier notification and assessment of events, and (4) enhanced communica-tion between Licensees and Headquarters. Examples of plants with improved operations that were cited included Duane Arnold and Byron. Negative impacts cited were:
(1)anadversarial
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Reginal and I&E Program Minutes December 2, 1986 atmosphere, (2) the regulatory process is resource intensive and demotivating to good performers, and (3) there exists a stressful environmentintheworkplace(ex:
reactoroperators,etc.).
In response to a question from Dr. Remick, Mr. Keppler said there are cases of licensees (e.g., Point Beach) where their SALP ratings are excellent but they tend to take an adversarial relationship with the Region. This has impacted the Region's decision on backing off on inspections for this Licensee. Mr. Keppler said he does encourage licensees to " stand-up" for their rights when they feel the Region or Agency is in error on a given issue.
Regarding the fitness for duty issue, Mr. Keppler said he didn't see how NRC could ask less of its employees than it asks of licens-ees (ex: urine testing, etc.). The Region intends to inspect for the effectiveness of the fitness for duty programs. Mr. Michelson asked if INP0 inspectors are subject to fitness for duty require-ments. There was no ready answer to the question. NRC regulations require that licensee contractors are subject to these require-ments.
I 9.
B. Davis discussed the issue of prescriptive versus performance based regulatory requirements. He said that this issue has been discussed within the Staff, but the Region believes a thorough study and Commission Policy Paper is needed.
In general, a mix of both regulatory approaches appears desirable. The Region's rec-ommendation was that performance-based regulations be given a test on a trial basis. This test should be:
(1) with regulations l
pertaining to areas of lesser safety significance, (2) conducted by a few licensees (considered better performers), and (3) followed closely by detailed inspection programs. Mr. Davis said the pitfalls associated with performance-based regulations include:
the need for clear pidelines on their interpretation, a need for increased NRC Staff expertise, and the increased potential for
Reginal and I&E Program Minutes December 2, 1986 NRC/ licensee nonuniformity in the areas of performance, inspection, regulatory enforcement, etc.
Mr. Remick indicated that Part 20 is somewhat performance-based.
The Region agreed but said its goals are strictly layed out. Dr.
Remick said that highly prescriptive regulations (e.g., QA require-ments) haven't shown that this approach results in an increase in safety. Mr. Davis said that prescriptive regulations are preferred (i.e.,they'reeasiertoimplement). Mr. Ward noted that this is a complex issue and indicated that careful thought is needed by all involved vis-a-vis any policy change.
It was noted in further discussion that the Region's experience in the material licensee area has shown that the Licensees guided by prescriptive regulations (ex: well loggers) show fewer problems than for those who tend to make their own interpretations of the requirements (i.e., a form of performance-type regulation).
10.
C. Norelius reviewed the LWR inspection program. He noted that there is a set of Modules (procedures) to guide an inspector's activities. However, M 20% of the inspector's time is expected to be devoted to random (" follow-your-nose") type inspection. The RI's also spend N20% of their time on back shift or weekend activities.
In response to questions from Mr. Michelson, Mr.
I Chrissotimos said the inspection program is, by necessity, a sampling-type program.
A Master Inspection Plan is developed for each plant based on:
(1) l I&E program requirements, (2) resources, and (3) SALP results. The l
Plan is continually updated to reflect performance trends. Exam-ples of a MI plan for a good performer (Kewaunee) and a less stellar plant (LaSalle) were shown. Each single unit plant has at least one RI; each dual-unit plant site has at least two RI's.
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7 Reginal and I&E Program Minutes December 2, 1986 In response to Mr. Michelson, Mr. Norelius said RI " capture" (objectivity) is a concern and the Region monitors for this prob-lem-mostly through person-to-person contact with the Region Office representatives. The Region also talks to the licensees as well.
RI's are normally rotated at five' year intervals. There are quarterly RI/ Region Office meetings for exchange of ideas / concerns among the RI's.
11.
In closing, Dr. Remick said he found this meeting very informative.
The information presented was on a first hand basis unlike much of what is obtained in a meeting at Headquarters. He said that the discussion was very candid as well and thanked the Region for this.
Mr. Keppler said he enjoyed the exchange and volunteered to follow-up on any questions we may have in the future.
Dr. Remick noted a set of questions from G. Reed for Region III response. He said discussion of these items would be postponed to a later meeting due to a lack of time.
- 12. The meeting was adjourned at 3:00 p.m.
NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 1717 H Street, N.W., Washington, D.C., or can be purchased l
from ACE-Federal Reporters, 444 North Capitol Street, Washington, DC 20001, (202) 347-3700.
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REGION III LICENSEES 28 Licensed to Operate 1
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REGION Ill OPERATOR LICENSE PROGRAM I.
INITIAL AND REPLACEENT LICENSES RESPONSE TO ANNUAL GENERIC LETTER FOR POWER REACTORS RESEARCH REACTOR REQUESTS FORf%L APPLICATION SUBMITTAL AT LEASE 30 DAYS IN ADVANCE 331 IN FY 86 256 SCHEDULED FOR FY 87 II, REQUAllFICATION PROGRAM EVALUATION 10 CFR 55 APPENDIX A NUREG 1021 {e.Vw:mnnw srnos.)
20% OF STAFF AT 50% OF FACILITIES PER YEAR 120 PEk YEAR AVERAGE 25 IN FY 86 - 120 IN FY 87 III. STAFF RESOURCES CURREfGLY 6 CERTIFIED EXAMINERS INCLUDING SECTION CHIEF NRC/ CONTRACT SPLIT OF 46/54 IN FY 86 9 NEw EXAMINERS TO CERTIFY BETWEEN PARCH no JUNE 1987 FOST ExnilNERS FORMER SR0/ TRAINERS l
IV. RESULTS 81% FOR ALL EX/MS IN REGION Ill FY 86 NATIONAL PAST RATE OF 80%
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E EGION III OPERATING EACTOR LICENSING ACTIONS 1.
SELECTED LICENSING ACTIONS TRANSFERRED TO EGIONS SALEM ATWS GENERIC LETTER 83-28 ITU1S ISI AND IST PROGRAM RELIEF EQUESTS CONTROL ROOM DESIGN REVIEW ITEMS MISCELLANEOUS TECHNICAL SPECIFICATIONS AENDMENTS
- 11. STATUS SINCE IMPLEENTATION IN FY '83 EGION 111 HAS COMPLETED 282 LI&NSING ACTIONS 6134 VANHOURS EXPENDED = 21.75 MANHOURS / ACTION t
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OBJECTIVES OF SALP PROGRAM A.
TO IMPROVE THE NRC REGULATORY PROGRAM, B.
TO PERMIT SOUND DECISIONS REGARDING NRC RESOURCE ALLOCATIONS.
C.
TO IMPROVE LICENSEE PERFORMANCE.
D.
TO COLLECT, THROUGH AN INTEGRATED NRC STAFF EFFORT, AVAILABLE OBSERVATIONS ON A PERIODIC BASIS AND EVALUATE LICENSEE PERFORMANCE BASED ON THESE OBSERVATIONS.
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SALP FUNCTIONAL AREAS a.
Operating Phase Reactors 1.4 Plant Operations 2.
Radiological Controls 3.
Maintenance 4.
Surveillance 5.
Fire Protection 6.
Security I
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Outages 9.
Quality Programs and Administrative Controls Affecting Quality 10.
Licensing Activities 11.
Training and Qualification Effectiveness 12.
Others(AsNeeded)
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SALP FUNCTIONAL AREAS b.
Construction Phase Reactors 1.'
Soils and Foundations 2.
Containment, Safety Related Structures, and Major Steel Supports 3.
Piping Systems and Supports 4.
Safety Related Components - Mechanical 5.
Auxiliary Systems 6.
Electrical Equipment and Cables 7.
Instrumentation 8.
Quality Programs and Administrative Controls Affecting Quality 9.
Licensing Activities
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Others (As needed)
SALP BOARD
- CHAIRMAN, DIRECTOR, DRSS
- DIRECTOR, DRS (Ist ALTERNATE CHAIRMAN)
- DIRECTOR, DRP (2nd ALTERNATE CHAIRMAN)
- SENIOR RESIDENT INSPECTOR (SRI)
- DRP REACTOR PROJECTS BRANCH CHIEF
- NRR PROJECT MANAGER
- NRR MANAGEMENT REPRESENTATIVE DRP SECTION CHIEF CHIEF, TECHNICAL SUPPORT STAFF DRP PROJECT INSPECTOR DRS AND DRSS REPRESENTATIVES AS DESIGNATED BY THE CHAIRMAN REGIONAL ADMINISTRATOR'S OFFICE REPRESENTATIVE (0BSERVER)
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(neasured in Stenderd Oevlettens
r PERFORMANCE INDICATORS PURPOSE:
DIRECT NRC VANAGEEta ATTENTION VALUE:
tbRE FREQUEta UPDATE THAN SALP COMPARE PLANTS ON NATIONAL BASIS ATTRIBUTES:
NUCLEAR SAFETY RELATED AVAILABLE TIE LY DATA NOT SUSCEPTIBLE TO PANIPULATION COMPARABLE BETWEEN LICENSEES WORTHY GOALS DYtudilC RANGE ltOEPENDENT OF EACH OTHER LEADING ltOICATORS SHOULD CORRELATE WITH SALP INDICATOR SET:
SCRAMS SAFETY SYSTEM ACTUATIONS i
SIGNIFICAta EVEfRS SAFETY SYSTEM FAILURES FORCED OUTAGE RATE ENFORCEE NT ACTION ItOEX EQUIPE NT FORCED UTAGES PDDE OF PRESENTATION:
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